November 22, 2016–The FCC should require states that submit alternative plans to deploy a radio access network (RAN) other than one deployed by the First Responder Network Authority’s (FirstNet) partner should make a detailed showing that the RAN will be interoperable with the nationwide public safety broadband network, AT&T, Inc., said in reply comments filed yesterday.
“As with any nationwide communications network, achieving and maintaining interoperability for the NPSBN will be incredibly challenging. The complexities will be multiplied if a State should opt-out, and Congress’ objective for a nationwide, interoperable network would be doomed if such a State should fail to establish and maintain an interoperable RAN,” AT&T said in comments in PS dockets 16-269, 12-94, 06-229, and WT docket 06-150. “Indeed, a lack of interoperability in a single State could have a catastrophic impact on the NPSBN as a whole. Accordingly, a State that submits an alternative plan should be required to demonstrate in detail how its RAN would be interoperable with the NPSBN, and demonstrate a serious long-term commitment of resources, funding, expertise, and cooperation. Without such showings and commitments from opt-out States, FirstNet’s NPSBN risks being balkanized—neither nationwide nor interoperable.”
AT&T, which is one of three entities that is known to have submitted a bid for the FirstNet contract, submitted its comments in response to a notice of proposed rulemaking released by the FCC in August seeking comments on the rules it should it adopt to evaluate alternative plans from states that want to opt out of having FirstNet’s partner build their RAN (TRDaily, Aug. 26).
AT&T said that states that want to opt out “must meet a heavy burden of demonstrating true interoperability and an ongoing, genuine commitment to maintaining interoperability across the network—from the RAN to devices to applications and beyond—throughout the duration of FirstNet’s operation. The Commission should demand that opt-out States meet this burden, and should include user equipment (‘UE’) and applications in its review.”
In other reply comments, FirstNet said that states that submit alternative plans should not be able to amend or submit supplemental versions of their documents to the Commission. FirstNet said that permitting such filings “would compromise the timely deployment of the network in conflict with the statute’s express mandates. Moreover, such a process would add uncertainty to network planning, deployment, and sustainability.” – Paul Kirby, firstname.lastname@example.org