December is upon us, which means 2019 is drawing to a close. In a recent Mission Critical Communications web post, it was reported that as of November 13, 2019, FirstNet (Built with AT&T) had met 66% of build-out requirements for the first five years of the 25-year contract. AT&T states that by the end of 2019 it will be at the 70% completion milestone. However, also according to the article, the next payment to AT&T from FirstNet the Authority is not due until FirstNet reaches 80% of the build-out completion goal.
In 2019, AT&T will have spent more on building the network than it has received in FirstNet Authority reimbursements from the original funds allocated to FirstNet as part of the proceeds from FCC spectrum auctions. According to records, AT&T spent $850 million in the first nine months of 2019 and received only $134 million from the Authority. All of the bidders, including AT&T, understood it would take a large investment in order to meet the build-out requirements and that the money they spent would be recovered over the 25-year span of the contract.
When AT&T was awarded the FirstNet contract, it made all its LTE radio spectrum available for FirstNet and has provided full priority and pre-emption on its own LTE spectrum before building a single Band-14 public-safety broadband site. This enabled many public-safety organizations to become FirstNet users much earlier than the FirstNet Authority planned. As you might recall, the RFP required a Mobile Virtual Network Operator (MVNO)-type service as the public-safety Band 14 network was under construction. What AT&T offered in its bid response was much more than a mere MVNO. Instead of temporary use of network spectrum that may or may not have included pre-emption, AT&T committed to make its own spectrum available for all FirstNet users.
With what AT&T included in its bid, FirstNet is years ahead of where it would have been had another bidder won and built out a Band 14-only public-safety system. In the final years the public- safety community spent in front of Congress, filing thousands of pages of documents with the FCC, and working with the Executive Branch, there was some concern about whether 20 MHz of spectrum would be sufficient to handle public safety’s needs. There were no issues on a daily basis when public-safety usage was spread out across the entire United States, but it was thought there would be problems during close-in incidents when there would be many users in a small area using a lot of video in both directions and a great deal of data.
I wrote several articles about this and explained that during such times the spectrum used by agencies at an incident must be managed. I described a full-blown incident making heavy use of video when a paramedic team attempts to send an ultrasound in real time to determine if a patient is bleeding internally. The ultrasound would occupy 5 or 6 MBs of the total network capacity and if this was not coordinated with fire and police on the scene using FirstNet, other data or videos or the ultrasound might not be sent because network capacity would be maxed out. With AT&T building Band 14, using its own spectrum as part of the FirstNet network, and pledging availability to its 5G network to public-safety users, this situation is much less likely to occur.
FirstNet (Built with AT&T) is well ahead of the build-out milestones set out in the RFP awarded March 30, 2017, and while the build-out was supposed to take five years, the final opt-in for all states and US territories was in December 2017. It is a tribute to the dedication of AT&T executives and the group heading up the project that FirstNet has been built out to this extent. The network is only one element, albeit perhaps the most important element of the FirstNet mission. This mission won’t be complete until there are common applications to enable data sharing among agencies and Push-To-Talk (PTT) services running on FirstNet interoperate with each other.
FirstNet planned to release its Mission-Critical Push-to-Talk service by the end of 2019, which has now been extended into the first part 2020. As my regular readers know, I am not a fan of “Mission-Critical Push-to-Talk” because it is called “mission-critical.” This nomenclature wrongly imparts a warm-fuzzy feeling that the network will magically become mission-critical as well. AT&T is working diligently to upgrade its network to make it more public-safety grade (a term I prefer) but this will take more time and investments. The State of California recently passed or is about to pass a law that because of “planned” power outages during high-fire danger periods, all cell sites (commercial and FirstNet) must provide battery back-up of at least 72 hours.
Seventy-two hours is a long time, but it is not long enough for some of power outages and inspections of high-tension lines before power is restored. Use of batteries and generators is the most effective way to keep sites alive when commercial power is not available and these have been installed in many of the sites considered to be of most importance. Smaller, fill-in cells have not been equipped with this type of power back-up and it is unclear if they will be. In many cases these smaller cell sites have been built to augment network capacity in given areas. If these smaller sites fail, coverage from the larger sites can normally handle the load and maintain coverage where needed.
There is a difference between commercial broadband networks and FirstNet that can be summed up this way: Commercial networks are considered to be “best-effort” networks and FirstNet is being built as a public-safety-grade network from day one. As such, FirstNet has included portable cell sites and has added more. We have seen all cell operators deploy portable cell sites but not as quickly and efficiently as FirstNet. This is one more thing that sets FirstNet apart from commercial networks.
I think FirstNet growth in both network coverage and number of public-safety agencies and users may have set some records. Further, FirstNet has added a large number of approved devices including new handhelds, laptops, and tablets, and many software applications have been reviewed, approved, and added to the FirstNet applications store. It also appears that 2020 will be another banner year. However, there is one issue that needs to be resolved in favor of FirstNet and that is interoperability.
FirstNet Interoperability Debate
The FCC has received a number of responses to the BRETSA (Boulder Regional Emergency Telephone Service Authority) filing. The FCC has yet to review and comment on the many responses both in favor of and opposed to the filing. Basically, the filing alleges FirstNet should be required to provide interoperability with wireless broadband networks so public-safety users on these other networks can share in interoperability benefits afforded to FirstNet users.
There are many matters being brought to bear here. One questions the FCC’s jurisdiction over this issue since FirstNet is an independent authority under the National Telecommunications and Information Administration (NTIA), which is part of the Department of Commerce (DOC), which is part of the Executive Branch but is unrelated to the FCC.
Next, BRESTA is asking for all things interoperable—networks, applications, video, and push-to-talk. FirstNet itself has not reached the point of interoperability in many of these areas. How can it be required to provide network interoperability with things that are not yet interoperable on FirstNet, let alone other networks. It must be noted that the folks in Boulder already have a contract for ESChat, an over-the-top push-to-talk application that provides cross-network push-to-talk services. ESChat does not impact FirstNet because it is an application and it does not require network integration, sharing of the FirstNet core, or present any of the other issues with what BRETSA is requesting.
One issue with cross-network operability is that while LTE may be a standard approved by the 3GPP, each new release contains options and each network operator is free to choose which, if any, to include in its network. Therefore, it is clear that no two LTE networks in the United States may be alike and that finding common ground for LTE network interoperability would probably break FirstNet.
Many of us involved helping get FirstNet passed into law carefully weighed all options. Should there be one network or several networks? Should the United States be divided into four zones, with each of the then-four nationwide network operators building 25% of the network, and then tie the four networks together? In the end, it was decided that a common network made the most sense for many reasons. Major among these were that there would be a single point of contact if something did not work as planned or if there was a problem, and a single network would be compatible with itself. Public safety had already experienced enough finger-pointing when one vendor built the network, another provided the backhaul, and others provided radio and console equipment. Unlike with commercial networks, when there is a problem with FirstNet it must be fixed quickly. When one vendor blames another for a malfunction, public safety and the citizens it serves lose.
Also fresh in our minds was the more than 25-year battle to finally establish P25 as a “digital land mobile radio standard” that required all vendors to certify their products are compatible with P25. That hasn’t stopped some vendors from adding bells and whistles in an attempt to entice their customers to buy replacement equipment. It took more than 25 years, but today P25 is a real standard. FirstNet is “open” in the sense that there are many devices and applications. Even so, there are still issues with a lack of common applications, too many PTT vendors that are not required or willing to interoperate, and so forth. How can FirstNet interoperate with other networks before it can provide interoperability across its own common network?
In closing, I would like to address the fact that AT&T bid on the contract to be the single supplier for the FirstNet network for public safety and its pricing and response to the bid was based on being the single provider. As mentioned earlier, when AT&T bid on the contract, it knew full well it would initially cost much more to build out than any compensation received from the Authority and public-safety customers. The rules cannot be changed after the award, regardless of which vendor won the contract. FirstNet has become a major communications network for public safety, and those who regret not bidding on the RFP should not be permitted to lessen the value of the contract between AT&T and the federal government. Do you think any network operator that won a contract would let another vendor claim a piece of the pie…especially after they said they had no interest in the pie before bids were opened?
T-Band and the FCC
This week the FCC made two announcements regarding the T-Band (470-512 MHz shared use of TV spectrum in eleven metro areas). The first was that it was suspending processing of T-Band renewal applications. According to Alan Tilles, a well-known specialist in FCC law (and a good friend), the FCC will accept applications (and you should file them) but they will be held in queue pending whatever happens with the T-Band (referring to the movement in Congress to pass a bill repealing the T-Band giveback that was part of the FirstNet rules approved by Congress and signed into law). He also stated that licensees filing for renewals may continue to operate, also pending what happens to the band. These suspensions were announced by the Wireless Telecommunications Bureau and Public Safety and Homeland Security Bureau. This advice from Alan Tilles should be followed by all T-Band license holders.
The second announcement and the most important in my mind was the statement by FCC Chairman Pai that called on Congress to repeal the mandate that the FCC auction the T-Band (470-512 MHz) spectrum. The FirstNet legislation calls for this is spectrum to be returned to the FCC for auction. At that time, members of Congress felt this spectrum would be worth billions of dollars on the auction block. It has been proven in two NPSTC reports, by the GAO office, and by members of the public-safety community that this spectrum is of much more value to the public-safety community in and around the eleven major metro areas that currently have access to the T-Band.
In several Advocates I have cast doubt on the real value of this spectrum when it cannot be used for nationwide services unless the TV stations that occupy the spectrum in the other parts of the country are forced to move. Further, in addition to public-safety systems, cities, businesses, and land mobile radio systems are approved for use on this spectrum. When FirstNet was signed into law, there was no consideration given to these business users nor were there any provisions for public safety to be moved to other available spectrum (there is none), or the cost ($billions) to relocate these agencies. Further, there was never enough time in the proposed timeline to allow the large number of departments to relocate, even if there was spectrum and funding to do so.
Chairman Pai joins the GAO, NPSTC, the IAFC, the IACP, NSA, and scores of other public-safety agencies in opposing auctioning of this spectrum. It now appears, with Chairman Pai’s concurrence, that the last “i” has been dotted and the last “t” crossed. Now it is up to Congress to quickly pass the repeal of the T-Band Act in both the House and the Senate and forward it to the President for his signature. Too many major departments in Boston, New York, Philadelphia, Los Angeles, and other cities are dependent on the T-Band to hesitate.
I hope everyone had a safe Thanksgiving and those within the first-responder community including the ECCs and dispatchers, had some time and turkey with their families. Holidays are tough on the first-responder community serving in a profession they entered into knowing it is a 24/7/365 commitment and personal plans will sometimes have to be put on hold as they report to assist their or another department. First responders are part of a unique group of dedicated people. Armed Forces Service Members, first responders, local, state, and federal employees, hospital and ER staff, are expected to be there for others at all times. We need to say “thank you” to all of you more often.
Public-safety agencies are making changes in their “normal” operations because the new normal is not the old normal. There are more fires and storms, deeper freezes, and hotter days, and “routine” days at work for public-safety professionals are becoming further and further apart. We don’t have enough 9-1-1 operators, dispatchers, and other public-safety personnel so we need find a way to attract more people who want to give back and understand the commitment they must make and still raise their hands. We need to encourage people who are trying to figure out what they want to be when they grow up to perhaps focus on helping others either as public-safety professionals or in other jobs that will provide a similar sense of giving back.
The year is going quickly and 2020 is almost upon us. I, for one, hope 2020 will be a year when the public-safety community works together to find common applications and common ways to simplify push-to-talk over FirstNet and LMR, and assist in coaxing all PTT applications to work together. FirstNet (Built with AT&T) will continue to build out during 2020, the FirstNet Authority will hopefully identify targets for money it will reinvest, and more public-safety agencies will realize FirstNet is not just another broadband network, it is a network designed to serve them and provide a level of interoperability they have never before experienced. The year 2020 should be one of great advancements in public-safety communications. I hope you will come along for the ride.
Until next week…
Andrew M. Seybold
©2019, Andrew Seybold, Inc.