FCC REPORT ON FUTURE SPECTRUM NEEDS FOR PUBLIC SAFETY By - Joe Fedele PLANNING FOR THE FUTURE When it comes to planning for the future many of us need all the help we can get. And your business is no different than that of the Federal Communications Commission. Between changes in technology and the competitive market place there are many pitfalls that must be side stepped. The FCC makes policies and changes based on the same market forces that many businesses face. To that end, the FCC released a report on February 9th entitled "Meeting State and Local Government Public Safety Agency Spectrum Needs Through The Year 2010". This fifty page report touches on all public safety issues from spectrum requirements to regulatory options. The objective of the Commission's study was to access the current and future spectrum needs of public safety agencies. The information contained in it are the basis for the Commission's plan to ensure that the spectrum requirements of public safety agencies are met through the year 2010. Because governmental and public safety agencies account for such a large portion of the paging, data and communications business it is imperative that you remain current on what the FCC's vision of the future is. And, although public safety agencies typically maintain their own communications systems, future needs may require that they turn to commercial services in order to accommodate industry growth. The Commission studied several issues of concern to many private and commercial spectrum users. The following is a summation of some of the key issues and how the FCC hopes to deal with them in the years to come. PUBLIC SAFETY NEEDS The report separates public safety requirements into two general categories. The first is conventional, narrow bandwidth, one-way and two-way voice and data communications. The second is advanced applications that transmit full motion video and high resolution images. Examples of this are mug shots and fingerprints used in law enforcement. These high-speed data transmissions require wider spectrum bands. In order to facilitate these requirements more spectrum is needed. It is estimated that 6 Mhz of bandwidth is needed for nationwide use and 12 Mhz for use in metropolitan areas. Some new wideband services could need a minimum of 25 Mhz of band space by the end of the decade and an added 50 Mhz by the year 2010. This brings the total to 75 Mhz. It is estimated that spectrum utilization in the 450 Mhz and 800 Mhz bands will double the the year 2010. Transit will require more than double the amount of spectrum it has today.These assumptions are based on projections that "transit communications operators will continue to take advantage of spectrum conservation measures". The report mentions spread spectrum, trunking, and emerging "spectrum efficient communication protocols" as possible solutions to meeting these needs. The spectrum projections were based on population growth, increased mobility, increased crime, suburbanization and population aging. Intelligent transportation systems or "smart bus" technologies would add to this demand for more band space. Estimates predict that almost half of the growth in channel demand could be satisfied by refarming, trunking, and the GPS Automatic Vehicle Location service. An entire generation of new technologies is envisioned for use by the public safety services. Some of these services include high-speed, high density data transmissions used by law enforcement that allow for fully remote capabilities. This would give police the freedom to operate outside of the station while still having access to all necessary information. More and more law enforcement is reliant on laptop and portable computer systems to relay information such as crime reports and fingerprint data. All these types of data transmission require a large amount of band space that must somehow be accounted for. THE PLAN Because the FCC is the primary agency charged with regulating the air waves it is their responsibility to "attempt to strike the appropriate balance between the wireless communications needs of the public safety community and recognition of the scarcity of the radio spectrum." The commission has proposed a two part plan to deal with these issues. The first part would initiate a data collection proceeding that would enable the FCC to gather information regarding the spectrum needs. The next step would be to ensure that public safety spectrum is used efficiently and that public safety wireless communications needs are satisfied. To that end the Commission proposes to establish an Office of Public Safety. Its purpose would be to accumulate and organize information for the FCC. Recently the Wireless Telecommunications Bureau appointed a Public Safety Liaison Officer. The Liaison Officer will "solicit informal comments on potential improvements to the public safety communications licensing process, such as allowing frequency coordinators or regional planners to take over the responsibility of assigning frequencies to the public safety agencies." The Commission has even suggested setting up an advisory committee to oversee the public safety licensing. UNANSWERED QUESTIONS The FCC needs to answer two basic questions before new spectrum allocations become reality. The first is, where do you find the spectrum to satisfy the need? And, second, how will the cost of these changes be paid for. Even the commission is perplexed on these matters. They state,"The difficulty we have had in defining state and local public safety agencies spectrum needs has convinced us of the need to create a mechanism to identify and collect data relevant for such a determination." So the commission is proposing to issue a separate notice in the near future the would request feedback from public safety licensees regarding the use of existing spectrum and current or future plans to enhance spectrum efficiency. They would also attempt to solicit information about anticipated wireless communications demands through the year 2010. With regard to voice communications, a determination must be made regarding the specific geographic area where wireless communications systems are needed. The commission must, "identify those other agencies with whom they need to communicate, and evaluate the feasibility of establishing and sharing a multi-agency wireless communications system." Other unanswered questions concern the need to differentiate between "existing voice and relatively slow-rate data communication and needs for services such as high-speed data and full-motion video." The commission will need to investigate how these answers are derived. Public safety agencies will be asked to provide estimates of future spectrum requirements that are based on indicators such as projected population growth, the crime rate, and their ability to pay for such changes. They will then be required to balance the cost of implementation of more efficient technologies against obtaining more spectrum. Regarding this report the commission states that, "the data collected from this portion of the Notice should help us identify not only how much spectrum may be needed, but also the most desirable frequency band or bands. It should also provide enough information to enable us to determine whether another nationwide allocation is needed or whether spectrum needs are more localized in specific highly congested geographic areas." The industry is relying on emerging technologies to expand wireless capacity. But, in order for this to work, public safety agencies would have to spend a considerable amount of money to move into these new arenas. Whether or not these agencies are prepared to shell out the kind of capital needed for these changes is another question in itself. In my opinion, the cost of lease vs. purchase may cause some agencies to look to commercial vendors to supply those needs creating added opportunities for the marketplace. The FCC is convinced that public safety communications needs are increasing. But a significant portion of it is primary reliance on radio systems owned and operated by each agency. The commission notes that "commercial systems, such as cellular and PCS systems, may be useful for routine administrative communications, but are of little value for most public safety emergency communications because public safety agencies have critical needs for reliability, immediate response, universal coverage, signal quality and encryption." This would lead you to believe that if commercial vendors want a bigger piece of the pie they will have to improve on all of these areas and then prove their case to an already skeptical industry. The commission clearly states that they "are not convinced that the only way to achieve this access is on systems individually owned and operated by individual public safety agencies." They also cite that, "there have been a number of cases where communities have maximized efficiency and minimized expenses by joining with other nearby communities to create a shared communications system." "Commercial services", the report states, "can accommodate the special needs of public safety services through various software applications. Mobile satellite services provide commercially available wireless communications systems for safety of life and property operations." "In this example, technology has provided at least part of the answer to the problem of obtaining ready access to a communications system in emergency situations. Inmarsat uses priority signalling for distress and safety communications in the maritime services while American Mobile Satellite Corporation (AMSC) has proposed dynamic frequency pooling to ensure availability to high priority users. These systems also provide privacy through encryption. The same smart technology used in the satellite services could be explored for use in the terrestrial services." The report mentions that a community owned trunked communications system is another way that agencies could eliminate inefficiently owned and operated systems. But notes that commercially available wireless trunked radio system can offer priority access through the use of sophisticated computer controls. "This allows safety of life and property transmissions to preempt non-emergency administrative transmissions, that public safety agencies want and need. With trunking, a single radio system shared by several agencies provides each agency with communications service virtually equivalent to having its own communications system. Shared trunked communications integrates dispatch, secure voice, data and telephone interconnect functions and coordinates communications among the sharing agencies." "In fact, this single capability of trunked systems is probably largely responsible for the big increase in the use of trunked systems by public safety agencies in recent years. The Orleans County, New York, system, which serves the Orleans County Sheriff, the New York State Police, three town police departments, 14 town highway departments, and other public service departments, such as mental health, public health, and emergency preparedness has implemented trunking. Other municipalities that have implemented trunking include Martin County, Florida, the City and County of Honolulu, Hawaii, and the City of Oakland, California. This same type of capability would enable public safety agencies to obtain priority access using commercial systems like SMRs, cellular, or PCS." Like state and local governments, federal agencies face comparable problems in meeting their needs of band space. Likewise, they are limited with very tight capital expenditure budgets. Consequently they too are taking a serious look at commercially available technologies. All of these factors could force many public safety agencies that traditionally operate their own communications systems to turn to SMR's for advanced services. The Omnibus Budget Reconciliation Act of 1993 mandates that "a plan for Federal agencies with existing mobile radio systems to use more spectrum-efficient technologies that are at least as spectrum efficient and cost-effective as readily available commercial mobile radio systems." But, again, the commission is short on information. "We conclude that more information is needed in order for us to determine whether additional spectrum allocations are necessary to satisfy the conventional voice and relatively low-speed data wireless communications requirements of public safety agencies. It is because of the serious dimensions of this assessment that we have decided to defer any definitive determination of the spectrum needs of state and local public safety agencies until we have collected more complete data." This shortage of hard facts will lead to yet another study. The Commission hopes to find alternative, spectrum efficient, systems for state and local agencies operating under tight financial restraints. "We also acknowledge, however, that some of these options involve expenditures that many state and local governments may find difficult to afford." ECONOMIC OPTIONS The Commission looked at several economics options including the use of commercial service providers, exclusivity to foster economic incentives, and leasing of excess band space. The recent sale of spectrum for PCS made the folks at the budget office salivate as huge sums of money were taken in through the bidding process. The government is obviously looking at ways to increase federal revenues without raising more taxes. Due to such factors as the state of the economy and the budget deficit the Commission now views the allocation of spectrum in a slightly different manner. In the past most licensees did not pay for spectrum. Consequently they did not "experience the full costs associated with using that spectrum." The report continues, "If a licensee has a choice between spending $1 million for a new radio system or $2 million for a system with equivalent features that uses one-third as much spectrum, it clearly would choose the less expensive system as long as it could freely obtain access to the necessary spectrum. The result is that many users may not be motivated to utilize spectrum efficiently." The Commission also views public safety agencies differently than commercial or even private users. The need for immediate channel access to protect life and property, for instance, is given a higher priority that perhaps a private delivery service. They also differentiate between "clearly defined public interest obligations" that "do not seek to maximize profits" and commercial users. Also, public safety users generally face a much longer planning cycle than other users. The report looked at economic incentives that "can be used to encourage state and local public safety agencies to seek more spectrum efficient means of satisfying their growing wireless communications requirements." One option is to utilize commercial services more frequently. Another would allow public safety agencies to lease unused spectrum for wireless services. These options could open up more markets to SMR's. Exclusivity is another option that could create economic incentives. The report states that "licensees of systems of a specified minimum size would be able to apply to the Commission to stop licensing new users on their channels, and thereby create a more stable and predictable operating environment. We anticipate that licensees would then be able to rely on exclusive channel use to make mutually beneficial arrangements with co-channel licensees in their geographic area. These arrangements could include such things as establishing a new radio system that all current licensees could use, or dividing the channel into several smaller channels that could be used on an exclusive basis by each of the current licensees. Our experience with exclusive channel assignments in the 800 and 900 Mhz private land mobile bands and in the Cellular Radio Service suggests that, with the appropriate incentives like exclusive use and technical and operational flexibility, public safety licensees with exclusive channel assignments would be likely to make more intensive use of the increasingly scarce spectrum resources in the bands below 470 Mhz." REGULATORY OPTIONS The Commission is considering several regulatory options that would alleviate spectrum congestion. Those options include the consolidation of smaller services into broader service pools, increased sharing of spectrum and systems among state, local, and Federal public safety agencies, and increased State role in public safety spectrum planning and management. The Federal government may release as yet unspecified band space for use by the private sector and public safety services particularly for the development of new wideband technologies. Several actions now pending before the Commission could greatly influence public safety's use of existing spectrum. Refarming rules, for instance, could greatly increase channel capacity for public safety services. Refarming plans were used to narrow channel bandwidths for channels below 470 Mhz. This encouraged technical flexibility and spectrum efficiency by reducing maximum allowable power levels and antenna heights. Refarming allowed for the migration of users from 25 kHz channel bandwidth to 12.5 kHz, 6.25 kHz and 5 kHz channel bandwidths. The Refarming technique were used in the private land mobile spectrum to increase channel capacity by two or three times previous levels. But refarming rules for public safety remain pending and no final action has been taken. The Commission is now considering a petition originally filed in April of 1992 that would use UHF-TV Channel 16 in New York City for public safety agencies. Several subsequent petitions have been filed since then but no action has yet to be taken as of this writing. TECHNICAL OPTIONS Further developments using digital technologies and digital access techniques and the use of sectored antenna systems are among the technical considerations the FCC is now exploring. The Commission cites that "digital voice systems are rapidly being deployed in mobile services such as SMRs and cellular. Radios that operate on 12.5 kHz channels and use digital technology are becoming available for public safety applications. Two promising digital technologies are currently available, Time Division Multiple Access (TDMA) and Code Division Multiple Access (CDMA). The cellular industry has adopted a standard for each of these technologies and enhanced SMR systems have deployed TDMA systems in several major markets. TDMA is a technology that increases the number of communications channels by dividing each available channel pair into multiple time slots. The TDMA system being used by many cellular licensees splits the 30 kHz channel into three time slots, potentially enabling as many as three users to share the channel at any one time. The TDMA system being implemented by enhanced SMR licensees splits the 25 kHz channel into six time slots, potentially enabling as many as six users to share the channel at any one time. Besides increasing capacity, TDMA has the advantage of allowing complete privacy through digital encryption, as well as facilitating access to advanced digital data services." "CDMA is a technology that employs spread spectrum modulation techniques and coding schemes to permit many separate communications to share a single wideband communications channel. With CDMA, each radio transmission is spread over a large band of spectrum at relatively low power. Each transmission is uniquely coded so that CDMA receivers can extract the correct message. The wider the communications channel the greater the advantages of CDMA in increasing communications capacity. The current cellular CDMA standard specifies a 1.25 megahertz channel scheme. CDMA systems being used in cellular systems have the potential to provide 7 to 10 times the capacity of existing analog systems. CDMA has a theoretical potential to provide up to 20 times the capacity of current analog systems. Both TDMA and CDMA technologies continue to develop and are becoming more robust and reliable. These technologies could be employed to increase the communications capacity of wireless public safety communication systems significantly." "Cellular and enhanced SMR licensees routinely use sectored antenna systems to expand the capacity of their current channels. This technology uses phased antenna arrays to divide the base station coverage area into three independent 120ø sectors or even smaller 60ø sectors. Each sector has an individual dedicated antenna array that receives and transmits communications only within its sector. The overall antenna system is designed to prevent interference and overlap from adjacent sectors. By employing a 120ø sectored antenna system the capacity of the system is increased by a factor of three. Adoption of this technology by public safety licensees could increase the capacity of these systems as well." GOOD NEWS FOR PCS & COMMERCIAL SERVICE PROVIDERS In the report, the Commission presents the use of commercial service providers as a means to "encourage greater use of current and future commercial wireless radio systems by providing commercial operators with incentives to provide public safety agencies with priority access." One proposal would allow for new PCS licensees the option to obtain additional blocks of spectrum, either free or at a significant discount from their true market value, so long as they provide service to public safety agencies. Restrictions on the use of such spectrum may require operators to tailor the service for specific priority access applications. PCS systems are viewed to provide country wide wireless communications services for many public safety agencies through the use of new technology. It is hoped that inexpensive radios could be used in conjunction with existing and sophisticated wireless communications infrastructures that most public safety agencies could not afford to implement on their own. PCS could provide public safety agencies with wide area coverage that existing systems do not offer. OPPORTUNITIES FOR THE ACQUISITION OF MORE SPECTRUM Trying to find more spectrum for private of commercial use has come to be a near impossible task in some areas of the country. One proposal in the report would allow for the leasing of public safety spectrum to other wireless services. This is also seen to be a way to produce revenues for public safety. The report states that, "revenue from leasing could be used to offset the cost of implementing more efficient technology in currently allocated spectrum. Also, by permitting the leasing of public safety spectrum capacity for other uses, any concern about the opportunity cost of additional public safety allocations would be reduced. This, in turn, would reduce the need for detailed spectrum requirements projections and justifications for such allocations." The FCC seems convinced that many of the nation's spectrum needs could be fulfilled through the use of more spectrum efficient technology. In order to speed the process the Commission would "make available a band of vacant spectrum that could be used for such technologies. Such a band would be reserved for public safety licensees that will use technologies that meet or exceed a Commission spectrum efficiency standard. Licensees would be given exclusive rights to use their assigned channel(s) as an incentive to invest in new equipment. The reservation of such a band for innovative technologies should encourage and accelerate the introduction of new, more efficient radio equipment. It should also make it easier for public safety agencies that may be operating under severe spectrum constraints to migrate to the new band under a transition that they themselves determine." Unfortunately there is no such spectrum available that isn't adjacent to or even close to existing public safety bands. But, the report explains, "if there is sufficient interest in this option by the public safety community, the Commission will work to attempt to identify spectrum."