Before the NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION

UNITED STATES DEPARTMENT OFCOMMERCE Washington, DC 20230

In the matter of Development of the Nationwide Interoperable Public Safety Broadband Network Notice of Inquiry

) ) ) ) ) )

Docket No. 120928505–2505–01 RIN 0660–XC002

COMMENTS OF ERICSSON

PATRIK RINGQVIST MARK RACEK PRINCIPAL SOLUTIONS MANAGER DIRECTOR, SPECTRUM POLICY ERICSSON INC ERICSSON INC 6300 Legacy Drive 1634 I Street, N.W., Suite 600 Plano, TX 75024 Washington D.C. 20006-4083

Mark.Racek@Ericsson.com Tel.: +1 202 8240110 Fax: +1 202 783 2206

November 9, 2012

TABLE OF CONTENTS

I. Introduction and Summary ........................................................................................................1

A. User-Driven Architecture .....................................................................................................3

II. FirstNet Nationwide Network Proposal .....................................................................................6

A. General Comments...............................................................................................................6

B. Multiple Network Diversity Concept...................................................................................8

C. Distributed Core Network Concept ...................................................................................10

D. Terrestrial Mobile Partner Concept ...................................................................................12

E. Deployable Infrastructure Concept ....................................................................................14

III. Service Delivery Platform Considerations...............................................................................15

IV. Network Operations Considerations ........................................................................................19

A. Blended Network Operations .............................................................................................20

B. The Operations Nexus........................................................................................................20

C. Recommendation ...............................................................................................................21

V. Other FirstNet Considerations .................................................................................................21

A. Public/Private Arrangements .............................................................................................22

B. FNN Proof of Concept .......................................................................................................22

C. Industry Advisory Groups..................................................................................................23

Conclusions ....................................................................................................................................24

Before the NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION

UNITED STATES DEPARTMENT OF COMMERCE Washington, DC 20230

In the matter of Development of the Nationwide Interoperable Public Safety Broadband Network Notice of Inquiry

) ) ) ) ) )

Docket No. 120928505–2505–01 RIN 0660–XC002

COMMENTS

Ericsson is pleased to provide its comments to the National Telecommunications and

Information Administration (“NTIA”) of the U.S. Department of Commercein response to

NTIA’s Notice of Inquiry (“NOI”).1 The NOI solicits comments on the First Responder

Network Authority (“FirstNet”) concept related to the delivery and development of a nationwide

interoperable public safety broadband network (“PSBN”), as defined in the Spectrum Act 2 and

as presented at the FirstNet Board of Directors meeting on September 25, 2012.

I. INTRODUCTION AND SUMMARY

Ericsson has been engineering fixed and mobile technologies for over 130 years, and its

products are implemented in communications networks in 175 countries. Ericsson also has

special expertise in the products that optimize network performance and permit providersto

deliver reliable communications. For example, Ericsson is a leading innovator and driver of

LTE, the standardized 4G wireless technology that is to be employed in the PSBN. LTE will

deliver extremely high performance wireless service (ultimately, in excess of 100 Mbps), which

1 77 Fed.Reg. 60680 (Oct.4, 2012). 2 Middle Class Tax Relief and Job Creation Act of 2012, Pub L. No. 112-96, 126 Stat. 156

(2012) (the “Spectrum Act”).

2

will support wireless multimedia applications and services to allow first responders to act

effectively in the interest of public safety.

Ericsson congratulates FirstNet on swift action in taking the first step to define the

FirstNet Nationwide Network (“FNN”) foundational concepts that it proposes to be employed in

designing and building the PSBN and for reaching out to its future constituents (i.e., users) and

the telecommunications industry at large for input and guidance on this critical issue.

The FNN concept is expected to deliver the PSBN within the construct of the Act. This

presents many unique challenges that call for blending commercial and Public Safety (“PS”)

requirements, securing consensus across a broad spectrum of stakeholders, employing private

business concepts and establishing public private arrangements to foster partnerships that will

enable self-sustaining means to operate the network and deliver the quality of service and

reliability required for a mission critical system.

Specifically our comments are focused on the following points:

• PSBN network deployment and architecture should be driven by public safety use cases.

• The PSBN architecture must enable evolution of technology and user needs.

• The FNN concept may face implementation changes due to differences between public

safety mission-critical user needs and commercial network user expectations.

• Integrate, adapt,and leverage commercial Service Delivery Platform (“SDP”) technology

with Public Safety requirements that will provide a focus on the application developer

community as the SDP customer.

• Leverage installed PSBN waiver systems as real world proof of concept environments.

• Use and leverage industry resources and advice for planning the PSBN.

Our comments are focused on analyzing the FNN concepts of Multiple Network

Diversity, Distributed Core Network, Terrestrial Mobile Partners and Deployable Infrastructure

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as they apply to meeting PS user requirements. Additionally we discuss considerations for the

Service Delivery Platform component of the PSBN core, Network Operations and other FirstNet

Business Plan elements.

To gain the highest efficiency and maximum utility from its fixed treasury allocation we

urge FirstNet to develop a total cost of ownership (“TCO”) planning and ongoing management

program. This TCO effort will highlight and uncover the costs to address the challenges of

development and sustainment of a national interoperable PSBN that meets the needs of the

diverse range of stakeholders and subscribers.

To this end, FirstNet should ensure that the design starts with and meets the needs of the

Public Safety community and leverages work completed by the National Public Safety

Telecommunications Council (“NPSTC”), Association of Public-Safety Communications

Officials (“APCO”), and others.

In summary, with its large spectrum of stakeholders, unique blend of Public Safety,

government, and commercial requirements, fixed funding allocations and accelerated design,

build and operate vision, FirstNet must be guided by the principle of delivering a network that is

available, reliable, and offers the level of service expected by the public safety users.

A. USER-DRIVEN ARCHITECTURE

Sam Ginn, the Chairman of FirstNet’s Board of Directors, stated in his opening remarks

at the September 25, 2012 Board meeting, “Our real test is we’ve got to provide capabilities to

public safety to allow them to do their job better.”3 This underlying focus on the user is a premise

Ericsson shares and that we believe should guide all activities. An informed network

3 Transcript, Meeting of the First Responder Network Authority, at 7 (Sept. 25, 2012),

available at http://www.ntia.doc.gov/files/ntia/publications/firstnet_board_9-25-2012_transcript.pdf#page=7.

4

architectural plan incorporates fundamental business use case elements such as, but not limited

to, the value proposition to the user, the user experience, user adoption of the provided services,

the ability to retain the user as a subscriber and the ability to match the evolution of the user need

with the evolution of the architecture.

The PSBN will be built using LTE technology, as mandated in the statute and

recommended by the FCC interoperability board, and that will provide an excellent FNN

foundation because the LTE standards are user-centric and were developed based on use cases.

FirstNet needs to consider more than the LTE standards, however, in meeting PS user needs.

FirstNet needs to correlate and blend the dynamic interplay between user centric public

safety requirements and business partnering (public/private arrangements) with technological

innovation to deliver the desired level of Functionality, Reliability, Availability, Security, and

Priority. This will enable FirstNet to create an ecosystem for PS that has the potential to bring

new PS-oriented products such as infrastructure, devices, applications and security solutions to

the market. A user requirements-driven process for all aspects of planning, including the

network architecture, will foster the acceptance and consensus of FirstNet’s constituents and

strengthen the value of all elements of the ecosystem.

The FNN concept and narrative presentation at the FirstNet Board meeting allowed

Ericsson to grasp the orientation of the Board as outlined in the objectives section of the FNN

presentation. However there was little discussion of the user nor business requirements, industry

standards and economics that were the basis for the conclusions and premise for the approach

proposed by the Board.

Key conceptual elements that were not stated in the FNN presentation that must be

considered are:

5

• A network deployment architecture needs to consider more than standards, costs and

“time to network.” Standards are one element of the architecture foundations.

• A phased or multiyear plan that correlates user requirements with planned technology

evolution was not explicitly illustrated but is critical to delivering the value expected by

PS. This multiyear view should be a foundational element and form the basis of the

network architecture.

• No two operators’ “deployment architecture” is alike, due to myriad variables,even

within the commercial operator environment. The deployment architecture decisions are

based in great part by user requirements and budget availability.

• Potential differences in needs between public safety users and commercial network users

could drive differences in deployment architecture decisions and network evolution

decisions between FirstNet and operators.

• Public safety use cases may demand public safety specific functionality — e.g., one-to-

many communication and Land Mobile Radio (“LMR”) interoperability needs.

• Public safety services are provided at jurisdictional levels with local jurisdictional

knowledge necessary for the successful delivery of public safety services. Oversight and

control by the local jurisdiction is essential and should be part of any public safety

network architecture consideration.4

Ericsson has applied this user-centric approach to our NOI comments, evaluating how

effective the presented FNN concept in our opinion meets the stated needs of public safety user

community. The architecture is not about Core and Radio Access Network (“RAN”) 4 National Public Safety Telecommunications Council, Broadband Working Group, Local

Control Task Group, Local Control in the Nationwide Broadband Public Safety Network, Rev. F (March 2012), available at http://npstc.org/download.jsp?tableId=37&column=217&id=2254&file=LC21%20Local%20Control%20Definition%20Rev%20F.pdf.

6

architecture, but about how well the network performs end-to-end inmeeting the users’

expectations. The FNN concept presentation demonstrates support for many of the PS user

requirements, but not all, as stated earlier. Ericsson suggests that FirstNet assemble and correlate

user requirements, leveraging existing resources (e.g.,SafeCom and NPSTC), and then

objectively measure the ability of the FNN proposal to deliver on these requirements. This

analysis could define how well FirstNet will meet the needs of its constituents and provide a gap

analysis as a yard stick to completeness of network deployment architecture.

II. FIRSTNET NATIONWIDE NETWORK PROPOSAL

A. GENERAL COMMENTS

Ericsson understands from the FirstNet board meeting presentation that FirstNet has

considered three main architectural options in its proceedings and reached the conclusion that the

FNN proposal is the desired option that will accelerate the service availability and reach

operational capabilities faster and at the same time provide a highly reliable network service.

Ericsson supports FirstNet’s vision of leverage of existing industry capabilities to reach

operational capabilities faster and at a lower cost. This vision is also expressed in the Act for the

same reasons. We understand that, when viewed in the context of the stated FirstNet objectives

and FirstNet’s budget constraints, a stand-alone “greenfield” implementation may not be

feasible, even if such an option may offer network services custom-designed for PS user needs

and missions.

We interpret the FNN proposal to consist of four main concepts; we will focus our

comments on each of these four concepts in this section:

7

• Multiple Network Diversity, which is accomplished through arrangements with Mobile

Network Operators (“MNOs”) and Mobile Satellite Service providers (“MSSs”) to enable

PS users to access non-FirstNet spectrum.

• A FirstNet-operated Distributed Core Network consisting of Evolved Packet Core

(“EPC”) and Service Delivery Platform (“SDP”).

• Arrangement with a Terrestrial Mobile Partner, i.e., an MNO, to leverage existing

MNO infrastructure when building regional RANs.

• Use of Deployable Infrastructure to augment fixed infrastructure during emergencies.

We also propose adding key support elements such as Operational Support Systems

(“OSSs”) and Business Support Systems (“BSSs”) to the PSBN architecture. OSS functions are

critical for provisioning, sustaining the network, monitoring the network, repairs, upgrades and

to enable public safety local oversight and control functions. It is also required to provide

provisioning and management of PS users and their devices. BSS functions are critical to sustain

the network operations, enable customer care and ensure accurate billing. The network should

be able to provide billing reports and agency interfaces of each agency’s users, devices and

applications.

It was also not clear in the FNN proposal presentation whether a TCO analysis had been

completed. It appears that a key driver for FirstNet is “time to network,” or how quickly the

PSBN could reach operational status. The PSBN should not only be designed to minimize initial

build costs(capital expense, or “CAPEX”), but also to minimize operational expense (“OPEX”)

and TCO. A TCO model includes the cost for operating, maintaining, and evolving the network,

in addition to the build costs. It is important that all these factors are considered.

In summary, decisions made today can have large unforeseen future impacts if key facets

and variables are not folded into the planning process. Ericsson proposes that the FNN concept

8

is a strong first step in the overall preliminary planning process but that more work is still

required to develop and deliver a plan and architecture for this critically needed Public Safety

network.

B. MULTIPLE NETWORK DIVERSITY CONCEPT

A nationwide public safety broadband network covering all states and territories with

ubiquitous coverage is a laborious and expensive achievement for any operator. The FirstNet

task is even more challenging, as PS requires significantly greater coverage than any commercial

mobile network. PS must operate in all geographies, including rural areas. As Ericsson

understands the FNN concept, FirstNet proposes to solve this issue by using multiple network

capabilities provided in partnership agreements and enabling national roaming with those

partners. This is deemed especially important in early stages of network deployment when

public safety spectrum coverage may be sparse. While Ericsson understands the general premise

of the concept, several implementation challenges remain.

Roaming is a well understood practice in the mobile industry, and the LTE standards are

well-defined for roaming, but the LTE roaming scenarios required for PS operations may not yet

be in use by the mobile industry and necessary real-world experience may not yet be fully

available with regards to these roaming scenarios. This means that implementation issues may

remain that should not be underestimated.

One of the well-established industry practices for roaming leverages roaming exchange

networks to ease the roaming tasks of interconnect, security and accounting. The FNN proposal

is silent on the use of roaming exchanges. The FCC Interoperability Board, on the other hand,

9

did recommend the use of such roaming exchanges,5 a recommendation that should be supported

and is believed to speed up the operational capability of roaming.

FirstNet needs to define the service expectations for users when roaming to partner

operators’ networks, as the user experience couldbe different when roaming versus when

residing in the home network of FirstNet. If it is an unstated goal to preserve public-safety-grade

user experience while roaming, this will in all probability impose new requirements on the

visited network operator as well as on any intermediary roaming exchange service providers.

Aspects considered essential for meeting public-safety-grade-user experiences are quality

of service and prioritization as well as session continuity. Quality of service while roaming into

a partner operator’s network is not commonly used by the industry today; the most common

practice is to use only best-effort traffic channels. Although many PS applications can use best-

effort data services, it cannot be considered public-safety-grade. FirstNet and its partners

(operators and roaming exchanges) may need to implement specificdeployment architecture for

public safety grade priority and quality of service in this scenario..

Another consideration in supporting session continuity is that active sessions may be

handed over multiple times between operators. There is a special concern in cell border

situations, where varying conditions may cause the session to frequently alternate between

operators, a scenario which increases load and reduces user experience. This situation should be

avoided and may require new roaming algorithms in the public safety devices.

5 Technical Advisory Board for First Responder Interoperability, Recommended Minimum

Technical Requirements to Ensure Nationwide Interoperability for the Nationwide Public SafetyBroadband Network,http://hraunfoss.fcc.gov/edocs_public/ attachmatch/FCC-12-68A3.pdf (May 22, 2012)

10

Voice over LTE is also not yet widely supported in networks. It should therefore be

anticipated that voice in a roaming scenario is a future application and not to be supported

initially.

Security in any roaming scenario for public safety users and traffic must be considered.

Mobile VPN solutions are used today to achieve the wanted grade of security. Not using mobile

VPN with roaming partners and still obtain public safety grade security must be thoroughly

analyzed.

In summary, while the multiple network diversity concept may provide for an increased

network coverage and availability, it should not be assumed that it provides a public safety grade

user experience automatically. FirstNet should define an acceptable public safety user

experience while roaming and then work with network partners to ensure this user experience

can be realized while the public safety user is roaming to partner networks.

C. DISTRIBUTED CORE NETWORK CONCEPT

The FNN concept proposes to establish a FirstNet dedicated distributed core network that

consists of two main components: Evolved Packet Core (“EPC”) and Service Delivery Platform

(“SDP”). Ericsson agrees that a common core is essential to reach the objective of establishing

the PSBN with common services, and we also agree that this core should be dedicated for

FirstNet’s use and be distributed for reliability and efficiency reasons.

There are, however, several aspects of the proposed PSBN core implementation that need

to be further defined to secure a smooth implementation of the PSBN core network. The 3GPP

standards offer several implementation options; each option needs to be evaluated against the

architecture objectives and user requirements. Ericsson recommends that FirstNet resolves the

11

open issues and undertakes this evaluation as soon as possible leveraging input from the mobile

industry.

Some of the aspects that need to be clarified are (1) architecture objectives (e.g., different

objectives on reliability, costs and user experience can drive different PSBN core network

implementations);(2) function of core network in mobile partner networks as depicted in the

FNN concept presentation (e.g., function will drive interconnect requirements and interfaces

between the PSBN core and terrestrial mobile partner network);(3) scope of network sharing in

terrestrial mobile network partner network (which determines if 3GPP EPC features for shared

networks are needed or not);and(4) integration points with public safety agency networks for

local oversight and control as well as service access.

Both the statute and the FCC interoperability board discuss interconnectivity with

external networks, including legacy public safety LMR networks. These aspects are not

addressed in the FNN proposal as presented. The FCC interoperability board report6 shows such

inter-network connectivity to be the responsibility of the PSBN core. FirstNet should confirm if

that is its intention and incorporate such interconnectivity in the FirstNet architecture diagrams.

The SDP component of the PSBN core is stated to contain voice, PTT, messaging,

location and video application servers and data warehouses, plus the FirstNet App Store. The

FCC interoperability board report allows for multiple deployment options for these

applications:(1) nationwide applications by FirstNet as stated in the FNN proposal; and (2)

applications deployed by a PS agency. Other options could also be desired, such as third party

application environment (e.g., hosted by a vendor, MNO, or another private partner). The core

network architecture should consider and allow all these scenarios as well as extend a third party

6 Id.

12

developer environment. The latter aspects are described in a separate section in our NOI

response.

The FNN concept as presented by FirstNet should also be complemented with

capabilities for managing network security, subscriber information, device information, customer

care and network elements. These management capabilities are normally implemented through

various operation support solutions and back-office IT solutions. It can also be expected that

such functions needs to be integrated with corresponding functions in the terrestrial mobile

partner networks and in public safety agency networks in order to provide a complete network

view to both FirstNet and its public safety agency customers.

In summary, a dedicated, distributed PSBN core network as described in the FNN

proposal is essential to provide a uniform user experience. Several aspects of the proposed

PSBN core implementation, such as desired user experience, integration points with partner and

agency networks and operation and maintenance including local oversight and control aspects;

needs to be further defined to secure a smooth implementation of the PSBN core network that

delivers the right user experience.

D. TERRESTRIAL MOBILE PARTNER CONCEPT

Ericsson understands that FirstNet proposes to enter public private arrangements with

terrestrial mobile partners, i.e., MNOs, to leverage existing MNO infrastructure when building

regional RANs. The use of multiple terrestrial mobile partners’ networks is seen as improving

time to an operational network because significant MNO assets and capabilities could be used by

FirstNet. As stated earlier, Ericsson understands that, when viewed in the context of the stated

FirstNet objectives and its budget constraints, FirstNet should leverage partner capabilities as

13

much as possible. The question is, however, which assets to leverage and who the partners are.

The FNN concept is very vague on these points.

In addition to MNO partners addressed in the FNN concept, FirstNet should also consider

making use of, and leveraging, the valuable assets of other existing public/private entities, e.g.,

tower companies, fixed operators, cable operators, mobile vendor industry, utilities, public safety

and local government. Each of these entities offers valuable assets that can be leveraged, and

Ericsson believes FirstNet should evaluate such options. FirstNet should also clarify that it

intends to use a single RAN operating partner in a specific geographical area. Such a practice

would be much easier to manage and more aligned with commercial network practices, as

opposed to having multiple RAN operating partners in the same area.

The next question is what assets FirstNet should leverage and whether FirstNet envisions

a shared resource situation. For instance, cell site collocation is common in the mobile industry,

where MNOs leverage infrastructure assets from tower companies, utilities, and others as well as

transport solutions for cellsite backhaul. Network sharing, where the same spectrum is used by

the network sharing partners, is standardized in 3GPP. Commercial operators use spectrum

sharing to reduce costs in some cases, especially for rural areas.

Network sharing is not just about infrastructure costs, though; it also has an impact on

operations and customer care where different user requirements and expectations may create

divergence limiting the effectiveness of sharing. Additional insights are needed to evaluate the

cost/benefit of network sharing when the partners have different business concepts. This may be

the case with mission-critical public safety operating models and commercial operator business

models, especially in a spectrum sharing scenario.

Good relationships with terrestrial mobile partners are the key for successful geographic

coverage, and FirstNet and its partners must define and establish business models that are clear,

14

distinct, and easy to set up and manage. This common business model drives synergies between

the partners, making sharing a mutually beneficial practice. FirstNet needs to further elaborate

on what business model is to be used for two entities with very different businesses.

It is expected that FirstNet and its partner terrestrial operators will implement a means for

securing the sites and facilities of the network, as well as protection of the user data. Hence, the

network of FirstNet and its partner terrestrial operators must be hardened and protected from any

attack. Care must be taken to address sensitive information requiring special protection in

accordance with federal privacy and national security laws.

In summary, FirstNet needs to elaborate on, and more clearly define, the proposed

concepts — namely, the assets that are to be shared, the integration points with the FirstNet core

network, the business models governing the sharing, the operational models used, and the

security models used to protect the public safety network and information. If these concepts are

not better defined, it is not clear whether the proposed terrestrial mobile partner concept will

deliver the full public-safety-grade user experience that public safety needs.

E. DEPLOYABLE INFRASTRUCTURE CONCEPT

Ericsson supports and encourages the use of Deployable Infrastructure (“DI”) in the case

of emergencies. DI can meet the needs of incidents that require immediate capacity or

replacement communications. Ericsson has first-hand DI experience through the Ericsson

Response7 team, and our experiences may benefit FirstNet as it defines the FirstNet DI solutions

in more details. Ericsson Response provides essential mobile communications to support

disaster relief and humanitarian aid. Ericsson Response rapidly deploys communications

solutions to support relief organizations’ response to disaster or their ongoing humanitarian aid. 7 See the Ericsson web site for Ericsson Response information, http://www.ericsson.com/

thecompany/sustainability_corporateresponsibility/ericsson_response.

15

For example, Ericsson Response worked with a number of organizations through the UN-

sponsored Emergency Telecommunications Cluster to provide communications and Internet

access for relief workers in South Sudan in 2012, and built an emergency mobile network in

Haiti in 2010.

An important part of DI that cannot be overlooked is how it is integrated into the PSBN’s

operational model. Decisions as to when and where infrastructure will be deployed and

maintained for integration into the PSBN must be considered. An uncoordinated approach for

DI deployment may cause interference and reduce service capabilities of both the PSBN and the

deployed DI.

It may be natural to put the control of the DI in the hands of people in charge of the

emergency response. This would for the most part be the local public safety agency in whose

jurisdiction the emergency incident occurs. Alternatively, operator or equipment vendor

ownership may offer national and or regional depots for immediate accessibility and support of

mobile systems.

Deployable infrastructure thus poses several challenging control and governance issues

that will require resolution before DI can be considered for use within the FirstNet public safety

network effectively.

III. SERVICE DELIVERY PLATFORM CONSIDERATIONS

The mobile industry has seen a remarkable explosion in the number of mobile

applications in recent years. There are now well over a million applications available for

download8 and billions of applications downloaded each month.9 These are amazing numbers,

8 As of June 2012, the Google Play application store reported 600,000 apps, while Apple had

over 650,000. http://www.androidauthority.com/google-play-20-billion-app-downloads-600000-apps-games-98006/.

http://www.androidauthority.com/google-play-20-billion-app-downloads-600000-apps-games-98006/http://www.androidauthority.com/google-play-20-billion-app-downloads-600000-apps-games-98006/

16

which show the user demand for innovative applications and the innovative spirit in the mobile

industry. FirstNet clearly expressed a desire to leverage this innovative spirit for the benefit of

the public safety user community, an objective Ericsson fully supports.

Ericsson, as a world leader in the mobile industry, has seen this amazing evolution from

the inside, and is in a unique position to offer insights into what drives the application explosion,

its impacts on mobile networks and what actions operators should take to drive the application

eco system to enable application development. Ericsson’s overall recommendation is that

FirstNet consider the different factors, elements and practices that are part of the commercial

mobile industry application ecosystem. It is our belief that FirstNet can learn from these and

emulate best in class solutions from the mobile industry.

Ericsson’s comments take into account the different needs of the different actors in the

mobile application eco-systems: public safety users,10 device community, application developers

and network operators. Ericsson suggests that FirstNet focus on providing the building blocks

that enable application development, publishing, discovery, usage, billing, and support. These

building blocks form the Service Delivery Platform (“SDP”) framework. The SDP framework is

a horizontal application enabler that integrates with operation support systems, business support

systems and the network infrastructure. It provides a comprehensive range of services that

enriches services offered to users (by bridging telecom and internet services and offering a

(footnote continued) 9 Ingrid Lunden ,Google is seeing about 1 billion downloads of Android apps per month, while

Apple is seeing about 1.25 billion app downloads per month.” Google Play About To Pass 15 Billion App Downloads? Pssht! It Did That Weeks Ago,http://techcrunch.com/ 2012/05/07/google-play-about-to-pass-15-billion-downloads-pssht-it-did-that-weeks-ago/ (May 7, 2012).

10 Users in this context can mean individuals and M2M devices connected to FNN, but also public safety agencies. In many cases, public safety agencies are managing the user applications and not the individual public safety users.

17

advanced user experience),helps FirstNet optimize usage of the PSBN (through content

adaptation, filtering and QoS), and attracts device and developer community (by offering

simple, secure and controlled access to FirstNet assets and clearly defined business models).

The SDP framework should expose PSBN capabilities so they can be leveraged by

application software in an easy manner, regardless of if the software is executed in PSBN, a

cloud environment or on the device. Examples of such network capabilities are Voice, Video,

Messaging, Identity Management, Subscriber Information, Location, Presence, Media Injection,

QoS, Priority and Billing. Ericsson also sees a need for Contextual Communications, a concept

where communication happens in the context of a digital interaction. The context is captured

and is made available to the other parties (persons or machines) by the SDP. These network

capabilities and context information can for ease of use be exposed in the form of Application

Programming Interfaces (APIs) packaged into software libraries to provide run time environment

support for invoking network capabilities (both at initiation and at termination) and passing

context information.

Security is a key issue for public safety and requires special consideration in the SDP

framework. All API invocations should be designed to take a security token and authentication

key pair that will perform authentication and authorization of the particular user and service level

enforcement for API invocation (such as success rate). The standardized HTTPS and SRTP

protocols can be used as the logical transport mechanism for signaling and media respectively for

all provided services.

Public safety users need to trust the applications — i.e., they need to be confident that

they are reliable and that they provide the right mission-grade performance. FirstNet needs to

address several aspects to meet these expectations, e.g., a process for bringing developers on-

board that ensures qualified developers have the right tools available; service assurance

18

capabilities that assure applications and services are delivered with quality results over the

PSBN; business activity monitor applications that provide visibility to FirstNet, developers, and

public safety agencies; policy controls to ensure applications are not using excessive network

resources; and, finally, a certification process geared toward public safety that certifies both

developers and applications to the standards FirstNet establishes.

The most important key to success may be to focus on the developer community and their

needs. A service delivery platform without developers is like a car without fuel; it serves no

purpose. In the application-driven era that we are living in, the customers of an SDP are not the

end users but the developers. The developers make compelling applications that lead to satisfied

end users doing their job better. The developer community, either individuals or companies, is

made up of people who have limited time and need to get paid for their work. The most

successful developer platforms are those that make the most money for the developers who write

code for them. This is seen in open application system development programs where developers

target iOS before Android since the iOS ecosystem generates more money per application than

the equivalent application in Android.11

When targeting the developer community creating a developer platform there are four

independent key success factors to consider: (1) Unique Value Proposition —What does the

platform provide that I cannot get elsewhere?; (2) Simplicity: How easy is it to use?; (3)

Business Model — Can I afford to use it?; and(4) Distribution — If I use the platform, will it

help me get application customers? Ericsson recommends that FirstNet design its SDP

developer community offering with these four key factors in mind and position itself as the

11 See Flurry Analytics report: http://blog.flurry.com/bid/85911/App-Developers-Signal-Apple-

Allegiance-Ahead-of-WWDC-and-Google-I-O.

http://blog.flurry.com/bid/85911/App-Developers-Signal-Apple-Allegiance-Ahead-of-WWDC-and-Google-I-Ohttp://blog.flurry.com/bid/85911/App-Developers-Signal-Apple-Allegiance-Ahead-of-WWDC-and-Google-I-O

19

channel to public safety for all application developers. One good model is Happtique,12 which

offers applications for healthcare professionals, an industry closely related to Public Safety.

In summary, we applaud FirstNet’s early attention to the service delivery platform

environment. It is our opinion that applications are key for the success of FirstNet and the

measure of success for FirstNet SDP has to be user adoption. Users will adopt applications only

when it makes sense for them and only if they offer a rich user experience. The path to success

is to leverage the experiences of the mobile industry, apply the public safety user needs to that

experience and to focus on the application developer community treating them as the true SDP

customer. Without developers, no applications and without applications the SDP serves no

purpose for the public safety user community.

IV. NETWORK OPERATIONS CONSIDERATIONS

The FNN concept focused at a high level on the network implementation options that

were assessed, the objectives of the concept, the proposed high level conceptual PSBN serving

architecture evolution, and, finally, a summary of the issues resolved by the concept. It did not

directly address or provide insight in the FirstNet’s views on network and business operational

considerations. As Ericsson has for many years managed network operations on behalf of

mobile operators both in the U.S. and globally,our experience has ingrained the principal that

network operations is a critical consideration in the architecture plan and design of any mobile

network as well as what the design delivers for the subscriber end-to-end service experience and

how its integrates into the overall business operations management environment. This principal

is especially paramount with the PSBN that has been defined as a mission critical system, which

12 Happtique is the first mobile application store developed by healthcare professionals for

healthcare professionals. More information about Happtique can be found at http://www.happtique.com/.

http://www.happtique.com/

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is based on a technology (LTE) that is in the first phase of the evolution curve and will, as

applicable, leverage public-private arrangements. With this as background, Ericsson provides

the following comments regarding the current version of the FNN concept.

A. BLENDED NETWORK OPERATIONS

Commercial network operations strategies have evolved significantly in the last decade

incorporating standards and recommendations that have been created by organizations including

(but not limited to) TIA, the TM Forum and ITIL. The PS community, APCO, NPSTC, NENA,

and the Department of Homeland Security (“DHS”), among others, have created network

operations and emergency response requirements and recommendations for use within the Public

Safety and government environments. FirstNet will have to blend these opposite approaches,

their respective orientations, and their diverse systems and processes into a homogenous

operations environment that is supported by the network architecture plan and design.

B. THE OPERATIONS NEXUS

The deployment of new LTE networks globally has been the catalyst not only for evolved

operations standards and recommendations but has driven the development and implementation

of the next generation of Network Operations Centers (NOC), Security Operations Centers

(SOC) and their respective network operations support systems. Other elements that have

changed dramatically are network, device, user and application management and security,

network support, field, and engineering methods and training (learning systems), network

performance, configuration, and inventory management and many other key operations areas.

These functional areas fall within the nexus of Network Operations, Maintenance,

Administration and Provisioning (“NOAM&P”).

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On the business operations side, FirstNet will be faced with the challenges of creating the

ability to provision and care for the change management of devices, subscribers, and

applications, to capture, parse and reconcile usage and billing, to capture and manage revenue, to

enforce and manage roaming agreements, to meet the demands of extraordinary and emergency

events, and many other business operations functions.

In the end, however evolved the NOAM&P and business operations environments may

become, their mission is still the same, to support and ensure the basic goal of provisioning,

connecting, and keeping connected a mobile device, its user, and subscribed services and

applications in a cost-effective and secure manner that achieves the performance goals and

requirements for the network operator’s business and its operations model.

As outlined, Network and Business Operational models are complex, have a strong

influence and impact on the network architecture and in a blended Commercial and Public Safety

operational context requires cross functional recommendations, input and discussion with

FirstNet stakeholders, constituents, suppliers and operators to ensure a holistic and complete set

of operational requirements are integrated into the plan and design of the PSBN.

C. RECOMMENDATION

Ericsson therefore strongly recommends that FirstNet seek comment and guidance on the

blended network and business operations requirements for the PSBN before final decisions and

approvals are rendered on the architecture, topology and serving arrangements.

V. OTHER FIRSTNET CONSIDERATIONS

As outlined in the previous sections of Ericsson’s comments, the development and

delivery of a PSBN, similar to a new operator environment, has a large scope of user and

stakeholder, technology, operations, funding and revenue management, oversight and

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compliance management, and business and enterprise decision criteria that have inter-linking

dependencies with each other. The following discussion offers considerations and solutions to

assist in determination of the impacts of these linkages.

A. PUBLIC/PRIVATE ARRANGEMENTS

FirstNet, as defined in the Act, has public private arrangements as a cornerstone of its

charter. The balance between the public good and goals of the FNN concept and the business

realities of its potential private partners will be one lynchpin of FirstNet’s success. Technology

architectures alone do not provide the entire solution to accelerated implementation. The private

partner challenges that arise under the current FNN concept deserve closer inspection,

investigation, and analysis, as does the execution and management of these tasks and activities.

For example, large scale geographic sourcing in potential private partner areas without balancing

national and local sourcing considerations may potentially have a negative effect on competition

and the aggregate and much needed FirstNet revenue. As discussed later in this section, FirstNet

should broaden its approach to seek further input for this critical foundational element of the Act

prior to determining of what will be the final balanced approach required to successfully deliver

a national interoperable PSBN.

B. FNN PROOF OF CONCEPT

Within the commercial mobile environment, after agreement and publication of standards

and the subsequent research and development has be competed, integrated mobile systems

(network, OSS/NMS, subscriber and device provisioning, billing, usage and performance

management, etc.) such as the one envisioned by the FNN concept are tested in controlled lab or

isolated and segregated environments such as the Public Safety Communication Research

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(PSCR) 700MHz demonstration network at the NIST facilities in Boulder, Colorado or the FCC

certification processes used to certify devices for use in the commercial device ecosystem.

However these isolated environments do not replicate the real world, which is the reason

for employing live user trials. Today there exist within the U.S. several PSBN systems, installed

as part of the earlier PS 700MHz waiver authorizations, that would provide a rapid means for

FirstNet and other government agency groups to conduct live Public Safety and Government

trials of the FNN concepts and agreed to alternatives approaches in a real world environment.

Ericsson strongly urges FirstNet and NTIA to leverage these installed assets to accelerate the

much needed proof of the validity of the FNN concepts and potential alternatives and to

consolidate consensus from its “constituents”.

C. INDUSTRY ADVISORY GROUPS

The Act called for the creation of a standing Public Safety Advisory Committee and

authorized FirstNet to establish additional standing or ad-hoc committees. As outlined in Section

V.A of these comments, there are many inter-dependencies in the planning and decision

processes associated with the implementation of commercial mobile network. The same

functional elements, albeit with variances due to the nature and purpose of the network, exist for

the FNN concept. In private enterprise for major funding and expenditure decisions as with a

large scale public programs such FirstNet, cross functional teams are established to round out the

core project teams abilities. In this case, Ericsson proposes that FirstNet create, similar to the

FCC’s Technical Advisory Board for First Responder Interoperability, one or more advisory

committees to deliver, within a defined period, information focused on, for example, the

following areas: Public Safety Use Case Architecture Assessments, Public/Private Arrangement

Model Assessment, Network and Business Operations Framework, Subscriber and Device

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Fulfillment and Management Framework, Service Delivery Platform Framework, and PSBN

Proof of Concept Validation Plan. Additionally we urge FirstNet to ensure that, per the Act,

after these initial efforts are completed, functional public/private committees are established to

ensure continuity and to leverage expertise in areas critical to the success of this program. A

model such as the earlier FCC National Reliability and Interoperability Council structure with its

annual focus that changed from year to year dependent on the current major focus requirements

could be a means to deliver this environment from a proven framework.

Ericsson, with its membership in many recognized standards and advisory bodies on a

global scale, stands ready to support and assist FirstNet in the creation of a unified and

collaborative public/private advisory approach for development and delivery of the PSBN

enterprise and eco-system.

CONCLUSIONS

As the world’s largest mobile network infrastructure, systems, and network operations

services provider, Ericsson supports FirstNet and Public Safety in all areas of designing,

building, and operating a nationwide PSBN and is available to consult with FirstNet to clarify

and expand upon these comments or for other issues FirstNet may face in the execution of its

responsibilities. We encourage FirstNet to engage and consult with private industry during this

process to fully leverage the commercial industry’s experience. We commend FirstNet for

starting such consultation with this NOI and Ericsson is pleased to provide its comments to the

NOI.

The FNN concept is an excellent start to FirstNet’s responsibility to deliver the PSBN

within the construct of the Spectrum Act. FirstNet faces many unique challenges that call for

blending commercial and PS requirements, while securing consensus across a broad spectrum of

stakeholders. We understand that establishing public/private arrangements to foster partnerships

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that will enable a self-sustaining means of operating the network is a key component of the FNN

concept.

We support FirstNet’s focus on the PS user — in our view any deployment plan has to be

driven by the needs of the users of the network, in this case PS users. Ericsson suggests that

FirstNet assemble and correlate PS user needs and objectively measure the ability of the FNN

concept to deliver these requirements. We note that the FNN concept may face implementation

challenges stemming from the different needs of PS users and commercial network users. These

challenges have to be overcome through deliberate, focused activities detailing architecture

plans, operational models and business models governing the implementation of PSBN and the

relationships between FirstNet, its partners, and its constituents. Ericsson recommends that one

of the focused activities should be to establish real-world proof-of-concept PSBN environments,

leveraging already installed PS LTE assets.

Ericsson is excited about the PSBN prospects and stands ready to support Public Safety

and FirstNet in its important duty.

Respectfully submitted, ERICSSON

/s/ Patrik Ringqvist /s/ Mark Racek Patrik Ringqvist Mark Racek Principal Solutions Manager Director, Spectrum Policy Ericsson Inc Ericsson Inc 6300 Legacy Drive 1634 I Street, N.W., Suite 600 Plano, TX 75024 Washington D.C. 20006-4083

Mark.Racek@Ericsson.com Tel.: +1 202 8240110 Fax: +1 202 7832206

November 9, 2012

I. Introduction and SummaryA. User-Driven Architecture

II. FirstNet Nationwide Network ProposalA. General CommentsB. Multiple Network Diversity ConceptC. Distributed Core Network ConceptD. Terrestrial Mobile Partner ConceptE. Deployable Infrastructure Concept

III. Service Delivery Platform ConsiderationsIV. Network Operations ConsiderationsA. Blended Network OperationsB. The Operations NexusC. Recommendation

V. Other FirstNet ConsiderationsA. Public/Private ArrangementsB. FNN Proof of ConceptC. Industry Advisory Groups