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Prepared Witness Testimony The House Committee on Energy and Commerce
The Spectrum Needs of Our Nation's First Responders.
Subcommittee on Telecommunications and the Internet
Mr. Stephen L Carrico
Mr. Chairman and honorable members of the Subcommittee: I am Stephen Carrico, Director of Communications and Business Development for Wisconsin Public Service Corporation, representing the United Telecom Council. I am a former UTC Chairman of the Board and currently serve as Chair of UTC's Homeland Security Steering Committee. I thank you for the opportunity to appear before you today to discuss issues of vital concern to all emergency responders. For 55 years, UTC has been the voice of electrical, gas and water utilities in matters relating to their voice and data telecommunications. UTC's several hundred critical infrastructure members range in size from multi-state organizations such as American Electric Power in the Midwest and Entergy in the South, to municipally owned utilities and co-ops operating in cities, towns and rural areas throughout the country. All of these companies own, maintain and operate mission-critical communications systems. Most importantly for purposes of this hearing, these include two-way land mobile radio systems on which we all rely for both routine and emergency communications. Critical Infrastructure Communications Affect Homeland Security All critical infrastructure industries are becoming increasingly dependent on information management and private internal communications systems to control and maintain their operations. A 2002 study by the National Telecommunications and Information Administration (NTIA), entitled, "Current and Future Use of Spectrum by the Energy, Water and Railroad Industries," makes very clear the extent of this dependency to meet essential operational, management and control functions. In fact, the physical components of the energy and water production, supply and delivery networks can be wholly intact but rendered virtually useless through control or incapacitation of these internal communications systems. An article in the Washington Post a year ago noted that Al Qaeda operatives spent time on sites that offer software and programming instructions for the distributed control systems (or DCS) and supervisory control and data acquisition (known as SCADA) systems that run power, water, transport and communications grids in the U.S. - so, too, should this aspect of critical infrastructure protection receive your serious consideration. All parties concerned with homeland security agree that one of the most important considerations is the availability of reliable communications for emergency responders. In this regard, there are three important issues which need to be addressed: 1) The critical players that require such communications include not only the first responders from the public safety community, but also the critical infrastructure enterprises such as power and water utilities which must provide a first line of defense; 2) We must ensure effective and interoperable communications between the communities of public safety responders and critical infrastructure enterprises; and 3) Government oversight of the communications facilities and services relied upon by public safety and critical infrastructure, which is now shared between the FCC and NTIA, must be streamlined to ensure effective protection from interference as well as interoperability. Emergency Responder Communications It is understood that the local and state police and fire personnel are among the first responders to an emergency, as well as emergency health care workers. But critical infrastructure employees - the emergency utility workers - are often overlooked as vital to any emergency response. Along with protecting life, the first order of business following a manmade or natural disaster is the restoration of essential public services, including water (to fight fires and ensure clean and safe supplies), gas and electricity (to restore heat, light and energy generation capabilities). These are the first services that must be brought back on line, so these workers are among the first personnel on the scene. Case in point: as soon as the magnitude of the 9/11 disaster became apparent, more than 1900 Consolidated Edison emergency workers were dispatched to Ground Zero to assist critical service restoration efforts and provide emergency communications capabilities to others on the scene. ConEd's two-way land mobile radio system was among the only communications available and was widely used during the first few hours following the collapse of the Twin Towers. In a more recent and more common example: so far this year, Consumers Energy of Michigan has been called on to respond to two major storms. On Thursday, April 3rd, an ice storm swept across Michigan's lower peninsula. Through the following day, a total of 425,000 customers were without power. Over 10,500 "wire down" calls were received. All available Consumers Energy crews and available contractors were put into the field, along with over 125 electric line crews from neighboring utilities. On Sunday, May 11th through Monday May 12th, strong winds in excess of 50 miles per hour hit Lower Michigan. Electric service to 101,000 customers was disrupted. Over 2,200 reports of down wires were received and resolved. Responding to these storms required massive communication resources. All work was coordinated via the Consumers Energy 800 MHz trunked radio system. Only by having a reliable, private two-way radio system is Consumers Energy able to adequately respond to such emergencies. Critical infrastructure entities use the same kind of radio equipment as Public Safety agencies, and as fellow emergency responders, we understand their communications needs better than any other industry. The most important aspect of our radio systems is reliability -- utilities build their systems for 24-7 and "five 9s" operation. The job of an electric lineman until recently was considered the most dangerous in the nation - these crews rely on their radios just as police and fire personnel do. And one element of reliability beyond that of traditional public safety: our radios must work, wherever our crews go, when the power is out. During any kind of manmade or natural disaster, you will see police, fire, utility and other emergency personnel on the scene at the same time. Any discussion of emergency interoperability must include critical infrastructure if the United States is to have an effective system. The White House has recognized this fact and has urged UTC's inclusion in energy, water and telecommunications sector work on Homeland Security. Local Efforts Toward Interoperability Congress recognized the importance of our systems in 1997, when you included utilities, pipelines and other critical infrastructure among "public safety radio services:" those private systems that provide support to such vital systems that entities operating them should have access to spectrum without obtaining it via auction. Since then, critical infrastructure has not sought access to existing public safety spectrum; however, the FCC has not made a separate allocation to non-public safety private wireless since 1985. Therefore, UTC and its members have looked for opportunities to bolster interoperability among all emergency responders by other means. The most effective means on a local basis has been through shared radio systems, and there are dozens of these throughout the country. Many of them have been built by utilities, because we often can get the system funded and into operation faster than public safety agencies. And - we build our systems so they work when the power is out. Just a few examples of shared systems: Gainesville, Florida, where Gainesville Regional Utilities has built and maintains a non-profit, shared 800 MHz system. Local public safety agencies use this system as low-cost subscribers. There are many municipalities, as throughout the Philadelphia metro area, where local utilities and public safety agencies share a common radio system owned by the local government. In Mississippi, Alabama, Georgia and the Florida Gulf Coast, Southern Company has built a commercial 800 MHz system to utility standards, making it attractive to thousands of public safety users, as well. A system like Southern's is the only form of commercial system appropriate for mission-critical communications, since utilities must have complete coverage of their service territories, as well as guaranteed reliability at all times. No consumer-oriented commercial wireless provider can afford to offer service to this standard, nor do commercial systems continue to function during power outages of any duration. However, these shared systems are only local attempts to solve interoperability problems, and the United States needs a nationwide solution so that all emergency responders can communicate with each other. We offer our expertise to help reach this vital goal. Critical Infrastructure Has No Dedicated Spectrum Unlike traditional public safety, the critical infrastructure industries have no designated spectrum for their own use, and we suffer from increasing congestion and interference on the bands we share with millions of other non-public safety private wireless users. We have requested a small, exclusive allocation of six to ten megahertz, on which we propose to construct a nationwide system. This system would be interoperable among the multiple utilities that always respond to regional emergencies, and would be made available to traditional public safety, federal agencies and others through additional equipment, or as part of a network of networks. While it is understood that spectrum is a scarce resource, homeland security initiatives should consider an exclusive allocation of spectrum to critical infrastructure for the establishment of a nationwide emergency communications network. This would achieve three objectives: 1) economies of scale would drive down the cost of equipment; 2) efficient spectrum use would dictate the use of this spectrum on a day-to-day basis for critical infrastructure operations support, while entities would be responsible for maintaining the emergency network; and 3) emergency response capability would be served by all response agencies having immediate access to fully operational communications equipment, priority access and a fully interoperable network when the need arose. A very good home for this system would be on the 700 MHz band, on spectrum adjacent to the 24 MHz allocated to public safety. UTC includes an overview of this proposal in our written statement. Thus, in answer to the subcommittee's question of whether public safety has enough interference-free spectrum for interoperability, this segment of "public safety radio services" does not, and emergency responders as a whole will not be interoperable without critical infrastructure. However, we are ready and willing to help all parties reach this goal. The FCC's 800 MHz Proceeding Hundreds of mission-critical utility radio systems are operated on the 800 MHz private land mobile radio (PLMR) frequency band. Such systems are of varying age and technological sophistication, from analog conventional use to advanced digital systems that incorporate voice and data transmissions. Several utilities are deploying such advanced systems across wide areas, with expectations of using them for, not only routine and emergency field communications in support of service and power restoration, but also for key telemetry systems that actually control the nation's power and water infrastructures. Because of the ability to use frequencies exclusively within a licensed area, coupled with the variety of equipment manufactured, the 800 MHz band is probably the most important PLMR band currently available for critical infrastructure communications, especially for entities seeking to deploy more advanced technology. 800 MHz interference is not only a public safety problem. Many UTC members operating on this band also have suffered interference, almost exclusively from Nextel's system. Prime examples are Union Electric in the St. Louis, MO area and Consumer's Energy in Michigan, which have had to resolve a number of interference problems; they have done so through use of engineering solutions such as those found in the "Best Practices" guide. However, interference resolution alone is not enough. UTC is a leading member of the 800 MHz User Coalition, which has submitted an alternative position to Nextel's. More than 30 parties, including several trade associations, individual critical infrastructure entities, small commercial carriers, the cellular industry and some public safety agencies, have already signed on to the Coalition document, filed on May 29, 2003, and more are added daily. Statements by Nextel and its supporters that its "consensus" plan is supported by a vast majority of affected licensees are simply untrue. The User Coalition stresses that interference to all user systems must be resolved, at the cost of the interfering licensee - and that future interference must be prevented through improved engineering practices, as well as regulatory flexibility that enables "channel swaps" and shared systems. Mandatory rebanding is an inefficient, overly expensive and ultimately, ineffective solution, since interference would still be present at the end of the process. Moreover, rebanding to "separate" compatible systems from incompatible ones only freezes a moment in time: these systems are not static, and migration to better technology will change the landscape again within a few years. However, in spite of FCC policy directions in favor of better spectrum efficiency, less detailed regulation and market-based solutions, the Nextel plan would require a massive, four-year (at the minimum) reshuffling of the entire band placing all licensees in restricted space, and resulting in only Nextel being able to deploy advanced technology and better spectrum efficiency. To many utilities already building digital wide-area systems for themselves and their communities, this is unacceptable. UTC and dozens of our member companies have opposed the Nextel plan consistently, as have many public safety agencies. Such restrictions only scratch the surface of the User Coalition parties' concerns about the Nextel "consensus" plan: there are serious questions about the FCC's authority to implement the plan, and challenges are likely should it be adopted. This band is too important to all its users; the solution for interference must be one that keeps it fit for the future of all of those that depend upon it. ATTACHMENT A PROPOSED PROCEDURES FOR INTERFERENCE MITIGATION IN 806-824/851-869 MHz BAND I. Procedures to Identify and Avoid Incidences of Interference in the 806-824/851-869 MHz band. Any licensee wishing to install a new antenna in the 851-869 MHz band at height of less than 30 meters AGL ("low-site transmitters") shall notify co- and adjacent channel licensees within the protected service contour (via filing at the FCC in ULS or an alternative database) and appropriate frequency coordinators 30 days in advance of the installation of the site providing the following information:
II. Procedures to Address Identified Interference Problems A 806-824/851-869 MHz licensee receiving interference will immediately notify any suspected interfering low-site system operator or operators of the problem by:
The Complainant shall identify:
All licensees receiving notice of complaint via the website shall respond within two business days and shall confirm whether they have systems operating within 5,000 feet of alleged site of interference. On-site analysis: The Complainant shall contact the potentially responsible contributors to the interference to arrange for an on-site analysis to take place within five business days (or later at the discretion of the complaining entity). The Complainant and all potential contributors shall support the analysis effort. Mitigation steps:
The Complainant shall have a duty to cooperate in the implementation of the most cost-effective solution. If an agreement between the parties is not reached within 60 calendar days after receipt of the written notice of interference, any affected party may submit the matter to the FCC for resolution. The FCC shall order appropriate steps to resolve interference in the most efficient manner, including by such means as specifying the transmitter power, antenna height or frequency, or requiring other changes in operation or equipment to correct the problem. ATTACHMENT B TECHNICAL RULE MODIFICATIONS The following technical rules, in addition to the requirement, described above, that interfering licensees correct their interference, should be adopted as part of the effort to resolve interference through improved mitigation techniques. The FCC should:
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