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PCIA Agrees

FirstNet’s Success Depends on Roaming, Industry Partnerships, APCO Says

When it is built, FirstNet must take advantage of commercial infrastructure and “public/private partnerships,” the Association for Public-Safety Communications Officials said in a filing at the NTIA, dated Thursday, which has not yet been posted by the agency. But APCO gave a thumbs down to any proposal built around a partnership with a single national wireless carrier. PCIA - The Wireless Infrastructure Association, meanwhile, stressed the role commercial infrastructure must play in support of the national public safety network.

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The FirstNet Board had asked interested parties to comment on a presentation on the conceptual network architecture made at the FirstNet board meeting Sept. 25 by board member Craig Farrill (CD Nov 1 p1). Farrill laid out three options: building a standalone network, working with a national carrier, or working with multiple wireless networks and systems. NTIA Wednesday delayed the due date for filings for a week until this Friday because of Hurricane Sandy, but a number of key players submitted comments by the original deadline.

Building a network in cooperation with a single nationwide carrier would be “unwise,” APCO said. “APCO strongly favors an approach that underscores the need to create a diverse nationwide network with multiple wireless networks and systems,” the group said. “FirstNet needs to also leverage deployable ‘micro’ networks as well as the infrastructure owned by rural telecom companies, rural electric cooperatives, electric utilities, and federal, Tribal, state and local governments. Further, APCO agrees that FirstNet should consider incorporating mobile satellite networks into the overall design to maximize network coverage."

APCO also stressed the importance of roaming as laid out in the February spectrum law establishing FirstNet. “While not an ideal solution, roaming onto commercial networks will provide public safety with immediate access to commercial service -- including LTE where available -- either until the public safety broadband network is built out, or to serve as a redundancy option if the nationwide network is unavailable or congested,” APCO said. “Until either the public safety broadband spectrum is fully built out, or roaming agreements are executed with multiple service providers leading to devices with multiple carrier bands, interoperability can be achieved at the 3G or earlier level."

Priority access rules are also critical to a successful network, APCO said. “Public safety would benefit from priority access service agreements, which are especially important during emergencies when all networks experience high congestion levels,” the group said. “Additionally, FirstNet should ensure that, when roaming, emergency responders can remain in communication with the dispatch center.”

PCIA emphasized the key role industry must play in helping build a national public safety broadband network (PSBN) (http://xrl.us/bnxnpy). “FirstNet should partner with wireless infrastructure providers to draw upon their years of experience to plan and construct the PSBN. This public-private partnership would immediately benefit the PSBN,” PCIA said. “First, the PSBN could leverage existing infrastructure to maximize its coverage and performance because commercial wireless sites already cover 98% of the Nation’s population. Second, such partnerships would quickly bring the PSBN up to operational capacity by allowing collocation of PSBN equipment on existing wireless infrastructure.” Partnerships would also lower the costs of building a network “by taking advantage of the significant cost savings associated with the use of existing facilities,” the group said. “If FirstNet’s goal is to construct the PSBN swiftly and efficiently, it should take advantage of the purpose-built towers, rooftop installations, distributed antenna systems, and small cells that the wireless infrastructure industry has worked hard to deploy."

The National Public Safety Telecommunications Council said it is preparing a “Statement of Requirements,” due by year-end, which should be helpful to the FirstNet Board. “NPSTC recognizes that FirstNet has a daunting task to design and implement the Nationwide Interoperable Public Safety Broadband Network,” the group said (http://xrl.us/bnxnrb). “As highlighted on numerous occasions during the last 6 years of regulatory and policy discussions anticipating the actual availability of the public safety broadband network, public safety has more stringent communications requirements than those typically provided by commercial networks for the general consumer population. ... NPSTC believes that FirstNet obviously will need to go beyond the high level framework presented at its first meeting in deciding the most appropriate path to take to meet those needs."

States focused on FirstNet’s need for better state partnerships, the halted local public safety projects around the country, the leveraging of commercial networks and the network’s potential cost in their comments. These filings along with other planning documents show widespread preparation and debate.

Seven states addressed “broader threshold issues" facing the network’s “Herculean effort.” The national network will need to develop a clear budget to “enable State leaders with responsibility for budgetary and network operations matters to understand and plan for the costs and capabilities of the PSBN within the appropriate timeframe,” said Idaho, Montana, Nevada, Oregon, South Dakota, Utah and Wyoming in joint comments (http://xrl.us/bnxnfp). States will need to develop their own budgets and perhaps pass laws to fit FirstNet, they added. It’s critical that FirstNet looks into generating revenue from spectrum leasing and user fees, they said. FirstNet also needs to kickstart deployment in “those States that are funded and ready to proceed with interoperable network assets,” the state commenters said. NTIA suspended seven Broadband Technology Opportunities Program grantees’ public safety broadband initiatives in May out of fears over incompatibility and waste (CD Sept 24 p18). The projects, located in Charlotte, N.C, the San Francisco Bay Area, Adams County, Colo., and elsewhere, have been in limbo since suspension. NTIA and FirstNet should “remove the hold on funding for those BTOP projects immediately,” the states said.

These seven BTOP grantees haven’t been idle. There has been an “exchange of letters” between BayRICs and FirstNet, BayRICs Interim General Manager Barry Fraser told us. “They see value in these early projects,” he said, despite what he calls no timeline or true direction. “We're waiting to see.” BayRICs staff “is also working with the six other BTOP public safety grantees to set up meetings with FirstNet,” Fraser told the Bay Area Urban Area Security Initiative Approval Authority in a Nov. 8 dated report (http://xrl.us/bnxniw) published in advance of the authority meeting set for that day. Fraser’s California staff is told the next FirstNet board meeting will take place Dec. 11 or 12, and “grantees have discussed a joint briefing to be held immediately before or after” it happens, according to the document. BayRICs requested $100,000 of additional FirstNet integration funding for the 2013 grant cycle, on top of $340,000 requested for maintenance, monitoring and consulting. The state of California is holding “a series of public forums with stakeholders” on FirstNet, and BayRICs plans to participate, the report said. The FirstNet “lack of clarity” has slowed activity at BayRICs sites, it said.

The joint state commenters also support the creation of a FirstNet board advisory committee for states, with members “appointed by the governors or their designees and composed of the senior technical advisors to the governors and the State Chief Information/Technical Officers,” they said. The National Governors Association previously criticized FirstNet for not including enough state representation (CD Sept 25 p13). Florida’s comments cited this as its “main concern” and also judged public safety presence “absent” (http://xrl.us/bnxnkd). FirstNet should “appoint a nonvoting representative from the governors to attend FirstNet meetings and work directly with FirstNet personnel and consultants,” the joint state commenters said. The FirstNet board has begun considering architecture before it’s “had an opportunity to solicit, much less digest, any information from states that would describe public safety’s requirements,” said the Mid-Atlantic Consortium for Interoperable Nationwide Advanced Communications (MACINAC) (http://xrl.us/bnxnsz). The District of Columbia, Delaware, Maryland, Pennsylvania, Virginia and West Virginia statewide interoperability coordinators sponsor the two-year-old MACINAC Initiative. It’s calling for enhanced state partnerships and believes FirstNet will benefit from all states opting in.

North Dakota is “optimistic” but sees challenges, State Chief Information Officer Lisa Feldner said in comments (http://xrl.us/bnxnjx). Preemption and quality-of-service benefits “may not generate the volume of day to day users required to make this network a success,” she said. Carriers would also have to make large-scale accommodations never done before, she said. Florida pointed out the network will need to exhibit built-in “robustness and resiliency” not typically supplied by commercial wireless providers. The Washington State Interoperability Executive Committee outlined questions and concerns about how public safety architecture differs from commercial and long-term planning of the network (http://xrl.us/bnxnpd). The Arizona Department of Emergency Management will hold statewide planning meetings this month, where Fort Mojave will participate as liaison for 21 tribes, the Native American nation said in comments (http://xrl.us/bnxnqp). Fort Mojave described its many public safety activities and called for tribes to be “funded directly and adequately” in FirstNet execution. MACINAC worried about negotiating with carriers and about commercial network reliability, it said.

Cost remains a major state concern. FirstNet capital expenditures for all 50 states may exceed $16 billion and operational expenditures more than $795 million, an Oct. 16 Minnesota Department of Public Safety presentation to the governor’s broadband task force estimated, rough numbers based on Minnesota’s projected costs and multiplied by 50. The “FirstNet bill provides up $7.3 Billion; most likely won’t cover even HALF of CAPEX,” the presentation said (http://bit.ly/Tj2JiZ). The “FirstNet bill provides no OPEX, but gives FirstNet the authority to collect fees to support operational expenses. Unlikely that government at all levels will generate new revenues at these levels; better to focus on cost savings and efficiencies.” Minnesota will create a statewide body to address planning activities, develop a state public safety broadband plan and assess assets Minnesota can contribute, it said. Minnesota’s forthcoming comments haven’t been posted to NTIA’s site.