Public Safety Communications: Preliminary Information on FirstNet's Efforts to Establish a Nationwide Broadband Network
Released: 2015-03-11T00:00:00

Letter

Background

The 2012 act established numerous responsibilities for FirstNet, most of which relate directly to developing the public safety network. For example, in establishing the network, FirstNet must issue open, transparent, and competitive Requests for Proposals (RFP) to private sector entities for the purpose of building, operating, and maintaining the network; enter into agreements to use, to the maximum extent economically desirable, existing commercial, federal, state, local, and tribal infrastructure; promote competition in the public-safety equipment marketplace by requiring that equipment for the network be built to open, non- proprietary standards; and develop the technical and operational requirements for the network, as well as the practices and procedures for managing and operating it.

In establishing the infrastructure for the public safety network, the 2012 act requires FirstNet to include the network components depicted in figure 1.

In developing the public safety network, FirstNet must work with a variety of stakeholders. The 2012 act required FirstNet to be headed by a 15- member board with 3 permanent members and 12 individuals appointed by the Secretary of Commerce. The 2012 act also required FirstNet to establish a standing public safety advisory committee to assist it in carrying out FirstNet’s responsibilities and consult with federal, regional, state, local, and tribal jurisdictions on developing the network. For state, local, and tribal planning consultations, FirstNet is required to work with the Single Points of Contact (SPOC) who have been designated by each state. Specifically, SPOCs are the individuals responsible for working with FirstNet in their states, and FirstNet will work through these individuals to gather requirements from key stakeholders in each state. The 2012 act requires FirstNet to notify the states when it has completed its RFPs for building, operating, and maintaining the public safety network. Once a state receives the details of FirstNet’s plans, it has 90 days either to agree to allow FirstNet to construct a Radio Access Network (RAN) in that state or notify FirstNet, NTIA, and FCC of its intent to deploy its own RAN. The 2012 act required FCC, the entity responsible for managing and licensing commercial and non-federal spectrum use—including spectrum allocated to public safety—to grant FirstNet the license to the public safety spectrum that the act set aside for FCC has also conducted spectrum auctions, as required by the network.the 2012 act, so that auction proceeds could be used to fund FirstNet. The 2012 act provides $7 billion from these proceeds to FirstNet for buildout of the network, and requires FirstNet to become self-funding beyond this initial $7 billion by generating revenue through user fees and other sources.

Requests for Waiver of Various Petitioners to Allow the Establishment of 700 MHz Interoperable Public Safety Wireless Broadband Networks, Order, 25 FCC Rcd 5145, (2010); Requests for Waiver of Various Petitioners to Allow the Establishment of 700 MHz Interoperable Public Safety Wireless Broadband Networks, Order, 25 FCC Rcd 6783, (2011). networks will be incorporated into its nationwide network, and has noted that various factors could affect this determination.

FirstNet Is Making Progress Meeting Responsibilities but Lacks Certain Elements of Effective Internal Controls

FirstNet Is Making Progress Carrying Out Statutory Responsibilities

Our ongoing work indicates that FirstNet has made progress carrying out its statutory responsibilities in three areas—(1) establishing its organizational structure, (2) planning the public safety network, and (3) consulting with stakeholders—but could face challenges in each of these areas.

Establishing its Organizational Structure

As a newly created entity within the federal government, FirstNet has taken a number of steps to establish its organizational structure and hire staff. As required by the 2012 act, the Secretary of Commerce appointed FirstNet’s inaugural Board Members in August 2012 and, in February 2013, established the Public Safety Advisory Committee (PSAC). In April 2013, the FirstNet Board selected an Executive Director to lead its day-to-day operations. Since then, FirstNet has hired, and continues to hire, other senior management personnel to lead its organizational units (such as a Chief Counsel and Chief Administrative, Financial, and Information Officers), Directors and organizational chiefs to further lead and perform its work, and other general staff. As of February 2015, FirstNet had over 120 employees.

Stakeholders we spoke with and surveyed for our ongoing work expressed concern that organizational issues have slowed FirstNet’s progress, and could continue to do so. In particular, in response to our survey, numerous SPOCs either noted that FirstNet’s placement within NTIA could create “bureaucratic” obstacles or that FirstNet should be more independent from NTIA. However, FirstNet officials told us that while FirstNet has leveraged its relationship with NTIA in administrative and legal matters, it exercises strong independence in decisions that are directly program-related. Numerous stakeholders we surveyed and interviewed were also concerned about the pace of FirstNet’s hiring, noting that the federal hiring process is too slow, has not allowed FirstNet to hire staff quickly enough, and has delayed FirstNet’s progress. For example, FirstNet hired State and Local, Tribal, and Federal Outreach Leads in June and August 2014, almost 2 years after FirstNet’s Board Members were appointed, and is still in the process of hiring staff for key positions. According to FirstNet officials, FirstNet faces challenges hiring as quickly as it would like to due to government hiring procedures, but is seeking direct hire authority from the Office of Personnel Management.

Planning the Public Safety Network

To plan the public safety network and help ensure that its approach is open and transparent and meets the 2012 act’s requirements, FirstNet intends to follow the Federal Acquisition Regulation (FAR) process for its comprehensive network services procurement. This process will culminate in one or multiple RFPs for “network solution(s)”—that is, proposals for the building, deployment, operation, and maintenance of the public safety network. To help it draft the RFP(s), FirstNet has sought comments through an October 2012 Notice of Inquiry, 13 RFIs issued between April 2013 and September 2014, and a September 2014 Public Through these items, FirstNet has sought comment on various Notice. technical aspects of the network, devices and applications for public safety, and its interpretations of the 2012 act’s requirements. FirstNet received almost 600 comments to these Notices and RFIs. FirstNet confirmed in February 2015 that it expects to issue a draft RFP and a second Public Notice by the end of March 2015. FirstNet has also received technical input from a variety of stakeholders, such as FCC, the PSAC, the National Public Safety Telecommunications Council (NPSTC), and the Public Safety Communications Research (PSCR) program.

While many stakeholders we surveyed and interviewed for our ongoing work noted that FirstNet’s progress has been too slow, some also noted that they were satisfied with FirstNet’s progress given the complex nature of FirstNet’s tasks and that it is a government entity subject to federal rules and regulations. Some also said that FirstNet’s progress has improved recently, especially as FirstNet has hired more staff. However, numerous stakeholders we interviewed cited upcoming difficulties. For example, they noted that deciding the level of network coverage and security, working out agreements for use of existing infrastructure, and navigating state regulations will be difficult issues to address moving forward.

Consulting Stakeholders

FirstNet has initiated a process to consult with the SPOC in each state and FirstNet officials have conducted outreach to other stakeholders. FirstNet began its formal state consultation process in April 2014; as part of this process, FirstNet plans to hold an initial consultation meeting in each state. Initial state consultation meetings began in July 2014—when FirstNet conducted its first consultation with Maryland—and FirstNet expects these initial meetings to continue through 2015, with additional rounds to follow. As of February 25, 2015, FirstNet has conducted initial consultation meetings with 14 states and Puerto Rico. Additionally, from October 2013 to February 2015, FirstNet officials visited 39 states and territories while participating in 187 events, such as public safety, industry, and government (including federal, state, local, and tribal) conferences. FirstNet also launched a public website in March 2014, where it regularly posts updates, presentations, board meeting minutes, a list of upcoming speaking engagements, and other information.

The majority of stakeholders we surveyed for our ongoing work were generally satisfied with the level of FirstNet’s consultation and outreach, but others were dissatisfied and said that they would like more new information. Specifically, in response to our survey, 54 percent of SPOCs said they were either “moderately” or “very” satisfied with FirstNet’s overall level of consultation, coordination, and communication with their state, including the level of input FirstNet has sought from their state, and 22 percent said they were either “moderately” or “very” dissatisfied. Numerous stakeholders we surveyed and interviewed said that they would like more new and detailed information and that they would like FirstNet to focus more on certain aspects of the public safety network during outreach. However, in response to our survey, many SPOCs also acknowledged that the level of new and detailed information exchanged will likely increase once they hold their initial state consultation meeting with FirstNet.

FirstNet Has Not Assessed Risk or Established a Complete Control Environment

Internal controls are the plans, methods, policies, and procedures that an entity uses to fulfill its mission, strategic plan, goals and objectives. An effective internal control system increases the likelihood that an entity will achieve its objectives. For our ongoing review, we assessed FirstNet’s policies and practices against two components of an effective federal For internal control system: Risk Assessment and Control Environment.those two components, we found that FirstNet lacks certain elements that contribute to the proper implementation of effective internal control systems. While FirstNet has stated that it is relying on the Department of Commerce and NTIA’s internal controls where it has not developed its own, it is important for FirstNet to implement its own controls, as the Commerce Office of Inspector General (OIG) noted as early as February 2014 in a memo on the management challenges facing FirstNet.

Risk Assessment

According to federal internal control standards, management should assess risks facing the entity as it seeks to achieve its objectives. Specifically, entities should first clearly define their objectives then identify and analyze risks from both internal and external sources. Analyzing risks generally includes estimating the risk’s significance, assessing the likelihood of its occurrence, and deciding how to respond to it. Risk assessments inform an entity’s policies, planning, and priorities, and help entities develop responses to the risks they face, so that they can achieve their objectives.

Our preliminary results indicate that, although FirstNet has set objectives and taken some steps to assess risks it has not yet fully assessed risks it may face in accomplishing its objectives. Specifically, FirstNet has set three key objectives and has further delineated how it will accomplish these objectives in a “roadmap” that identifies additional long-term and short-term objectives and milestones. To support its development of this roadmap, FirstNet created a “risk register” that identifies some risks related to its financial sustainability as well as possible counter- measures.they had not yet fully assessed risks because they were in the process of defining risk factors and, again in December 2014, because they were in the process of conducting a legal compliance risk assessment of certain key risk areas. In December 2014, FirstNet officials also said that they intend to perform periodic risk assessments in various areas to manage risks on an iterative basis. However, as of February 2015, FirstNet has not yet completed these risk assessment activities; therefore, we were unable to evaluate them and it remains unclear how effective FirstNet’s efforts will be in helping it to identify and respond to obstacles to fulfilling its responsibilities.

However, FirstNet officials told us in November 2014 that As FirstNet performs these assessments, we believe that it will be important for FirstNet to incorporate all of the elements of risk assessment detailed in the federal internal control standards. An internal control system that is not based on complete risk assessments (that is, assessments that incorporate these elements) could lead to FirstNet responding to risks in a reactive manner and could hinder FirstNet’s ability to achieve its objectives while maximizing use of its available resources. We are concerned that the complexity of FirstNet’s objectives, makeup of its board, and challenges it will face becoming self-funding illustrate the multitude of potential risks FirstNet faces. For example, as we point out later in this statement, various factors could hinder whether public safety entities adopt the public safety network—and thus how much user fee revenue FirstNet can collect—which could pose risks to FirstNet’s ability to become self-funding.

Control Environment

The control environment is the foundation for an internal control system and provides the basic structure that helps an entity achieve its objectives. To help set this environment, according to federal internal control standards, an entity should, among other things, demonstrate a commitment to integrity and ethical values, such as by setting a positive “tone at the top,” providing and evaluating adherence to ethical and behavioral guidance, and removing temptations for unethical behavior.

Our preliminary results indicate that, although FirstNet has taken a number of steps to establish an effective control environment, it has not yet finished doing so. FirstNet has held ethics briefings, counseling, and training; distributed ethics documents; and instituted a Board Member Vendor Interaction Policy to establish processes for interacting with vendors with a potential interest in FirstNet’s procurement. However, as of February 2015, FirstNet had not yet developed Standards of Conduct, which is an important form of ethical and behavioral guidance. According to FirstNet officials, FirstNet intends to develop Standards of Conduct but has not yet done so because, as a “startup” entity, building up the organization while making progress meeting statutory responsibilities is a balancing act affected by FirstNet’s priorities and resources.

Nonetheless, absent Standards of Conduct, we are concerned that FirstNet may not be able to address deviations in conduct and performance and take corrective actions in a timely manner. Indeed, FirstNet itself established a special committee in May 2013 to review ethical concerns raised by one of its Board Members. Similarly, in a December 2014 report, the Department of Commerce OIG identified concerns with FirstNet’s financial disclosure reporting and contracting practices, among other things. The report highlighted that the FirstNet Board, out of necessity, includes members with significant ties to the telecommunications industry that make strategic decisions regarding FirstNet’s operations and, thus, are at increased risk of encountering conflicts of interests. We believe that establishing and evaluating adherence to Standards of Conduct may help FirstNet ensure that all its personnel are held accountable for their actions and that stakeholders maintain trust in its ability to be a good steward of public funds.

FirstNet Faces Difficult Decisions in Determining How to Pay for a Nationwide Public Safety Network Estimated to Cost Billions Cost of a Public Safety Network Estimated to Be at Least $12 Billion over the First 10 Years

Various entities have estimated the cost to construct and operate a nationwide network for public safety from a low of $12 billion to a high of between $34 and $47 billion, over the first 10 years. As shown in table 1, a variety of entities have developed cost estimates for a public-safety broadband network, although they have used different assumptions about the network’s scope. Key assumptions influencing these estimates include whether the network is constructed, operated, or financed in partnership with commercial entities, and the number of sites needed to provide the network’s coverage. Our ongoing work has found that differences among these estimates are difficult to identify since some of the estimates do not explicitly state all of their assumptions.

Various Factors Will Influence Cost of FirstNet’s Public Safety Network

Our preliminary analysis indicates that cost estimates notwithstanding, various factors will influence the cost of constructing and operating FirstNet’s public safety network, including (1) the business model used, especially the extent of commercial partnerships; (2) use of existing infrastructure; (3) efforts to ensure network reliability; and (4) network coverage.

Extent of Commercial Partnerships

FirstNet’s business model, especially the extent to which it partners with commercial carriers or other private enterprises, will influence the cost to construct and operate the public safety network. The 2012 act gives FirstNet the authority to engage in a variety of commercial partnerships. In a partnership, public safety and commercial users could share the network’s infrastructure and spectrum, with public safety given priority to all network capacity during emergencies. Some public safety stakeholders we spoke with maintained the need for FirstNet to work with commercial partners in building and operating the network for it to be financially sustainable. One study also calculated that the value of serving both commercial and public safety users is greater than the additional costs to serve commercial users.

Use of Existing Infrastructure

The use of existing infrastructure will influence the cost to construct and operate FirstNet’s public safety network. Under agreements to share existing wireless-network infrastructure, FirstNet may be able to make use of, for example, cell towers, antennae, cabling, radio-processing equipment, backup power facilities, and the links between towers and the nearest communications hub, to the extent economically desirable to do so. According to FCC estimates, capital costs would be 2.5 times greater without this form of sharing. However, the use of existing infrastructure can have limitations. For instance, negotiating access to existing infrastructure can be a time-consuming process—especially with government-owned or controlled facilities and where multiple owners must be contracted with—ultimately slowing down network deployment. For our ongoing work, we spoke with Swedish officials about the public- safety communications network in their country, and they told us that they sought to use existing infrastructure to save costs when constructing their network, but faced problems in their largest cities convincing tower owners to allow the government to rent the towers. Furthermore, there may be a risk when public safety relies on infrastructure owned by commercial operators, particularly if it has to rely on a single provider in any given location that can then charge high fees.

Efforts to Ensure Network Reliability

FirstNet’s approach to ensure the public safety network is safe, secure, and resilient (that is, the overall reliability of the network) will also influence the cost to construct the network. FirstNet is required by the 2012 act to “ensure the safety, security, and resiliency of the network,” and NPSTC has provided guidance to FirstNet as it constructs and implements the network. If FirstNet implements all of NPSTC’s best practices, it will significantly add to the cost of building the network. For example, transmission sites, such as cell towers, should have back-up power sources when used for public safety communications, according to NPSTC. Existing commercial sites, however, generally do not have such backup, primarily to reduce costs in extremely competitive markets.

Network Coverage

The public safety network’s coverage will also influence the cost to construct and operate it. The 2012 act requires FirstNet to establish a “nationwide” network, but does not define the level of coverage that constitutes “nationwide.” Generally speaking, increasing the area covered by the network, as well as the extent to which coverage penetrates buildings, increases the amount of infrastructure needed, and thus the cost of the network. It may be relatively affordable, for example, to cover large segments of the population concentrated in relatively small areas. Providing coverage outside dense metropolitan areas can be particularly expensive. One study has shown that a nationwide public- safety broadband network could generate much more revenue than the network costs in urban areas, but less revenue than costs in rural areas.

FirstNet Faces Difficult Decisions about User Fees and Commercial Partnerships in Determining How to Become Self-Funding

Our preliminary analysis suggests that, although FirstNet has various revenue options that it is authorized to use to become self-funding, it is unclear how FirstNet will use those authorities. As the cost estimates above illustrate, FirstNet’s network will likely cost tens of billions of dollars to construct and initially operate. To meet the costs of building and maintaining the network, the 2012 act authorizes FirstNet to generate revenue through user fees and commercial partnerships, the latter of which can involve secondary use of the network for non-public safety services.

User Fees

FirstNet can generate revenue by charging public safety entities a user fee to gain access to the network. According to stakeholders we spoke with and surveyed for our ongoing work, demand for FirstNet’s public but the following factors could hinder safety network is significant,adoption of the network and thus FirstNet’s ability to collect user fee revenue:

Fee size. If FirstNet’s user fee is too high, it could hinder public safety adoption, and if it is too low, it could bring in too little revenue. Numerous stakeholders we spoke with noted that FirstNet’s cost would play a role in whether they adopt the public safety network and that user fees must be competitive with existing commercial services. While low user fees would be attractive to public safety entities and therefore may increase adoption, they would also bring in a relatively smaller amount of revenue per user. As a FirstNet Senior Program Manager reported in December 2014, there is a trade-off with low user fees between adoption and the network’s financial sustainability. Some stakeholders also noted that the cost of equipment and devices needed to access the network could limit adoption, especially since public safety entities are continuing to invest in their LMR networks.

User base. While a large user base can potentially bring in significant user fee revenue, it could be challenging to manage. The 2012 act established that FirstNet’s primary customers will be entities that provide “public safety services.” How FirstNet interprets “public safety services,” as established in the 2012 act, will expand or contract the potential sources of revenue. As one public safety official we spoke with noted, the network has more value to public safety entities when there are more users on it, because entities will all be able to communicate with each other. A large user base, however, can require priority and preemption rules, if certain users are to have privileged access to the network. According to some public safety officials we spoke with, such rules can be difficult to establish among public safety entities.

Coverage. Widespread network coverage can attract more users, and thus user fee revenue, but is expensive to construct and maintain. Some of the public safety entities we spoke with said that the network’s coverage would play a role in whether they adopt the public safety network, noting in particular that the coverage should be at least as good as existing commercial services. One public safety entity we spoke with said that existing commercial coverage is inadequate, while two other entities said that commercial service can become unusable during large events because of the number of users on the network. However, as noted above, providing extensive coverage can be very costly. Indeed, a few SPOCs noted in survey responses that providing rural coverage in their states will be challenging, with one commenting that “it is inconceivable that FirstNet will be able to deploy a terrestrial network in the vast areas that are unpopulated or sparsely populated.”

Reliability. Although FirstNet is required to construct a resilient network, practices to ensure this can be costly. Some public safety officials we spoke with said that the network’s reliability would play a role in whether they adopt the public safety network. A few officials specifically said that if the network did not reliably work when first utilized by public safety, adoption would suffer, since public safety has a low tolerance for unreliable technology. However, as noted above, ensuring reliability requires significant capital expenses.

Commercial Partnerships

Our ongoing work also found that FirstNet can generate revenue through commercial partnerships, but the extent of commercial interest in these partnerships, and thus the value of this authority for FirstNet, is unknown. Under the 2012 act, FirstNet can receive payment for the use of the public safety network’s capacity by non-public safety users as well as use of the network’s infrastructure. The value of secondary access to the network’s capacity depends in part on the availability of the spectrum, which itself will be determined by the capacity available given the network’s design. According to one major carrier we spoke with, no business is likely to enter into a partnership with FirstNet because its public-safety user base has not been defined, and thus the network capacity available to secondary (commercial) users is unknown. According to this carrier, the risk would be too high for a commercial entity to enter into an agreement without knowing exactly how the entity will be able to use FirstNet’s network. If public safety preempts all commercial traffic, then the commercial entity will struggle to generate income from this venture and may lose favor with its customers. However, another major carrier we spoke with maintained that FirstNet will have to partner with at least one commercial carrier to be financially sustainable and that given the significant investments in Long Term Evolution (LTE) infrastructure made by commercial carriers, FirstNet would do well to utilize some of this infrastructure through commercial partnerships. Although the historic Advanced Wireless Services spectrum auction FCC concluded in late January 2015 could indicate significant demand for spectrum capacity among commercial carriers, the extent of carriers’ interest in partnering with FirstNet is not fully known. While there may be some benefits in partnering with FirstNet, companies may also prefer to compete directly with FirstNet with their own public safety products.

Although Early Builder Projects Are Providing Lessons, FirstNet Has Not Developed a Plan to Evaluate Them

Early Builder Projects Have Learned Lessons As They Develop Public Safety Networks

Governance

Early builder project officials described governance challenges that FirstNet may face as the governing entity for the nationwide network. For example, officials from one project told us some public safety entities may not have a clear understanding of FirstNet’s goals and plans. The officials told us localities are willing to participate in the public safety network, but FirstNet will face difficulty in establishing timely technical decisions and effective policies that keep pace with local enthusiasm to participate. The officials said FirstNet can address this challenge by setting expectations about what the network will provide, including the specific intent, purpose, and planned capabilities.

Financing the Network

Officials from the early builder projects also learned lessons related to financing a new public safety network that could be applicable to FirstNet. For example, officials from one project told us they will face sustainability challenges due to the limited number of users that will be able to utilize their network. According to the officials, their project will not be able to charge their users enough to make the operations sustainable without pricing the users out of the services. The officials told us a possible way to address this challenge would be to expand the service to public safety entities in neighboring metropolitan areas and airport service areas that have established broadband infrastructure.

Conducting Outreach

Early builder project officials cited lessons they learned for conducting outreach while developing their public safety networks. According to officials working with one of the projects, network coverage will be a challenging outreach topic and FirstNet must be prepared to explain the coverage strategy for each state. The officials said most public safety officials in their state are aware that network coverage is typically provided through a myriad of approaches such as permanent infrastructure, mobile “deployables,” and satellites. However, the officials noted, until FirstNet sets clear expectations on those approaches, state stakeholders for the public safety network may face difficulties holding constructive conversations about which coverage solutions are the most feasible.

Planning for Network Deployment

Officials from the early builder projects as well as the canceled public safety projects also described lessons they learned about planning their network’s deployment that could benefit FirstNet. An official from one of the canceled projects said his team faced several challenges including local zoning conditions that impacted project schedule and cost, a newly- passed city code that required towers to withstand higher wind loads which increased costs, and commercial competitors lowering their subscription rates to compete with the planned public safety network. Officials from an ongoing project told us their project initially identified network build-out sites but learned that environmental assessments would need to be completed for each site, which would threaten the project’s planned schedule. To address the challenge, the project narrowed its build-out site pool to exclude marsh lands and other areas with obstructive tree lines and include publicly-owned sites such as police and fire stations. With the publicly-owned sites identified, project officials worked with their state’s legislature to pass an exemption to state environmental reviews. The official from the project told us that an important lesson learned is to thoroughly understand all of the process steps and risks prior to plan execution.

FirstNet Has Processes in Place to Identify Early Builder Project Lessons but Has Not Developed a Written Evaluation Plan

Our preliminary results indicate that FirstNet has taken steps to collect and evaluate information and lessons learned from the early builder projects, but could do more to ensure that the information and lessons are properly evaluated. Specifically, FirstNet has taken steps to identify the data and information it will collect from the early builder projects. As noted above, FirstNet entered into agreements with the projects that permit their use of FirstNet’s spectrum. Under these agreements, in exchange for spectrum use, the early builders agree to conduct specific activities on their networks, also known as key learning conditions; develop a Key Learning Conditions Plan with FirstNet; and provide FirstNet with quarterly reporting on their project’s use of FirstNet’s spectrum, progress achieving project milestones, and in some cases, the experiences of their network users. In October 2014, FirstNet provided the projects with quarterly report templates, instructions, and timing for completing the reports. Additionally, FirstNet intends to gain knowledge from the projects through contractors who have been assigned to each project to collect and log formal and informal lessons, and through weekly meetings FirstNet officials told us they hold. Finally, in April 2014 FirstNet authorized the PSAC to establish an Early Builder Working Group.

Although FirstNet has taken these steps, we are concerned that it lacks a detailed data-analysis plan to track the performance and results of the early builder projects. For the early builder projects, their performance and results are captured in the observations and lessons learned reported to FirstNet and identified by consultants. We have previously found that a well-developed evaluation plan for projects like the early builder projects can help ensure that agencies obtain the information necessary to make effective program and policy decisions. Such a plan should include, among other things, a detailed data-analysis plan to track performance and evaluate the project’s final results. Even though FirstNet staff and contractors remain in close contact with the projects, without a plan to track those projects, it is unclear how FirstNet intends to evaluate the projects’ observations and lessons and determine whether or how the lessons are addressed. As a result, we believe that FirstNet could miss opportunities to leverage key lessons related to governance, finance, outreach, and network deployment. Given that the early builder projects are doing on a regional and local level what FirstNet must eventually do on a national level, a complete evaluation plan that includes a detailed data-analysis plan could play a key role in FirstNet’s strategic planning and program management, providing feedback on both program design and execution. Furthermore, such a plan could provide FirstNet officials the opportunity to make informed midcourse changes as it plans for the public safety network, and facilitate transparency and accountability for FirstNet’s decision-making.

Chairman Thune, Ranking Member Nelson, and Members of the Committee, this concludes my prepared remarks. I am happy to respond to any questions that you or other Members may have at this time.

GAO Contact and Staff Acknowledgments

If you or your staff have any questions about this testimony, please contact Mark L. Goldstein, Director, Physical Infrastructure Issues at (202) 512-2834 or goldsteinm@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this statement. GAO staff who made key contributions to this statement include Sally Moino (Assistant Director), Susan Baker, Melissa Bodeau, Kyle Browning, David Hooper, Kristen Kociolek, Josh Ormond, Nalylee Padilla, Kelly Rubin, Grant Simmons, Andrew Stavisky, and Michael Sweet.

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