Subject: [NEXTEL-1] 700 MHz TV Clearing, its Impact on TV Viewership, and Options for Accelerating Public Safety Access

From: Marcelrf <[email-masked]>
Date: Sat, 13 Mar 2004 03:59:13 -0500

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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