3 States Outline Concerns, Recommendations in Comments to FirstNet
Tuesday, August 11, 2015 | Comments
At least three states have made public their comments to the First Responder Network Authority (FirstNet) special notice and draft request for proposals (RFP), outlining areas of concern and recommendations for the federal entity.

The state of Ohio “strongly” urged FirstNet to consider existing commercial coverage as a primary metric in reviewing vendor proposals. “Regardless of whether FirstNet positions itself as a competitor to commercial cellular carriers or not, the organization must acknowledge that first responders are using commercial wireless service today, are very satisfied with their service, and will compare FirstNet’s offering to it,” the comments said.

Ohio said FirstNet’s baseline coverage model does not depict stakeholder needs in a meaningful way or convince state users to adopt the service. The state said FirstNet should also base coverage requirements on county-by-county coverage and needs assessments.

Ohio called FirstNet’s definition for substantial rural coverage milestones “completely inadequate” and “contradictory to FirstNet’s baseline coverage model.” Using the proposed rural milestones, FirstNet’s total rural coverage commitment is 997 square miles or 2 percent of Ohio. The state requested clarification and suggested FirstNet consider a different definition for “substantial rural milestone” that reflects a more robust level of coverage and is more consistent with its proposed coverage baseline.

Ohio also took FIrstNet to task for not providing details on its service level agreement (SLA). “… We feel that it is very difficult to comment on the Notice as a whole without seeing the proposed terms of FirstNet’s SLA,” the comments said. “The level of commitment of service — availability, response windows, support, remuneration of damages, dispute resolution, exceptions and many other factors — will drive the cost for vendor proposals and, in turn, FirstNet’s cost.”

The state included sample data and reference documents to provide FirstNet background on what users in Ohio will expect when FirstNet does ultimately publish an SLA.

In its comments, the state of Washington recommended that FirstNet publish at least three documents: a user requirements document, a preliminary RFP and a final RFP. Washington’s comments aligned with Ohio, suggesting FirstNet did not provide enough details on SLAs or governance processes to allow commenters to provide helpful information.

Specific to the acquisition process, Washington urged FirstNet to enable vendors to bid only on the functions they desire, whether packaged in a single bid or broken into many. “The result will be stronger bids for more tailored capabilities, reducing the inefficiencies caused by layers of subcontracts that typically plague large government acquisitions,” Washington’s comments said. “It will allow FirstNet to select the best provider for each function, freeing it from the partnering decisions of the prime vendor in a bidding team. Thus, FirstNet will not have to settle for a second-rate applications ecosystem, for example, in order to procure the first-rate radio access network (RAN) solution offered by a single bidding team.”

FirstNet should permit bids on a one-state, multistate or national basis to provide RAN, backhaul, subscriber adoption, subscriber life cycle management and covered leasing agreement (CLA) goods and services, Washington said.

Similar to Washington, the state of Colorado also took issue with the procurement process planned by FirstNet, agreeing that the process should be more agile. States should have a say in the vendor selection process as well, Colorado said.

Colorado also said the complexity of the RFP will hinder the network in several ways. “By creating such a complex RFP, it appears that there is the potential to only have a very small number of entities capable of developing the requested solution,” Colorado said.

The complexity could cause delays, increase costs and limit competition, leaving public safety in the same position it is in today, Colorado said.

Colorado also noted concerns with rural coverage, the long rollout schedule and timelines, and charging states for local control services.

“The ability for local entities to manage and control network activity in dynamic situations must be integrated into the standard costs and should not be an additional charge,” Colorado said.

FirstNet said earlier this month it is analyzing 175 comments, capabilities statements and operational architecture (OA) inputs into the special notice and draft RFP, which were due July 27. FirstNet is not making the comments public, but some entities that submitted comments are releasing them to the public.

Ohio’s FirstNet response is here. Washington’s comments are here. Colorado’s comments are available here.

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