An international consulting firm has called the Federal Communication Commission's proposed public safety network "so fraught with uncertainties, problems, and the potential for conflict" that it is unlikely to perform as intended.

RCC Consultants [2]' 126 page critique of the FCC's Ninth Notice on the 700 MHz Band says that one of the central points of the proposal—letting the network lease broadband spectrum to commercial companies—goes against Federal law.

The FCC plan fails "to establish broadband services that have as their sole or principal purpose the protection of life, health or property;" RCC's February 15th filing charges. The firm provides wireless support to state and local governments.

On December 20th, 2006, the FCC launched a Notice proposing [2] a national public safety communications services provider that will operate almost 250 video and broadband channels, and be allowed to access hundreds more under certain conditions.

The network will be run by an entity that charges on a fee-for-service basis, even permitted to market spectrum to other companies "through leases or in the form of public/private partnerships."

RCC's filing says that

• The FCC national broadband plan rests on unproven technology. The FCC's Ninth Notice suggests that a proposed national public safety entity could finance itself by leasing unused broadband to commercial firms that use "cognitive radios" that detect "white space"—temporarily unused TV signals. These companies would buy such access knowing that in the event of a public emergency they would immediately be booted off the air.
  But RCC questions whether this technology can be trusted, specifically whether spectrum being used for commercial purposes can be restored to public safety purposes on a "near-instant" basis.
  "While cognitive radios employ a technology of promise," the firm writes, "there is no consensus that cognitive radios can now or in the near future provide the required ultra-reliable near instant access by the national licensee. It seems, therefore, that the entire superstructure of the Commission’s Public Safety Broadband Proposal ultimately rests upon one rather weak reed."
• The FCC proposes "the establishment of a monopoly" that will not be able to tackle the nation's public safety interoperability problems. "Freed of competition and the availability of choice on the part of customers, monopolists have no history of prompt, effective, customer-driven actions," RCC argues.
  The proposal also largely excludes regional and local groups from input into the new network, "except for their role as users on a fee for service basis," RCC contends:
  "This derogation of the role of regional communities imports the risk, and possibly the certainty, that the national public safety broadband network proposed will not meet state, local, and regional needs whether because of deployment issues, coverage issues, cost issues, or otherwise."
• The FCC plan violates Federal law. RCC cites Section 337(f) of the Communications Act, which defines the term “public safety services" as services "the sole or principal purpose of which is to protect the safety of life, health, or property," and that are provided by State or local governments, or nongovernmental organizations.
  The FCC exceeds its legal authority, RCC argues, "by proposing to license an entity which is neither a state or local government entity nor a nongovernmental organization that is authorized by a government entity whose primary mission is the provision of public safety services;"
• The FCC proposal goes against the weight of opinion in previous public safety comment cycles. Most FCC commenters on this issue, RCC asserts, have not filed in support of the "monopoly" model the Commission now proposes, but have favored networks developed on a regional or local basis, coordinated by so-called "Regional 700 MHz Planning Committees" (RPCs).
  While the FCC's stress on a broadly interoperable system is important, RCC observes, "time and experience are required for public safety users to define their interoperability requirements in relation to data, and broad premature prescriptions respecting data interoperability are not helpful."

The firm concludes its comments by asking the FCC to develop "a bottom-up rather than a top down approach to the development of wideband and broadband public safety networks."

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