Public Safety Advocate: FirstNet Progress—RFP IOC Goals Compared to Today’s Network

The Request for Proposal (RFP) issued by FirstNet the Authority includes a section known as Section J-8 that deals with dates by which certain items and portions of the network coverage are to be completed. This Initial Operational Capability description (IOC) will be used to track the progress of the successful bidder and to justify progress payments the FirstNet Authority will make to the winning bidder. There are five IOCs based on “months from award” by which the system can meet minimum operational capabilities and one more that serves as the Final Operational Capability (FOC).

It is important to understand that payments made to the winning bidder will not come close to covering the expenditures that will have been made. The bidder recoups this investment by putting the network into operation so it can use Band 14 spectrum to augment its own spectrum for commercial customers at times when Band 14 is not being used by the public safety community.

The RFP was awarded to AT&T on May 30, 2017. Therefore, IOC-1 was due to be completed by November 2017 (6 months), IOC-2 by May 2018, IOC-3 by May 2019, IOC-4 by May 2020, IOC-5 by May 2021, and IOC-6, the final set of milestones by May 2022. These time-frames are intended to keep FirstNet (Built by AT&T) moving forward and to provide FirstNet the Authority with measurable timelines to evaluate performance. When the vendor meets the timelines, a pro-rated portion of the $7.5 billion set aside by the federal government from proceeds of other spectrum auctions will be disbursed, and performance of the selected vendor will be evaluated.

Each IOC level has an increasing number of items that must be completed within that timeframe. Some have to do with the 3GPP release version of LTE (Long-Term Evolution) to make sure public safety has the latest updates. However, since 3GPP standards are not always released on time, the IOC timeframe for this task will probably change but the task is clear: Public Safety is to stay as current as possible with all LTE upgrades. I thought it would be of interest to compare today’s FirstNet (Built by AT&T) progress with the IOC list provided in the FirstNet RFP.

When comparing where FirstNet was expected to be with where the network is today, it must be understood that when the RFP was being written and then re-written after two comment periods, it was believed that the successful bidder would build out Band 14 for the entire network— only Band 14. With this in mind, I feel some within the public safety community do not fully appreciate how much more time it would have taken to provide additional coverage, add Band 14, and complete a number of related tasks that are not typical activities for a commercial network operator. We will compare what is actually available for FirstNet users today with what they would have had today according to the IOCs.

According to the IOC schedule, we should be four months into the third IOC, which requires:

  • Completion of Mission-Critical services and Operations Phase 1
  • Evolution of business support systems to meet future enhancements
  • Achievement of 50% of Contractor’s IOC-5 public safety device connections target
  • Completion of RF site integration of the CORE
  • Completion of Security Phase 3
  • Completion of Devices Phase 3
  • Achievement of 60% of Contractor’s Proposed Band 14 coverage in rural areas
  • Achievement of 60% of Contractors Proposed Band 14 coverage in non-rural areas

Note that 60% of Band 14 in both rural and non-rural areas must be completed at this point. This requirement was included for two reasons: First, Band 14 in non-rural areas is the moneymaker for the vendor, and in rural areas it was a point Congress wanted to hammer home. Thus, the RFP requires both rural and non-rural Band 14 coverage at the same rate of deployment.

There are a number of other lesser requirements for IOC-3 as well, including local control, devices, completion of Phase II coverage hardening, and other items needed to put the network into operation. IOC-3 does not conclude until May 2019, but it is fair to say that because AT&T offered up its entire pool of LTE spectrum including priority and pre-emption, many of these milestones have been more than met. For example, the CORE was in operation before the start of IOC-3.

Everyone from the federal government to the public safety community needs to understand what the expectations were for the construction and full operation of FirstNet when the RFP was released (sixty months) and how much of the network and the other required operational parameters have been met well ahead of time. There is no doubt in my mind that FirstNet is much further along than it would have been had a vendor won the RFP and focused only on Band 14 as the Nationwide Public Safety Broadband Network (NPSBN).

At this time, we would be at a point where 60% of Band 14 would have been deployed, (Phase 3 is not due until May 2019) and only the first two phases of coverage would have been fully or partially implemented. Instead, we have a robust network that already covers a large number of agencies, devices to use on the network, some but not all the applications that will be available in a network that is as fully secure as any network can be, and more. It also demonstrates that FirstNet is important to the vendor and that while there are some areas where improvement in vendor/public safety communications is needed, for the most part, things are moving along well.

Especially in the western states, I hear complaints about it taking too long to fill in and expand coverage. Yet when you measure what is already available against the FirstNet IOC milestones you can appreciate how much further FirstNet is down the road than it might have been. We are all impatient for more and better coverage, to discover more applications and devices, and to be able to manage FirstNet on a local level. However, we also need to realize that it was only because of the winning bidder’s response to the RFP and its willingness to share its existing LTE spectrum that we have more than 2,500 departments signed up and making use of FirstNet on a daily basis.

There is still much to be done. Those working for the vendor know that, hopefully, FirstNet the Authority realizes that, and the public safety community should too. Think back to your Land Mobile Radio (LMR) network deployment. It did not happen all in one day and in many places and, as it should be, it is still being enhanced and additional coverage is being provided including inbuilding communications, new sites, and ways of extending the LMR network coverage to make it better.

The same will be true of FirstNet, but there is a difference between LMR and LTE networks. I don’t know of a single LTE network where the owner or operator has declared the network to be 100% complete. They too are adding capacity and coverage. FirstNet (Built by AT&T) will be making use of AT&T’s 5G assets as they are deployed, while the LTE portion of the network will continue to be tuned and expanded as quickly as possible. The contract may be for 25 years but the FirstNet network will outlast that. If any of us are still around as the contract expires, we probably won’t be able to recognize what FirstNet was “back in the day.”

Technologies change, they advance, and new technologies are discovered. If it has accomplished nothing else, FirstNet has brought an understanding of what is needed, how to build it, and how to keep it current, not letting it become outdated as some LMR systems are today. This responsibility is a full-time job for many and they do it because they understand how important this new network is to the future of public safety communications. I often look back to the days when this all started and realize the drive and goals then are the same as they are today. We have new people joining people who have been here since the beginning, working shoulder to shoulder to build and nurture this network. Our vendor has blown past the IOC-3 requirements and I expect it to blow by all the IOCs as it moves forward.

Winding Down

For the most part, I have been following the issues about data throttling and Net Neutrality being discussed by others who have done an excellent job of covering them. However, I do want to weigh in on one very important and often-missed point: Early on, the APCO broadband committee and others decided that the NPSBN would need its own network identifier. Every network in the world has a unique PLM-ID (Public Land-Mobile network Identification). APCO’s broadband committee, the Public Safety Alliance (PSA), and the Public Safety Spectrum Trust (PSST) all agreed it made sense for a nationwide public safety broadband network to have its own identity. Therefore, in 2011, the process was put into motion and ATIS, the organization in the United State responsible for assigning PLM-IDs, was contacted. After many discussions with ATIS and others, public safety received a separate, unique PLM-ID in 2011, a full year before FirstNet became a reality.

I bring this up because every device on the FirstNet network today has a SIM card with this special PLM-ID. This means these devices are registered on FirstNet, but in the case of data usage, it is also important that FirstNet (Built by AT&T) know each and every subscriber to the network has qualified as being part of a public safety entity and if there are any issues with data services, the Network Operations Center (NOC) can automatically identify the user as a bona fide public safety user.

Other networks can tell if the customer is an individual, part of a city or county group, or some other classification used by the network’s billing program for rate plans. However, they cannot easily determine if the user is a public safety user that needs be handled differently during major incidents. FirstNet users can be instantly identified and additional resources can be provided for them when they are needed. At the time we applied for and received the Public Safety PLM-ID, we had no idea it would play an important role in authenticating public safety users on a network, we thought we could use sub-categories to determine the general home location of the user. As it turns out, the PLM-ID, which is exclusively for public safety, enables the network operator to identify and work with the public safety community when needed. Last point—even non-Band 14 devices on FirstNet will have this SIM so no matter what part of the network the devices are on, their presence will be known.

Andrew M. Seybold
©2018, Andrew Seybold, Inc.

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1 Comment on "Public Safety Advocate: FirstNet Progress—RFP IOC Goals Compared to Today’s Network"

  1. Randy Kaminsky | October 12, 2018 at 7:25 pm | Reply

    Andy, How will the introduction of E-Sim technology effect the PLM ID and will it temporarily narrow the compatibility of some phone makes on FirstNet?

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