department of commerce washington, dc 20230 national ... · 11/9/2012 · from commercial lte...

Before theDEPARTMENT OF COMMERCE

Washington, DC 20230

In the Matter of

National Telecommunications and Information Administration

Development of the Nationwide Interoperable Public Safety Broadband Network – FirstNet NOI

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Docket No. 12092850-2505-01

RIN 0660-XC002

COMMENTS OF VERIZON

The conceptual network architecture for the Nationwide Interoperable Public Safety

Broadband Network (“NPSBN”) proposed at the first meeting of the First Responder Network

Authority (“FirstNet”) Board of Directors includes several important features.1 The proposal

appropriately maintains the NPSBN’s primary public safety role, while facilitating mutually

beneficial public-private partnerships. It also has elements in common with the architecture

described in the White Paper that Verizon provided to the FirstNet Board and other

stakeholders.2 Some components of the Board’s conceptual framework, however, merit further

consideration or clarification. In particular, the framework’s recommendation to promote

increased network reliability through access to multiple commercial networks does not account

for the importance of hardening the NPSBN; nor does the recommendation appear to consider

the impact on overall equipment costs, mobile device availability, or radio frequency engineering

1 See NTIA, Development of the Nationwide Interoperable Public Safety Broadband Network, Notice of Inquiry, Docket No. 12092850-2505-01, 77 Fed. Reg. 60680 (Oct. 4, 2012) (“FirstNet NOI”); FirstNet Nationwide Network (FNN) Proposal, Presentation of F. Craig Farrill to the FirstNet Board of Directors, Sept. 25, 2012 (“Farrill Presentation”).2 See Verizon Recommendations to FirstNet (Sept. 2012) (“Verizon White Paper”). The Verizon White Paper is attached hereto as Appendix A.

Comments of VerizonDocket No. 12092850-2505-01

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issues. In addition, the framework does not clearly explain the connectivity arrangements

between the FirstNet and commercial core networks, and between the FirstNet RAN and the

FirstNet core network.

I. FIRSTNET MUST IMPLEMENT THE NPSBN EXPEDITIOUSLY IN ORDER TO MEET CONGRESS’S OBJECTIVES.

The events of September 11, 2001 focused national attention on the vital importance of

effective emergency communications and the critical need for an interoperable communications

system that enables state and local first responders to communicate during emergencies. Public

safety’s need for effective interoperable communications is well documented, and first

responders’ access to advanced broadband communications will enable them to do their jobs

more effectively and ultimately save lives. After a decade of work by policymakers, the public

safety community, private sector companies, and various other interested stakeholders, President

Obama this year signed the Middle Class Tax Relief and Job Creation Act of 2012 into law,3

through which Congress has established a three-part framework that promises to make this vision

a reality: a broad and flexible governance structure that enables FirstNet to leverage commercial

networks, as well as state and local government resources; Federal funds to initiate network

construction; and a significant allocation of spectrum (including the 700 MHz “D Block”) to

ensure that public safety’s needs are met well into the future.

FirstNet’s network plan and implementation strategy should follow several overarching

principles: focus on the primary mission of ensuring effective emergency communications;

leverage the assets and capabilities of state/local government and the private sector; establish a

business model that encourages viable public-private partnerships; facilitate local controls; and

3 Middle Class Tax Relief and Job Creation Act of 2012, P.L. No. 112-96, §§ 6101-6303, 126 Stat. 156 (2012) (the “Public Safety Spectrum Act”).


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prioritize network implementation to make the best use of available funds. Moreover, in order to

provide first responders with effective communications and satisfy Congress’s clear objective,

FirstNet should work collaboratively with state and local government representatives and the

public safety community to implement the NPSBN as quickly and effectively as possible. The

FirstNet Board has appropriately demonstrated a sense of urgency by proposing the conceptual

network architecture at its very first meeting.4 Verizon shares this sense of urgency and

encourages FirstNet to take the necessary steps to begin planning the network in consultation

with state and local government representatives, and to initiate deployment of the NPSBN as

quickly as possible. If implemented in a manner consistent with the approach outlined in

Verizon’s White Paper, meaningful deployment could commence within the next 12-24 months.

II. FIRSTNET SHOULD IMPLEMENT A “DIVERSE NATIONWIDE NETWORK” LEVERAGING EXISTING COMMERCIAL INFRASTRUCTURE.

The Farrill Presentation appropriately recognizes that effective public-private

partnerships are necessary if FirstNet is to achieve Congress’s objectives.5 Verizon has

consistently advocated public-private partnership arrangements that would enable those charged

with building the NPSBN to leverage the significant investments that Verizon has made in

constructing its own advanced broadband networks.6 Verizon wholeheartedly agrees that

building a standalone public safety network that does not leverage public-private partnerships

would not satisfy the direction of Congress, would be extremely expensive to build and operate,

4 See NOI at 60681.5 See Farrill Presentation at 7-12.6 See Comments of Verizon Wireless before the Federal Communications Commission, PS Docket No. 06-229 et al., filed June 20, 2008, at 11-21; Verizon Wireless Ex Parte Presentation in PS Docket No. 06-229, filed Aug. 13, 2009, at 4.


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and would take an extended period of time to deploy nationwide.7 It has been more than ten

years since the events of 9/11 demonstrated the critical need for effective interoperable

communications for first responders, and FirstNet’s deployment plan should ensure that it does

not incur additional extensive delays in meeting those critical needs. By partnering with

commercial wireless providers and others in the public and private sectors that have already

made significant investments in communications and related infrastructure, such as state and

local governments, FirstNet can accelerate deployment and achieve a nationwide network much

faster and at substantially lower cost.8

Verizon supports local site sharing arrangements that would allow the NPSBN to share

physical infrastructure (e.g., land, building/tower space, power and HVAC equipment, backhaul

rights-of-way) with commercial operators or other commercial entities that own such assets.9

Such arrangements can reduce the cost of deploying the NPSBN and can also help to speed its

deployment. Verizon is willing to enter into such commercial agreements with FirstNet subject

to availability and Verizon’s ongoing need to provide reliable service to its customers.

Moreover, partnering with a diverse array of private sector entities, rather than a single

nationwide operator, will enable FirstNet to leverage a broader base of infrastructure

investments. As Mr. Farrill’s presentation notes, cumulative U.S. wireless network investments

exceed $350 billion, and the aggregate number of commercial cell sites nationwide exceeds

7 See Farrill Presentation at 9.8 See Verizon White Paper at 2-5.9 See id. at 4-5, 8-9.


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285,000.10 Partnering with multiple private sector entities will enable FirstNet to leverage the

combination of assets that provides the best fit for its deployment plan.

Congress recognized that states and localities also have significant assets that FirstNet

could leverage for the benefit of the NPSBN and the first responders that use it.11 These assets

include sites, towers, and other state and local government-owned infrastructure already used to

support public safety communications systems, including infrastructure in rural areas where

commercial networks are not currently deployed, and extensive backhaul networks in which

states have made significant investments. Partnering with state and local government agencies to

use such infrastructure will both promote more timely and cost effective NPSBN deployment,

and enable those state and local government agencies to make better use of their significant

investments.

The proposed network architecture also appropriately recognizes that first responders’

ability to roam to and from commercial broadband networks will significantly improve access

for first responders and increase the overall utility of the NPSBN.12 This was an important

reason why the FCC’s Technical Advisory Board chose commercial operators’ widely-deployed

Long Term Evolution (LTE) technology as the preferred technology for the NPSBN.13 Where

FirstNet has not yet deployed its network – which will include substantial geographic areas

particularly during the NPSBN’s early stages – access to commercial LTE networks would

10 Farrill Presentation at 10.11 See Public Safety Spectrum Act § 6206(c)(3)(B); see also Farrill Presentation at 10.12 Farrill Presentation at 11-12; see also Verizon White Paper at 12-13.13 See Technical Advisory Board for First Responder Interoperability, Recommended Minimum Technical Requirements to Ensure Nationwide Interoperability for the Nationwide Public Safety Broadband Network, § 4.5.3 (May 22, 2012)(“Interoperability Board Recommendations”).


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enable first responders to utilize broadband services that are interoperable with FirstNet’s.

Moreover, even where FirstNet has deployed its network, securing agreements for access to

compatible commercial networks could provide additional capacity during those rare

emergencies in which FirstNet’s network capacity proves insufficient.

To this end, Verizon already is planning for bi-directional roaming between its

commercial LTE network and the NPSBN. Bi-directional roaming would allow authorized

public safety users that are homed on the NPSBN to roam onto Verizon’s network when out of

FirstNet’s coverage area, and it would allow authorized public safety users that are homed on the

Verizon network (e.g., where FirstNet has not yet deployed a network) to roam onto the NPSBN.

As Verizon described in its White Paper, bi-directional roaming arrangements will offer

significant benefits to FirstNet and the public safety community.14

Verizon is concerned, however, with the inference in the proposed network architecture

that access to multiple commercial networks (both terrestrial and satellite based) will, in and of

itself, provide the level of reliability that is needed to support public safety’s mission critical

communications.15 Access to multiple commercial networks could certainly increase the

availability of broadband services for first responders since FirstNet would have multiple

alternative paths on which to rely for service. The overall reliability afforded to FirstNet users

through such a multi-network approach, however, would depend on the reliability of each

commercial network and the individual components that comprise each of those networks.16

Commercial operators often share components such as towers and other infrastructure, and a

14 Verizon White Paper at 12-13.15 See Farrill Presentation at slide 11 (suggesting that 99.999% reliability can be achieved by having access to five commercial networks).16 See Verizon White Paper at 10-12 (describing Verizon’s network reliability practices).


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severe storm could knock down a tower or flood a building that is shared by multiple commercial

operators, or disrupt commercial power sources that serve multiple commercial networks.

FirstNet will need to take all of these factors into account when deciding what level of hardening

it requires for the NPSBN.

In addition, a single NPSBN device must be able to accommodate many different

spectrum bands in order to accommodate such a multiple network approach. While multi-band

devices are commonplace in today’s wireless marketplace, achieving the right mix of supported

bands in each device is a complex process that must account for the technical challenges of

accommodating an increasing number of spectrum bands and technologies, potential interference

between different bands, device size, battery life, and the economics associated with the market

demand for access to some bands versus others. Designing a handset that accommodates the

multiple commercial network approach will be especially challenging for FirstNet due to

technical challenges associated with the 700 MHz band and the cost implications of designing

public safety grade devices with special features that may not have mass market appeal.

In developing its roaming and device strategy, FirstNet should assess how it can benefit

from commercial LTE deployments in the 700 MHz band, as well as other bands, and whether to

also support interoperability with commercial 3G networks in bands that are already widely

deployed (e.g., the 850 MHz cellular and 1.9 GHz PCS bands).17 Such an approach is consistent

with the Technical Advisory Board for First Responder Interoperability recommendations18 and,

in addition to promoting wider availability of devices at lower cost, might facilitate broader

network coverage by using commercial 3G networks where LTE does not yet exist.

17 See Verizon White Paper at 8.18 See Interoperability Board Recommendations §§ 1.3.5 and 4.5.3.


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III. ANY CONNECTIVITY ARRANGEMENTS SHOULD SUPPORT A FIRSTNET CORE NETWORK DEDICATED TO EMERGENCY COMMUNICATIONS.

FirstNet’s principal mission is to ensure effective emergency communications for the

nation’s first responders and, as discussed above, the establishment of viable public-private

partnerships can help FirstNet fulfill this mission. While FirstNet may benefit from sharing

some infrastructure, it should not share core network components, i.e., the IP Multimedia

Subsystem (IMS) and Evolved Packet Core (EPC), as doing so would undermine its ability to

provide secure, high priority communications for first responders. The proposed network

architecture appears to support this approach, but FirstNet should make this requirement explicit.

The proposed architecture appears to allow sharing of the Band 14 Radio Access

Networks (RAN). Clarification is required, however, regarding how the FirstNet Distributed

Core Network, the FirstNet Band 14 RAN, and any commercial network components would be

interconnected. Verizon’s White Paper recommends a network architecture that would facilitate

Band 14 RAN sharing where FirstNet deems it appropriate.19 Where such arrangements are

established, connectivity to commercial networks should be achieved in accordance with

industry technical standards that have been designed to promote network sharing.20 These

standards would allow any emergency responder communications destined for the FirstNet core

to be separated from commercial traffic destined for the commercial carrier’s core, consistent

with Verizon’s recommendations. As a general matter, connectivity between the FirstNet core

19 See Verizon White Paper at 2-6.20 Industry standards support RAN/spectrum sharing among different network operators, and any such arrangements established by FirstNet should comply with the Multi-Operator Core Network (MOCN) configuration specified in those standards. ETSI Technical Standard 123 251 V10.1.0.


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and any commercial carrier cores should be addressed through bi-directional roaming

arrangements, as discussed in the White Paper.21

The proposed support for arrangements with multiple commercial mobile operators also

warrants clarification. The conceptual network architecture suggests that FirstNet could support

multiple partnering arrangements for deploying its Band 14 RAN in a specific geographic area.22

Verizon agrees that FirstNet’s deployment plan should facilitate partnering arrangements with

multiple entities, as FirstNet’s ideal partner(s) may differ from one area to the next. FirstNet

should clarify, however, that it does not propose multiple RAN deployments with independent

commercial entities in the same geographic area, as such arrangements would result in

unnecessarily duplicative RAN costs and significant RF interference issues.

CONCLUSION

Verizon commends FirstNet for developing an initial conceptual framework for the

NPSBN and for seeking public comment in a timely manner. For the reasons described herein,

however, FirstNet should provide clarification on how it would implement this framework and

how FirstNet should integrate the NPBSN architecture with the networks of commercial service

providers. Moreover, before finalizing a network architecture, it is important for FirstNet to

develop an appropriate business model in consultation with its state and local government

partners. Finally, since private sector deployment of LTE networks is already occurring at a

21Verizon White Paper at 12-13.22 See id. at 17-18.


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rapid pace, FirstNet should move as expeditiously as possible to complete these initiatives and to

developing a concrete plan for deploying the NPSBN and meeting its statutory mandate.

Respectfully submitted,

/s/ Robert G. Morse

Michael E. Glover Of Counsel

November 9, 2012

John T. Scott, IIIRobert G. Morse1300 I Street, N.W. Suite 400 West Washington, DC 20005 (202) 515-2400

Attorneys for Verizon

Verizon Appendix A

Verizon Recommendations to FirstNet (September 2012)

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Establishing an Effective Framework for a Nationwide Public Safety Broadband Network

Verizon Recommendations to FirstNet Overview The events of September 11, 2001 focused national attention on the critical need for an interoperable communications system that enables state and local first responders (e.g., police, fire and emergency medical), as well as federal agencies (e.g., FEMA, FBI), to communicate during emergencies. In February 2012, a new law was enacted that addresses this important national objective. The Middle Class Tax Relief and Job Creation Act of 2012 (Spectrum Act) requires the establishment of the First Responder Network Authority (FirstNet) to oversee the construction and operation of a nationwide public safety broadband network (NPSBN). FirstNet, which will be operated as an independent entity under the National Telecommunications & Information Administration (NTIA), will have access to 20 MHz of spectrum in the 700 MHz band and $7B of federal funding through grants awarded by NTIA. The Spectrum Act requires FirstNet to work with states and local municipalities in building out the network, and encourages it to partner with commercial carriers, to the extent economically desirable. Verizon has drafted this paper in an effort to assist FirstNet in its efforts to develop the most effective framework for implementing the NPSBN. It is based on Verizon’s significant experience and expertise in building and operating advanced communications networks, as well as its understanding of public safety’s communications needs. Verizon’s views regarding implementation of the NPSBN may change as FirstNet’s plans for deployment become better understood, and the views presented here should not be interpreted as a commitment to do business with FirstNet in any specific way. That determination can only be made in response to a formal request for proposal (RFP) from FirstNet. Guiding Principles for Constructing a Nationwide Public Safety Broadband Network Verizon supports the Spectrum Act and believes that the NPSBN, if implemented effectively by FirstNet, will provide first responders with not only a communications system that is fully interoperable but one with advanced broadband capabilities that will meet their needs well into the future. As FirstNet develops its network plan and implementation strategy, Verizon believes it should be guided by several overarching principles:

Focus on the primary mission of ensuring effective emergency communications. FirstNet must be careful not to let interests in commercializing the network or the spectrum undermine the goal that Congress has mandated - ensuring reliable, high priority communications for first responders.


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Leverage the assets and capabilities of state/local government and the private sector. FirstNet should work cooperatively with the states and the private sector, as doing so will enable it to speed deployment and minimize the cost of building the network.

Develop a business model that encourages viable public-private partnerships. In order to be viable, partnerships must address the needs of both public and private sector partners. FirstNet should be careful not to repeat the mistakes of the past by attempting to implement flawed models like that attempted with the D Block auction.

Facilitate local controls. Since State and Local first responders are the primary users of the NPSBN, FirstNet should work closely with these officials to ensure that the network is designed to meet their operational requirements.

Prioritize network implementation to make the best use of available funds. FirstNet should make its initial network investments in those areas where public safety’s needs are greatest. Only $2B will be available to FirstNet in the near-term, with the additional $5B not available until after the completion of incentive auctions for broadcast TV spectrum.

Network Architecture Pursuant to the Spectrum Act, the Federal Communications Commission (FCC or Commission) established a Technical Advisory Board for First Responder Interoperability (Interoperability Board) to develop the recommended minimum technical requirements to ensure a nationwide level of interoperability for the NPSBN.1 The Interoperability Board was required to base its recommendations on commercial standards for Long Term Evolution (LTE) technology, and its recommendations were approved by the Commission on June 21, 2012. The use of LTE technology by FirstNet is significant, because it is the technology that has been adopted by commercial service providers worldwide. This will allow FirstNet to leverage the ongoing developments of a multi-billion dollar technology ecosystem, which will promote lower costs, more rapid innovation, and interoperability with commercial service provider networks. LTE is a common term used to describe a family of global standards that are specified by the Third Generation Partnership Project (3GPP). LTE is an all-Internet Protocol technology platform that is composed of a set of network elements within the 3GPP network architecture. A more thorough discussion of these network elements is included in the Interoperability Board’s recommendations and in relevant 3GPP standards documentations, and will not be repeated here. For the purposes of this document, we will focus on three broadly described network elements – the IP Multimedia Subsystem (IMS), the Evolved Packet Core (EPC) and the Radio Access Network (RAN). 1 Verizon was represented on the Interoperability Board by Diane Wesche, Executive Director, Government Network & Technology, and it supports the recommendations of the Board.


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• IMS is a standards-based architecture (defined by 3GPP) that is designed to support any

application, on any device, across any network. IMS provides common IP services across wireless and wired networks and simplifies the development environment which speeds application development. There is no need to rewrite code for various device form factors or transport networks. Code is generally written once and published to multiple users. The main benefit of the IMS core is to provide centralized services regardless of the type of endpoint. The IMS core includes the Home Subscriber Server (HSS).

• The EPC is a mobile core network and its main responsibilities include mobility

management, policy management and security. The EPC consists of the Mobility Management Entity (MME), the Serving Gateway (S-GW), and the Packet Data Network Gateway (P-GW). This architecture has fewer nodes compared with previous 3GPP architectures and, therefore, has lower packet delay. This capability is particularly important for real-time voice and video applications.

• The RAN for LTE consists of a single node (eNodeB or eNB) that interfaces with the

user equipment. The eNB hosts the Physical (PHY), Medium Access Control (MAC), Radio Link Control (RLC), and Packet Data Control Protocol (PDCP) layers that include the functionality of user-plane header-compression and encryption. It also offers Radio Resource Control (RRC) functionality corresponding to the control plane. It performs many functions including radio resource management, admission control, scheduling, enforcement of negotiated uplink Quality of Service (QoS), cell information broadcast, ciphering/deciphering of user and control plane data, and compression/decompression of downlink/uplink user plane packet headers.

Verizon believes it is important that FirstNet oversee the construction and operation of a single, logical national IMS core and EPC that is built with a sufficient level of redundancy and geographic diversity to promote network resiliency during times of stress or during regional disasters when local outages may occur. Verizon achieves this in its own LTE network by taking a number of measures including: (1) development of a cohesive, interoperable national network architecture; (2) deployment of redundant EPC components (e.g., MME and S-GW) at a significant number of regional locations across its national network; and (3) deployment of redundant IMS core components (e.g., HSS) located at a few key locations. Verizon also believes that FirstNet’s IMS core and EPC should be dedicated to emergency communications. This will ensure the highest level of service quality and priority for first responders during times of crisis. Any secondary uses of FirstNet’s spectrum or other network resources (e.g., RAN) should not utilize the FirstNet IMS core and EPC. Rather, any non-public


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safety traffic should utilize commercial network cores through partnerships with commercial service providers (as envisioned by the Spectrum Act). Verizon believes that the RAN should be implemented on a state or regional basis, because of the localized nature of these network elements. This could be achieved either through deference to regional, State, tribal and local jurisdictions in the planning process (§ 6206(c)(2)) or grant of a valid “opt-out” request (§ 6301(e)). Under the first option, FirstNet could oversee the construction and operation of the RAN itself while also ensuring that more localized expertise is involved with construction and operation of the RAN based on local needs. Under the second option, it could delegate responsibility to the states to oversee the construction and operation of the RAN in their respective states (under the Spectrum Act’s “opt out” provisions). Verizon believes that RAN deployment will likely be driven by local first responder needs and infrastructure sharing arrangements that involve state and local agencies, commercial service providers, tower companies, and others that vary from one area to the next. Consequently, we acknowledge that in many instances states may be in a better position to build and operate the RAN, subject to a condition that they interconnect to the FirstNet IMS and EPC. Verizon does not believe that state-deployed RANs would undermine the critical goal of nationwide interoperability, so long as FirstNet establishes a uniform technical framework that all states would be required to follow, and each RAN adheres to the recommended minimum technical requirements of the Interoperability Board. Central management of the core architecture is important to ensure operational integrity of the IMS and EPC. In fact, the use of a single, national architecture is a requirement of the Spectrum Act. However, subject to FirstNet meeting its legal obligation to ensure nationwide standards for use and access of the network, Verizon believes FirstNet should work closely with state and local public safety officials to ensure a level of local control is incorporated into the network design to allow local officials to manage customized attributes to the network. Verizon incorporates such capabilities into its own network operations. For its commercial LTE network, Verizon determines a national architecture and design and then provides requirements or guidelines to more than twenty regional operational organizations within Verizon that have responsibility for operating, maintaining, and managing certain aspects of some EPC components and the RAN. Although Verizon has a national organization with oversight, planning and design responsibilities, certain functions are distributed regionally. The same approach could be taken by FirstNet, in close coordination with any states wanting to operate their own RAN. The recommended network architecture for the NPSBN is shown in the following diagram.


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In implementing its own LTE network, Verizon has employed a multi-vendor approach in selecting network equipment. Specifically, Verizon utilizes two different manufacturers of key IMS core and EPC components, with RAN vendor selection matched to certain EPC nodes (i.e., S-GW and MME). This provides the competitive benefits of using multiple vendors, while ensuring compatibility of the EPC and RAN. Moreover, in this early stage of LTE deployment, RAN components only exist today that are paired with some of the same vendor’s EPC components. FirstNet may wish to consider the same type of multi-vendor approach. Doing so, however, does not mean that FirstNet would have to sacrifice the benefits associated with a single logical EPC with state-based RANs interconnected to that EPC. FirstNet could design a fully redundant, multi-vendor EPC architecture, while specifying to the States the compatible RAN architecture. Spectrum Sharing Options Verizon believes that there are two forms of spectrum sharing that could be employed by FirstNet (or the States) to generate revenue that can offset the cost of building and operating the


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NPSBN.2 The first is an outright spectrum lease (e.g., FirstNet leases 10 MHz of spectrum it doesn’t need in a particular area) and the second is dynamic spectrum sharing (spectrum leased in real time, as FirstNet needs dictate). While the latter is likely to be more appealing to FirstNet, it would be less appealing to commercial providers because it creates less certainty about spectrum availability. This was one of the principal flaws of the partnership model envisioned by the D Block auction. Verizon believes that it is premature to make any judgments about spectrum sharing opportunities before FirstNet undertakes a more comprehensive spectrum needs analysis as part of its network plan. Moreover, FirstNet may wish to limit any spectrum sharing arrangements in the early stages of NPSBN deployment, in order to ensure that it is fully meeting the needs of first responders. Partnerships that involve spectrum sharing may be more likely in rural areas, where FirstNet’s spectrum needs are considerably less and the commercial interest in 700 MHz is high due to its favorable propagation characteristics. These types of partnerships have the added benefit of promoting broader deployment of commercial broadband services while at the same time expanding FirstNet’s coverage. Verizon’s LTE in Rural America program provides a useful example of such a partnership. (See https://aboutus.vzw.com/rural/Overview.html for more information). Under that program, Verizon leases its 700 MHz spectrum to rural wireless providers that build out their own RAN. Both Verizon’s customers and the customers of the rural wireless providers benefit from an expanded LTE footprint. A similar model could be employed by FirstNet in partnership with rural providers that seek access to 700 MHz spectrum, though first responder and commercial traffic would need to be segmented and directed to different EPCs. Financial Model It is critical that FirstNet establish a financial model for the NPSBN that assures its viability over the long term. Given the significant cost of building a standalone broadband network across the country and the limited availability of government funds, FirstNet should give strong consideration to utilizing partnerships with telecommunications companies, tower companies, and others that have already invested (or plan to invest) in broadband networks and associated infrastructure. In doing so, however, it must ensure that these partnerships are aligned with FirstNet’s primary mission of providing emergency communications. 2 Under an “opt out” arrangement, where a State builds and operates a RAN that interconnects to the FirstNet EPC, Verizon would expect the State to lease the spectrum from FirstNet and control whatever sharing of the spectrum and RAN takes place between it and a commercial partner. However, even under circumstances where FirstNet builds and operates a RAN in a particular State, that State should have considerable input into the spectrum and infrastructure sharing arrangements established by FirstNet.

https://aboutus.vzw.com/rural/Overview.html


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In identifying what types of partnerships would be most effective, FirstNet should learn from the lessons of the past. The failed D Block auction, for example, demonstrated clearly that commercial and public safety objectives are not always aligned and that a “shared network” designed to guarantee priority use for first responders is not likely to attract commercial investment. Conversely, a “shared infrastructure” model for the RAN, in which public safety and its commercial partners share cell sites, towers, power equipment, and other ancillary components of the network, would reduce the cost of network build-out without sacrificing either partner’s need for dedicated capacity (as the FCC concluded in its post-auction review of the D Block). In building the RAN and backhaul, existing public infrastructure should also be leveraged. As already noted, spectrum sharing may also be feasible, and might represent a revenue source for FirstNet under certain circumstances. Any sharing of the EPC or RAN, while technically feasible, presents challenges and trade-offs for both FirstNet and its prospective commercial partners that could have significant impacts on a public-private partnership. FirstNet should assess these options very carefully, and make sure it fully understands what the long term implications might be, especially with regard to any technical deterioration of service for emergency responders. As already noted, Verizon believes that it is imperative for national security and public safety reasons that the IMS core and EPC built and operated by FirstNet be dedicated to emergency responder use. Sharing either with commercial uses will raise the very challenging priority issues that prompted the need for a NPSBN in the first place. Assuming these network elements are dedicated for first responder use, Verizon believes that the financial model that FirstNet employs for those elements should be based on a managed services contract that FirstNet establishes with an IMS/EPC operator, with initial capital funded through the federal grant dollars made available through the Spectrum Act. Given the importance of the IMS core and EPC to the NPSBN, Verizon recommends that this capital outlay be one of the principal uses of the $2 billion initial funding that FirstNet may borrow from the U.S. Treasury. Operating expenses associated with the IMS core and EPC, as well as future capital upgrades, could be covered through access fees paid by those first responders using the NPSBN (as envisioned by the Spectrum Act). FirstNet may also wish to recover a portion of the initial capital outlay of the IMS core and EPC through these state/local access fees, but it would need to make that determination as part of a more comprehensive assessment of the network’s long term use and cost structure. Verizon believes that the same basic financial model (i.e., managed services contract) could be applicable to the RAN if the RAN is designed to be dedicated for first responder use, though a state-built RAN would require capital outlays to the state and not exclusively to FirstNet. Some public-private partnership arrangements, however, are also possible to further reduce the cost of network deployment and operation. As already noted, spectrum leasing might be utilized as a revenue source if FirstNet (or the State) determines that it doesn’t require access to all 20 MHz


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of the spectrum. This spectrum lease could be established with the commercial partner with whom FirstNet (or the State) contracts to build and operate the RAN, as a way to offset those costs, or it could be established with an independent wireless operator. It is also possible to share the RAN as part of a spectrum lease to further offset the costs of building the NPSBN. Verizon acknowledges that opportunities to share the spectrum and/or RAN are likely to vary significantly on a state-by-state (or area-by-area) basis given the disparate needs of public safety users and prospective commercial partners in different parts of the country. Consequently, the states are likely to be in the best position to assess these spectrum/RAN sharing opportunities. Deployment Focus FirstNet will have access to $7 billion of federal funds, but only $2 billion will be available in the near term. Consequently, it is critical that FirstNet prioritize its initial deployment to make the most of this initial funding. Verizon recommends that FirstNet’s initial deployment phase focus on the following areas:

1. Construct and operate a logical, national (but geographically diverse) IMS core and EPC that will ensure core services are available to all parts of the country as those areas are deployed.

2. Construct and operate RANs in those areas where first responder needs are determined to be the greatest.

3. Use public-private partnerships, e.g., infrastructure sharing and spectrum sharing (where appropriate) to promote broadband access in rural areas where commercial alternatives don’t exist.

4. Use commercial 3G/4G networks in those areas where the NPSBN is not yet available (facilitated through the use of multi-band devices).

5. Construct and operate deployable assets, such as cells on wheels (COWs) and cells on light trucks (COLTs), as such equipment can be rapidly deployed to augment coverage and/or capacity in the event of a major emergency or to simply address public safety’s expanding needs. These assets could also be utilized where FirstNet has not yet constructed a network, to augment the use of commercial networks during emergencies.

Site/Infrastructure Sharing Verizon has long advocated sharing infrastructure (e.g., land, building/tower space, power and HVAC equipment, backhaul rights-of-way) with the NPSBN, and is willing to support such arrangements with FirstNet subject to their availability and the needs of the business. Such arrangements can reduce the cost of deploying the NPSBN and would also help to speed its


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deployment. Verizon does not currently see a significant value in sharing active network elements (such as parts of the EPC or RAN) because it does not believe it would be in the best interests of FirstNet, the public safety users, or Verizon. RAN (specifically eNodeB) sharing is likely to be driven by determinations regarding sharing spectrum. Note also that Verizon will have fully deployed its own nationwide LTE network by the time FirstNet is ready to begin its own deployment, so it will not likely be cost effective for Verizon to deploy a shared eNodeB. Importantly, while 3GPP standards address the capabilities of sharing spectrum and RAN, each type of sharing arrangement will be unique. Due to the complexity of the technical and business aspects of sharing arrangements, more work is required before these options would be ready for commercial deployment. Verizon has long standing relationships with backhaul providers and has utilized those relationships as it has increased its backhaul capacity with fiber optic systems. Fiber is our backhaul facility of choice, when it is available, due to its higher capacity and ability to accommodate the increased bandwidth requirements of LTE. Use of fiber optic systems also minimizes the additional tower space required for microwave radio antennae. Sharing backhaul presents special challenges related to engineering logistics, capacity, and contract concerns that may make it undesirable for Verizon to share its backhaul facilities with FirstNet. Sharing backhaul rights-of-way is likely to be more plausible. All such arrangements would have to be reviewed on a case-by-case basis. Verizon offers some additional advice to FirstNet as it considers what infrastructure investments it will need. With regard to backhaul, it may be advantageous for FirstNet to leverage its buying power based on the number of links that would be required to support the NPSBN, as Verizon Wireless has done with its own network. However, leveraging the investments in backhaul networks made by the States may provide a more attractive option under some circumstances. Backhaul options will likely be influenced significantly by the types of site sharing arrangements that are established. While collocation at existing commercial cell sites will likely yield the greatest savings, where new sites are required, Verizon recommends that FirstNet seek to utilize existing structures as that will help to reduce build cost and promotes more rapid deployment. Verizon also believes that FirstNet should invest in deployable assets, such as cells on wheels (COWs) and cells on light trucks (COLTs), as such equipment can be rapidly deployed to augment coverage and/or capacity in the event of a major emergency or to simply address public safety’s expanding needs. These units should be pre-positioned around the country in accordance with public safety’s specific needs.


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Prioritization Verizon has fully implemented voice and circuit switched data priority access on its 3G CDMA network in support of the federal government program Wireless Priority Service (WPS), and has begun the process of planning for priority access on its 4G LTE network. This implementation will take advantage of the capabilities built into LTE, utilizing Access Priority (the ability to gain access to cell sectors as determined by the Random Access Channel), Admission Priority (the ability to establish a connection or bearer) and Traffic Priority (the ability to gain transport and spectrum resources relative to other traffic). This same set of capabilities is available with LTE either on the NPSBN or commercial networks. While LTE will support full preemption, and FirstNet may wish to employ it on the NPSBN, Verizon has no plans to implement preemption of commercial traffic on its LTE network. In addition to supporting priority access for public safety customers homed on Verizon’s commercial network, Verizon is planning to implement priority for public safety users that roam onto its LTE network from the NPSBN (again, without preemption of commercial traffic). Planning for this service is in the early stages and will require discussions with FirstNet in order to define priority schemes that map different levels of priority between the two networks. These definitions would be established as a part of any roaming agreement with FirstNet, if such an agreement is requested by FirstNet and if parties mutually agree. Network Hardening Verizon Wireless has taken many steps to prevent outages from affecting its customers. Its emergency response capabilities have been tested and proven during many difficult situations including the wildfires, tornadoes, flooding and hurricanes. The performance of Verizon Wireless’ network, the most reliable in the country, is a combination of strong technology and capable employees. Network operations teams across the country conduct exercises each year to confirm team members have access to contacts, systems, tools, and suppliers to resolve any potential disaster or disruption that occurs. These teams are empowered to identify and implement ways to make the network stronger, more efficient, and available for Verizon’s customers when they need it, even during natural disasters. Thanks to these efforts and ongoing preparations and investments, our network has stayed strong – even through the natural disasters of past years – while other communication networks often were adversely impacted or failed. Verizon provides voice and data service through a sophisticated network consisting of dozens of switching systems and thousands of base stations throughout its cellular footprint. Many critical network systems are located in geographically diverse locations. The most critical systems provide uninterrupted service to customers, even if one location is damaged. These systems are


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designed to automatically fail-over to an alternate location with minimal, if any, impact to customers. These systems are tested at least annually as part of Verizon Wireless’ Business Continuity/Disaster Recovery program, and in many cases are tested more frequently to maintain reliable service. Many critical circuits in Verizon’s network infrastructure are provisioned with special priority. This is intended to ensure that, in the event of a disruption, these circuits are repaired as quickly as possible. This capability is just one part of Verizon’s significant ongoing investment in network reliability. The operational loss of any communications facility is a serious issue, but the resiliency of Verizon’s Network Equipment Centers (NEC) and Mobile Switching Centers (MSC) is especially important. In addition to supporting Verizon’s 2G and 3G networks, the NECs and MSCs also house the components of Verizon’s 4G LTE EPC, i.e., the MME, S-GW, and P-GW. Each NEC and MSC is protected by automatic power backup systems, by automatic fire-suppression systems, and by physical security systems and alarms. In each NEC and MSC, network operations personnel routinely backup system data for the switch itself and the peripheral systems. Automated backup routines are supplemented with scheduled manual backup routines and off-site storage of critical data. Verizon has more than 40,000 cell sites across its nationwide network to provide the desired level of service, both in terms of coverage and capacity. Despite the large number of sites, Verizon still takes the loss of a single cell site seriously. Therefore, Verizon takes special care to harden its cell sites. To the extent that FirstNet wishes to share these sites with Verizon, the following hardening features would provide benefits to the NPSBN:

• Automatic fire suppression and detection systems that are alarmed

• Physical security and intrusion systems that are alarmed

• Automatic power backup systems, including batteries and generators

• Special arrangements with suppliers of major components, up to and including the building and tower, to facilitate immediate priority restoration

• Earthquake hardening of shelters and towers in earthquake prone zones

• Overlapping and redundant coverage of cell sites

• Diverse routing of backhaul circuits in certain critical areas Service protection and restoration strategies are an integral part of Verizon’ network management. MSCs and cell sites are automatically and continuously monitored for numerous factors, from call processing to room temperature. All MSCs have battery backup and


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permanent generators. Verizon also maintains and utilizes a fleet of dozens of Cells on Wheels (COWs), Cells on Light Trucks (COLTs), and generators on trailers (GOaTs) that can be rolled into hard-hit locations or areas that need extra network capacity in a given area. In addition, Verizon also maintains towers on wheels and portable generators. Verizon has implemented Telecommunication Service Priority (TSP) capabilities on critical backhaul circuits, which provides priority service restoration if a circuit is disrupted. Verizon Wireless has two geographically diverse Network Operations Centers (NOCs) that monitor all facilities, cell sites and switches across its nationwide network. These NOCs are staffed 24x7 with experienced personnel who work closely with the regional field operations teams and with suppliers to coordinate and expedite the restoration of service in the event of outages. Verizon has set up alarms for critical components at the cell sites and the MSCs. These send prioritized alarms and detailed data to the MSCs and NOCs. The detail includes identification of any malfunctioning module and the component responsible. Alarms are coded with varying degrees of priority, so that minor problems do not obscure critical problems from a technician's attention. The code also helps the technician determine how quickly the problem must be addressed. Verizon recognizes that FirstNet may determine that the NPSBN requires network hardening at a level that exceeds what Verizon or another commercial service provider can support. If that is the case and FirstNet still wishes to utilize commercial sites, then additional funds would need to be allocated to facilitate the necessary upgrades. Roaming The importance of roaming between the NPSBN and commercial networks has already been noted, and Verizon has previously committed to offering roaming services to NPSBN users. Verizon Wireless is the industry leader in deploying advanced broadband networks and is the only carrier with a contiguous coast-to-coast 700 MHz spectrum coverage. Verizon Wireless operates the nation’s largest LTE network. It is on track to meet its goal of covering more than 400 U.S. markets by the end of 2012, and expects to cover its entire current 3G footprint with its 4G LTE network by the end of 2013. With its reliable network and extensive coverage, Verizon is well positioned to help FirstNet provide first responders with broader connectivity as it builds out the NPSBN. While Verizon’s commercial networks will be especially important in the early phase of deployment as the NPSBN is constructed, it can also provide a critical “relief valve” in situations such as special operations – planned and unplanned – where additional capacity is needed by FirstNet to supplement the capacity of the NPSBN. Verizon’s commercial networks may also serve as important back-up facilities to the NPSBN in the event of expected or unexpected outages, thereby eliminating a single point of failure.


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Verizon Wireless is planning for and testing bi-directional roaming between its commercial LTE network and the NPSBN. Bi-directional roaming would allow authorized public safety users that are homed on the NPSBN to roam onto Verizon’s network when out of FirstNet’s coverage area, and it would allow authorized public safety users that are homed on the Verizon network (e.g., where FirstNet has not yet constructed a network) to roam onto the NPSBN. Bi-directional roaming will provide benefits to support various scenarios. NPSBN users would have wireless broadband access while outside of the NPSBN coverage area, as well as inside the NPSBN footprint when additional capacity is needed to supplement the NPSBN. Public safety customers that utilize Verizon’s LTE network would have the ability to roam onto the NPSBN when necessary (e.g., when providing mutual aid), while also having access to all of Verizon’s resources (e.g., customer service, device software management, ability to fallback to Verizon’s 3G network). Bi-directional roaming will also promote the development of dual band devices by commercial providers that include FirstNet’s spectrum (identified as Band 14 by 3GPP) which will increase interest among manufacturers, reduce production costs, and ultimately promote a larger ecosystem of devices from which FirstNet can choose. As described in the next section, the development of such devices will be a significant challenge for FirstNet. By promoting dual band devices, bi-directional roaming will enable public safety users to buy commercial devices in the near term that could later operate on the NPSBN (SIM change and software flash may be required). This will enable capital device expenditures by public safety into commercial technologies today to be scalable to operation on the NPSBN. It will also further enhance the ability for FirstNet to offer spectrum sharing arrangement, since an ecosystem of devices that could operate on Band 14 and commercial bands will be more likely. Device management and security is an important issue that FirstNet will need to address. Verizon recommends the use of a validation process similar to what is used by the National Communication System (NCS) for WPS to verify any user’s credentials to access the network. Additionally, any device or identity management security policy deployed over FirstNet would also need to be enforced over commercial public safety users that would have access to roaming to FirstNet. Verizon recommends that FirstNet consider the CJIS security policy as a baseline for security and identity management.3

3 The security policy developed by the Criminal Justice Information Services is considered to be Sensitive But Unclassified (SBU) material. This policy may not be posted to a public website and discretion must be exercised in sharing the contents of the policy with individuals and entities who are not engaged in law enforcement or the administration of criminal justice. For these reasons, access the policy and its addendum from within the State-provided IDACS system, or log on to the FBI CJIS Division's Law Enforcement Online secure web site to obtain a copy.


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In preparation for roaming arrangements with FirstNet, the standard GSMA roaming documents (AA.12, AA.13, AA.14, IR.21) are being reviewed, with adjustments in mind to support the unique requirements of public safety. Verizon is committed to public safety and intends to provide roaming services, as described herein, to facilitate interconnection of public safety users between the NPSBN and Verizon’s commercial wireless networks. Consequently, it is working through internal detailed designs, negotiating with Internet Packet Exchange (IPX) vendors, and developing testing plans, in preparation for the initial NPSBN deployments. Verizon looks forward to working with FirstNet to further refine these activities. Device Availability It is important that wireless devices be developed that meet public safety’s specific needs, while enabling use of those devices on the NPSBN as well as on commercial networks. FirstNet users will require multiple form factors of smartphones, tablets, mobile broadband cards, and routers. While “commercial grade” devices may meet the needs of some first responders, others will likely need specialized devices, such as those that meet military specifications or devices that are intrinsically safe. FirstNet should not expect these devices to cost the same as commercial devices widely available from commercial providers today. Even “commercial grade” devices may be more expensive since they would not include the equipment subsidies that many commercial providers routinely provide as part of their service contracts. Due to the complexity of combining Band 14 and commercial bands into one device, while adding public safety grade design and features, Verizon recommends that FirstNet develop a device strategy that is aligned with its roaming strategy and includes both near term and long term objectives. Importantly, not every commercial band can be included in every device, and the number of bands supported will significantly impact the size, cost, and battery life of the device.4 Initially, Verizon believes that FirstNet should seek to develop devices that include Band 14 as well as some combination of commercial bands (3G and 4G) that enable the broadest possible access to broadband services.

4 Verizon has previously provided a variety of information to the FCC to address the challenges associated with incorporating multiple bands into wireless devices. References to this information, as well as information provided by others in the private sector, are referenced here for FirstNet’s use. See Comments of Verizon Wireless, In the Matter of 700 MHz Mobile Equipment Compatibility, Petition for Rulemaking Regarding the Need for 700 MHz Mobile Equipment to be Capable of Operating on All Paired Commercial 700 MHz Frequency Blocks, RM-11592, (“Interoperability Petition”), filed March 31, 2010; see also Reply Comments of Verizon Wireless, In the Matter of Promoting Interoperability in the 700 MHz Commercial Spectrum, WT Docket No. 12-69, (“Interoperability NPRM”), filed July 16, 2012; see also Comments of Verizon Wireless, in response to Interoperability NPRM, filed June 1, 2012; see also Comments of Qualcomm Incorporated, in response to Interoperability NPRM, filed June 1, 2012; see also Comments of Qualcomm Incorporated, in response to Interoperability Petition, filed March 31, 2010.


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Verizon has launched several initiatives to promote a more robust ecosystem of commercial LTE devices, which might be used to help promote the development and wider availability of devices for FirstNet’s use:

Open Development Initiative (ODI) – provides tools for business partners to develop innovative devices and applications and to certify their solutions with a simplified process on the Verizon Wireless network. (http://opennetwork.verizonwireless.com) Verizon LTE Innovation Centers – provide the opportunity for participants to rapidly develop products within Verizon Wireless’ diverse LTE ecosystem of technology and product enablers. (https://www.lte.vzw/com/) Verizon Development Community (VDC) – provides application developers the latest tools and resources, as well as a streamlined go-to-market process for placement in our V-CAST Apps store. (http://developer.verizon.com) 4G Venture Forum (4GVF) – a collaboration of select venture funds, Verizon Wireless, Alcatel-Lucent and Ericsson, designed to facilitate the identification and commercialization of next generation 4G-related technologies.

Through our ODI program we have certified the Motorola Solutions VML 700 modem to operate on the Verizon network. The VML 700 and the LEX 700 smartphones, soon to be certified, also include Band 14 capability. Other equipment manufacturers are making ruggedized devices that will include both commercial spectrum bands and Band 14. Technical Standards & Testing Verizon is committed to open standards and participates in many standards bodies such as 3GPP and 3GPP2. It plays an active role in the proceedings, including submitting its own proposals where appropriate. Since wireless service providers are more “systems oriented,” Verizon is generally more involved in the development of high level systems requirements. The more detailed engineering aspects of standards development are normally addressed by equipment and software vendors. It is not uncommon, however, for these vendors to seek Verizon’s support for proposals and recommendations. Standards describe what to build and how to build it in the area of hardware and software. Verizon has the responsibility for getting it all to work together. This is accomplished through interoperability testing (IOT). There are nuances related to a commercial wireless network that require special treatment including back-end integration into billing systems, IMSI assignment, 3G/2G connectivity, etc. These interfaces are designed and then tested during IOT. There is

http://opennetwork.verizonwireless.com/

https://www.lte.vzw/com/

http://developer.verizon.com/


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ongoing testing during the building, deployment and operation phases. Standards give wireless providers the “thou shalt” direction and then optional parameters can be implemented and tested in the IOT process. Hardware and software vendors test their products before they get to Verizon, but oversight responsibility for inter-vendor testing falls to us to ensure that the products are compatible with and not harmful to our network and services. Verizon manages the process by ensuring rigorous testing and documenting carrier-specific call flows. Implementing software and hardware releases from different vendors at different times makes it difficult for wireless providers to install software and hardware into the network in a coordinated manner. The release management process is a significant effort and includes coordination of IOT, first office application testing, and scheduling of deployment of new hardware and software into the network. Verizon decides what to implement based on a number of factors:

• Current network architecture and operation • Network capacity issues • Marketing input • Hardware/software vendor interoperability

In addition to infrastructure testing, Verizon conducts Interoperability Development Testing (IODT). Chip vendors and device vendors work together. Verizon works closely with them to influence the outcomes, and tests its own applications very carefully. Third party applications are less rigorously tested. Devices are rigorously tested prior to being sold. Verizon’s testing procedures include:

• Technical Entrance Criteria Checklist for device vendors to complete and then initial “safe for network” testing

• IODT to ensure all aspects of a device are operational and functioning properly

• Field Testing prior to final approval on the network

• Any special testing that could include testing a device with Band 14 capabilities Next Generation 911 Services The Spectrum Act includes provisions designed to promote the development of Next Generation 911 (NG911) services and a requirement that FirstNet take steps to promote the integration of the NPSBN with public safety answering points (PSAPs) or their equivalent (§ 6206(b)(2)(C)). Verizon agrees with Congress that the development of NG911 services is an important public policy objective. Emergency services like 911 and Enhanced 911 have been important programs


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for enabling the public to get help when they need it. As commercial networks evolve to IP-based technologies, 911 systems must evolve with them. Implementation of NG911 will not only allow the public to seek help in new ways, but it can increase the reliability and resiliency of 911 services, for example, by enabling 911 “calls” to be routed to the PSAP that can best provide help. More pertinent to FirstNet’s network planning considerations, however, is how these NG911 systems can be integrated with the NPSBN, using IP-based technologies as the enabler. Given its significant experience in this area, Verizon offers the following advice to FirstNet on how it might achieve this important objective. Based on the evolving NENA i3 standards, NG911 is an initiative to replace existing narrowband, circuit switched TDM E911 infrastructure with resilient IP network technology based on Emergency Service IP Networks, or ESInets. This initiative is driven by three principal factors: (1) the need to optimize public safety operations efficiency through regionalization and consolidation; (2) support for all types of emergency communications including non-voice (multi-media) and video; and (3) the need to support multi-agency interoperability and integration that facilitates information sharing and optimized incident awareness. Integration of the NPSBN with complementary NG911 networks and services is thus an important public safety objective, and FirstNet should consider how interoperability between state and/or regional networks and the NPSBN can optimize PSAP/EOC functionality as well as enhancing incident awareness for first responders. Summary Verizon appreciates the opportunity to share with FirstNet its experiences and expertise in the area of advanced broadband communications. The decision to utilize standards-based commercial technology to support the NPSBN and to enable partnerships with the private sector will go a long way to promoting a cost effective and timely solution. However, in order to satisfy Congress’ mandate, FirstNet must focus on its principle mission of ensuring reliable emergency communications and it must ensure that any public-private partnerships work well for both sides. Verizon believes that an effective framework can be established, and we look forward to a continued dialogue with FirstNet in the future.

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