Proposed FirstNet Architecture Not Sufficiently Hardened, Final NTIA Comments Fear

The Early Builders Advisory Council wants new FirstNet pilots. The group includes 21 700 MHz public safety waiver recipients, who banded together over the last two years. The council presented an overview of the 21 projects, summarizing investments and offering suggestions for how they can help FirstNet, with sample business models for different projects (http://xrl.us/bnze2v). The council wants to “partner” with FirstNet to, “in many cases, pilot solutions in our jurisdictions,” it said. These 21 projects included certain suspended NTIA Broadband Technology Opportunities Program grantees like California’s BayRICS, Colorado’s Adams County Communications Center and the network of Charlotte, N.C. Mississippi asked to deploy its pending network (http://xrl.us/bnze9o).

The council questioned whether FirstNet’s architecture will be “resilient enough to survive a disaster” and advocated for “multiple, regional, hardened and fully capable FirstNet Enhanced Packet Cores distributed throughout the United States and in remote areas and territories.” Verizon also worried about reliability, noting the initial FirstNet presentation describing multiple commercial networks “does not account for the importance of hardening” (http://xrl.us/bnze4x).

"Redundancy does not necessarily equate to increased availability or survivability,” the New York City Police Department said (http://xrl.us/bnze6x). Oregon “applauds” the FirstNet board for choosing to use existing commercial infrastructure but is worried, echoing the concerns of other officials in recent weeks (CD Nov 1 p1). The state “will need some assurance” that the public safety network will be hardened because commercial networks aren’t “designed to the same stringent standards” as public safety ones, it said (http://xrl.us/bnyuiy). Mesa, Ariz., raised the same concern about the reliability of commercial networks, as did New Jersey (http://xrl.us/bnze7h). “One need look no further than the performance of the cellular telephone networks during Hurricane Sandy and Tropical Storm Irene,” Mesa Communications Administrator Randy Thompson said (http://xrl.us/bnyumv). Motorola Solutions raised this concern of public safety hardening (http://xrl.us/bnze8n). Mesa is also “concerned” about potentially foreign ownership of parts of the commercial networks, the city said -- another point raised in other comments (CD Nov 7 p1). The Wireless @ Virginia Tech research group warns of jamming attacks that could happen in five to 10 years under LTE technology (http://xrl.us/bnyuok). LTE is vulnerable according to early research, the group said. “Extremely effective attacks can be realized, using fairly low complexity."

Many questioned who should be able to access FirstNet. The FirstNet board “fails to acknowledge the full spectrum of first responders,” Springfield, Ore., said (http://xrl.us/bnyunfz). Public works departments need to be considered among first responders, the city said. There’s a need “to develop funding opportunities for this critical aspect” of the network, it said in a letter from the city’s director of development and public works. FirstNet should partner with utilities, the Utilities Telecom Council said (http://xrl.us/bnze2c). The Early Builders Advisory Council suggests broad inclusion, adding “’second responders,’ government agencies, critical infrastructure entities such as utilities, public works entities, transportation entities, airlines, and appropriate private entities.” These entities “may prove to be a financially invaluable partner to FirstNet,” said the Telecommunications Industry Association (http://xrl.us/bnze52). AT&T warned that FirstNet should limit the network to “users providing public safety services."

Oregon questioned FirstNet’s “reliance on multiband communication devices,” which the FirstNet board’s September presentation on architecture said will occur. The board should note this reliance more explicitly, Oregon said. It encouraged FirstNet to leverage both commercial and government-owned resources. It advocates for “a cloud-based services architecture.” Mesa recommends FirstNet ignore the apps for now and “focus on getting a broadband data network built” and utilize LTE tech, it said. The NYPD worried the devices might be “technically challenging and ultimately financially prohibitive."

Former Rep. Scott Klug, R-Wis., called the FirstNet law “unconstitutional.” It “represents a federal takeover of the Michigan police network, built out over 20 years at a price of nearly $400 million,” he wrote (http://xrl.us/bnyuqa). Klug, now at law firm Foley and Lardner, said the law “parallels the Medicaid provisions of the Affordable Care Act” and will be subject to similar constitutional challenges. Klug is a former member of the House Communications Subcommittee, he noted. He urged the Michigan attorney general to fight back against FirstNet along with attorneys general in four other states with “well-developed” public safety networks.

Verizon is planning for “bi-directional roaming between its commercial LTE network” and FirstNet, the carrier said. It included a September white paper on how FirstNet should operate. FirstNet should enter into roaming agreements with commercial carriers regardless of integration with these networks, T-Mobile said (http://xrl.us/bnze8z). AT&T offers FirstNet “the capabilities to implement and develop this intelligence, such as common backbone transport, data centers, IP networking, and professional service,” it said (http://xrl.us/bnzez4). It advocates for open standards. Dish Network’s efforts should be integrated, the satellite provider said, calling for a “multi-network, multi-platform approach” (http://xrl.us/bnze56). Research In Motion has “extensive experience in delivering assured services over a platform similar to the network envisioned by FirstNet” with its BlackBerry and other efforts, and is “well positioned” as a “partner,” RIM said (http://xrl.us/bnzfag).

California advocated for including more local governments, local control over the network and local resources integrated into FirstNet’s architecture (http://xrl.us/bnze5d). Pennsylvania outlined more ways for FirstNet to include states in the planning and eventual network (http://xrl.us/bnze96). Massachusetts offered a brief set of bullet points, echoing points other states have made on the need for a FirstNet partnership with states, a sustainability model developed and presented, leveraging municipal and commercial resources, governance early on and controlled costs (http://xrl.us/bnyukh). Oregon also suggested a “revised opt-in” model for states to give them a “more substantial role.” State, regional, tribal and local “needs should drive” the network, Sprint Nextel said, urging collaboration as a key focus.