On September 11, 2019, the Public Safety and Homeland Security Bureau (“PSHSB”) released a Public Notice (“Notice”) seeking comment on Petitions for Declaratory Ruling and Rulemaking (“Petitions”) filed by the Boulder Regional Emergency Telephone Service Authority (“BRETSA”) on November 21, 2018, concerning FirstNet interoperability issues (PS Docket No. 19-254).

Background: On July 6, 2018, the Colorado Public Safety Broadband Governing Body (“CPSBGB”) filed a Request for Clarification regarding FirstNet interoperability responsibilities. The PSHSB dismissed this request without prejudice finding that such a request was premature because there was no controversy or uncertainty that warranted Commission action. BRETSA filed a Petition for Reconsideration along with the above-referenced Petitions, arguing that the PSHSB should grant CPSBGB’s requests. The PSHSB dismissed the Petition for Reconsideration as untimely, finding that events underlying the request were unfolding in a way that would resolve the interoperability concerns so the request was not ripe for review and therefore untimely.

Requests Under Review: PSHSB is seeking comment on BRETSA’s other requests that seek clarification surrounding FirstNet interoperability – specifically, its request for a declaratory ruling to ensure that “interoperability is a fundamental responsibility of FirstNet and that FirstNet is supported at all levels including network, services, applications, and devices.” BRETSA also requests the Commission issue a notice of proposed rulemaking or notice of inquiry to address roaming and prioritization for applications such as push-to-talk and mission-critical push-to-talk. Additionally, BRETSA requests the Commission also address the following issues:

  • The responsibility of providers other than FirstNet (providers of public safety land mobile radio (LMR) systems or services and public safety priority services offered over Commercial Mobile Radio Service (CMRS) networks) to assist FirstNet with the development of interoperability solutions and to provide full interoperability with FirstNet, LMR and other CMRS public safety services (subject only to technological limitations);
  • Roaming and prioritization applicable to LMR and other CMRS public safety priority services; and
  • Available FCC dispute resolution processes and standards concerning matters of interoperability, roaming, and prioritization.

PSHSB is seeking comment on all of the above and any other issues raised by the BRETSA Petitions.

Comments are due September 26, 2019.

Reply comments are due October 11, 2019.

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