The FCC’s Draft 4.9 GHz R&O/NPRM


It’s been a pretty crazy two weeks in the public safety communications universe.  In addition to what is presently facing first responders on the streets and in the forests, the FCC has dropped a draft Sixth Report & Order and Seventh Further Notice of Proposed Rulemaking in the 4.9 GHz proceeding.  It has caused a lot of talk and discussion in the industry, much of it confusing.

Continue reading “The FCC’s Draft 4.9 GHz R&O/NPRM”

We’ve Seen This Interference Movie Before


Science projects can be so much fun. We all remember the science fairs when we were in school with volcanos, homemade playdoh, and a million other things. Science projects are also so important to life. Marie Curie, Jonas Salk and hopefully someone developing a COVID-19 vaccine soon come to mind.

However, public-safety communications should not be a science project. Mistakes in this instance can prove costly. If risks are to be taken, they shouldn’t be taken without adequate testing.

Unfortunately, that’s exactly what the FCC has permitted in its decision to allow unlicensed devices to share the 6 GHz band with public-safety and critical infrastructure industries (CII) microwave systems. By permitting such sharing without first demonstrating that co-existence can work in the field, there is a dangerous risk that this science project can have disastrous consequences.

Continue reading “We’ve Seen This Interference Movie Before”

Tips For Using Third Party Application Preparers


Lately, we’ve been asked by a number of long-term clients to take over their application preparation process.  The clients have been enterprise users, municipalities and two-way radio dealers.  This is nothing new for us, our licensing staff has taken over this responsibility for entities big and small for many, many years.

What is “new” now is that many FCC land mobile radio-familiar employees are retiring, and entities have been reluctant to replace them.  Even when they are replaced, the new folks can be terribly lost in this highly esoteric area, with huge consequences for simple errors.  Further, the pandemic shutdown has resulted in the loss of some personnel, placing additional strain on this process.  While I wrote about this in 2017, it seems like an appropriate time to revisit the issue.

If you are in a similar situation, due care should be taken with regard to your chosen entity, whether it is a law firm, a third-party application preparation service or even a Part 90 Frequency Advisory Committee (FAC).  Sometimes, the “cheapest” option is the most expensive option at the end of the day.  Thus, there are a series of questions that should be asked before selecting an entity to perform this function. Continue reading “Tips For Using Third Party Application Preparers”

The Citizens Broadband Radio Service – An Overview

view of vintage camera

Photo by Karol D on

The Citizens Broadband Radio Service (CBRS), is a spectrum sharing plan that provides a more efficient alternative to the traditional methods of allocating spectrum. In April 2016, the FCC finalized rules for spectrum sharing, authorizing 150 MHz of new spectrum – originally used by the Navy and other Department of Defense personnel – for commercial uses on a shared basis with the incumbent users of the spectrum. Continue reading “The Citizens Broadband Radio Service – An Overview”

Carpenter v. U.S. – Implications For Smart Cities

time lapse photography of city road at nighttime

Photo by zhang kaiyv on

The Supreme Court’s decision on the privacy of cell phone records in Carpenter v. United States, and the need for law enforcement to obtain a warrant, could have implications for the future of smart, connected cities.

The smart building of the future contains a variety of sensors, from heat and motion sensors that detect how many people are in a room, to metal detectors for hotels.  Outside of the building, cities are putting sensors in the street for Dedicated Short Range Communications (DSRC), which will connect vehicles to infrastructure to avoid accidents (and more).  These are just a few of the connected environment sensors that is part of our near future.  IoT devices already outnumber the world’s population.  Here’s a nice presentation from Bosch on just some of what a connected city will enable.

These smart city/smart building technologies will be tied back to databases which represent a treasure trove of information for city/building planners, energy providers and…….. law enforcement.

Where does this data reside?  Does it reside with the municipality (for DSCR, traffic cameras, etc.), with the building owner, or with Google (who has your mapping information)?  Can a third party purchase that information from the municipality for data analytics (perhaps Facebook)?  Can law enforcement access this information, and under what non-emergency conditions?  If law enforcement is provided such access, how do we ensure the chain of custody of that data?

Should a building owner be required to provide building information, and if the owner does so without a warrant, should the building owner be required to provide you with affirmative notice when you enter?  Can you opt-out of providing this information to the building owner?

These questions have consequences for the First Responder Network Authority (FirstNet).  FirstNet is designed to be a nationwide broadband system for police and fire fighters.  One of the most powerful uses of the network is to give first responders the ability to harness the power of IoT in order to enable better information upon which to act in emergencies.  For example, access to internal video cameras at the Washington Navy Yard would have enabled police on the outside of the building to know the location and number of shooter(s) inside the building during the incident in 2013.  If the building was a private facility, instead of a government facility, does accessing inside building IoT represent a unreasonable search and seizure?

As a participant in the Telecommunications Industries Association’s (TIA) Smart Buildings Program, I see opportunities to create simply amazing technologically advanced buildings that resemble the best of Star Trek.

I do not suggest or recommend any answers to these questions here.  However, it is a conversation that must be had as a society, and considered prior to the issue arising in a litigation context.  Part of that discussion will be shaped by the Carpenter decision, which certainly would seem to suggest that access to many of the potential data users discussed above will require a warrant.

Connectivity and analytics of shared information is an important part of creating a more efficient future and limiting the use of our planet’s scarce natural resources, with the hope of making a better world for all.  How that future isn’t considered to be a “Big Brother” future is a conversation to have now.

800 MHz Post-Rebanding Interference – What You Need To Know


On November 6, 2017, the FCC held an Open Forum on Interference from broadband systems to public safety land mobile radio operations.  We were honored to have been asked to participate.

During the session, we were asked about our efforts to provide education to the public safety community about the issue.  We told the FCC about our half day interference workshops at the International Wireless Communications Expo (which we’ve done multiple times), presentations at numerous APCO meetings, and magazine articles.  The Commission urged us to keep getting the word out, and so this is the purpose of this blog post. Continue reading “800 MHz Post-Rebanding Interference – What You Need To Know”

The Elimination Of Net Neutrality Must Protect Public Safety


A Fact Sheet was recently issued by Democratic FCC Commissioner Clyburn on the FCC’s proposal to eliminate Net Neutrality.  As noted by the Commissioner, the Rules sought to be repealed were previously upheld as reasonable regulation by the U.S. Court of Appeals.
You may wish to read the Fact Sheet in conjunction with Last Week Tonight’s Story by John Oliver from a couple of years ago.  You might want to move to the 2:30 point of the video to skip the setup jokes.
There are significant questions as to how the elimination of these rules impact public safety communications.  It was originally argued that Net Neutrality would keep carriers from being able to offer public safety preemptive service.  That apparent hurdle was overcome, as can be seen by AT&T’s FirstNet offering as well as Verizon’s competing offering.
It has also been suggested by a former FCC attorney that the absence of Net Neutrality would have a negative impact on public safety.
Public Safety is increasingly dependent upon IP connected services, from transmitter sites with IP-based interoperability, to IoT security, to backhaul and controls, to VOIP E911 calls.
Regardless of which Net Neutrality position you believe in, what is important is that if the FCC continues on its apparent course to “free” providers of their current responsibilities, the final rules must include provisions that specifically preclude the ability of providers to give a reduced prioritization to public safety traffic (or to make them pay more), regardless of whether such traffic is FirstNet related.

Mandatory 6.25 kHz VHF/UHF Narrowbanding? Not Soon!


A recent FCC decision resulted in some riled up members of the Part 90 land mobile radio community.  Specifically, on July 30 the FCC denied a Waiver Request submitted by the International Municipal Signal Association (IMSA).   IMSA had requested that the FCC waive the requirement that Part 90 VHF & UHF radio manufacturers include a 6.25 kHz bandwidth mode (or equivalent efficiency) into newly type-accepted products. Continue reading “Mandatory 6.25 kHz VHF/UHF Narrowbanding? Not Soon!”

To FirstNet Or Not To FirstNet, That Is Your Question

FireWatching the FirstNet decision making process by states has been a fascinating experience.  As of this date, a number of states have opted-in, at least one state having “barely considered” opting-out.  In contrast, other states have issued RFPs to determine whether in fact alternatives exist which are economically and technically feasible.  The State of Michigan has even gone as far as to select Rivada Networks as a vendor if the state opts-out. Continue reading “To FirstNet Or Not To FirstNet, That Is Your Question”