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County of Fairfax, Virginia

Response to National Telecommunications and Information Administration, U.S. Department of Commerce

Notice of Inquiry - Docket No: 120928505-2505-01

November 9, 2012

Confidential - not for distribution outside Fairfax government entities without written permission

County of Fairfax, Virginia response to National Telecommunications and Information

Administration, U.S. Department of Commerce’s Notice of Inquiry Docket No: 120928505-2505-01

November 9, 2012

Confidential - not for distribution outside Fairfax County government entities without written permission

1. Introduction ......................................................................................... 3

2. Fairfax County Comments .................................................................. 4

3. Conclusion ........................................................................................... 6

4. Attachment A ....................................................................................... 6



November 9, 2012


1. Introduction

Fairfax County is the largest jurisdiction by population in the Commonwealth of Virginia, with

1,037,605 citizens living within its 407 square miles. Public safety services are provided by 7

local law enforcement agencies, the Fairfax County Fire Department and numerous state and

federal agencies. Interoperable communications in this region are both challenging and critical,

but with the creation of the National Capital Region with 19 other local jurisdictions,

interoperability has become reality.

With the allocation of the D-Block frequencies to Public Safety, and the creation of the FirstNet

Board, both mandated by recent legislation, there is now the opportunity to provide first

responders with a secure, reliable, nationwide interoperable, public safety grade broadband

wireless network.

The County has identified public safety interoperable broadband services as a priority and on

June 28, 2010 filed a waiver to continue efforts to deploy a network as quickly as possible in the

700 MHz public safety broadband spectrum. In March 2012, the County also applied for a

Special Temporary Authority (STA) to deploy a pilot 700 MHz Public Safety network. In

September 2012, Fairfax County initiated collaboration with the State of Virginia to develop a

State coordinated local-build approach. We intend to submit a Special Temporary Authority

(STA) for deployment of the nationwide network which will include network design,

Governance agreements, and investment criteria. The network will conform to all requirements

established by FirstNet and the FCC and will be integrated into the nationwide public safety

broadband network.

Fairfax County, Virginia is pleased to provide the following comments to the National

Telecommunications and Information Administration (NTIA), U.S. Department of Commerce

Notice of Inquiry (NOI) on the Development of the Nationwide Interoperable Public Safety

Broadband Network. We appreciate the opportunity to work in strong partnership with the

FirstNet Board, Federal Communications Commissions (FCC), NTIA our State and partner

jurisdictions to implement the best possible network for our nation’s first responders.



November 9, 2012


2. Fairfax County Comments

Network Architecture

The County of Fairfax, Virginia is committed to serving its first responders with the belief that it

is a necessity to establish the nationwide public safety network. Fairfax is in concurrence that the

FirstNet Board should not engage in the model of building a stand-alone network, but create a

diverse and dynamic nationwide network. The State and local jurisdictions have invested

significant resources, formed crucial alliances and partnerships, and invested in infrastructure

and equipment, all of which should be leveraged in standing up the nationwide network.

Leveraging all partnerships, infrastructure, resources, etc. of the State and local jurisdictions will

provide for the greatest possibility for success of the common goals of achieving reliable,

redundant ubiquitous coverage, while maintaining complete interoperability at the most efficient

cost.

Fairfax County is in support of the distributed core network approach, including a hardened

system of evolved packet core networks and service delivery platform that are dispersed in

highly secure locales throughout the nation. Fairfax is also in support of the concept of devices

supporting Band Class 14 with commercial roaming capability and redundancy to their 3G and

2G systems.

The current Radio Access Network (RAN) build out described on slides 17-19 of the Network

Architecture presentation during the initial FirstNet Board meeting needs more clarification. It

implies that FirstNet will partner with multiple mobile operators in a given geographic area, with

each building out RAN 14. If this is the vision of the FirstNet Board, it would potentially result

in substantially higher RAN costs and create RF interference issues as well. If the FirstNet Board

decides that the addition of a satellite component is a work around, Fairfax County believes that

this approach will be cost prohibitive and impose an undue burden on State and local

municipalities. More clarification is needed if that is the intent of the FirstNet Board.

Additionally, if the FirstNet Board envisions full 700 MHz band devices, is there a strategy to

address the limits in the number of frequencies that can be present in a single device?

Additionally, will there be further clarification on how it will address an approach that will limit

the redundancy over a single commercial network by eliminating roaming to 3G and 2G

services?

More clarification is needed on the question of a state or region having the ability to represent

one of the core clouds on the conceptual charts under an opt-in scenario. The county believes

that leveraging, and even encouraging a state and local led build-out “opt-in” option will yield a

higher number of state and local adoption / opt-in participants.



November 9, 2012


The FirstNet board would benefit exponentially by allowing State led STA jurisdictions to build

out their networks early. These early deployments provide tangible, actionable data that can be

leveraged to develop Governance, data sharing strategies, policies, requirements,

interoperability, and roaming.

Fairfax County supports a nationwide Governance model that allows for the ability to

dynamically control resources of the network at the State/Local level, as well as allow

State/Local input into the Nationwide Governance model. This requirement is vital to the success

of the nationwide network and is essential to next generation incident management.

Early deployments must be completed in a way that ensures interoperability with FirstNet,

emphasizing the need for local control and governance, while having a flexible architecture to

support multiple configurations. Our belief is that the aforementioned Opt-In option should

allow States to own/operate an evolved packet Core within the State, but as a part of a virtual

FirstNet Core Architecture. This would allow the State/Local jurisdictions to maintain the day to

day operations and governance of the network while maintaining nationwide interoperability.

We believe that this is the only way to maximize State/Local adoption. Moreover, this approach

will ultimately enable the States/Locals to contribute financially to the nationwide network.

Development of Public Safety Applications

Fairfax County supports a standardized approach to approving mobile applications for the

nationwide network. We believe this will enable the creative abilities of multiple developers to

submit innovative mobile applications that are subjected to efficient and timely security, and data

sharing testing before network launch. However, the approval process must not result in

innovation stifling regulations and inefficient unnecessary delays.

Fairfax also encourages FirstNet to include NG911 architectural considerations as a part of the

early technical design efforts. Limiting NG911 considerations may result in a fragmented PS

communications network design and create inefficient, costly and mission effecting network use.

Finally, Fairfax read with great interest the iCERT (Industry Council for Emergency Response

Technologies) FirstNet recommendations. This industry based set of recommendations was

balanced and while it considered their collective commercial interests it also placed the

appropriate level of importance on State and Local control as well as the need for early

deployments. We have included the iCERT FirstNet recommendations as a part of our filling in

Attachment A.



November 9, 2012


3. Conclusion

The ability for the Public Safety community to have dependable, reliable, and effective

communications is critical. The distinct need for a private broadband wireless network for

Fairfax County, Virginia and our tri-state area, as well as the entire nation is both essential and

fundamental. The three fundamental drivers that justify the public safety broadband network are:

to improve data throughput, to provide network availability, and to improve network reliability.

Underlying these drivers for a broadband network is that the network must be cost effective so

that it can be shared by critical agencies, first responders, public service, transportation and other

critical infrastructure providers.

The transition to a public safety grade LTE network is both timely and necessary. The primary

goal for Fairfax County is a network that will enable Fairfax County to provide broadband

communications services to over 99 percent of the County’s population, to all critical

infrastructure facilities and to all roads that extend into the remote areas to and from these critical

infrastructure and high population center locations.

In Closing, the County of Fairfax, Virginia appreciates the dedication and diligence that the

FirstNet Board and partner organizations have taken in their approach to the development of the

Nationwide Public Safety Network. The County of Fairfax, Virginia strives to continue to work

with other jurisdictions, the FCC, the NTIA, and the FirstNet Board, to achieve the goal of a

fully interoperable 700 MHz Public Safety Nationwide Network.

4. Attachment A



November 9, 2012


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