Lets see, the claim is public safety does not use its spectrum efficiently. PS has never had a block of contigous spectrum to start with so there is little comparison. PS can simultaneously at any given instant connect 100, 200, even 500 subscribers in a confined area using a single 12.5 kHz channel. Not even the combined power of all the carriers anywhere could begin to come close to that efficiency using thier "tehcnology". If you know how to analyze the FCC granted license database, 80% of active PS use across the entire US is handled with 7.3 Mhz of spectrum. Sounds pretty efficient to me!

I attended the hearing and was pleased to see the engagement of the Senators in attendance. They asked very tough questions focused on the risk of re-opening the DTV legislation and putting off the granting of 24MHz of prime spectrum to public safety as well as the $1 Billion scheduled to be spent on interoperability grants by the Department of Commerce this year.

Larry Irving and I both served as Assistant Secretary of Commerce for Information and Information (Larry for President Clinton and me for President George W. Bush) and we both recently published a white paper on the right path to achieve interoperability (http://www.perkinscoie.com/content/ren/updates/tc/gallagher.pdf) and an editorial on the same subject (http://news.com.com/If+catastrophe+strikes+tomorrow%2C+are+we+ready/2010-1033_3-6156878.html).

The key points were echoed by Senators at the hearing. We must not waste the 24 MHz of prime spectrum currently designated for public safety. That spectrum should be for 21st century technologies and interoperable systems only. And, all funding going forward should only fund the same type of systems. Public safety deserves the best, future-focused technology, not more of the same systems that are the root of the problem.

Our plan should be particularly attractive because it is not hard to explain, is achievable starting this year, and doesn't incur the risk or delay of new legislation.

The spectrum use counts being stated by members of the commercial side of the industry distort the reality of the use of spectrum by public safety. The "Right Call" paper and the more recent CTIA whitepaper both quote base line figures that include broadband spectrum at 4.9 GHz that has only recently been made available with a similar case for the 24 MHz at 700 MHz. Neither should be considered in any assessment until there is an opportunity for public safety to implement in those bands. Public safety has not yet had an opportunity to deploy the 4.9 GHz and 700 MHz spectrum so it is rather awkward to include such spectrum in any comparison. A reciprocal case could be made, there is additional spectrum used by the commercial industry to provide communications. (Satellites, satellite radio and TV broadcast could be reasonably included as well). So much for truth in advertising.

In reality, 80 % of current licensed mobile operations in public safety take place in less than 8 MHz of operational bandwidth; covering the entire United States.

If there is any real public safety spectrum inefficiency, it comes from the time/spatial element of non-use of existing channels, but that is understandable based on the legacy element of the spectrum below 700 MHz and is further qualified by the very critical nature of the operational requirements of public safety. There has been no technology available to enable PS to better use this spectrum, so they do the best with what they have. It is not “green space”, nor is it readily “refarmable” or restructurable with standard current technology. SDR/cognitive technology provides some hope, but is as yet unproven and public safety is not the place to do the proving.

Public safety, frankly, does not have the “pull” (including funding) to drive the development of a technology that includes the special features that are critical to public safety. Public safety WILL need, and use, the support of commercial developments, both hardware and systems. Public safety WILL need to have critical service capability to provide advanced data-centric capability. So far, it is doubtful that any commercial carrier is prepared to support those needs. That is why many in the public safety community are so adamant in demanding control of their own spectrum. What other leverage does public safety have?

If the commercial industry is to consider providing service for public safety there are a few critical capabilities that public safety does, inarguably, require. Issues such as coverage, capacity, and physical plant robustness are the easy ones. The nature of operations within public safety absolutely demands the capability to “talk around” the infrastructure for cases where the infrastructure is either not resident or is destroyed. Hurricane Katrina clearly pointed out the later requirement. Restoration of the infrastructure even 10 minutes after failure is unacceptable when safety of life is critical in the mean time.

Lets talk about how we can develop subscriber equipment that can communicate one to one and one to many directly; preferably in an IP based addressable manner with NO infrastructure with a multi-mile (open environment) capability. Lets talk about the ability to provide a single communications path that can provide true broadcast to as many subscriber units as may be in range and authorized to receive. (Even iDen PTT requires an individual channel resource for each subscriber.) These two features are absolutely core to basic public safety communications.

Are the commercial carriers ready to step up to the plate and provide the requirements of public safety? Or are we just hearing platitudes intended to distract the regulators and legislators? The legislators and regulators could step up to the plate and force the issue, but it would be better if the industry worked together, with each other and public safety. Even if they would, it still requires significant change in any funding mechnisms that can only be enacted through political/legislative action.

The commercial mobile industry owes its very existence to the work and development originated by public safety stemming from the development cycle of the original FM land mobile radios. The commercial industry only moved ahead (abandoning public safety) when the commercial case for “wireless” became a reality. Its time to pay it back.