Guest Editorial: Intra-Operable Networks, T-Mobile Ex Parte Filing

Published: 4/03/2020
Author: Andrew Seybold, CEO, Principal Analyst, Andrew Seybold, Inc.

The Public Safety community came together from 2009 until 2012 to convince Congress to allocate broadband spectrum for a nationwide public safety broadband network to solve existing interoperability issues and to provide access to data, and video services. The Public Safety Community reviewed a number of options for a public/private partnership and decided that a single, nationwide network was the best way to build out the network. Congress agreed. Now that FirstNet is a success, and more agencies are signing up every week, commercial broadband networks now want a piece of the public safety business. This column is about one T-Mobile, a network which fought public safety and wanted the spectrum auctioned but now wants to be part of the very network they fought against.

Regular Public Safety Advocate followers are probably familiar with an expression I picked up years ago that remains true today: “Paper does not refuse ink.” It is also true that when the ink hits the paper and the finished product is littered with so-called “facts,” fact-checking the document will reveal any distortions intended to convince others that the conclusions of the document are accurate. I recently saw a copy of a T-Mobile Ex Parte filing with the Federal Communications Commission (FCC) dated March 19, 2020, which is a perfect example of such a document.

T-Mobile sent this filing to the FCC in an effort to continue to stir things up and push for a ruling from the FCC regarding PS docket No 19-254, Petition filed by the Boulder Regional Emergency Telephone Service Authority (BRETSA). T-Mobile documented the results of a meeting with FCC personnel for the stated purpose of asking the FCC for a declaratory rule stating that interoperability between broadband networks is a fundamental responsibility of the First-Responder Network Authority. Its point was to ask the FCC to require that FirstNet enter into bilateral roaming agreement(s) with commercial carriers regardless of an agency’s primary carrier.

I was present and participated in many of the events and statements that have been twisted in this document. Starting in 2009, I was part of the Public Safety Alliance (PSA) and then became a communications advisor to both the National Sheriffs Association (NSA) and the International Association of Chiefs of Police (IACP). In 2010, I was appointed a member of the FCC’s Public Safety Advisory Council (PSAC) by the NSA. I attended all FCC PSAC meetings and I can attest to the fact that not once during these meetings or preparation of the final report did this organization ever discuss multiple broadband networks, it was always one network. During the time I worked with the PSA and Congress on what the bill would include, I prepared many dozens of filings with the FCC refuting filings submitted by T-Mobile, Sprint, and others including some of the FCC’s own staff.

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