NTIA: Give early public-safety deployments the full 700 MHz allocation

The National Telecommunications and Information Administration (NTIA) wants the FCC to revisit its recent order authorizing early public-safety LTE network deployments on 10 MHz of 700 MHz spectrum and instead open up the full 20 MHz available in that band for public safety.

"NTIA believes that such action would further the critical goal of advancing interoperability as well as mitigating cost concerns associated with the deployment of a nationwide public safety broadband network," wrote Lawrence Strickling, assistant secretary for communications and information, in a letter to FCC Chairman Julius Genachowski.

On July 30, the FCC adopted an order permitting limited deployment of broadband networks for first responders using the existing public safety broadband spectrum allocation of 763-768/793-798 MHz, which is leased out by the Public Safety Spectrum Trust (PSST). Only jurisdictions complying with the commission's Special Temporary Authority (STA) rules will be allowed to use this spectrum for early deployments.

NTIA appears comfortable with the STA rules, which only provide operating authority in six-month increments. But the agency is displeased that the FCC's order does not permit the use of the spectrally adjacent D Block--758-763 MHz/788-793 MHz--which the Middle Class Tax Relief and Job Creation Act of 2012 reallocated to the new First Responder Network (FirstNet) authority under NTIA.

NTIA contends that allowing public-safety agencies to use the entire 10 x 10 MHz of spectrum rather than restricting them to the existing 5x5 allocation would have numerous benefits in terms of network capacity, interoperability, cost savings, timing and lessons learned.

STA deployments of 5 MHz channels "risk failing to interoperate with FirstNet's 10 MHz bandwidth channels," wrote Strickling. He said if the LTE networks require a software or firmware upgrade to conform to 3GPP standards, "individual STA recipients would likely have to recall and reprogram all devices," which would entail extra costs for waiver recipients.

It will be "costly, time-consuming and technically challenging to transition a system based on 5 MHz channels to 10 MHz channels as will be required for compatibility with the new nationwide network," read the letter, adding no vendor has yet demonstrated "a streamlined path for this upgrade that could possibly be managed for efficient network launch."

MissionCritical Communications reported that Public Safety Communications Research staff said during the Association of Public-Safety Communications Officials (APCO) International conference earlier this month that they are upgrading all vendor and laboratory equipment for the public-safety broadband demonstration network to the 10 x 10 MHz channels. "It required all vendors to update to larger systems," said Emil Olbrich, PSCR lead project engineer. "It was not as easy as we expected."

Strickling echoed that point in his letter, stating, "The upgrade process at the Public Safety Communications Research (PSCR) program facilities has proven labor-intensive and lengthy."

Harris County, Texas, which has indicated it will participate in the FCC's STA process to operate the public-safety LTE equipment it deployed, could upgrade its 700 MHz radio equipment to the full 10x10 spectrum allocation via a firmware upgrade, according to MissionCritical Communications. "My understanding of the adjacent spectrum around the 10x10 frequencies is that there is an adequate buffer to mitigate any interoperable issues, and that if there are issues, it would be better to addresses them now in our early deployment," said Robert Cavazos, director of broadband services for Harris County ITC mobility.

Despite NTIA's insistence, it is not clear that the FCC has authority to provide special temporary authority (STA) for D Block operations, since that spectrum technically falls under FirstNet's jurisdiction. According to Urgent Communications, most industry observers "believe that is why the FCC didn't include that spectrum in its recent ruling."

For more:
- see this NTIA letter (PDF)
- see this MissionCritical Communications article
- see this Urgent Communications article

Related articles:
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Feds test public-safety LTE but will cancel 21 700 MHz waivers
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Public-safety LTE plans disrupted by 700 MHz D-Block legislation