Andy Seybold’s Public Safety Advocate, July 20, 2017

MCPTT over LTE and Direct Mode
[Not quite] Mission Critical PTT over LTE is being tested and put into service for live network beta testing. Two things are missing from these trials and tests: a mission-critical or public safety-grade network for the Mission Critical Push-To-Talk application to run over and perhaps more importantly, the way forward to provide direct-mode communications. The UK’s LTE system for public safety to go live in 2020 and replace its existing Tetra system is probably, at the moment, the most robust of the existing LTE networks available.

Recently in France, the European Telecommunications Standards Institute (ETSI) held MCPTT testing sessions and a number of vendors participated to see how well they performed and if they met the 3GPP Release of LTE version 13, which includes specifications for on-network push-to-talk services but does not yet address the issue of direct-mode on and off-network communications. In many instances, direct-mode PTT is as important and in some instances, more important than network-based PTT services. While I recently wrote an Advocate about PTT over LTE and over Land Mobile Radio (LMR) that detailed some of this information, there are a number of things happening in Europe and especially the United Kingdom that could have far reaching effects on how and when PTT services are actually deployed over LTE on and off-network systems.  Read the full blog here Continue reading

FEMA Plans Nationwide EAS Test September 27

The Federal Emergency Management Agency has informed the FCC that it plans to conduct another nationwide test of the Emergency Alert System (EAS) on September 27. A secondary date for the test would be October 4, FEMA told the Commission in a July 14 ex parte filing in PS docket 15-94.

The second nationwide EAS test was held last September (TR Daily, Sept. 28, 2016). In April, the FCC’s Public Safety and Homeland Security Bureau released a report that recommended the agency take several actions in the wake of last year’s nationwide EAS test, including encouraging the use of FEMA’s Integrated Public Alert and Warning System (IPAWS) as the primary source of alerts and examining how to improve and expand IPAWS alert content (TR Daily, Apr. 21).

Courtesy TRDaily


NTIA Group OKs Guidance for Informing IoT Device Users about Security Upgrades

Guidance on how manufacturers of Internet of things (IoT) devices should communicate with consumers about security upgrades for those devices was adopted today by a multistakeholder group organized by the National Telecommunications and Information Administration.

The four-page document approved by the group advises providers of IoT devices to “consider communicating to consumers prior to purchase” whether a device can receive security upgrades, how those upgrades will be delivered, and the date on which the device will no longer receive upgrades.

“The ideal level of detail and the method of communication may differ across manufacturers, software providers, and product and service categories, as well as across buyer types,” it says.  “These voluntary communications may evolve over time as threats, solutions, and products change, and as needed to be consistent with consumers’ familiarity, expectations, and security needs.” Continue reading

FCC Fines Robocalling Platform $2.88 M

Over the dissent of FCC Commissioner Mike O’Rielly, the FCC today imposed a $2.88 million fine against Dialing Services LLC for “facilitating” unlawful robocalls. Commissioner O’Rielly argued that the Telephone Consumer Protection Act’s provisions against unauthorized robocalls apply to entities that actually place calls, whereas Dialing Services provided technology and services to customers that actually made the calls.

He said that he did “not have sufficient confidence that some of the allegations [made against Dialing Services] are correct.”  He added that the Commission “seeks to punish a technology and its operator,” rather than the companies making the unauthorized calls.  He said that the technology offered by Dialing Services could be put to legitimate uses, which “opens a huge can of worms.”

Commissioner O’Rielly also said he was concerned about the precedential value of the action, saying that “the guidance provided by this item will affect other technology platforms.” Continue reading

NW Regional Technology Center for Homeland Security Reports on Industry Day


The Department of Homeland Security (DHS) Science and Technology Directorate (S&T) Silicon Valley Innovation Program hosted an Industry Day in Seattle, WA, to share with the local tech community about newly opened topic calls in the following areas:

 3D Dynamic Mapping – real-time 3D mapping and visualization of the inside of building spaces under varying conditions.

 Energy Harvesting Fabrics – non-traditional power sources to reduce the logistical and weight burden that first responders are required to carry.

 Identity and Anti-Spoofing of Non-Person Entities –identity assurance and anti-spoofing capabilities for non-person entities (i.e., sensor platforms, wearable devices, small unmanned aerial vehicles).

Applications are accepted on a continuous, rolling basis and will be evaluated on a quarterly basis. For deadlines and more information visit the DHS Homeland Security Innovation Programs site.


Andy Seybold’s Public Safety Advocate, July 13, 2017

Location Services, When? The FCC has new rules for locating calls that come into the Public Safety Answering Points (PSAPs), and eventually they will include a third dimension, that being height of the phone above ground. Sadly, the requirements imposed on the carriers for next-generation 9-1-1 are watered down from what is truly needed. I have been told the Federal Communications Commission (FCC) relaxed its requirements at the request of carriers and the national carrier association. In any event, the new rules for incoming location are totally inadequate for locating citizen 9-1-1 callers and first responders who may be in trouble inside a building or other structure.

Further, while I have no visibility into the FirstNet state plans, I am told the requirement for better inbuilding location seems to indicate these services may not be implemented until 2022. This is too long to wait when there are technologies available today that can meet the most stringent of the public safety requirements and could be put into play much earlier. The FCC has been running test beds for several types of location-based services including GPS and cellular network-based, building a database of Wi-Fi hotspots, using beacons, and other types or combinations of technologies. It appears as though the systems approved by the FCC will be a blend of several different technologies for rural, suburban, and metro-area location services. As stated above, none of the FCC rules currently require anything close to what is needed by the public safety community. Read the entire article here Below is the weekly news courtesy of Discovery Patterns: Continue reading

Rinehart’s Regulatory Review June 2017, by Bette Rinehart

FCC Establishes Process for State “Opt-Out”

On June 19, FirstNet announced that it would be delivering to each state, via web portal, its proposal describing how it intends to build out the Radio Access Network (RAN). States will have 45 days to review the proposal and exchange feedback to FirstNet before the 90 day response period begins.  States who opt out of the FirstNet plan must submit their proposal to develop a state RAN to the FCC for that agency’s approval.  To get FCC approval, the state-proposed RAN must interoperate with the FirstNet broadband network.

This month the FCC established the timeline and process by which a state will notify the Commission of the decision to opt out as well as the FCC’s review process.

In the Report & Order the FCC determined:

  • FirstNet must notify the FCC of the date on which plans are delivered to a state or states
  • FCC must issue a Public Notice announcing the deadline by which the state or states must provide opt out notifications to FirstNet, NTIA and the FCC
  • States will have 90 days after receiving the final plan to review the FirstNet proposal and either accept it or opt out and build their own RAN.
    • Opt Out Notice must include certification that NTIA and FirstNet were notified
    • A special email address will be established for this purpose
  • Either the Governor or a designee may provide the notice
    • Governor must provide written notice of the delegation of authority
  • After opting out, the state has 180 days to:
    • Develop and issue an RFP providing for full deployment of the state RAN (not just development of a plan),
    • Receive firm bids in response to the RFP
    • Select a winning bidder
  • After selecting a winning bidder, the state has an additional 60 days to finalize their opt out plans
  • Opt out plans must be filed with the FCC within 240 days of the opt out notification
    • Filers may request confidential treatment of their Plan
  • Plans must address:
    • The four general subjects identified in the Act – construction, operation, maintenance and improvements of the state RAN
    • The two interoperability requirements set forth in the Act and
    • The Technical Advisory Board for First Responder Interoperability Report requirements for the RAN
  • The Plan must include a certification that the 180-day timeframe was met
  • The Plan must include a certification by the Governor or a designee, confirming the state’s adherence to FirstNet network policies relating to technical interoperability as well as to the Interoperability Board Report recommendations
  • Plans should follow the statute, have clear headers identifying each required element and an explanation as to how the state plan meets the requirements
    • Suggested headers are: Construction, Maintenance, Operation, Improvements of the RAN
    • Simply attaching the RFP will not be sufficient
  • Each filing will be treated as a separate restricted proceeding with the parties initially limited to the State, the NTIA and FirstNet
  • After the opt out period has elapsed, the FCC will release a Public Notice listing states which have opted out, each with a separate rulemaking proceeding
    • Parties other than the state, NTIA and FirstNet will have 30 days to ask to participate in the review of the state opt out plan.
      • Anyone making such a filing will have to explain why they are interested in the proceeding, how their participation would help the FCC in its review of the opt out plan and why their interests are not represented by either FirstNet, NTIA or the state.
  • The FCC will make an initial review (within 10 business days of filing if possible) of the opt out plans to ensure that they meet the filing criteria and issue one or more Public Notices announcing that the application has been “accepted for filing.”
    • The Accepted for Filing Public Notice will start the 90 day aspirational “shot clock” established by the FCC during which it must review and approve or dismiss the opt out plans
    • Within 15 days of the “accepted for filing Public Notice,” NITA, FirstNet and any others who have been granted party status in the proceeding must review and provide comments on the state opt out plan
    • The state will have 15 days to respond to any comments filed, by either amending their plan or filing reply comments
      • States may respond only to issues raised in Comments; they may not amend other areas of their plan
  • The FCC will suspend its 90-day “shot clock” only under special circumstances such as a national, state or local emergency that would require diversion of Commission resources to address the emergency.
  • FCC review of the opt out plans will be limited to:
    • The RAN elements (defined as cell site equipment, antennas and backhaul equipment) required to enable communications with subscriber devices using the PS broadband spectrum
    • Does the plan demonstrate compliance with the Interoperability Board’s requirements characterized as “SHALL”?
      • Those requirements were included in Attachment B of the Report & Order
  • The second prong of FCC review was to evaluate the interoperability of the state RAN with the PSBN.
    • FirstNet filed ex partes containing documents that they asked the FCC use when evaluating interoperability with the PSBN.
    • To obtain a full record, the Order requires the PSHSB to release a Public Notice providing a brief period for public comment on FirstNet’s proposals
    • Once the public input has been reviewed, the FCC will release a separate Order indicating which elements of the FirstNet proposal it will use to evaluate the opt out plans
  • States will not have to demonstrate interoperability in the field
  • FirstNet will not have to modify its network to suit a state plan
  • After completing the review of each state opt out plan received, the FCC will release a separate Public Notice for each request briefly describing the Commission’s decision.
  • NTIA will review elements related to coverage, financing, applications and equipment text of the Report & Order is available at:

Comment Sought on FirstNet’s Ex Parte Filings Related to State Opt Out Plan Requirements

Continue reading