Development of the Nationwide Interoperable Public Safety Broadband Network Notice of Inquiry. Comments from ClearSky Technologies, Inc.

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1 Department of Commerce National Telecommunications and Information Administration Docket No: Development of the Nationwide Interoperable Public Safety Broadband Network Notice of Inquiry Comments from ClearSky Technologies, Inc. November 8, 2012 ClearSky Technologies, Inc. 390 North Orange Avenue, Suite 1350 Orlando, FL November 8,

Notice of Inquiry Comments from ClearSky Technologies, Inc.

2 Introduction First, an acknowledgement to the leadership and staff at NTIA for the years of effort it took to launch FirstNet. Also, congratulations to the FirstNet Board for stepping up to one of the most ambitious wireless network build out efforts in history. It is truly a project of epic proportions that can create tremendous good for first responders in particular and the country as a whole. These comments regarding the Notice of Inquiry are provided by Dean Fresonke, Senior Vice President of Business Development at ClearSky Technologies. In this document we will focus on the rural U.S. markets and the unique issues and opportunities these regions bring to the FirstNet Nationwide Network (FNN). Addressing the Needs of the Rural Wireless Operators As a company solely dedicated to providing services to rural wireless carriers, we were greatly encouraged by the dialog during the FirstNet Board meeting on September 25 th, 2012, acknowledging the need to include all rural markets in FNN. Mr. Farrill s statement that two simultaneous tracks are required, one addressing urban market issues and one addressing rural market issues and that both are equally important is, in our opinion, exactly correct. The needs between urban and rural markets are radically different. Mr. Bryan suggested that the rural markets represent somewhere around 80% of the coverage requirement and have only 20% of the population. Mr. Farrill cited that potentially 59,000 of first responder agencies are in rural markets out of 60,000 total. Data from the wireless industry reinforces this same message. Consider there are approximately 320 million wireless subscriber connections in the U.S. (1.01 for every citizen) and approximately 100 mobile network operators. The 10 largest carriers have an estimated 310 million of these subscribers, leaving less than 10 million subscribers spread across 90 operators. While some of the large operators November 8,

It is truly a project of epic proportions that can create tremendous good for first responders in particular and the country as a whole.

3 overlap coverage, these small operators are licensed to provide tremendous geographic fill covering over 1/3 of the U.S. geography. In other words, this is a group of operators with less than 4% of total subscribers covering a third of the country. The LTE coverage map published originally by FierceWireless from Mosaik Solutions shown here makes this point in stark color. Vast areas are not currently covered by LTE and many of these areas are not on the build out roadmaps of the large carriers. Rural operators will be essential to create the desired coverage a reality. However, because of low population densities, rural operators are driven by economics and business models quite different from the Big 10 carriers. About ClearSky Technologies, Inc. The team at ClearSky Techologies understands these challenges intimately. For over 12 years we have been providing hosted infrastructure to the rural wireless carrier community in an ongoing effort to keep them technically on par with the larger operators using the economic leverage of shared infrastructure. We are thankful to count 75 of the rural operators as customers. With this background, we would like to comment on the FNN architectural model from the perspective of the rural market. We will suggest some additional concepts that will help FirstNet achieve its vision ubiquitous coverage - by helping the rural operators achieve theirs a commercially viable LTE service. November 8,

The LTE coverage map published originally by FierceWireless from Mosaik Solutions shown here makes this point in stark color.

4 The Role of LTE Infrastructure as a Service (LTE IaaS) Providers In the presentation on Slide 5, public safety, wireless operators, network suppliers, handset suppliers and application developers are cited as the members of the FNN ecosystem. We suggest that an important, separate category of companies will be essential, namely LTE Infrastructure as a Service (LTE IaaS) providers. As part of our LTE IaaS business, we offer operators various options to build and operate LTE networks by providing centrally hosted LTE components such as the Evolved Packet Core (EPC). The conceptual FNN network Mr. Farrill presented on Slide 18 is very similar to what we re already providing, albeit for consumer use. There is a small but competent group of IaaS companies serving the rural markets. ClearSky and other LTE IaaS organizations can work together to enable many aspects of FNN in the rural markets. FirstNet can leverage this considerable expertise by including IaaS providers in your planning efforts. We propose to make ourselves available to work on overall architecture and assist in planning to include the capabilities of the LTE IaaS community. Augment the Distributed EPC Architecture with Private Roaming Hubs The FNN slides suggest a distributed set of EPCs, operated by or on behalf of FirstNet, as the top layer of the architecture. Radio Access Networks (RANs) from various operators would then employ Multiple Operator Core Network (MOCN) configurations to enable the same radio base stations to connect to both the FirstNet EPCs and the private EPC of the wireless carrier. This is an excellent design approach, making use of the existing capabilities of LTE equipment and addressing the needs of both first responder and consumer users. However, several real-world situations require augmenting this strategy. The remoteness of rural markets, cost of backhaul, and local carrier network configurations can make it more viable and reliable to use the rural carrier s EPC for the November 8,

As part of our LTE IaaS business, we offer operators various options to build and operate LTE networks by providing centrally hosted LTE components such as the Evolved Packet Core (EPC).

5 FNN traffic. If all FNN traffic in a rural market had to be backhauled to FNN EPC s in urban clusters, rural markets could lose connectivity and thus access to their own networks should a disaster occur somewhere between the two locations that severe communications. Also, should a state opt-out of the FirstNet build out, their separate networks will need to interconnect with the FirstNet core. So instead of relying on centralized EPCs with MOCN-enabled towers connected to them, FirstNet should also consider a private IPX and Diameter signaling network where participating carriers EPCs can connect to the nationwide infrastructure. In the vernacular of LTE, this would be a private version of an IPX network, carrying both the user plane data back to FirstNet s PDN Gateway and the Diameter signaling traffic between the rural network EPC and the FirstNet EPCs. If a state opts out of FNN and decides to build their own network, the FNN IPX network creates the necessary national interconnect. Our vision of the private IPX and Diameter signaling network is virtually identical to work submitted by the Interconnectivity Infrastructure Group (IIG) within the Public Safety Spectrum Trust Operator Advisory Committee (PSST-OAC) in their V19 document submitted March 9, The IIG offered valuable insight not only to both the architecture and interconnection strategy but also resolved industry terminology issues that are unique to the FNN concept. We propose ClearSky assist in defining how an FNN IPX network would be designed, leveraging our experience in designing similar IPX/Diameter signaling architectures for connecting clusters of rural carriers. Shared RAN Offers Opportunities but Requires Incentives In rural markets, maximizing coverage per capital dollar spent almost always equates to building a three sector macro base station. A current generation LTE base station has a small base band unit at the base of the tower connected to three remote radio units (RRUs) that generate the RF energy to November 8,

between the two locations that severe communications. Also, should a state opt-out of the FirstNet build out, their separate networks will need to interconnect with the FirstNet core.

6 transmit and contain the receive circuitry to listen. Carriers will purchase the RRUs specifically for the licensed frequencies they have in their coverage area. With the exception of Verizon s Band 13, FNN s Band 14 is separated enough in frequency that most manufacturers will require a dedicated set of 3 remote radio heads to be mounted on the tower, along with the appropriate antennas to operate in Band 14. The RRUs are the most costly component of a base station. In a simplistic example of $60,000 worth of base station gear, the RRUs and antennas could represent over $50,000. That means $10,000 is reusable and an additional $50,000 needs to be invested to support Band 14. Obviously this is just the upfront capital. Ongoing expense is increased too. Tower owners will want additional rent for the Band 14 RRUs and antennas. Additional backhaul capacity to the tower sites will add cost every month. Rural carriers will need motivation to make this type of investment. Part of that motivation could come from use of Band 14 spectrum to deploy consumer services to their regular subscribers. The low density of first responders in rural markets makes this very viable. With the ongoing technical work to assure that first responders preempt consumer traffic and have assured prioritization, Band 14 can safely carry considerable commercial traffic. Providing rural operators the use of Band 14 could be an important part of the incentive program that will be necessary to get rural operators to start their LTE build outs and support the additional cost of Band 14 equipment. Vital to this strategy is the necessity for carriers to have access to attractive phones and data devices that use Band 14. FirstNet will need to consciously and proactively drive the development of the device ecosystem, taking into consideration not just hardened devices for the first responder tool belt but also devices attractive to the consumer market so the rural operators can sell into their subscriber base and make use of the Band 14 capacity. November 8,

with the appropriate antennas to operate in Band 14. The RRUs are the most costly component of a base station.

7 We propose to help coordinate efforts of FirstNet in this area of defining incentive programs, especially with the help of key non-profit industry groups representing the rural operators such as the Competitive Carriers Association ( November 8,

non-profit industry groups representing the rural operators such as

First Responders Network Authority Presentation to the Board

First Responders Network Authority Presentation to the Board Nationwide Network (FNN) Proposal F. Craig Farrill September 25, 2012 1 Agenda Introduction Roles and Responsibilities Nationwide Network (FNN)