Public Safety Advocate: State Plans Being Delivered

On June 19, 2017, as promised, FirstNet and AT&T delivered the state plans three months ahead of what was required in the FirstNet RFP. The delivery of these plans was via a secure web portal  that will be home to the plans and only accessible by authorized personnel in each state. The rest of us can view some of what is occurring and suggested coverage maps by going to the public site FirstNet.com (.com, not .gov), a new site dedicated to FirstNet state plans.

FirstNet has already provided each of the State (single) Points of Contact (SPOCs) with the information they need for themselves and others they want to also have direct access to the state plan. The FirstNet.com site is designed to provide information for those with an interest in FirstNet, the state plans, coverage, products, and services. FirstNet.com also enables stakeholders not directly involved with the state plan to be able to learn more about what FirstNet and AT&T are offering the public safety community.

The FirstNet team is telling me webinars are next up for the various regions in order to provide further information about how the SPOCs and their teams can make use of the interactive maps, submit and manage comments, and request support. FirstNet has also set up about fifty meetings with the states to walk them through the plan and process, answer questions, and take their feedback.

The email FirstNet sent out with the notification to the SPOCs included this statement about the review and comment submission period:

“This email notification begins the up to 45-day State review period of the State Plan. As outlined in the State Plan Guidance document sent May 5, please compile feedback from your State’s reviewers and assemble in the State Plan Comments template that was provided with the guidance package. The form can be provided upon request as well. Please submit the form to [email address removed] by no later than 5 p.m. PT Friday, Aug. 4. FirstNet and AT&T look forward to engaging with you throughout the review period to discuss the plan and your feedback.”

The next 45 days will be busy for the SPOCs and their teams, and hopefully they will share much of what they are learning with the ultimate customers in the jurisdictions: public safety. This would be the best way to make sure the state plan, when presented to the governor for his opt-in or opt-out decision, has been vetted by those for whom the service is intended. This will also be a tough time because vendors responding to state RFIs and RFPs, which are not due yet, will be trying their best to find out what is in the state plan so they can up the ante in their own responses.

Hopefully, other states will be following the example of California Cal OES, which has already scheduled nine state plan review meetings across the state, all in late June or early to mid-July. This is a great way to make sure the public safety community across the entire state receives the correct information directly from the state and in plenty of time to provide feedback to the state’s SPOC and team members.

States have the absolute right to seek other vendors’ ideas and pricing, but as with any RFP process, each vendor should be required to submit its response based on what is contained in the RFP, not what it may find out about the FirstNet state plan. If the plans are leaked, I believe there is a danger a vendor might simply say, “we will beat the state plan,” and the state will opt out based on that kind of response, only to find there are many buts, ifs, and maybes attached to the RFP response. That is one reason for the three steps to opt-out approval: the FCC, NTIA, and finally FirstNet. If a state passes muster at these three steps and does opt out, there are then safeguards in place to make sure no state has any unpleasant surprises over the course of the 25-year contract.

States considering building and maintaining their own radio access network (RAN) will likely need additional information that is still pending at either the FCC or NTIA. The FCC order regarding the opt-out process is pending a Commission decision on Thursday, June 22. Grant levels for construction of the RAN are currently under review and the NTIA order for proposed guidelines for the State Alternative Plan Program (SAPP) are pending comments by August 18. As soon as this information is available it will be uploaded to the FirstNet Portal. It should be noted again that the information not included in this version of the state plans only effects states that want to opt out and I am told this omission will be remedied very quickly.

Less than three months into their contract together, FirstNet and AT&T have already met their most important commitments when it comes to getting the state plans out the door. Now it’s incumbent on the FCC and NTIA to complete their work so states have a full and complete picture of what is needed to meet the requirements of building and maintaining the network for the 25-year life on the contract.  The need to complete these remaining items in a timely fashion is critical. Considering how much work has already been done over the past several months on all of these items, I would expect the remaining considerations to be completed quickly.

I hope states will take their time to get it right—to really take a deep dive into the state plan, into the coverage as it is today and as it will be each year for the next five years, and how it can be improved with local participation over time. As I stated in my last Public Safety Advocate, even if the coverage now shows it is not what is needed in a state or areas within a state, I believe the best option is still for the state to opt in and then work with both FirstNet and AT&T to expand the coverage where needed. AT&T has repeatedly stated it is ready to earn the public safety community’s business, and that means coverage is one of the most important elements of the state plans. However, it also means that gaps will be filled in over time, coverage will improve, and since AT&T is bringing the FirstNet network along as it upgrades its own commercial infrastructure this network will benefit going forward.

The SPOC teams will be very busy for the next 45 days, as it appears FirstNet and AT&T will be, too. This is the window to get it right, to make sure everyone is on the same page. After the final plan is delivered in September, the SPOC can make his or her recommendation to the governor’s office knowing the public safety community is behind that decision, whatever it is. The last part of the puzzle is whether the governor will take the recommendation and act on it or be influenced by politics rather than reason. I, for one, hope not!  FirstNet has delivered on the network…now it’s time for public safety to make it theirs!

Andrew Seybold
© Andrew Seybold, Inc.

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