Public Safety Advocate: News and Commentary

It has been an interesting few weeks. As of now, FirstNet/AT&T has 36 of the 56 states and territories opted in, New Hampshire has opted out, and the deadline for opting out is fourteen days away. I say for opting out since if a state opts in by December 28, that is great for FirstNet, but if states don’t make any decision they will have opted in by default. It will be interesting to see how all this shakes out over the holidays. Also, this week, Verizon, once again, has decided not to bid on a FirstNet system. In this case, it is California. Verizon stated it will not submit a proposal to the state of California because FirstNet and AT&T have the system rigged. That is the second time instead of bidding on the project Verizon has made an excuse not to bid. It now appears as though Verizon’s only desire is to keep its existing public safety customers and perhaps convince a few more to join them.

I don’t understand Verizon’s recent moves. It did not show up to bid on the RFP, after the award to AT&T it said it had looked at it but did not need the spectrum for secondary use, but that it has always supported the public safety community, which is true, at least for the past ten years. After the RFP award, during last year’s APCO conference, Verizon announced it would build a duplicate network including a core and provide Band 14 services to its public safety customers. There are two issues with that, the first being that FirstNet holds the license for Band 14 so Verizon cannot simply put its customers on Band 14. If it is really to offer Band 14, a second SIM would be required in the device and another contract would have to be in place with AT&T. The other issue is that the way the law reads there will be only one public safety core (redundant of course) and therefore every public safety user on Band 14 must be connected to that core, and it is mandated that the one core will be built, managed, and operated by AT&T. For the past few months Verizon has been quiet and now it claims it won’t bid the California RFP because FirstNet and AT&T are not playing fair. Based on what I have seen, I am not convinced upper-level management at Verizon is 100 percent onboard with these efforts.

It will also be interesting to watch New Hampshire. It appears as though the first order of business for the state is to negotiate a full contract with Rivada. I certainly hope New Hampshire protects itself against the possibility that when the losses start to pile up for the vendor, the state is not stuck with the bill. The state and Rivada now have 180 days to provide a plan to the FCC to ensure that the Radio Access Network (RAN) build-out in the state will be fully compatible with FirstNet and that it will be upgraded as FirstNet/AT&T upgrades its network. It would have been fascinating if the state had opted out earlier because then we would have a parallel course between FirstNet and the state to see how both systems are developed and built out. As it stands now, New Hampshire will be somewhat behind the curve in implementing its network simply due to the federal agencies that need to approve the RAN (FCC), award a grant (NTIA), and enter into a spectrum lease for Band 14 (FirstNet).

The other issue I have expressed regarding New Hampshire is that I don’t understand what the business model is for Rivada. There are not enough first responders in the state to generate sufficient revenue and Rivada has said it will charge public safety only a penny a month, but then I also saw that would be between the hours of midnight and six a.m. Still, most fire departments are volunteer, and most of the law enforcement community is made up of smaller departments. I don’t believe, therefore, that there is enough revenue to be generated from the public safety community to pay for a Band 14 system roll-out. Add to that the fact that at least now, I cannot identify any need for the Band 14 secondary spectrum for secondary use. If the Rivada model is still as stated before the FirstNet bid, Rivada will set up auctions for use of the spectrum and rent it out to other network operators on an as-needed basis. The problem I see with that model going forward is that there does not appear to be any shortage of bandwidth and broadband capacity in New Hampshire that would make the spectrum valuable to other network operators. There must be another model Rivada believes will work within the state. I only hope the state ends up with the network it needs and that it stays up and running.

Core Issues

One issue that is garnering a lot of attention concerns the FirstNet core. The core, or Evolved Packet Core, is actually a complex set of computers, routers, and other specialized products that run the network. The core does everything from identifying users, validating their access capabilities, locating which cell site they are in, and a lot more. At this point, FirstNet is saying there will be one core, and it will be the one AT&T is planning to deploy in May of 2018. In reality, this is not a single core, it has to be redundant as are all wireless broadband cores. The issue with opt-out states is that Rivada would love to build a public safety core inside New Hampshire but the federal law (not FirstNet, not AT&T, but the law passed by Congress) says an opt-out state has the right to build out its own radio access network (RAN) but it does NOT say it can deploy its own core.

The system architecture approved by FirstNet is that any first responder on the network, regardless of whether the state has opted in or opted out, needs to be connected directly to the FirstNet (AT&T) core and not some other core that is then connected to the FirstNet core. This does not mean an opt-out state cannot have its own core, but its core can only be used for secondary users on the system, not for the first responder community. The reason this is so important has to do with security on and over the network, the applications that will be fully vetted to ensure they are safe and remain up to date, the use of one set of log-on credentials, and much more. It makes sense for there to be a single system manager (core) in order to maintain security across all features and functions of the network.

I do not believe the FCC can direct the architecture or the core to be changed. The law is precise in stating that opt-out states can build their own radio access network and a RAN does not include a core. It appears that the matter would have to be taken up by Congress to have any changes made or perhaps even taken to court. Both options are time and money-consuming endeavors that would not result in any resolution in the near future. Therefore, the prudent course of action for opt-out states and first responders that decide to stay on Verizon or one of the other broadband carriers is to accept the decision and make sure any and all first responders who are on Band 14 spectrum are, in fact, attached to the FirstNet core and therefore have a contract in place with AT&T.

Opt-In States

As of the writing of this blog, 64.3 percent of the states and territories have opted in to FirstNet. That leaves 19 (New Hampshire is the only opt-out). As stated earlier, I think some of the states that have not made a decision will end up letting December 28 pass with no action by the governor, which means the state will be automatically opted in. In some ways this might not be the best choice for a state. It appears from what I am hearing that some states have reached agreements with AT&T for specifics that go beyond what was presented to them in the state plan. If this is true, the states that allow the date to pass with no action may not have provided the agencies within their states with the best possible starting point. The individual jurisdictions can and will certainly work with FirstNet/AT&T to reach the best deal and coverage they can possibly negotiate for the agencies within a state. However, they might have been better served if the state had stepped up and negotiated with FirstNet/AT&T before the state opted in and the locals have to deal with FirstNet/AT&T.

Buy, Lease, or Subscription

At present, AT&T has provided various pricing structures for services on the FirstNet network. It will be selling devices that have been approved for FirstNet and offering a few additions I am sure. You will also be able to purchase devices, handhelds, tablets, and in-car routers with capital funds earmarked for public safety as is common practice today. Or in some cases the devices can be leased. Some industries, including the land mobile radio Industry, are not only selling or leasing devices and/or services but are also providing a complete solution for an all-inclusive monthly fee. Many refer to this as a subscription service.

The latest industry to do this is the automotive industry. Volvo, Ford, and others have launched subscription services. A car is provided, insurance is provided, repairs are paid for, and you have the car on a month-to-month basis. I am not sure whether there are minimum terms but I know in the LMR industry Motorola and others are doing essentially the same thing. Need an LMR system? They will come in and develop one that fits your needs, install it, and then maintain it for a monthly fee. No capital expenditures (capex), only operating expenses (opex) and at the end of the subscription your system is replaced with a new, more up-to-date system.

Using this type of subscription service is almost like what AT&T and others are doing with bundling lease payments for devices on the same bill with the services. This goes a step further because it would be a system approach to a public safety department. All of the devices, handhelds, mobile routers, tablets, network services, and replacement of any lost or destroyed devices could be included in the subscription. For most departments, opex funds are easier to obtain than capex funds. The only issue I am aware of is duration of the subscription. Some cities and counties have limitations. But it appears from all I have read as though the subscription model will be used more and more for cars, equipment, services, and many other things. I wonder how long it will be before FirstNet/AT&T offers a total subscription service.

Conclusions

The end of 2017 is the culmination of a lot of sweat and tears, walking the halls of Congress, filing documents with the FCC, and enlisting the willing help of the former Vice President of the United States. Early on it was a dream of only a few people and it grew into what it is today because others believed and joined in the cause. It is what it is today because so many people worked so hard before and after the bill was passed. We were told we could never get it through Congress, then we were told we could never get the network built. We beat the odds and we will continue to beat them.

Those who would try to come to the party late after not throwing their hat in during the heavy lifting and those pushing states to opt out may claim they have the interests of the public safety community at heart. Perhaps they do but public safety has already lived through many issues of not being able to communicate. We saw that with 9/11, Katrina, Sandy, Maria, and more. It is time to do this right, and right means all first responders need to be on the same page at the same time.

Andrew M. Seybold
©2017 Andrew Seybold, Inc.

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