The District of Columbia (D.C.) this week released its request for proposals (RFP) in an effort to solicit bids from vendors willing to build and maintain the alternative radio access network (RAN) in D.C., if the mayor decides to have the district pursue the “opt-out” alternative to FirstNet.

D.C. officials issued the RFP on Monday, with bids due on Nov. 27. D.C. is the 15^th state or territory to issue an RFP without having the governor announce an “opt-in/opt-out” decision. As with all RFPs to date, the D.C. procurement would result in a contract only if the district managed to secure all of the “opt-out” approvals from the FCC and the National Telecommunications and Information Administration (NTIA), as well as a spectrum-lease agreement with FirstNet.

Under the law that established FirstNet, governors in all 56 states and territories have the choice of making an “opt-in” decision—accepting the FirstNet deployment plan and allowing AT&T to build the LTE radio access network (RAN) within the state’s borders at no cost to the state—or pursuing the “opt-out” alternative, which would require the state to be responsible for building and maintaining the RAN for the next 25 years.

With an extremely dense population and a relatively geographic footprint, D.C. has long been considered the most logical entity to pursue the “opt-out” alternative from a purely economic standpoint of being able to generate enough revenue from the commercial sale of excess capacity on the network. In fact, D.C. was the only entity cited by name in FirstNet’s legal interpretations that were used to establish “opt-out” policies.

However, other industry sources have noted the fees that D.C. may have to pay in an “opt-out” scenario—for access to spectrum, the FirstNet LTE core and opt-out termination penalties, if the “opt-out” effort fails—could be substantial. In addition, some have noted that it could be politically difficult for D.C. to pursue the “opt-out” alternative, if all of its much larger surrounding states choose the “opt-in” route. Governors in both Virginia and Maryland—the two states adjacent to Washington, D.C.—have announced their “opt-in” decisions.

The D.C. RFP calls for potential vendors to submit bids that “financially self-sustaining” and are designed to provide 100% coverage with 99.99% network availability. The deployment would be scheduled for completion within two years of D.C. awarding a contract, if that happens.

In addition, the RFP specifies that contractor winning the award would be responsible for paying the fees to access the FirstNet LTE core and the 700 MHz Band 14 spectrum licensed to FirstNet. The contractor also would have pay any financial penalties associated with failing to meet targets for public-safety adoption of the network and any opt-out termination fee, if applicable.

FirstNet released its initial state plans on June 19 and made them actionable, so governors would have the opportunity to “opt-in” to FirstNet prior to the final state plans being released on Sept. 29. Governors in 53 states and territories that received initial state plans on June 19—the exceptions being the Pacific territories of Guam, American Samoa and the Northern Mariana Island, which will have a separate timetable—are required to make their “opt-in/opt-out” decisions by Dec. 28.

Thus far, 25 states—Virginia, Wyoming, Arkansas, Kentucky, Iowa, New Jersey, West Virginia, New Mexico, Michigan, Maine, Montana, Arizona, Kansas, Nevada, Hawaii, Alaska, Tennessee, Nebraska, Maryland, Idaho, Texas, Louisiana, Minnesota, Alabama and Indiana—have announced their “opt-in” decisions, as did the U.S. Virgin Islands and Puerto Rico territories.

Meanwhile, 14 states have joined D.C. in issuing an RFP without having their governors announce an “opt-in/opt-out” decision to date: Colorado, Georgia, Massachusetts, Mississippi, Missouri, New Hampshire, North Carolina, Oklahoma, Oregon, Pennsylvania, Rhode Island, Vermont, Washington and Wisconsin. Of these states, New Hampshire is only state to announce the winner of its procurement—Rivada Networks.