Public Safety Advocate Dec 1 2016

Thu Dec 1 17:35:38 2016

California’s RFI

California has issued an RFI, a request for information as opposed to a request for proposal, to learn more about what would be required if it opted out of the FirstNet network build-out and decided to work with a vendor to do it itself. In the RFI it is very specific about not wanting any pricing included with the response, only information.

In many cases this is a well thought out RFI and defines a number of options for contractor owned, state owned, contractor managed, contractor built, state managed, and a public/private partnership approach. It asks not only about leasing of the spectrum for secondary use but mentions that the excess spectrum, could, in fact, be auctioned to the highest bidder, which is the preferred business model of one of the FirstNet RFP bidders.

The RFI also states that 72 percent of the state is underserved or not covered by commercial broadband communications today and that the RFI response could include not only band 14 deployment where it can be deployed. The RFI also includes the following provision:

“The operator may use carrier aggregation and other advanced radio access techniques to deliver bandwidth to PSEs using a combination of Band Class14 spectrum and other operator owned/controlled spectrum.”

This is an interesting but realistic approach to deploying the network quickly and then, perhaps over time, adding more band 14 (FirstNet) cell sites. However, it is not entirely clear how the need for absolute priority would be satisfied using other than band 14 spectrums.

Some other interesting points in the RFI include the provision that if vendors do not commit to cover 90 percent of the geographic area within California they must “release” spectrum outside of their coverage footprint so other vendors could gain access to it and provide the coverage. This seems to only acerbate the issue of FirstNet compatibility throughout the state. Covering 90 percent of the geographic area of California will be a real challenge. No cellular company does so today, and I don’t believe even the California Highway Patrol, operating in the 40–50-MHz low band range, with very high power base stations and mobile radios, meets that coverage goal. If it cannot be done at low band, which covers a lot of terrain, it will be difficult for anyone, including a FirstNet Partner, to cover that much of the state. The vendor would have to cover a lot of wilderness and federal forests as well the rest of the state and the RFI says the network must be 99.99 percent reliable, a really tough goal for a network built on the concept of cellular systems with many, many points of failure between the Radio Access Network (RAN) and the network’s back-end.

Much of the RFI replicates the requirements of the FirstNet RFP that apply to the state of California but it is not clear to me if those who wrote this RFI are confused about the funding rules put into place by Congress (not FirstNet) when it comes to contributing funds to the Nationwide FirstNet system or if the state has basically pre-ordained it can handle the income any way it chooses to the detriment of the nationwide network. It may not matter in any event since even with the number of major population centers in California it appears from our back of the envelope calculations that if a vendor does have to build out 90 percent of the geographic coverage for the state, the California system will not be self-sustaining and will require either an influx of FirstNet revenue derived from other states or for California to step up and fund the shortfall, or perhaps stick a bidder to a future RFP for the state RAN with the costs of the build and operation within the state for the next 25 years.

My overall impression of the RFI is that it was written as a document asking for everything under the sun to see how much California can get from a non-FirstNet vendor and how much it might cost the state. And it bothers me that it is asking for 90 percent coverage of the geography of the state and not 90 percent of the populated areas yet it admits in the RFI that 72 percent of the state is underserved or not served at all with broadband services by the commercial wired, fiber, and wireless operators in the state. The challenge for any respondent to this RFI would be to figure out how to afford to build out this vast amount of geography and to make any money with the state system even over the 25 years of the life of the contract.

The state of California, I believe, is making very limited use of the 700-MHz LMR spectrum assigned to it by the FCC because there was no large amount of funding available. Yet it appears from the RFI (which is not binding on either the state or the vendor submitting it) that it is now looking at a number of options including self-funding the RAN needed to deploy FirstNet.

An RFI is a good approach to gathering information prior to a FirstNet/Partner plan being presented to the state governor’s office. It is not binding, whereas an RFP does, in fact, bind the vendor in the event the state opts out and decides to go it alone. An RFI makes more sense since not only will the state receive some great input from those serious about becoming bidders, it can also receive input and suggestions from organizations not large enough to qualify as full RFP bidders but have some ideas to assist the state or are looking to partner with others.

During my time in Santa Barbara I was a contractor to the County Office of Emergency Management and worked closely with many Public Safety agencies within the county and its cities as well as the communications organizations. Several of us attended state and FirstNet sponsored FirstNet events, and I was the go-to person for the County on FirstNet. At no time during the years I was there did anyone from the state reach out and ask any agency or organization I am aware of, what the needs of our county and its cities were for FirstNet. I have to wonder where the 90 percent coverage requirement came from. I know that in Santa Barbara County alone, 90 percent coverage would include a great deal of U.S. Forest land which is home to a lot of wildlife and sometimes hikers, but no one lives there, and the FirstNet RFP provides for areas such as these to be covered by transportable systems that can be flown in and set up.

So we now have at least three RFPs and one RFI issued. One of the RFPs has been awarded IF the state opts out, two of the RFPS have had their deadlines extended to provide time, I believe, for better and more complete responses and/or for the announcement by FirstNet as to the RFP winner/Partner. The California RFI is due on January 2, 2017, and hopefully the FirstNet award will be announced prior to that.

I am glad states are preparing to be able to compare a state build vs. a FirstNet/Partner build within their own state but I am uneasy that a number of them are trying to find ways to keep all of the income from the use of the Radio Access Network (RAN) within their own state. They are not taking into account that for this network to be successful it must be about the entire United States, its territories, and its tribal communities, not simply about what a state can get for itself by providing a much needed and overdue nationwide broadband network for our Public Safety community.

During the multiple years, the Public Safety Alliance (PSA) and Public Safety Spectrum Trust were working to convince Congress, the Executive Branch, and the FCC this system is needed, those who wore the uniforms in the halls of Congress and attended an untold number of meetings were from many states but were not representing only their own state. They represented the entire police, sheriff, fire, and EMS communities in the effort to gain approval to build a nationwide broadband network that would provide services regardless of where Public Safety needs to go. If this effort turns into what each state can get for itself instead of what each state can do for the first responder community, it will hurt FirstNet and make this a much more difficult network to build and operate.

State elected and appointed officials owe it to those who elected them to look out for the interests of the state. Being prepared to sit down at a table and negotiate with FirstNet and its Partner is a good idea. However, viewing FirstNet as a source of new revenue for a state is, first of all, not in keeping with the law Congress passed, and second, short sighted. Every state sends its first responders to neighboring states or across the country in times of need. The object of FirstNet is to provide a fully operational broadband network for our first responders no matter where they are sent so they can communicate, and hopefully save additional lives and property. It is not about how much money a state can make on the backs of our first responders!

Andrew M. Seybold

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