Mixed Comments on Opt-Out Requirements, FirstNet Revises Interoperability Matrix
By Sandra Wendelken, Editor
Monday, June 19, 2017 | Comments

The state of Colorado, Southern Linc and Rivada Networks submitted comments generally agreeing with the FCC’s draft order outlining proposed rules for states that choose to opt out of the First Responder Network Authority (FirstNet) state plans.

The Colorado Office of Information Technology and the FirstNet Colorado Governing Body said the FCC’s draft order “does an excellent job at balancing the needs of the national effort with the ability of states to ensure that each has all options available to them to comply with statutory obligations,” the filing said. Colorado’s comments said any proposals to shorten the timelines in the FCC’s draft order or make the procedures and requirements more onerous would limit a state’s ability to prepare and file an alternative opt-out plan.

The FCC proposal provides for an opt-out state to have 240 days from the date of its opt-out notification to the commission to file an alternative state plan in the docketed proceeding established for that state. The 240 days includes 180 days to complete the request for proposal (RFP) process and an additional 60 days to complete and submit the alternative plan to the commission and FirstNet.

FirstNet told the FCC that the FCC should require an opt-out state to have in place an executed contract with a vendor prior to submitting an alternative plan to the FCC. Only one state — New Hampshire — has contracted with a vendor for a potential opt-out system.

AT&T officials said the commission should adopt a 60-day deadline for reviewing alternative plans submitted by opt-out states. AT&T also said the FCC should not allow an opt-out state to submit amendments or supplements to its original proposed alternative plan, and only the governor, not a designee, should provide opt-out notice to the FCC.

Colorado said the Spectrum Act does not require the governor of an opt- out state to personally notify the National Telecommunications and Information Administration (NTIA), FCC and FirstNet of the opt-out decision. “This interpretation of the act would lead to absurd results,” Colorado said.

In a June 14 filing, Southern Linc reiterated its position that opt-out states are allowed to operate their own core networks under the statute that created FirstNet. In its comments earlier this month, AT&T disagreed, saying the Spectrum Act “plainly precludes” an opt-out state from operating its own public-safety broadband core network.

The Association of Public-Safety Communications Officials (APCO) International said it agrees with the draft order’s finding that requests for consideration of a separate state network core are “outside the scope of [the commission’s] statutory review responsibility.”

APCO generally agreed with FirstNet and AT&T that opting out will be a difficult process. “Rivada does not need to be a facilities-based carrier to be able to begin to provide LTE (Long Term Evolution) services to states while it builds out the band 14 network — or to supplement band 14 after that network is built,” said comments from Rivada Networks. “Rivada can and will enter into MVNO (mobile virtual network operator) and roaming agreements with existing facilities-based LTE providers to obtain the capability for public-safety entities to use existing commercial LTE services in addition to Rivada’s dedicated band 14 services.”

FirstNet submitted a revised interoperability compliance matrix to the FCC June 16. “After the commission adopts its rules in this proceeding, FirstNet looks forward to having additional conversations with the bureau to discuss the commission’s evaluation utilizing the revised interoperability compliance matrix,” the FirstNet filing said. FirstNet removed numerous requirements from the interoperability compliance matrix.

The FirstNet revised interoperability compliance matrix and letter about the matrix are here.

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