Public-Safety Groups Request FirstNet Interoperability in FCC Filings
Tuesday, October 08, 2019 | Comments

Several public-safety professionals and jurisdictions, along with commercial carriers, said the FCC should require interoperability between the First Responder Network Authority (FirstNet) and other Long Term Evolution (LTE) carriers and LMR networks, while FirstNet and its contractor AT&T said third-party interoperability is not outlined in the legislation that created FirstNet.

“As a chief of police for a large metropolitan department, it is vital to our overall success during a critical incident to ensure public safety has interoperability between FirstNet and other carriers,” said Jeff Spivey, chief of police for Irving (Texas) Police Department. “I believe the right to choose a provider is important to ensure agencies can make decisions based on the needs of their individual communities. So, cross-carrier interoperability with FirstNet is a must for that to happen. If not, we’ve just created another ‘stove pipe system’ with the only difference is it’s run by the federal government. This takes away local governments’ ability to choose what carrier they would like to use if they want to be interoperable with FirstNet.”

Comments were filed after the FCC last month requested input on petitions for declaratory ruling and rulemaking filed by the Boulder (Colorado) Regional Emergency Telephone Service Authority (BRETSA) in to ensure interoperability with the First Responder Network Authority (FirstNet).

Last year, BRETSA asked the FCC to issue a declaratory ruling and a notice of proposed rulemaking (NPRM) or notice of inquiry (NOI) on the same grounds presented in a request for clarification previously filed by the Colorado Public Safety Broadband Governing Body (CPSBGB).

“We do not believe Congress intended to award frequencies to FirstNet to enable it to become yet another silo leveraging market share on limited interoperability,” BRETSA said in its comments.

The agency said that the longer the commission delays clarifying the interoperability requirements of FirstNet and other public-safety radio systems, overseeing and actual progress toward full interoperability, and providing recourse for service or equipment providers met with refusals by other providers to implement full interoperability, the more full interoperability will be impeded by market incentives for providers to leverage market share through proprietary implementations of services, interfaces and features.

The Minnesota Department of Public Safety Emergency Communication Networks (ECN) said the FCC should issue a declaratory ruling to confirm that interoperability is a fundamental responsibility of FirstNet. Minnesota’s two-way radio network ARMER supports nearly 2,000 law enforcement, fire and EMS agencies throughout the state with more than 96,000 registered users.

“When mission-critical push-to-talk (MCPTT) services are offered through FirstNet or other wireless broadband providers, these services will likely be used to supplement the voice services provided by ARMER,” the agency said. “As a result, it is critical that interoperability exists between these multiple services to fully support the public-safety mission.”

MCPTT should also support interoperable features including common talkgroups between the different services, voice coding algorithms, radio/device IDs, priority settings and encryption, Minnesota ECN said.

Additionally, survey research performed by the state indicates that all four nationwide wireless broadband service providers provide service to public-safety agencies throughout Minnesota. Public-safety subscriptions to FirstNet are expanding; however, at the time of the survey, a large majority of public-safety broadband subscriptions were with providers other than AT&T/FirstNet. Minnesota ECN anticipates that multiple commercial carriers will continue to provide wireless broadband service to the statewide public-safety community for years to come.

“Therefore, it is highly unlikely that a single broadband service provider will be providing PTT and other broadband data services to public-safety agencies within Minnesota at any given time or at the scene of any given multiagency coordinated response,” the Minnesota filing said. “As a result, it is essential that interoperability of these services exists between broadband service providers, including FirstNet. The primary services that will require interoperability are likely to include PTT, MCPTT, situational awareness and video applications, as well as others.”

The agency also said interoperability solutions developed between service providers, including roaming partners, must include provisions to recognize and transfer priority settings associated with individual public-safety users, groups, and/or applications.

Ryan Poltermann, who works for Commdex Consulting, said many interoperability questions remain unanswered. Questions such as the differences in vocoder used and whether end-to-end encryption and rekeying particularly with LMR consoles will be supported are critical to public safety. LMR and LTE should be capable of using the same user talkgroups, device IDs should be shared across systems, and the location of each type of user should be available on both platforms for safety, his comments said.

“While the responsibilities of other carriers is highlighted in the FCC document, we request that FirstNet’s obligations to interoperability be addressed,” Poltermann said. “… Having multiple cellular carriers available to public safety is beneficial in normal operations and emergency situations: Many agencies choose to spread their operation across multiple carriers to achieve their required level of redundancy and resiliency necessary to support their life-saving missions. While AT&T has made efforts to cover as much of the country as possible, public safety demands complete redundancy, and thus, access to multiple cellular networks.”

Poltermann also noted potential problems with over-the-top (OTT) PTT apps and requested more transparency from FirstNet to public safety.

“All networks supporting public-safety communications should be fully interoperable, supporting consistent levels of priority and pre-emption and ensuring that all public-safety voice and data applications work consistently from one network to the other,” said a filing by The Digital Decision, a consulting firm that works with Verizon, among others. “Such interoperability is logical, technically feasible and achievable. Moreover, it is necessary to ensure that Congress’ goal of interoperable public-safety communications is fully realized.”

In joint comments, SouthernLinc and C Spire, two regional LTE carriers, said directing FirstNet to embrace network interoperability and offering FirstNet expert-agency guidance on how to achieve common standards and practices across communications platforms will reduce public-safety expenses and promote product differentiation and innovation.

“Southern Linc and C Spire urge the commission to affirm that ensuring interoperability between public-safety communications systems and other wireless networks is a fundamental responsibility of FirstNet,” the carriers said. “Holding FirstNet accountable for achieving interoperability is a critical national priority, not an indistinct future goal.”

Verizon suggested the FCC should use the SAFECOM definition of “full interoperability,” between different wireless providers’ public-safety communications networks, and said that ensuring that the public-safety community is able to communicate with one another was the prevailing federal government perspective when Congress passed the Spectrum Act, which created FirstNet. Verizon said FirstNet’s approach to date limits interoperability only to FirstNet customers communicating on the FirstNet network.

“Restricting users’ ability to use critical features and capabilities on a single network provides public safety users with proprietary ‘intraoperability,’ not true interoperability with other interoperable networks,” the carrier said.

Verizon said the commission should clarify minimum elements of full interoperability to ensure public-safety users recognize the benefits. Specifically, the FCC could require good faith negotiations between carriers on interoperability scope, open standards, and priority and pre-emption levels and protocols. Verizon said the legislation that created FirstNet preserved the full extent of the FCC’s Title III authority over non-federal spectrum licensees such as FirstNet that offer these services.

“Clarifying that FirstNet must provide full interoperability to meet its statutory and licensee obligations falls within the scope of this Title III authority,” Verizon said.

Conversely, FirstNet said the BRETSA petitions seek to “undo the work of Congress, the Interoperability Board, the commission, the FirstNet Authority and AT&T.” FirstNet said the interoperability mandate of the 2012 legislation directed the nationwide public-safety broadband network (NSPBN) to operate as a single network by requiring all the radio access networks (RANs) built under the FirstNet program public-private arrangement be interoperable with the RANs built by any states or territories that opted out of the FirstNet-proposed deployment.

“The 2012 act neither mandates nor contemplates any requirement for the NPSBN to be interoperable with (or that the NPSBN core connect to) separate commercial or other third-party networks, including, for example, LMR systems and commercial mobile radio service (CMRS) providers,” FirstNet said. “Simply put, as defined in the 2012 Act, the NPSBN is interoperable.”

FirstNet said the commission should dismiss the BRETSA petitions, with prejudice, and allow the 2012 framework to continue to govern the successful deployment and operation of the NPSBN.

“Mandating the ‘full interoperability’ and roaming capabilities BRETSA seeks is unnecessary, unworkable and unwise,” AT&T said in its comments. “It is unworkable because ‘full interoperability,’ if intended to mean heightened interoperability between the NPSBN and third-party networks, would impede FirstNet’s mission by creating a patchwork of separate networks — the very problem the NPSBN was designed to avoid. And it is unwise because so-called ‘full interoperability’ would impair network security and resiliency, while wasting time and resources.

AT&T added that the Spectrum Act does not require LTE- to-LMR interoperability. The legislation created an Interoperability Board tasked with “develop[ing] recommended minimum technical requirements to ensure a nationwide level of interoperability for the [NPSBN].” In turn, the Interoperability Board developed a single recommendation regarding NPSBN-LMR interoperability, which itself is a recommended aspiration, AT&T said.

Nonetheless, AT&T said it is developing LTE-to-LMR interoperability solutions. “FirstNet PTT over LTE has the capability to be interoperable with a public-safety agency’s existing LMR network today, providing redundancy and extending the reach of its LMR network,” the carrier said. “AT&T also supports a wide array of open IP-based standards that provide subscribers with a variety of options for implementing LTE interoperability between an LMR system and the NPSBN, including Project 25 (P25), radio over IP (RoIP), Inter RF Subsystem Interface (ISSI) and Console Subsystem Interface (CSSI).”

The carrier reiterated its commitment to announce MCPTT services by the end of this year and said it released a request for proposals (RFP) for an interworking gateway function that will terminate standard system interfaces and allow MCPTT to interoperate with existing LMR technologies.

AT&T also said the legislation requires NPSBN users to be able to roam on commercial networks, not that third-parties be able to roam on the NPSBN. “Permitting widespread commercial roaming on the NPSBN would be contrary to FirstNet’s mission of creating a dedicated public-safety broadband network,” AT&T said.

AT&T said imposing full interoperability and roaming requirements would expose the NPSBN’s highly secure core to other networks that lack the same security features. “The result would be multiple attack vectors that could penetrate the system, undermining the reliability and security that the NPSBN was created to achieve,” the carrier said.

Reply comments in the matter are due Oct. 11.

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