D Block debate requires big-picture perspective

Tomorrow, the House Communications and Technology subcommittee will conduct a hearing entitled “Creating an Interoperable Public Safety Network,” which could provide a glimpse of the political environment facing public safety’s effort to have lawmakers reallocate the 700 MHz D Block for first-responder broadband use.

In the Senate, public safety has bipartisan support for D Block reallocation, although there are myriad proposals about how the much-anticipated LTE networks for first responders should be deployed and paid for. In the House, many members question whether such spectrum reallocation makes sense.

All House members just completed an election cycle in November, when voters expressed concern about government spending and the massive national debt that continues to swell every day. In fact, many were elected on platforms focused on curbing federal spending and reducing the deficit.

Given this backdrop, it’s understandable that some House lawmakers have concerns about reallocating the D Block to public safety and to provide about $10 billion in federal funds to support the buildout and maintenance of first-responder LTE networks nationwide. Instead, some believe it would be better to auction the D Block to commercial operators — an exercise that would generate an estimated $3 billion for the U.S. Treasury, according to the Congressional Budget Office (CBO).

FCC officials have been conspicuously quiet about the notion of auctioning the D Block, but they still believe that the 10 MHz of 700 MHz broadband spectrum licensed to the Public Safety Spectrum Trust (PSST) is enough to serve public safety’s broadband LTE needs, according to a background memorandum regarding the hearing.

However, there are several compelling arguments that support D Block reallocation. The most recent are the tests conducted by Andy Seybold on the San Francisco Bay Area pilot LTE network, which revealed that the current 10 MHz would leave public safety “severely limited” in using wireless broadband when mid-sized incidents occur — something that happens daily in metro areas and weekly in suburban locations.

Obviously, if the current 700 MHz allocation is not enough to address public safety’s broadband needs in a given cell sector during a mid-sized emergency, the idea of public safety being able to share the spectrum with other government users, critical-infrastructure personnel or even commercial users would not be an option, in most cases. And that would be a shame, because such partnerships could make the network more robust, more reliable, interoperable with more key people and address multiple needs, instead of just those of police, fire and EMS.

With the D Block, these kinds of partnerships are much more viable to everyone involved, because public safety would have enough spectrum to share the valuable asset with secondary and tertiary responders, which would be more willing to invest their funds into a network with this additional data-capacity overhead. And, although the capacity for the system would double, the additional costs associated with deploying and maintaining the network are virtually the same for a 20 MHz network when compared to a 10 MHz network.

In addition, the $3 billion CBO estimate on D Block auction proceeds would appear to be rather optimistic. After all, Verizon only bid $4.7 billion for 22 MHz of nationwide spectrum in the adjacent band, so $2.1 billion would be a better estimate on a per-MHz basis.

On top of that, multiple industry sources have said that a guard band is needed between the public-safety network and a commercial network built on D Block spectrum. As a result, the bidder essentially would be bidding on the use of 6 MHz of spectrum, not 10 MHz. Thus, if you project Verizon’s bid on a per-MHz basis using this metric, the winning bid would be less than $1.3 billion.

Finally, the laws of supply and demand are not working in favor of a high-dollar D Block bid, because the commercial wireless landscape has changed since the first 700 MHz auction.

AT&T and Verizon — the carriers with the deepest pockets — have their 700 MHz spectrum and support allocation. T-Mobile is the nationwide carrier that has the greatest spectrum needs and was the loudest advocate for a D Block auction, but that talk has virtually disappeared since the company announced plans to merge with AT&T. The other nationwide carrier is Sprint, which hasn’t been a significant player in a spectrum auction in more than a decade.

Many lawmakers have expressed the desire to auction the D Block, because they would like to see another nationwide carrier compete with AT&T and Verizon. However, if the two behemoths are allowed to bid, one of them probably will win, because they have the most money to spend, the D Block would be valuable to them (especially Verizon, which owns the adjacent C Block), and it would block competition.

On the other hand, if rules were created that block AT&T and Verizon from bidding, the revenue generated for the U.S. Treasury might struggle to reach the $1 billion level, because remaining prospects would not have deep pockets and the idea of battling entrenched giants with only 6 MHz of spectrum cannot be an attractive notion to wireless newcomers.

Furthermore, by reallocating the D Block and enabling critical infrastructure users such as utilities to access—and help fund — the private LTE network, things could get simpler for everyone in the future.

For instance, as the FCC clears spectrum in other bands in the foreseeable future, all of it can be allocated for commercial auction, instead of having to save a slice to meet the growing needs of critical-infrastructure and public-safety users. That should translate into more auction revenues in the future. And, by consolidating public safety in a single band, we should be able to avoid the problems that first responders have experienced by being in multiple spectrum bands on the voice side.

Of course, beyond all of these dollars, lawmakers should not lose sight of what is most important: the safety of our first responders and the citizens they protect. Politics and number crunching aside, providing the spectrum and funding that lets public-safety users be armed with 21^st century communications tools in an ever-challenging environment is simply the right thing to do.

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