What’s in a name? For FirstNet, “public-safety entity” definition is critical to system planning, business model

Police, fire and EMS equals “public safety”—that’s the formula that was followed for years. Since the tragic events of 9/11, the U.S. Department of Homeland Security has adopted a more expansive definition of public safety that includes critical-infrastructure entities such as government, utility, healthcare and transportation entities.

Today, FirstNet is preparing to deploy an unprecedented nationwide broadband system for public safety, and it has initiated a proceeding to ask, “What is a public-safety entity?” On the surface, it might sound like an almost trivial inquiry. In reality, the answer may not be as straightforward as some initially might think, and the final determination promises to have significant ramifications on FirstNet’s network design and self-sustaining funding plans.

In this proceeding, FirstNet’s staff seeks comments on its admittedly “broad” legal interpretations of the law that Congress passed in 2012 to create FirstNet. It should be noted that the FirstNet board has not taken a position on any of these legal interpretations, including the notion of what constitutes a public-safety entity. Board members are expected to make decisions regarding these legal questions after reviewing the comments from the proceeding, so they can be used in the development of a draft request for proposal (RFP) early next year.

Mind you, this proceeding does not really address prioritization and preemption questions, except to provide a very general framework on the notion of which entities can be considered for priority use and which ones are relegated solely to secondary use. However, the operational realities of which entities—or, more likely, which individual personnel—gets bandwidth priority at a given time is a matter that promises to be the source of very lengthy and spirited debates in the future.

There is no question that law enforcement, fire and EMS qualify as public-safety entities that can receive priority access on the FirstNet system. In addition, there is a growing consensus that critical-infrastructure players such as governments, utilities, transportation organizations and healthcare facilities should be considered public-safety entities in certain circumstances.

For those who still have doubts about the importance of the critical-infrastructure groups, consider the following public-safety scenarios:

• Governments—When bad things happen, the response can dictate that additional resources are needed that cost money, which requires approval from a government administrator and/or an elected official. In addition, if a situation arises that requires assistance from the National Guard, that aid can only happen through a request from local officials to the governor of a state; no incident commander has the power to make that happen individually.
• Utilities—If a power line goes down and blocks a road, traditional public safety may not be able to access a given incident until the power-line issue is resolved. More important, any response effort is complicated exponentially if the commercial power grid is not working or if the water supply is contaminated in some way.
• Transportation—An important part of many first-response scenarios, from rerouting traffic to enabling the evacuation of a geographic region.
• Healthcare facilities—Ensuring good communication with hospitals and other healthcare providers is key when an incident results in numerous injuries. All the best efforts of EMS personnel in the field can go for naught if the patient is transported to a hospital that is at capacity or does not have the facilities to treat the injury. Moreover, higher levels of remote patient care and triage in the field—guided by doctors at a hospital—is technically possible, but it requires the kind of prioritized bandwidth that FirstNet promises.