Andrew Seybold's  Comments on: FCC White Paper, The Public Safety Nationwide Interoperable Broadband Network: A New Model for Capacity, performance and Cost

In June 2010, the FCC published its second white paper supporting its recommendations in the National Broadband Plan (NBP) submitted to Congress in March of this year. The first white paper detailed the FCC’s ideas related to the cost of building and operating a nationwide public safety Broadband network. I reviewed that document and prepared my own white paper challenging many of the FCC’s assumptions and questioning its findings. 

This second white paper details the FCC’s analysis of the capacity of the 10 MHz of spectrum already assigned to the public safety community and claim that 10 MHz of broadband spectrum (5 MHz by 5 MHz) will be sufficient for most public safety broadband requirements well into the future. The following is my response to the FCC’s second report.

It is my opinion that the authors of the paper were charged with reinforcing the position previously taken by the FCC that the D Block should be auctioned to a commercial operator. Instead, they should have been charged with taking an uncommitted view of the needs of the public safety community and developing a paper based on an understanding of the differences between commercial and public safety networks and requirements. It appears that this FCC white paper was developed for the purpose of further justifying a position it already recommended to Congress in the National Broadband Report. There are many discrepancies in the FCC white paper and a number of assumptions that, while they may be valid for commercial networks, are not valid for a mission-critical public safety broadband network.

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