Subject: [NEXTEL-1] Report: Fourth Meeting of the FCC Technological Advisory Council III

From: Marcelrf <[email-masked]>
Date: Thu, 25 Mar 2004 11:38:44 -0500

Report: Fourth Meeting of the FCC Technological Advisory Council III

0.0 Executive Overview

The Federal Communications Commission Technological Advisory Council
(the TAC) held the fourth meeting of its third two-year cycle on Friday
January 23, 2004 in Washington, D.C. (FCC TAC III, Meeting 4). The
Council, with thirty-three members selected because of their
professional and technical expertise, is to provide scientifically
supportable information on those emerging technologies likely to impact
the work of the FCC. Each meeting of TACIII is organized around specific
topics of interest to the Commission. The two focus topics of this
meeting were Public Safety, organized by Gregory Lapin, and Critical
Infrastructure Protection and the Law, organized by Stewart Personick.

A videotape of the meeting serves as the official minutes of this
meeting. This report is a reorganization and distillation of discussions
and presentations at the public TAC meeting and includes some additional
supporting information. This working document, written for the purpose
of facilitating the on-going tasks of the Council and as an informal
summary for those who may be interested, does not necessarily represent
either the recommendations of the TAC as a whole or the opinion of any
individual or organization associated with the TAC. At this meeting,
there were four prepared presentations followed by open discussion. In
this overview and the report that follows, the remarks, observations,
and opinions of the speakers who were invited are summarized together
with some of the resulting open discussion stimulated in reaction. There
was not sufficient time for all those who wished to support or refute
what was presented to do so, and not all positions presented are
mutually compatible.

Public safety (PS) communications organizations have a strong interest
in new and more efficient systems that will make communications more
attainable. Sean O’Hara of the Syracuse Research Corporation and the
NPSTC (National Public Service Telecommunications Council) gave an
overview of the communications requirements of the public safety
community, methods to improve the overall efficiency and effectiveness
of PS communications, and some of the obstacles preventing change.
O’Hara concentrated on those issues where public safety requirements
differ from traditional requirements, and in the way public safety
professionals, for cost reduction purposes, are revisiting requirements
to increase their ability to leverage technology from the broader
commercial market. New technology may present the opportunity to
simultaneously improve spectrum efficiency and make the technology more
affordable to agencies that, above all, must protect the public in time
of emergencies.

Public safety communications must be ubiquitous (including unpopulated
areas), have reliable authentication, controlled access to sensitive or
classified information, in some cases maintain evidentiary integrity,
and work when other systems fail. Traffic patterns and loading can be
more stressful than in commercial networks. PS equipment must be
physically rugged, reliable, and often also light-weight and battery
powered. All of these conditions conspire to make equipment acquisition
very expensive, especially since requirements are set locally and not as
a single unified national (or international) set of specifications.
Because public safety has a small and fractured market, PS is starting
to look at meeting some mission requirements though technologies adapted
from other markets. Leveraging these markets would not only reduce the
cost of PS equipment but would infuse PS with the same innovations
enjoyed by these markets.

PS management is organizationally spread over a large number of
relatively small, autonomous entities. Even though there are many common
requirements, specifications can vary significantly between users
fragmenting the market even more. Several TAC members felt that the lack
of a single, national, unified organizational vision of PS
communications was the primary obstacle to higher performance and lower
cost. It is inevitable that some PS requirements will need to be
different from commercial equipment; however, it is not obvious that
those requirements must also vary widely between administrative domains.
Many PS objectives should be achievable with modifications and
enhancements to commercial equipment, although it is unlikely that all
of the mission-critical needs of PS could (or should) be absorbed by
standard, commercial networks.

Stu Personick is the Chair of the National Academy of Engineering
Committee that produced the report Critical Information Infrastructure
Protection and the Law. William J. Cook, Partner at the law firm
Wildman, Harrold, Allen and Dixon LLP, is a member of the Committee.
While other studies have explored the technical and operational aspects
of information infrastructure security and dependability, the purpose of
this study was to explore the role of the law as both a facilitator and
an obstacle to achieving information infrastructure security and
dependability. Because sharing of information among private sector
entities, and between the private sector and the public sector about
infrastructure vulnerabilities and countermeasures is widely considered
to be a key ingredient for improving the security and dependability of
critical infrastructures, the report focuses on how existing laws and
associated policies discourage and/or motivate private sector firms to
share information about vulnerabilities and recent attack-related
events.

Cook reviewed the key points of the National Research Council report.
Because all critical infrastructures (transport, power, water,
healthcare) have, in turn, become increasingly dependent on the evolving
information infrastructure, protection of the communications networks is
especially crucial to ensuring the security of the nation. For the
sharing of information about vulnerabilities, threats, and
countermeasures to proceed effectively, companies should be able to
rapidly report all newly discovered vulnerabilities and incidents to a
responsible authority with the ability further disseminate such
information, and to rapidly elicit an appropriate response from
government and industry. There are, unfortunately, several obstacles
preventing this from happening. Many private sector companies believe
that proprietary information shared with federal government entities may
be subject to disclosure, or inadvertently disclosed by government
employees to third parties under the Freedom of Information Act (FOIA).
Companies are reluctant to share information  about security-related
incidents or threats because of concerns including: information sharing
being interpreted as an anti-trust violation, the admitted
vulnerabilities of one firm being exploited by competitors (“our systems
are more secure than their systems”), shareholder lawsuits for breach of
fiduciary responsibility by revealing the weaknesses of exposed
systems,  and about future difficulties resulting from unexpected shifts
in government policy with respect to the permitted uses of reported
information. There are also trade secrets to protect. Many of these
concerns and obstacles could be ameliorated by an appropriate legal
framework. However, at this time, uniform legal standards with respect
to such things as “safe harbors” are still not in place. Trust is the
dominant factor in determining the degree to which effective information
sharing will actually take place.

In another presentation, Stu Personick focused on the network
vulnerability issues that could lead to massive, catastrophic events in
network-based infrastructures. He explored how engineers might address
the issues, and whether there is any relevant agenda that should be
proposed for a regulatory agency. Network-enabled, fast and easy access
to information, and rapid, informed decision making and control, are the
key enablers through which the utilization of expensive assets in most
other critical infrastructures (e.g., the electric power grid) is
optimized, and through which rapid access to mission-critical
information (e.g., in the delivery of medical services) is achieved.
This makes the communications infrastructure the “nervous system” of
most other critical infrastructures. Unfortunately, these beneficial
characteristics are the very same ones that could allow harmful,
disruptive, or even catastrophic operational commands to be carried out
nearly instantaneously and on a large geographic scale. Accidents and
intentional malicious acts have always had the potential for causing
serious harm, but we what is new and different is the speed, scale, and
scope of the harm that can be caused when network-based systems are
engineered and operated in a manner that focuses only on the benefits
and fails to focus on the risks. Stu felt that, generally speaking,
insufficient attention is being paid to “rainy day” failure or attack
scenarios, and that this is a correctable shortcoming. While the
technical and operational aspects of these issues will most
appropriately be the responsibility of the private sector, certain legal
and regulatory frameworks may need to be established to enable private
sector firms to take the necessary real-time actions in response to
perceived attacks on the communications infrastructure. For example,
operators should be free to implement the blocking of network traffic
that appears to be associated with a massive denial of service attack
without the fear of unexpected liabilities.

The next formal TAC meeting will be on Friday, April 23, 2004. The
Commission has also scheduled all of the other general TAC meetings for
2004:

        Wednesday, July 28, 2004
        Wednesday, October 27, 2004

Prepared by J. A. Bellisio
Approved by R.W. Lucky           March 8, 2004

Report: Fourth Meeting of FCC Technological Advisory Council III

1.0 Introduction
As announced, the fourth meeting of the Federal Communications
Commission Technological Advisory Council III (FCC TAC III, or TAC) took
place on Friday January 23, 2004 at The Portals, 445 12th Street SW.,
Washington, D.C. Alternate Designated Federal Officer (DFO) Dr. Kent
Nilsson, Special Counsel and Deputy Chief, OET, Federal Communications
Commission, opened the meeting. The TAC is chartered for two years at a
time, and this meeting was the fourth one of its third two-year cycle.
The TAC currently has 33 members representing a broad cross section of
industry and academia.

Each meeting of TACIII is organized around one or two topics of interest
to the Commission. The two focus topics of this meeting were Public
Safety, organized by Greg Lapin, and Critical Infrastructure Protection
and the Law, organized by Stu Personick.

This report is a reorganization and distillation of discussions at this
fourth meeting of TAC III written to facilitate the ongoing work of the
Council. It also includes other information made available between
meetings. A complete videotape of the meeting serves as the verbatim
minutes (see Annex 1) of the meeting. As described in the annex, this
report does not necessarily represent per se either the final
recommendations of the TAC as a whole or the opinion of any particular
member. This report and other TAC information is posted on the TAC
website: http://www.fcc.gov/oet/tac/ .

There is a synopsis of each presentation in this report together with a
link to the full set of presentation visuals. The main points of the
open discussions are also summarized. The technical observations offered
in the discussions and presentations were those of individuals and were
not necessarily agreed to by others present. There was not sufficient
time for all those who wished to support or refute what was presented to
do so, and, as can be seen from this report, not all positions presented
were mutually compatible.

The next formal TAC meeting will be on Friday, April 23, 2004. All
meetings are at the same Washington location. The Commission has now
scheduled all four general TAC meetings for 2004 including: Wednesday,
July 28, 2004; and Wednesday, October 27, 2004.

2.0 Mission and Charter of the Technological Advisory Council

The TAC’s mission is to provide technical advice to the Federal
Communications Commission and to make recommendations on the issues and
questions presented to it by the FCC. In order to fulfill its mission as
acting as a source of early warnings, the TAC addresses technological
questions referred to it by the FCC Chairman, the FCC Chief
Technologist, or by the Chief Engineer.

Annex 2 of Report: First Meeting of the FCC Technological Advisory
Council III contains the full Charter of the TAC (see
http://www.fcc.gov/oet/tac/TACIII-Report1.zip Annex 2, also Annexes 3, 4
and 5). The members represent themselves as individuals, but as voting
members of the Council are expected to reflect the interests of their
company or interest group. They serve in a representative capacity and
thus are not expected to provide disinterested advice to the Commission.
They do not act as spokespersons for the Commission, are not compensated
for by the Government, and are not deemed "Special Government
Employees.” The charge given to prospective members is in Annex 3 of the
First Meeting Report referred to above. The TAC has been established as
a federal advisory committee under the Federal Advisory Committee Act
(FACA, 1972). An overview of the legal status of the TAC is given in
Annex 4, and the Federal Advisory Committee Act (1972) is discussed in
Annex 5 of the First Meeting Report.

TACIII, the third instantiation of this group, is expected to meet three
of four times each year. Participation at the meeting “roundtable” is by
the designated members and invited speakers only, but all meetings are
open to public observation and members of the public may be recognized
by the chair for comments. Participation by member substitutes or by
teleconference is not permitted. The meeting is usually broadcast on the
Internet.

Annex 3 at the end of this report is a list of contacts at the
Commission helpful for TAC activities.

3.0 Membership of the Technological Advisory Council (TAC III)

Except as indicated (*), all were present at the Friday January 23, 2004
meeting. Affiliations shown were those at the time of the meeting. Annex
2 of this report gives current contact information for TAC members.
Biographies of members can be found in Annex 6 of Report: First Meeting
of the FCC Technological Advisory Council III
(http://www.fcc.gov/oet/tac/TACIII-Report1.zip  Annex 6).

TAC Chairperson:

Robert W. Lucky - Corporate Vice President, Applied Research, Telcordia
  Technologies, Retired

TAC Executive Director:

Jules A. Bellisio - Consultant, Telemediators, LLC (Telcordia
Representative)

Members of Council:

Len Barlik - Vice President, Technology Research and Development, Sprint

 Corporation

Kwame A. Boakye - Vice President, Technology, Harris Corporation

Vinton Cerf - Senior Vice President, Architecture and Technology, MCI,
Inc.

*Hossein Eslambolchi - President, AT&T Laboratories

*David J. Farber - Professor, University of Pennsylvania

*Bran Ferren - Co-Chairman and Chief Creative Officer, Applied Minds,
Inc.

*Larry Goldberg - Director of the Media Access Group, WGBH

Richard R. Green - President and Chief Executive Officer, CableLabs

Dale N. Hatfield - Director of the Interdisciplinary Telecommunications
Program,
 University of Colorado at Boulder

Dewayne L. Hendricks - Chief Executive Officer, Dandin Group, Inc.,

Charles L. Jackson - Consultant

Ira Jacobs - Professor, Bradley Dept. of Electrical and Computer
Engineering, Virginia
 Polytechnic Institute and State University

Kevin Kahn - Intel Fellow, Director Communications and Interconnect
Technology
 Lab, Corporate Technology Group, Intel

Paul Kolodzy - Director, Center for Wireless Network Security,
Professor, School of
 Engineering and School of Technology Management, Stevens Institute of
Technology

Kalle R. Kontson - Vice President & Chief Scientist, Spectrum
Engineering Sector, Alion
 Science and Technology

Gregory D. Lapin - Chair, ARRL (American Radio Relay League) RF Safety
Committee

*Paul F. Liao - Chief Technology Officer, Matsushita Electric Corp of
America (Panasonic)

Richard Lynch - Executive Vice President and Chief Technology Officer,
Verizon
 Wireless

*Craig Mundie - Senior Vice President and Chief Technical Officer,
Advanced Strategies
   and Policy, Microsoft Corporation

*Nicholas Negroponte - Founding Chairman, MIT Media Lab

Stagg Newman - Senior Telecommunications Practice Expert, McKinsey and
Company

Stewart (“Stu”) Personick - Consultant

Ted S. Rappapport - Director, WNCG, Dept of Electrical and Computer
Engineering, University of Texas at Austin

David P. Reed - Adjunct Professor, MIT Media Laboratory, and HP Fellow,
HP Labs

Dennis A. Roberson - Vice Provost for New Initiatives, Illinois
Institute of Technology

Andrew G. Setos - Executive Vice President, News Technology Group

*Nitin J. Shah - Independent Consultant, Broadband\Mobile\Wireless

Cas Skrzypczak - General Partner, Global Asset Capital

*Padmasree Warrior - Senior Vice President and Chief Technology Officer,
Motorola

*Mark Wegleitner - Senior Vice President, Technology, Verizon
Communications

Robert M. Zitter - Executive Vice President, Technology Operations, and
Chief
 Technology Officer, Home Box Office

(* = Not present at this meeting.)

About 35 members of the public were present at the meeting and comments
from the public are reported as appropriate. The meeting was webcast,
videotaped, and carried by closed circuit television throughout the
Commission’s offices. Live RealAudio access to the TAC meeting is
available through the FCC web site at:
http://www.fcc.gov/realaudio/mt012304.ram. It is expected that future
TAC meetings will also be available from the
http://www.fcc.gov/realaudio/ site. Persons interested in listening to
future meetings should understand that the webcast typically begins to
be accessible at no more than about five minutes before the 10:00 AM
meeting start time.

4.0 Agenda as announced and Revised

TECHNOLOGICAL ADVISORY COUNCIL III
Agenda –Fourth Meeting
Friday January 23, 2004
Federal Communications Commission Meeting Room
The Portals, 445 12th Street, SW
Washington, D.C.

10:00 AM- Opening  Kent Nilsson – Alternate DFO

10:05- Introductions and    Commission Representatives,
   Opening Remarks       Robert Lucky, TAC Chair,
           and TAC Members

AM Focus: Public Safety   Gregory D. Lapin, Organizer
10:20- Introduction to Public Safety   Greg Lapin, Deerfield
Emergency     Communications        Services and Disaster Agency
10:30- Communications Requirements  Sean O’Hara, Syracuse Research
    for the Public Safety Community      Corporation & NPSTC
10:45- Panel Discussion     TAC Members and Speakers

11:15 Current and Future Communications  Sean O’Hara, Syracuse
Research      Technologies for Public Safety      Corporation & NPSTC
11:30 Panel Discussion     TAC Members and Speakers

12:00 - 1:00 PM       -Break-

 PM Focus: Critical Infrastructure   Stewart D. Personick, Organizer
  Protection and the Law
1:00- Summary of NRC Report: Critical   William J. Cook, partner at the
Infrastructure Protection and the Law    law firm Wildman,
Harrold,              Allen and Dixon LLP
1:30- Vulnerabilities of Communications   Stu Personick, Chair,
National   Networks and Mitigation      Academy of Engineering
               Committee on Critical               Infrastructure
Protection and               the Law
2:00- Panel Discussion    TAC Members and Speakers

3:00 PM- Adjourn      Kent Nilsson, Alternate DFO

5.0 Meeting Focus (AM): Public Safety Communications

Greg Lapin, organizer of the Public Safety Communications segment,
besides being a TAC member is also Associate Director of the Deerfield
(Illinois) Emergency Services and Disaster Agency based in his home
community (http://www.deerfield-il.org/govt/commissions.html). With the
heightened emphasis on homeland security, public safety (PS)
communications is of current interest to the Commission. Greg spoke
about how, in recent years, new frequency bands have been allocated and
how a spate of new technologies designed for this frequency space have
been developed. Although there are a number of recurring issues
associated with public safety communications that the Commission must to
consider, most come back to the efficient and effective use of spectrum.
Not only do others often covet the special allocations, but
cash-strapped public service organizations also have a strong interest
in new and more efficient usage that will make communications more
attainable. The FCC may have an opportunity simultaneously improve
spectrum efficiency and make the technology more affordable to agencies
that, above all, must protect the public in time of emergencies.
Obviously, if in a disaster the primary public communications
infrastructure is lost we must be sure that key personnel retain the
ability to communicate. With the current interest in improved homeland
security, it may be that new technology to solve this problem will also
make it possible to both improve spectrum usage and enhance operational
capabilities. If a coordinated approach is taken, there can be a real
“win-win” scenario.

Most of the regulations for public safety communications are found in
47CFR Part 90 of the FCC rules. An extensive list of frequency channels
(the public safety pool) is provided and a system for effective
assignment of channels has been developed. Frequencies are assigned
regionally with specific coordinators for the PS areas of police, fire,
special emergency, emergency medical, highway maintenance, and forestry
conservation. There are 55 regions defined for the US and territories
with more groups qualified for PS frequencies than most people realize.
Groups qualifying for public safety frequencies are:

• State and local government agencies
• Private fire and police companies
• Hospitals
• Private ambulance companies
• Forestry conservation organizations
• Rescue organizations
• Emergency physicians and medical schools
• Persons with disabilities or emergency medical conditions
• Veterinary services
• Disaster relief organizations
• Beach patrols
• Persons or organizations in isolated areas
• Communications common carriers
• International police radio communications

Table 1 shows what bands are being used.

Table 1: Where is Public Safety Talking?                Source: Greg
Lapin

It would appear there are quite a few frequencies assigned to public
safety, and it spans much of the usable frequency spectrum. Some of the
bands are exclusive to public safety while others are shared with other
users.

Greg Lapin’s complete set of presentation visuals can be found at:
http://www.fcc.gov/oet/tac/TACIII_presentation_1-23-04.zip (unzip
1.23.04 Gregory Lapin....)

5.1 Communications Requirements for the Public Safety Community

Sean O’Hara ([email-masked]) of the Syracuse Research Corporation
(http://www.syrres.com/aboutsrc/default.htm), and the NPSTC (National
Public Service Telecommunications Council, http://npstc.du.edu/), gave
an overview of the communications requirements for the public safety
community. Gene McGahey ([email-masked]), of the National Law
Enforcement and Corrections Technology Center (http://www.nlectc.org/ ),
and NPSTC, was also involved in the preparation of this presentation.

Sean concentrated on those issues where public safety requirements
differ from traditional requirements, and in the way public safety
people, for cost reduction purposes, are revisiting requirements to
increase their ability to leverage technology from the broader
commercial market. A primary rational for the regulator’s special
treatment of public safety results from its presumably unique
requirements, so it is critical to understand all the special problems
being addressed by the requirements before any changes are proposed. It
is also important to carefully separate the resulting requirements into
those which can be met (with software) at an application layer from
those which must have a direct impact on the design and allocation of
physical (transport) layer resources. Then there are many requirements
impacting the physical design of equipment that have a huge impact on
equipment cost but are not directly FCC problems. Finally, there are
other issues that can be addressed only if a myriad of locally
autonomous agencies are willing to change standard operating procedures.
Unfortunately, for historical reasons, there is a considerable
commingling of solution sets for all of these issues that prevents a
clean parsing of requirements.

Not all public safety communications are mission critical or have the
same stringent latency requirements. In the mission, different voice and
data applications have different priorities and are best met in certain
bands with certain technologies. Different agencies also have vastly
different applications and application priorities. A “mission critical”
activity immediately and directly affects loss of life or property. A
voice “Shoot - don’t shoot” is needed without network delays and must be
completely understandable. Certain types of data, e.g., robot control
for a bomb squad, need to be real time and without error. In spite of
the drama associated with such communications, we need to remember that
most of the time communications supports routine activity that can
tolerate normal (commercial network) queuing and delays. The problem is
that we must always be fully prepared with reserve capabilities for
those rare occasions when there is both mission critical activity and
high traffic.

In addition to some of the high availability and low latency
requirements implied above, interoperability dependent on situation and
end user application is also a major issue. Personnel need to
communicate with others just when they need to, not to everyone all the
time. Because, for historical and technical reasons, public safety
networks have not been designed as universal access common carrier
systems, interoperability between different regions and different
agencies has become a problem to be solved. Incompatibilities between
equipment groups can lead to the necessity of repeating messages on
multiple systems simultaneously, producing a type of traffic loading
cascade unlike that in the common carrier networks. This loading
situation is further exacerbated by the multiplication effect of the
one-to-many “narrowcasting” mode often used by public safety agencies.
As Sean O’Hara reports, these factors and others combine to give PS
communications a much higher peak to average ratio than one would expect
with commercial traffic.

Although commercial cellular strives for broad coverage for its customer
base, public safety communications often must be truly ubiquitous and
even include some completely unpopulated areas. Security requirements
also differ from those common in other networks. There must be rigorous
authentication and user privilege control, controlled access to
sensitive and classified information, and in some cases the need to
maintain evidentiary integrity.

Sean O’Hara’s complete set of visuals for this presentation can be found
at:
http://www.fcc.gov/oet/tac/TACIII_presentation_1-23-04.zip (unzip
1.23.04 O’Hara 10:30 AM….)

5.2 Current and Future Communications Technologies for Public Safety

In a second presentation, Sean O’Hara described how the PS community is
adopting new technology. In addition to all of the system requirements
just outlined above, public safety equipment must be physically rugged,
reliable, and often also lightweight and battery powered. All of these
conditions conspire to make equipment acquisition very expensive
especially since specific requirements are set locally and not as a
single unified national (or international) set of specifications.
Because public safety has a small and fractured market, PS is starting
too look at meeting some mission requirements though technologies
adapted from other markets. TIA Project-25 (http://www.ptig.org/) is
working to facilitate such a solution with a suite of equipment
standards, network interfaces, peripheral interfaces and PS-related
specifications. WiFi, for example, has a very large, global market and
many of the advanced capabilities that PS needs are being addressed in
these larger markets. Leveraging these markets would not only reduce the
cost of PS equipment but would infuse PS with the same innovations
enjoyed by these markets.

With the support of the European Commission and the ETSI members, the
TETRA standard
(http://portal.etsi.org/portal_common/home.asp?tbkey1=TETRA) has been
developed over a number of years with emphasis on ensuring the standard
will support the needs of emergency services throughout Europe and
beyond. TErrestrial Trunked RAdio (TETRA) is a modern digital Private
Mobile Radio (PMR) and Public Access Mobile Radio (PAMR) technology for
PS.

Currently, the predominant PS technologies are narrowband voice using
analog FM or digital (FDMA and TDMA), and there is narrowband data.
Operations are partitioned using both conventional and trunked methods.
Systems utilize both standards-based and proprietary technologies. New
allocations have fostered the introduction of new technologies and all
digital, spectrally efficient systems using OFDM, for example, are
beginning to appear. The cost points achievable with the unlicensed
utilization of ISM and U-NII equipment have been attractive to many PS
agencies. PS data systems using IEEE 802.11 have begun to pop up across
the country. PS is looking to leverage all of U-NII along with 4.9 GHz
(as well as possibly 5.9 GHz ITS). Technology innovation in Part 15
devices will likely quickly trickle down to PS, as will MIMO, smart
antennas, etc.

As with the military, the software defined radio (SDR) offers the
possibility of a cost-reduced device that can be software-customized for
a specific application.  As with any new technology there are still
concerns such as the security of SDR radio configuration and software
downloads. Can configurations be kept secure and unauthorized users
controlled? And, if others use the SDR, can the PS spectrum remain
secured? The NPSTC is working actively with the SDRF (Software Defined
Radio Forum, http://www.sdrforum.org/ ) to address these and many other
SDR issues.

The cognitive radio is another issue. The FCC has adapted a broad
definition of a cognitive radio device, and advanced use of these
devices brings a couple issues to note. While cognitive radios can be
used to enhance PS operations and interoperability, cognitive radios can
also be used to enable easement into the licensed PS spectrum. The PS
community has made it clear that they need to be “sold” before they
share. There are many questions yet to be answered relating to the
effectiveness of probing techniques, the hidden node problem, methods of
feature detection, and the simplex and tactical interoperability of
channels. All in all, the PS judgment is that this technology is too
fraught with concern to be widely supported right now.

Although not all newly proposed technologies represent an unqualified
benefit to PS, the sense is that the solution to the PS cost and
effectiveness problem lies in adaptation of commercial, off the shelf
technology by mapping PS requirements to the capabilities of larger
markets. O’Hara is personally involved in many of the coordination
activities and is working to promote the embedding of some PS “hooks” in
to emerging standards so as to facilitate the later repurposing of
commercial technology for PS.

Sean O’Hara’s complete set of visuals for this presentation can be found
at:
http://www.fcc.gov/oet/tac/TACIII_presentation_1-23-04.zip (unzip
1.23.04 O’Hara 11:15 AM….)

5.3 Discussion of Public Safety Communications

Most of the discussion centered on methods to improve the overall
efficiency and effectiveness of PS communications and the obstacles
preventing this. Enhancing spectrum efficiency is an FCC issue directly,
but there was also a general exploration of the idea that there should
be ways to make PS communication better and cheaper at the same time.
Some of the discussion did not relate to situations that the FCC could
deal with directly, but this was inevitable because there is such a
strong coupling between many issues - and everyone has an interest in
homeland security. The TAC discussed the environment controlling PS
decisions, the cost problems of PS, and ways to improve the overall
picture.

5.31 Environment

PS communications survives in a harsh and dangerous environment as
compared to its commercial equivalent. This inevitably leads to some
radio systems which are both physically independent and differently
specified from commercial systems. The question is: How different and
independent must PS radio systems be? By comparison, fixed (landline) PS
communications generally share commercial facilities as enhanced by
virtual private networking. Is a similar model possible with radio?

Another PS “environmental” issue is that PS management is
organizationally spread over a large number of agencies. Many of these
agencies are relatively autonomous and are very small compared to a
national operation such as a cellular wireless operator. Although there
are many common requirements, specifications can vary significantly
between users greatly fragmenting the market. Some of the differences
are for sound operational reasons, but we have to believe that many are
just the result of history and the lack of a powerful coordinating
force. Many of the technical specification variants are also a
reflection of the fact that standard administrative operating procedures
are not normalized across all agencies, even those performing identical
functions. Some of the PS technical solutions in common use do not
provide what would be described as a modern separation of the physical
and the application layer. Some operational procedures even seem to have
evolved as a reflection of the way the legacy technology actually worked
and may now be amenable to revision.

It is easy to speculate on ways that things could have evolved
differently, but we need to remember that the primary goal of PS was and
still is to protect the public and not to experiment with telecom
technology. PS administrators have limited, incremental budgets and must
be necessarily conservative when the public safety and security is at
stake. Legacy systems can’t be abandoned precipitously. Physical
requirements alone can make equipment very expensive. The leveraging of
COTS (commercial off-the-shelf) technology could have a cost impact
similar to its effect on the military, but the problem is probably worse
because of the lack of centralized authority.

5.32 PS Cost Issues

Although the primary PS concern for the Commission and therefore for the
TAC is spectrum usage, it is not possible to put this issue in context
without addressing the cost structure facing the PS community. System
cost is coupled to the rate at which new, more efficient technology can
realistically replace the old, and is the primary control over the money
allocated for the research and development of next generation systems
adapted to PS needs. Radios currently used for PS communications are
usually of very high quality and are sold into a small market made even
smaller by localization. According to some estimates, a typical PS radio
costs around $5000 with about one million dollars being spent on
infrastructure for each site (serving typically about 200 users). These
numbers seem quite high as compared to WiFi or even cellular. The good
news is that there is obviously an ability to pay when technology is
needed, but not all of this money can be tapped to deploy radically new
equipment because agencies can only change the legacy base
incrementally.

It is common practice in most communities to offload routine PS
communications traffic to commercial networks. It is reported that most
police carry normal cellphones. WiFi and other low cost technologies are
coming into greater use. Richard Lynch commented that his Verizon
Wireless network is widely used by PS, and although Verizon is reliable
and has excellent coverage, they do not want to be in the position of
being public safety’s only carrier. This is an important remark, because
it seems that even if some special attributes (e.g., priority,
narrowcasting) were added to commercial networks to accommodate PS, it
is inevitable that some independent capabilities will always be needed
if only to be kept in reserve for unexpected incidents.

PS currently occupies spectrum that might be of value to others. An
academic question to ask is whether or not this spectrum is so valuable
that it would attractive to pay to replace all of the legacy PS systems
in exchange for an alternative use for the PS frequencies. Chuck Jackson
did this comparison some time ago and found that, given the high cost of
PS-quality radios, a swap like this would be a close call. Apparently,
PS doesn’t occupy a great deal of valuable spectrum, although some of it
might be described as “prime waterfront territory.”

Good communications can be a very cost-effective force multiplier. Many
believe that advanced information technology is the key to reliable
homeland security. It may be that when all things are considered we can
show that a modernized, more efficient PS structure, even with expensive
new equipment, is the least-cost path to achieving national security
objectives.

5.33 Observations on the Future

It would seem that organizational difficulties are a major impediment to
both cost reduction and the introduction of more spectrum-efficient
technology in the PS sector. Even in the commercial world with just a
handful of major carriers it is difficult to get standardization, but
with PS we are dealing with thousands of independent communities. There
are a few central groups within the country trying to focus some of the
effort now including the Department of Homeland Security. One of the
activities of critical concern to this Department is interoperability
between all of the different kinds of equipment already deployed,
starting first with a definition of the problem and the scope of the
issue.

For total interoperability, it is not sufficient to have just
interworking at the communications level. Not only must applications
also interwork, but human operational procedures must be compatible
across administrative domains. Some of these issues are clearly beyond
the control of the telecom engineer and need to be addressed by human
factors coordination. But even though command paradigms of different
agencies vary on a local basis, and we would not expect everyone to use
the spectrum and operate in the same way, it is still possible to
achieve cost efficiencies with technological commonality.  Somebody in
Kansas is going to use spectrum for something quite different than
somebody in New York City, but we can still imagine them using hardware
from the some pool. If and when interoperability standards for
technology are mandated, we don't necessarily want to take important
operational choices away from users and force them into solutions that
aren't best for them.

As Vint Cerf described, one way to think about interoperability is the
in way it was done when the Internet was built. Interoperability was a
philosophy and the Internet idea was to preserve all of the flexibility
and all of the options at every layer of the network as appropriate. The
Internet started out by maintaining interoperability at the packet
level. That was a successful strategy that created interoperable systems
that span the globe, but Vint felt that the idea of specifying
interoperability application by application and usage by usage was
prescription for failure He feels that some in the PS community have
fallen into this trap, possibly because it appears to be the most
conservative, fully planned approach.

The question is: What is the interoperability and at what layer? Some
people are trying to achieve interworking at the lowest possible layer.
A better way for them to interwork might be at higher layers because
that is what has made IP technology-independent and work so well. If all
of PS were running packet mode, for example, we could have existing and
new software-defined devices working at different frequencies in
different networks but with packets interoperating on an end to end
basis. In the layers above we could start adding applications,
prioritization and allocation of facilities. Vint wondered if there was
any way that the FCC could facilitate some experimentation along these
lines in some frequency band. We have some examples of this kind of
capability in the military and it would be nice to have similar examples
in the public safety domain.

Stagg Newman observed that problem facing PS is primarily an information
transfer problem, not a spectrum problem. The Internet separated the
physical layer problem from the information transfer problem and that
should be considered here. Apparently, at $5,000 to $7,000 per user we
have considerable per user affordability. If we revisit fundamentals
rather than just focusing on spectrum issues we may come up with a far
more optimum, cost-effective solution that could involve sharing with
the commercial or military spectrum.

Kevin Kahn thought that was important to articulate a long term vision
that we could start implementing, or we would run the risk of having
exactly the same discussion many years from now. PS needs a big-picture
architecture that points to the target platform they would really like
to evolve to just the way the Internet defined a platform for
communication. Public safety communication has some specific
requirements to do data interchange that arise out of its mission. If we
had a clean sheet of paper, where would we be going? The Internet didn't
make all of the other kinds of proprietary networking technology vanish
immediately, but it gave the vision needed for new equipment. New
applications began to aim at the target, and we got more and more
flexibility as we moved forward. It will create opportunities and public
safety will suddenly have innumerable new applications that they can
use. Kevin felt that a definition of the basic target platform was the
most critical thing to establish and that he didn’t see this question
being discussed.

As Vint pointed out, one reason that we were able to do the Internet was
that the Defense Department was willing to take a huge risk on a
technology that wasn’t necessarily assured to work. Possibly the new
Department of Homeland Security can play this role, because none of the
other people who offer public safety services today are willing or able
to take this kind of risk, nor should they be. There is always a regular
replacement cycle, so eventually the legacy can be replaced, but we need
a plan. We don't need to ask local groups to take these risks; we need
to have an agency that's willing to make a long-term investment in
exploration of an alternative platform for these kinds of services and
to prove out the platform. Let’s shift the responsibility for opening up
this new alternative to a place that can take some risk, can afford to
do the research and development, can do the demonstrations, and to prove
in the technology. We fully expect PS people to be conservative when our
lives are at stake so it is not unreasonable to expect that they need to
be properly “sold.”

One of the things Sean hoped the TAC would away from his presentation is
that public safety is starting to walk down a road to a new paradigm. By
looking at the requirements and wider markets and they are trying to
find ways to infuse leading-edge technology into their market. By
becoming embedded into key standard development activities they are
making sure their requirements are covered under things that are
intended for the broader markets. Once we start proving that these
commercial-like technologies and networks can meet the bulk of PS
requirements, public safety will start to change course and ride the
commercial wave but it will be a big move for them. It's a good step in
the right direction.

6.0 Meeting Focus (PM): Critical Infrastructure Protection and the Law

Segment organizer Stu Personick was also Chair of the Nation Academy of
Engineering (National Research Council of the National Academies) group
that put together the report Critical Information Infrastructure and the
Law. Study Director Cynthia Patterson ([email-masked]) co-edited the
report with Stu. The report can be viewed at:
http://books.nap.edu/openbook/030908878X/html/index.html or purchased
from the same web site. While other studies have explored the technical
and operational aspects of information security, the purpose of this NAE
report was to emphasize the role of the law as both a facilitator and
obstacle to achieving information security. It is not a general
description of cyber crime, but an overview of the key issues relating
to the way the law impacts our ability to improve the security of the
information infrastructure. The way laws are constructed and applied can
have a controlling impact on the willingness of people to share
information about vulnerabilities and how they are exposed to
liabilities.

The first presentation was an overview of the findings of the report.
Because sharing of data about vulnerabilities and countermeasures is
often presented as a key ingredient for improving security, the report
took some efforts to discover what the legal community might do to
motivate industry to share information. In a second presentation, Stu
spoke about reducing the vulnerabilities associated with critical
network-based infrastructures.

6.1 Summary of Critical Information Infrastructure Protection and the
Law

William J. Cook ([email-masked]), Partner at the law firm
Wildman, Harrold, Allen and Dixon LLP reviewed the key points of the
National Academy report: Critical Information Infrastructure Protection
and the Law, an Overview of Key Issues. Because all critical
infrastructures (transport, power, water) have in turn become
increasingly dependent on the evolving information infrastructure,
protection of the communications network is especially crucial in
insuring security of the nation. Beyond just the national interest,
there are strong economic motivations for information infrastructure
operators to consider security seriously including their exposure to
liability and the impact of their actions on ongoing insurance premiums.

The sharing of information about threats and countermeasures has
generally been a centerpiece of both government and private sector
efforts toward improving critical information infrastructure protection
(CIIP). Most information sharing still occurs through informal channels.
For sharing to work effectively, companies should be able to report all
vulnerabilities and incidents to a responsible authority that has the
ability to elicit an appropriate response from government and industry.
There are unfortunately several disincentives preventing this from
happening efficiently. Many private sector companies believe that
proprietary CIIP-related information shared with federal government
entities may be subject to disclosure to third parties under the Freedom
of Information Act (FOIA). Companies are reluctant to report internal
incidents or threat discoveries because of the concern about creating an
anti-trust violation, about future unwanted FOIA disclosures, about
vulnerabilities being disclosed to competitors, and about revealing
liabilities for exposed systems to potential terrorists. There are also
trade secrets to protect. Many of these bottlenecks could be ameliorated
by an appropriate legal framework, however, at this time, uniform
federal security standards are still not in place. Meanwhile,
uncoordinated regulatory schemes and diverse state laws expose
corporations to the regulatory actions of various courts that are
independently setting their own security standards. Courts are also
expanding tort exposure, creating a market for cyber insurance
protection for the financial, retail, and telecommunications sectors.

One proposed national strategy to secure cyberspace, as promulgated in
February 2003, is to encourage large enterprises to self-evaluate the
security of their own networks with respect to the security of the
nation’s critical infrastructure. Such evaluations might include:
conducting audits to ensure effectiveness and use of best practices;
developing continuity plans which consider offsite staff and equipment;
and participating in industry wide information sharing and best
practices dissemination. As Cook observed, this kind of activity is
apparently just not happening on a widespread basis. Although many of
the difficulties in securing networks are deeply technical in origin,
this is an area where the legal and legislative community can have a
controlling impact. Not only do information infrastructure providers
need a clear legal “green light” for some of the positive actions they
might take, but they also need the assurance that the permission to take
action is being given by agencies with broad authority, and that there
will be long-term stability in the application of the law.
Unpredictability of government action can be a major obstacle to
achieving security objectives.

The speaker sited a representative collection of laws influencing the
security issue and the full report (see web reference above) is
recommended as an overview of these regulations. In spite of the
criticality of this issue as a matter of national security and of the
economic significance of potential losses, there appears to be no entity
coordinating either a public policy approach or fostering research or
development in this area. There are no generally accepted standards that
an operator can point to to show that due diligence was exercised in the
securing of their network.

William J. Cook’s complete set of visuals for this presentation can be
found at:
http://www.fcc.gov/oet/tac/TACIII_presentation_1-23-04.zip (unzip
1.23.04 Bill Cook….)

6.2 Reducing the Vulnerabilities Associated with Critical Network-based
      Infrastructures

Stu Personick focused on the vulnerability issues that could lead to
massive, catastrophic events in network-based infrastructures. He was
primarily thinking of events caused either by global systematic faults
or by intentional malicious acts. Such events could result in a very
large loss of life and economic damages so huge as to be beyond the
range of a simple cost-benefit analysis. He wanted to explore how
engineers might address the issue, and whether there is any relevant
agenda that should be proposed for a regulatory agency.

Our modern network infrastructures and information systems are the
central enabler allowing assets to be more effectively monitored and
controlled, thus leading to a more efficient utilization of those
assets. Networking enables fast, informed decision making supported by
more complete information. It enables transactions to be conducted more
quickly and efficiently. The communications infrastructure is the
backbone upon which most other infrastructures (power, transport,
finance, healthcare, etc.) are optimized. Unfortunately, these
beneficial characteristics are the very same ones that could allow
harmful, disruptive, or even catastrophic operational commands to be
carried out nearly instantaneously and on a large scale. We need to
understand the root of this kind of vulnerability and how to protect
ourselves against it.

Stu observed that information technology, unlike civil engineering with
its long tradition of conservative, fail-safe design, is new field and
practitioners are prone to over-optimizing designs to maximize speed and
cost efficiency. Insufficient attention is being paid to “rainy day”
failure or attack scenarios. Accidents and intentional malicious acts
have always had the potential for causing serious harm, but we what is
new and different is the speed, scale, and scope of the harm that can be
caused when network-based systems are engineered and operated in a
manner that focuses only on the benefits and fails to focus on the
risks.

Because the network is the infrastructure of other infrastructures, the
defense of the network is of overarching importance to everyone’s
security. It is debatable as to whether or not the Internet as a
platform is intrinsically more or less reliable than its predecessors,
but because the Internet has become newly embedded into so many other
systems, the total risk-exposure and vulnerability that we face seems to
be significantly higher than before. This is not inevitable. With proper
engineering and careful attention to vulnerabilities, we can be
protected. The price will be systems that may not work quite as fast or
may cost more because of redundancies, but this is the type of cost that
must be paid if we care about safety. It is the lesson civil engineers
learned long ago.

Stu Personick’s complete set of visuals for this presentation can be
found at:
http://www.fcc.gov/oet/tac/TACIII_presentation_1-23-04.zip (unzip
1.23.04 Personick ….)

6.3 Discussion on Vulnerabilities

Vint pointed out that for some types of systems such as air traffic
control where mission criticality considerations have always come first,
great progress has been made in insuring reliability. One lesson learned
is that reliability and resistance to vulnerability needs to be examined
on a layer-by-layer basis. Of course, we should start with a robust
communications infrastructure, but it is really up to each individual
application to protect itself against faults and attacks. Not all of
security can be relegated to the communications platform.

There are many actions that the network could take to reduce the chance
of various types of attack. As Stu observed, network operators will be
reluctant to implement even the best of these if they are not sure of
the legal ramifications of their actions. There needs to be a clear
policy to protect those who could do something about vulnerabilities
from unexpected liabilities. What does the government need to do to
protect an operator working in a free marketplace from being held liable
for doing something that sounds reasonable on the surface?

Ira proposed that we have safety standards for systems and software in
the same way that we have such standards for other potentially harmful
products. This could prove to be difficult to implement because many
failure modes are still unpredictable, and the technology is advancing
so fast that it may be unrealistic to assume engineers can always get it
right the first time. In any case, if we had a generally accepted list
of “best practices,” not only would we have better systems, but in the
event of problems designers could point to the list to prove they were
properly diligent.

7.0 Focus of Next Meeting

As a result of recently passed legislation, the Commission will need to
develop rules to effectively block wireless spam. Because they will soon
be initiating a rulemaking process, they have requested the TAC to
generally explore the issue of spam. This will be one topic for the next
meeting. Additionally, we are currently planning to have an update on
wireless broadband.

Annex 1: Official Meeting Minutes vs. This Report

 A VHS videotape of the Friday January 23, 2004 meeting serves as the
set of comprehensive minutes of that meeting and represents the official
archive. Copies of the meeting tape can be obtained from the
Commission's contracted copier, In Focus. They may be reached by phone
at:   +1 (703) 843 - 0100   ext. 2278.

This report is a reorganization and distillation of discussions and
presentations at the public TAC meeting and includes some supporting
information produced between meetings and from other meetings of all
three instantiations of the TAC. This report, as prepared by the TAC
Executive Director, although intended to reflect faithfully facts and
opinions as expressed by members and speakers, has not been approved by
any member other than the Chair and therefore should not be construed as
necessarily representing the position of anyone associated with the TAC.
It is a working document written for the purpose of facilitating the
ongoing tasks of the Council and as an informal summary for those who
may be interested. This report is not the minutes, nor does it; per se,
necessarily represent the final recommendations of the TAC as a whole.
Observations, technical judgments, and opinions summarized in this
report do not necessarily reflect those of any individual or
organization associated with the TAC. The opinions offered in the
discussions and presentations were those of the individuals and are not
necessarily agreed to by others present. There is not sufficient time at
any meeting for all those who wish to support or refute what was
presented to do so, and not all positions presented are mutually
compatible. No representation is made as to the accuracy or to the
suitability of information in this report for any purpose. Reliance upon
any information in this report is solely at the user’s discretion and no
person or entity associated with the TAC will be liable in any way for
resulting damages of any kind.

Additional FACA (Federal Advisory Committee Act) information is at the
Office of Government Policy web page at: http://www.policyworks.gov

Annex 2: Current Addresses TAC Members

Name    E-Mail Address

Barlik, Len    [email-masked]
Bellisio, Jules   [email-masked]
Boakye, Kwame  [email-masked]
Cerf, Vint   [email-masked]
Eslambolchi, Hossein  [email-masked]
Farber, David   [email-masked]
Ferren, Bran   [email-masked]
Goldberg, Larry  [email-masked]
Green, Richard    [email-masked]
Hatfield, Dale   [email-masked]
Hendricks, Dewayne  [email-masked]
Jackson, Chuck  [email-masked]
Jacobs, Ira   [email-masked]
Kahn, Kevin   [email-masked]
Kolodzy, Paul   [email-masked]
Kontson, Kalle  [email-masked]
Lapin, Gregory  [email-masked]
Liao, Paul    [email-masked]
Lucky, Robert   [email-masked]
Lynch, Richard  [email-masked]
Mundie, Craig   [email-masked]
Negroponte, Nicholas  [email-masked]
Newman, Stagg  [email-masked]
Personick, Stu   [email-masked]
Rappaport, Ted S.  [email-masked]
Reed, David P.  [email-masked]
Roberson, Dennis  [email-masked]
Setos, Andrew   [email-masked]
Shah, Nitin   [email-masked]
Skrzypczak, Casimir  [email-masked]
Warrior, Padmasree  [email-masked]
Wegleitner, Mark A.  [email-masked]
Zitter, Robert M.  [email-masked]

Annex 3: FCC staff

FCC staff associated with the TAC:

Edmond (Ed) J. Thomas, Chief of the Office of the Engineering and
Technology
    [email-masked]

TAC Designated Federal Officer (DFO): Jeffery (Jeff) M. Goldthorp,
Chief, Network Technology Division, Office of Engineering and Technology

    [email-masked]

Julius Knapp, Deputy Chief, Office of Engineering and Technology,
     [email-masked]

Bruce Franca, Deputy Chief, Office of Engineering and Technology,
    [email-masked]

FCC staff  available to address questions from the TAC:

General Issues:

 Jeff Goldthorp: Designated Federal Officer to the TAC
    Chief, FCC/OET/NTD
    [email-masked]
    Phone: 202-418-1096

            Kent Nilsson:  Alternate Designated Federal Officer and
Legal Advisor
    Special Counsel and Deputy Chief, FCC/OET/NTD
    [email-masked]
    Phone: 202-418-0845

 Young Carlson: Administrative Management
    [email-masked]
    Phone: 202-418-2427

Audio/Visual Center:
 Dann Oliver:  Manager
    [email-masked]
    Phone: 202-418 -0460

 Jeffrey Riordan: A/V Staff
    [email-masked]
    Phone: 202-418-0460

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