[TrunkCom] 700 MHz TV Clearing, its Impact on TV Viewership, and Options for Accelerating Public Safety Access

[Marcelrf]

700 MHz TV Clearing, its Impact on TV Viewership, and Options for
Accelerating Public Safety Access
by Motorola, Inc.

February 2, 2004

Executive Summary

Effective mobile and portable communications are essential to public
safety operations. Police officers, firefighters, emergency medical
personnel and their departments use mobile and portable communications
to exchange information that can help protect public safety officials
and the citizens they serve. Traditionally, this information was mostly
by voice. Increasingly, as public safety entities strive to increase
efficiency and effectiveness in today�s world, they also need the
capability to transmit and receive high performance data, still images
and video reliably. Spectrum is the road upon which such communications
travel and increased communications requirements lead to the need for
more spectrum.

Based on a thorough justification of need, Congress and the Federal
Communications Commission dedicated 24 MHz of spectrum in the 700 MHz
band to public safety in 1997. However, six years later, incumbent
television stations operating on channels 62, 63, 64, 65, 67, 68 and 69
prevent public safety access of this essential resource in most major
urban areas where the demand for more spectrum is the greatest. The
recent focus on increased interoperability and Homeland Security make
availability of this public safety spectrum nationwide even more
critical. Current law and policies set December 31, 2006 as the date for
clearing television from the band. However, this is not a firm date.
Broadcasters do not have to clear the band until 85% of the households
in their service areas have the capability to receive digital TV, an
environment unlikely to be met in most markets by yearend 2006.

In hearings on the public safety spectrum issue, some members of
Congress expressed concern that a firm clearing date would impact the
viewing public. As shown in this paper, the potential harm to the
viewing public is minimal, compared to the public safety need for this
spectrum, which Congress and the FCC already confirmed. First, only 75
stations, equaling 5% of the 1500 U.S. TV stations, impact public
safety�s availability of its 700 MHz band spectrum. Second, Motorola�s
analysis of independent television industry data shows that on average,
only 14% of the TV households who have the option to view these stations
actually do so at all and that of those viewing, 82% watch by cable.
This means that, on average, only 3% of the TV households within these
stations� coverage areas tune to these stations over-the-air sometime
during an average week.

Therefore, the public interest benefits of clearing the 700 MHz spectrum
for public safety access
nationwide no later than December 31, 2006, far outweigh those of
allowing it to stay encumbered
by television.

Additionally, we recommend a number of options that may accelerate the
clearing of these TV stations, for enactment by the FCC and/or Congress.
These include: (1) require analog TV stations to cease analog operations
and operate only on their digital channel; (2) allow analog TV stations
to temporarily move their analog operations and operate in analog mode
on their digital channel; and (3) allow analog TV stations to
temporarily stop over-the-air broadcasts and operate only via cable or
satellite TV. While these may provide some quicker access, they do not
preclude the need for Congress to change the law, removing the
exceptions, so that December 31, 2006 is a firm date by which all TV
stations must clear from channels 62, 63, 64, 65, 67, 68 and 69.

1 Introduction

Wireless communications is a critical tool for state, local and federal
governments, as well as critical infrastructure, transportation and
private industries, especially in view of today�s heightened security
concerns. This is particularly true for our nation�s public safety first
responders, where having the right information immediately available at
the point of decision, wherever needed, is critical for protecting
themselves and the citizens they serve. Simply put, public safety�s
uncompromising mission critical communication requirement is to have the
right information, to the right people, at the right point in time,
whether that information is transferred via voice, data or images.
Public safety users best state this requirement as:

�The first priority must be to provide public safety with mission
critical radio communication systems that provide reliable
agency-specific � police, fire, EMS �communications. (Mission critical
radio communications are those required when life or property is at
stake.)�1 Any discussion of wireless communications must begin with an
explanation of radio spectrum.  Communications systems use
electromagnetic waves to send voice and data information across the
airwaves. While the engineering and physics may be complicated, the most
important point is that wireless communications cannot take place
without users having access to sufficient spectrum in which to operate
their communications systems. Spectrum designated for exclusive use by
public safety is the lifeline to their emergency response, detection and
prevention capabilities. The bottom line is that without access to
adequate spectrum, wireless communications cannot take place,
effectively and ubiquitously.

Spectrum is a finite resource for which more and more users of
ever-growing wireless technologies are increasingly competing,
especially in metropolitan and even suburban areas. Non-federal use is
regulated by the Federal Communications Commission (FCC or Commission).2
As state and local governments are also experiencing growth in number of
users, agency jurisdictional coverage areas, and introduction of new
technologies, existing public safety radio channels are becoming
extremely crowded in these dense population centers.

Recognizing this urgent need for additional spectrum, the public safety
community through the
Public Safety Wireless Advisory Committee (PSWAC), issued a report on
September 11, 1996 that
documented the need for 97.5 MHz of additional spectrum to meet their
communications needs

1 �When They Can�t Talk, Lives Are Lost� brochure, February 2003,
developed by The National Task Force on
Interoperability (NTFI), page 7. NTFI is comprised of members from 18
major national associations for local and State
elected and appointed officials and public safety officers.

2 The National Telecommunications and Information Administration
regulates spectrum for federal government
users and in many cases works jointly to with the Commission to address
spectrum related issues of interest to both
users.

The greatest amount of this spectrum is needed for emerging advanced
wireless wideband and broadband technologies, adapted for mission
critical public safety applications.  These include high-speed data,
intranet access, imaging and video transfers and on-scene multimedia
mobile command communications. The need for additional spectrum
continues to exist and is even more critical today given the nationwide
public safety focus to improve Homeland Security.  Recognizing public
safety�s need for spectrum, in 1997 Congress and the FCC reallocated 24
MHz of spectrum from TV channels in the 746-806 MHz band (TV channels
60-69) to support mission critical public safety communications. This
band is generically called the 700 MHz band. Specific band segments
within 700 MHz allocated to public safety are 764-776 MHz (TV channels
63 and 64) paired with 794-806 MHz (TV channels 68 and 69). Television
stations within channels 60-69 are expected to vacate this spectrum as
part of the transition from analog to digital television.  Notably,
access to the 700 MHz band essentially doubles the spectrum public
safety has to support wide area operation. The 700 MHz band is critical
to public safety for two key reasons:

(1) Together, the new 700 MHz and current 800 MHz bands provide the best
opportunity to integrate interoperable communications. The 700 MHz
band�s close proximity to the 800 MHz band allows public safety agencies
to expand their current 800 MHz narrowband voice and data systems for
interoperability and regional coordination on an �intra� as well as
�inter� agency basis. New portable and mobile radios, as well as
infrastructure equipment, capable of operating in both the 700 and 800
MHz frequency bands in one radio are commercially available today. The
Commission adopted Project 25 Phase 1 as the interoperability standard
for narrowband voice and data communications in the 700 MHz band.4
Further, the Commission last year granted each state a license to
operate such narrowband communications in the 700 MHz band. At the local
level, public safety users are completing regional plans required by the
Commission to start implementing local and regional systems.

(2) 700 MHz is the only dedicated spectrum allocation where public
safety can implement advanced mobile wide area systems that bring
high-speed access to databases, the internet/intranet, imaging and video
to first responders in the field.  The wideband technology to deliver
high-speed data in the 700 MHz band offers a whole new level of mobile
communications capabilities, which is far beyond today�s voice and low
speed data applications. For example:

a. An officer or agent could transmit video of a potential bomb, or
biological weapon and get real time counsel from an expert in another
location.

Final Report of the Public Safety Wireless Advisory Committee to the
Federal Communications Commission and the National Telecommunications
and Information Administration, September 11, 1996, p3.  4 FCC Fourth
Report and Order and Fifth Notice of Proposed Rulemaking, �The
Development of Operational, Technical and Spectrum Requirements for
Meeting Federal, State and Local Public Safety Communications
Requirements Through the Year 2010�, WT Docket No. 96-86, released
January 17, 2001.


b. Local or state police could instantly send or receive a photograph of
a missing or abducted child.

c. Crime scene investigators can transmit live video of footprints,
fingerprints and evidence to speed analysis and apprehension of
perpetrators.

d. Firefighters can access building blueprints, hydrant locations
hazardous material data and other critical information.

e. Paramedics can transmit live video of the patient to doctors at the
hospital that could help save lives.

Motorola and Pinellas County, Florida, conducted a successful trial of
technology that can provide all of the above capabilities as part of
what we refer to as the Greenhouse Project. A subsequent Greenhouse
Project is being finalized with another major metropolitan public safety
department.

The capabilities demonstrated are the emerging powerful multi-media
applications that will bring
public safety communications into the Twenty-First Century. Public
safety users have completed
the wideband interoperability standard through the Telecommunications
Industry Association
(TIA). In turn, TIA recommended this standard, identified as TIA-902, to
the Public Safety
National Coordination Committee (NCC), the Advisory Committee created by
the Commission to
provide recommendations on the use of the 700 MHz. As it did with the
Project 25 narrowband
standard, the NCC recommended the TIA-902 standard to the Commission for
subsequent
endorsement as the wideband interoperability standard in the 700 MHz
band.

Unfortunately, because of incumbent broadcast television use, most of
this nation�s largest
metropolitan area public safety agencies cannot use this spectrum today,
nor can they predict with
any certainty when they might have access to these frequencies.
Therefore, they cannot deploy, nor
plan for the deployment of, the interoperability and advanced technology
that will improve their
effectiveness and safety. Under current law, while TV incumbents are
required to vacate this
spectrum at the end of 2006, they can receive an unlimited extension of
this deadline based on the
state of the transition in their particular market. Specifically, the
Balanced Budget Act of 1997 set
the guidelines for determining the end of the transition to digital
television in a given market. The
law set a conditional deadline of December 31, 2006 for broadcasters to
complete the transition to
digital broadcasting, stating that the Commission may not renew a
television broadcast license that
authorizes analog television service for a period that extends beyond
that date. However, an analog
broadcaster may request an extension of the deadline if it can
demonstrate any one or more of the
following are not met in that market area:

1. Fewer than 85% of the households in the broadcaster�s market are
capable of receiving digital broadcasts. To be counted as broadcasts,
households must be able to receive any one digital broadcast
over-the-air using a digital TV set or analog set equipped with a
digital-to-analog set-top converter box or be able to receive at least
one digital programming channel of each broadcaster in the market from a
multi-channel video programming distributor (MVPD) such as a cable
system.

2. One or more of the four largest networks has an affiliate in the
broadcaster�s market that, despite the �due diligence� required by the
law, is not broadcasting a digital signal.

3. Digital to analog converter technology is not readily available in
the broadcaster�s market.
The law leaves most of the details of the market penetration test to the
Commission�s discretion.7 Many experts seem to accept that the 2006 date
is not likely to be met in any television market. As a result, there is
no �hard date� by which TV stations must vacate this spectrum to allow
for public safety access, a situation that leaves the public safety
community and those who support its efforts and needs unsure of the
future.


In order for any public safety agency to use the spectrum it has been
assigned in the 700 MHz band, any TV stations operating on those public
safety transmit and receive frequencies (referred to as the co-TV
channels) must have ceased operations. In addition, any TV stations in
that market that are operating one TV channel up or down from the co-TV
channel (referred to as the adjacent TV channels) also must have ceased
operations. In effect, as many as seven TV channels (62-65 and 67-69)
must be cleared before first responders in that market will be able to
access the 24 MHz of new spectrum and deploy the equipment that uses
this spectrum.  The purpose of this paper is to share Motorola�s market
and engineering analysis into this TV clearing issue. Motorola provides
the results to date of this effort.


http://www.motorola.com/cgiss/docs/700mhz_whitepaper.pdf

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