More Public-Safety Jurisdictions Jump into FirstNet Interoperability Debate
Monday, October 21, 2019 | Comments

Three more public-safety agencies jumped into the debate around interoperability and the First Responder Network Authority (FirstNet) in recent FCC filings.

The states of Pennsylvania and Illinois and the New Jersey State Police, along with four entities that didn’t file initial comments, supported a petition asking the FCC to require interoperability between Long Term Evolution (LTE) commercial networks used by public-safety agencies. No public-safety jurisdictions or active duty public-safety officials asked the FCC to dismiss the petition.

However, several retired public-safety officials who advocated for public safety’s access to 700 MHz band 14 spectrum with Congress before FirstNet’s formation said the nationwide public-safety broadband network (NPSBN) is interoperable without connecting to other networks, agreeing with arguments from FirstNet and AT&T.

The reply comments were in response to an FCC request for input on a petition for declaratory ruling and rulemaking filed by the Boulder (Colorado) Regional Emergency Telephone Service Authority (BRETSA) requesting interoperability with FirstNet. Initial comments were due last month, and reply comments were due Oct. 11.

The main themes of the debate revolve around the best way to avoid LMR’s interoperability problems, interpretation of the legislation that created FirstNet and its interoperability intent, and whether the FCC has legal authority to develop policy related to FirstNet interoperability.

Pennsylvania FirstNet said it supports the BRETSA petition because first responders may subscribe to carriers other than FirstNet and when first responders arrive on the scene of an incident, they must be able to communicate with other responders on other networks or services.

“It doesn’t merely mean that a responder on one network can make a phone call or deliver a data file to a responder on another network,” said Pennsylvania FirstNet. “It means that the networks these responders use must follow the same priority protocols to ensure that all affected network operators treat the communications with the level of priority that is appropriate for the mission.”

Maj. Diane Stackhouse, Pennsylvania FirstNet single point of contact (SPOC), signed the filing and said public-safety applications, including mission-critical push to talk (PTT), must work consistently for all responders regardless of the network they use. A lack of interoperability risks the lives of first responders, the filing said.

“FirstNet was created to ensure reliable, effective and interoperable communications for the nation’s first responders,” the Pennsylvania filing said. “PA-FirstNet believes that FirstNet cannot fulfill that mission without ensuring that first responders using its network can communicate, without limitation, with responders on other networks.”

Illinois said it is “an enthusiastic supporter of the FirstNet project.”

“Based on our reading of both the Middle Class Tax Relief and Job Creation Act of 2012 and the relevant sections for FirstNet of US Code, Title 47, Chapter 13, Subchapter II, we believe that Congress intended that there be seamless interoperability for emergency responders between the FirstNet network and commercial cellular networks, no matter if FirstNet was built from the ground up, or supplied as a service by a carrier,” said Illinois in its filing.

“However, we see disturbing parallels between the current lack of prioritized interoperability between carriers and the history of interoperability (or lack thereof) between proprietary digital LMR systems,” the Illinois filing said.

New Jersey State Police participated in the JerseyNet pilot initiative instituted by the New Jersey Office of Homeland Security and Preparedness (NJOHSP). The pilot program used band 14 deployable technology with cross-carrier interoperability in mind, the filing said.

“The primary goal was regardless of who was going to be contracted to build out the network, that FirstNet would be able to handle all carriers gaining access to the public-safety band 14 spectrum in some contractual manner,” New Jersey State Police Communications Bureau said. “This would have allowed all network carriers to build equipment with the band 14 radios incorporated into them allowing priority access to the band 14 network and while establishing full interoperability. The New Jersey State Police supports a cross-carrier solution for FirstNet.

“Similar to P25 (Project 25), a standard needs to be established for FirstNet to promote interoperability at all levels. A lack of interoperability, especially during large-scale emergencies, impedes emergency response efforts, potentially placing citizens, first responders and the community at risk.”

Two reply comments were filed in favor of FirstNet and AT&T’s stance that the only way to overcome the national interoperability problem is with a single NPSBN with a single set of standards and a single independent governing board.

“First, it is critical that the FirstNet/NPSBN operate a single nationwide network and not a network of networks as suggested by some,” said Harlin McEwen, former chair of the Public Safety Advisory Committee (PSAC), established by the FirstNet legislation to assist FirstNet. “Without this fundamental requirement, any other networks that might want to interoperate with the FirstNet/NPSBN would limit the ability of FirstNet and AT&T to implement new and evolving technology that would be incompatible with those other networks. This is one of the primary reasons LMR interoperability has been unachievable.

“Second, the security of the FirstNet/NPSBN must be protected. There is a reason that operators of commercial networks in the CMRS (commercial mobile radio service) have not connected their networks. Sure, there are competitive reasons, but the primary reason is that it poses severe security risks. In today’s environment we see networks being hacked and compromised on a daily basis and the risk increases significantly when networks are interconnected.”

“The history of the mostly failed attempts to gain national LMR interoperability make it clear that we should not go down that path again,” McEwen said. “Interconnecting networks is not necessary to gain the interoperability the public-safety community has been advocating for many years.”

McEwen performs “very limited strategic advisory work for AT&T/FirstNet.” “I am doing that to make sure AT&T does not stray from the needs and goals of public safety,” he said in an email. “However I wrote the FCC filing without any input or advice from AT&T, and it is from the heart, my years of involvement with getting a nationwide public-safety broadband network.”

Another filing from Al Gillespie, Jeff Johnson, Richard Mirgon, Ray Flynn and Charles Dowd said they “collectively file these comments as founders and former members of the Public Safety Alliance (PSA) who advocated for the reallocation of the D block spectrum along with the funding to build a nationwide public-safety broadband network — our leadership, work, and advocacy that led to the creation of FirstNet and the Public Safety Broadband Network with the passage of the Middle Class Tax Relief in 2012.”

Some of the signatories receive compensation from AT&T, and Johnson and Dowd are former FirstNet board members.

The former PSA members’ filing said a single, national network vision was articulated in section 6202 of the legislation. “We reviewed that language with congressional staff prior to passage, and we continue to support that language today,” the filing said. “Subsequently, anything less puts the success of FirstNet and public safety at substantial risk.

“We would ask that even if the commission should believe it has legal authority that it should not intervene as it would be poor public policy to have multiple government agencies attempting to regulate FirstNet. This would only lead to confusion,” the filing said.

The former PSA members concluded their filing by arguing that the FCC intervening “would encourage those who would want to see FirstNet fail by attempting to use the commission and its process as a tool to disrupt FirstNet.”

America's Public Television Stations (APTS) weighed in to support the BRETSA petition and commercial carrier interoperability. APTS supports datacasting technology for public-safety applications.

“APTS, which has offered to FirstNet and AT&T the vast resources of public television stations on a number of occasions, thus far without success, agrees that such a review is advisable,” the filing said. “To leave public television stations, serving almost 97 percent of the American people — including some of the most rural and remote areas of our country — on the sidelines of the FirstNet infrastructure is to ignore a robust, reliable and ubiquitous partner whose public-safety capabilities have proven effective in a variety of critical use cases. An inquiry to address the scope of FirstNet’s obligations — and its willingness — to provide access to and from other public-safety networks, especially in light of FirstNet’s statutory requirements for coverage in rural areas, would be useful to all concerned.

“At a minimum, such a proceeding will provide the commission an opportunity to hear directly from public-safety entities across the country and to develop a record to assist FirstNet in creating the best possible communications ecosystem for first responders.”

Others supporting an FCC declaratory ruling that ensures interoperability with FirstNet and a notice of proposed rulemaking (NPRM) establishing rules outlining interoperability between FirstNet and other providers include William J. Bratton, who is an advisor to Verizon, and the Digital Decision, a consulting firm that works with Verizon.

“We are disappointed that FirstNet is evolving away from its original purpose by not allowing for interoperability between carriers,” said Bratton in a joint filing with Jerome M. Hauer, a former public-safety official and current consultant. “The lack of interoperability makes first responders’ jobs significantly more difficult, interfering with the ability of public-safety agencies at the city, state and federal levels to communicate with each other. This outcome endangers the lives of brave public servants and the people they pledge to protect.”

The Digital Decision said that earlier this year, based on the Department of Homeland Security (DHS) CISA Wireless Priority Service (WPS) contractual requirements, Verizon and AT&T completed a successful implementation of quality of service (QoS) interoperability between both networks when using DHS WPS provisioning.

“This interoperability now allows a WPS-enabled first responder's voice traffic to retain the QoS QCi (QoS class identifier) parameters through both carrier's LTE networks,” the filing said. “It demonstrates how critical DHS CISA (Cybersecurity and Infrastructure Security Agency) views priority interoperability between carrier networks. …DHS interoperability around WPS serves as an example of full interoperability. Similar to what DHS CISA mandated through contractual agreements with each carrier, the FCC needs to compel FirstNet to assume the responsibility for complete interoperability.”

Both FirstNet’s and AT&T’s reply comments said DHS interoperability work, including the Interoperability Continuum, can’t supplant the Interoperability Board mandated in the bill that created FirstNet. In its original comments, Verizon suggested the DHS SAFECOM definition of interoperability should be used.

FirstNet also said Verizon is mischaracterizing, misinterpreting and minimizing FirstNet’s responsibilities under the legislation. AT&T also weighed in, agreeing on those points, and said again that the network is already interoperable as Congress mandated.

T-Mobile USA addressed roaming to and from FirstNet to other commercial networks. “FirstNet asserts that only roaming from the NPSBN to other networks is addressed in the 012 Spectrum Act and that even that form of roaming is completely at its discretion,” T-Mobile said. “While the 2012 Spectrum Act admittedly only addresses roaming onto other commercial networks, the public interest requires that roaming from other commercial networks to FirstNet be available for all the reasons noted above. Rather than adhere to FirstNet’s overly restrictive view of its obligations, the commission should intervene to ensure the public interest and Congress’ intent are prioritized.

“Redundancy in communications is a critical component of preparing for emergency situations, and the most effective way of ensuring redundancy is by establishing cross-carrier roaming for public safety,” T-Mobile’s filing said.

ESChat’s filing addressed the issue of over-the-top (OTT) applications, specifically mission-critical push-to-talk (PTT) providers. An initial filing from Ryan Poltermann, a consultant in the public-safety industry, said OTT apps cause interoperability confusion for first responders.

“The availability of OTT PTT solutions offer a competitive and interoperable option to FirstNet’s future MCPTT solutions,” ESChat said. “It is ESChat’s position that public safety must be able to choose the wireless service provider or providers that best suits their needs. OTT PTT solutions offer the only option for wireless provider-independent communications — OTT PTT solutions that are able to take advantage of wireless carrier enhancements, such as QoS (quality of service), RAN (radio access network) priority and pre-emption as offered by Verizon and FirstNet. This approach provides public safety the most diverse and enhanced method for secure, reliable and interoperable PTT communications.”

Verizon, Mutualink and Poltermann, which all filed initial comments, also filed reply comments, expanding further on their views in favor of commercial carrier interoperability with FirstNet. Vermont resident Stephen Whitaker also filed reply comments with a technical feasibility statement for expediting interoperability and suggested Vermont could host a pilot project.

Would you like to comment on this story? Find our comments system below.

Post a comment
Name: *
Email: *
Title: *
Comment: *

On 10/24/19, Sean Tajkowski said:
Let me be clear. I'm saying the interoperability between two or more public-safety cores. Not a public-safety core to commercial core. Security policies and priorities are policy based and can be interoperable themselves; communicate on a purpose-built network for life safety. If they want to play and make money in this space, then cooperate. The technology is not the issue — never was with LMR either. It's the human factor. These are walled gardens we are talking about. No security risk on a purpose built network created for life safety globally.

On 10/23/19, Sean Tajkowski said:
After 9/11, recognizing the need for an overarching emergency communications strategy to address these shortfalls, Congress directed the Department of Homeland Security (DHS) Office of Emergency Communications (OEC) to develop the first National Emergency Communications Plan (NECP). Title XVIII of the Homeland Security Act of 2002, 6 United States Code 101 et seq. as amended calls for the NECP to be developed in coordination with stakeholders from all levels of government and from the private sector. In response DHS worked with stakeholders from federal, state, local and tribal agencies to develop the NECP, a strategic plan that establishes a national vision for the future state of emergency communications. The desired future state is that emergency responders can communicate — as needed on demand and as authorized, at all levels of government, across all disciplines.

Interoperability was the highest priority since the Sept. 11 incident with both a presidential and congressional directive in the matter. Why is this even being discussed as an option or a issue? It's a federal project that went against its own guidelines and directives while others were and are turned down for funding that not only meet these directives but build with these parameters in mind from day one. This entire program has been learn as you go and has very little planning outside of throwing money at the game. It's why we established an oversight group for this emerging technology in the first place. Planning was the goal, not sales and poor tactics. All I hear is look at what Verizon did wrong and stuff like that. Not interested. Show us how yours is better and fulfilled all obligations to current safety needs and future technological advances. This program is so mismanaged. I have nothing invested. I have been in the LTE space for over seven years, and you show me no additional value and go against proven risk management directives such as interoperability. Get it together. You're not exclusive, and there is no all-eggs-in-one-basket solution in a state of an emergency. You guys are dangerous with this model and your preaching. Fraud, just flat out fraud. Commercial lobbying over life safety. Sickened by these articles.

On 10/23/19, Leon van der Linde said:
Isn't it dangerous to have all your eggs in one basket? I would have thought that that would be a major concern or is there something else going on behind the scenes.
Interoperability will really mean that all networks will have to run exactly the same software and operating system and configuration. That could also be a problem.


August 2022

7 - 10
APCO Conference and Expo 2022
Anaheim, California

More Events >

Site Navigation