The BayRICS Authority has been involved in planning efforts for public safety broadband since 2011. We made an early attempt to build a regional network (which has been replaced by FirstNet). We were disappointed to lose the opportunity to build that regional system, but we have worked hard since then to support and guide the progress of FirstNet. We worked closely with the California Governor’s Office of Emergency Services (CalOES) and the California First Responder Network Authority (CalFRN) on state consultation and evaluation of the FirstNet-AT&T State Plan. We have also conducted comprehensive research on alternatives to FirstNet.
I must admit that the FirstNet solution today is not the same product that we envisioned seven years ago. The current solution is not perfect, but it is a good start, and there is tremendous opportunity for public safety agencies to make it better in the near future. But only if the State opts-in.
Here are some of the reasons why I am confident that opt-in is the only choice for California:
- Opt-In results in minimal cost, risk and delay for the State. FirstNet and its commercial partner, AT&T will assume all of the risk and cost to deploy the network in California. AT&T has agreed to leverage its existing network to make FirstNet services available as soon as the State opts-in. The FirstNet/AT&T State Plan has been carefully vetted by CalOES, and AT&T has made significant efforts to meet the minimum requirements set by CalOES and CalFRN. BayRICS believes that the AT&T solution now meets all of those minimum requirements. The risk of low subscribership is also borne by AT&T. If it does not sign up sufficient numbers of public safety customers, AT&T will be subject to monetary penalties.
- Opt-Out is risky, costly, and will result in long delays. Federal law requires the State to issue a Request for Proposals (RFP), award a contract to a vendor for an alternate plan, secure the plan’s approval from the Federal Communications Commission (FCC) and Department of Commerce, then negotiate a spectrum lease agreement with FirstNet. Simply gaining approval for an alternate plan could take years to complete. Once approved, the network will be costly for the State to build, and the State must assume all risks of network failure. An opt-out decision is a 25-year obligation for the State. Technology changes quickly these days--required technology upgrades over 25 years will multiply the cost and the risk to the State.
- Opt-out delays will harm local first responders. Because AT&T has agreed to make FirstNet services available as soon as the State opts-in, current AT&T public safety customers could begin benefiting from enhanced broadband services immediately, and agencies with service from competing carriers can begin to compare their current service with the FirstNet offering. An opt-out decision will prevent all current AT&T customers from migrating to FirstNet, and there will be no FirstNet offering in the State to evaluate for many years. Opt-out delays will prevent all our first responders from using these critical services, which will save lives, protect property and keep our first responders safer in the field.
- Healthy competition is the leverage we have today to improve the FirstNet-AT&T solution. Opting-in to FirstNet will create a robust competitive market for public safety broadband services. No state or local agency is required to sign up for FirstNet services--agencies will be free to choose a competitive carrier if they find better service. The best way for local agencies to improve the FirstNet solution is to "vote with their pocketbook." Low adoption rates will be a big incentive for AT&T to improve coverage or service at the local agency level. But only if the State opts-in.
Congress created FirstNet to meet the last remaining goal of the 9-11 Commission--one nationwide interoperable network for public safety. We ask the Governor to consider the benefits FirstNet will bring to our state and its first responders and make the opt-in decision for California today.