On October 27, 2014, NPSTC provided its recommendations to FirstNet regarding elements of the network, the various categories of users, and the interpretation of rural areas. “NPSTC generally concurs with many of the interpretations offered by FirstNet on other sections of the Notice on which we do not comment. Also, NPSTC recommends that FirstNet draw on the expertise of the Public Safety Advisory Committee (PSAC) as it develops user definitions and work to ensure that its final decisions are consistent with the PSAC’s recommendations. The PSAC represents a wide range of public safety and government organizations and is working to develop comprehensive eligible user definitions based on generally accepted practices of the public safety community.”

“NPSTC takes the view that these definitional issues first and foremost must be addressed in the context of what will make the NPSBN more useful and helpful to public safety agencies in protecting life and property. Therefore, NPSTC urges FirstNet to pay close attention to the work and recommendations of the PSAC. Also, NPSTC believes actual use of the network once it is deployed will reveal opportunities and situations that cannot all be thought of in advance when developing legal definitions. Therefore, NPSTC urges FirstNet to leave room for some flexibility in any legal definitions so that future needs can be accommodated once actual deployment and use of the network is underway.”