P25 as a Service Addresses Governance Issues

A study of governance policies and practices can be instructive in identifying issues that negatively impact the adoption of hosted public safety LMR offerings. It is important to acknowledge that the following examples are illustrative of how various governance policies affect user agencies’ willingness to join a shared LMR network; it is not intended to evaluate technology or any other aspects of the offering. 

1.       A governance deficiency which frequently deters agencies from joining a hosted LMR service is the lack of financial risk management and mitigation.  For example, many governance models do not provide a safety net to protect its user agencies against budget shortfalls.  If a budget shortfall occurs, user agencies frequently find themselves making large, lump-sum capital outlays to vendors to ensure continuity of operations for the network or face the possibility of a network shutdown. 

This situation is epitomized with the Mississippi Wireless Communication Commission (WCC), which recently announced that it needs $14 million to sustain its state-wide Mississippi Wireless Information Network, or the network will have to be shut down by February 2015. According to a key official with the WCC, the agency is looking to the state legislature to provide the funding to continue network operations, as user fees have proven to be too problematic in the past.

Alternatively, the user fees associated with a P25 as a Service offering from a telecommunications carrier will be calculated to cover ongoing network maintenance, upgrades, and other operational requirements.  And, because the management and operation of mission-critical networks are part of their federal-government business, carriers have the resources and experience needed to accurately estimate these costs. As with other service offerings from carriers—for example, wireline, 3G/4G/LTE wireless and data-communications services—the ongoing maintenance and enhancement of the network is not the responsibility of client agencies.

2.       Another weakness with existing governance policies is monitoring and maintaining accountability and compliance to system operations best-practices and technical-maintenance procedures. On July 5, 2013, the Michigan Public Safety Communications System (MPSCS) failed and was out of service for almost 15 hours. Detroit Police Chief James Craig indicated that the MPSCS services lacked accountability and periodic testing. Gary Brown, chief compliancy officer for the city of Detroit, said that the above failure was not the first time the MPSCS tower has failed. It was further acknowledged by others that the system has had recurring problems. 

Carrier-provided P25 as a Service includes performance guarantees and public-safety-grade service level agreements (SLA). Carriers perform testing and pre-emptive maintenance as an ordinary course of business, and there is a single point of responsibility—the carrier. As a result, there isn’t any question about who is accountable, and the process for assessing compliance is transparent. For agency clients, this provides a significant level of confidence that accountability and escalation is unambiguous.

3.       Finally, some governance models have policies that obligate users to share the costs associated with vendor-controlled technology refreshes. These costs can be significant and require capital procurements to keep the system viable and operational. Municipalities and counties are therefore required to seek the approval of city councils or county commissioners to pay the large capital expenditures needed to sustain the system. Central to this issue is the determination of a fair and equitable way for all user agencies to contribute to the ongoing cost of upgrades and replacements created by a continuous stream of end-of-life (EOL) notices.

With a per-device subscription fee, the P25 as a Service model inherently provides a fair and equitable allocation of upgrade costs based on network usage. There is no need for complicated cost allocation algorithms or lump-sum capital assessments, as client agencies pay for what they use based on the number of devices that are registered to the LMR network.