FirstNet – "Opt Out" means you choose a Capitalistic Approach, rather than a "Nationalistic Approach" to building the Public Safety Broadband Network.

My-oh-my the web we weave. Just read the following articled entitled “FirstNet: Is Opting Out an Option? Myriad factors and unknowns cloud the question for now” by
Adam Stone, Emergency Management on November 17, 2014.
The first thing that came to mind about this article was the lack of substance behind the negativity of an “Opt Out” solution — a solution that actually makes sense –especially in the absence of an alternative. As has been the case since the beginning – you show me yours and I will show you mine! In fact the “Opt Out” solution has been shown, presented, answered and quantified on many occasions with many different entities, State Governors, Legislatures and Public Safety Officials, and via a Public Private Partnership model. The only reason we are talking about this topic is because the alternative is either non-existent, toxic, or secretly bestowed upon only a select few for the benefit of a “nationalistic approach” where as their solution becomes very profitable option for the Federal Government and its overreaching control of the States assets – especially if classified as a Title II Utility.
Everyone hears the topic “Opt Out”, and then “he or she” hears about the need for the State to let the Federal Government come in and fund and build the solution “for free”.  Then we are told that “we” should avoid the topic of “Opt Out” all together by allowing this nice big brother to come in and just do it for you – which reminds me of myself when I was young.
As a self-centered little juvenile I used to instruct my little brother that the small lollipop tastes so much better than the big one and that I will take on the burden of eating the gross lollipop by allowing him to eat the much tastier one. As you may have imagined I made out pretty well on the back of my brothers hard efforts in collecting Halloween candy.
What this argument fails to disclose is that, yes, the State would be responsible for its own build, but doing so with a Public Private Partnership means private investment will actually come in, pay for the entire build, its deployment and operate it long-term — and prioritized for Public Safety! In fact the State just takes an ownership position then collects revenue from the P3 and Public Safety gets Free service. What’s so bad about this idea? After all isn’t that what the Nationalistic Approach would do, but only reap the benefits for themselves on a much more unrealistic scale? Where would they get the money to fund their solution? Who will build it for them? Who will run it? I can guarantee you it won’t be any State Governor. So, let me get this straight, I could have told my little brother that the smaller lollipop is so much better than the big one, then take ownership of all his lollipops, while at the same time still making him go out and collect all the candy? That would have sounded pretty good for such a self-centered older brother.  But, then it was just candy.
The reason is simple; the “FirstNet Nationalistic Solution” entitles this one organization, under the control of a select few, to monetize the use of the spectrum for their own vision of what the States need. Plus, it doesn’t hurt that they will take in all the profit for their own needs, while at the same still masking the need for the State to help fund it and build it anyway. Is it just me, or does something sound a little coercive and unethical about such behavior? Do we really think the Feds are going to come in and fund the deployment of FirstNet without hitting both the Federal tax base as well as the State tax base? Just because the carrier interest has been effectively undermined, doesn’t mean they have gone away. Ever hear of a wolf in sheep’s clothing? In this case we have the epitome of greed through an image of Satan dressed up in a sheepskin.
The fact is a Nationalistic Approach offers the chance for the State to supposedly get a network “for Free”, but it fails to disclose what the Feds gain in return. The return is the control and profitability of the valuable spectrum that should be specifically addressing a State’s own needs by monetizing the spectrum, and its revenue, to help improve “the State’s” economic concerns, employment outlook, and taxation relief under a State’s own control. Do we actually believe that a Nationalistic Approach to this, from the top down, will be in the best interest of the State, it’s citizens and its direct needs for Public Safety? Remember a majority of the emergency response solutions are local, so why have a Nationalistic Solution to a local problem? What part of the nationalistic approach addresses the tax relief part of the Tax Relief Act?
Having spent more than 25 years in the telecom industry, I can safely state that there has never been a network of this size and complexity created from a top-down approach. In context, if a network has to be created from the bottom-up, then why wouldn’t we start with a small design, in a select geography, that is created within the boundaries of one State? Does that not make sense – especially when it has so many efficiencies for its deployment needs, as well as its direct benefits for the State? Does this not bleed of alignment with the Middle Class Jobs Creation Act of 2012? If you’ve ever played fifty-two-card pickup, then you know you can’t pick up all fifty-two cards at once. You must pick them up one at a time.
The term “Opt Out” is not just a simple message of “a State will build its own network”. The term “Opt Out” means a State “Opts Out” of the Nationalistic Model, which will be the demise of the approach? If the Federal Government wants to declare telecommunications as a “Utility” within “Net Neutrality” then this nationalist approach would be the starting point to creating that overarching entity. Plus, as I have stated in the beginning of this article, FirstNet has no sustainable business model…it’s that simple. I have promoted a single business model, that I developed over ten years of research, which makes sense – that being The Myers Model® Public Private Partnership. 

What does Public and Private Partnership mean, as rush Limbaugh can attest, its a choice. Who do you want designing, building, operating and maintaining your Public Safety Broadband Network — the “Public” government?; Or, you and me the “Private” people? 
In the end the question is quite simple; “Governor, are you going to select a nationalistic solution or are you going to select your capitalistic approach? One solution gives benefit to the Federal Government and the other to your State.”
But who am I am I other than….
Just some guy and a blog…

The FCC, and the President, just did AT&T a huge favor! The answer to Net Neutrality is in the FirstNet mission.

With AT&T ceasing work the real message to the FCC, and President Obama, is the willingness of AT&T to hang their TURF contractors out over the cliff as a threaten to ruin an already fragile market. By doing so AT&T is threatening the President, and the FCC, with mass extermination of the already struggling contractors who are constantly squeezed like a lemon until an explosion of bankruptcy prevails. This isn’t the first time AT&T has had the market on eggshells, every time AT&T sneezes these small players face drastic measures of cutting staff. Most of these smaller firms are “hire-and-fire” companies as it is, which hasn’t helped the hiring process at all, but this may put a nail in the coffin for the entire market. But maybe AT&T didn’t think this all the way through, or maybe they did? By delaying their own plans to expand and capture more market, they may in fact be destroying the market for certain silos within their own company, which has been the intention all along.
If AT&T were already consolidating and stripping silos, that are detrimental to the bottom line, the most burdensome area to focus on would be the enterprise or fiber business. As I wrote about in the past, the only real piece of the physical architecture that is amenable to Net Neutrality is Layers 1 and 2 – that being the fiber, conduits, right-of-ways, etc.. The content and services layers, Layer 3 and above, are to fluid in their demand to meet market needs and are unmanageable in the context of Net Neutrality, multiply that by the number of providers and you will quickly see the useless advantage of trying to manage access and services in an equitable fashion. The focus of Net Neutrality lies in Layer 1 and 2, not the services layers of Layer 3 and above. This is why an Attorney, or a President, is not equipped to intervene in such a market; you must be abreast of what the Layers are within the telecommunications space. I don’t see too many network engineers struggling to change Tort Reform, why should we see Attorneys struggling with TCP, UDP or NAT services? It’s all about the money that’s why.
With that said, who is really suffering? If I were AT&T and I needed to shed the burdensome silos, which are severely detracting from my bottom line, what better way in making a needed drastic change than under the disguise of government intervention. Let the government come in and take over the fiber networks, for a fee of course, then I am free and clear to shed and consolidate my resources and re-shape the company towards the more profitable Content Services market, which is really where I want to go anyway. So in fact, President Obama just did AT&T a huge favor by giving them reason to eliminate the contractors who support their Layer 1 and 2 deployments. You should note that these contractors are encumbered with unions, so it’s not all bad.
In the end though, all the small contractors will suffer the most — which means you and I. AT&T gets cover and a real reason to morph its business into the much more profitable Content and Services space. And, the government gets what it was asking for — burdened with the cumbersome, costly fiber infrastructures, and a legal conundrum of drastic changes to unionization.
There is an answer though. The only way out of this mess is for the Government to leave the commercial assets alone; establish their own fiber infrastructure; and then allow Net Neutrality to happen on their own infrastructure. It may be just me but anybody else smell the stench of more taxpayer funding and a new overreaching government agency? The answer may lay with FirstNet.
FirstNet, and its requirements to build a nationwide broadband network in support of priority public safety usage, requires vast amounts of fiber transport and fixed microwave. If there is any asset that has the best chance of reutilization within the FirstNet deployment, it’s Fiber and Microwave. These technologies make up the Layer 1 and 2 infrastructure of the Public Safety Broadband Network. Being that the target coverage for FirstNet is 100% makes all available assets in this space attractive for repurposing to a nationwide architecture. As I have spoken about in the past, the only real business model to successfully implement such a broadband solution, that doesn’t cost the taxpayers anything, is through a Public Private Partnership – The Myers Model® in fact.
FirstNet needs fiber and the FCC wants to grant Net Neutrality – seems like a marriage made in heaven.
But who am I other than….

Just some guy and a blog….

FirstNet — Obama Tries to Design a Broadband Network and puts the FCC on the Hot Seat to Answer Net Neutrality and Broadband to all Americans — the Answer lies within the Public Safety Broadband initiative!

[“Net neutrality” has been built into the fabric of the Internet since its creation — but it is also a principle that we cannot take for granted. We cannot allow Internet service providers (ISPs) to restrict the best access or to pick winners and losers in the online marketplace for services and ideas. That is why today, I am asking the Federal Communications Commission (FCC) to answer the call of almost 4 million public comments, and implement the strongest possible rules to protect net neutrality.]
This is what happens when Attorneys want to design a broadband network. Before this can of worms gets opened allow me to explain something. The “Internet” is made of many layers. The first and second layers are basically the right-of-ways, the spectrum, the conduits and the networking equipment to power the “transport” network of broadband communications.  Essentially these two layers make up the physical infrastructure of assets. In the past, for the carriers to make money, they were forced to put money into these two layers so that they can provide “services” at layer 3 and above.  We can’t afford to get the “physical infrastructure” mixed up with the definition of “broadband content services and access”.
What really needs to happen here is the physical infrastructure (layers 1 and 2) needs to be classified as a Title II Utility, but the broadband services (layers 3 and above), which ride on top of the physical infrastructure, should stay in the open market.
If an “Internet Service Provider”, or video-streaming provider (Netflix, Blockbuster), wants to sell access to their content then why would we try to classify them as a Utility? These streaming companies aren’t in the business of access; they’re in the business of content. This is why you see AT&T delivering Uverse. UVerse allows AT&T to move into the content space, which is in direct competition with those streaming companies. The issue AT&T has is its own internal organization framework. AT&Ts organization is big, cumbersome and made up of many silos, some of those silos are still investing in upgrades to an infrastructure in support of the “old” commodities approach. Internally there are competing product silos that are trying to move away from physical access needs, while at the same time the corporate office are trying to commit to pure content delivery – which by the way is much more profitable than the traditional commoditized “Internet Access” model. To add, these new product offerings puts AT&T into a content market that is being dominated by much smaller niche players who are much more nimble, can react, and foster more focused creativity than the giant telecoms.
If AT&T can’t afford, or don’t want to play, in the access model delivered through the commoditized assets of layer 1 and 2, then are we basically saying that AT&T and Verizon are going to be a Utility?  Although this could be very lucrative, and there may be some entrepreneurs in the carrier space that wouldn’t mind the longevity and stability of this model, the case analysis demonstrates that it won’t be the best fit for these telecom giants. It’s too hard to change a horseshoe on a galloping horse in mid-stride during a terrestrial downpour in a field full of deep mud.  These organizations would have to expend large amounts of capital to make the change, to which has no guarantee it will even work when completed – if its ever completed.  Afraid to say but the future of the carriers will be limited to cost cutting measures and the stripping of silos that don’t match where the leadership wants to go. That means a LOT of layoffs are inevitable. Why is that?
As you can imagine the cost to build and maintain layers 1 and 2 are increasing the pressure on the traditional broadband services model where as the commercial carriers see the need to move away from owning the physical assets in layer 1 and 2 and moving to a pure layer 3 content and above play. This means a dramatic decrease in the overheads from their bottom lines and a dramatic increase in profit margins. But trying to get a large ship to change the course in a shallow pond will be suicide? If you sell broadband service to a consumer with a smart phone, then the overhead the carriers traditional must carry is roughly 70% of its profit margin. In short, I sell you a $40 dollar a month “all-you-can-eat” plan and I have to give  $28 away just to pay for my physical assets – and those costs continue to rise — especially when the carriers are being monopolized into building out to the rural areas where the cost justification of putting more money into the infrastructure doesn’t make sense.
Another hot topic is that the access model of old has been commoditized into stagnation and the cost of providing the infrastructure to support that commoditization doesn’t help.  The commoditization of the access opened the door to smaller, more nimble, broadband companies who only sell the broadband content that adapted to the broadband infrastructure that exists today. This is why the commercial carriers (AT&T, Verizon, etc..) are putting pressure on the streaming content providers to pay more for access.  
It’s just bad timing. The timing associated with expanding broadband to all Americans is forcing the issue of change onto the carriers, faster than they anticipated. A majority of the carriers are eliminating old architecture daily and are opting to sell assets to whoever wants it – as long as they get exclusive rights to that infrastructure. This means the carriers want to monopolize the access model for their own content – at least initially.  Title II puts kinks in that plan though — or does it? Look at the glass half-full in this case. By moving away from the notion of trying to monopolize their content delivery why not just let the assets go? Eliminate a lot of infrastructure, quickly, and move into more profitable content while at the same time eliminating deadweight draining blood from the bottom-line– just a thought.
The main course has already been established though. You are either at the table or you’re on the menu. There is one thing that is not being mentioned – FirstNet and the Public Safety Broadband Network.
Signed into law on February 22, 2012, the Middle Class Tax Relief and Job Creation Act created the First Responder Network Authority (FirstNet). The law gives FirstNet the mission to build, operate and maintain the first high-speed, nationwide wireless broadband network dedicated to public safety. FirstNet will provide a single interoperable platform for emergency and daily public safety data communications.
Why is FirstNet, or the Public Safety Broadband Network, so important? Well, because it’s the perfect catalyst to build one homogenous infrastructure of broadband fiber and wireless assets. By partnering within a prioritized scheme of users, where as Public Safety is priority 1, they will be a great opportunity to put money into the infrastructure of assets that the President is calling a “Utility”. The premise of FirstNet is to build a nationwide broadband network of fiber and radio access networks, the same architecture the carriers are trying to shed.
No, we can’t just buy the carriers assets to make it our own. What we can do is establish a framework for collecting land, right-of-ways and the spectrum to build a truly hardened, protected and cyber-secured infrastructure that enables all layers of prioritized access and usage schemes – to include commercial broadband access to all Americans and the ointment to the “Net Neutrality” rash. This new National Asset will form the baseline for the communications framework of the nation. Work has already commenced on this front. Why not consider the infrastructure needs of FirstNet as the basis for creating a Public Private Partnership between government requirements and private industry needs for a holistic access model? Sounds like a great solution that knocks out multiple birds with one stone. There is one model that was designed for just this purpose….The Myers Model®.
But then who am I other than….
Just some guy and a blog….

FirstNet — Public Safety Community! Never bite the hand that feeds you!

Everyone has heard the term “don’t bite the hand that feeds you”, well this may be the epitome of such a K-9 expletive. But, it’s been along time coming and finally we are getting somewhere. Addressing a recent article entitled, “Public-safety groups disagree on ‘public-safety entity’ definition, including utility usage of FirstNet”, dated Nov 6, 2014, by Donny Jackson of Urgent Communications.
“An electric utility, or any equivalent entity, does not fall within the definition of public-safety entity,” the APCO filing states. “Any conclusion to the contrary would be a plainly wrong reading of the Act’s provisions, and a stark departure from Congress’s intent to create a dedicated network for first responders.
“If Congress intended a broad definition of the kinds of entities that would be considered ‘public-safety entities,’ it certainly could have mentioned groups like utilities, highway departments, or building inspectors, etc., rather than reference existing statutes with language like ‘sole or principal purpose of which is to protect the safety of life, health or property’ and ‘emergency-response providers.’
What does “Public Safety Entity” mean? This question seems to be the topic of the day. I think a lot of people are confusing the term “Public Safety Entity” with “Priority Access”. There are a couple of things that one needs to consider.
The Public Safety Broadband Network (PSBN) is just a broadband network — a broadband network running LTE as its RAN (Radio Access Network). In actuality the PSBN network is the exact same type of network and technology that runs our smart phones today. No we don’t want the carriers to run this network! The only difference between deploying this solution from a carrier deployed solution is the frequencies that FirstNet will operate on — plus a lot more hardening, protection, coverage area and its user base.
With the term “Public Safety Entity” it’s easy to see how one can envision some Fire Station or Police Station somewhere, but in reality anybody that performs some type of protection, life saving or intercession during an emergency is really considered a “Public Safety Entity” – such as Police, Fire, EMS, Utilities, Transportation and the likes. There is an issue when defining the “Public Safety Entity”.
When we try to define a “Public Safety Entity” it’s natural to think in terms of prioritization, this is where we need to focus in order to solve this problem. Defining “Priority Access” is not the same thing as just defining a “Public Safety Entity”. To define Priority Access we need to know the normal operational procedures and those procedures that are adhoc during a disaster from any and all entities that partake. From that analysis we can then allocate entities to certain pools of “customers/users”.
The broadband technology we have today; the fact that we are just now defining mobility; and the creative associated with new applications yet to be envisioned; the initial rollout of this network will be under utilized. We must consider these characteristics when defining priority access. During normal operations the justification is more specific to meeting the needs of a business model so we can fulfill self-sustainment and funding obligations. Defining priority access during an emergency is all about who needs to get there first, what must they do when they get there, and how should they support the bigger disaster situation at hand. To think you can fund, design, build, and operate a network based on just one of these defining processes will not suffice.  There is not enough revenue to “self-sustain” either solution separately. You need both.
In essence, when defining a “Public Safety Entity” you must first define a customer’s/user’s needs then define the technical Quality of Service (QOS) they will be assigned during times of normal operations and times during a disaster. It’s really that simple. If you are a Police, Fire or EMS entity then you will get priority 1 all the time. If you are a Utility you will get Priority 2 during normal operations and then, based on need, you will be provisioned Priority 1 as required. Most of the time this can be defined ahead of time and automatically applied when the incident commander takes charge – that’s part of the beauty of LTE.
Getting back to the “not enough revenue to sustain” comment – I want to discuss the term “Normal Operation”. As each entity is defined into their respective priority groups, Priority 1 group is First Responders; Priority 2 group is Governor defined service support organizations, i.e. Utilities, Transportation and the likes, we can concentrate on making the solution viable and sustainable for the long-term (there is also a Priority 3 group but we won’t talk about that just yet).   Priority 1 users need to realize the importance of Priority 2-3 users. This network will not be possible without the support and the user-base that these groups bring. Without their incorporation into the solution then Priority 1 users won’t have enough cash to make it work.
The spectrum is allocated to Public Safety, that’s why they’re defined as Priority 1, but those Priority 1 users mustn’t believe that they can design, build, operate and maintain such a complex platform of communications on their own. Let alone the cost impact on those organizations to equip their overheads with the talent needed. The fact is this broadband solution will redefine any organization as a telecommunications player that will compete with its overall mission of saving lives. We’re not talking about a 5-10 site LMR network; we’re talking about thousands of towers, backhauls solutions, fiber transport initiatives and hundreds, if not thousands, of provisioned services. Just the resources alone will blow away any OPEX budget on any Federally or State provided budget for Public Safety.
If AT&T spends $30 Billion in two years to do an upgrade what do you think FirstNet will require? AT&T only covers 42% of the geographic landmass. How many resources do you think AT&T employs just to make their own private network work? For a Public Safety organization to think they can do it on their own will only delay the inevitable. We must have cooperation between all three Priority Groups of users so that we can create a broadband company that mimics the requirements of commercial carriers, yet stays private in nature and purely focused on the broadband needs of the Priority Groups.
In closing, the technology can decipher, isolate and prioritize the traffic anyway we want and on any given situation. The governance will establish the framework for the prioritization of users in both normal situations and during disasters. Given the size and the complexity of the required broadband solution, it is inconceivable to think that “Public Safety Entities” can do it alone – it has to be a partnership between Priority 1, Priority 2 and Priority 3 requirements. Thus, in defining the term “Public Safety Entity” we need, we require, that the term stay “broad” in nature, and yes, we must always remember who the Priority 1 users are. Nobody “owns” this network. The network is being built as a national asset in support of prioritizing Public Safety first under one homogenous broadband communications platform. If anybody physically “owns” this network it would be at the State level. FirstNet will govern the national asset from the Federal level in support of Public Safety in general and for the State’s needs. Public Safety doesn’t exist otherwise.

To put things in perspective though, as I have stated in the past, its just an LTE network. Technically we can design it anyway we want, but who gets access, and what priority they fall in, has to come from the State Governor. That is where they project team will sit when designing, building and implementing the State’s portion of the network, so this is where our focus should be. 

But then again I’m…

Just some guy and a blog….