Now that the 700 MHz D-Block has been reallocated to Public Safety to provide 20 MHz (10X10 MHz) of total nationwide broadband spectrum, funding, and a new governance organization, how do we measure the success of this new network? I believe it is important to be able to provide both those who doubt its viability and those who might be interested in forming public/private partnerships with a way to measure the level of success as the network is built and put into operation.
The Federal Communications Commission (FCC) has announced the membership of a committee to define the requirements for interoperability that need to be incorporated into the network. Once this task has been completed, the FCC will review the resultant recommendations and if it agrees with them it will forward them to the National Telecommunications Information Administration (NTIA) for use by the new governance organization known as FirstNet. I hope the FCC and the committee will draw on all of the great work that came out of the Waiver Recipients Working Group and several of its broadband committees within the National Public Safety Telecommunications Council (NPSTC), and the Association of Public-Safety Communications Officials (APCO International) with its Broadband Committee. Thousands of hours of work were put in along the lines of the FCC charter and with the short deadline imposed on the FCC by the law. In my mind, it would be counter-productive not to make use of all of the information that came out of these efforts.
The same goes for the FirstNet organization, which is to be named and in place by August 20, 2012. I hope it too will take full advantage of the knowledge that has come out of the above-named organizations and others. NPSTC, for one, has set up numerous sub-committees under its broadband committee with some of the best minds in Public Safety communications contributing to the work that has been completed and that is still in process. The Waiver Recipient Working Group’s sub-committee on interoperability has also done sterling work. FirstNet should also consider the recent APCO Broadband Committee work on a nationwide network roadmap, which differs somewhat from the exact language in the law. I believe this roadmap will give both states and local entities more choices in how to move forward, and this can be very helpful when striving for agreement among the various organizations that will make use of the network.
Once this early work is finished and the requests for proposals and other details are worked out, it will be time to start building out the network. As it is being built and Public Safety agencies come online, I believe that from the very beginning we need to track answers to the following questions as a minimum:
- How much of the area now covered by Public Safety mission-critical voice networks is covered by the mission-critical data and video network?
- In each area that is built out, how many users (actually customers) are signed up to use the network and what is the projection for more users moving forward?
- What is the cost per user? How much of that is for local network use and how much goes to FirstNet?
- How well does the network serve the needs of the agencies using it?
- How good is the in-building coverage?
- What types of applications are being put into service?
- How has the network helped keep first responders safer?
- How has the network helped contain incidents from becoming larger?
- How much of rural America is actually served by this network?
I am sure we should be measuring other parameters as well, but for purposes of this discussion, I want to convey the fact that we need to document and track the advancement of the network, its use, and its contribution to the success of the first responder community. We need to make sure that as we move forward there are ways to demonstrate to all that the vision of adding data and video capabilities to our first responders’ voice capabilities is paying dividends and that as the network evolves and new applications and services are brought online, the network is successful.
This brings me to some recommendations I would like to offer for a successful network and assurance that technical aspects of the network are not overshadowed by politics and other distractions. This network needs to be built and used by all first responders in order to provide the maximum benefit to the Public Safety community.
I believe that those that have already obtained waivers from the FCC for early build-outs should be permitted and even encouraged to build out their systems as planned. Those that have funds from grants should be encouraged to move forward as quickly as possible in order to meet their deadlines, and those that have waivers but no grant funding should be allowed to move forward if they are interested in self-funding prior to the nationwide build-out.
FirstNet and the States
As the law is written, FirstNet will be working with states on the implementation of the network, and it is assumed that states will consult with local entities to provide for the best deployment within each state. Eventually, each governor, hopefully with the input and advice of the statewide Public Safety community, will need to decide if that state wants to opt out of the FirstNet plan and take on the responsibility of building the Radio Access Network (RAN) in that state.
The big issue here is that some states are struggling with their own budget deficits and won’t be able to augment the FirstNet Radio Access Network deployment within their state. Further, during the past three years, very few states have been engaged in the process or are even aware that the new Public Safety Broadband system is law and that there is funding for it. It would behoove FirstNet to meet with the appropriate representatives from each state to educate them and to determine how they plan to move forward. This is vital since there are some political issues in a number of states and in some the relationships between local communities and the state are not as good as might be assumed. Therefore, I am hoping that FirstNet will assure that states involve the local Public Safety community in the decision about how to move forward.
The vision of the law appears to be that FirstNet will build, operate, and maintain the entire network. I am not sure this is a truly realistic vision. FirstNet cannot possibly know, down to the local level, what is required and the specific circumstances in each area. I would hope that FirstNet will, at the very least, allow operational control of the network to be handled by the local entities. The broadband network, even with 20 MHz of spectrum, will need to be managed during major local incidents and it is not realistic to assume that FirstNet will be able to manage, on a real-time basis, the local demand for bandwidth, priority levels, and Quality of Service.
Another issue that needs to be addressed is the concept of the Evolved Packet Cores (EPC). A broadband network based on LTE needs EPCs in order to function. It appears as though FirstNet will include some number of EPCs deployed across the United States and that the local and state Radio Access Networks will all be connected to these central EPCs. This is how commercial networks are deployed and it generally works well. However, even with this approach, a few of the nationwide operators have experienced nationwide outages. One of the differences between a commercial broadband network and the Public Safety Broadband network is that the Public Safety network MUST be “always on” and capable of mission-critical data services.
One of the weak links in a nationwide network architecture is that if a connection to and from the EPCs fails, or is disabled by an earthquake or other disaster, the RAN that has lost the connection is out of service. Since the EPC provides the “brains” to verify users, keep track of them, and locate them within the system, if the EPC connection is severed the RAN is useless and the system, in that area, will be non-functional until the connection(s) have been restored. Further, unless local applications servers are permitted, the EPCs will not only have to be capable of signaling data, they will have to handle very large amounts of data that for the most part should be handled on a local level.
Several committees have studied these issues in great detail and discussed them with LTE experts in the commercial world. What I consider to be a better approach would be to design the system to be more flexible. My preference would be to see the augmentation of the nationwide cores (EPCs) with two or more additional types of EPCs or cores. The first would be EPCs set up and run as EPCs hosted by a commercial vendor that could connect to the nationwide cores and serve a number of different agencies. Next I would permit major metropolitan areas concerned about having to access the nationwide core in a remote location to be able to purchase their own EPC, or at least the elements necessary to provide the minimum capability to maintain connectivity in the event of a service outage. I would also recommend that the system include the ability for local agencies or groups of agencies to host their own applications servers to minimize the amount of data traffic that must be routed through the nationwide EPCs. This would also save a considerable amount of money in terms of fiber and microwave backhaul costs and it would reduce the network’s operational expenses.
The bottom line for me is that while FirstNet is the organization charged with designing, building, maintaining, and operating the nationwide network, if the network is to succeed in its goal to bring mission-critical broadband to all first responders, some flexibility may be required in order for some states and many local Public Safety organizations to buy into the network. I am hoping that FirstNet does not interpret the law based on the exact meaning of the words but decides that some flexibility is needed to ensure the success of the network.
This is also an area that, while referred to in the law, is neither explicit nor clear and I have some concerns about how it will be implemented. If FirstNet interprets this part of the law to mean that all public/private partnerships must be set up and maintained by FirstNet and/or that these partnerships be on a nationwide basis, it will be a disservice not only to the network but also to potential local and regional partners that want to work with the Public Safety community. If FirstNet interprets this to mean that it is left to each state to work out public/private partnerships, in my estimation, this also will not provide the flexibility that is needed to assist in building the network quickly and in many suburban and rural areas.
There are, of course, some obvious partners that already provide commercial broadband services across the nation: AT&T, Sprint, T-Mobile, and Verizon Wireless. There are also many smaller wireless providers including Metro PCS, Cricket, members of the Rural Cellular Association (RCA), and a number of other independent wireless companies. A more regional approach to partnerships would permit electric and other utilities as well as the regional telcos to work with Public Safety. Many of these companies have infrastructure in the way of tower sites, high-tension towers, and other facilities for the location of cell sites. Many of them already make use of fiber and microwave for backhaul services, and some, including rural power co-ops, are sitting on a lot of money that could be helpful going forward.
Partnerships should not be viewed as one-size-fits-all, nor should they be viewed as statewide. I believe they should be viewed on a local or regional basis. Many telcos and power companies provide services across state borders, thus statewide partnerships would not always serve the majority of the population as well as partnerships based on a more regional approach. This is a complex issue that will have to be managed properly but it can be done and the more of these partnerships FirstNet is willing to consider, the further the $7 billion will go and the sooner we can obtain additional income to pay for additional build-out and operational expenses.
Cost Per User
This issue needs to be dealt with head-on and early. I have heard all kinds of numbers tossed around for this. It is assumed that in order to make the network self-sustaining over time that there will be a per-user monthly fee. Where this monthly fee is set will have a huge impact on the number of users, and therefore the income for the network. What we don’t know at this point is whether there will be a single nationwide fee per user or if states will be permitted to tack on an additional fee. In either case, if the goal of the network is to help it grow and provide broadband services to as many users as possible, the monthly fee will have to be reasonable. But what is reasonable?
One of the numbers tossed around by one of the waiver recipients in California when talking to a city council was a per-user fee of $72. This is much too high and will hold down the number of users any city or county will be able to have on the network. The result could be that the only users permitted by a city or county would be the senior officers of each department. This will not be enough to support the network. A price this high will also mean that some cities and counties will simply keep their current commercial broadband contracts and not move over to this network. This would not promote the nationwide, fully interoperable concept that was at the foundation of the network concept.
What do I think is a fair price to charge? That is a tough question to answer, but if I could set the price it would be less than $20 per user per month. However, I suspect that $40 per month per user would be acceptable to most departments. So the issue then is how many users are needed at $40 per month. Of course the other question that needs to be addressed is whether local cities and counties have to pay for the electricity, backhaul, and other operational costs associated with the network in their area or will FirstNet have to pay for these? If the locals have to pay, could they add a surcharge to the FirstNet fee in order to offset some of the costs? For example, could FirstNet decide to charge $40 per user and a city add $2 per user per month on top of this charge? If that model works, what are the right numbers?
Remember that there are no roaming costs associated with using the network anywhere it is built. The only roaming costs that will be incurred will be when a Public Safety device roams onto one of the commercial networks.
Another pricing issue for me is whether it would be better to charge per device. The network will start out with vehicle-mounted devices but over time, handheld devices will be added so that when personnel leave their vehicles they will still have broadband capabilities. Will we reach a point where there will be no vehicle-mounted devices and they will be on the person only? I am not so sure of that. A police car with a single officer in it would equal two devices or $80 per month. With two officers in the vehicle the monthly cost for that vehicle would jump to $120 per month. In a fire engine with a crew of four and one device mounted in the engine, we have a total cost of $200 per month.
I don’t have any concrete answers to the pricing issue, but it will have to be addressed and in some ways it is the same issue the commercial operators face when they set data pricing. How much can you charge per month and still attract users? However, in the case of a commercial operator the cost is borne by the individual subscriber or the company and not by a city or county that already has to make drastic budget cuts. At one point it was suggested that a fee be added to every commercial wireless user, just as there is today for 911 services. However, that was discarded by Congress a long time ago and would, I believe, be difficult to implement and track today. Still, the ongoing costs of the network will to have to be paid for somehow. The trick will be to set the price low enough that more Public Safety users will be on the network.
FirstNet has its work cut out for it, not only in the areas mentioned above but in many more as well. There is no way that those who authored the bill could have addressed all of these issues as well as others that will pop up once the system is underway. The bill could have been ten times longer and still not have covered all of the issues that will need to be dealt with. Therefore, it will be up to FirstNet to move forward and I hope its members will keep in mind that the goal here is to build the first ever, fully-interoperable, mission-critical broadband network for Public Safety.
There is no doubt in my mind that this group will have to be made up of very dedicated individuals with a broad range of knowledge including Public Safety requirements, network technologies and capabilities, and, of course, the financial aspects of getting this done. It will be a daunting task and the Public Safety community will need to stay unified in its effort to help FirstNet accomplish this goal in the fastest, fairest, and most financially sound way possible. I look forward to learning who is on the FirstNet board and how they plan to move forward. They will, in large part, determine the success or failure of this network. We cannot allow it to fail and I trust they will fully understand that as well.
Andrew M. Seybold