Public safety doesn’t need more spectrum

Ahead of tomorrow’s Senate Commerce Committee hearing on public safety communications, the Consumer Electronics Association released a report (PDF) it commissioned from Criterion Economics analyzing the Cyren Call plan. The report concludes that the Cyren Call plan would upturn Congress’s carefully crafted DTV transition scheme. It also calls into question whether the private sector would build a more expensive broadband network than it would otherwise have to in order to meet the more rigorous needs of public safety.

Like I said, the study was commissioned by a special interest and it should be read in that light. (And by all means, read it yourself and make up your own mind.) However, the study does outline some basic facts that support something I’ve been saying for a long time: public safety communications does not need more spectrum, what it needs is spectrum reform. Here’s a sampling from the report:

The federal government has allocated 99.7 MHz of spectrum for use by state and local public safety agencies. Of this total, less than 17 MHz of spectrum (in the frequency bands between 150 and 869 MHz) is currently used to support the vast majority of public safety’s current communications systems. More than three-quarters (76.5 MHz) of the spectrum allocated to public safety has been allocated since 1996 and is not yet widely used. …

To put this information in perspective, public safety has been allocated spectrum (99.7 MHz nationwide) that exceeds the spectrum holdings of any U.S. wireless operator, including Cingular (which averages 52 MHz nationwide), Verizon (which averages 40 MHz nationwide), Sprint Nextel (which averages 50 MHz of cellular/PCS spectrum and approximately 70-80 MHz of BRS spectrum in the 2.5 GHz band), and T-Mobile (which averages 25 MHz nationwide). Yet, it currently uses 20 percent or less of this spectrum for the operation of emergency communications systems.

The report goes on to state that the private sector uses spectrum much more efficiently. The wireless carriers, on average, serve about a million customers for each MHz of spectrum they have. On the other hand, only 20,000 to 30,000 first responders will be served per MHz of spectrum licensed to public safety. Obviously this isn’t an apples to apples comparison because public safety has different needs, but such a big difference has got to give you a clue about who’s using spectrum efficiently and who’s not. As I point out in my recent paper, public safety doesn’t have the incentive to use spectrum efficiently:

The cost of spectrum to a public safety agency is measured not by what it paid for the spectrum, which is nothing, but rather by its opportunity cost–i.e., the loss of a potential benefit from other alternatives uses of the spectrum, such as gaining income by selling it or leasing excess capacity. As we have seen, the spectrum cannot be traded and it can only be used for public safety communications. This policy in effect insulates public safety agencies from the true opportunity cost of spectrum. …

Carnegie Mellon engineering professor Jon Peha has calculated that the number of antennas deployed by public safety entities nationwide correlates less with population or geographic area than with the number of political jurisdictions. This means that more antennas are put up, and more spectrum is used, than is necessary to cover an area simply because local agencies and jurisdictions do not coordinate to share antennas and spectrum. Peha also points out that “the number of antenna towers, base stations, and repeaters used by a public safety agency are largely independent of the number of responders using that agency’s wireless system where this number does not exceed 100, and 85% of US public safety agencies support no more than 100 users.”

In contrast, a commercial network operator will not employ more spectrum or equipment than necessary to produce a given amount of communications capacity at a certain quality level. Commercial management of spectrum has been shown to be consistently more efficient than government management. Unlike public safety users, commercial carriers have an incentive, as well as greater freedom, to combine into larger and more efficient networks. Public safety agencies do not have the same incentives because they do not face the true cost of spectrum.

For example, as the price of a good decreases, its consumption increases. Because public safety agencies are faced with an artificially low opportunity cost they will be induced to use more spectrum than would otherwise be efficient and therefore waste spectrum. In contrast, public safety agencies face correct opportunity costs when it comes to patrol cars and guns. Instead of direct gun or car subsidies, police departments are given budgets that they then use by weighing the money’s alternative uses. Faced with alternative uses for a budget, a police department will presumably not buy more guns or cars than it needs or can use.

What I hope this tells you is that public safety does not need more spectrum, what it needs is reform that changes how the spectrum already allocated to it is used. Letting commercial entities offer public safety communications might be the ticket, but there’s plenty of spectrum already allocated for public safety over which to do it.

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