An Opportunity for Open Source and Open Standards At the FCC
An Opportunity for Open Source and Open Standards At the FCC
An Opportunity for Open Source and Open Standards At the FCC

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    As some readers may know the FCC has launched a proceeding on a national public safety band. You can find the Notice of Proposed Rulemaking here. I believe this provides an opportunity to push for greater use of open source and open standards in the public safety world — a move which could significantly lower costs and enhance interoperability.

    You can see some basic background on this rulemaking and some of the politics behind it on my other blog. To summarize what's relevant here: in 1996, Congress allocated 24 MHZ of spectrum for public safety out of the returned analog spectrum after the completion of the digital transition (an to auction the remaing 60 MHz). In subsequent rulemakings, the FCC determined it would take 12 MHz for a voice and 12 MHz for “data.” It divided the 12 MHz for voice into licenses and to distribute among the public safety community on a geographic basis, and proposed doing the same thing for the 12 MHz of data.

    Recently, however, because of the interest in the Cyren Call proposal, the FCC has decided to reexamine whether to take the 12 MHz designated for data and use it for one, national licensee that would partner with the public safety community and provide a national broadband network. As with the Cyren Call proposal, the private party could lease the excess spectrum to finance the network and turn a profit (as a producer incentive).

    Lets leave aside the question of whether or not a single national band or a public/private partnership is the right way to go and instead step back on the larger question. What can the FCC do to drive down the cost of public safety equipment and to enhance interoperability — in a way that does not impose a huge uncompensated cost on the existing public safety licensees (who are not exactly rolling in dough)?

    One answer, applicable here, is to require that any licensee in the band must use equipment which operates under open standards and for which the necessary source code is available to all interested developers under the General Public License. Other refinements to address the problems of blakinization and lock-in are likewise, in my opinion, appropriate.

    Why does this matter? A key problem in the public safety world (or communications world generally) is the expense of equipment and the lack of interoperabilty between different equipment systems. It's not enough that services on different frequency bands cannot communicate. It is also the case that services on the same band cannot easily communicate effectively because they run different sets of proprietary protocols.

    This is a deliberate and rational choice of equipment providers. As a service/equipment provider, you want to lock in customers to your technology, require them to buy everything from you, and require them to pay a huge hourly rate for any consulting/debugging. As an added bonus, if you capture a sufficient percentage of the market, you can hope to become the de facto standard by shear force of market power so that even if everyone must adopt a common standard, the common standard they adopt is yours.

    Which is why, absent any other consideration, you as a manufacturer don't want your system to interoperate easily with other systems. Yes, that feature increases the utility to the user, which is a big draw to purcahsers. But it also increases the ability of users to switch to another service. Worse, if the vendors are all using their own proprietary systems, the negotiations among vendors to achieve interoperability becomes complex, with “compensation” based on which party is succesful in persuading the other that the other should pay for the privilege of compatibility to “compensate” for potential lost customers. Yes I know (and believe) the counter argument that because it is a mutual and equal benefit to both parties interoperating, that the idea of one “compensating” the other is rather ridiculous and arbitrary. But in a free market the parties are supposed to come to that rational, enlightened decision on their own.

    Not only does this end up interfering with interoperability and driving up cost, it also denies manufacturers the benefits of economies of scale. The public safety market starts small enough already (when compared with something like the general enterprise market or the consumer products market). So we further subdivide it into different sectors (police, fire, EMT) and then subdivide it again by having vendors fight it out for market segments. Small wonder the cost of equipment is ridiculously high.

    As a side note, I would add that it should also require any private partner reselling wireless broadband to the public to operate under principles of network neutrality. But even without the public/private aspect, open stanndards and open source can do much to enhance interoperability and drive down cost.

    The FCC has the power to regulate licensees and equipment manufacturers. It can require open standards and that equipment manufacturers make available the code to operate such devices under the GPL. If the Commission really wants to create a national band for the express purpose of providing cheap, interoperable broadband to all public safety entities, then preventing a repetition of the usual standards fights and squables over equipment seems a good place to start.