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On July 20, 2010 FCC Chairman Julius Genachowski submitted the following report to the Honorable Henry A. Waxman, chairman of the of U.S. House of Representatives Committee on Energy and Commerce. In this report, Chairman Genachoski makes some very strong and accurate comments on the state of P25 digital trunked radio technology for public-safety.  His comments support my theory that P25 is obsolete and will be usurped by a packet-oriented, multicasted communications protocol.

I’m glad the FCC has recognized that P25 is a dead-end, however I’m concerned that it may be assuming a cellular-like broadband network is the solution for interoperable public-safety voice communication.  It is not,  and I am confident that the public-safety community would ultimately reject common-carrier hosted radio systems.

Packet-oriented digital voice communication over radio using ad-hoc networks in the area of an incident will prevail.  This architecture will allow reliable on-scene communication without relying on base station infrastructure that may not be in close proximity to the incident.  Radios on vehicles will act as network routers and forward data packets containing voice frames to base station radios.  This architecture will be scalable and affordable, unlike the highly centralized P25 digital trunked radio systems that are being sold today.

Click here to view the official document on the Committee on Energy and Commerce web site.

The following questions were posed by Chairman Waxman, followed by Chairman Genachowski’s answers.

Question

1. Please provide a list of the top four vendors of public safety narrowband equipment and their respective market shares. If the FCC does not track this information independently, please use public references to provide these details.

Answer:

The FCC does not formally monitor market share information of public safety narrowband equipment vendors. However, publicly available information indicates that the Motorola Corporation (Motorola) has a significant share of the United States public safety narrowband equipment market. For example, a June 9, 2010 Washington Post article states that Motorola’s market share in the public safety equipment market is 80%. Public information also shows that the following vendors, among others, compete in this sector, but with significantly smaller market share overall than Motorola: PlantCML (subsidiary of EADS), Harris Corporation, Thales, Kenwood, and RELM Wireless.

Question

2. Have proprietary solutions affected interoperability, innovation, cost or competition in the market for public safety communications equipment?

  • a. How would the greater use of open standards affect these factors?
  • b. What steps should the FCC take, if any, to encourage the use of open standards in public safety communications?

Answer:

The staff of the FCC’s Public Safety and Homeland Security Bureau (Bureau) believe that proprietary solutions and market dominance play an important role in the problems with interoperability, innovation, cost and competition in the market for public safety communications equipment. This conclusion is consistent with the National Emergency Communications Plan (NECP) issued by the Department of Homeland Security, which states (page 24) that “[t]he proprietary nature of many communications technologies creates an ongoing challenge to system connectivity and establishing interoperability among them.” Similarly, Dereck Orr, the Program Manager of the Public Safety Communications Research Program of the National Institute of Science and Technology recently testified before the Committee on Science and Technology, Subcommittee on Technology and Innovation, that interoperability is impacted by the proprietary nature of public safety communications equipment.

Bureau staff and many outside experts have found proprietary solutions to have a significant impact on the cost of public safety communications equipment. This, perhaps, is illustrated best by comparing widely-available commercial wireless and the proprietary public safety narrowband communications equipment. For example, the staff’s research has found that while a state-of-the-art consumer cellular device typically costs a few hundred dollars, a typical land mobile radio for public safety communications may cost as much as $5,000. This is at least partly because public safety is unable to capture the benefits of competition and economies of scale associated with equipment and devices that are manufactured for the commercial consumer marketplace, Commission staff expect that leveraging the commercial mass market could reduce costs for public safety devices substantially – even with such requirements as ruggedizing, many experts suggest that handset costs should be measured in hundreds of dollars not thousands.

Similarly, Bureau staff and many outside experts believe that proprietary equipment negatively impacts innovation. Project 25 (P25), the leading standard for public safety narrowband communications, has taken more than 20 years to develop and is still not complete. This fact is almost without parallel in the standards environment and one that many experts would not associate with successful, leading edge products. As a result, P25 systems still rely upon proprietary solutions and the beneficial effect of competition through open standards is not fully realized. A comparison to Tetra, a European standard similar to P25 but which was successfully completed in 1995, makes this stagnation clear. Though similar in function to P25, Tetra products are both more spectrally efficient than P25 and significantly cheaper. Our information suggests that this is the result of a competitive marketplace based on open standards. The protracted development of P25 has allowed vendors to take advantage of selling proprietary solutions.

Another key to ensuring competition in the public safety equipment market is open standards. However, open standards are not enough. To this end, I have directed the Public Safety and Homeland Security Bureau to issue a Public Notice soon (Competition Public Notice) that will look at the impact of promoting competition for public safety communications technologies.

Further, the Commission has a unique opportunity through the FCC’s Emergency Response Interoperability Center (ERIC) to create a national framework for the deployment and operation of an interoperable public safety broadband network. This framework will enable a strong market to be created to serve the needs of the public safety community. This in turn will lead to greater competition, which will result in greater innovation in the public safety broadband communications device and equipment market.

Question:

3. Please provide information on whether the public safety interoperable voice network, governed by Project 25, has achieved true interoperability.

  1. a. Has interoperability been hindered by a lack of competition in equipment and device availability?
  2. To the extent that interoperability has been hindered, please provide specific examples.

Answer:

A broad array of experts have observed that existing public safety narrowband systems have not achieved true interoperability. As the 9/11 Commission concluded, the absence of interoperable communications capabilities among public safety organizations at the local, state, and federal levels was a problem of the highest order (page 293). Unfortunately, there has been little progress in solving this problem. Further, the Report of the Select Bipartisan Committee to Investigate the Preparation for and Response to Hurricane Katrina (pages 163-182) found that public safety on the ground lacked the interoperability required for seamless on-the-ground coordination. And, during a hearing held on May 27, 2010, by the House Science and Technology Committee, Subcommittee on Technology and Innovation on Interoperability in Public Safety Communications Equipment, the majority of witnesses recognized that additional work was required to achieve interoperability for the public safety narrowband systems.

There is insufficient information available on the impact of limited competition in equipment and device availability for public safety communications. By contrast, the Commission has data from the commercial industry indicating that the highly competitive commercial mobile industry equipment market has had long standing technical solutions to interoperability, including PSTN voice calling, text messaging, roaming and IP connectivity. Thus, a central feature of the forthcoming Competition Public Notice noted above is to seek comment on whether and to what extent the interoperability for public safety narrowband voice communications has been hindered by a lack of competition in equipment and device availability, and how this can be remedied in the future.

Question:

4. Does the current structure of the public safety equipment market hinder efforts to achieve interoperability for a broadband public safety network? If so, please provide a description of possible steps the Commission might take to remedy this action.

Answer:

The current structure of the public safety equipment market may hinder efforts to achieve interoperability for a broadband public safety network. To remedy this state of affairs, the National Broadband Plan recommended an incentive-based partnership approach that leverages commercial technology and economies of scale, including the commercial deployment of a broadband wireless network using the D block. By leveraging commercial broadband deployment for consumers in the 700 MHz band, public safety will have access to lower cost equipment and devices, additional capacity, and increased redundancy and resiliency. In addition, by ensuring that public safety technology remains within the mainstream of commercial technology evolution, public safety applications and services will necessarily be based on open, global standards.

Question:

5. Section 101(b) of the staff discussion draft sets forth criteria for the Commission to consider in establishing rules for interoperability. How should this list be revised to ensure that interoperability is achieved in the broadband network, unlike the “failure” that occurred in the narrowband network? What technical and operational framework might be more appropriate to ensure interoperability on a future nationwide wireless public safety broadband network?

Answer:

A broad framework for interoperability is essential to ensuring that this network is interoperable from day one and remains so as the technology evolves. The Bureau staff believes that interoperability can be achieved and maintained only through a combination of technology standards, license conditions, network governance, funding conditions and regulations. If any of these factors is missing, interoperability will not be achieved.

The staff discussion draft includes necessary elements for consideration in establishing rules as part of this broad framework. The Commission, , however, notes that any path forward should permit flexibility to identify additional criteria identified through any rulemaking process. To that end, the FCC recently issued a Public Notice for additional information on interoperability to help effectuate the work of the Emergency Response Interoperability Center (ERIC) to create an interoperability framework. Comments were filed in response to this Public Notice on July 19, 2010. Further, the Commission will receive additional information on the impact of competition in the equipment market in response to the upcoming Competition Public Notice. All of this information, along with the experience that ERIC and the FCC gains from reviewing and acting on the interoperability showings submitted by waiver recipients on July 19, 2010, will assist the FCC in identifying any additional criteria necessary to the creation of an effective interoperability regime.

In addition to the promulgation of rules, a significant challenge in achieving interoperability involves ensuring that the thousands of independent public safety jurisdictions comply with the appropriate interoperability framework. While the FCC can utilize its licensing regime and its enforcement authority to bring this about, it will also be very important to condition any grant program on compliance with these important interoperability requirements. It will also be imperative that other Federal agencies, including the Department of Justice and the Department of Homeland Security, who work closely with public safety agencies on governance and standard operating procedures, ensure that the proper procedures are in place so all can be certain of interoperability from day one of this network.

Question:

6. Can interoperability requirements applied to the wireless public safety broadband network be utilized to promote interoperability between narrowband and broadband networks?

Answer:

While creating an interoperable public safety broadband network will not, in and of itself, solve all the troubling interoperability problems faced by existing narrowband networks, it does present an important opportunity to make progress in this area. In the short term, there is the possibility of technical interoperability requirements that would promote narrowband and broadband network interoperability. For example, this can be done through the use of gateway and other equipment. In the longer term, it may be possible to support mission critical voice communications that currently are provided only on narrowband systems. This ability will enable public safety to begin to migrate off of existing narrowband networks and end up with a single device for all of their communications needs using the latest technologies and on a cost-effective basis.

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