Groups Question 700 MHz Device Interoperability, Single Core in FirstNet Comments
Tuesday, September 05, 2017 | Comments
Industry groups are questioning device interoperability in the AT&T Long Term Evolution (LTE) 700 MHz bands in comments to the FCC regarding First Responder Network Authority (FirstNet) interoperability. Commenters continued to promote separate public-safety LTE cores and only one interoperability review, which should be conducted by the FCC, as well.

The questions come in response to the FCC’s request for comment on whether the commission should use FirstNet’s proposed criteria when evaluating the interoperability of a state’s radio access network (RAN) with the nationwide public-safety broadband network (NPSBN) under the second prong of the commission’s statutory interoperability analysis.

The Competitive Carriers Association (CCA) said it is critical that the opt-out process follow three important tenets: the review process must be realistic and attainable; evaluation must flexibly embrace different network configurations including core-to-core interconnection; and the NPSBN’s design should ensure that handsets used in the FirstNet ecosystem include all LTE bands, not just those chosen by AT&T.

CCA said FirstNet’s interoperability matrix ignores the role devices play in achieving public-safety interoperability. “The matrix fails to address interoperability concerns that FirstNet seems intent on creating through its support of handsets tailored to operate on certain networks at the expense of additional resiliency and redundancy in the event of an emergency,” CCA said. “This outcome defies the public interest, and threatens to reassert the de facto monopoly that failed public safety and led to the creation of the NPSBN.”

In a later joint notice of ex parte with Rivada Networks officials, CCA said AT&T, through FirstNet, has certified a series of devices for its network that support band class 17, but not band class 12 or band class 14. “Indeed, the current portfolio will not interoperate with other 700 MHz band licensees’ networks, and worse, these devices will not interoperate with the public-safety network,” the filing said.

AT&T said the FCC should disregard CCA’s comments on device interoperability. “If a state decides to opt out and instead embark on building a RAN in its state, it is likely that it would do so with a commercial partner, just as FirstNet has done with AT&T,” the carrier said. “Such a partner can source devices with band 14 capabilities by simply asking that band 14 be added to chipsets that are available today. These might include devices that operate on band 14 as well as the LTE bands used by Sprint, Verizon, T-Mobile, AT&T, or all/some of the above. The devices sold by FirstNet would in no way reduce the choices available to an opt-out state network operator, much less “lock out” an opt-out state as CCA breathlessly predicts. An ‘all LTE band’ requirement would leave users of the NPSBN and an opt-out state network in the same position, though — saddled with inferior equipment.”

On the issue of separate cores, CCA said the interoperability criteria applied during the FCC’s review of state plans “appear to permit interoperability through the interconnection of two cores on a roaming basis, which is critical to permitting states to operate their own interoperating cores.”

Verizon also asked the FCC to clarify whether a state may deploy a separate network core from FirstNet if it chooses to opt out of the FirstNet and AT&T state plan.

In its comments, C Spire also lobbied the FCC to allow separate public-safety cores. “For example, if Mississippi decided that it needed to provide higher priority to public-safety users via more aggressive pre-emption of non-public-safety traffic, it could not do so by deploying a state-specific RAN alone,” the company said. “It would require access to and control of a state-specific core. Indeed, Congress would not have created a specific opt- out process if all it intended to do was allow states to run dumb pipes without any local input into technology or capabilities.”

Several commenters also said the FCC is the only entity allowed to provide an interoperability review under the enabling legislation.

FirstNet Colorado Governing Body (FNCGB) said that the Middle Class Tax Relief and Job Creation Act of 2012 clearly provides that the commission is the sole arbitrator of technical interoperability. “Consequently, any effort by FirstNet or AT&T to impose additional hurdles on interoperability violates the Spectrum Act,” the Colorado filing said.

“Network design and interoperability guidance from FirstNet is welcome, but the Spectrum Act does not allow the FCC to subordinate its expert agency opinion to FirstNet,” the CCA filing said.

FNCGB said that any network policies referenced by FirstNet are incomplete at this time and therefore not applicable to the commission’s determination of technical interoperability. Both the FCC and FirstNet assume that AT&T’s implementation will meet the minimum technical requirements, but there has been no proposal to date for a mechanism to ensure compliance, Colorado said.

“In order for the commission to perform a proper analysis of whether a state meets the standard of minimum technical interoperability, the commission must also certify that the national network meets the same requirements,” the filing said. “Any test of a two-party relationship must ensure that both parties meet the standards. Without verification that FirstNet’s partner (AT&T) has met the interoperability standards, a fair and objective analysis of potential opt-out states cannot be met.”

Southern Linc, which recently partnered with several Alabama agencies to offer public-safety LTE services, said FirstNet’s spreadsheet of technical standards is ambiguous. The spreadsheet omits standards states will eventually need to know to interconnect with the FirstNet system. For instance, in a roaming arrangement, should state opt-out designs support local breakout or home-based-routing? States do not need to know which of these options FirstNet prefers to design their state networks, but states will eventually need to know this information to interconnect with FirstNet’s system.

All the FirstNet interoperability comments are here.

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