New York City last week asked the FCC for permission to construct a 700 MHz public-safety broadband network on spectrum currently held by the Public Safety Spectrum Trust (PSST) while promising that the network would comply with national interoperability standards for an envisioned national first-responder broadband network.

In the waiver request to use the PSST's 10 MHz of spectrum, New York City reiterated a desire to also use the 10 MHz D Block frequencies if allowed by Congress and plans to build out its 700 MHz network using LTE as its broadband wireless technology. The waiver request was submitted prior to declarations by three public-safety organizations — the Association of Public-Safety Communications Officials (APCO), the National Emergency Number Association (NENA) and the National Public Safety Telecommunications Council (NPSTC) — endorsing LTE as the public-safety broadband standard.

In addition, New York City agreed that its broadband network would meet all standards established for a national broadband network. While these endorsements may make it more likely that LTE ultimately will be the technology choice for this endeavor, it is not a guarantee — something New York City realizes, NYPD Deputy Chief Charles Dowd said.

"We understand the obligations that go with that," Dowd said. "If we somehow make the wrong choice on technology, we would have to redo it."

Dowd said there is considerable overlap between LTE and WiMAX — the other technology typically mentioned in the public-safety broadband discussion — so he does not believe switching the network to WiMAX would be cost prohibitive, if necessary.

New York City already has a 2.5 GHz broadband network that was built by Northrop Grumman, which supposedly was built to public-safety standards. However, a 700 MHz system would provide better in-building coverage — making it a better choice for mission-critical voice applications than narrowbanding NYPD's current system — and would allow it to be on a band with the rest of the nation, Dowd said.

"That [2.5 GHz] network does not have the interoperable capabilities that a 700 MHz network is going to have," Dowd said.

By overlaying a 700 MHz network on top of the already-hardened sites associated with the 2.5 GHz network, New York City hopes to save money in deployment costs, Dowd said.

Exactly how New York City would be allowed to use the spectrum currently held by the PSST is questionable. There has been speculation within the public-safety community that entities like New York City could "sub-license" the spectrum from the PSST, but such a mechanism does not exist for that spectrum under current rules.

"We would want all the rights and privileges on that spectrum that we have on our existing spectrum today," Dowd said. "Again, there are obligations that go with that, and that has to do with being fully interoperable and building to the same technologies as everyone else is."

Most industry observers do not expect the FCC to act on the waiver request until the commission is reconstituted. The Senate today is scheduled to conduct the nomination hearing for Julius Genachowski, President Barack Obama's choice for FCC chairman.

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