Comment on Public Safety Broadband Network

Today the Department of Commerce’s National Telecommunications and Information Administration (NTIA) published a ‘notice of inquiry’ in the Federal Register (77 FR 60680-60681) concerning proposals for the development of a nationwide interoperable public safety broadband network. The notice seeks public comment on the presentation made at the First Responder Network Authority (FirstNet) Board of Directors' meeting held on September 25, 2012, as well as to invite input on other network design and business plan considerations.

Specifically the NTIA is soliciting proposals that address the following requirements (77 FR 60681):

1. Meets public safety's requirements for priority, quality of service, and preemption features;

2. Uses, to the extent possible, existing radio access network and core network infrastructure installed by commercial mobile operators in order to maximize the coverage and performance delivered to public safety while minimizing the capital expenditures;

3. Reaches operational capability as quickly as possible; and

4. Enables voice services (cellular telephony and push-to-talk (PTT)) both within the FirstNet network as well as to/from other commercial networks, including the public switched telephone network (PSTN).

Expand Public Safety Definition

While it is not specifically stated in the notice or presentation, it appears that the FirstNet concept is centered around the needs of the classic ‘first responder’ community; police, fire and emergency medical personnel. These personnel certainly need to the ability to communicate with each other in a seamless manner, especially when responding across jurisdictional boundaries.

It seems to me, however, that in the modern world this definition needs to be expanded to take into account private sector security and response personnel. Well publicized incidents at chemical facilities in the Charleston, WV area in the last couple of years have clearly pointed to the need for closer communications between facility response personnel and public first responders. This communications would be enhanced by allowing (and in some cases requiring) critical infrastructure response personnel to communicate on this new broadband network.

Specifically, high-risk facilities identified under national level security programs such as CFATS or MTSA might consider requiring communications capability with a nationwide public safety broadband network (PSBN) to be included in site security plans. Similarly chemical facilities regulated under the EPA’s Risk Management Plan might require the same communications capabilities as part of the facility’s emergency response plan.

Additionally, the increased sophistication and private deployment of a wide variety of electronic sensors (including video, intrusion detection systems and hazardous material detectors) in and around critical infrastructure facilities could provide first responder personnel with critical information about the situation to which they are responding. Providing usable links of this sensor data to the public safety network is also something that needs to be considered.

Public Comments

The NTIA has requested that public comments on this topic be submitted by November 1^st, 2012 (a very short notice for many corporate and institutional responders). Responses may be emailed to NTIA at firstnetnoi@ntia.doc.gov. Copies of comments submitted will be posted on the NTIA web site.

NOTE: I am emailing a copy of this blog as such a comment.