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Jeff Cohen, chief counsel for the Association of Public-Safety Communications Officials (APCO) International, explained in his testimony that the 6 GHz band is used for a variety of critical services. “Public safety uses the 6 GHz band mainly as backhaul for 9-1-1 dispatch and first responder radio communications, which is especially important in rural areas where the alternative to microwave would be prohibitively expensive or impractical fiber deployment, if it is even available,” he said.

Cohen, one of eight witnesses who testified at the hearing, said the prospect of sharing this band comes down to two questions — the potential for interference and whether a sharing mechanism can be reliably demonstrated in advance to ensure that there will be no interference to public safety.

Concerning the potential for interference, the unlicensed community — which includes Google, Facebook and other wireless and online heavyweights — submitted technical showings that do not appear to fully appreciate the real-world implications of the deployment of hundreds of millions of unlicensed devices, or the fact that public-safety microwave links are designed to ensure high reliability and availability — a downtime of no longer than 30 seconds per year, Cohen said.

“APCO remains unconvinced that there is any way unlicensed devices could share this spectrum without being required to use some form of an automated frequency coordination mechanism,” he said. “Additionally, any automated frequency coordination system must undergo substantial testing and be proven in advance to be effective at preventing interference to public-safety communications. Further, public safety must be assured that any interference that does occur will be rapidly resolved.”

Cohen said that the spectrum bands housing public-safety operations are not the appropriate arena to deploy new, unproven spectrum sharing and frequency coordination methods. “Fixed service systems such as those relied upon by public safety for mission-critical communications are not designed to detect interference and are incapable of attributing it to a particular source,” he said. “Thus, it is important to be especially mindful of the fact that if the sharing mechanism fails, or consumers or equipment manufacturers disable or misuse the interference protection mechanisms, there is no way to reverse the resulting interference. There will be hundreds of millions of unlicensed devices out in the stream of commerce, and should interference occur to public-safety microwave (which we must assume will occur), it will be very difficult if not impossible to identify and stop the interfering device. Worse, public safety will have no alternative communications path. That would mean the irreparable loss of communications critical to public safety.”

Julius P. Knapp, chief of the FCC’s Office Of Engineering and Technology, addressed 6 GHz and public safety in his testimony, implying the commission is aware and working on technical analysis for the band.

“This spectrum is particularly well positioned for the expansion of the Wi-Fi spectrum that is already available in the 5 GHz region,” Knapp said. “This spectrum is heavily used by utilities, public safety and commercial wireless providers for point-to-point microwave services, as well as by others. We’re working through some complex technical issues, both internally and with outside stakeholders.”

“While there are critical incumbent services in this band that must be adequately protected, this band includes 1,200 megahertz of spectrum that should be investigated for potential unlicensed and licensed use,” said Scott Bergmann, CTIA senior vice president, legislative affairs.

APCO’s Cohen also used the hearing to address the UHF T-band spectrum at 470 – 512 MHz.

“… Given everything that would have to be set into motion, including all the actions the FCC would need to take, and with nowhere for public safety to move to, the right thing to do is for Congress to repeal this provision,” Cohen said to lawmakers. “There would be no budgetary impact with repeal. Further, there has been little if any interest expressed by potential bidders for this spectrum, making the prospect of any new spectrum efficiencies or significant auction revenue slim, contrary to the typical goals of spectrum auctions. Further, it remains APCO’s position that it would be unfair to ask public safety for anything in exchange for repeal of this provision.”

Finally, Cohen addressed 5G and its benefits to public safety. He noted how a 5G hot spot inside a building could provide highly accurate indoor 9-1-1 dispatchable location-quality data and improve wireless emergency alerts.

“if we don’t upgrade the nation’s 9-1-1 systems, 5G will never reach its full potential,” he said. “While 5G technology will tremendously enhance the communications capabilities of the general public and first responders, it will only further widen the gap between those capabilities available to the public and what’s possible for 9-1-1. Unless we modernize the 9-1-1 system, all these innovations are lost at the door of the 9-1-1 center.”

Cohen’s full testimony is here.

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