Comments on Development of the State and Local Implementation Grant Program

Please accept the attached document as the Nez Perce Tribe’s comments regarding the development of the state and local implementation grant program for the Nationwide Public Safety Broadband Network.

Anjee Toothaker
Nez Perce Tribe
Office of Legal Counsel
(208) 843-7355
X = 3702

Attached please find comments from the National Governors Association in response to the Request for Information regarding the State and Local Implementation Grant Program for the Nationwide Public Safety Broadband Network.

If you have any questions, please contact Heather Hogsett (hhogsett@nga.org, 202-624-5360), Thomas MacLellan (tmaclellan@nga.org, 202-624-5427), or Mike Obrock (mobrock@nga.org, 202-624-5390).

Morgan Wilson
Legislative Coordinator
Office of Federal Relations
National Governors Association
Phone: (202) 624-7822
Fax: (202) 624-5825
mwilson@nga.org

Please find attached Montana’s comments in response to NTIA’s Request (Docket No: 120509050-1050-01) regarding the Nationwide Public Safety Broadband Network.

Thank you.

Sheena Wilson
Deputy Chief of Staff
Office of Governor Brian Schweitzer
P. O. Box 200801
Helena, MT  59620
406-444-5503
406-444-4151 (fax)
swilson@mt.gov

Attached please find the comments of the Statewide Interoperability Coordinators of Delaware, the District of Columbia, Maryland, Pennsylvania, Virginia and West Virginia in response to NTIA's Request for Information published in the Federal Register on May 16, 2012 in Docket No. 120509050-1050-01.  Please accept these comments into the record in this docket.  If there are any questions, please contact Kenneth Boley at the email address and phone number below.

Thanks.
--
Kenneth R. Boley
The Interoperability Group
ken@interopgroup.com
202-746-4600

See attached comments from North East Wisconsin Public Safety Communications (NEWCOM)

--

Andrew Faust, GISP
210 McClellan Street, Suite 210
Wausau, WI 54403
(715) 849-5510 ext. 305
email: afaust@ncwrpc.org
http://www.ncwrpc.org

Gentlemen,

Please find attached Fairfax County, Virginia’s response to the NTIA RFI Docket No: 120509050–1050–01in PDF format.

It is a pleasure working together to achieve the common goal.

With kindest regards,
Steve Brundage

Stephen L. Brundage
Director of Communication Technologies and Regional Initiatives
12000 Government Center Parkway, Suite 361
Fairfax, Virginia 22035
703.324.2398 (w)
703.475.7507 (c)
703.324.4017 (f)
Steve.brundage@fairfaxcounty.gov

To Whom it May Concern:

Attached, please find the response from the Los Angeles Regional Interoperable Communications System (LA-RICS) to the NTIA RFI regarding the State and Local Implementation Grant Program.

Please feel free to contact me if you have any troubles with the file or if you have any questions.

Best regards,
Sara Henry

LA-RICS Project Team
2525 Corporate Place, Suite 200
Monterey Park, CA  91754
Sara.Henry@LA-RICS.org
Office:  (323) 881-8311
Fax:       (323) 264-0718

Please find attached comments of APCO International on the Request for Information issued by the National Telecommunications and Information Administration (NTIA) concerning the development of the state and local implementation grant program for the nationwide public safety broadband network.

Kindly direct any inquiries to the undersigned.

Sincerely,

Jeffrey S. Cohen
Chief Counsel – Law and Policy
Director of Government Relations
APCO International
1426 Prince Street
Alexandria, VA 22314
(571) 312-4400 ext. 7005

Response of RCC Consultants, Inc., to the Request for Information (RIN: 0660-XC001) of the National Telecommunications and Information Administration Respecting the Development of the State and Local Implementation Grant Program for the Nationwide Public Safety Broadband Network, NTIA Docket No: 120509050-1050-01.

Respectfully submitted,
RCC Consultants, Inc.
By: Carl Robert Aron
Founder and Executive Vice President
E-mail: c.aron@att.net and caron@rcc.com
Phone: (509) 536-2966

Michael Scales [MScales@sandovalcountynm.gov]
Thu 6/14/2012 3:38 PM

These comments follow the questions indicated in your request:

Comments to NTIA regarding RIN0660-XC001

Public Safety Broadband Network

Consultation:

1. DATA:

1. Primary concern of the consultant would be the geography needing to be serviced.  What quality of signal would be needed to meet the requirements of the project.  Network availability? local, state, regional, federal infrastructure?  Mix? Network responsibility? local, state, regional, federal? Mix? What Future funding sources will be there?
2. Activity Programs: State and Local programs would depend on the future funding abilities

2. State Government
   1. This may vary with each state.  New Mexico could go with either the SWIC or DoIT CIO
   2. In the State of NM, I would suggest the existing Homeland Security SICWG committee
   3. This would depend on the scope of the grant and the amount funded.  This could be an issue due to lack of funds that should be coordinated at a state level to give the largest coverage with local buy in.
   4. Most tribal agencies in NM are serviced by County or BIA organizations.  Public Safety inclusion is a requirement, but may have some local roadblocks due to jurisdictional boundaries, and local politics
   5. Due to local politics, it may be hard to get the tribal agencies to participate.  In order to be eligible to apply, a pre-requirement could be put in place indicating that there must be signed verifications and/or waivers, by all agencies in the designated area, proving they were participants in the planning process or that they waived their participation in the planning process.    
   6. As the NM Department of Homeland Security and Emergency Management (NMDHSEM) have access to all these disciplines, they would be the focal point for dissemination of information.
   7. The definition for REGIONAL should be standard nationally.  In several grants, the term has been so loosely defined that it is convoluted.  More points may be rewarded to an entity based on the number of participating agencies.
   8. This again could be coordinated by the NM DHSEM
3. State input
   1. A portion of the funding should be designated for this collaboration.
   2. A majority of the standards and processes should be standardized, however as we all realize, each jurisdiction is different in their operations and methods.  If it meets the needs of the project – the standard should be loose enough to allow minor variance.
   3. That would depend on the content required by FirstNet
4. Existing Authorities
   1. Coordination with DoIT on the implementation of broadband services.  In NM, this is an enterprise operation.
   2. DoIT has obtained a grant for a pilot project.  NMDHSEM SICWG is monitoring the implementation.
   3. With minimal changes in authority, the existing committees will work
   4. That would be determined by the coverage
   5. Again would be determined by the coverage
   6. Yes
   7. Yes

5. Leverage Infrastructure
   1. A complete review of existing systems and the scalability of the systems for future use
   2. In NM, limited staff are available for this service
   3. Notify the NGO’s and if they are interested, work with SICWG
   4. This could create an issue for the security of the network.  With the sensitive nature of the public safety groups, oversight of the private sector would be a major concern.
6. RFP
   1. Depending on the need for local purchasing, would determine the need for integration
   2. Depending on the purchasing process, some states may suggest local purchases to expedite the service
   3. If eligible, yes
7. SHSGP programs from DHS have a peer review that ensures oversight and goal achievement.  This would be a suggestion that would aid the transparency of the process.
8. Again depending on the Federal model and the determination of responsibility of the state/local groups would determine the allowable expenses.
9.  All of the items listed in the question as well as travel and per diem for the meetings and assessments
   1. Yes, as this information may support the overall project
   2. New positions should only be created/approved if it is determined:
      1. Is this a short or long term position
      2. Once the grant period is over, will there be other funding to support this position
10. Would depend on the Coverage goal
11. In several states, these practices exist.  The consultant should incorporate as many of these standards prior to the construction as possible.
12. SBI Grant
    1. Yes
    2. Coverage goal dependant
13. Outcomes
    1. Yes
    2. Predetermined Metrics
    3. State Project Manager
    4. Existing network and coverage vs post project network and coverage
14. These tools are nice, but need to have better user interface and instruction to gather the information required for the project
15. Grant distribution - NMDHSEM
    1. Depends on goals of project
    2. Centrallized purchaseing (mass purchase with local delivery, would bring cost down)
    3. Yes
16. CIO/CTO are very important in the network design, security and maintenance if it is a local requirement
17. In today’s economy you will find it hard for any local agency to find matching funds for this project.
18. The need for the public safety agencies to exchange information
19. This request for information is not detailed enough on the goals of the project to fully determine proper answers for this questionnaire.  Additional information on the project and requests for specific information will be forthcoming during the consultant primary interviews.  The total funding for this project will not be adequate to ensure above a 50% coverage of the populated areas of the United States.

Documentation for this request identifies several key issues:

1. NTIA and FirstNet are authorized to take all actions for design, construction and operation of this project.
   1. What is the coverage % goal?  Population or property?
   2. Who will be the oversight, or quality assurance group to monitor compliance?

The concept of allowing transmission of data to mobile units in the field is a daunting effort that will be hindered by the expense of the infrastructure and connectivity.  Due to the geography of the local area, the need for additional tower facilities will be great.   The network issue between the sites will also be an area of interest to ensure that interference and security issues are identified and dealt with appropriately. These expenses are not only for the design and construction, but for the operation and maintenance of the system(s).  Concerns on future funding of the operation have always been primary as most grants will provide for the initial design and construction, but not for the continued operation.  Local agencies may or may not have the ability to properly fund an enterprise operation of the communications system.  Presently in the State of New Mexico, if you are near an Interstate or US highway, chances are that you will have network infrastructure available – but what about the remote areas?  The build out cost for that alone nationally is astronomical.  Because this is a “radio” system, what licensing will be required?

The geography of Sandoval County includes all designations except for Ocean front property.  In the flat land area, the signals would travel freely and infrastructure requirements minimal; however in the canyon and mountain areas, additional support, technology, and infrastructure would be required.   The use of other agency infrastructure for redundancy and reliability could be considered, but that again brings in concerns of maintenance and reliability of a network we have no control over.  In Sandoval County, ten percent (10%) of the land is considered private ownership; the other ninety percent (90%) is Forest, BLM, National Park or Tribal ownership.  Permission for infrastructure facilities, in some cases may require congressional approval.  The processes for gaining these permissions often extend past the grant timeline.

Network concerns would be determined by the design of the system.  Local access requirements verses state or federal requirements.  Will this be a managed network from the federal, state or local side?  Who will be in charge of designing the network?  Because of the nature of the data that will be transmitted, high security requirements must also be considered.  Will there be a centralized network operations center (NOC) that monitors the condition of the network?  Or will the locals need to implement a NOC of their own? If the NOC exists at any level, how will it be funded?  The State Department of Information Technology is already over tasked, understaffed and underfunded in many of their projects.

Michael A. Scales
Michael A. Scales, K5SCA
Communications Administrator
Office of Emergency Communications
NMCEM, NMCOMC/L
APCO-AFC Local Advisor - NM
Office 505.867.7522 Cell 505.934.5847

Mollohan, Jim [Jim.Mollohan@gta.ga.gov]
Thu 6/14/2012 3:35 PM

National Telecommunications and Information Administration(NTIA),

On behalf of the Georgia Department of Public Safety(GDPS) and Georgia Technology Authority(GTA), I am sending the attached response to NTIA’s RFI.

Thanks,

Jim
___________________________________

Jim Mollohan PMP, NPDP, PMC
Senior Wireless Product/Tech Project Manager
State of Georgia
Georgia Technology Authority
47 Trinity Ave SW
Ste 330-22
Atlanta, GA 30334-9007

Email: Jim.Mollohan@gta.ga.gov
Office: 404-656-5619
Mobile: 678-296-3940
Fax: 770-344-5937
gta.georgia.gov

ECPC [ECPC@HQ.DHS.GOV]
Thu 6/14/2012 2:53 PM

Please find attached all comments submitted to the Emergency Communications Preparedness Center (ECPC) from the Department of Transportation on the NTIA’s RFI on the State and Local Grant Program for the Nationwide Public Safety Broadband Network (Docket No: 120509050–1050–01 / RIN 0660–XC001).

Butzlaff, Nathan B (GOV) [nathan.butzlaff@alaska.gov]
Thu 6/14/2012 11:53 AM

Pursuant to NTIA’s May 16, 2012 Federal Register Request for Information, the State of Alaska is submitting comments regarding the development of the State and Local Implementation Grant Program for the Nationwide Public Safety Broadband Network. 

We appreciate NTIA’s consideration of the State of Alaska’s comments.  Please do not hesitate to contact me if NTIA has any questions.

Regards,
Nathan Butzlaff

Nathan Butzlaff
Associate Director of State-Federal Relations
Office of Governor Sean Parnell
State of Alaska
Hall of the States
444 North Capitol St., NW
Suite 336
Washington, DC 20001

Direct: (202) 624-5988
Mobile: (202) 304-4606
Main:  (202) 624-5858
Fax:  (202) 624-5857
Nathan.Butzlaff@alaska.gov

Wood, Curtis (EPS) [curtis.wood@state.ma.us]
Thu 6/14/2012 10:34 AM

Dear Sirs/Madams:

Attached is the official response from the Commonwealth of Massachusetts to the Request for Information for the:

DEPARTMENT OF COMMERCE

National Telecommunications and Information Administration [Docket No: 120509050–1050–01] RIN 0660–XC001 Development of the State and Local Implementation Grant Program for the Nationwide Public Safety Broadband Network

Thank you for the opportunity to comment on this proposed program.

Respectfully submitted,

Curtis M. Wood, Undersecretary
Forensic Sciences and Technology
Massachusetts Executive Office of Public Safety and Security
617.274.5512
curtis.wood@state.ma.us

William Burgess [william.burgess@comcast.net]
Thu 6/14/2012 9:41 AM

Laura M. Pettus
Communications Program Specialist
Office of Telecommunications and Information Applications
National Telecommunications and Information Administration
U.S. Department of Commerce

Dear Ms. Pettus –

On behalf of the NSGIC Board of Directors, I’m forwarding the attached comments as a WORD document in response to the Request for Information (RFI) issued as Docket No: 120509050–1050–01.

Please contact me if you have any questions regarding this submission.

Take Care

Bill Burgess, Washington Liaison
National States Geographic Information Council
24760 Logans Woods Drive
Denton, Maryland  21629

443-448-4395 (Office)
443-786-8404 (Cell)

william.burgess@comcast.net

http://www.nsgic.org

Plantz, Sue@CIO [Sue.Plantz@state.ca.gov]
Wed 6/13/2012 3:15 PM

Dear National Telecommunications and Information Administration:

Thank you for the opportunity to provide responses to the NTIA Implementation Grant Program for the Nationwide Public Safety Broadband Network.  Attached please find the responses from the State of California.  This document was prepared by the California Technology Agency, Public Safety Communications Office and the California Emergency Management Agency.  If you have any questions you can contact, Sue Plantz, Deputy Director PSCO Governance and Telecommunications Services Division at sue.plantz@state.ca.gov or (916) 657-9512, or Michael Crews, CalEMA Interoperability Coordinator at Michael.crews@calema.ca.gov or (916) 845-8602.

Docket No:  120509050-1050-01

RIN:  0660-XC001

Development of the State and Local Implementation Grant Program for the Nationwide Public Safety Broadband Network

AGENCY: National Telecommunications and Information Administration, U.S. Department of Commerce.

ACTION: Request for Information

Prepared by: California Technology Agency, Public Safety Communications Office and California Emergency Management Agency

Sincerely,

Sue Plantz
Deputy Director, Telecommunications Governance and Services Division
California Technology Agency
Public Safety Communications Office
601 Sequoia Pacific Blvd.
Sacramento, CA 95811
(916) 657-9512 (phone)

NOEL Steve [Steve.Noel@odot.state.or.us]
Mon 6/11/2012 8:08 PM

Hello,

Submitting comments for the State of Oregon:  Comments submitted by Steve Noel, Major Projects Branch, Oregon Department of Transportation.

Thank you,

Steve Noel

Steve Noel
Oregon SWIC - Major Projects Branch, ODOT
Office 503.934.6940/Cell 503.551.4206
Steve.Noel@odot.state. or.us

Delatorre, Carlos X. [cdelatorre@macro.com]
Fri 6/8/2012 5:30 PM

Dear Board Members,

Please accept my comments regarding the Development of State & Local Implementation Grant Program for NPSBN

Thank you

Carlos Delatorre
Principal Consultant, Public Safety / Telecommunications
__________________________________________________________

Macro Corporation
A KEMA Company
1880 Office Club Point, Suite 1000
Colorado Springs, CO 80920
Tel (719) 272-8224
<mailto:cdelatorre@macro.com>
Website:  www.macro.com
This message may contain confidential or privileged information. If you are not the addressee,
please return the message to its sender and delete it from your files.

"Experience you can trust"

Please consider the environment before printing this email.

Lisa Hansen [LHansen@azdohs.gov]
Thu 6/7/2012 5:44 PM

Input from Arizona.  This was also submitted to NGA.

Thanks,
Lisa L. Hansen
Assistant Director Planning and Preparedness
Arizona Department of Homeland Security
Office: 602-542-7014
www.azdohs.gov

Laura Berkey-Ames [lberkey@APWA.NET]
Thu 6/7/2012 4:50 PM

To Whom It May Concern:
On behalf of the American Public Works Association, attached you will find comments (Docket No: 120509050-1050-01) in response to the development of the State and Local Implementation Grant Program for the Nationwide Public Safety Broadband Network.

Please feel free to contact me if you need additional information.

Regards,

Laura M. Berkey-Ames

Laura Berkey-Ames
Government Affairs Manager
American Public Works Association
Ph:(202) 218-6734 | Fax:(202) 218-6735
Your Comprehensive Public Works Resource

Please Consider the environment before printing this email

dr.myers@me.com
Thu 5/31/2012 11:04 AM

Attached you will find my response to the RFI requested by the NTIA/Department of Commerce.

Rex Buddenberg [buddenbergr@gmail.com]
Mon 5/21/2012 11:20 PM

comment attached

buddenberg

Jeff.Pierce@state.sd.us
Tue 5/22/2012 10:18 AM

NTIA/SLIGP;

Please find attached comments on the Public Safety Broadband Implementation Grant process from the perspective of the State of South Dakota. If you have any questions or comments my contact information is in the document as well as below.

Jeff Pierce
Technical Administrator/SWIC
State of South Dakota
Bureau of Information & Telecommunications
700 Governors Drive
Pierre, SD 57501

Jeff.pierce@state.sd.us

o-605-773-4347
m-605-280-4428