Public Safety Advocate: FirstNet Managed Services, FCC’s Location Blunder, 5G Czar?

With this being Thanksgiving week and many people taking time off from their work, this issue of the Advocate is being published early. Of course, some will work the holiday so the rest of us can enjoy the time with family and friends. We must not forget those in the Armed Forces, law enforcement, fire departments, and especially paramedics who are busier than normal during holidays. Please remember to thank these service people as you interact with them this Thanksgiving.

FirstNet as a Managed Service

Several months ago, I wrote about managed services, a trend that was gaining favor for Land Mobile Radio (LMR) systems and service, automobiles, and other high-dollar procurements. Rather than buying devices or a radio network outright, paying for it as a capital expense (CAPEX), and paying for system services using Operational Expense (OPEX) funds, a complete system can now be acquired as a service. Motorola Solutions has been the leader in this type of system selling and other LMR vendors have followed.

According to the Sierra Wireless press release, its AirLink® Managed Network Service with FirstNet® Connectivity service bundle equips public-safety agencies with AirLink Routers, 27/7/365 technical support, and more than twenty years of Internet of Things (IoT) security experience. With built-in FirstNet connectivity and a secure private network architecture, the service provides reliable connectivity public-service agencies can count on for mission-critical applications. Further, public-safety agencies can “enjoy an end-to-end solution right out of the box” without having to spend capital funds.

Having had a Sierra Wireless MG-90 dual-SIM mobile router in my own vehicle and full access to Airlink services for several years now, I can say from experience that the modem and service combination has performed flawlessly. I use this router and the associated cloud-based application to map out coverage differences between FirstNet and Verizon, and use the router to provide WiFi both in my vehicle and for a WiFi bubble around it. The Sierra Wireless offering with this router and all the accompanying services looks like a winner to me. (Just for the record, Sierra Wireless is not a client.)

Tango Tango

Sierra Wireless is not the only company offering FirstNet or an element of FirstNet as a managed service. Tango Tango provides Push-To-Talk (PTT) as a service. This service has been very successful and the company continues to add public-safety agencies and sell to smaller agencies around its client, adding to its client list. Not only is this growing the Tango Tango installed base, it is creating large areas where multiple agencies are able to communicate via FirstNet using PTT. Tango Tango’s methodology is creating larger and larger areas served by multiple agencies that are able to fully interoperate through PTT services over FirstNet. 

This model of managed services works well for organizations with tight budgets, or that have better access to OPEX funds than CAPEX funds. Motorola’s offering for LMR radio systems includes, I am told, an end-of-life revitalization of network and user devices as part of the contract.

With another type of managed service, you can buy a vehicle today for a no-money-down monthly price that includes the vehicle, insurance, and maintenance. Some automobile companies offering this plan are extending the end-of-life, get-a-new vehicle option along with the deal.

FirstNet is growing fast, both in terms of coverage and the number of agencies that become a part FirstNet. Managed-service contracts can help speed the process for potential new FirstNet user agencies, and I expect other companies to follow in the footsteps of Sierra Wireless and Tango Tango. This new way to manage expenditures will benefit public-safety agencies with limited budgets.

Federal Government Mis-Steps

There are two items in the news I want to chime in on this week. The first concerns rules the Federal Communications Commission (FCC) adopted for 9-1-1 location accuracy. For a number of years, the public-safety community has been asking for better location accuracy both outdoors and, as important, in buildings. Over the past few years, we have seen a great deal of activity from potential vendors in this field. In the July 13, 2017 issue of the Advocate, I outlined the proposed goals of what was even then a watered-down set of requirements as stated by the FCC. At that time, the FCC’s goals were as follows:

 Horizontal location requirements

“All CMRS (cellular) providers must provide (1) dispatchable location, or (2) x/y locations within 50 meters, for the following percentages of wireless 911 calls within the following timeframes, measured from the effective date of rules adopted in this Order (“Effective Date”):

  • Within 2 years: 40 percent of all wireless 911 calls.
  • Within 3 years: 50 percent of all wireless 911 calls.
  • Within 5 years: 70 percent of all wireless 911 calls.
  • Within 6 years: 80 percent of all wireless 911 calls.

Vertical location requirements:

All CMRS providers must also meet the following requirements for provision of vertical location information with wireless 911 calls, within the following timeframes measured from the Effective Date:

  • Within 3 years: All CMRS providers must make uncompensated barometric data available to PSAPs from any handset that has the capability to deliver barometric sensor data.
  • Within 3 years: Nationwide CMRS providers must use an independently administered and transparent test bed process to develop a proposed z-axis accuracy metric, and must submit the proposed metric to the Commission for approval.
  • Within 6 years: Nationwide CMRS providers must deploy either (1) dispatchable location, or (2) z-axis technology that achieves the Commission-approved z-axis metric, in each of the top 25 Cellular Market Areas (CMAs):
    • Where dispatchable location is used: the National Emergency Address Database (NEAD) must be populated with a total number of dispatchable location reference points in the CMA equal to 25 percent of the CMA population.
    • Where z-axis technology is used: CMRS providers must deploy z-axis technology to cover 80 percent of the CMA population.
  • Within 8 years: Nationwide CMRS providers must deploy dispatchable location or z-axis technology in accordance with the above benchmarks in each of the top 50 CMAs.
  • Non-nationwide carriers that serve any of the top 25 or 50 CMAs will have an additional year to meet these benchmarks.”

Since then tests, both official and unofficial, were conducted and vendors have set about to solve these issues in a multiplicity of ways. The FCC has set up test beds to review:

  • “The National Emergency Address Database (NEAD)
  • Crowd-sourced Wi-Fi
  • Dedicated or managed Wi-Fi locations
  • Observed Time Difference of Arrival (OTDOA), based on LTE
  • Metropolitan Beacon System (MBS)”

Even in 2017, I expressed concern about the FCC parameters not being sufficient, and now, during the November 2019 open meeting of the FCC, the Commissioners voted basically to make location on the z-axis, which specifies the height or floor within a building, a non-starter. The FCC will now require merely a raw altitude estimate on the z-axis. This means the reported location may in fact be nowhere near the location of the calling party or where first responders are trying to find the caller and the incident. The rule states 3 meters which is 10 feet. Hight high is the typpical story in a building? The answer of course is 10 feet or 3 meters.

In its press release about this issue, APCO stated the following:

“The Commission’s new rules require the nation’s largest wireless carriers to provide nothing more than a raw altitude estimate, which absolves the carriers of their obligation to protect people who call 9-1-1 for help. In the leadup to the Commission’s action, APCO and 9-1-1 directors from across the country urged the Commission to take a different approach by including reasonable requirements of the wireless carriers to provide at least the floor number of the caller.  APCO raised significant concerns that the Commission’s plan will not provide first responders with information they can readily use and, worse, will not result in real-world improvements.

“The Commission delivered a major win for wireless carriers and the one or two companies that can be used to fulfill these new regulatory requirements,” APCO Executive Director and CEO Derek K. Poarch said. “The carriers are already indicating that they will underperform on these weak requirements and abandon efforts that had been underway to make more significant improvements. The Commission had the responsibility to do the right thing for our citizens’ safety.  Instead, the Commission is giving the carriers a pass, failing the American public, and leaving many issues unresolved that will ultimately cause its plan to fail. Lives will be lost as a result.”

In light of all the work already done by the vendor community and test beds set up by the FCC and others, there is no excuse for this change of heart.

There is some speculation that the wireless carriers pushed for this watered-down set of location requirements, but based on information in the press, there is no way to prove or disprove this. The two largest carriers are AT&T, which is building the FirstNet public-safety nationwide broadband network and is working to serve the public-safety community, and Verizon, which did not bid on the FirstNet contract but now says it really cares about its public-safety customers. I have to assume these carriers would not pressure the FCC to water down a requirement that is designed to save the lives of both citizens and first responders.

5G Czar

Meanwhile, a group of bi-partisan U.S. Senators has urged the White House to appoint a 5G Coordinator, citing a lack of a “coherent national strategy” for 5G. I wonder why we did not have an LTE, 3G, or even 2G coordinator and instead let the marketplace determine what technologies to deploy and how to deploy them. Last time I looked, the FCC was responsible for all non-U.S. Government radio spectrum and how it is to be used. 

I often find myself at odds with the FCC, especially when it wants to push unlicensed spectrum into a vital portion of spectrum such as the 6-GHz band, and since it seems to think public safety, which has been using broadband for only a few years, no longer needs the 4.9-GHz band. In this case, I have to believe those who are the foundation of the FCC and have been doing their jobs well for many years know how to help shape 5G. They also know that mandated spectrum “coordination” by an individual who is a political appointee will not make the journey into 5G land any easier or smoother. 

In the world of wireless communications, we are and should remain driven by the market and users, not by what someone sitting in a U.S. Government (non-FCC) office thinks needs to be done to ensure 5G is rolled out “correctly.” At this juncture, we don’t even know what “correctly” is when it comes to 5G. 5G is in its infancy and as it ages and becomes more seasoned, those who understand spectrum and the free market, not some politically-appointed person, will help mold 5G to best serve all of us. After next year’s election, we could end up with a short-lived 5G Coordinator who is replaced by yet another who has different ideas. Let the market determine 5G the way is has determined every wireless technology that has come before.

Winding Down

This will be a short week for many, but a busy holiday season means it will be a time of increased responses to incidents for our public-safety community. Especially at this time of year, we need to thank those who, as they say, “run into harm’s way instead of away from it.” 

We are also approaching an anniversary of sorts for FirstNet. On December 28, 2017, the last of the fifty states and six territories opted into FirstNet. While there were already agencies on FirstNet (Built with AT&T) at that time, to me, this marked the start of what FirstNet was to be. FirstNet began with many of us having faith this journey would turn out how we had envisioned for the many years before this network became a reality.

FirstNet remains ahead of due dates established by the FirstNet Authority and it is growing quickly, even with some noise from other network operators that did not bother to show up for the bidding. There have been and will continue to be bumps in the road. A few states do not seem to feel they are receiving the proper level of attention from the builder of the FirstNet network, and in only the past twelve to eighteen months, some states have seen huge improvements in their FirstNet coverage. 

Again, I remind my readers that had a winning bidder built out only Band 14, many agencies that benefit from FirstNet today would still be waiting. Instead, today we have a robust public-safety network that is growing quickly to serve the needs of the public-safety community. Patience is still needed in some areas, but I am certain these will be covered and up and running before the five-year deadline is upon us. 

Will we reach the goal we had in mind when we began working on this project in the early 2000s? Back then, the goal was to have a single, nationwide broadband network that provides full interoperability for all public-safety agencies when they are serving within their own community and when they traverse from one end of the United States to the other to assist with major incidents. We are well on our way and departments that could not communicate with each other in the past are doing so in increasing numbers. 

Literally hundreds of people have made FirstNet what it is today, and I would like to take this opportunity to thank everyone who has worked so diligently to establish FirstNet and all those who have joined in to make FirstNet a reality.

Until next week…

Andrew M. Seybold
©2019, Andrew Seybold, Inc.

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