Public Safety Advocate: FirstNet’s Competition

The law that created FirstNet is very clear when it comes to states and territories opting in or out of FirstNet. There are two ways to opt in: The governor of the state or territory decides to opt in by the December 28, 2017 deadline, or the governor simply does nothing in which case the opt in for that state is automatic. Opting out requires the state to provide the FCC, within 180 days, a plan demonstrating that the Radio Access Network (RAN), the only portion of the network authorized by law for states to build on their own, will be 100-percent compatible with the FirstNet network. The state will then negotiate a grant from the National Telecommunications and Information Administration (NTIA) for some of the network. As a final step, there must be a spectrum lease agreement between the state and FirstNet. All of this is called out in the law Congress passed in 2012. These are not conditions imposed by FirstNet.

Now if a state opts out, the FirstNet mandate is that the radio access network provided by the state or its vendor must be connected to the FirstNet core when public safety users populate the FirstNet network. FirstNet has also said that secondary users may, in fact, be routed to a different core located within the state or operated by the vendor. Again, ALL public safety traffic is to be routed to the FirstNet core. This makes sense when you understand this is to be a nationwide network sharing resources and applications that is usable across the entire nation.

Once a state has opted in there are no additional federal rules that impact public safety agencies within the state. Each agency has the option to join the FirstNet system, stay with its existing broadband provider, or to not use any broadband services. This local level is the area in which competition is occurring. Verizon has said it will actively seek to keep its existing public safety customers and to add more customers. It is also trying to obtain permission to host its own public safety core. Both FirstNet and AT&T are opposed to this with good reason. Having multiple standalone cores does not lend itself to fulfilling the goal of full interoperability this network was envisioned to provide. I have been told by experts in the field that if the cores are connected to each other the overall system will be more difficult to secure from a cyber security perspective, which is high on the list of network priorities.

The argument of a single core versus multiple cores came up among other issues during the recent hearing held by the U.S. House of Representatives, Committee on Energy and Commerce, Subcommittee on Communications and Technology on November 1, 2017. Several letters were submitted to the subcommittee as well as testimony from a few of the witnesses, some of whom were attempting to share their view with the subcommittee that there are options to the FirstNet/AT&T network that need to be permissible to better serve public safety.

One of the letters was from Verizon, which stated its case for Verizon to compete with FirstNet both on a state and local level. The letter basically covered all the points Verizon made during its “launch” at APCO in August of this year and since then. The most interesting thing to me about both the letter and the comments is that they state 1) Verizon has no interest in monetizing the FirstNet spectrum as a secondary user on the spectrum and 2) that each state or area that chooses to go with Verizon will need a Verizon run core network back-end system.

It appears that Verizon believes it can build a mirror image of FirstNet and somehow connect the two networks. It states in its letter that it has always believed each state should be able to build its own network and then join the FirstNet system, providing full compatibility. This is basically an approach of a network of networks that was discussed extensively and then dismissed first by the Public Safety Spectrum Trust (PSST), then the Public Safety Alliance (PSA), and finally by FirstNet. It should also be noted here that both Verizon and AT&T participated in the PSST and PSA discussions. I have no recollection of Verizon not being in favor of the final decision of a single nationwide network.

Yet in its letter to the sub-committee, Verizon states, “As FirstNet began to implement Congress’ mandate, Verizon offered its expertise and guidance on what we believed would be most effective. We believed that a state-centric approach was much more likely to meet public safety’s unique requirements than a one size-fits-all approach. We recommended a framework that would promote state- or regional-based partnerships with a requirement that the resulting state or regional networks be required to interoperate in order to create a nationwide network for public safety’s use.” In reality, everyone was suggesting what FirstNet should do and how it should build its network. FirstNet did have plans early on to allow vendors to bid on an entire nationwide network or portions of the network that would then be connected to each other. In the end, FirstNet decided the best way to proceed was to restrict the bids to a single, nationwide network, which is what the RFP reflected.

When I was vice-chairman of the APCO broadband committee, the issue of multiple cores was a subject of a lot of conversation. Some believed major cities would each want their own core, and that the network could support multiple cores all talking to each other. However, on further examination we realized that the amount of traffic between cores to keep them all in sync and to make sure they all had identical registration information, applications, and all the other pieces and parts would tax any backhaul system with a great deal of duplication of data going back and forth. Our stance at this point was to recommend a single core system (with back-up cores in different locations), which is how every network operator deploys its cores today.

It appears that each time there is a potential competitor to the overall vision of the network, one of the first things it wants is the ability to host its own core. This was (is) true of Rivada Networks and it is now true with Verizon. FirstNet’s and AT&T’s stance is that adding more cores to the network will reduce the security of the network. There are very few instances I know of where two competing networks have tied their cores together to better serve all of their clients. Historically, Verizon and AT&T have not provided interconnections except through third-party roaming services. AT&T and Verizon have contracts with the same Push-To-Talk (PTT) provider but do not permit cross-network PTT. It should be clear from this that there are issues with cross-network measures. If you want a PTT system that works across networks, ESChat and others provide that service. However, AT&T and Verizon have decided not to share their PTT systems across networks.

Monetizing Band 14

Verizon also stated it is not interested in monetizing Band 14 FirstNet spectrum, which by the way, was also its excuse for failing to submit a response to the FirstNet RFP. At the same time Verizon points a finger at AT&T for offering up all its existing LTE spectrum plus Band 14 for the first responder community. What this boils down to is that Verizon seems to believe its network is already perfectly suited, without any additional spectrum or build-out, for the public safety community on its network while casting aspersions at AT&T for offering up its own spectrum PLUS Band 14. It appears as though the public safety community is to believe the Verizon network is already hardened and covers all the areas each state has indicated is important to them. Yet during the northern California fires, all the networks, AT&T, Sprint, T-Mobile, and Verizon, lost service to the area. Even the fiber buried underground was burned and useless. But let’s not lose site of the fact that Land Mobile Radio (LMR) services, at least unit-to-unit, remained on the air. We should also not forget that all the network operators responded to the fire areas with Cells On Wheels (COWs) to try to bring back services. However, there are times when even site hardening is simply not enough.

Verizon says it has better coverage than AT&T, but I have to wonder how it squares this statement with the fact that in September of this year Verizon announced it was booting rural customers off the network because they were using data services too much and Verizon was having to pay huge roaming fees to its rural partners. Exactly how will Verizon provide for the need for public safety coverage in these areas if it has cut off service to its rural customers?

I also have to wonder about Verizon’s statement that its public safety customers will be able to make use of the FirstNet Band 14 where is has been deployed by AT&T. According to what I have learned while investigating this claim, the only way that can happen is if a device is capable of dual (two) SIMs, one for AT&T Band 14 and one for Verizon’s network. Then the issues are: Who pays for two subscriptions for each device? How does AT&T, which includes all its own LTE spectrum as well as Band 14, then limit Verizon customers’ access to only Band 14?

Verizon and other networks have the right to offer public safety better deals, and perhaps even, at this point, better coverage. However, Verizon saying it has always been pro public safety and has looked out for public safety, then comes along entering the fray and saying basically, “Yes we support public safety but only as long as it is on our network.” The primary issue to me is with Verizon back in the game and stirring things up, how do we end up with the vision of FirstNet that has always been a nationwide, fully interoperable, secure network that provides services for any and all within the public safety community? These people know being able to communicate with neighboring agencies or agencies in another state is a big deal.

If I had a crystal ball I would predict that some public safety departments will stay with their existing broadband supplier until such time as AT&T can demonstrate it can offer the coverage the department needs, is price-competitive, and has the advantage of being the FirstNet network with all the benefits that come with it, including full pre-emption. FirstNet has already been a long time coming and it appears that it will be a while before there is truly one public safety broadband network across the nation. P25 Digital LMR systems were more than 25 years in the making. Hopefully, FirstNet won’t take anywhere near that long!

Andrew M. Seybold
©2017 Andrew Seybold, Inc.