Frontline’s Plan Attacked, Bolstered Using ‘Market’ Forces
Frontline Wireless used the same argument -- market forces -- as its opponents in the reply comment round of the 700 MHz band auction and service rules. Frontline said requiring wholesale arrangements is one of the market incentives that will benefit public safety.
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The possibility that a new start-up like Frontline could go belly-up, a market outcome, was prevalent through many of the replies both from those supporting a public-private partnership and from opponents. The Frontline proposal of excluding incumbents, requiring wholesale and open access suggest “that such a service may not be financially viable…,” said Arcadian Networks, a 700 MHz guard band licensee. “The Commission should not conduct an experiment with the valuable E-block spectrum, particularly if our nation’s first responders are going to rely on it.”
Since Frontline’s open-access wholesale model is untested, Cyren Call and the Assn. of Public-safety Communications Officials (APCO) told the FCC, it needs to install safeguards. If the E-block auction winner is a start-up, the FCC should ensure that the auction winner has a workable business plan before awarding the license, Cyren Call said: “Like the situation when a contractor wins a home repair job based on a low bid, and then discovers that he must either reduce his scope of work or request more money, neither public safety nor the E-block winner will be well- served if the auction price is inflated based on the winning bidder’s failure to understand the true cost of the undertaking.” And all negotiations regarding the network- sharing arrangement between the E-block auction winner and public safety should be wrapped up before the license is awarded, Cyren Call said.
APCO rejected large incumbent wireless carriers’ contention that public safety has enough spectrum. “What these and other parties ignore is that public safety alone cannot afford to build a broadband network,” it said. Public safety doesn’t have the money to build a nationwide, interoperable next-generation network, it said. The prospects are slim for legislation to give public safety more money, APCO said.
The FCC shouldn’t rely on promises from the established wireless carriers that market forces will push the wireless industry to build a nationwide interoperable public-safety network, Cyren Call said: “The Commission must not allow itself to be lulled into reliance on commercial mobile radio service claims that this time will be different; this time it will solve public safety’s communications requirements.”
Public safety’s interests must be protected, APCO said, adding that if the E-block winner is an established carrier, “the rules must ensure that the carrier does not simply offer access to its existing commercial network.”
Frontline said that if the FCC rejects the company’s proposal, the Commission would be “maintaining or more accurately cementing, the status quo by allocating the spectrum in the usual manner for it to be acquired by deep- pocket incumbents with a history of indifference to public safety’s needs and a business strategy and motivation that resist competition and innovation.” Requiring carriers to structure their businesses “based on rules directed a furtherance of particular objectives for broadband Internet access” would be inconsistent with the FCC’s “flexible-use philosophy,” AT&T said.
To blunt the strict geographic buildout requirements favored by some on the Commission, CTIA offered a proposal based on population targets. Licensees would be required to cover 1/3 of the license area population within 5 years and 3/4 within 10 years. If a licensee missed the first benchmark, it would have only 3 years to meet the 3/4 threshold. If a licensee failed to meet the 3/4 threshold, it would lose the spectrum in its uncovered area. This plan would avoid “the multiple problems associated with geographic requirements,” said CTIA.
A suggestion by Mobile Satellite Ventures to embed satellite chips in public-safety radios deserves more attention, said APCO. The chips need to be available “in sufficient quantity at minimal cost to avoid delays in equipment development and deployment,” it said. MSV also must clarify whether the chipsets would give public safety access to more than one satellite provider, said APCO.
APCO attached to its comments an AP article discussing the lack of cellphone and landline service after the devastating tornado in Greensburg, Kan. The article reported problems at all the major cellphone carriers. Emergency responders had some satellite phones, AP reported.