Colorado Group Asks FCC to Ensure FirstNet Supports Interoperability
Friday, July 13, 2018 | Comments

The Colorado Public Safety Broadband Governing Body (CPSBGB), formally the First Responder Network Authority (FirstNet) Colorado Governing Body, filed comments asking the FCC to ensure the nationwide public-safety broadband network (NPSBN) supports interoperability and roaming. However, an AT&T spokesperson said the state plans to withdraw the filing, while a CPSBGB member said public safety was not consulted on any such decision.

Specifically, the group requested that the FCC clarify that ensuring interoperability is a fundamental responsibility of FirstNet and that interoperability is supported at all levels including network, services, applications and devices. The CPSBGB requested that the commission establish rules for all roaming arrangements to ensure interoperability. The board said the FCC should open a rulemaking docket to address roaming and prioritization as it applies to applications such as push to talk (PTT) and mission-critical PTT (MCPTT), as well as to other applications.

“A rulemaking will facilitate clear and moderated public input through a transparent process that will culminate in clear and established rules that will guide all participants and give public safety confidence in any service offering or carrier it chooses for LTE (Long Term Evolution) technology,” the July 6 filing said.

The filing, on behalf of public-safety stakeholders within the Colorado, included a report titled “Mission Critical Push to Talk (MCPTT) Implementation for Colorado.” “The conclusion of the report was that based on information received, the implementation of PTT and MCPTT in the FirstNet network would likely lead to interoperability issues within the state,” the filing said.

At the time of the report in December 2017, Verizon had 65 percent market share in Colorado, and AT&T had 15 percent. Therefore, the board said it is unlikely that a single network will serve the majority of public-safety users with implementation of the NPSBN taking place via a commercial carrier. National and regional commercial carriers have announced their intentions to enter the public-safety market with similar services as those offered by AT&T.

“While increased competition for advanced public-safety services is likely to benefit first responders through enhanced features and lower pricing, it is likely to simultaneously undermine the primary tenant of the NPSBN effort — interoperability,” the filing said.

The board said that recent statements by AT&T and FirstNet indicate that there is presently no intention to establish standards or agreements with other commercial carriers to ensure prioritized interoperability for critical public-safety applications and access. “We fear that without standards or agreements to ensure prioritized interoperability, first responders will continue to experience issues related to interoperability that will effectively leave the status quo unresolved,” the filing said.

The Colorado board said the FCC is the appropriate entity to establish rules to ensure interoperability because it has the necessary procedural and structural infrastructure, the technical knowledge through the Public Safety and Homeland Security Bureau and the statutory authority to adopt rules.

The filing cites the 2012 Aurora, Colorado, theater shooting as an example where 27 public-safety jurisdictions responded to an active shooter incident. A future scenario involving multiple agencies would likely involve multiple commercial broadband networks providing public-safety services. “In this theoretical scenario, agencies assisting the primary agency would not have interoperability or priority access in a roaming situation, which may prevent utilization of PTT and MCPTT functionality,” the filing said. “This is problematic.”

The FCC’s broad licensing authority gives it both the authority and the responsibility to ensure that FirstNet satisfies its various duties and responsibilities under the legislation that created FirstNet, the governing board said.

The filing said Section 1426(b)(2) of the Middle Class Tax Relief and Job Creation Act requires FirstNet to promote competition in the equipment market by, among other things, requiring that equipment for use on the network be “built to open, nonproprietary, commercially available standards” and are “capable of being used by any public-safety entity and by multiple vendors across all public safety broadband networks operating in the 700 MHz band.”

“AT&T’s closed product offering for PTT/MCPTT does not meet this open and interoperable standard,” the filing said.

In a July 12 filing, Verizon said the FCC should place CPSBGB’s request on public notice as soon as possible. “It is important that industry standards and agreements between network providers, equipment vendors and application developers ensure that interoperability objectives are achieved,” said Robert G. Morse, assistant general counsel, Verizon federal regulatory and legal affairs. “Verizon supports the development of such standards and agreements, and looks forward to working with FirstNet, AT&T, the public-safety community and others in the industry to achieve those goals. Interoperability should be supported across the entire public safety ecosystem and should include interoperability for services, applications and features (e.g., priority and pre-emption protocols) used by first responders.

An AT&T spokesperson said the state of Colorado notified AT&T of its plans to withdraw the filing.

“We are working to ensure that Colorado can benefit the most from FirstNet’s investment in Colorado,” said Brandi Wildfang Simmons, chief communications officer for the Colorado Governor’s Office of Information Technology, in response to a question about whether the filing would be withdrawn. “While the intent of the FCC filing was to bring attention to the ongoing need to collaborate with vendors and our local communities, we will work directly with our partners to address these concerns. We plan to provide this update to the FCC.”

Carl Stephens, a member of the CPSBGB who represents the 9-1-1 community, said the former Colorado FirstNet Governing Body is now the CPSBGB, so the group can champion all forms of broadband in the state, not just FirstNet. Fifteen public-safety professionals from around Colorado, along with Brian Shepherd, Colorado’s broadband program manager, comprise the board. Stephens said July 13 the board still has the same members and leadership.

"It was filed because we believe interoperability is very important for public safety, not just that apps are interoperable between systems but different systems are interoperable," Stephens said.  "While I believe strongly in FirstNet and am hopeful for its future, right now I believe it does not fit many agencies needs. Each agency has different needs but one of the common concerns I hear is that lack of coverage requires these agencies to use other providers, and we need all these providers to work together to create an interoperable system. That’s why I support the governing board's filling."

Stephens is the executive director at the Garfield Emergency Communications Authority in Rifle, Colorado.

"I was just told that [the governor's] office is requesting it be rescinded," said Stephens July 13. "This is without any feedback to the Colorado Public Safety Broadband Governing Body. I find this disheartening. During the opt-in/opt-out decision, the governor seemed to value feedback from the Colorado FirstNet Governing Body, but since now we are the Colorado Public Safety Broadband Governing Body, it appears that our opinion and the opinion of public safety is no longer valued."

“FirstNet is being built on open industry standards, which means that FirstNet subscribers will be able to seamlessly communicate with customers on commercial networks of AT&T, Verizon, Sprint or T-Mobile, and vice versa, just as they can today,” the AT&T spokesperson said. “The FCC has already properly declined to rule on this matter. Remember, the legislation behind FirstNet calls for a single, nationwide broadband network that will drive interoperability for first responders across agencies and jurisdictions — not replicate a patchwork of networks. This is what public safety urged Congress to create. But we know there are industry players working in the background to dismantle the vision of FirstNet for their own gain. And it’s our obligation to see to it that public safety wins.”

“We are focused on ensuring the delivery of the nationwide network that public safety asked for, as directed by Congress,” said a FirstNet spokesperson. “The FirstNet Authority looks forward to continuing to work with and support Colorado’s public-safety community as FirstNet is implemented in the state.”

The CPSBGB filing is here.

The MCPTT report is here. Information from the report was part of an article titled “Why MCPTT Interoperability Is Critical,” which ran in the March 2018 issue of MissionCritical Communications magazine.

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