Monday, September 12, 2016

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

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

SEC. 6206. POWERS, DUTIES, AND RESPONSIBILITIES OF THE FIRST RESPONDER NETWORK AUTHORITY. (B) promote competition in the equipment market, including devices for public safety communications, by requiring that equipment for use on the network be — (i) built to open, non-proprietary, commercially available standards;

The real question is – acting as a sales person of a product line – how do I get my proprietary, non-standard, solution into the overall deal? It’s simple actually, you just mask its involvement as part of your “private” side of the Public Private Partnership you are promoting. Through the “private” side of the deal, I would introduce my product as a means for commercial assurance to guarantee spectrum to private entities, thus isolating the Public Safety spectrum. The problem though is that you are still introducing a “proprietary solution” to the spectrum allocation to the State, which is the basis for the law. In short, there is no way around implementing a proprietary solution to the Public Safety Broadband Network without breaking the law. There is a reason that the law states “built to open, non-proprietary, commercially available standards” and that reason is quite simple – the spectrum belongs to First Responders.

If we split the spectrum at its core, all we are doing is taking spectrum away from Public Safety and giving slices of it to others– thus the carriers creating the nine-tenths of the law scenario (let alone security issues). Plus, who wants to be the first in the Nation to deploy a proprietary spectrum solution? What happens if this proprietary solution is not well accepted by others? What happens if it technically fails? Who will be responsible for developing a new architecture to account for those technical issues? Who is going to have to pay the adjoining States that need to interface with a proprietary solution? Who will account for the losses if the overall business model fails? Who in the end will be held responsible? Maybe this is why the law was written the way it was written? The law was written to protect this allocation of spectrum to Public Safety.

A few years back there was a far less complex solution to using the underutilized bandwidth within a packetized network. The BoD (bandwidth on demand) solution became a proven method of delivering broadband to end users, but the offering never really caught on. Why you ask? Well because everyone can get their own fiber and their own transport network without the hassles of worrying about if they will have bandwidth available that day.  Plus, the traditional commercial networks of yesteryear were born on the TDM based solutions. The Time Division Multiplex solution was designed to carry 32-bit based traffic customized for voice. With the introduction of packetized networks, the TDM framework was not properly adjusted for the larger 64-1400-bit packet solutions. Plus, the TDM solution uses 30% of its 32-bit frame for call control protocols, thus was ill suited for the packetized requirements. In layman’s terms, the carriers used a network that was designed for voice and the internet needed packet networks. Then came the FDM solution.

In actuality the first DARPA and SUN (Stanford University Network) UNIX based networks were based on FDM, but when the commercial voice service came along they forced their standards onto the Internet, thus forced the architecture of TDM onto the market. Why? Because there was still more money to be made in voice services back then. The fact is 15 years ago BoD was a great idea for those small to mid-size players to which access to broadband is a steep cost to carve out – we’re talking small level bandwidth solutions – but reality of access service costs today is minimalistic and has no real bearing on the outcome, thus the demise of the Bandwidth-on-Demand using TDM frameworks. Ultimately it was a ploy to utilize the lost overheads in the TDM network to improve profit margins. When it came to spectrum, and still holds true today, the larger wireless players all paid for their own spectrum rights, so why would they need the split the RF signals on their platforms, thus the demise of any needed RF spectrum-on-demand solution-- Arbitrage? What we face today is a repackaged gift of 15 years ago that is being peddled to the Public Safety market as a must have to save their priority status when using their own spectrum. It’s like getting a gift for Christmas from 15 years ago from Aunt Bev and then repacking it for Uncle Tom for this Christmas.  

With the amount of “conceptually’ unlimited bandwidth in fiber, and the amount of spectrum allocated for FirstNet, any other method of spectrum usage just introduces unnecessary complexities that can be unmanageable for a large network – such as a statewide or national deployment of broadband. Public Safety should be using its spectrum like a traditional carrier uses its spectrum – they use it all for themselves. Any secondary users of the network will be prioritized and isolated to packet based network architectures. The only real customers you will find in the spectrum market will be large carrier type organizations, who undoubtedly already have their own spectrum rights and just want to add more to their holdings. There is way more money to be made in controlling the entire band of spectrum for Public Safety itself and selling its available packet solutions to second or third parties, thus funding First and Secondary Responders for the foreseeable future. One sure way for Public Safety to lose their spectrum rights, would be to introduce private commercial operations that has way more intrinsic desire to expand profit services to its user base, thus forcing the Public Safety out of the picture in the long-run. The question will be asked later on, who has more need, and who supports more Americans? Following that question is when the politicians will take over.

One final thought; splitting the spectrum and allocating it to third parties, presents a major security problem and will require a large amount of funding to secure its foundation. Who is going to pay for the added requirement of securing an already overly complex cyber security mandate? How to isolate spectrum intrusion when you have all your commercial and private users on the same spectrum? What if the adjoining State doesn’t want to split up its spectrum under such a solution, how do we justify the secure connection between the two?

But what do I know I’m….

Just some guy and a blog…..

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