Update: Comment Deadlines Set in DACA Inquiry

Last month we reported on an Inquiry initiated by the FCC with respect to implementation of Deployable Aerial Communications Architecture (DACA) techniques. Those techniques include use of small unmanned aerial vehicles, weather balloons or high altitude long distance unmanned vehicles to restore communications capabilities in disaster situations. The Notice of Inquiry has now been published in the Federal Register, as a result of which the comment deadlines have been set. Comments are due by July 25, 2012, and replies are due by August 14.

Up, Up and Away: In NOI, FCC Is High on DACA

Commission seeks input on Deployable Aerial Communications Architecture techniques.

When communications fail in the midst of a disaster, who can you call? Trick question: most often, you can’t call anyone because, as the question assumes, communications have failed.

But the Commission has now taken a preliminary step toward addressing the problem that gives rise to that assumption: as we predicted last year, the FCC has released a Notice of Inquiry (NOI) looking toward implementation of Deployable Aerial Communications Architecture (DACA) techniques. 

DACA techniques are designed to assist, in emergency situations, with the restoration of communications not just to first responders, but also to consumers.  Think small unmanned aerial vehicles (SUAV), weather balloons, high altitude long distance unmanned vehicles (HALE), and deployable suitcase systems.  The idea is to come up with gear that can be deployed during the first 72 hours after a disaster to help ensure communications capabilities without requiring deployment of special user devices. 

The Commission has already sought public comment on DACA, from which the Public Safety and Homeland Security Bureau prepared a White Paper on the subject.  The NOI is the next procedural step through which the FCC is looking to develop a record on which to base a set of DACA regulations.

As might be expected, the NOI is short on any detailed proposals, but very long on questions about virtually all aspects of DACA.  The Commission is looking for information about: operational/technical details; availability of equipment; previous experience (particularly on the part of the military, which has successfully deployed DACA in a number of emergency scenarios in which infrastructure was unavailable); deployment/cessation criteria; international coordination considerations; and potential licensing mechanisms (e.g., license, temporary authority).

The FCC is also particularly concerned about the potential for DACA-based service creating interference to services that may remain operational despite catastrophic circumstances.

It seems clear that the Commission is convinced of the potential utility of DACA.  But as they say, the devil is in the details. Responses to the NOI should help the FCC craft rules to facilitate maintaining critical services during emergencies, without causing interference to whatever services have managed to survive. We can be confident both that emergencies will continue to occur and that prompt resumption of communication services during those emergencies will be a matter of the highest priority.  If DACA techniques can help in such situations, the sooner the Commission gets a firm handle on those techniques and devises an appropriate regulatory approach to them, the better. The deadlines for comments and reply comments in response to the NOI have not yet been established.  Check back here for updates.

Trial Balloon: FCC Looks Skyward for Disaster Relief

Staff-written white paper explores airborne technologies to maintain communications in the face of major disruptions.

The sequence is predictable: first the disaster, then the finger-pointing over the failure of emergency communications. We saw it on 9/11, Hurricane Katrina, and even the eventful Mineral VA earthquake, the one that toppled plastic lawn chairs miles away.

Now the FCC has issued a white paper aimed at solving the problem of communications in the aftermath of a disaster. The new acronym is DACA, for “Deployable Aerial Communications Architecture”: a set of techniques for hoisting a communications system to an altitude suitable for relaying signals. The paper mentions four specific approaches.

  • Small unmanned aerial vehicles: hand-launched, battery-powered aircraft that fly at an altitude of about 500 feet. Think of those model helicopters they sell at the mall, but bigger.
  • Weather balloon technologies that can carry a six-pound repeater package, although only for short periods of time.
  • High altitude long distance unmanned vehicles that can operate for longer durations with heavier payloads. 
  • Deployable “suitcase systems” that use pre-packaged portable transceivers loaded onto low-flying aircraft.

The white paper, though, leaves a lot of questions unanswered. The biggest omission, to us, is a failure to mention that none of the proposed DACA systems would operate on its own. Each of the options, rather, is a mechanism for relaying communications from the ground. But those ground-based communications in turn must depend on the same facilities that are vulnerable to damage, flooding, or power failure. The white paper does mention the importance of satellite communications in disaster scenarios, but satellite systems likewise merely relay signals between ground-based earth stations. Thus, even with DACA in place, communications systems remain vulnerable.

Also missing from the white paper is any detailed discussion of frequencies DACA systems might use without causing interference to whatever terrestrial systems remain operating. And we hope that future work acknowledges the important contributions of amateur radio operators to post-disaster communications, with provisions to improve the reliability of their efforts.

The white paper does contain an interesting new idea.

Past discussions of communications following a disaster have focused mostly on the needs of first responders. Here, though, the FCC, while mentioning the need for uninterrupted public safety communications, also seeks to maintain consumer services such as cellular, Wi-Fi, and Internet. This would allow the public to stay in touch and informed, notwithstanding major hurricane or earthquake damage – although some of the public we know will take the opportunity to keep up with Facebook updates and watch funny cat videos, even while the storm rages and the earthquake rocks the foundations.

The FCC took the release of the white paper as an opportunity to expand its toy room.   Exhibits there during September include DACA equipment, along with “command and control” solutions and situational awareness devices, and vehicle mounted platforms for public safety communications. (While the FCC’s announcement of the display of this gear includes the obligatory fine-print disclaimer that inclusion in the display does not constitute Commission endorsement of any particular device, more prominently in that announcement we are told that the display “showcase[es] a range of state-of-the-art tools”, including the “latest” in certain types of devices.)

The next step in developing these ideas will be a Notice of Inquiry that asks the public what issues the FCC should consider in moving toward implementation. That will be a key step. A lot of seemingly good ideas break down when it comes to specifics. We look forward to seeing whether DACA can survive the transition from rough outline to operational details.