Public safety spectrum, here we go again
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Better late than never, here are my thoughts on the FCC’s auction for the D Block public safety band. There was only one bid for the block, Frontline Wireless to shut down, and some are even suggesting improprieties. Sadly, we’ve got a long way to go before we have an operating public safety network. Why did the D Block auction fail? I think at root the problem is that the FCC simply placed too many restrictions on the would-be licensee, and that’s something the FCC should keep in mind as it considers what to do next.
Under the D Block’s service rules the commercial licensee must come to an agreement with the Public Safety Spectrum Trust (which is the licensee for the adjacent public safety spectrum) about the details of the network to be built. If it doesn’t come to an agreement, the FCC can impose whatever requirements it sees fit on the licensee, and if the licensee surrenders its license or has it taken away, they must pay a forfeiture penalty that can run into the millions. Because there are no similar penalties for the non-profit PSST to come to agreement, this allows the PSST to basically dictate the terms of the network. Why would anyone bid for the privilege to be a part of that deal?
Sadly, Chairman Martin doesn’t seem to get this. He recently lamented the fate of the D Block:
“Did we get everything perfect in it? Obviously not because no one was willing to end up taking on that burden,” Martin conceded. “So, do I wish that someone was willing to take on that burden? Yes. And do we need to restructure it in such a way that someone is willing to take on that burden? Absolutely. But absent somebody else coming up with some idea to solve this, this is the only way to solve what’s really a public-safety crisis.”
Instead of expecting some selfless corporation to “take on the burden” of such a thankless deal, why not try instead to create a license aligned with the interests of both the private sector (profit) and public safety (cheap and interoperable communications solutions)? Here’s my recipe:
- Get rid of the PSST, a bureaucracy more than prone to capture that will do nothing but hold a commercial licensee hostage.
- Take the spectrum now held by the PSST and combine it with the D Block. Create two national licenses on the combined spectrum so as to inject competition and avoid a monopoly provider.
- Place public safety obligations on each of those licenses but allow the licensees to lease excess capacity. What sort of obligations? Obviously public safety should have priority, and leased access would only be secondary. Beyond that, the FCC could include minimum performance standards in the licenses to ensure that the networks are built to public safety standards without having to prescribe specific technologies or methods.
- Auction the licenses without reserve prices.
There are no doubt more than a few hurdles for such a plan to overcome, but I think it makes sense to allow market forces develop public safety networks. I’d love to hear any critiques of this idea. No doubt I’ll be submitting a comment to the inevitable rulemaking on this issue and it would help me to figure out the weaknesses of this scheme.
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This is the personal site of Jerry Brito, a lawyer and writer in Washington, D.C. He’s an academic researcher and the creator of Unclutterer and several other blogs. More »
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6 comments posted
Posted by Al Nowakowski - 04/01/2008
You show a very basic lack of knowledge about what spectrum is involved and why the PSST controls it.
Half of the spectrum to be used for this new system was taken from the 24 MHz of 700 MHz spectrum specifically assigned to public safety. If you remove the PSST, you will have just another commercial system with NO responsibility to serve or meet the requirements of the public safety community. And you will have crippled the future development of any public safety broadband system by giving the spectrum specifically designated for that purpose to a commercial service.
Do your homework!
Posted by Jerry Brito - 04/01/2008
Al, That’s not a very constructive way of engaging in conversation. Just like anyone else, I’m trying to help solve the interoperability problem for the benefit of first responders and all Americans. Different folks have different ways of thinking about things, and I hope you can respect that. This problem is over 30 years old, and if we just think the same way we’ve been thinking and rejecting anything that seems radical out of hand,we might not uncover unexpected solutions.
Yes, I am suggesting two commercial systems (putting the spectrum in the hands of public safety has not previously gotten us anywhere - this is the ‘radical’ part), but I hope you’ll re-read what I wrote and notice that I do account for how to make these commercial companies accountable. First there wold be a public safety obligation with specific performance standards, and second there will be the constraints of the market (i.e. they will want to keep their public safety customers happy and subscribed–especially if there are competing networks). I hope you can give me the benefit of the doubt and engage me on the merits.
Posted by Al Nowakowski - 04/02/2008
I’ll engage you when you show that you understand the actual situation, and who controls what.
Let me quote your piece. “Take the spectrum now held by the PSST and combine it with the D Block.”
The spectrum held by the PSST IS the D block! If you can’t even get the basics right, how can we discuss this?
Sorry if I’m blunt, but I hear a lot of absolute nonsense about this topic and “what ought to be done” from folks who don’t bother to understand the basics of what is going on.
As someone who works closely with public safety agencies, I can appreciate their problems, and what MIGHT be done. As an engineer, I think I can anticipate what actually CAN be done.
Giving every first responder a cell phone is NOT the great solution a lot of people think it is. Ever tried to do a one-to-many call on a cell phone? That’s a fundamental requirement of a dispatch system, and cell phones can’t do it… They might in the future, but then pigs might fly…
Posted by Jerry Brito - 04/03/2008
Al, I have to defend myself from your claim that I don’t know what I’m talking about. Here is the band plan straight from the PSST’s own website:
As you can see, they make a distinction between their public safety holding and the commercial D Block. I’ve also never said I wanted to give first responders a cell phone.
It seems you only want to play semantics and take down straw men rather than address the merits of my proposal. You’re also rude and you’re not helping the cause of public safety interoperability, even if you are an engineer. Please don’t bother posting here again.
Posted by Charles Werner - 04/09/2008
As stated previously, leaving the development of a public safety network in the hands of commercial entities will never happen…if there was interest, it would have already happened. And, having the direct experience of those wouldbe experts, generally have little understanding of public safety needs…from equipment to spectrum needs.
And as stated 1/2 of the 700 MHz spectrum that would be assigned to the PSST is assigned to public safety. The other half is the D block. Please do not demean those that are passionate about what is and has been needed for many years. Just curious, when was the last time that you entered a hazardous environment, a burning building or similar situation. When you live it, know it and understand it, then you will fully appreciate the position of public safety.
Thanks.
Posted by Jerry Brito - 04/10/2008
Chief Werner, I’d like to address two of your points.
First, if it could happen, it would have happened by now. The problem is that it’s impossible for a private company to compete with free, and the current regulatory regime hands out free spectrum to public safety so that they have to build their own networks. We don’t think it’s weird that police departments buy their cars from Ford and GM. The system we have now for spectrum would be the equivalent of giving police departments steel and glass and rubber and asking them build their own cars or use subcontractors to build them.
Second, I don’t see one single thing I’ve said that demeans those passionate about public safety. That said, the idea that only those people who have ever entered a burning building have a right to be engaged in this conversation is ill-advised. We need as many people as we can thinking about this issue. Those who have been passionate about public safety have been thinking and working on the problem for 30+ years. Maybe it’s time to let in some ideas from other fields.
Cheers.
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