D block questions for the FCC and public safety

When two sides of a debate have a large stake in the outcome, it's easy to focus on the theatrics of the disagreement rather than the substance.

Conclusory statements get passed off as argument and the two sides burrow down. This is why I hope the Federal Communications Commission takes this opportunity given by the Public Safety Alliance to answer some assertions that public safety groups make about the D block, the 10 megahertz swath in the 700 MHz band that most public safety organizations want license to, and want badly.

Public safety groups contend that their existing 10 MHz license in the 700 MHz band isn't enough, and without license to the D block, plans for a national interoperable broadband first responder network won't be realized. The FCC, through its National Broadband Plan, proposes auctioning off the D block to the private sector with the condition that first responders gain priority access to the D block during emergencies.

Namely, the Public Safety Alliance contends that:

• The FCC greatly underestimates the current and future capacity needs of public safety when it assumes that 10 MHz of broadband spectrum is adequate.
• FCC assertions that a sufficiently dense infrastructure of transmission towers would offer public safety enough traffic capacity doesn't take into account local, state and federal regulations preventing tower build out.
• The FCC density argument also doesn't factor for potential transmission interference caused by density, as well as increased backhaul, operations and maintenance costs caused by a dense tower infrastructure.
• Priority access to the D block will not give sufficient bandwidth for public safety during emergencies because a privately-controlled D block would already be congested with traffic.

But, in the spirit of both sides debating the substance of matters, can public safety groups that want to prevent the auctioning off of the D block answer a few questions, too?

• How will public safety pay for a 20 MHz national broadband wireless network? It's likely that the money earned during a D block auction would be used to support creation of a public safety network. Public safety officials have characterized the funding issue as a separate problem, to be solved after they get license to the D block. But it's not a separate issue, since the auction holds out the promise of a funded project; questions of execution can't be separated from answers of what's a best solution.
• Also, how will public safety pay for the end user devices of a 20 MHz network? Because the existing 10 MHz public safety license is adjacent to the D block and both will use LTE, end user devices developed by the private sector would drive down costs of public safety devices. Without that incentive in the form of private sector incentive to develop those devices for a large market, how can public safety ensure that even poor and rural counties will be able to afford access to the broadband network?

I can't wait to see the next round of white papers. - Dave