DOD, FBI-LEEDA Raise Questions About FirstNet in Comments to NTIA

"I think it just shows there’s a lot of education that still needs to be done about [FirstNet] and a lot of questions,” said a public safety official Tuesday.

Since FirstNet “could be used to support the United States during both natural disasters and attacks, it is recommended that consideration be made in reviewing the ownership composition of each mobile network operator (MNO),” the DOD group said. “The national security interests of the United States will best be served by ensuring that any MNO incorporated into the FNN is primarily owned by a U.S. entity or equivalent. By extension, similar considerations should also be made for networking and [radiofrequency] hardware as deemed appropriate.” The filing does not address the fact that Verizon Wireless, T-Mobile and Sprint Nextel, if the Softbank/Sprint deal is approved, are owned at least in part by foreign interests.

FBI-LEEDA suggested its members may not be willing to subscribe to FirstNet once it eventually is up and running. The group is made up of local law enforcement officials who took part in the training program at the FBI Academy or one of the regional FBI command colleges. Law enforcement was anxious to see a network built, but “there exist[s] in our community an ongoing skepticism that a federal program implemented by a single Board in Washington, D.C. will incorporate the diverse needs of 4 million first-responders,” FBI-LEEDA said (http://xrl.us/bnybh9). “This Notice of Inquiry does not dispel that concern. FirstNet will fail in its mission if law enforcement chooses to retain its legacy systems around the country based on FirstNet’s new costs and services."

FBI-LEEDA surveyed its membership and tallied 425 responses, with more coming in, the group said. Only 34 percent of those who answered said their “needs and requirements are known and understood” by the FirstNet Authority. Members also questioned the cost of the system. Only 31.6 percent said they would be willing to subscribe if the cost is $20 or higher per user per month and just 37 percent said they would be willing to buy new devices to utilize the national network. Asked if they had been approached to “provide input to the federal government” about the network, 93.4 percent no.

A second public safety official said the FBI-LEEDA survey shows FirstNet is still little understood, with many decisions to be made. “I think the information that is reported is accurate,” the official said of the survey. “The problem is the context in which you ask the questions.” The cost of the network and what services the network will actually provide won’t be known for some time and FirstNet could replace local networks, the official noted. Asked about the DOD comments, the official said: “The federal people think differently; they have different needs and they are the smallest community domestically” in the public safety world.

FirstNet needs to consider “multiple build-out models” when developing the national public safety network’s architecture, advocates of state and local government said this week. The National Association of Telecommunications Officers and Advisors, the National League of Cities, the U.S. Conference of Mayors and the National Association of Counties told NTIA its “concerns” with FirstNet’s inaugural proposals, in joint comments.

The $7-billion FirstNet is underfunded -- a point which has now achieved “general agreement,” the state and local advocates said. Private sector money is thus all the more important, they said, when considering public-private partnerships. The FirstNet board’s initial proposed model may lack practicality, they said. It calls for “user devices capable of operating on the spectrum bands of each mobile partner” but those aren’t available yet and “there may be both technical and market-based challenges to the development of such devices,” the commenters said. The model fails without the devices, they said.

Local governments have “a tremendous amount of infrastructure, such as towers, fiber, and microwave facilities” that should be leveraged in FirstNet, the state advocates said. These non-commercial sources of infrastructure should include utilities, they added. “These assets have already been financed by tax- and rate-payers and may be available for use at low cost,” they said. FirstNet should look at government-owned dark fiber and I-Nets for backhaul, commenters said. Such leveraging also has the potential to reduce complications with environmental reviews and zoning processes, according to the comments. They also slammed the “apparent lack of attention to the need for some measure of local control over network services.” The organizations described how local governments are most knowledgeable about relevant staff and first responders and how critical that knowledge is during a disaster. Jurisdictions also need to control “certain network operational functions,” they said, referring to “hands on the knobs” authority.

They encourage the FirstNet board to examine different projects, such as the One Maryland Inter-County Broadband Network and National Capital Region Network, for inspiration and lessons learned. They also ask the board and NTIA to lift the suspension on the seven suspended stimulus grantees tasked with their own public safety broadband networks. California’s BayRICs is one such grantee and submitted its own comments asking for permission to deploy as a pilot program (http://xrl.us/bnybon). “Quickly restarting these projects will preserve the work accomplished and immediately infuse an additional $382 million in [Broadband Technology Opportunities Program] funding into the nationwide network,” said Interim General Manager Barry Fraser. BayRICs also advocates for local control over FirstNet public safety services and offers a detailed critique of the proposed network architecture, with concerns about its hardening, security and a suggestion it use multiple layers.

The Minnesota Department of Public Safety recommend FirstNet build its core infrastructure first and its radio access network (RAN) second (http://xrl.us/bnybko). “Wireless users can access the FirstNet core network through private data networks, or by roaming on commercial carriers, until FirstNet deploys its RAN,” it said. The department added that 911 centers could access it then. It pointed out that the overall network may take years to build out. The focus should be on services, which “will ensure the highest amount of interoperability,” it said. The app store model isn’t “appropriate,” it said. The Arkansas Public Safety Broadband Working Group called for FirstNet’s immediate consultation with public safety officials and states along with a “well-developed” business plan (http://xrl.us/bnybmp). The group worries that the initial FirstNet architecture presentation didn’t discuss network security or the management of future network upgrades. It supports the app store model and suggests app stores “unique” to each state’s needs. The California Chapter of the Association of Enterprise Architects cautioned the FirstNet board to not reverse the public safety network gains of the past decade (http://xrl.us/bnybns). It’s “absolutely critical that any new network mesh with the existing network,” the chapter said, encouraging leveraging when possible.