FirstNet — The State of New Hampshire just picked a proprietary solution for its Opt-Out Public Safety alternative to FirstNet?

/ drmikemyers / Leave a comment

A lot of people don’t understand what “spectrum arbitrage” is. You can do a search on something called “bandwidth on demand” (BoD). The concept of spectrum-arbitrage and BoD are basically the same thing, except Rivada’s Arbitrage platform switches and allocates unused RF signaling and splits the spectrum up so that users who do not have priority can use the portion of the network that is not being used – at the RF layer – so they say. The problem is that the Arbitrage solution is highly technical and introduces an enormous amount of complexities to the physical layered solution and initiates a highly sophisticated multipart business model requirement. What happens if the adjoining States who decide not to deploy the proprietary Arbitrage solution? What happens to the clients on those adjoining solutions? Does this mean that a local or regional carrier has to augment his own infrastructure to account for the difference in interfaces between an adjoining State?  How does a State that doesn’t employ the proprietary platform have its billing engine interface with a State that is proprietary? To me its counterintuitive to the development of a good network architecture based on a proprietary solution. I think we saw the same thing with Motorola and the LMR solutions a few years back, didn’t we? If the typical off-the-shelf-solution works exceedingly great, why add another proprietary layer of complexity to the mix? It just doesn’t make any sense. The plain truth is that it doesn’t meet the requirements of the law.

SEC. 6206. POWERS, DUTIES, AND RESPONSIBILITIES OF THE FIRST RESPONDER NETWORK AUTHORITY. (B) promote competition in the equipment market, including devices for public safety communications, by requiring that equipment for use on the network be — (i) built to open, non-proprietary, commercially available standards;
The real question is – acting as a sales person of a product line – how do I get my proprietary, non-standard, solution into the overall deal? It’s simple actually, you just mask its involvement as part of your “private” side of the Public Private Partnership you are promoting. Through the “private” side of the deal, I would introduce my product as a means for commercial assurance to guarantee spectrum to private entities, thus isolating the Public Safety spectrum. The problem though is that you are still introducing a “proprietary solution” to the spectrum allocation to the State, which is the basis for the law. In short, there is no way around implementing a proprietary solution to the Public Safety Broadband Network without breaking the law. There is a reason that the law states “built to open, non-proprietary, commercially available standards” and that reason is quite simple – the spectrum belongs to First Responders.
If we split the spectrum at its core, all we are doing is taking spectrum away from Public Safety and giving slices of it to others– thus the carriers creating the nine-tenths of the law scenario (let alone security issues). Plus, who wants to be the first in the Nation to deploy a proprietary spectrum solution? What happens if this proprietary solution is not well accepted by others? What happens if it technically fails? Who will be responsible for developing a new architecture to account for those technical issues? Who is going to have to pay the adjoining States that need to interface with a proprietary solution? Who will account for the losses if the overall business model fails? Who in the end will be held responsible? Maybe this is why the law was written the way it was written? The law was written to protect this allocation of spectrum to Public Safety.
A few years back there was a far less complex solution to using the underutilized bandwidth within a packetized network. The BoD (bandwidth on demand) solution became a proven method of delivering broadband to end users, but the offering never really caught on. Why you ask? Well because everyone can get their own fiber and their own transport network without the hassles of worrying about if they will have bandwidth available that day.  Plus, the traditional commercial networks of yesteryear were born on the TDM based solutions. The Time Division Multiplex solution was designed to carry 32-bit based traffic customized for voice. With the introduction of packetized networks, the TDM framework was not properly adjusted for the larger 64-1400-bit packet solutions. Plus, the TDM solution uses 30% of its 32-bit frame for call control protocols, thus was ill suited for the packetized requirements. In layman’s terms, the carriers used a network that was designed for voice and the internet needed packet networks. Then came the FDM solution.
In actuality the first DARPA and SUN (Stanford University Network) UNIX based networks were based on FDM, but when the commercial voice service came along they forced their standards onto the Internet, thus forced the architecture of TDM onto the market. Why? Because there was still more money to be made in voice services back then. The fact is 15 years ago BoD was a great idea for those small to mid-size players to which access to broadband is a steep cost to carve out – we’re talking small level bandwidth solutions – but reality of access service costs today is minimalistic and has no real bearing on the outcome, thus the demise of the Bandwidth-on-Demand using TDM frameworks. Ultimately it was a ploy to utilize the lost overheads in the TDM network to improve profit margins. When it came to spectrum, and still holds true today, the larger wireless players all paid for their own spectrum rights, so why would they need the split the RF signals on their platforms, thus the demise of any needed RF spectrum-on-demand solution– Arbitrage? What we face today is a repackaged gift of 15 years ago that is being peddled to the Public Safety market as a must have to save their priority status when using their own spectrum. It’s like getting a gift for Christmas from 15 years ago from Aunt Bev and then repacking it for Uncle Tom for this Christmas.  
With the amount of “conceptually’ unlimited bandwidth in fiber, and the amount of spectrum allocated for FirstNet, any other method of spectrum usage just introduces unnecessary complexities that can be unmanageable for a large network – such as a statewide or national deployment of broadband. Public Safety should be using its spectrum like a traditional carrier uses its spectrum – they use it all for themselves. Any secondary users of the network will be prioritized and isolated to packet based network architectures. The only real customers you will find in the spectrum market will be large carrier type organizations, who undoubtedly already have their own spectrum rights and just want to add more to their holdings. There is way more money to be made in controlling the entire band of spectrum for Public Safety itself and selling its available packet solutions to second or third parties, thus funding First and Secondary Responders for the foreseeable future. One sure way for Public Safety to lose their spectrum rights, would be to introduce private commercial operations that has way more intrinsic desire to expand profit services to its user base, thus forcing the Public Safety out of the picture in the long-run. The question will be asked later on, who has more need, and who supports more Americans? Following that question is when the politicians will take over.
One final thought; splitting the spectrum and allocating it to third parties, presents a major security problem and will require a large amount of funding to secure its foundation. Who is going to pay for the added requirement of securing an already overly complex cyber security mandate? How to isolate spectrum intrusion when you have all your commercial and private users on the same spectrum? What if the adjoining State doesn’t want to split up its spectrum under such a solution, how do we justify the secure connection between the two?
But what do I know I’m….
Just some guy and a blog…..

FirstNet — State of New Hampshire selects Rivada for its Opt-Out solution…..but why?

/ drmikemyers / Leave a comment
So the very first Opt-Out RFP hit the streets with New Hampshire back in January. Just recently the board, based on points, decided to go with Rivada over Parsons. This is a remarkable thing being that Parsons had only 4 weeks to respond to a bid to which Rivada spent a number of months massaging. Parsons still came in second beating Motorola and a few others. Beat Motorola! That is a big thing for this market. Remember Motorola is an industry leader in North America when it comes to the Public Safety market – they have 98% of the space. This isn’t the first time I’ve beaten Moto though. There were two other times as well and they were all about the Public Safety Broadband Network.
Who is Parsons? Parsons is what the market calls an EPC – Engineer, Procure and Construction – company. Parsons is usually associated with large-scale engineering and construction projects around the world; construction projects that are delivered with large Public Private Partnership arrangements. Why would an EPC be the best positioned entity for deploying the Public Safety Broadband Network as well as delivering a true Public Private Partnership?
Parsons does not promote a product, such as a radio, handset, or a “spectrum arbitrage solution”. By not producing a product this puts Parsons at a distinct advantage – the advantage of remaining non-committal to any product offering. By staying non-committal to any vendor’s solution, they are open to any solution that fits best for the client. In this case, for the PSBN network, we work with all vendors and have been working with them for years now. What about carrier relationships, don’t you have to be an OEM that works for the carriers to make any headway?
Parsons, which might surprise some, does a lot of work for the carriers. The EPC is best suited for the carrier space when it comes to the needed upgrades, new installs, large project road-mapping, and construction. So, naturally fitting into the build-out of the PSBN nationwide is not new to Parsons, especially when deploying large-scale Public Private Partnerships.
Parsons brings something that others cannot bring – a long history of constructing large complex builds; most importantly they bring direct P3 experience from around the world. What everyone needs to understand is that more than 80% of the Public Safety Broadband Network will be all about the civil and related construction elements – something Parsons is well suited for. The actual amount of OEM equipment in the PSBN will be less than 3% of the entire capital program to build it, so why put all the risk on an OEM to be the prime for the build – OEM being someone like a Rivada. Rivada’s primary focus is on selling its products — not acting like an OEM. In fact, when an OEM says they can build the PSBN solution, all they are doing is adding cost to the budget by layering pass-thru partners as subs. Any additional costs to a P3 increases the amount of risk associated with the investment needed to fund the entire program. Parsons literally works on a daily basis with Billions of dollars in P3 funding models around the world. I can guarantee you that Rivada, Motorola, Nokia, Fujitsu, Ericsson or any other OEM provider has never even come close to working with the P3 model, especially in North America where the P3 model has never been used in the telecom or broadband space before.
An OEM creates and sells equipment that will be used on the network to power technology. With that product comes the need to develop new products, enhance existing products and manufacturer the tools to run those products. The life-cycle of an OEM is never-ending and cyclical in nature, something that Rivada, Ericsson, Nokia and others are akin to – why? Because they are in the business of selling products, not construction services. Nothing wrong with that, but for an Opt-Out State it could mean, and historically has meant, disaster for building out broadband. So, if the development and construction of a broadband solution, for an Opt-Out State, is relevant to >80% in civil and construction related services, why would you choose a vendor to build your solution who is responsible for <3%?
As with any EPC they focus on what’s known as multipliers. Multipliers are a number that divides the overhead and profit against the direct labor of a project. For the Parsons market that falls between a 2.5 to 3.5 region for any given project – really depends on the client, the location and the economy. For an OEM that same multiplier approach is in the ballpark of 5-7..why? Because you have to include all the product development, product management, warehousing, manufacturing process and the sales approach as part of the overheads – this is why OEMs don’t compete in the services market. Nothing wrong with that, it’s just a different market and a different business approach. One thing is for sure…you don’t want to be applying 5-7 multipliers to a project where you can get 2.5.-3.5 multipliers. Another fact is that an OEM who takes on the expertise to build and fund your network, will still need a Parsons anyway, because that’s what Parsons does for a living — construction. What the OEM does is position itself to be the decision maker, takes on the primary risk (80% of the scope of the program thus the majority of the profit anyway, but without the risk. But who really takes on the risk of a fledgling telecom model that has failed in the past and will fail in the future? The State!
So let’s say you are New Hampshire and you choose to go with an OEM solution, the Rivada solution, what does that mean to the State?  First off the State may be blinded by the idea that the Rivada solution will pay for everything, which may be the case, but that means somebody will have to pay for it. There are two possibilities the taxpayers, or the private investors. What’s wrong with that? The fact remains that you are still paying for a much costlier build due to the layered parties all adding their overheads and costs to the sum solution. With higher costs means you have to sell those higher costs to either the taxpayers or the private investors. But, let’s go with the investor path.
In comparison to the state taxpayers, the investors are definitely no slackers when it comes to investing their own money – or their shareholder’s money. The investor will not invest in an opportunity that costs too much, detracts from their long-term gain, and carries too much risk. For a Parsons solution the risk is much lower in that you have the party that is responsible for more than 80% of the overall projects profit running your program; which equates to lower cost due to the fact that you are not layering other partner’s costs on top; and ultimately can contribute a much cheaper multiplier rate to the entire program. This is the case in point for why Parsons beats Motorola in these bids – Parsons simply comes in costing less while better positioned to take on the control and the risk of the entire solution.
Why didn’t Parsons beat Rivada though? The solution submitted to New Hampshire was put together in 4 short weeks – that includes model conception, content creation, printing, corrections, edits, approvals, then shipment. The overall proposal (the meat of the proposal) was rushed and put together within a week. The fact remains that had Parsons had more time to go over the proposal, and really look at the solution presented, they would have beaten Rivada as well.  By perfecting the approach, Parsons will insure an unbeatable approach on the next one.  
In the end, why would you want an overpriced OEM leading your program to install statewide broadband network who will only turn around and hire the same EPC firms to do the majority of the work; an OEM with no P3 experience at all; an OEM whose prime directive is to sell their proprietary equipment over anything else; an OEM whose business model does not align with the Public Safety Broadband Network’s future; an OEM who only increases the risk, cost and complexity to the entire solution? Why would you risk an entire statewide buildout of a Public Safety critical infrastructure, whose sole purpose is to insure the safety and wellbeing of First Responders and the public, to a product driven company who has no experience in designing, building, operating and maintaining a broadband network let alone no experience in Public Private Partnerships?
But what do I know I’m ……
Just some guy and a blog…….

FirstNet — Your missing the big picture here!

/ drmikemyers / Leave a comment
I read a lot of material on a daily basis. Much of that material pertains to FirstNet. I have noticed something about all the hoopla in respect to Opt-In versus Opt-Out and I think most people don’t understand one crucial piece of the entire argument. Let me indulge myself a little bit.
FirstNet is crying out that any and all,States must comply with their interoperability characteristics when it comes to deployment and long-term operations. This is understandable given the nature of the law to create “one network” for Public Safety. The physical build-out of the network, the chosen vendor solutions, and the ability to adopt technical standards is not the issue here – I’m afraid this is where both FirstNet and the Opt-Out players have a failure to communicate. The fact is that the real argument is about each party using the network for their own advantage.
If a State decides to Opt-Out, and FirstNet wants to insure it gets the network that meets its needs as well, then as a designer of the network all I would do is isolate the FirstNet network from the rest of my network using the same footprint. In short, I would isolate the fiber, isolate backhaul and protect edge access for prioritized Public Safety solutions as Priority 1. You can build a lot of fiber into your network; you can also have duplicate backhaul solutions; you can even isolate and encrypt traffic demands right on the handset or radio interface. All other data traffic whether it be Utilities, Transportation, Agriculture or even commercial usage, would be Priority 2 or 3 depending on the States business model. The fact I’m trying to make is that what’s important is the accommodation for both networks within the same infrastructure – this is where everyone is missing the point.
The beauty of Band-14 being owned by Public Safety is not because they get their own isolated network, it’s because they get to be priority on the network they own. Without secondary or tertiary use of the network the Public Safety Broadband Network won’t work — they need the revenue to get the “fully-funded” and “self-sustainment” mandate in the law. The physical demands of hardening and coverage only complement each parties network desires – all boats rise with the tide. The technology is perfectly designed, in fact was designed, for the prioritization, classification, protection and isolation of data traffic patterns. There will be only one physical network, as described in the law, it’s just FirstNet will have its own fiber, its own backhaul, and it’s own encrypted access for the Public Safety Broadband Network – which was the plan all along. FirstNet will even have its own awarded contractor to build their solution as well, but so will the State. The State will use the excess capacity, or “other” assets for their own good, which includes the spectrum. What we are trying to do here is capitalize on the use of the spectrum for what it is intended to be used for – provide more bandwidth than any one stakeholder can use and to generate enough revenue that makes everyone happy.
So everyone stop getting all up in arms about the FirstNet versus the Opt-Out States, the fact remains that it’s really only one infrastructure. If FirstNet wants its own building to support the State’s Public Safety entities, its own fiber, its own access, then so be it have your new contractor deploy it for you. Meanwhile, the State can capitalize on the use of the infrastructure to consolidate its own Public Safety needs, in an adjacent building to FirstNet’s, for the purpose of the State to take advantage of benefits – through a Public Private Partnership – in consolidating State First/Secondary Responders and commercial broadband services throughout its coverage areas. Seems to me to kill two birds with one stone. FirstNet gets its backup solution for communications nationwide and the State gets to use the assets to create jobs, bring in investment and generate revenue for other needed services. Who would complain about that? I would recommend that FirstNet allow the State to build its own network first though, else FirstNet will run out of money fast and with no means to bring in more.
Just some guy and a blog….

FirstNet – How did Kentucky Wired go from the most “coveted” P3 program to almost dead?

/ drmikemyers / Leave a comment
We have seen this before with such ventures as Utopia in Utah and Nevada, the SF-RICS, LA-RICS and now the Kentucky Wired Program. They never came close to achieving what they set out to do and some have bitten the dust. It’s all about the business model and how you construct your Public Private Partnership (P3).
Governor Beshear took a lot of credit for the P3 in Kentucky and the State won numerous awards during 2015, such as the “coveted 2015 Deal of the Year award from The Bond Buyer”. By 2016 Governor Bevin downgraded it to just a few counties, then most recently it was put on holdindefinitely due to lack of funding.  The problem isn’t that the P3 format is flawed, the problem is in the balance of power, financial arrangement and some shady deals.  
I was part of a team that provided the competitive bid to the Macquarie and Kentucky Wired Program; but we proposed a fully funded network and a self-sustaining long term contract to the State without any need for taxpayer funding — The Myers Model. Our solution even consolidated all the States fiber resources and would have established the base transport network for the State’s Public Safety Broadband effort. But, the State went with a bonded taxpayer deal, whereas Macquarie was the sole financier on the private side.  The Macquarie deal called for $23 Million from the State taxpayers, another $25 Million from Federal taxpayers, and Macquarie would finance the rest of the $150 Million with the State paying a $25 Million fee every year for 25 years. Good for Macquarie, bad for the taxpayers. Then came the change in administration and a new Governor.
Enough was enough for programs funneling enormous amounts of taxpayer funds to questionable deals was not going to fly anymore. The fact is that the Macquarie deal may have started as a typical bonded program with honorable intentions to deliver broadband, but it was managed by a government entity influenced by one private investor. Had Kentucky Wired been setup as a true privately owned commercial broadband company, then the framework of the P3 model would have changed. In essence, Macquarie would have never taken on the entire risk of the deal without bringing in partners. Those partners would have scrutinized the revenue projections and the market economics to a point of not bidding. Why? Well because the only thing different from the model proposed, to what the market has been doing for more than 30 years, is the bonded program. What Macquarie was trying to do was position the State to inforce payment for services on its constituents through their Utility Bills  – the same solution they tried to sell to the State of Utah called Utopia. That was political suicide.
The deal Macquarie was proposing tilted the balance between the parties in the P3. Macquarie was doing whats best for Macquarie, while staying mute on acknowledging the faults in the model. In short, Macquarie did what Macquarie needed to do for its own best interest – the State was naive to what was going on. It wasn’t like the State wasn’t warned, they just decided to ignore it, then got greedy with the private entity that was created (reference “Something’s Rotten In The State Of Kentucky”). 

The format that Macquarie was peddling was never going to work, because this was the same model that commercial fiber providers have been struggling with for years, the only difference was that Macquarie was getting the State to put the taxpayers at risk by mandating an added cost to their utility bill, while at the same time getting them to pay for some of the build, then on top of that they positioned the State to use taxpayer money in its self-sustainment for the next 25 years.
The competing bid by Sterne Agee is still the way all the States should follow when trying to deliver their broadband needs. There needs to be a cooperative strategy that includes the wireless Public Safety Broadband Network with the fiber broadband aspect of the deal, doing so increases the amount of services and customers the network can use. It will provide the State with a hardened infrastructure so that its economic engine can thrive while at the same time generating enough revenue to attract private investment. But, there were other issues like the structure of ownership as well.
The ownership of the Macquarie deal had only one private investor – Macquarie. There was also no shareholder agreement between the investor(s) and the State. The framing of this deal had all the revenue hidden from State coffers, while the private entity reaped the benefits of the profit, at the same limiting their exposure to the capital cost structure of the buildout. Had this been a balanced approach with multiple investment parties coordinated under an ownership board, then all the eggs would not have been in one investors hands while the State held all the risk – thus the taxpayers. Then again it looks a lot like a bait and switch, which would have meant that Macquarie had positioned itself for an early exit once the network got to a certain point in development, allowing itself to capitalizing on its investment by selling its stake at a higher price to another party.  
The only way to get a solid P3 to work for any State, is the need to create an entity that is not reliant upon just one or two entities. We saw similar problems with the BT project in the UK called AirWave, whereas BT was the sole provider of investment for the takeover of the Nation’s Tetra network. The entity itself needs to be able to drive itself and not reminiscent of a game of Jenga. If Governor Bevin wants to get broadband to their rural areas, then they should study the competitive bid from Sterne Agee  – available through FOIA.
 Just some guy and a blog….

FirstNet – NPTSC complains about fresh eyes and fails to see the bigger picture?

/ drmikemyers / Leave a comment
Well, well…it seems Mr Steven Brill hit a nerve. I have toiled with the rebuttals from Public Safety (NPSTC), but I’m afraid they are missing the point. It has been more than 4 years since “FirstNet” started – a fact nobody can deny. What NPSTC needs to understand is that it’s not about Public Safety at all. What Mr Brill is trying to convey is that a federal program to deliver such a complex broadband solution nationwide is in disarray. I did not interpret Mr Brill’s comments as an attack on Public Safety, but rather on the lack of real insight into creating the network.
I’ve been in the industry for 30 years and have never seen a network constructed from such a lofty position with such ambitious goals without first coming up with a business plan. I would never tell a Fire or Police Chief how to construct a police force and how to manage them, and you can take my advice or not, the fact remains we can’t construct a broadband network from the top-down by a bunch of lawyers. FirstNet was given the task to build the network FOR Public Safety, but if FirstNet hasn’t even constructed a single State by now, how do we expect they will get all 50 plus 6 territories? FirstNet should have built consensus on a business plan that everyone would have accepted before it started vying the carriers for information. It’s not FirstNet’s fault, it’s the lawmakers who think that they can write a law, have the President sign it, and then everything will just magically happen. As I stated from the very beginning, we need a business plan. Coming up with an “objectives based RFP” is not a business plan, it’s an invitation for the carriers to come in and takeover. So if there is anybody to blame for the past 4 years, and nothing to show for it, it lays directly at the feet of FirstNet…not Public Safety.
Any network veteran will tell you that this whole solution should have started small and based on an entrepreneurial spirit of creativity scripted within a business plan that builds efficiencies into product introductions to meet the demands of its users. As I hinted to from the very start, FirstNet was never going to succeed taking this route and I’m afraid it is only going to get worse from here.
FirstNet will award their RFP to a carrier consortium and program manager – someone like AT&T partnered with General Dynamics purely because of its size and scope. This will only create more confusion, animosity and resentment throughout the market to which Public Safety will be on the receiving end, especially if “Public Safety” thinks that 4 years is not long enough to build even one State solution. Such blindness only makes Public Safety look like they don’t know what they are doing – which is exactly the case – they don’t. After all, I wouldn’t try to design, build, operate and maintain a Police force, thus I don’t expect Public Safety to know how to build a broadband network, especially one so complex. But it was Public Safety that put their trust in FirstNet — it is FirstNet that is not delivering here.
FirstNet failed to realize that you can’t build this network from the top down and it definitely can’t be built without even analyzing your market of users and the product offerings you need to sell. You can spend all the money you want on putting together a federal level organization to design, build, operate and maintain the entire nationwide solution, that doesn’t mean anyone at the State level will trust that you have what’s best for their local presence. You can’t just come in and expect Public Safety is going to buy an add on service to which they are already getting for cheaper. It doesn’t matter what the Public Safety guys say they need. Such interaction between the Federal and State governments will never fall under the decision matrix of Public Safety – it will always fall upon the Governor level (another layer that isn’t in the business of building broadband networks). The Governor will always do what’s best for the entire State and its fiscal standing. The fact remains that the State will be responsible for its portion of building its own network…it’s written in the law…they just don’t know how much yet.
If NPSTC has anyone to complain about, it should be the stewards of their solution – Mr. Brill is just stating the obvious from an outsider’s point of view. Anyone who has been closely tied to everything going on with FirstNet are positioned well within the frying pan and thus have a hard time trying to get back out. Essentially, Public Safety is so informed that they have lost focus on the bigger picture and what the perception is from the outside. For example: large government program worth Billions, not being advertised to well to the general public, and being pushed forward during an election cycle. It’s easy to see how someone can state how bloviated this has become.
In the end, there is one thing for sure…. FirstNet needs to change….and they need to do it now if they want to survive through this election cycle. Did you ever ask yourself why it is written in the law that FirstNet would be an “Independent Agency” within the Federal Government? I can tell you it wasn’t because they had confidence in the federal way of doing business, else they wouldn’t have wanted it “Independent”. At this point though, FirstNet, needs to scrap its notion of building a large carrier type of solution and focus on the States (a State) to design, build, operate and maintain a true infrastructure solution from the ground up that supports broadband. FirstNet also needs to sever its ties to the carriers and come clean. The carrier business model will not work in this instance – apples and oranges. If you want the carriers to improve, just introduce competition and I can guarantee you they will move on.
But what the hell do I know I’m….
Just some guy and a blog….

FirstNet has really bitten the big one? Who would have thought?

/ drmikemyers / Leave a comment
Just got finished reading Steven Brill’s article entitled “The $47 Billion Network That’s Already Obsolete” (Sep 2016) Mr. Brill makes some obvious claims of federal government waste and unraveled requirements that have become the hallmark of a federally driven program. I don’t know about you, but have you notice that when anyone suggest the government has a solution for a problem, everyone rolls their eyes to the back of their heads?
The very same topic has been covered throughout my blog since the beginning – only now people are starting to notice. Maybe it’s the upcoming elections; maybe the fallibility of federal programs; or maybe it’s just plain old greed. The fact is what it is – we’re 15 years after 9-11; we’re 4.5 years since the law was passed; we’re 4 years since FirstNet was created and we still have nothing to show for it.
Had this one little man’s idea of pushing the Opt-Out, using the Public Private Partnership, been listened to in the first place, we wouldn’t be here. At the minimum we would have seen one, if not two, of our first State’s coming online already. I had envisioned as much as ten States having at least 75% of their networks completed….but noooo…..what an asinine idea for anyone to believe that such a grand solution, for such a complex requirement, could possibly come from a lonely little blogger, especially one that the Federal Government couldn’t come up with on their own? Well, I told you so. The fact is, and Mr. Brill points this out, the network that FirstNet is touting is in fact “obsolete” already. Welcome to 5G! And by the way, its gonna cost you more!
The fact remains the same, the only way this is going to get built is from the ground-up through a State initiative. With the kind of cuts that will be forthcoming, with a new administration, I can almost guarantee you that FirstNet’s budget will be cut and the States will be given the go-ahead to construct their own Public Safety Networks on the D-Block spectrum on their own dime. If that doesn’t happen, then the carriers will improve their own bottom-line ten-fold – and Public Safety will get nothing that they don’t already have. There is a solution though.
FirstNet needs to get ahead of the game and create templates for design, project schedules and frameworks for State driven RFPs, then help organize the State’s to start construction of their own Opt-Out solution. If FirstNet doesn’t take these steps, then their very existence will be scant for future dealings – in short, you don’t take these steps you will be disbanded. What do you honestly believe the outcome is going to be when FirstNet announces a carrier relationship solution for Public Safety Broadband? Do you think it’s all going to be hunky-dory and everyone is just going to go along with the plan? Do you think it won’t become a contention of legal debate for years to come? Do you really think it won’t be impacted with a change of administration? The only thing FirstNet has created so far, is a centralized socialistic voice of one-size-fits-all. If FirstNet wants to show any hint of success, it needs to start engaging the States to build their own solution and stop screwing around. Just because the carriers believe that if they delay, and demonstrate contention in the ranks, that they will get the spectrum through an “I told you so” event, they will be sorely mistaken.
FirstNet is the end-game for any national carrier that tries to take its reigns away from Public Safety. The political quagmire associated with trying to build such a network solution will be catastrophic for even the largest of carriers. Can you imagine all the lawsuits if States are pushed towards such a solution? FirstNet has the makings for the worst financial boondoggle in the history of the United States – if not the world.
What about the States though?
Well, each State has the ability to use its own resources to advertise a Public Private Partnership(P3) RFP to construct their statewide solutions. Through the P3 the State will get its funding, its self-sustainment, its ownership control, revenue, and a solid Public Safety infrastructure for the foreseeable future. As I have stated in past articles, a State doesn’t need FirstNet – FirstNet needs the State.
If FirstNet continues down this path who loses? Public Safety loses. Who wins? The carriers do. The carriers will eventually get all the spectrum because “they are the only ones that know how to build a broadband network” – right? I’ve been in the telecom industry for 30 years, the carriers don’t even build their own networks. What makes you think they can do any better than just an entrepreneurial blogger? After all, it was a lonely little railroad worker, turned scientist, that created the first telegraph networks that became the catalyst to all the world’s telecommunication infrastructures. It wasn’t the government that decided it needed to talk to other stations along the railroads. The government didn’t just put out an RFP expecting everything would be great. It was a lonely little citizen who felt he needed to create a solution for a problem he faced daily. You can’t get more “ground-up” than that. Today’s FirstNet solution is no different. Stop thinking about the end-game, the entire solution, and the limelight of control — start focusing on the seed and where you need to plant it.
I continue to push the idea that the State needs to take hold of its own destiny and move on. Stop waiting for something from the federal government that will never come. The FirstNet solution is so misconstrued, that its downfall will be a long slow collapse of bureau-crap-tic solutions festering away with the stench of wasted money, time, and resources only to be savored by long-term overly paid government workers that will have nothing to show for it but a pension of poor healthcare benefits.
Just some guy and a blog…..

FirstNet — NTIA starts to have a combined approach to Opt-Out and Opt-in? First stop revenue!

/ drmikemyers / Leave a comment
If you can’t beat them join them.
Maybe, just maybe, I’m starting to see tones of a combined Opt-Out and Opt-In solution being considered by the NTIA. This is excellent news! By incorporating the Opt-Out and Opt-In solution into a combined approach is a very smart thing to do. Now States that decide to build out their own radio access network can obtain a template of a design consideration when implementing minimum standards for hardened sites, transport IP solutions, virtual network connections and cyber security related solutions. Most importantly, the State gets the opportunity to create its own solution of interoperability between adjoining States.
One important topic that needs to be considered – one that few people seem to understand – is the use of the revenue. If you read the NTIA, or FirstNet’s, interpretation of the law you will notice that they don’t go very deep into the topic of the revenue, other than “a State can’t use the revenue” and “all revenue the State makes has to be reinvested back into the network”.
First off, this would be an asinine effort to block the State from using the revenue; after all the network and the spectrum belongs to Public Safety, so why can’t they use their own revenue? Why can’t they capitalize on the use of the spectrum to improve things throughout the State and the Nation? Why must the revenue be restricted to just reinvesting into FirstNet and private investors? That makes no sense. That’s like opening up your own super market, but not letting anyone to collect revenue from sales.
Second, if you read the law it specifically states:
(g) PROHIBITION.—
(1) IN GENERAL.—A State that chooses to build its own radio access network shall not provide commercial service to consumers or offer wholesale leasing capacity of the network within the State exceptdirectly through public-private partnershipsfor construction, maintenance, operation, and improvement of the network within the State.
(2) RULE OF CONSTRUCTION.—Nothing in this subsection shall be construed to prohibit the State and a secondary user from entering into a covered leasing agreement. Any revenue gained by the State from such a leasing agreement shall be used only for constructing, maintaining, operating, or improving the radio access network of the State.
In short, when FirstNet says that a “State can’t use the revenue” this is in fact a lie, or at least misinterpretation of the law. Through a Public Private Partnership, and/or a lease agreement, the State can use the revenue generated off the use of the network.  I will give them the benefit of the doubt and say that what FirstNet is trying to convey is that the States that Opt-out, should not think if the network as an open spicket of revenue for the State. Now this seems to be the gallant thing to do, if you know there will be nefarious activities that will follow. But, how will FirstNet ever try to enforce such a rule? I can just see it now; FirstNet tells Texas they can’t use the D-Block spectrum anymore because funds are being used for building roads, thus Public Safety is hit with statewide outages causing chaos.

That’s looking at the glass half-empty. If you look at the glass half-full we should encourage the generation of revenue for the State, because the increase in revenue means more support for Public Safety, the economy and the market place. In fact, any share of revenue that the State acquires, through the use of its Public Private Partnership, should be prioritized and re-invested into Public Safety, but also be allowed to flow into other needy programs within the State, such as Healthcare, Schools, Transportation, the Elderly, etc.. Anybody that would deny such use of the revenue, isn’t understanding the complete outcome of what the network can produce.

You will also note that within the law it really doesn’t address the private side of the Public Private Partnership — it only addresses the State and FirstNet. The fact is that any primary investor that funds the Public Private Partnership will, in fact, obtain its own rights to equitable shares within the invested entity, thus equivalent in revenue distribution. In short, if anyone wants to invest their own money into a State Public Private Partnership to design, build, operate and maintain the State’s Public Safety Broadband Network, then they will be able to generate revenue off their equitable share of ownership. So I ask once again, why constrict the States revenue portions to just Public Safety and FirstNet? All you are doing is limiting your own self for no real reason at all.
You should note; anyone can invest into the State’s DBOM Public Private Partnership, and should be encouraged. Why? Because a statewide hardened infrastructure that supports all forms of connectivity should be open to all market participants, i.e. local, regional, national carriers, local utilities in the likes. Plus, it allows those same participants to save on owning the assets, increases their coverage, and thus revenue which can only improve the local economy with more investment and job creation statewide.
But whom am I other than….

Just some guy and a blog….

FirstNet to award RFP to the carriers! The State gets nothing the carriers get it all?

/ drmikemyers / Leave a comment
So let me get this straight – FirstNet is considering to do what it said it was going to do from the start? Give all the spectrum to AT&T or Verizon anyway? I mean, if I were Verizon, or AT&T, I would submit a bid for the FirstNet spectrum too. After all, where else can you avoid your spectrum caps and get some of the most valuable spectrum on the planet — for free — than from the Federal Government on the back of Public Safety and the taxpayers. Has anyone seen the revenue made from these carriers in the last year? AT&T alone has a market cap of $261 Billion with $162 Billion in revenue last year alone, so adding some more revenue to boot, without paying for the spectrum, or for a measly $6 Billion a year, is nothing, especially when they get to expand their capacity more than a hundred fold. Business wise, yah, if I were AT&T I would submit a bid as well. But, ethically is getting the spectrum for pennies on the dollar, on the backs of Public Safety and the taxpayers, the right thing to do? How would someone sleep at night knowing that they took advantage of, and conned, Public Safety and the taxpayers in the largest theft of spectrum on the planet?  
I guess “doing what’s right and not take advantage of others who know no better” is questionable and doesn’t hold any value today? We have politicians getting away with much worse. What would it matter for those same politicians to get their hands on some of the cash from FirstNet that will be coveted by the commercial carriers? Or is this just a bad deal for the States? Imagine if a State were to build its own Public Private entity to capitalize on the use of its own spectrum, with a relationship with those same carriers, but on their own terms? If FirstNet moves forward with a carrier based solution, all they are doing is screwing the States. It’s like a bad contractor taking advantage of an old Lady who can’t defend herself with a half exposed roof. The carriers will be glad to take your spectrum, for their own use, leaving you with a network only half built (or less) – unless you pay them some more money to complete it. Who in the end will have to pay for these bad decisions? Public Safety and the taxpayers, most importantly, the State taxpayers. Mark my words.
Through a State driven Public Private Partnership, a State can capitalize on the broadband services and revenue provided by Private Investment. Some of those investors could be the carriers themselves. Essentially, the State would incentivize the use of the spectrum to capitalize on a private entity to commission its much needed hardened infrastructure to support both wireline (fiber networks) and wireless broadband solutions (5G, etc.). This solution would enable the prioritization of First Responders, State agencies and entities over any commercial use of the network; while at the same time reaping the benefits of much needed revenue to help support Public Safety needs for the foreseeable future. This private entity within the State would hire locally, maintain locally, and increase incentives for private investment to come into the State’s economy – the FirstNet carrier solution will not do that. The FirstNet carrier solution will not even try to tackle building out to the rural areas of the State — which makes up more than 62% of the geographic landmass of the United States.
If FirstNet awards a carrier based solution, then FirstNet will have come full circle since its first days of pushing a carrier solution onto Public Safety. The carrier FirstNet solution only allows the carrier to increase its capacity 100 fold, across the entire United States, for their own benefit of increased profits all while paying a measly fee to FirstNet. What a waste of time, money, and resources. This is what could happen if we have the government trying to run a broadband solution.
But who am I other than…
Just some guy and a blog….

FirstNet — Every naysayer has a problem for every solution. 5G at 340X the capacity of existing 4G for PSBN.

/ drmikemyers / Leave a comment
Just recently Hans Vestberg, CEO for Ericsson, stated:
“Ericsson is seeing 340x higher speeds from the technology, up to 25 Gbps, and 20-30x improvements in battery capability. “It’s extremely powerful technology,” he said. “That’s why we see the high interest.””
By the time a State starts building its portion of FirstNet, we will be delivering 5G capacity to all the rural and metro areas. Rural areas make up 66% of all the landmass in the United States; 16% to wilderness; and 18% to metropolitan areas. Tests performed today demonstrate that during an emergency Public Safety utilizes less than 3% of a given geographic areas capacity. During normal operations Public Safety utilizes less than 1%. At 340X more capacity on 5G Public Safety won’t even be a blip on its own network – even during a disaster. That means a whole lot of available capacity to help fund Public Safety in a very big way. In fact, such capacity will become the cornerstone to building a solid infrastructure that can support entire economic engines.
Imagine having a network with a hardened fiber transport expanding throughout all territories; 5G wireless (Micro, Macro, Small Cell) with inclusive DAS; and solid backhaul of fiber and microwave that is inclusive of FTTx solutions; and all of this infrastructure that can support a States entire economy; diverse and protected; and expandable for future technologies. A network that will cover all the geography of a given State. A network that the carriers would love to lease space on to increase their own profits while at the same time expanding their coverage. A network where wireline and wireless options to the home are as common as delivering power or water – but only better. Imagine a network that can isolate traffic between a large private fiber network down to the single packet of an email message, all protected, impenetrable, and based on an infinite amount of transport capacity. This is entirely doable. All you need is the right balance within the business model to accommodate the solution.
I’ve said for a long time that you should avoid nay-sayers because they always have a problem for every solution. The fact is that developing a business model to accommodate this solution is very doable – and it’s not new. In the past all of the networks developed within the United States were based on a subscriber model of users buying phones, paying monthly access, and selling services. It’s easy to assume that this model has worked in the past, thus should be used when moving forward. But, that is not true. Those models of supporting large carrier solutions are not the model FirstNet needs in moving forward with. FirstNet has to rely upon a much wider base of users; all having disparate needs of what how they use broadband access; all having the fundamental need for broadband to power their operations and ideals. The only way you can reasonably assemble such a balance is through a partnership between governmental needs fostering commercial incentives to attract private investment – in short you need a Public Private Partnership. But…. there is something else you need to develop for such a solution – control.
By focusing on a Top-Down, nationalistic, or government administered approach you will lose control of all the variables associated with your deployment – and quickly. Each and every State is different in how they do things and what their needs are. It sounds really good to build the Corporate Headquarters first, then administer each geographical unit underneath – sounds very sensible. The problem is that even the national carriers did not start this way. They started from a small Mom and Pop solution that expanded as the demand increased. By constructing a solution from the top-down we are saying that we know what the future holds, so why mess around with building it based on demand and just go to the end and bypass all the pain and sweat. That solution will not work. You have to build it based on demand and you have to start small – thus the bottom-up approach encased in a State solution. In short, we build all the pieces and then put together the national puzzle. We can’t just say we a have a puzzle and then expect that all the pieces will just fit together on their own.
By focusing on the bottom-up solution both of the solutions for Opt-In, or Opt-Out, will work. The real difference will be that with the Opt-in you give all the control to FirstNet to try and run the solution for your State – and you will have to help pay for that effort. The Opt-Out solution enables the State to maintain its own control and relies on private investment to come in a pay for it – not the taxpayers. The physical build is the same for both solutions, but the modeling and the rollout based on demand will be drastically different.
The Opt-in solution will rely upon a partnership between a national carrier and a program team. The complexity of the team, and its balance between investment needs, will force a metro first expansion first, then opportunistically focusing on rural expansions. Why? Because the partners in the Opt-In solution are focused on their existing carrier model and the need to generate revenue based on that pre-existing model – especially if they have to make a $5 Billion payment to FirstNet every year for 25 years. Sounds like a lot right? What the carrier doesn’t tell you is that they will make 5 times that figure monthly. The only difference now, is that instead of them having to pay for the spectrum, then setup operations to sell service, FirstNet is offering the spectrum for pennies on the dollar and the use of their already existing infrastructure, thus increasing the margins substantially… and yes they will allow Public Safety priority, especially when they know that Public Safety uses less than 1% of the network capacity anyway. I can guarantee you that the Opt-in solution will still face the same issue that the carriers face today — expanding to the rural areas – if the demand is not there (and they will insure that the need is not there) – they will not build to those areas. Remember, they are beholden to the shareholder, not the taxpayer like FirstNet thinks.
The Opt-Out solution is focusing on the State’s ability to control its own destiny in a more controlled state. For the Opt-Out Public Private Partnership solution the State is one of those investors that the company is beholden too, thus the taxpayers. The newly created privatized broadband company can focus on selling all that capacity, at all layers of its network, while at the same time expanding its hardened infrastructure to insure the rural areas are the priority. Where a carrier is driven by the ARPU model (average rate per user) this new broadband entity will focus on a holistic approach to layering its customer base through fixed, monthly, and on demand service solutions to an expanded, and fixed, base of users covering all State and Federal agencies, private commercial entities, and the commercial taxpayer base. In this case, the network will allow those same carriers focusing on the Opt-In solution to expand its coverage area without spending any money on capex to build, while at the same time not being responsible for the spectrum allocated to Public Safety.
In the end, the Opt-Out is more manageable; more focused on local needs; yet still delivers what the national solution wants.
But what do I know I’m…

Just some guy and a blog….

Response to Federal Register Document “State Alternative Plan Program (SAPP) and the First Responder Network Authority Nationwide Public Safety Broadband Network”

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Document Citation:

81 FR 46907
Page:
46907 -46913 (7 pages)
Agency/Docket Number:
Docket Number: 160706588-6588-01
RIN:
0660-XC02
Document Number:
2016-17034
Respondent:
Dr. Michael Myers
Dr.Myers@me.com

Abstract

The following document outlines response questions pertaining to the SAPP; how it pertains to HR3630 “The Middle Class Tax Relief and Jobs Creation Act of 2012”; and the deployment of the Nation’s Public Safety Broadband Network.

 

Summary

In summation, this document outlines the interaction needed for States that elect to “Opt-Out” from the “FirstNet” plan. This document provides a context and alignment between necessary next steps and actions that will be required by the State in providing its alternative solution for a statewide Public Safety Broadband Network (SPSBN). Overall the document is relevant with some baseline observations and recommendations.
The context of this response is to help and improve on the FCC (Federal Communications Commission), the NTIA (National Telecommunications and Information Administration), the “FirstNet” organizational development, and a State’s ability to execute a cooperative arrangement for deploying the Nationwide Public Safety Broadband Network (NPSBN).

 

Responses

Response 1 – Overall the context and the ambience of the message being delivered seems to be that of a “this party will do what it will do and that party will do what it wants to do”. I believe the underlying message should be one of a cooperative framework. This document reflects more of a “requirement” rather than a “entreaty”. In the end all parties, e.g. FirstNet, Opt-Out State, Opt-In State and Public Safety, are driven for the same cause of constructing the NPSBN. The only contextual difference in who builds the solution is almost moot. With that said, it is recommended that the NTIA and DOC establish FirstNet as a unifier in developing the technical solution that can accommodate both the Opt-In and the Opt-Out solution, not an Opt-In only scenario.

Response 2

·      Section 1, Paragraph 4 — “This Notice provides initial guidance on NTIA’s process to review a state’s application for authority to enter into a spectrum capacity lease with FirstNet and for optional grant funds to assist in the construction of its RAN.”
·      Section II, Sub C, Paragraph 1 – “Required authorization to enter into a spectrum capacity lease from FirstNet to operate its state RAN”
There is confusion as to whether or not the term “FirstNet” applies to the original appointed 15-Member Board.
HR3630 SEC. 6202. PUBLIC SAFETY BROADBAND NETWORK. (a) ESTABLISHMENT.—The First Responder Network Authority shall ensure the establishment of a nationwide, interoperable public safety broadband network.
HR 3630 SEC. 6203. PUBLIC SAFETY INTEROPERABILITY BOARD. (a) ESTABLISHMENT.— There is established within the Commission (FCC) an advisory board to be known as the ‘‘Technical Advisory Board for First Responder Interoperability’’.
HR 3630 SEC. 6204. ESTABLISHMENT OF THE FIRST RESPONDER NETWORK AUTHORITY. (a) ESTABLISHMENT.—There is established as an independent authority within the NTIA the ‘‘First Responder Network Authority’’ or ‘‘FirstNet’’. (b) BOARD.—(1) IN GENERAL.—The First Responder Network Authority shall be headed by a Board, which shall consist of—(A) the Secretary of Homeland Security;(B) the Attorney General of the United States;(C) the Director of the Office of Management and Budget; and (D) 12 individuals appointed by the Secretary of Commerce in accordance with paragraph (2).
As you can tell no place in the law does it clearly state who the actionable licensee is. In one context it could be “The First Responder Network Authority”; the “Technical Advisory Board for First Responder Interoperability”; or the FCC. The actual “FirstNet” organization, made up of its CEO, President, etc., was never allocated the spectrum lease from the FCC, only the 15-Member Board, therefore any lease arrangements — if sub-lease arrangements are allowed by the law (Telecom Act 1936). I think a little bit of clarification from the FCC should reexamine the law and apply it as necessary. The difficulty will be the negotiations between “FirstNet” and State. FirstNet would formulate a biased perception towards their own solution over any State solution, thus be in the position to deny any solution other than their own. It is recommended that a third party, not part of the First Responder Network Authority or FirstNet, be commissioned to review all leases, plans and grant programs that pertain to the State’s Opt-Out solution submitted for approval. 

Response 3

·      Section II, Sub D – “FirstNet has interpreted some of the statutory provisions described above…. NTIA will utilize FirstNet’s relevant interpretations of provisions of the Act in carrying out its responsibilities on these matters.
·      Section III, Sub B – “The state must request Lease Authority from NTIA to obtain from FirstNet the right to operate its RAN on the Band 14 spectrum licensed to FirstNet.”
·      Section III, Sub C – “State has fully executed a spectrum capacity lease agreement with FirstNet.”
As was mentioned above in the previous response, such action puts any State solution for Opt-Out at a disadvantage in that the NTIA is not taking the agnostic approach for approving any designs, plans, or grant programs for the Opt-Out State, thus could be interpreted to be in conflict with the law and open to judicial arguments in the District Court.
(h) Judicial review
(1) In general – The United States District Court for the District of Columbia shall have exclusive jurisdiction to review a decision of the Commission made under subsection (e)(3)(C)(iv).
(2) Standard of review
The court shall affirm the decision of the Commission unless—
(A) the decision was procured by corruption, fraud, or undue means;
(B) there was actual partiality or corruption in the Commission; or (C) the Commission was guilty of misconduct in refusing to hear evidence pertinent and material to the decision or of any other misbehavior by which the rights of any party have been prejudiced.
For the benefit of time and cost associated with legal interpretations I would suggest a third party review process of all State Opt-Out solutions.

 

Response 4

·      Section IV, Sub A, Paragraph 2 – “Therefore, a state will need to be compliant with the RAN-specific network policies established by FirstNet as required by the Act in order to meet the demonstrations required in 47 U.S.C. 1442(e)(3)(D).”
In reviewing this statement, you will notice that there are no “RAN-specific network policies established by “FirstNet””. Therefore, this statement is moot. It is recommended that all technical “RAN-specific policies” be administered by the assigned Technical Advisory Board listed in the Act.
HR 3630 SEC. 6203. PUBLIC SAFETY INTEROPERABILITY BOARD. (a) ESTABLISHMENT.— There is established within the Commission (FCC) an advisory board to be known as the ‘‘Technical Advisory Board for First Responder Interoperability’’.

 

Conclusion

Overall the First Responder Network Authority, and its acting agent the “FirstNet” organization, must construct templates for governance, deployment, and technical adherence so that States can have requirements laid out prior to their design considerations in any State Opt-Out solution. This will help the State, and FirstNet, in forming a baseline for requirements needed when advertising their own Design, Build, Operate and Maintain (DBOM) Request for Proposals. The State gets the specs it needs to put in its RFP; FirstNet gets to have some form of standardization across all solutions with the ability to establish a framework of requirements that all States can use, or modify, to meet their own specific solutions. Most of the differences within each State Opt-Out solution will be driven by its ownership model and revenue distribution with its “partner”. It can be assumed that the State will be satisfied if the technical requirements that FirstNet would suggest to them. Doing so will enable the State to cut-n-paste them into their own individual RFPs.
It is further recommended that FirstNet come up with a template for Governance and baseline services for revenue operations, e.g. framework for the organization of a commercial entity and the preliminary service offerings. This is not a FirstNet vs. the State effort. The State wants FirstNet to setup its basic technical and interoperable requirements so that the burden does not fall upon the State. If FirstNet does not establish a framework for such actions then the risk of divergent solutions will be high, thus risking the success of the overall and holistic goal of all parties.
Being that the established law does not clearly define “FirstNet the organization”, trying to acquire any type of lease arrangement for use of the spectrum will be a tough battle to fight. To avoid such entanglements, it is recommended that FirstNet become part of the State minority ownership team. Given that all the State Opt-Out solutions will most likely fall into a State driven “Public Private Partnership” (P3), it is recommended that FirstNet outline its role in a State’s Opt-Out Public Private Partnership by taking a minority stake in each of the State’s P3 solutions, thus insuring itself revenue for the long-term support of the overall nationwide solution. As outlined in the law, any revenue that FirstNet generates from such partnerships will be fully compliant with reinvestment necessities to fulfill self-sustainment and self-funding needs. With a FirstNet ownership stake in each State P3, FirstNet will fulfill its obligations to the law, avoid legal hurdles, and foster better relationships between the States and FirstNet. The only objections to this solution would create an unnecessary losing position forced upon Public Safety, the American Economy, and its taxpayers, thus defeating the sole purpose of building the Public Safety Broadband Network.
Signed:

Dr. Michael Myers