Frequently in this space, we have noted the need for the FCC to act quickly to make the agency’s vision of a 700 MHz broadband wireless network for public safety a reality. Early indications are that the FCC is determined to uphold its end of the bargain.

The latest evidence is the circulation of a draft order that would grant 20 waiver requests — initial reports were 19, but a last-minute application from Wisconsin has been added, according to FCC officials — from public-safety agencies to build broadband networks in their geographic areas on the 10 MHz of spectrum licensed to the Public Safety Spectrum Trust (PSST).

If granted, the waiver jurisdictions would have the right to deploy LTE networks for first-responder use. In the process, a number of nagging questions regarding the proposed 700 MHz networks could be addressed in a real-world environment, instead of being debated only in white papers premised on assumptions that must be based on speculation.

Some of these issues include financial models for the entities to pay for these networks — remember, Congress has yet to even introduce a bill that would provide funding help, much less appropriate any money for the effort — and how these entities would “sublicense” spectrum from the PSST.

If done in the near future, passage of the draft order by the FCC commissioners also would give the waiver applicants the option of building out their networks in conjunction with the LTE deployments of Verizon and AT&T to realize potential efficiencies the FCC noted in the national broadband plan.

What would be ideal is to let some of these waiver networks be deployed, so that public-safety usage patterns could be tracked, which would provide data for much more informed discussions about first responders’ capacity needs — a debate that would have a direct impact on the D Block-reallocation issue — than is available today. However, if the FCC sticks to the current plan auctioning the D Block early next year, none of the waiver applicants would be able to provide such data in time to influence the decision.

However, the FCC should resolve some other key issues before granting the waivers. One is to establish some sort of framework for jurisdictions to work with each other. For instance, both New York City and the state of New York have applied for a 700 MHz waiver. So, who’s in charge of the New York City buildout? There are myriad potential ways to handle this, but the FCC’s decision on the waivers promise to set an important precedent as the process moves forward nationally.

Another important issue is whether a guard band is necessary between the commercial D Block and the PSST spectrum. Different engineers have offered differing opinions on the matter, but many carriers and vendors have said they believe a guard band is needed between the two swaths, unless they are operating on shared infrastructure. In the case of the waiver entities that want to build networks immediately, sharing with the D Block operator will not be an option in designing a network, because it will be at least a year before that operator is even identified.

While public safety has been outspoken in clamoring for D Block reallocation, the waiver applications are based on using the full 10 MHz — 5 MHz x 5 MHz — of PSST spectrum. If the FCC grants use of the full 10 MHz to the waiver entities, it would be very difficult for the commission to take the guard band out of the public-safety spectrum in the future, because the networks were designed to use the full 10 MHz.

If the FCC wants to maintain the flexibility of being able to take a potential guard band out of the public-safety spectrum, then the waivers should only allow buildout on 3.75 MHz x 3.75 MHz. Of course, this would reduce network capacity by 25%, which may alter the economics to the point that the waiver cities do not believe it is worthwhile to deploy the network.

On the other hand, allowing the waiver jurisdictions to utilize the entire PSST spectrum would mean that a potential guard band would need to come out of the D Block allocation, with the same 25% reduction in usable spectrum. For carriers trying to compete with AT&T and Verizon — both of which have at least 20 MHz of 700 MHz spectrum in most U.S. markets —that’s not an attractive notion. A D Block auction with only 3.75 MHz x 3.75 MHz of usable spectrum would attract much lower bids, and some potential bidders may opt to not participate at all.

There are other options, such as reshuffling the 700 MHz spectrum to allow the guard-band spectrum in the band that is licensed to users such as Access Spectrum and Pegasus, but that would require an entire new proceeding and for someone to pay those operators to vacate the spectrum. Even an FCC operating with its current sense of urgency would have a hard time getting that done in time for a D Block auction to be conducted early next year.

As a result, it’s important that the FCC have a clear vision of the long-term plan — perhaps not all the details, but the key fundamentals — before granting 700 MHz waivers that promise to set precedents that could be difficult to undo in the future.

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