[House Hearing, 111 Congress]
[From the U.S. Government Publishing Office]
INTEROPERABILITY FOR PUBLIC
SAFETY RADIO EQUIPMENT
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HEARINGS
BEFORE THE
SUBCOMMITTEE ON TECHNOLOGY AND INNOVATION
COMMITTEE ON SCIENCE AND TECHNOLOGY
ONE HUNDRED ELEVENTH CONGRESS
SECOND SESSION
----------
MAY 27, 2010
and
SEPTEMBER 23, 2010
----------
Serial No. 111-97
and
Serial No. 111-110
----------
Printed for the use of the Committee on Science and Technology
INTEROPERABILITY FOR PUBLIC
SAFETY RADIO EQUIPMENT
=======================================================================
HEARINGS
BEFORE THE
SUBCOMMITTEE ON TECHNOLOGY AND INNOVATION
COMMITTEE ON SCIENCE AND TECHNOLOGY
ONE HUNDRED ELEVENTH CONGRESS
SECOND SESSION
__________
MAY 27, 2010
and
SEPTEMBER 23, 2010
__________
Serial No. 111-97
and
Serial No. 111-110
__________
Printed for the use of the Committee on Science and Technology
Available via the World Wide Web: http://www.science.house.gov
______
U.S. GOVERNMENT PRINTING OFFICE
57-175 WASHINGTON : 2010
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COMMITTEE ON SCIENCE AND TECHNOLOGY
HON. BART GORDON, Tennessee, Chair
JERRY F. COSTELLO, Illinois RALPH M. HALL, Texas
EDDIE BERNICE JOHNSON, Texas F. JAMES SENSENBRENNER JR.,
LYNN C. WOOLSEY, California Wisconsin
DAVID WU, Oregon LAMAR S. SMITH, Texas
BRIAN BAIRD, Washington DANA ROHRABACHER, California
BRAD MILLER, North Carolina ROSCOE G. BARTLETT, Maryland
DANIEL LIPINSKI, Illinois VERNON J. EHLERS, Michigan
GABRIELLE GIFFORDS, Arizona FRANK D. LUCAS, Oklahoma
DONNA F. EDWARDS, Maryland JUDY BIGGERT, Illinois
MARCIA L. FUDGE, Ohio W. TODD AKIN, Missouri
BEN R. LUJAN, New Mexico RANDY NEUGEBAUER, Texas
PAUL D. TONKO, New York BOB INGLIS, South Carolina
STEVEN R. ROTHMAN, New Jersey MICHAEL T. McCAUL, Texas
JIM MATHESON, Utah MARIO DIAZ-BALART, Florida
LINCOLN DAVIS, Tennessee BRIAN P. BILBRAY, California
BEN CHANDLER, Kentucky ADRIAN SMITH, Nebraska
RUSS CARNAHAN, Missouri PAUL C. BROUN, Georgia
BARON P. HILL, Indiana PETE OLSON, Texas
HARRY E. MITCHELL, Arizona
CHARLES A. WILSON, Ohio
KATHLEEN DAHLKEMPER, Pennsylvania
ALAN GRAYSON, Florida
SUZANNE M. KOSMAS, Florida
GARY C. PETERS, Michigan
JOHN GARAMENDI, California
VACANCY
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Subcommittee on Technology and Innovation
HON. DAVID WU, Oregon, Chair
DONNA F. EDWARDS, Maryland ADRIAN SMITH, Nebraska
BEN R. LUJAN, New Mexico JUDY BIGGERT, Illinois
PAUL D. TONKO, New York W. TODD AKIN, Missouri
HARRY E. MITCHELL, Arizona PAUL C. BROUN, Georgia
GARY C. PETERS, Michigan
JOHN GARAMENDI, California
BART GORDON, Tennessee RALPH M. HALL, Texas
HILARY CAIN Subcommittee Staff Director
MEGHAN HOUSEWRIGHT Democratic Professional Staff Member
TRAVIS HITE Democratic Professional Staff Member
HOLLY LOGUE Democratic Professional Staff Member
MATT McMAHON Democratic Professional Staff Member
MELE WILLIAMS Republican Professional Staff Member
JULIA JESTER Republican Professional Staff Member
VICTORIA JOHNSTON Research Assistant
C O N T E N T S
Interoperability in Public Safety
Communications Equipment
February 3, 2010
Page
Witness List..................................................... 2
Hearing Charter.................................................. 3
Opening Statements
Statement by Representative David Wu, Chairman, Subcommittee on
Technology and Innovation, Committee on Science and Technology,
U.S. House of Representatives.................................. 8
Written Statement............................................ 9
Statement by Representative Adrian Smith, Ranking Minority
Member, Subcommittee on Technology and Innovation, Committee on
Science and Technology, U.S. House of Representatives.......... 10
Written Statement............................................ 10
Witnesses:
Dr. David Boyd, Director, Command, Control and Interoperability
Division, Science and Technology Directorate, Department of
Homeland Security (DHS)
Oral Statement............................................... 11
Written Statement............................................ 13
Biography.................................................... 16
Mr. Dereck Orr, Program Manager, Public Safety Communications
Systems, National Institute of Standards and Technology (NIST)
Oral Statement............................................... 17
Written Statement............................................ 19
Biography.................................................... 25
Dr. Ernest L. Hofmeister, Senior Scientist, Harris Corporation
Oral Statement............................................... 25
Written Statement............................................ 27
Biography.................................................... 34
Mr. John Muench, Director of Business Development, Motorola Inc.
Oral Statement............................................... 35
Written Statement............................................ 36
Biography.................................................... 43
Chief Jeffrey D. Johnson, President, International Association of
Fire Chiefs, and Chief, Tualatin Valley Fire and Rescue, Aloha,
Oregon
Oral Statement............................................... 43
Written Statement............................................ 45
Biography.................................................... 46
Appendix 1: Answers to Post-Hearing Questions
Dr. David Boyd, Director, Command, Control and Interoperability
Division, Science and Technology Directorate, Department of
Homeland Security (DHS)........................................ 68
Mr. Dereck Orr, Program Manager, Public Safety Communications
Systems, National Institute of Standards and Technology (NIST). 72
Dr. Ernest L. Hofmeister, Senior Scientist, Harris Corporation... 74
Mr. John Muench, Director of Business Development, Motorola Inc.. 81
Appendix 2: Additional Material for the Record
Statement for the Record from Skyterra Communications............ 86
C O N T E N T S
Progress on P25: Furthering Interoperability and Competition for Public
Safety Radio Equipment
September 23, 2010
Witness List..................................................... 90
Hearing Charter.................................................. 91
Opening Statements
Statement by Representative David Wu, Chairman, Subcommittee on
Technology and Innovation, Committee on Science and Technology,
U.S. House of Representatives.................................. 97
Written Statement............................................ 97
Statement by Representative Judy Biggert, Acting Ranking Minority
Member, Subcommittee on Technology and Innovation, Committee on
Science and Technology, U.S. House of Representatives.......... 98
Written Statement............................................ 99
Prepared Statement by Representative Harry E. Mitchell, Member,
Subcommittee on Technology and Innovation, Committee on Science
and Technology, U.S. House of Representatives.................. 99
Witnesses:
Mr. Tom Sorley, Deputy Director, Radio Communication Services,
City of Houston Information Technology Department
Oral Statement............................................... 100
Written Statement............................................ 101
Biography.................................................... 111
Ms. Ellen O'Hara, President, Zetron
Oral Statement............................................... 112
Written Statement............................................ 114
Biography.................................................... 117
Mr. Marvin Ingram, Senior Director, Arinc, Public Safety
Communications
Oral Statement............................................... 117
Written Statement............................................ 119
Biography.................................................... 121
Mr. Russ Sveda, Manager of the Radio Technical Service Center,
Department of the Interior
Oral Statement............................................... 122
Written Statement............................................ 123
Biography.................................................... 124
Appendix: Additional Material for the Record
Letters to Chairman David Wu and Representative Adrian Smith from
John Suzuki, Senior Vice President of Sales, EF Technologies,
Inc., dated September 22, 2010................................. 132
INTEROPERABILITY IN PUBLIC SAFETY COMMUNICATIONS EQUIPMENT
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THURSDAY, MAY 27, 2010
House of Representatives,
Subcommittee on Technology and Innovation,
Committee on Science and Technology,
Washington, DC.
The Subcommittee met, pursuant to call, at 10:00 a.m., in
Room 2318 of the Rayburn House Office Building, Hon. David Wu
[Chairman of the Subcommittee] presiding.
hearing charter
U.S. HOUSE OF REPRESENTATIVES
COMMITTEE ON SCIENCE AND TECHNOLOGY
SUBCOMMITTEE ON TECHNOLOGY AND INNOVATION
Interoperability in Public Safety
Communications Equipment
thursday, may 27, 2010
10:00 a.m. 0912:00 p.m.
2318 rayburn house office building
I. Purpose
Communication among first responders is essential in emergency
response. Recent disasters, including 9/11 and the 1999 Columbine High
School shooting, have illustrated the communication problems that can
occur when multiple agencies respond to a disaster. Compatible
technology is critical to enabling interoperability, or the ability of
first responders to communicate with their counterparts from other
agencies and jurisdictions. For two decades, the public safety
community, private industry, and the Federal Government have been
working on technical standards that will ensure that digital land
mobile radio (LMR) systems from different vendors are interoperable.
The purpose of this hearing is to discuss the status of these standards
and the interoperability capabilities of public safety LMR equipment.
II. Witnesses
Dr. David Boyd, Director, Command, Control &
Interoperability, Science and Technology Directorate,
Department of Homeland Security
Mr. Dereck Orr, Program Manager, Public Safety
Communications Systems, National Institute of Standards and
Technology
Dr. Ernest L Hofmeister, Senior Scientist, Harris
Corporation
Mr. John Muench, Director of Business Development,
Motorola Inc.
Chief Jeffrey D. Johnson, President, International
Association of Fire Chiefs, and Chief, Tualatin Valley Fire and
Rescue, Aloha, Oregon
III. Brief Overview
The public safety community has long recognized the challenge of
providing for interoperable communications. Enabling first responders
from different agencies and jurisdictions to communicate requires not
only cooperation and planning, but also compatible technology. However,
without common standards, there is no assurance that a manufacturer's
proprietary systems will interoperate with its competitors' systems.
Since 1989, representatives from public safety, industry, and the
government have been working together to develop common standards
(known as the ``P25'' standards). The purpose of these standards is not
only to ensure interoperability, but also to promote market
competition, spectrum efficiency, and an easy transition from analog to
digital radio systems.
Much progress has been made on these standards since 1989 and P25
radios and radio systems are now available. However, not all of the
standards originally called for have been completed. As more public
safety agencies make significant investments in radio systems, it is
important to assess the status of the process and understand its impact
on public safety.
In addition to the development of standards, assessing the
compliance of P25 radios with the standards is critical for ensuring
the investment made by governmental agencies will meet the expectations
of the P25 process. Currently, there is no formal mechanism within the
existing P25 process for validating that products claiming P25
compliance are in fact built correctly to the standards. The Department
of Homeland Security (DHS) Compliance Assessment Program (CAP), a
voluntary testing program, provides an alternative verification
mechanism and is therefore an important tool for public safety in
making equipment procurement decisions. However, the CAP currently does
not require all of the testing that was originally envisioned.
IV. Background
Lack of Interoperability
The lack of communications interoperability has posed significant
challenges in the response to large-scale disasters, such as the 1995
Oklahoma City Bombing, the 2001 attack on the World Trade Center in New
York City, and Hurricane Katrina in 2005. At the scene of the Oklahoma
City bombing, fragmented communication frequencies and conflicting
standards prevented police and fire agencies from communicating with
the National Guard, Federal Emergency Management Agency, and other
Federal agencies. Lack of interoperability contributed to the chaos and
tragedy of 9/11 when some 200 firefighter did not receive a message
broadcast on NYPD radio channels that the collapse of the first tower
was imminent. And, in the days immediately following Hurricane Katrina,
local and Federal agencies could not talk to one another. For example,
first responders in helicopters were unable to communicate with crews
patrolling in boats, hampering rescue efforts. Even the response to the
Columbine High School shooting was hindered by a lack of interoperable
equipment. Nearly 1,000 first responders from different agencies
arrived on the scene but the lack of interoperability prevented them
from being able to adequately assess the situation and the threat
level, slowing the response. In these situations, first responders had
to use message runners, an inefficient practice that limits the flow of
information to incident commanders.\1\
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\1\ Tristan Weir, Federal Policy Toward Emergency Responder
Interoperability: A Path Forward. Thesis submitted for a Masters of
Science in Technology Policy from the Massachusetts Institute of
Technology, 2006.
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Enabling interoperability requires major planning and coordination
among the agencies and jurisdictions that may need to work together
when responding to a disaster. However, as the examples above
illustrate, incompatible radio systems significantly hamper
interoperability. Technology-based causes of interoperability include
proprietary designs or unique configurations among different radio
systems that operate in different frequencies of the radio spectrum.
First responder agencies have used a variety of ad-hoc solutions to
enable interoperability, such as swapping radios or creating mutual aid
channels, but such solutions are less efficient than systems designed
to interoperate.
Project-25
The process of developing open standards for digital public safety
radios began in 1989, when the Association of Public-Safety
Communications Officials (APCO) and the National Association of State
Telecommunications Directors (NASTD), with the involvement of the
Department of Justice (DOJ) and other Federal agencies, launched
Project-25 (P25). The developers initiated P25 with the goals of having
a user-defined and user-driven standards process that would allow for
interoperability, multi-vendor procurement of equipment, an easy
transition from legacy analog equipment to digital equipment, and
greater spectrum efficiency.
The involvement of the user community makes P25 a unique technical
standards development process. The Telecommunications Industry
Association (TIA), which is a standards development organization
accredited by the American National Standards Institute (ANSI), writes
and maintains the technical standards documents. The public safety
community interacts with TIA's technical standards process through a
Steering Committee. Aided by a User Needs Subcommittee, the Steering
Committee develops the Statement of User Requirements on which the
standards are based. Memoranda of Understanding govern the interaction
between TIA's standards development committees and the Steering
Committee. This interaction is further facilitated by a working
committee between the two groups.\2\
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\2\ The APCO 25/34 Interface Committee (APIC), a joint subcommittee
of the Steering Committee and the TIA Private Radio Section.
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Public safety LMR systems include fixed infrastructure, such as
towers and base stations, and portable units, such as handheld and car-
mounted radios. P25 seeks to provide for standardization of eight
interfaces where components of the LMR systems must communicate with
each other.\3\ The first set of standards developed focused on the
Common-Air Interface (CAI), which defines the communication protocols
between radio transmitters and receivers. This standard is intended to
ensure that a portable radio from one manufacturer can communicate with
a portable radio from another manufacturer. It is crucial for overall
interoperability between two different systems. Other standards suites
needed for interoperability cover the interfaces between the larger
infrastructure components. These include: \4\
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\3\ http://www.pscr.gov/outreach/p25dsr/menu-top/
p25-interfaces.php
\4\ Project 25: The Quest for Interoperable Radios, Issue Brief
from the COPS Interoperable Communications Technology Program, Dan
Hawkins, May 2007.
The Console Subsystem Interface (CSI), which defines
how radio frequency components of the system and console (such
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as the equipment used by dispatchers) connect with one another.
The Fixed Station Interface (FSI), which defines how
components of the radio system that are fixed in place (such as
base stations) connect with other components of the system.
The Inter-RF subsystem Interface (ISSI), which
defines how different radio networks should connect with one
another.
Although the P25 process began in 1989, the entire suite of
standards for all eight interfaces is not yet complete. According to a
2007 Government Accountability Office (GAO) report,\5\ despite spending
over $2 billion from 2003 to 2005 on interoperability, many states were
far from achieving that goal. GAO identified the slow rate of P25
standards development as among the myriad factors hindering faster
adoption of interoperable public safety communications systems. The
report noted that the P25 standards committees took four years (from
1989 to 1993) to develop the CAI, but that the committees developed no
additional standards between 1993 and 2005 that could be used by
manufactures for additional elements of a P25 compliant system.
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\5\ First Responders--Much Work Remains to Improve Communications
Interoperability. GAO-07-301, April 2007.
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Although GAO did find that ``significant progress'' was made in
defining the three other interfaces most critical to interoperability
after 2005, they cited concerns from participating National Institute
of Standards and Technology (NIST) researchers that these standards
were still incomplete, allowing manufacturers to develop products based
on inconsistent interpretations. Tests conducted between 2003 and 2006
showed that these inconsistent interpretations of the standards caused
P25 radios to fail aspects of interoperability tests.
The 2007 GAO report further cited concerns that the lack of
compliance testing had limited the impact of the standards process for
digital LMR systems. Developers include compliance tests within
standards documents to provide a mechanism to validate whether a
product is actually built to the standard and minimize issues that
arise with inconsistent interpretations of the standard by different
manufacturers. Without this testing, there is no way to validate that a
product labeled ``P25 compliant'' will perform as intended.
In response to GAO's 2007 assessment that work on P25 had slowed
after the CAI, TIA asserted that 114 standards and documents were in
fact published between 1993 and 2005 and that manufacturers themselves
had initiated compliance testing to ensure the interoperability of
their products.\6\ However, according to the Public Safety
Communications Research (PSCR) program,\7\ standardization for all
eight of the P25 standards remains incomplete. According to the PSCR
program's Project 25 Documents and Standards Reference for May 2010:
``For most cases, a P25 interface, service, or equipment standard is
not complete until all documents that provide the Overview, the
Protocol Specifications, the Protocol Conformance Test Procedures, the
Performance Measurements Methods, the Performance Recommendations, and
the Interoperability Test Procedures are published or are approved for
publication by the appropriate [TIA] committee.'' Although much
progress has been made, only the ISSI has been fully completed.
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\6\ http://www.tiaonline.org/gov-affairs/
press-publications/documents/TIAResponsetoGAOReportonP25.pdf
\7\ The PSCR program is housed in Boulder and is a joint effort
between the National Institute of Standards and Technology/Office of
Law Enforcement Standards (NIST/OLES) and the National
Telecommunications and Information Administration/Institute for
Telecommunication Sciences (NTIA/ITS). http://www.pscr.gov/projects/
lmr/p25-stds-dev/
p25-stds-dev.php.
Involvement by the Federal Government
Over the past 15 years, multiple Federal agencies have addressed
the interoperability issue, from the DOJ to the Federal Communications
Commission (FCC). The current lead within the Federal Government is the
Department of Homeland Security (DHS) SAFECOM program. SAFECOM provides
technical research and development through the DHS Science and
Technology Directorate and practitioner guidance and coordination
through the Office of Emergency Communication.
Although Federal agencies have been involved with P25 since it
began, the 2004 Intelligence Reform and Terrorism Prevention Act (P.L.
108-458) specifically directed the Secretary of Homeland Security to
establish a program to enhance the interoperability of public safety
communications. In addition to facilitating planning and coordination
among all levels of government, the legislation directed the Department
of Homeland Security to work--in consultation with NIST, the private
sector, and others--to ``accelerate the development of national
voluntary consensus standards for public safety interoperable
communications.''
Compliance Assessment Program (CAP)
As noted above, no formal mechanism exists in the P25 process to
validate that the radio equipment meets the standards. In the report
accompanying the FY 2006 Department of Homeland Security Appropriations
Act (H. Rept. 109-241), Congress directed DHS to work with NIST and the
DOJ on a P25 Conformity Assessment Program. The resulting DHS
Compliance Assessment Program (CAP), which certifies testing
laboratories and specifies which tests must be conducted, is a
voluntary process for P25 equipment suppliers to show that their
equipment meets P25 standards for ``performance, conformance, and
interoperability.'' However, conformance assessment testing is not
currently required, nor do CAP requirements exist for all eight
interfaces.
The SAFECOM Recommended Guidance for Federal Grant Programs
requires that grant applicants using DHS funds to purchase P25
equipment must obtain Supplier's Declaration of Compliance (SDoC)
documents and Summary Test Reports (STR) when they purchase the
equipment. DHS also provides a website (www.rkb.us) where manufacturers
can post these documents.
Conformity assessment tests whether a manufacturer has interpreted
and implemented a standard correctly. It is more rigorous than
interoperability and performance testing and is arguably the best
mechanism for ensuring that manufacturers are interpreting the
standards consistently and for ensuring that all standardized functions
on the radio will interoperate. Finally, conformity assessment testing
is considered important for ensuring the backwards compatibility of new
technology that must be connected to legacy systems, sometimes as many
as 20 years old.
Additional Issues with P25
In addition to the concerns outlined above, GAO's 2007 assessment
of interoperability identified two other issues preventing more
widespread adoption of P25 equipment: (1) the lack of information and
expertise among state and local agencies in buying equipment to meet
their needs, and (2) the increased cost of P25 systems over
conventional radio systems.
Digital radios are complex and manufacturers offer many different
features and levels of functionality. GAO noted that agencies lacked
comparative information about product functionality and typical first
responder requirements. In addition, P25 radio units can cost more than
2- to 3-times the cost of conventional analog radios suitable for first
responder use. Building an entire P25 LMR system, which is critical for
interoperability, is also a major cost for municipalities.
700 MHZ and Public Safety Broadband Network
The P25 standards cover interoperability for voice communications
over digital LMR systems. With the availability of broadband, many
public safety agencies are integrating data functions into their
operations. Since there is no dedicated public safety broadband
network, public safety agencies must use commercial wireless providers.
A public safety broadband network is part of ongoing discussions on the
use of the newly-available portions of the 700 MHz band. Public safety
officials see the 700 band as a resource for extra voice capacity,
broadband, and Voice-IP back-up systems. Many would like to see a
public/private partnership build a network that would allow public
safety priority access during an emergency but be available for
commercial users during normal operation.
While public safety demand for spectrum is generally less than
network capacity in normal operations, demand can often exceed capacity
during a crisis. A public/private network would potentially allow for a
more efficient use of resources, but commercial providers have been
hesitant to commit to the extra requirements and hardening a public
safety network requires. For example, public safety networks must be
available in remote locations and the infrastructure must be able to
withstand disasters, like hurricanes or earthquakes. The inability to
solve these challenges contributed to the failure of the recent FCC
auction of spectrum designated for a public safety/commercial carrier
partnership (the ``D-Block'') to meet the reserve price.
Debate is ongoing on how to govern, finance, and build a network to
provide greater spectrum resources to public safety. However, the
National Public Safety Telecommunications Council, DHS, and NIST have
developed a public safety Broadband Network Statement of Requirements
document to offer guidance to the FCC, which has stated that a 700 Mhz
public safety broadband network must be interoperable, but has not
issued regulations on how such interoperability would be achieved. In
addition APCO is identifying gaps in standards to ensure that the
network will support interoperability and roaming. Standards are
particularly important if the national public safety broadband system
is eventually built out as a system of networks.
Finally, the move toward broadband could pose a challenge as public
safety agencies move to comply with FCC narrow-banding requirements. In
2004, the FCC mandated that by 2013, all public safety agencies needed
to transmit using 12.5 kHz-wide channels, rather than using 25 kHz-wide
channels. It has been further proposed that, by 2018, public safety
will migrate to 6.25 kHz-wide channels and the P25 standards process is
already in the process of developing standards for 6.25 kHz. As the
name implies, though, data-rich broadband communication requires wider
channels. Thus, within the public safety portion of the 700 Mhz band,
systems will have to enable both broadband and narrowband
transmissions.
V. Issues and Concerns
Status of Standards
Project 25 began in 1989. Although the standards developers have
made much progress since that time and P25 systems are now being
fielded around the country, the complete suite of standards has not yet
been completed. Continued advances in technology will mean continued
updates and revisions for the P25 standards. However, as public safety
organizations implement P25 systems, it is important to gain insight
into how the status of the standards development process will affect
their current operations and future procurements.
Compliance Assessment Program
Radios are a lifeline for first responders. Ensuring that they work
as intended is critical for the safety of these individuals and the
lives and property they protect. It is also critical in ensuring that
the significant amount of public money used to procure these systems is
well spent and improves the communication capabilities of public safety
agencies. The DHS CAP may provide the public safety community with the
assurance that products sold as P25 compliant meet all of the
requirements of the standards. Potentially, too, it may identify areas
where the standard has not been uniformly implemented. While it is
important to balance the time and expense incurred by manufacturers in
performing compliance testing with the benefit to the public safety
community, it is also essential that there is a trusted process
available to ensure that P25 equipment is interoperable and meets the
other requirements of the standards.
Future Issues
P25 is unique in bringing the user community and industry together
in the standards development process. Such cooperation in the standards
process is important as public safety increases its use of broadband
and other technologies.
Chairman Wu. The hearing will come to order.
Good morning and thank you for coming to today's hearing
focused on interoperability in public safety communication
equipment, and I want to warn everyone in the room first, not
our witnesses, because they are extremely knowledgeable, that
the topic of this morning's hearing is extremely complex,
technical, and has kind of made my head swim at times. However,
I do believe that it is very, very important to public safety
and good government.
We have learned important lessons from Oklahoma City,
September 11, Columbine High School and Hurricane Katrina and
other disasters that interoperable communication is crucial to
effective emergency response. When time is of the essence and
lives are at stake, a clear flow of information is absolutely
essential. Unfortunately, it is not uncommon for police
officers, firefighters and other emergency responders from
different regions, from a single region, or even a single city
to be using incompatible communication systems which don't talk
to each other. This lack of interoperability has contributed to
the deaths of first responders and hindered the ability to
rescue people in harm's way.
Enabling interoperable communication systems, where public
safety personnel can talk with each other in real time, takes
planning and cooperation by all levels of government.
Interoperability also requires equipment that is capable of
communicating with each other and assuring interoperability
requires complete standards, conformance testing and compliance
assessment. First responders on digital land mobile radio
systems built to proprietary specifications cannot communicate
well. Lack of published standards and compliance testing may
also have consequences for competition among equipment vendors
and consequently options for and prices to emergency service
agencies.
When I visited NIST's [National Institute of Standards and
Technology] interoperability and standards lab this past
February in Boulder, Colorado, I was shocked to learn that
after more than 20 years of development, the vast majority of
standards needed to assure interoperability for first
responders and to enhance competition for the benefit of
purchasers are not yet usable. This puts first responders at
unnecessary risk and provides governmental purchasers with less
competition than they would otherwise have.
Since 1989, the public safety community and industry have
been working together on Project 25, or P25, a suite of
standards that will not only enable interoperability but also
produce competition in the marketplace for digital land mobile
radio systems and provide other benefits. While there has been
some progress on the P25 standards since 1989, the standards
remain incomplete.
In this hearing, I would like to understand the
implications of this for public safety agencies procuring
systems sold as P25 compliant. I would also like to get a
better sense of when we can expect all of the standards to be
completed or at least usable. For purpose of comparison, we
have standards for cell phones and other forms of
communication, and not only standards, but with respect to cell
phones we have gone through G1, generation 2, generation 3 and
now we are transitioning to G4 devices, and standards have been
established for all these different generations of devices.
A second issue that we will discuss today is the lack of a
formal compliance assessment process for the P25 standards. A
compliance assessment process tells purchasers that a product
meets all of the requirements of a standard. Any laptop with a
Wi-Fi logo, Bluetooth-enabled devices or indeed any toaster
with an Underwriters Lab sticker, had to go through testing and
certification to be able to display those marks. P25 does not
have an equivalent independent testing certification process.
The Department of Homeland Security's Compliance Assessment
Program can fill this gap. It seems to me that emergency
services communication is too important for caveat emptor to be
the standard. Also, when first responders spend millions of
dollars on new, complex communications technology, expecting
interoperability, conformance and relying upon the P25 logo,
they should not come up empty-handed.
In addition to being mission-critical and life-critical
technology, these systems represent major expenditures for
governmental agencies across the country. I, and most other
Members of Congress, are asked every single year for funds to
upgrade emergency responder communication systems. Taxpayers
deserve both safety and value for their dollar.
I would like to thank our witnesses for being here today.
It is important that this process move forward and that the
public safety community and industry continue to work together
to make further advances in first responder technology.
Chairman Wu. Now I would like to recognize Mr. Smith for
his opening statement.
[The prepared statement of Chairman Wu follows:]
Prepared Statement of Chairman David Wu
Good morning and thank you for coming to today's hearing focused on
interoperability in public safety communication equipment.
We've learned an important lesson from September 11th, Hurricane
Katrina, and other disasters: interoperable communication is critical
to effective emergency response. When time is of the essence and lives
are at stake, a clear flow of information is essential. Unfortunately,
it is not uncommon for police officers and firefighters from a single
region, or even a single city, to be using incompatible communication
systems. This lack of interoperability has contributed to the deaths of
first responders and hindered the ability to rescue people in harm's
way.
Enabling interoperable communication systems, where public safety
personnel can talk with each other in real-time, takes planning and
cooperation by all levels of government. However, interoperability also
demands radios that are capable of communicating with one another.
First responders on digital land mobile radio systems built to
proprietary specifications cannot communicate. Ad-hoc solutions, like
patching technologies or sharing radios, are less efficient than the
seamless interoperability offered by systems based on open
architecture.
The purpose of today's hearing is to examine the status of the
standards development process for this open architecture. Since 1989,
the public safety community and industry have been working together on
Project 25, or P25, a suite of standards that will not only enable
interoperability, but also promote competition in the marketplace for
digital land mobile radio systems and provide other benefits. While
there has been a lot of progress on the P25 standards since 1989, the
entire set of standards remains incomplete. I would like to understand
the implications of this for public safety agencies procuring systems
sold as ``P25 compliant'' and get a better sense of when we
realistically can expect all of the standards to be completed.
A second issue that we will discuss today is the lack of a formal
compliance assessment process for the P25 standards. A compliance
assessment process signals to the purchaser that a product meets all of
the requirements of a standard. Any laptop with a Wi-Fi logo, or any
toaster with an Underwriters Laboratory sticker, had to go through
testing and certification to be able to display those marks. P25 does
not have an equivalent process. The Department of Homeland Security's
Compliance Assessment Program fills this gap, but we must be sure it
provides the highest possible level of assurance to the public safety
community that systems sold as P25-complaint actually meet all of the
requirements of the standards. It seems to me that there ought to be a
formal, comprehensive system in place to ensure that it is not caveat
emptor when first responders spend millions of dollars on complex
communications technology.
The most important question for the first responders who rely on
this equipment is ``does it work?'' In addition to being mission-
critical technology, these systems represent major expenditures for
government agencies across the country. Particularly at a time of
uncertain and dwindling budgets cost-effective procurement enabled by
an open-architecture is essential.
I'd like to thank our witnesses for being here today. Project 25 is
unique in the world of standards development in that the users of the
technology--in this case our public safety officials--are integral to,
and directly involved in, the standards development process. It is
important that this process move forward, and that the public safety
community and industry continue to work together to make further
advances in first responder technology.
Mr. Smith. Thank you, Mr. Chairman, for calling today's
hearing on the interoperability of public safety communications
equipment, specifically Project 25, or P25 standards.
In nearly every public safety emergency, as the events
mentioned by the Chairman to the baseball-sized hailstones that
hit my home community this week, we are reminded of the need
for our first responders to have interoperable communications
across both jurisdictions and lines of duty. Although the P25
standard was initiated in the late 1980s, it was the terrorist
attacks on September 11 which prompted government and industry
to actively implement these standards with action continuing to
this day.
All parties clearly understand it is in their interest to
ensure emergency communications tools advertised as P25
compliant meet that standard. At the Federal level, we have a
responsibility to ensure local jurisdictions are able to work
together and taxpayer dollars are spent only on equipment which
works as promised. Equipment manufacturers know sales will go
elsewhere if competitors' products achieve higher levels of
operability and interoperability, and our first responders
clearly understand the importance of interoperable equipment in
protecting the lives of themselves and certainly those whom
they serve. At the same time, we must keep in mind
interoperability is inconsequential if outside forces such as
power outages actually knock out equipment and advances in
technology and increased availability of bandwidth may move us
to technologies above and beyond P25 standards.
I expect the primary questions addressed in this hearing
will be, what has been achieved so far, where is it going and
is it progressing quickly enough while also touching on where
emergency communications may go into the future.
With that, thank you, Mr. Chairman. Thank you to the
panelists for sharing your insight and expertise, and I look
forward to a constructive hearing. I yield back.
[The prepared statement of Mr. Smith follows:]
Prepared Statement of Representative Adrian Smith
Thank you, Chairman Wu, for calling today's hearing on the
interoperability of public safety communications equipment--
specifically Project 25, or P25, standards.
In nearly every public safety emergency--from national scale
disasters such as the 9-11 attacks and Hurricane Katrina down to
localized storm events such as the baseball-sized hail and high winds
we experienced earlier this week in western Nebraska--we are reminded
of the need our first responders have for interoperable communications,
across both jurisdiction and lines of duty.
Although the P25 standard was initiated in the late 1980s, it was
the terrorist attacks on September 11 which prompted government and
industry to actively implement these standards, with action continuing
to this day.
All parties clearly understand it is in their interest to ensure
emergency communications tools advertised as P25 compliant meet that
standard. At the Federal level we have a responsibility to ensure local
jurisdictions are able to work together and taxpayer dollars are spent
only on equipment which works as promised. Equipment manufacturers know
sales will go elsewhere if competitors' products achiever higher levels
of operability and interoperability. And our first responders clearly
understand the importance of interoperable equipment in protecting the
lives of themselves and those they serve.
At the same time, we must keep in mind interoperability is
inconsequential if outside forces such as power outages knock out
equipment, and advances in technology and increased availability of
bandwidth may move us to technologies above and beyond P25 standards.
I expect the primary questions addressed in this hearing will be
``What has been achieved so far?'' ``Where is it going?'' and ``Is it
progressing quickly enough?'' while also touching on where emergency
communications may go in the future.
With that, thank you again Chairman Wu, and welcome to our
panelists. I look forward to a constructive hearing and I yield back
the balance of my time.
Chairman Wu. Thank you, Mr. Smith.
If there are other Members who wish to submit opening
statements, your statements will be added to the record at this
point.
And now it is my pleasure to introduce our witnesses. Dr.
David Boyd is the Director of the Command, Control and
Interoperability Division of the Science and Technology
Directorate at the Department of Homeland Security. Mr. Dereck
Orr is the Program Manager of the Public Safety Communications
Systems Program at the National Institute of Standards and
Technology, or NIST. Dr. Ernest Hofmeister is Senior Scientist
at the Harris Corporation. Mr. John Muench is the Director of
Business Development of Motorola. And our final witness is
Chief Jeffrey Johnson, who is President of the International
Association of Fire Chiefs and the Chief of the Tualatin Valley
Fire and Rescue Department in Aloha, Oregon.
Welcome, all. You will each have five minutes for your
spoken testimony. Your written testimony will be included in
the record for this hearing, and since we do have your written
testimony and have read it, rather than simply summarizing,
please focus your comments as much as possible on answering the
following four questions. What factors have delayed the
development of the needed technical standards? What has delayed
conformance and compliance testing? What is the impact of the
absence of applicable standards and tests? And when can we
expect completion of those standards and tests needed to assure
interoperability and competition?
When you complete all your oral testimony, we will begin
with questions and each Member will have five minutes to
question the panel.
Dr. Boyd, please proceed.
STATEMENTS OF DAVID BOYD, DIRECTOR, COMMAND, CONTROL AND
INTEROPERABILITY DIVISION, SCIENCE AND TECHNOLOGY DIRECTORATE,
DEPARTMENT OF HOMELAND SECURITY (DHS)
Dr. Boyd. Thank you, Mr. Chairman, Ranking Member Smith.
Emergency responders need to be able to respond to
incidents using their own equipment, particularly when they are
supporting jurisdictions other than their own. And they need
the ability to exchange the whole range of data, imagery and
maps, as well as to communicate by voice and to combine all of
those sources of information as needed during an emergency. Any
strategy for improving interoperability must be informed by
practitioner input. That is, it must be based on actual user
needs and driven from the bottom up. Practitioners include the
end-user community that supports all aspects of securing the
homeland during both day-to-day operations and large-scale
incidents or disasters.
The existing response infrastructure is complex, as the
Chairman has already pointed out. There are more than 50,000
different emergency response agencies throughout the United
States, each with its own local and state government
regulations and requirements. Further, each locality has some
form of legacy communications system and its own budget and
planning lifecycles. The existing public safety communications
infrastructure in the United States represents, as a
conservative estimate, an investment of more than $100 billion
for voice system hardware alone. These existing systems cannot
be quickly or easily replaced so the only way to move toward
nationwide interoperability without wasting existing
investments is through a system of systems approach which
capitalizes on already existing infrastructure.
This approach allows agencies to join together using
standards, compatible procedures and training exercises without
having to discard major investments in existing systems and it
enables emergency responders to use their own equipment to
respond to incidents anywhere in the Nation. By leveraging
standards, emergency responders can communicate by voice and
exchange data, imagery, video and maps, creating situational
awareness that improves response for both daily operations and
major incidents. Furthermore, the system of systems approach is
naturally more robust. It eliminates the risk that one failed
technology, or link, will cause the entire system to fail.
Since 2004, the legislatively established Office for
Interoperability and Compatibility, OIC, which is within my
office within the Science and Technology Directorate, has
partnered with NIST and the National Telecommunications and
Information Administration to accelerate the development of the
Project 25 suite of standards for narrowband communication.
These standards help produce voice communications equipment
that is interoperable regardless of manufacturer while
retaining compatibility with legacy systems and permitting
scaling from small to large incidents.
A few years ago, we discovered through testing that much of
the equipment advertised as P25 compliant was unable to
interoperate with P25 equipment manufactured by other
companies, and in many cases, even with earlier P25 equipment
manufactured by the same company. In response, Congress
authorized OIC to establish the Compliance Assessment Program
in coordination with NIST. A comprehensive Compliance
Assessment Program is a key element to improving interoperable
communications. It provides a process through which equipment
can demonstrate that it correctly follows the standard and is
able to interoperate with other equipment that follows that
standard.
When interoperability testing is combined with conformance
testing, emergency responders can be assured that equipment
conforms to the standard and will interoperate with all
compatible equipment that correctly implements the standard
including equipment that hasn't been tested. Furthermore,
conformance testing helps provide increased confidence that
equipment developed in the future will retain compatibility
with legacy systems. Recognizing the need for an open and
transparent process, the program established a governing board
to represent the collective interests of organizations that
procure P25 equipment. Its membership consists of local,
tribal, state and Federal Government employees who are active
in the operation or procurement of communications systems. The
board considers all comments in an ongoing effort to address
both the requirements of the users and the concerns of the
manufacturers. Using testing standards published by P25, the
P25 CAP [Compliance Assessment Program] aims to add quality,
openness and rigor by building on the product development
testing already performed by manufacturers. The first group of
laboratory assessments began in December 2008, and by April
2009 DHS [Department of Homeland Security] recognized the first
eight laboratories. Four different manufacturers have had
emergency communications equipment complete the P25 CAP
process, which includes publishing Suppliers Declaration of
Compliance and Summary Test Reports.
Unfortunately, claims of compliance are not limited to the
equipment that has completed the P25 CAP and this could lead to
confusion among emergency responders. As a consequence, we have
clarified the definition of P25 compliant equipment through
SAFECOM guidance for Federal grant programs, which is used by
all of the interoperable grant programs outside of DHS as well
as by DHS.
I appreciate the opportunity to testify before you today. I
look forward to continuing to work with emergency responders
and manufacturers and I welcome the Committee's interest and
support of interoperable communications. I look forward to
answering any questions the Committee may have.
[The prepared statement of Dr. Boyd follows:]
Prepared Statement of David Boyd
Introduction
Good morning Chairman Wu, Ranking Member Smith, and Members of the
Subcommittee. Thank you for inviting me to speak to you today.
Within the Department of Homeland Security (DHS), the Science and
Technology (S&T) Directorate's Command, Control and Interoperability
Division (CCI) uses a practitioner-driven approach to create and deploy
information resources that enable harmonized and secure interactions
among homeland security stakeholders.
Since the creation of the Department, there has been considerable
progress in strengthening interoperable communications--the ability for
all emergency responders to securely communicate with whomever they
need to, when they need to, and when properly authorized to do so--
across the nation. Having access to relevant, real-time and actionable
information is vital to make tactical, strategic, and planning
decisions that can prevent terrorist attacks, protect the homeland from
natural or man-made disasters, improve response and recovery, and
strengthen the resiliency of our communities. Emergency responders need
to be able to respond to an incident using their own equipment and be
able to communicate not just by voice, but to have the ability to
exchange data, imagery and maps, and combine all of these sources of
information as needed during an emergency.
The Office for Interoperability and Compatibility (OIC) within CCI
works to ensure that the emergency response community--including local,
tribal, state, and Federal emergency responders--have the systems and
equipment functionality that they need to save lives and safeguard the
nation. Among its activities, OIC is authorized to accelerate, in
consultation with other Federal agencies, including the National
Institute of Standards and Technology (NIST), the private sector, and
nationally recognized standards organizations, as appropriate, the
development of interoperable communications \1\ and develop a
compliance assessment program \2\.
---------------------------------------------------------------------------
\1\ Intelligence Reform and Terrorism Prevention Act of 2004 Sec.
7303, Pub. L. No. 108-458 (codified at 6 U.S.C. Sec. 194)
\2\ Department of Homeland Security Appropriations Act of 2007,
H.R. Rep. No. 109-699
System of Systems
A successful strategy for improving interoperability must be
informed by practitioner input--that is, based on user needs and driven
from the frontlines up. Practitioners include the end-user community
that supports all aspects of securing the homeland during day-to-day
operations and large-scale incidents or disasters. The existing
response infrastructure is complex; there are more than 50,000
different emergency response agencies throughout the United States,
each with its own local and state government regulations and
requirements. Further, each locality has some form of legacy
communication system and its own budget and planning lifecycles.
The existing public safety communication infrastructure in the
United States represents, conservatively, an investment of more than
$100 billion for voice systems hardware alone. These existing systems
cannot be quickly or easily replaced.
One option to optimize resource effectiveness and eventually
realize nationwide interoperability is a system of systems approach.
The system of systems approach would allow separate agencies to join
together using standards, compatible procedures, and training exercises
without having to discard major investments in their existing systems,
and enables emergency responders to use their own equipment to respond
to an incident anywhere in the nation. By leveraging standards,
emergency responders could communicate by voice and exchange data,
imagery, video, and maps--creating situational awareness that improves
response for daily operations and major incidents. Furthermore, the
system of systems approach is more robust--it eliminates the risk that
one failed technology or link will cause the entire system to fail.
Acceleration of Standards
The standards development process is integral to achieving
interoperability. The ability to share critical emergency-related
data--a map, a situational report, the status of medical resources--on
demand and in real time is imperative in today's response environment.
While this need has been apparent for years, comprehensive standards do
not yet exist, because the systems and the range of standards required
is complex.
Communication standards allow for the creation of multi-vendor
systems that can bridge disparate technology and spectrum. In
conjunction with development of the standard itself, it is just as
essential that a compliance program for equipment testing be used. A
robust compliance program ensures products are not only interoperable
but also are implemented correctly by adhering to the standard.
Since 2004, OIC has partnered with NIST and the National
Telecommunications Information Administration's Institute for
Telecommunication Sciences to accelerate the development of the Project
25 (P25) suite of standards for narrowband communications. P25
standards help produce voice communications equipment that is
interoperable, regardless of manufacturer. In addition to
interoperability, P25 aims to promote more efficient use of spectrum
while retaining compatibility with legacy systems, and scaling to
support small-to-large incidents. While P25 consists of eight
interfaces, the emergency response community prioritized the
development of four interfaces:
Common Air Interface (CAI) \3\
---------------------------------------------------------------------------
\3\ This interface provides wireless communication between radios.
The major CAI standards documents are complete except for trunked
conformance test standard. The date for completion of this standard is
currently uncertain pending a commitment of resources from
manufacturers and support from the standards body.
Inter-RF Subsystem Interface (ISSI) \4\
---------------------------------------------------------------------------
\4\ This interface joins two land mobile radio systems so that they
act as one system and can support multijurisdictional, seamless
roaming. The ISSI functional standards are complete, and ISSI
commercial equipment is expected to begin deployment soon. The multi-
vendor seamless roaming allowed by the ISSI will constitute a serious
advancement over existing bridging technologies. Those technologies
will remain important for bridging existing equipment, since systems
are required to use the ISSI.
Console Subsystem Interface (CSSI) \5\
---------------------------------------------------------------------------
\5\ This interface specifies the basic messaging to interface a
console subsystem to a P25 RF Subsystem
Fixed Station Interface (FSI) \6\
---------------------------------------------------------------------------
\6\ This interface specifies a set of mandatory messages supporting
digital voice, data, encryption and telephone interconnectivity
necessary for communication between a Fixed Station and P25 RF
Subsystem
Specifically, CAI and ISSI are fundamental to system and equipment
interoperability, and thus are the highest priorities for both the
emergency response community and DHS S&T.
P25 standards are developed through a voluntary consensus process
\7\. The success of the overall effort is dependent on multiple factors
including active participation from the user community and equipment
manufacturers, the standards meeting requirements defined by emergency
responders, a willingness to build to the standard, and a comprehensive
compliance assessment program to determine whether equipment follows
the standard. The need for consensus throughout this effort often sets
the pace for how quickly they are completed. A strong desire for
progress and partnership among all stakeholders, manufacturers and
emergency responders alike helps build consensus and ensure a steady
pace.
---------------------------------------------------------------------------
\7\ National Technology Transfer and Advancement Act of 1995 Sec.
12, Pub. L. No. 104-113 (codified at 15 U.S.C. Sec. 272 note)
Compliance Assessment
A comprehensive compliance assessment program is a key element to
improving interoperable communications--it provides a process through
which equipment can demonstrate that it correctly follows the standard
and is able to interoperate with other equipment following the
standard. When interoperability testing is combined with conformance
testing, emergency responders can be assured that equipment conforms to
the standard and will interoperate with all compatible equipment that
correctly implements the standard, including equipment that was not
tested. Furthermore, conformance testing helps provide increased
confidence that equipment developed in the future will retain
compatibility with legacy systems.
A few years ago, it was discovered through testing that much of the
equipment advertised as P25-compliant was unable to interoperate with
P25 equipment manufactured by other companies and, in some cases, even
with earlier P25 equipment manufactured by the same company. In
response, Congress authorized OIC to establish the P25 Compliance
Assessment Program (CAP), in coordination with NIST. The P25 CAP allows
emergency responders to confidently purchase and use P25-compliant
products, and represents a critical step toward allowing responders to
communicate using their own equipment.
Recognizing the need for an open and transparent process, the P25
CAP established a Governing Board (GB) to represent the collective
interests of organizations that procure P25 equipment. Its membership
consists of local, tribal, state, and Federal Government employees who
are active in the operation or procurement of communication systems.
The P25 CAP GB encourages members of the public to attend meetings and
provide comments in order to increase stakeholder participation in the
program. Before the P25 CAP GB publishes compliance documents, they
solicit direct input from manufacturers, emergency responders, and
other interested parties during an open comment period. The GB
considers all comments in an ongoing effort to address both the
requirements of the users and the concerns of the manufacturers.
Through this open process, the GB continues to work towards the goal of
creating the first commonly-accepted definitions of compliance across
all interfaces.
Using testing standards published by P25, the P25 CAP aims to add
quality, openness, and rigor by building on the product development
testing already performed by manufacturers. The first group of
laboratory assessments began in December 2008, and by April 2009, DHS
recognized the first eight laboratories as part of the P25 CAP. A DHS-
recognized laboratory is authorized to produce detailed test reports
for P25 equipment. Four different manufacturers have had emergency
communications equipment complete the P25 CAP process, which includes
publishing Suppliers' Declaration of Compliance (SDoC) and Summary Test
Reports.\8\ The SDoC is the manufacturer's formal, public attestation
of compliance with the standards for the equipment and the Summary Test
Reports provides the equipment purchaser with a summary of the tests
conducted on the equipment along with the testing outcome.
---------------------------------------------------------------------------
\8\ As part of P25 CAP, SDoC and Summary Test Reports are required
to be published on FEMA's Responder Knowledge Base Web site at https://
www.rkb.us/
---------------------------------------------------------------------------
Unfortunately, claims of compliance are not limited to the
equipment that has completed the P25 CAP. This can lead to confusion
among emergency responders and in the marketplace. DHS has attempted to
clarify the definition of P25 compliant equipment through the SAFECOM
Guidance for Federal Grant Programs. Specifically, the SAFECOM grant
guidance states that ``all new digital voice systems must be compliant
with the P25 suite of standards.'' The grant guidance qualifies P25
equipment compliance to mean the completion of testing consistent with
P25 CAP. Only under compelling circumstances may an agency use grant
funding to purchase non-P25 equipment. The SAFECOM grant guidance
continues to be used by interoperable and emergency communications
grant programs outside of DHS, including the Department of Justice
Office of Community Oriented Policing Services Technology Program.
Conclusion
Emergency responders' ability to communicate is vital to completing
their mission, and the P25 CAP provides them with the credible facts
and data to evaluate manufacturers' claims of standards compliance. The
testing of P25 within communication equipment will improve
interoperability as well as confidence in the suite of standards. In
order to have a fully functional P25 CAP, at a minimum there must be
comprehensive compliance testing for the CAI and ISSI. Conformance
tests for the ISSI do exist and are under development for the CAI;
however, the successful incorporation of conformance testing in the P25
CAP is dependant on manufacturer participation. Without this rigorous
testing, a ``P25 radio'' is compliant in name only.
I appreciate the opportunity to testify before you today. I look
forward to continuing to work with emergency responders and
manufacturers, and I welcome the committee's interest and support of
interoperable communications.
I look forward to answering any questions you may have.
Biography for David Boyd
Dr. David G. Boyd joined the U.S. Department of Homeland Security
(DHS) upon its establishment in March 2003. Dr. Boyd serves as the
Director of the Command, Control and Interoperability (CCI) Division
within the Science and Technology Directorate. Dr. Boyd leads multiple
cutting-edge research and development (R&D) programs in communications
interoperability, cyber security, knowledge management, reconnaissance,
surveillance, and investigative technologies, and basic and futures
research; his CCI programs and projects comprise a budget of more than
$80 million. As one of the earliest members of the Department, Dr. Boyd
helped to build the Science and Technology Directorate from the ground
up. In 2004, he was selected to lead the Office for Interoperability
and Compatibility--an office established by Congress charged with
coordinating interoperable communications efforts across the Federal
Government and with the Nation's 60,000 emergency response agencies.
Dr. Boyd's ``bottom-up,'' practitioner-driven approach has
revolutionized the Federal Government's approach to strengthening
interoperable communications. Under Dr. Boyd's leadership, CCI includes
state and local emergency responders in the planning, development, and
implementation of projects. Needs gathered directly from responders are
used to develop comprehensive solutions that have the most significant
impact on practitioners and can be implemented throughout the Nation.
This approach has significantly improved the Federal Government's
relationship with these agencies and ensured that Federal projects
address the needs of responders in the field. Dr. Boyd is a recipient
of a 2005 Presidential Rank Award, the highest recognition available in
the Federal Civil Service, and holds a career appointment in the Senior
Executive Service. Both he and his Division have received more than a
dozen national awards since 2003.
Before joining DHS, Dr. Boyd served as the Director of Science and
Technology for the National Institute of Justice at the Department of
Justice, where he oversaw an activity which grew from a budget of $2
million and a staff of four into the single largest law enforcement and
corrections technology development activity in the United States with
an active portfolio of more than $750 million and a staff of more than
200 Federal and contract personnel in technology centers across the
Nation. His office managed R&D programs in every facet of technology
affecting law enforcement and corrections, including the forensic
sciences, less than lethal technologies, information and communications
technologies, and concealed weapons and contraband detection, among
others. He directed the DNA and forensic laboratory improvement
programs, which expanded the forensic community from fewer than six
DNA-capable crime laboratories to more than 130 in all 50 states.
Dr. Boyd has served on the White House National Science and
Technology Council, the National Security Council Committee on Safety
and Security of Public Facilities, and as the Executive Chair of the
Department of Justice's Technology Policy Council.
Prior to joining the Civil Service, Dr. Boyd served more than 20
years in the U.S. Army. He has commanded combat, combat support, and
training units in the U.S. and overseas, in times of both peace and
war, and has served on military staffs from battalion level to the
Pentagon, where--as an operations researcher--he was responsible for
the design and supervision of the development and application of
automated models in support of the Chairman of the Joint Chiefs of
Staff. He has represented the U.S. in bilateral meetings with Soviet
and other foreign analysts, and led a special strategic analysis in
support of the first Gulf War. His more than three dozen military
awards include the Bronze Star and the Purple Heart.
He is a graduate of the University of Illinois--Champaign, Golden
Gate University, the University of Illinois--Chicago, and Walden
University. He holds graduate degrees in Management and Public Policy
Analysis as well as a doctorate in Decision Sciences, and has published
extensively.
Chairman Wu. Thank you, Dr. Boyd.
Mr. Orr.
STATEMENTS OF DERECK ORR, PROGRAM MANAGER, PUBLIC SAFETY
COMMUNICATIONS SYSTEMS, NATIONAL INSTITUTE OF STANDARDS AND
TECHNOLOGY (NIST)
Mr. Orr. Chairman Wu, Ranking Member Smith, Members of the
Subcommittee, thank you for the opportunity to appear before
you today to discuss public safety communications and the P25
project.
The Public Safety Communications Research program, known as
PSCR, is a joint effort among NIST and NTIA [National
Telecommunications and Information Administration] at Commerce.
The PSCR serves as the technical lead for several
Administration initiatives focusing on public safety
communications. From the beginning, one of the core focus areas
of the PSCR has been to participate in the Telecommunications
Industry Association land mobile radio standards development
process. The vast majority of our first responders across the
Nation use land mobile radio systems every day to communicate
as they perform their missions. This includes the radios that
you see police officers or firefighters wearing on their belts.
Interoperability for these radios has been a problem as we
have seen in recent national emergency situations and achieving
interoperability is not possible without the existence of
published standards that define how the various components of a
public safety communications system will interoperate
regardless of manufacturer. In the absence of standards,
achieving this level of interoperability would not be possible.
Public safety users have recognized this for some time.
Approximately 20 years ago, representatives from local, state
and Federal public safety associations and agencies joined
together with industry to address the absence of available
standards for land mobile radios as they entered the transition
from analog to digital-based systems. Thus, Project 25, or P25
as we know it today, was launched. Based on our experience,
there are four main issues with P25 that are hampering progress
towards seamless interoperability and open competition.
First, since P25's inception in 1989, only one and a half
of the eight interfaces in the suite of the standards needed
for interoperability and competition as defined by P25 are
complete. Second, as a result of the lack of complete
standards, only a fraction of any P25 system purchased today is
truly standards based. Third, many public safety agencies
believe that when they purchase a system labeled P25 that it is
based on a complete set of standards. They interpret a P25
system to mean LMR [Land Mobile Radio] system that is fully
standards based. We believe it is important that public safety
agencies make their procurement decisions and valuations on a
realistic set of expectations. Fourth, there has been a lack of
industry-led compliance assessment and certification programs.
Compliance to the standard is essential and in fact every major
wireless technology we know of ensures interoperability among
devices and adherence to the standards by establishing rigorous
and comprehensive compliance assessment and certification
programs. P25 should be no different. We need to identify
problems with products or the standard in the lab, not in the
field.
NIST has been actively engaged on behalf of DHS in the P25
process to accelerate the adoption of standards. In addition,
to address the lack of a compliance testing program, DHS and
NIST partnered together to establish the Project 25 Compliance
Assessment Program. This is a government-led program outside of
the P25 standards development process and was created with
direction from Congress to ensure that Federal grant dollars
are being spent on communications equipment that will result in
interoperability and improve public safety's ability to protect
lives and property.
From the beginning, the P25 CAP was developed with the
expectation of incorporating all three types of tests,
performance, conformance and interoperability, into the
program. However, over the last year, an issue of including
conformance tests in the P25 CAP has arisen which has slowed
down our ability to launch a fully functional program. I want
to make clear: conformance tests are the one type of test that
ensures that a product adheres to the written standard and,
therefore, increases confidence that there will be
interoperability in the field. However, the general response
from industry was that only performance and interoperability
tests were necessary for compliance assessment.
DHS, NIST, other Federal partners and many public safety
users spent nearly a year trying to find an acceptable
resolution that would minimize the burden on industry while
maintaining the integrity of the P25 CAP through the inclusion
of all three types of tests. In the absence of achieving
consensus, and given public safety's insistence on the
inclusion of conformance tests in the P25 CAP, the program
moved ahead by including conformance tests for the most
recently published interface. I am pleased to say that over the
last two months we have witnessed a willingness within the P25
standards body to actively participate in the identification of
relevant conformance tests for the P25 CAP.
NIST hopes that within two years the P25 CAP is a fully
functional program including performance, conformance and
interoperability testing for at least the interfaces which are
crucial to interoperability. Achieving this will require
significant commitment and focus by all parties, and for its
part, NIST is prepared to assist in meeting this worthy goal.
NIST remains dedicated to continuing to work with this
Subcommittee, industry, our Federal sponsors and partners and
public safety users to see the P25 standards completed and to
develop programs to help public safety purchase interoperable
land-mobile radio equipment.
In conclusion, I want to thank Chairman Wu for his
leadership on interoperability standards for public safety
communications and for the positive effect his involvement has
had in moving this issue forward.
I am happy to answer any questions you may have.
[The prepared statement of Mr. Orr follows:]
Prepared Statement of Dereck Orr
Chairman Wu, Ranking Member Smith, Members of the Subcommittee,
thank you for the opportunity to appear before you today to discuss
Public Safety Communications and the P25 project. I serve as the
Program Manager for Public Safety Communications Systems in the Office
of Law Enforcement Standards (OLES) at the National Institute of
Standards and Technology (NIST). In addition, I am the Program Manager
for the Public Safety Communications Research (PSCR) program, which is
a joint effort among NIST and the National Telecommunications and
Information Administration (NTIA) at the Department of Commerce (DOC)
Labs located in Boulder, Colorado.
The Public Safety Communications Research (PSCR) program serves as
the technical lead for several Administration initiatives focusing on
public safety communications, most importantly the Department of
Homeland Security's (DHS) Office for Interoperability and Compatibility
(OIC) within the Science and Technology Directorate. The PSCR program
is also involved in many of DHS's key communications interoperability
related programs, including the SAFECOM Program within the Office of
Emergency Communications (OEC). The strong partnership among OIC,
SAFECOM and the PSCR program is an excellent example within the
Administration of multi-agency coordination and collaboration, and is
something for which we at NIST are very proud.
Working alongside our Federal partners, the PSCR program has
provided the lead technical role in some of the key advancements in
public safety communications over the last five years. NIST, in
partnership with OIC, has led the development of an open interface for
Voice-over-Internet Protocol (VoIP) public safety applications,
developed technical requirements for public safety video applications
to ensure that they meet the needs of public safety, so that, for
example, a police officer can properly identify suspects based on a
video. We have also scientifically corroborated concerns from the
public safety community that digital radios did not perform as well as
analog radios in loud noise environments. This has been particularly
important to the fire community whose communications were significantly
degraded at the time they would need to communicate most. In addition,
NIST has been heavily involved in the emerging public safety broadband
issue by leading, over the last several years, the technical committees
that have worked directly with public safety to define their
requirements for a nationwide public safety broadband system. We have
recently kicked off a project to develop and implement a broadband
demonstration system at the Boulder Labs that will focus on
understanding how the future fourth generation broadband standards will
and will not meet public safety's requirements for their mission
critical needs.
My DOC colleagues at the NTIA recently announced that it will make
Recovery Act broadband grants available to public safety entities that
this month received authorization from the FCC to build out broadband
public safety communications systems utilizing the 700 MHz band. I want
to note that my comments today are not related to those 700 MHz-based
broadband systems.
From the beginning, one of the core focus areas of the PSCR has
been to participate in the Telecommunications Industry Association
(TIA) Land Mobile Radio (LMR) standards development process. These are
the systems that the vast majority of our first responders use every
day across the Nation to communicate as they perform their missions.
These are the radios that you see police officers or fire fighters
wearing on their belts. As that is the topic of today's hearing, I will
focus the remainder of my remarks this morning on the current state of
the formal standards development and test programs for public safety
land mobile radio systems.
Interoperability for public safety communications is defined as
``the ability to share information via voice and data signals on
demand, in real time, when needed, and as authorized.'' The public
safety community expects that this level of interoperability will be
available using equipment from multiple manufacturers, that they are
transparent to the user requiring little or no special knowledge of the
system, and that they are not dependent on common frequency
assignments.
Achieving this definition of interoperability is not possible
without the existence of published standards that define how the
various components of a public safety communications system will
interoperate, regardless of manufacturer. In the absence of standards,
achieving this level of interoperability would not be possible.
Public safety users have recognized this for some time.
Approximately twenty years ago, representatives from local, state, and
Federal public safety associations and agencies joined together to
address the absence of available standards for Land Mobile Radios as
they entered the transition from analog to digital based systems. They
did this for two primary purposes. The first was to ensure that
interoperability could be achieved, assuming the use of equipment from
multiple manufacturers. Second, through standards, the public safety
community wanted to be able to take advantage of cost reductions
associated with a more competitive Land Mobile Radio market.
Understanding the difficulty in specifying the complex operations
of the various components of a land mobile radio system, the public
safety community partnered with the Telecommunications Industry
Association (TIA) to serve as the standards development organization
(SDO) for this effort. Thus Project 25, or P25 as we know it today, was
launched. For the last six years, PSCR has been an active participant
in the P25 standards process, especially in the development of test
standards.
A commonly misunderstood aspect of P25 is that it is comprised of a
single standard. Instead, it is a suite of standards that specify the
eight open interfaces listed below between the various components of a
land mobile radio system (e.g.: hand held to hand held, hand held to
base station, mobile unit to repeater, etc.):
Common Air Interface (CAI): this interface defines
the wireless access between mobile and portable radios and
between the subscriber (portable and mobile) radios and the
fixed or base station radios;
Inter-RFSubSystem Interface (ISSI): this interface
permits users in one system to communicate with users in a
different system, from one jurisdiction to another, from one
agency to another, from one city to another, etc.;
Fixed Station Interface (FSI): this interface
describes the signaling and messages between the RFSS and the
fixed station by defining the voice and data packets (that are
sent from/to the subscriber(s) over the common air interface)
and all of the command and control messages used to administer
the fixed station as well as the subscribers that are
communicating through the fixed station;
Console Sub-System Interface: this interface is
similar to the fixed station interface but it defines all the
signaling and (CSSI) messages between the RFSubSystem and the
console, the position that a dispatcher or a supervisor would
occupy to provide commands and support to the personnel in the
field;
Subscriber Data Peripheral Interface: this interface
characterizes the signaling for data transfer that must take
place between the subscriber radios and the data devices that
may be connected to the subscriber radio.
Network Management Interface: this interface allows
administrators to control and monitor network fault management
and network performance management.
Data Network Interface: this interface describes the
RFSSs connections to computers, data networks, external data
sources, etc.
Telephone Interconnect Interface: this interface
between the RFSS and the Public Switched Telephone Network
(PSTN) allows field personnel to make connections through the
public switched telephone network by using their radios rather
than using cellular telephones.
For any one of these eight interfaces to be considered complete (so
that multiple manufacturers can build and test to a common standard)
the following five types of standards documents have to be published:
Overview: serves as the general mission statement for
the interface;
Protocol: specifies the messages and procedures to be
followed in the development of equipment implementing the
interface;
Performance: specifies the test procedures to be
executed to ensure the device under test operates within the
expected bounds identified in the standard (i.e. emissions and
adjacent channel interference);
Conformance: specifies the test procedures to be
executed to ensure the device under test produces messages that
adhere to the message format and procedures detailed in the
protocol document;
Interoperability: Specifies the test procedures to be
executed to determine if two or more different devices under
test respond appropriately when communicating over the
interface.
The most important of these documents is the protocol document
which provides the details needed by each manufacturer to develop
products that implement the particular interface. However, of only
slightly less importance are the three test documents that allow each
manufacturer to comprehensively test their implementations in a common
way so as to limit variant interpretations of the protocol and ensure
overall uniformity in product development. In addition, uniformity in
implementation of the interfaces is crucial for seamless
interoperability.
Based on our experience, there are four main issues with P25 that
are hampering progress toward seamless interoperability and open
competition.
1) Standards for all eight interfaces are not published.
2) Only a portion of P25 systems are standards based.
3) It isn't clear to public safety agencies what a P25 system
entails.
4) There is no industry-led formal compliance assessment
program.
To date, only the conventional portion of the CAI and the Inter-RF-
Subsystem Interface have a completed suite of documents as defined
above. The more complex trunked CAI continues to lack conformance test
documents (crucial for uniform implementation) although trunked CAI
products have been sold for almost a decade. The remainder of the six
interfaces are in various states of document completion. Therefore,
since its inception in 1989, one and a half of the eight interfaces
have been completed.
Second, as a result of the lack of complete standards, only a
limited portion of a P25 system is truly standards based. To our
knowledge, only the CAI is currently supported in most P25 system
deployments, although some jurisdictions are now on the verge of
procuring the recently completed ISSI, and ISSI manufacturers are
piloting this new interface in several locations across the United
States.
Third, many public safety agencies believe that when they purchase
a system labeled P25, that it is based on a complete set of standards.
They interpret a ``P25 system'' to mean a LMR system that incorporates
the P25 interfaces. Most public safety agencies do not have the,
resources to dedicate to researching the status of the complex
standards process so that they have a clear picture of what a ``P25
system'' currently entails. The reason we, and our partners, try to
provide outreach to as many public safety agencies as possible is that
we believe it is important that they make their procurement decisions
and valuations on a realistic set of expectations.
Fourth, there has been a lack of a compliance assessment and
certification programs. As mentioned above, compliance to the standard
is essential and in fact every wireless technology we know of ensures
interoperability among devices by establishing rigorous and
comprehensive compliance assessment and certification programs.
Successful completion of the compliance assessment process often
results in limited rights to the use of a certification logo (i.e.
Bluetooth, Wi-Fi, or WiMAX) which is intended to impart to consumers
the fact that the product has been tested in some type of formal
process and should be expected to work with other devices with the same
logo.
In the case of P25, the industry participants never established a
formal and uniform compliance assessment and certification program.
Instead, testing to determine P25 compliance was performed by each
manufacturer in whatever manner they each determined was sufficient for
validation of their products. There has been no industry led formal
test regime and there is no certification process or stamp for P25
products.
The P25 logo has instead been used by manufacturers as a marketing
logo to convey to users that their product was developed to P25
standards specifications. However, many public safety agencies that we
speak with incorrectly assume that the logo is a certification stamp
signifying the completion of a formal and uniform test regime.
To address the first three issues, NIST has been actively engaged
on behalf of DHS in the P25 process to accelerate the adoption of
standards. To address the lack of a compliance testing program DHS and
NIST partnered together to establish the Project 25 Compliance
Assessment Program (P25 CAP). This is a government-led program outside
of the P25 standards development process, and was created with
direction from both Commerce and DHS appropriations committees in order
to ensure that Federal grant dollars are being spent on communications
equipment that will result in interoperability and improve public
safety's ability to protect lives and property. Additionally, this
program is designed to provide greater clarity to public safety
agencies regarding the status of the P25 standards, and to, more
importantly, provide them with a higher level of confidence that the
products they are purchasing will interoperate with other P25 products.
In this partnership, NIST performs the lab assessments and DHS develops
the overall program policy, as well as recognizing participating
laboratories. This program has been developed over the last five years
and is comprised of several key elements:
Test Standards: P25 CAP uses published P25
performance, conformance, and interoperability test standards.
Whenever possible, the P25 CAP looks for guidance from the P25
technical committees and manufacturers for input on what tests
are most applicable. In addition, the P25 CAP only uses a
subset of available P25 tests. The subset of tests are
published in DHS P25 CAP Compliance Assessment Bulletins.
Interfaces: The P25 CAP is currently focused on the
two P25 interfaces (CAI and ISSI) that are crucial to
interoperability and that will help achieve the nation-wide
system of system's approach supported by the DHS SAFECOM
Program.
Lab Recognition: The P25 CAP utilizes recognized
laboratories that have been assessed and recommended by PSCR
personnel based on adherence to appropriate portions of
international laboratory testing standards and on their
competence at executing the P25 tests specified in the DHS P25
Compliance Assessment Bulletin. If a laboratory successfully
completes the assessment phase, DHS issues a Certificate of
Recognition which signifies their ability to participate in the
P25 CAP.
Manufacturer Participation: The P25 CAP is a
voluntary process and relies on vendor participation for its
success. To be in compliance with the P25 CAP, participating
vendors must have their equipment tested in a DHS recognized
laboratory and must post the results of the testing at a
publicly accessible DHS website (www.rkb.us).
Federal Grant Guidance: The P25 CAP is required in
the SAFECOM Federal Grant Guidance which applies to DHS grant
programs and is leveraged by other Federal agencies as well,
such as the Department of Justice's COPS Office. The grant
guidance limits P25 equipment purchases to products that have
been tested in P25 CAP recognized labs and have the proper
documentation posted on the RKB website. This helps ensure that
all Federal investments support standards-based equipment and
interoperability.
The P25 CAP was developed with involvement from both the industry
and the public safety community. The goal of the program is to increase
public safety's confidence that P25 products being purchased will
operate and interoperate, based on a formal and uniform test program,
while at the same time minimizing the financial burden that
implementing a voluntary compliance program might place on the P25
industry. Therefore, it should be noted that the resulting program is a
minimalistic compliance assessment program. It does not rise to the
level of rigor imposed by the wireless technologies mentioned above or
that of the European public safety communications standard, TETRA. The
P25 CAP does not involve third party certification and does not lead to
a certification stamp. The program instead requires that a manufacturer
publish a Supplier's Declaration of Compliance which specifies the
product tested, the tests performed, and the DHS recognized lab used to
perform the test. The manufacturer must also publish a Summary Test
Report (STR) that provides pass/fail data for each of the tests
required by DHS. The SDoC and STR are posted by the manufacturers on a
DHS website (www.rkb.us). Public safety agencies using Federal grant
dollars can only purchase P25 equipment with published documents
available on the DHS website. In addition to testing information being
publicly available, the equipment will have been tested in laboratories
that have demonstrated an adequate quality management system and P25
testing proficiency. In striking this balance our hope is increase the
amount and quality of information available to the public safety
community, while at the same time creating a minimalistic program that
will gain wide-spread industry participation.
To date, DHS has recognized eight laboratories to perform the
current CAI tests required by the P25 CAP program. As of November 2009,
all DHS grantees purchasing P25 CAI related equipment are required to
ensure that the equipment is in compliance with the P25 CAP guidelines,
prior to taking final acceptance. Currently there are four
manufacturers who have complied with the current requirements of the
P25 CAP. All four have published information on their subscriber units
(walky-talkies) which is out of the approximately eleven manufacturers
that make P25 subscriber units (36% participation rate). In addition,
two of the four manufacturers have published documents relating to
their infrastructure (base stations, etc.) which is out of
approximately eight manufacturers that make P25 infrastructure--a 25%
participation rate.
The publication of this information is a significant milestone for
public safety. For the first time, public safety officials have one
place that they can go to obtain test results performed through a
formal process and whose results are presented in a common manner,
making comparisons between manufacturers' products much less time
consuming. In fact, we are aware of multiple public safety agencies
using the P25 CAP in their procurement decisions and evaluation.
However, the participation rate must increase for the program to be
truly effective.
It must also be noted that the current program covering the CAI
includes only performance and interoperability tests. This is due to
the fact that at the time of the publication of the DHS P25 CAP
Compliance Assessment Bulletin in 2008, there were no relevant
published CAI conformance tests to draw from.
Since 2008, conformance tests have been published for the
conventional CAI, and the PSCR program and its Federal partners are
currently working with the manufacturers and public safety users within
the standards committees to determine the appropriate tests to
incorporate into the P25 CAP. Although we are hopeful that we will be
able to identify existing, and where needed develop, appropriate
conformance tests for the conventional CAI, it must be noted that the
issue of conformance testing has been a significant problem within the
P25 standards community over the last year.
From the beginning, the P25 CAP was developed with the expectation
of incorporating all three types of tests (performance, conformance,
and interoperability) into the program. This expectation was
articulated in program documents, charters, and presentations. Many
manufacturers echoed this expectation in their own documents and
presentations. However, as was noted above, the issue of conformance
tests did not develop until after the drafting of the first DHS P25 CAP
Compliance Assessment Bulletin because at the time of publication there
were no published conventional or trunked CAI conformance tests to draw
from.
Leveraging published conformance tests into the P25 CAP became an
issue for the first time in April 2009 during the development of the
recommended set of tests for the ISSI. Because published conformance
tests for the ISSI were available for consideration, the PSCR
recommended a subset of the published conformance tests for inclusion
into the P25 CAP. The general response from industry to this
recommendation was that it was not their intent that the P25 CAP would
include conformance testing, and should instead focus on performance
and interoperability testing for compliance assessment. At that time,
the PSCR as well as our Federal partners and many of the public safety
users participating in the meetings reiterated the expectation that the
P25 CAP would incorporate conformance testing.
The rationale for this was, and remains, that at the core of any
compliance assessment or conformity assessment program is the
expectation that products will be tested to ensure that they adhere to
the messages and procedures mandated by the standard. Interoperability,
especially in the wireless field, is achieved through consistent
implementation of the interface standard across products and
manufacturers. If consistency in implementation is achieved, and the
protocol standard is unambiguous, then the expectation of
interoperability is significantly increased, though not guaranteed. By
implementing conformance testing in the P25 CAP, the program is
ensuring that each product tested is traceable to the published
standards.
The reliance on conformance testing is common across wireless
technology certification programs, all but one of which is developed
and administered by their relevant wireless industry associations and
interest groups such as Wi-Fi, Bluetooth, WiMAX, and LTE. The non-
industry conformance testing example is the European public safety
communications standard, TETRA. The TETRA compliance assessment program
is a joint program between government and industry, and relies heavily
on conformance testing as well. To exclude conformance testing from the
P25 CAP would make it, to our knowledge, the only wireless technology
compliance assessment program to do so. In fact, several of the
manufacturers of P25 equipment also develop TETRA products, as well as
other wireless devices for the standards listed above and submit their
other products for conformance testing as required by the respective
programs. As I have stated previously, the P25 CAP is already a
minimalistic program. All of the programs listed above are
significantly more rigorous and resource intensive. Removing
conformance testing from the program would call into question its
ability to achieve the goals of confidence and interoperability it was
established to address. Given the critical importance of the radio
equipment to both the first responders and the citizens they serve, we
cannot recommend such a course.
All of the programs mentioned above also rely heavily on
interoperability tests, as does the P25 CAP. However, interoperability
tests only demonstrate whether two different products work together. A
successful interoperability test result does not demonstrate that the
products adhere to the standard. In addition, you cannot infer that
because two different manufacturers' products interoperate that either
will be interoperable with a third manufacturer. Interoperability must
be confirmed with a direct test with another product, or in some cases
a test against a reference model which does not exist in the P25
industry.
Interoperability testing in any industry is resource intensive,
requiring significant coordination among all manufacturers.
Understanding this, the P25 CAP requires that participating
manufacturers only demonstrate interoperability with three other
manufacturers' products, thus limiting the number of coordinated tests
required. Conformance tests, on the other hand, can be performed
without any other manufacturer's equipment present.
Finally, Land Mobile Radio equipment is designed to be fielded for
years if not decades. Therefore, it is highly likely that products
fielded today will be operating alongside new products fielded ten or
even twenty years from now. However, there is no requirement that
manufacturers test future products against past products. To do so
would create an exponential growth in the number of tests required, and
would place an unfair financial and administrative burden on any P25
equipment manufacturer. Instead, by including conformance testing in
the program, products released today, as well as ten years from now,
will show traceability to the same standards, thereby increasing the
confidence in interoperability while minimizing the testing required.
NIST and DHS staff presented this rationale to the relevant
committees within P25 and worked for months to develop an acceptable
list of tests (at one point only proposing 18 conformance tests out of
the full set of 92). However, the final recommendation out of P25 to
DHS was that no conformance tests should be included in the P25 CAP for
the ISSI. DHS at that point developed a list of conformance tests, with
input from Federal, state, and local P25 system owners and/or managers
and published an ISSI Compliance Assessment Bulletin in March of this
year. The P25 CAP program is now awaiting applications from
laboratories interested in performing ISSI testing.
There were indications within the standards committee that there
would be similar resistance to including conformance testing for
compliance assessment for the other interfaces, including the common
air interface.
However, the tide has turned. I am pleased to say that over the
last two months we have witnessed a renewed willingness within the P25
standards body to actively participate in the identification of
relevant conformance tests for the P25 CAP. We are currently working
within the standards committees to identify and develop a recommended
set of conformance test for the conventional CAI, and we hope to see
significant and expedited progress on developing conformance tests for
trunked CAI equipment.
It is frustrating to many that we are only now implementing a
compliance testing program over a decade after the products have been
released into the marketplace. And it is true that the program will not
have a significant impact on the currently installed base. But what is
important to keep in mind is that the Federal Government's significant
investment in communications equipment for first responders and other
law enforcement agencies will drive procurement decisions. In addition,
there are thousands of agencies that will be upgrading their aging Land
Mobile Radio systems over the next decade, and most will likely adopt
the P25 standard. The P25 CAP will have a significant impact on these
future purchases and will improve the likelihood that interoperability
can be achieved.
NIST hopes that within two years, the P25 CAP has a fully
functional program including performance, conformance, and
interoperability testing for at least the CAI and ISSI interfaces which
are crucial to interoperability. Achieving this will require
significant commitment and focus by all parties, and for its part, the
NIST is prepared to assist in meeting this worthy goal. NIST remains
dedicated to continuing to work with this Subcommittee, industry, our
Federal sponsors and partners, and public safety users to see the P25
standards completed and to develop programs that help public safety
purchase interoperable Land Mobile Radio equipment.
Again, I am honored to be here before this Subcommittee today, and
I am happy to answer any questions that you may have.
Biography for Dereck Orr
Dereck Orr is the Program Manager for Public Safety Communication
Standards at NIST's Office of Law Enforcement Standards, and has held
that position since December 2002.
In that role, he leads a program that serves as an objective
technical advisor and laboratory to the Department of Homeland Security
and public safety to accelerate the adoption and implementation of the
most critical public safety communication standards and technologies.
From October 2003 until October 2004, Mr. Orr was detailed to the
Department of Homeland Security to serve as the Chief of Staff of the
SAFECOM Office within the Science and Technology Directorate, to help
establish the new program.
Prior to working at NIST, Mr. Orr served as a professional staff
member of the Senate Appropriations Subcommittee for the Departments of
Commerce, Justice, and State, and Related Agencies under Senator Fritz
Hollings. In that position, Mr. Orr was responsible for the
appropriations accounts relating to state and local law enforcement
issues.
Previously, Mr. Orr served four years at the Office of Community
Oriented Policing Services (COPS) at the Department of Justice.
Mr. Orr received a Masters in Public Policy from the College of
William and Mary and a Bachelor of Arts in American History from the
University of Texas at Austin.
Chairman Wu. Thank you very much, Mr. Orr.
Dr. Hofmeister, please proceed.
STATEMENTS OF ERNEST L. HOFMEISTER, SENIOR SCIENTIST, HARRIS
CORPORATION
Dr. Hofmeister. Thank you, Chairman Wu.
Chairman Wu and distinguished Members of the Subcommittee,
thank you for inviting me to testify on the interoperability in
public safety communications equipment.
Chairman Wu. Dr. Hofmeister, have you pressed your button?
Have you turned your mic on?
Dr. Hofmeister. It says ``talk'' here.
Chairman Wu. Maybe a little bit closer.
Dr. Hofmeister. I will try this. How is that?
Chairman Wu. Terrific.
Dr. Hofmeister. Well, thank you again for allowing me to
testify.
There are a number of technology approaches to achieve
increasing levels of interoperability, going from swapping
radios, to gateways, to shared channels, to proprietary shared
systems, to standards-based shared systems. Harris believes
that all of these approaches are deployed today to achieve
varying levels of interoperability.
At the upper end of the interoperability capability are
standards-based shared systems. The predominant standard for
these systems in the United States is the TIA-102
[Telecommunications Industry Association] P25 suite of Project
25 standards. The number of deployed P25 systems is increasing
and the level of interoperability across these systems provided
by different vendors is increasing, and with radios provided by
different vendors.
As a quick standard summary, the TIA-102 P25 standard suite
consists of approximately 69 published standards with about 13
in ballot as new, revised or addendum standards, and with about
15 in draft. This suite addresses 11 defined Project 25
interfaces in the categories of service, the system and
equipment. The P25 interfaces critical for interoperability and
competition (the common air interface [CAI], the inter-RF
subsystem interface [ISSI], and the fixed station interface
[FSI]) are specified in more detail in the current suite than
some others.
While some not involved in the standards development
process may comment that standards development takes a long
time, the TIA process, like other standards development
organizations, is a consensus-based process by design. The
standards are developed by top engineers from industry who have
the knowledge and perspective to assure successful product
implementation to the standard. Getting to consensus and
developing the requisite detail of the standard takes time but
the resultant standard product is technically solid and long-
lasting.
Harris believes that since 2005 the standards pace is at
full industry and user support capacity. We have many meetings
where everybody is making contributions, so we are kind of
working at capacity that we have, I believe, in the industry.
Now, there were several questions asked, and I am going to
try to answer what I can in the testimony here. One was, what
is the status of public safety land mobile radio standards in
terms of meeting the original P25 goals of enabling
interoperability, competition among vendors, spectrum
efficiency, graceful migration and user-friendly equipment?
Harris believes that the P25 community has made strong progress
in meeting each of these cited goals: specifically, the first
three. For enabling interoperability for radios and radio
infrastructure, detailed common air interface radio product
design and interoperability test standards are in place and
multiple vendor radio products and infrastructure radio
products have demonstrated a high functional level of
interoperability through the form of CAI interop testing as
part of the CAP program over the last year. As Dr. Boyd
mentioned, over 20 radio products or radio classes from four
vendors have been approved with Suppliers' Declarations of
Compliance posted to the official website.
For enabling interoperability with systems and networks,
detailed ISSI baseline product design and interoperability test
standards are in place. The P25 CAP requirements are in place.
The first ISSI products are emerging. Informal ISSI
interoperability testing among a number of vendors has already
taken place. Formal ISSI interoperability testing as part of
the P25 CAP is expected over the next year.
And for competition among radio vendors, fairly strong
competition among radio vendors has developed with over 15
vendors providing P25 radio products across a variety of
frequency bands. Competition among P25 system and network
vendors has developed with five vendors supplying P25 systems.
Almost all large P25 system procurements have a separate system
and infrastructure procurement and user radio procurement, so
there is competition on both levels.
For spectrum efficiency, from the start the P25 common air
interface provided the 12.5 kilohertz narrowband capability and
voice efficiency required by 2013 for ``narrowbanding'' the
below 512 band and now in the 700 megahertz public safety band.
The P25 phase 2 common air interface for two-slot TDMA [time
division multiple access] (two users in 12.5 kilohertz), well
along in development, will enable meeting the 6.25 kilohertz
per voice path requirement for the 700 megahertz band ahead of
the January 1, 2017 deadline, as well as the future unspecified
requirement for the below 512 band.
What mechanisms exist for customers to have confidence that
P25 equipment will be interoperable and function as intended?
There are several layers in place. First, P25 manufacturers
design and extensive internal product verification test
processes are already in place by Harris, and others. There is
past industry practice. The manufacturers with deployed or
deploying systems developed a practice of communicating and
resolving cited interoperability issues. P25 CAP is another
layer that has been installed recently. The DHS-recognized labs
are implementing the P25 CAP that performs formalized testing
to the standards and requirements to provide additional
assurance of interoperability, performance, and conformance (to
the standards) for critical interfaces. Harris supports a
solid, practical DHS P25 CAP program and associated testing for
the benefit of our customers, other public safety agency users,
and manufacturers. Harris developed and maintains a DHS-
recognized compliance laboratory.
In addition, as part of procurement requirements,
procurement agencies have the ability to specify special tests
as part of the procurement and we are seeing that specification
more frequently.
So Chairman Wu and other Members, thank you for the
opportunity to testify today and share with you the Harris
views on interoperability in public safety communications
equipment. Interoperability is a multidimensional challenge
that involves five interdependent elements: governance,
standard operating procedures, technology including standards,
training and exercises, and usage. The level of
interoperability achieved depends on the progress in each of
the elements and the coordination and management of the five
elements. My remarks have focused on the practical technical
solutions.
For the higher levels of interoperability, Harris believes
that while more work is needed, strong progress has been made
in recent years through the continued P25 standards
development, the CAP testing and the public safety procurement
requirements. The product P25 standards, the testing standards
and the product features are in place or soon will be in place
to enable a solid level of P25 trunked and conventional system
interoperability.
Thank you, Mr. Chairman. I would be happy to answer any
questions. Thank you.
[The prepared statement of Dr. Hofmeister follows:]
Prepared Statement of Ernest Hofmeister
INTRODUCTION
Chairman Wu and distinguished members of the Subcommittee, thank
you for inviting me to testify on ``Interoperability in Public Safety
Communications Equipment.''
I am a senior scientist in the Public Safety and Professional
Communications (PSPC) group of the RF Communications Division of the
Harris Corporation. I have worked as an engineer/scientist and
technical manager in the Land Mobile Radio (LMR) business for over 17
years for Harris and the predecessor companies of Tyco Electronics (M/
A-COM) and Ericsson GE. For the last ten years I have been leading the
business' LMR TIA-Project 25 standards participation.
Harris strongly supports the TIA-P25 standards development and has
identified more than 12 top senior Harris engineers to work on TIA-P25
standards development. A number of these senior engineers hold chair or
vice-chair leadership positions in TIA and P25 subcommittees. For the
last six years I have served as chair of two subcommittees involved in
critical standards development: the TIA TR-8.12 two-slot TDMA
subcommittee (next generation air interface) and the APIC Vocoder Task
Group (speech coding standards). I also represent Harris on the P25
Compliance Assessment Program matters in the P25 community. From 1999-
2003, I served on the Steering Committee of the Public Safety National
Coordination Committee (NCC) FACA advising the FCC on interoperability
channels/standards for the emerging 700 MHz public safety spectrum.
LMR products and associated standards represent the core business
of Harris PSPC. Harris PSPC is a leading supplier of assured
communication systems and equipment for public safety, Federal,
utility, commercial, and transportations markets--with products ranging
from the most advanced IP voice and data networks, to industry leading
multiband, multimode radios, to public safety-grade broadband video and
data solutions. With more than 80 years of experience, Harris PSPC
supports over 500 systems around the world.
Harris PSPC is a full capability P25 supplier with a full range of
P25 radio products, systems, networks and services with over 50 P25
systems either fully deployed or currently being deployed in North
America. Harris PSPC support of the P25 standard extends beyond
products alone. The Harris P25 Compliance Assessment Laboratory in
Lynchburg, VA was one of the first labs recognized by DHS as an
interoperability and performance testing compliance lab to satisfy the
DHS Compliance Assessment Bulletin (CAB) requirements for the P25 Ph 1
Common Air Interface. This facility has hosted several formal P25 CAP
interoperability tests with P25 suppliers such as Motorola, E.F.
Johnson, Kenwood, Tait, ICOM and Technisonic. Harris invests
significant resources each year in the P25 standard process, product
development and compliance assessment testing.
OVERVIEW COMMENTS ON PUBLIC SAFETY COMMUNICATIONS INTEROPERABILITY
Harris agrees with the description and characterization of
interoperability on the DHS SAFECOM Interoperability website page \1\
and in the DHS Interoperability Continuum Brochure: \2\
---------------------------------------------------------------------------
\1\ http://www.safecomprogram.gov/SAFECOM/interoperability/
default.htm
\2\ Interoperability Continuum, A tool for improving emergency
response communications and interoperability, U.S. DHS, from website
http://www.safecomprogram.gov/SAFECOM/interoperability/default.htm,
file
Interoperability-Continuum-Brochure-2.p
df
What is communications interoperability? Wireless
communications interoperability specifically refers to the
ability of emergency response officials to share information
via voice and data signals on demand, in real time, when
---------------------------------------------------------------------------
needed, and as authorized.
Interoperability is a multi-dimensional challenge
involving five interdependent elements as illustrated in the
diagram from the Interoperability Continuum Brochure:
The overall topic of Interoperability in Public Safety
Communications Equipment and the subtopics of P25 standards status,
customer confidence that P25 equipment will be interoperable, and
recommendations on timely standards development and compliance
assessment processes fall into the TECHNOLOGY element, so the remainder
of the Harris testimony will focus on the TECHNOLOGY ELEMENT.
TECHNOLOGY ELEMENT INCLUDING LMR STANDARDS STATUS
Technology Approaches--``Technology, including standards, for voice
and data communications is a critical tool for improving
interoperability, but it is not the sole driver of an optimum
solution.'' \3\ As displayed in the Technology bar of the
Interoperability Continuum, there are a number of approaches to achieve
increasing levels of interoperability: swapping radios, gateways,
shared channels, proprietary shared systems, and standards-based shared
systems. Harris believes that all of these approaches are deployed
today to achieve varying levels of interoperability.
---------------------------------------------------------------------------
\3\ From reference cited in footnote 2.
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Several gateway products on the market enable effective
interoperability among legacy analog communication systems and more
modern digital communications systems. While the LMR radio spectrum is
fragmented and split into multiple RF bands, certain bands through
regulatory rules and/or frequency coordination practice have set aside
subsets of channels to be shared for interoperability. In particular,
the narrowband portion of the 700 MHz public safety band has a number
of dedicated interoperability channels with the guidelines and standard
(P25 Ph 1 conventional) specified. The 800 MHz public safety band has
set aside mutual-aid channels for interoperability.
The emergence of multi-band, multi-protocol radios that can
communicate on several or all of the LMR bands with multiple radio
protocols will enable increased levels of interoperability in the
future. There are a number of proprietary shared systems where there
are gateways as well as agreements and shared protocols in place to
enable interoperability across these systems.
At the upper end of interoperability capability are standards-based
shared systems. The predominant standard for these systems in the U.S.
is the TIA-102 P25 suite of Project 25 standards. The number of
deployed P25 systems is increasing and the level of interoperability
across these systems provided by different vendors is increasing as
well with radios also supplied by different vendors.
Standards Status Summary \4\--As noted, the predominant LMR public
safety standard in the U.S. is the TIA-102 P25 suite of Project 25
standards.\5\
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\4\ Status from three TIA documents: PN-3-3591-UGRV1 (to be
published as TIA-102), Project 25 System and Standards Definition, TIA
Standard, January 2010 (in review for ballot in TIA-TR-8 committee);
TR8docs.xls (Apr 28, 2010); and TR8proj.xls (Apr 28, 2010).
\5\ The P25 standards have and continue to be developed under an
MoU agreement between the Telecommunications Industry Association (TIA)
as a sanctioned Standards Development Organization and the Project 25
Steering Committee representing APCO, NASTD, and the Federal Gov't
Project 25 started in 1989 and has developed and
continues to develop multiple standards in conjunction with TIA
and in response to the user/practitioner driven Project 25
Statement of Requirements (SoR). The SoR evolves to reflect new
user requirements and corresponding new and updated standards
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are developed.
Currently, the TIA-102 P25 standards suite consists
of approximately 69 published standards with about 13 in ballot
as new, revised, or addendum standards, and with about 15 in
draft. This suite addresses 11 defined Project 25 interfaces in
the categories of service, system, and equipment.
The P25 interfaces critical for interoperability and
competition [the common air interface (CAI), the inter-RF
subsystem interface (ISSI), and the fixed station interface
(FSI)] are specified in more detail in the current suite than
some other interfaces.
The focus of the P25 standards development effort
over the last couple of years is:
P25 CAP--developing the bulletins and standards
associated with implementation of the P25 Compliance
Assessment Program for the P25 Ph 1 trunked FDMA CAI,
the ISSI, the Ph 1 conventional CAI, and then the P25
Ph 2 trunked TDMA CAI.
P25 Ph 2 TDMA CAI--completing the standards suite
for the P25 Ph 2 trunked TDMA CAI for doubled capacity
and 6.25 kHz per voice path spectral efficiency. The
core definition standards needed for product
development are complete or nearly ready for ballot.
The associated test and measurement documents for
performance, interoperability, and conformance are well
along in the drafting stage.
ISSI Scopes 2 and 3--completing Scopes 2 and 3 for
the ISSI suite of standards. The Scope 1 standards are
complete, support product development, and are mature
for procurement. The core definition Scope 2 and 3
documents are well along with the supporting
measurement documents in drafting. The P25 console
interface standard (CSSI) is a subset of the ISSI
standard suite.
Security--completing the Inter KMF interface
standards and encryption updates.
While some not involved in the standards development
process might comment that standards development takes a long
time, the TIA process, like other Standards Development
Organizations, is a consensus based process by design. The
standards are developed by top engineers from industry who have
the knowledge and perspective to assure successful product
implementation to the standard. Getting to consensus and
developing the requisite detail of the standard takes time, but
the resultant standard product is technically solid and long
lasting.
Question 1a: What is the status of the public safety land mobile radio
standards process in terms of meeting the original Project 25 goals of
enabling interoperability, competition among vendors, spectrum
efficiency, graceful migrations from legacy systems, and user-friendly
equipment?
Harris believes that the P25 community has made strong progress in
meeting each of the cited original P25 goals.
Enabling interoperability--radios & radio
infrastructure: Detailed CAI radio product design and
interoperability test standards are in place and multiple
vendor radio products and infrastructure radio products have
demonstrated a high functional level of interoperability
through the formal CAI interoperability testing as part of the
P25 Compliance Assessment Program (CAP) over the last year. As
of May 24, 2010, twenty vendor radio products (or radio model
classes) from four vendors (EF Johnson, Harris, Motorola, and
Tait) have approved Suppliers Declaration of Compliance (SDoCs)
posted to the official RKB website for information and review
by public safety agencies and practitioners.
Enabling interoperability--systems & networks:
Detailed ISSI baseline product design and interoperability test
standards are in place. P25 ISSI CAP requirements are in place.
The first ISSI products are emerging. Informal ISSI
interoperability testing among a number of vendors has taken
place. Formal ISSI interoperability testing as part of the P25
CAP is expected over the next year.
Competition among vendors: Fairly strong competition
among radio vendors has developed with over 15 \6\ vendors
providing P25 radio products across a variety of frequency
bands. Competition among P25 system and network vendors has
developed with five vendors supplying P25 systems. Almost all
large P25 system procurements have a separate system/
infrastructure competition and user radio competition.
---------------------------------------------------------------------------
\6\ P25 radio or related product vendors include: Harris, Motorola,
EF Johnson, EADS, Tait, Kenwood, ICOM, Daniels, Reim, Datron, Thales,
Teltronic, Technisonic, Zetron, and Futurecom.
Spectrum efficiency: From the start, the P25 Ph 1
FDMA CAI provided the 12.5 kHz narrowband capability and 12.5
kHz per voice path spectral efficiency required by 2013 for
``narrowbanding'' the below 512 MHz band and now in the 700 MHz
band. The P25 Ph 2 TDMA CAI (two users in 12.5 kHz) standards,
well along in development, will enable meeting the 6.25 kHz per
voice path requirement for the 700 MHz band ahead of the Jan 1,
2017 deadline as well as the future (unspecified) requirement
for the below 512 MHz band. In addition to satisfying the
regulatory requirements, the P25 Ph 1 and Ph 2 CAIs are
efficient in using the scarce public safety spectrum. The P25
Ph 2 CAI essentially doubles the capacity of a P25 Ph 1 system.
In addition, both the P25 Ph 1 and Ph 2 CAIs are or will be
deployed using trunking and simulcast techniques for enhanced
---------------------------------------------------------------------------
spectral efficiency.
Graceful migrations from legacy systems: Over the
years, the P25 system vendors have successfully migrated many
of their legacy customers to P25 according to the customer
needs and plans and without disruption of mission critical
communications. Harris has successfully migrated a number of
its EDACS customers to P25 according to their needs and plans
and there are a number of migrations in the planning process
now.
User-friendly equipment: Harris believes that P25
equipment is user-friendly, but, because of its complexity,
formal training is highly recommended for the user to obtain
the maximum benefit with efficiency. Harris believes that all
P25 equipment vendors provide user manuals and offer formal
training for their products.
Question 1b: How does the status of the standards process impact the
communications equipment that public safety officials are buying today?
While the standard suite will continue to evolve with
new and revised standards (otherwise the standards are dead) in
response to the changing P25 SoR, Harris believes the current
suite of P25 standards are rich and mature with corresponding
products from several vendors so the public safety procurements
can be assured of competition and functional capability to
match the public safety user needs. The current suite,
including the P25 Ph 1 FDMA CAI and the baseline ISSI offer a
very solid and rich set of public safety features. There have
been many P25 procurements over the last few years with a
number underway now based on the current P25 standards suite
and products.
Almost all procurements specify a future smooth
migration to new features on particular interfaces. Early
adopters are specifying the coming P25 Ph 2 TDMA CAI for
capacity and spectral efficiency or a definite migration
timeline with committed costs to P25 Ph 2.
Question 2: What mechanisms exist for customers to have confidence that
P25 equipment will be interoperable and function as intended?
P25 Manufacturer Design and Extensive Internal
Product Verification Testing Processes: Harris follows rigorous
internal product design, test, and verification processes to
achieve the highest practical assurance that our products meet
design requirements, including standards, and have been tested
to demonstrate the features offered in the product at both the
product level and the system level. Harris follows a Stagegate
Product Development Process consisting of five thresholds
leading to production as part of the Harris Quality Management
System that is registered and conforming to the requirements of
ISO 9001:2008. Formal product and systems testing conducted by
the Harris Systems Integrity group consists of Engineering
Verification Testing (EVT), Systems Integration & Verification
Testing (6 months), and finally Final System Validation
Testing including Field Validation Testing (3-4 months).
Formal P25 Compliance Assessment Program (P25 CAP) testing for
the performance, interoperability, and conformance scopes as
appropriate for the P25 interfaces within the P25 CAP is
performed in a DHS Recognized P25 CAP Laboratory.
Past/Current Industry Practice: Prior to the
implementation of the P25 CAP, customers with a
interoperability/function concern went directly to the
manufacturer. If satisfaction was not received, the customer
could go to the appropriate TIA-P25 subcommittee for
resolution. This process continues today. A few years ago,
there were a number of issues identified in P25 systems being
deployed and these issues were treated in an informal Hosted
Manufacturers Interoperability Board (HMIB). After resolution
of this set of issues, the HMIB was transitioned into the
formal TIA TR-8.25 P25 Compliance Assessment subcommittee. In
many cases, interpretation of the standard created the issue
and the solution was to clarify the standard with revisions and
upgrades. The majority of this standards cleanup work has been
done. Products compliant with the newer standard versions
should not have issues of interoperability. Also, in many
cases. for newer interfaces the standards are consensus
``Greenfield'' so challenges with legacy implementations should
be much reduced.
As a result of the HMIB and associated activity, the
P25 manufacturers with deployed or deploying systems
developed a practice of communicating and resolving
cited interoperability items. There are communications
between the systems experts of Harris and Motorola on
cited interoperability items so that these items can be
understood and resolved. Over the last few years,
vendors have deployed multiple P25 systems that are
operational with radio user equipment from one or
several other vendors. Harris has at least two deployed
and operational P25 systems for which all the user
radios are supplied by other vendors.
P25 CAP: Recently, DHS recognized laboratories are
implementing the P25 Compliance Assessment Program (CAP) that
performs formalized testing to standards and requirements to
provide additional assurance of interoperability, performance,
and conformance (to the standards) for critical P25 interfaces.
The results of the formal P25 CAP testing for the product under
test are documented in SDoCs (Supplier's Declaration of
Compliance) and STRs (Summary Test Reports). The SDoCs and STRs
are reviewed by DHS and posted to the reference repository, the
RKB (Responder's Knowledge Base) available to public safety
procuring agencies and practitioners. The P25 interfaces
incorporated into the P25 CAP are: the P25 Ph 1 trunked FDMA
CAI, the ISSI, the P25 Ph 1 conventional FDMA CAI, and then the
P25 Ph 2 trunked TDMA CAI.
Harris supports a solid, practical DHS P25 Compliance Assessment
Program (P25 CAP) and associated testing for the benefit of our
customers, other public safety agencies/users, and manufacturers.
Harris developed and maintains a DHS Recognized P25 Compliance
Assessment Laboratory, recognized in May 2009, for the required scopes
of P25 CAP CAI Baseline testing for performance and interoperability.
The Harris Recognized Laboratory has performed performance testing on
its P25 radio products and has hosted formal P25 CAP interoperability
testing for multiple P25 radio product vendors. Similarly, Harris P25
radio and infrastructure products have been tested at two other
Recognized Laboratories. As a result of this testing, SDoCs and STRs
for seven Harris P25 products (or radio model classes) are now posted
on the RKB website.
Procurement Requirements: As part of procurement
requirements, procuring agencies can specify demonstration of
any special interoperability and function requirements
including, or in addition to, the P25 CAP.
Special Testing as Part of Contract: Procuring
agencies can also specify certain interoperability and
functional testing, including or in addition to, the P25 CAP as
part of their Customer Acceptance Testing.
Question 3: What recommendations do you have to ensure that the
standards development and compliance assessment processes meet the
needs of public safety in a timely manner?
Although challenging, the P25 suite of standards
could be organized into ``releases'' like some other standards
to simply and clarify the description of standards content over
time; i.e., Release 1, Release 2, Release 2.1 etc. P25 products
could then be marked as compliant with P25 Release 1, P25
Release 2 etc. This could also simplify any P25 product
compatibility descriptions.
Again, although challenging and having been discussed
a number of times by users and manufacturers in the P25
standards community, the array of P25 mandatory and standard
option features could be grouped or packaged into levels of
increasing capability; i.e., P25 Level 0 (baseline); P25 Level
1 (Level 0 plus more features); P25 Level 2; etc. This grouping
of features could make the product marking of features
supported and the P25 CAP testing of features packages more
simplified and efficient.
Agreement among public safety agencies on the
features for interoperability, as defined by several levels of
interoperability, would be beneficial. These levels could
include: P25 Interoperability Capability 0 (baseline); P25
Interoperability Capability 1 (Capability 0 plus more
features), etc. This grouping of interoperability capability
features would make specification and testing of
interoperability simpler, more efficient, and adaptable to the
interoperability needs of various public safety agencies.
Prioritizing the consensus-based standards
development according to the needs of the public safety
agencies and the industry capability to support the development
is important.
As a slight note of caution, Harris urges the
subcommittee to consider an appropriate balance among testing,
regulatory requirements and flexibility for innovation within
the P25 standards and products. Harris certainly supports
rigorous testing for compliance for mission-critical public
safety communication products and systems. While it can be
argued that more testing is always good and may catch an
unusual behavior or concern, there is a point where additional
testing, especially redundant testing, does not add significant
assurance benefit. It is possible that ``over-testing'' and
regulation requirements could become a barrier to entry into
the P25 market for smaller companies and deter a larger base of
competition. Also, for P25 manufacturers, the necessity of
supporting any over testing and regulation requirements will
divert critical engineering resources from advancement of new
P25 standards and the development of new P25 product features.
It will inevitably increase the time for completion of certain
standards and increase the time-to-market for some product
features that are much requested by public safety agencies.
CONCLUSION
Chairman Wu and other members of the Subcommittee, thank you for
the opportunity to testify today and share with you the Harris
Corporation views on Interoperability in Public Safety Communications
Equipment. As previously noted, interoperability is a multi-dimensional
challenge that involves five interdependent elements. These elements,
as illustrated in the diagram from the DHS Interoperability Continuum
Brochure, include Governance, Standard Operating Procedures, Technology
(including LMR standards), Training & Exercises, and Usage. The level
of interoperability achieved depends on the progress in each of the
elements and the coordination/management of all five elements. My
remarks today have focused on the Technology (including LMR standards)
area where we at Harris believe that substantial progress has been
achieved in recent years in the establishment of practical technical
solutions and approaches. For the higher levels of interoperability
based on standards-based shared systems, Harris believes that while
more work is needed, strong progress has been made in recent years
through continued TIA-P25 standards development, P25 CAP testing, and
public safety agency procurement requirement and practices that include
separate system infrastructure and user radio procurements. The P25
product standards, the testing standards, and product features are in
place or soon will be in place to enable a solid level of P25 trunked
and conventional systems interoperability.
Biography for Ernest Hofmeister
Dr. Hofmeister holds the position of Senior Scientist within the
Harris Public Safety and Professional Communications (PSPC) group. He
is responsible for establishing and representing the Harris PSPC
technical position on standards and regulatory issues within the
company, industry, and standards/regulatory bodies. He provides
leadership for Harris participation in the TIA TR-8 Mobile and Personal
Private Radio Standards committee and associated APCO Project 25
committees and holds several leadership positions on subcommittees and
task groups. Dr. Hofmeister represented the Harris PSPC predecessor
company, Tyco Electronics (M/A-COM), on the Steering Committee of the
Public Safety National Coordination Committee (NCC) advising the FCC on
operational rules for the emerging 700 MHz public safety band. He also
has technical oversight involvement on new technology introduction and
in establishing technical strategies in line with business strategies.
Relevant Experience
Dr. Hofmeister has worked in the Land Mobile Radio industry for 17
years in Lynchburg, VA with Harris, Tyco Electronics (M/A-COM) and
Ericsson GE Private Radio Systems in the positions of Senior Scientist,
Distinguished Fellow of Technology, Chief Technology Officer, and
Manager of Advanced Technology. He also led several developments for
the Ericsson LMR system product EDACS including the coordination of
Prism TDMA developments and advanced marketing of EDACS TDMA technology
and marketing. The TDMA developments included an air interface, a base
station and portable at 800 MHz, and a TDMA infrastructure overlay.
Previously, he spent eight years in research and development of
industrial imaging technology at the GE Corporate Research and
Development Center in Schenectady, NY and 21 years in research and
development of aerospace and defense radar systems at GE Aerospace
Electronics Systems in Utica, NY.
Past Employer
GE Corporate Research and Development Center, Schenectady, NY
GE Aerospace Electronic Systems, Utica, NY
Education and Certification
Ph.D. (EE) Syracuse University, 1973; Communications and Controls
Major
MSEE Syracuse University, 1969
BSEE Case Western Reserve University, 1963
GE Management Development Course, 1991; GE Engineering Operations
Course, 1983; GE Advanced (ABC) Course in Engineering, 1966
Chairman Wu. Thank you, Dr. Hofmeister.
Mr. Muench.
STATEMENTS OF JOHN MUENCH, DIRECTOR OF BUSINESS DEVELOPMENT,
MOTOROLA INC.
Mr. Muench. Thank you, Mr. Chairman Wu, Ranking Member
Smith.
When the P25 standard was first envisioned by APCO
[Association of Public-Safety Communications Officials], the
goal was to create a vibrant marketplace for public safety
equipment that allows all vendors to compete on a level playing
field. This goal has been achieved, providing interoperability,
product innovation and price competition to the public safety
market. Motorola took an early lead in the development of the
Project 25 radio systems, and today over 13 radio manufacturers
sell Project 25 equipment to public safety users throughout the
world. Project 25 started with a wireless interface, commonly
referred to as the common air interface, and this has been
functionally complete for some time.
In addition to the wireless interface, there are 10 other
interfaces, or connection points, for Project 25 systems that
are identified for standardization. Progress on the remaining
interfaces is in various stages of development and driven by
current market needs.
There are a growing number of industry participants that
continue the work necessary to complete and maintain a full set
of documents for each of the 11 interfaces. Since the Project
25 standard was first adopted by the FCC [Federal
Communications Commission] in 2001, 36 states have developed
statewide P25 networks as have 165 cities and counties. In
total, nearly 70 percent of the U.S. population is covered by a
public safety Project 25 network. Practically speaking, the
widespread adoption of the P25 standard has allowed for
interoperability, regardless of state or local boundaries.
Motorola invented the police radio in 1930 and strives
toward total customer satisfaction. When a first responder
orders a public safety radio and network, Motorola does not
simply perform the installation and walk away. We continue to
work to ensure the equipment performs as advertised, as
intended. This includes testing to validate interoperability
with P25 equipment from other manufacturers. Motorola
understands there are life-threatening consequences if
equipment fails to function as intended. Motorola has an open-
door policy that allows any manufacturer to test P25 standards-
based features with our P25 networks. Motorola also
participates in the DHS testing program. In adherence to the
NIST guidelines, Motorola has posted the compliance testing
results for our entire Project 25 portfolio of products on the
Responder Knowledge Base.
Significant progress has been made with respect to the
development of Project 25 standards. The original Project 25
goals created by the public safety community have been met and
additional standards work continues for new technologies and
features. In order to maintain an efficient P25 standards
process, it is important to maintain a diverse group of users,
as Project 25 covers Federal, state, county and local users.
These users include law enforcement, fire, police and EMS
services. It is just as critical to include industry
representation in these discussions as industry writes the
standards, they build to the standards and they test the
standards. For the consensus process, this group ensures that
there are agreed-upon common goals supported by the user
organizations and industry. These goals are properly
prioritized so that all participants have a common set of
objectives. Once those priorities are set, this Project 25
group must sustain focus on the task at hand until it is
complete. By keeping these basic steps top of mind during the
standards process, we can continue to meet the needs of public
safety in a timely manner.
Project 25, which is focused primarily on mission-critical
voice, is not the end of the interoperability story. Public
safety users are demanding high-bandwidth applications and
content to facilitate greater intelligence and information
sharing between local, state and Federal agencies. Motorola
believes it is imperative that Congress act to dedicate the D
block spectrum for public safety broadband. This will provide
public safety with enough spectrum to deploy broadband networks
in addition to the existing Project 25 mission-critical voice
networks capable of meeting the public safety demand for the
foreseeable future.
Again, I want to thank you for holding this hearing on an
issue critical to public safety in this country.
Interoperability saves lives, and Motorola remains committed to
building the mission-critical communications equipment first
responders have trusted for 80 years. Thank you.
[The prepared statement of Mr. Muench follows:]
Prepared Statement of John Muench
Chairman Wu, Ranking Member Smith, and members of the Committee,
thank you for the opportunity to discuss interoperable public safety
voice communication, and specifically the Project 25 Standard. It seems
only appropriate that the Technology and Innovation Subcommittee hold
this hearing, given the significant innovation and technological
advancements that have occurred in public safety communications, in
part, driven by the Project 25, or P25, standard.
What is the P25 Standard?
When the P25 standard was first envisioned by the Association of
Public-Safety Communications Officials (APCO), the goal was to improve
mission-critical communication interoperability, to see more
competition in the marketplace, and to spur innovation. Through the
hard work of APCO, Telecommunications Industry Association (TIA),
government officials, and equipment manufacturers, the P25 standard has
created a vibrant marketplace for public safety equipment that allows
all vendors to compete on a level playing field, resulting in price
competition and product innovation. Motorola took an early lead in the
development of P25 radios and today, over 13 equipment manufacturers
sell P25 equipment to public safety users throughout the world. (See
Appendix A.) In fact, the P25 standard is considered the key to
achieving interoperability by industry and government alike. As such,
the FCC has adopted P25 as the interoperability standard for public
safety narrowband operations in the 700 MHz spectrum recently made
available to public safety nationwide through the DTV transition.
What Is the Status of Interoperability?
Since the P25 standard was first adopted by the FCC in 2001,
thirty-six states have deployed statewide P25 networks, as have one
hundred sixty-five cities and counties. (See Appendix B.) In total,
nearly 70% of the U.S. population is covered by a P25 public safety
network. (See Appendix C.) Practically speaking, the wide-spread
adoption of the P25 standard has allowed for interoperability:
Among public safety agencies at the Federal, state,
and local level,
Between state police in neighboring states,
For multiple jurisdictions responding to a
catastrophic event, such as Hurricane Katrina, and;
At large-scale, planned events, such as the Super
Bowl and Olympics.
We have seen first-hand that effective, coordinated, and accessible
communications between first responders is critical to the public
safety mission, and the P25 standard has led to significant
improvements in public safety interoperability.
There is still a great deal of work to be done and several factors
will contribute to how quickly P25 is adopted by even more
organizations. One of the biggest hurdles to ubiquitous use is that it
takes very long periods of time to replace old systems and radios with
P25 compliant equipment. The life-cycle of a public safety radio is
anywhere from seven to fifteen years, and for a public safety network,
it can be decades. Given the limited budget resources of state and
local governments, Congress cannot mandate interoperability today and
see it realized tomorrow unless it provides the funds to accomplish
equipment replacement.
When Will the Standard Be Complete?
Standards work on P25 will only be complete when the standard is no
longer in use. From its inception, P25 was expected to be a living
document, subject to amendments, revisions, additions/deletions as
technology advanced. Revisions are normal and to be expected, given
that P25 replaces numerous proprietary solutions that have been sold by
multiple manufacturers for decades. As more P25 systems are deployed,
and more users become engaged in the process, additional requirements
emerge and changes are made.
Similarly, the original P25 architecture has been significantly
enhanced as the list of features and services expands. The first P25
architecture defined only five system interfaces. Interfaces are the
physical locations where one component ``connects'' with another.
Today, eleven P25 interfaces are identified. As desired features and
services are added or redefined, the interfaces that make up the system
architecture likewise must be reviewed and updated.
To date, TIA has published nearly two hundred documents, creating
or revising almost fifty published standards utilized by industry to
design and develop interoperable P25 products and systems. TIA further
develops and proposes documents for interoperability testing and
standards compliance demonstration to the government. Project 25 has
two phases of standards development driven by varying FCC regulatory
requirements. Phase 1 products are designed to operate in a 12.5 kHz
channel bandwidth and have been in use since the mid 1990s. Phase 2
equipment is developed to operate with greater spectral efficiency and
essentially double the number of voice paths that operate within a
single 12.5 kHz channel.
As of May 2010, the technical specifications for Project 25's Phase
1 systems are functionally complete, with compliance testing underway
and multiple manufacturers listed as meeting the National Institute of
Standards and Technology (NIST) compliance requirements for their
products. P25 Phase 1 allows for two critically important features.
First, Phase 1 ensures that a P25 radio in the hands of a first
responder can communicate directly with any other P25 radio in the same
spectrum band. This means that the Michigan State Police officers who
responded to Hurricane Katrina were able to directly communicate with
the Louisiana State Police, in Louisiana. Second, P25 Phase 1 allows a
first responder from one jurisdiction to communicate with the network
itself in a neighboring jurisdiction. This allows the first responder
to communicate not only with officers in the field, but with dispatch,
even though they are outside the coverage area of their ``home''
network.
While work continues on Phase 2, keep in mind that there is no
functional change that will be apparent to the officer or firefighter
in the field due to Phase 2 improvements. Phase 2 essentially allows
more public safety radios to utilize a given P25 network, but future
enhancements to the standard will not change interoperability for the
public safety official.
How Does a First Responder Know They Are Buying P25 Equipment?
Motorola places paramount importance on our relationship with our
customers in the public safety community. Motorola invented the police
radio in 1930 and views our customer relationship more like a
partnership.
When fire departments were concerned that firefighters who dropped
their radios in a fire could not find them in darkness and smoke,
Motorola responded with a glow-in-the-dark radio. Similarly, when law
enforcement expressed an interest in finding ways to improve officer
safety, Motorola developed emergency alerting capability in our radios.
When a police or fire department orders a public safety radio and
network, Motorola does not simply perform the installation and walk
away. We continue to work to ensure the equipment performs as intended,
including testing to validate interoperability with P25 equipment from
other vendors. Motorola understands there are life-threatening
consequences if equipment fails to function as intended.
In addition to the informal internal testing Motorola performs
individually and with our competitors at our labs in Schaumburg, IL,
Motorola also participates in the Department of Homeland Security
(DHS)-defined formal compliance testing programs. The formal testing
program is validated by the standards experts at the NIST. When the
testing is complete, manufacturers post their results in the Responder
Knowledge Base, or RKB. To date, Motorola has posted tested and
validated P25 equipment for portables, mobiles, and infrastructure.
(See Appendix D.)
Recommendations to Meet Public Safety Needs
As you can see, significant progress has been made with respect to
P25 standards development. The original P25 goals, created by the
public safety community, have been met, and additional standards work
continues for new technology and features. In order to maintain an
efficient P25 standards process, it is important to:
Maintain a diverse group of users and industry to
drive the P25 consensus process,
Document the common goal of the group, and;
Sustain focus on the goals.
By keeping these tenants top of mind during the standards process,
P25 practitioners can continue to meet the needs of public safety in a
timely manner.
Public Safety Needs More Spectrum for Broadband Applications
But P25, which is focused primarily on voice systems, is not the
end of the interoperability story. In the past ten years, we have seen
an explosion in demand for data applications in the consumer space, via
text, email, pictures, and video. Likewise, public safety users are
demanding high-bandwidth applications and content to facilitate greater
intelligence and information sharing between local, state and Federal
agencies, to enhance criminal investigations, and to improve the safety
of our first responders. Imagine an officer responding to a 9-1-1 call
and arriving on the scene, already knowing the situation on the ground
because she was able to see live video streaming in her vehicle, or a
firefighter being able to look at an electronic blueprint of a building
before arriving at the fire. These are just some of the innovative
applications available today to public safety, however, the use of this
data has been limited due to the lack of available spectrum.
Unfortunately, today's public safety officers have limited access
to data services. Prior to the 700 MHz allocations, public safety
lacked the spectrum to enable mobile services. Today's public safety
networks are only capable of providing the functional equivalent of
commercial texting services. Of course, public safety users can buy
mobile broadband service from commercial carriers, and many do, but
these networks rarely provide the reliability and coverage that first
responders demand from their communications networks. Motorola believes
that it is imperative that the Congress act to dedicate the 10 MHz ``D
Block'' spectrum for public safety broadband. This will provide public
safety with a total of 20 MHz of 700 MHz spectrum to deploy broadband
networks capable of meeting public safety demand for the foreseeable
future. Our nation's first responders deserve the same access to
content as anyone with a Facebook account or cell phone.
Conclusion
Again, I want to thank you for holding this hearing on an issue
critical to public safety in this country. Interoperability saves lives
and Motorola remains committed to building the mission critical
communications equipment first responders have trusted for eighty
years. Thank you.
Biography for John Muench
John Muench is the Director of Business Development as it relates
to worldwide standards activities associated with government and public
safety products for Enterprise Mobility Solutions for Motorola. John
directs both the Technical and Business activities supporting Standards
Development. Through a complete understanding of Motorola customers'
needs, his team translates services and features into TIA standards as
well as develops business strategies around those TIA standards. In his
16+ years at Motorola, John has participated in system engineering,
system design, project management and system roadmap planning for
private two-way radio systems in the United States and Europe. John's
experience encompasses all aspects of radio system design, including
base site, subscriber, dispatch, central office, security, radio, and
network management equipment. John's expertise includes managing sales
bidding strategies of next generation products, prioritization of
features to support the product development process and complex system
P&L management.
Chairman Wu. Thank you very much.
Chief Johnson, please proceed.
STATEMENTS OF JEFFREY D. JOHNSON, PRESIDENT, INTERNATIONAL
ASSOCIATION OF FIRE CHIEFS, AND CHIEF, TUALATIN VALLEY FIRE AND
RESCUE, ALOHA, OREGON
Chief Johnson. Thank you, Chairman Wu and Ranking Member
Smith. My name is Jeff Johnson. I am the Fire Chief of Tualatin
Fire and Rescue, President of the International Association of
Fire Chiefs, and for eight years have been Chairman of the
Oregon Wireless Interoperable Network. I am looking forward to
today's testimony.
I would like to begin my testimony this morning, sir, with
a working definition of interoperability. It is the ability for
public safety responders to communicate with staff from other
responding agencies and to exchange voice and data
communications on demand, when authorized, in real time. And
while interoperability is very important, mission-critical
operability is of greater importance because without
operability, there is no interoperability.
The majority of America's 30,000-plus fire departments
operate with analog radios. Digital radios available now for
about 20 years are being used by a growing number of
jurisdictions today. When these radios began entering the
public safety market, a standard known as P25 began development
and is still in process. P25 ensures a common standard of
performance features and a common air interface to allow
interoperability between the radios produced by different
manufacturers. This P25 standard is kept to mission-critical
operability and interoperability and has long been fully
supported by the International Association of Fire Chiefs.
The P25 digital standard is actually a complex suite of
standards which define the interface for radios, consoles, base
stations and other system components. However, we in the fire
service are not so much interested in how radio systems work,
but that they work.
We are pleased that the manufacturers are working with NIST
and DHS and that four of the major manufacturers now meet CAP
requirements. It has taken a very long time to get to this
point. I am pleased we are here, but we need to complete the
P25 standard in the interest of ensuring public safety that the
digital radios they buy will indeed work interoperably.
I would like to end my presentation this morning with a
glimpse of the future as we see it, which is all about
interoperability and communications standards. The
International Association of Fire Chiefs is working diligently
with other public safety leadership organizations to build out
a nationwide public safety interoperable wireless broadband
network. This is the future for public safety communications
and is vitally necessary. One of the major difficulties today
in achieving interoperability is trying to connect, at great
expense, I might add, the thin slices of disparate spectrum
which have been allocated by the FCC over the years to public
safety as each new band has become available. In effect, we are
building sideways connector roads to the lanes of spectrum
which have been allocated to public safety and adding no
meaningful forward throughput.
The envisioned broadband system needs to be mission
critical at the outset. At first, it will support data and
video communications. In time, the goal of the IAFC, and its
allies, is to use this network for mission-critical voice
communications. To achieve this goal, the D block of spectrum
is vital to developing this robust network. Only then can we
hasten the transition from the current land mobile radio
communications to mission-critical voice over Internet protocol
system. Our quest for the D block is a one-time opportunity to
make sure that the inadequate spectrum we have today is moved
to a larger, more robust and comprehensive broadband network,
and to create a national architecture of Internet protocol for
public safety.
Recently, the FCC announced in its national broadband plan
that it will auction the D block to commercial interests
without the needed public safety requirements. Thus, public
safety seeks passage of legislation to allocate the D block
directly to the Public Safety Spectrum Trust. H.R. 5081,
introduced by Representative Peter King, is currently before
the House Energy and Commerce Committee. The bipartisan
legislation has the strong support of both public safety
leadership and major national organizations representing state,
county and local government. Our collective mission is simple:
The D block is vitally needed by public safety to ensure an
efficient broadband system which will attract commercial
interest and reduce the need for government funding. This is
our only path to solving interoperability long term once and
for all.
Thank you, Mr. Chairman, for the opportunity to appear
before you and this Committee on this very important subject. I
would be happy to answer any questions.
[The prepared statement of Chief Johnson follows:]
Prepared Statement of Jeffrey Johnson
Good morning, Chairman Wu, Ranking Member Smith, and distinguished
members of this subcommittee. I am Jeff Johnson, president and chairman
of the board of the International Association of Fire Chiefs (IAFC) and
chief of the Tualatin Valley Fire and Rescue Department located in
Beaverton, Oregon.
I would like to begin my testimony with a working definition of
interoperability: the ability of public safety service and support
providers--law enforcement, firefighters, EMS, emergency management,
public utilities, transportation, and others--to communicate with staff
from other responding agencies, and to exchange voice and/or data
communications on demand, when authorized and in real time. And while
interoperability is very important, mission-critical operability is of
greater importance. Without operability, there is no interoperability.
Significant Federal, state and local resources continue to be
expended to develop greater interoperability between and among first
responder agencies as well as jurisdictions. It is a daunting task but
progress is being made. There are five separate lanes on the Department
of Homeland Security Interoperability Continuum to achieve that goal:
Governance, Standard Operating Procedures, Training and Exercises,
Usage, and Technology. Radio equipment falls into the Technology lane.
The majority of America's 30,000+ fire departments operate with
analog radios. Digital radios, available now for two decades, are being
used by a growing number of jurisdictions today. When these radios
began entering the public safety market, a standard known as P25 began
development and is still in process. P25 ensures a common standard of
performance features and a common air interface to allow
interoperability between the radios produced by different
manufacturers.
This P25 standard is key to mission-critical operability and
interoperability and has long been fully supported by the IAFC. The P25
digital standard is actually a complex suite of standards which define
the interface for radios, consoles, base stations and other system
components. However, we in the fire service are not so much interested
about how radios and systems work, but THAT they work.
To ensure that they work is part of the mission of both the Public
Safety Communications Research (PSCR) program, located at the NIST
laboratories in Boulder, CO, and the Department of Homeland Security's
Office for Interoperability and Compatibility (OIC). The OIC and NIST
have established a testing capability to ensure that digital radios
used by the fire service and other public safety entities will actually
perform as designed. It is called the P25 Compliance Assessment Program
(CAP). The CAP is composed of three testing elements which are:
Performance--the specifications are correct,
Conformance--to validate the various P25 protocols
used in the system, and
Interoperability--to prove that one or more
manufacturer's radios will operate on another manufacturer's
system.
These three tests conducted in P25 CAP-recognized testing sites
give fire chiefs assurance that the P25 radios they buy will work not
only on their system but with radios from other manufacturers on other
systems. All this is key to give assurance to fire departments that do
not have the capability to test the radios and systems they buy.
We are pleased that manufacturers are working with NIST and DHS,
and that four of the major manufacturers now meet the CAP requirements.
It has taken a very long time to get to this point. I am pleased we are
here, but we need to complete the P25 standard in the interest of
assuring public safety that the digital radios they buy will, indeed,
work interoperably.
I would like to end my presentation this morning with a glimpse of
the future--which is all about interoperability and standards. The
International Association of Fire Chiefs is working diligently with
other public safety leadership organizations to build out a nationwide,
public safety, interoperable, wireless, broadband network. This is the
future for public safety communications and vitally necessary.
One of the major difficulties today in achieving interoperability
is trying to connect, at great expense, the thin slices of disparate
spectrum which have been allocated by the Federal Communications
Commission (FCC) over the years to public safety as each new band
became available. In effect, we are building sideways connector roads
to the main communications lanes. What is needed is a nationwide
architecture allowing all public safety to have the ability to
communicate on one, major superhighway. So, while we need to maintain
operability and interoperability of the current mission-critical Land
Mobile Radio (LMR) systems, our future is in broadband technology.
The envisioned broadband system needs to be mission-critical at the
outset. At first it will support data and video communications. In
time, the goal of the IAFC and its allies is to use this network for
mission-critical voice communications. To achieve this goal, the D
Block of spectrum is vital to developing a robust network. Only then
can we hasten the transition from current LMR communications to
mission-critical Voice over Internet Protocol. Our quest for the D
Block is a one-time opportunity to make sure that the inadequate
spectrum allocations to public safety in the past are not repeated for
this new technology.
Public safety, from a spectrum allocation determined by Congress in
1997, is currently licensed for 10 MHz of nationwide broadband spectrum
in the 700 MHz band. The license is held by the Public Safety Spectrum
Trust (PSST), a 501(c)(3) corporation composed of 15 public safety
organizations. The original plan was to combine public safety's 10 MHz
with 10 MHz from the adjoining D Block of spectrum to be sold at
auction to build out a 20 MHz nationwide broadband network that would
be built to public safety mission-critical standards. But, the
submitted bid did not meet the reserve price set by the FCC.
Recently, the FCC announced in its National Broadband Plan that it
will auction the D Block to commercial interests without the needed
public safety requirements. Thus public safety seeks passage of
legislation to allocate the D Block directly to the PSST. H.R. 5081,
introduced by Rep. Peter King, is currently before the House Energy &
Commerce Committee. The bipartisan legislation has the strong support
of both public safety leadership and the major national organizations
representing state, county and local government. Our collective message
is clear: the D Block is vitally needed by public safety to ensure an
efficient broadband system which will attract commercial interests and
reduce the need for government funding.
Thank you, Mr. Chairman for the opportunity to appear before you on
this very important subject. I would be pleased to respond to any
questions.
Biography for Jeffrey Johnson
Jeff Johnson, Fire Chief and Chief Executive Officer, joined
Oregon's Tualatin Valley Fire & Rescue (TVF&R) in 1989, following an
11-year fire service career in Douglas County, Oregon. Chief Johnson
served as a TVF&R Division Chief and Assistant Chief prior to becoming
Fire Chief in 1995.
TVF&R is a fire district with approximately 500 members providing
fire, EMS, specialty rescue and prevention services in the Portland
metropolitan area. While under Chief Johnson's leadership, TVF&R has
twice received the International Association of Fire Chiefs (IAFC)/U.S.
Safety and Engineering Fire Service Excellence Award, the top award for
organizational excellence in the fire service. TVF&R is accredited by
the Center for Public Safety Excellence's Commission on Fire
Accreditation International (CPSE/CFAI).
Chief Johnson is an ambassador for excellence and innovation in our
service to the community. Additionally, he advocates for cooperative
initiatives and other business practices that achieve efficiencies and
demonstrate smart government and value for the citizens' investment. He
has authored two fire service books and is a featured guest lecturer
across the nation.
In August 2009, Chief Johnson was installed as the President and
Chairman of the Board of Directors of the International Association of
Fire Chiefs (IAFC). He also holds membership in the Metropolitan Fire
Chiefs Association and various IAFC Sections. He is the IAFC's
alternate representative to the SAFECOM Executive Committee and a
member of the USA Delegation to the Comite Technique International de
Prevention et d'Extinction du Feu (CTIF), also known as the
International Association of Fire and Rescue Services.
In March 2010, Chief Johnson was appointed to the U.S. DHS/FEMA
Local, State, Tribal and Federal Preparedness Task Force by DHS
Secretary Janet Napolitano to assist in assessing the state of the
nation's disaster preparedness and developing recommendations specific
to building resiliency into communities across America.
Jeff is a graduate of the National Fire Academy's Executive Fire
Officer (EFO) Program and achieved the CPSE Chief Fire Officer (CFO)
Designation. He is also a member of the Institution of Fire Engineers
U.S. Branch (MIFireE).
By gubernatorial appointment, he is the Chair of Oregon's State
Interoperability Executive Council, and a member of the Oregon Homeland
Security Council and the Oregon Broadband Advisory Council. He is Past
President of both the Western Fire Chiefs Association and the Oregon
Fire Chiefs Association (OFCA), the Past Chair of the Oregon Governor's
Fire Service Policy Council, and a charter member of Oregon's
Meritorious Service Committee. Locally, he is a board member for both
the Washington County Office of Consolidated Emergency Management
(OCEM) and for the Washington County Consolidated Communications Agency
(WCCCA), which is the local 911/dispatch center.
In the corporate environment, Jeff sits on the boards of two
private companies, specifically as a member of the Informed Publishing,
Inc. Board and as the chair of the Emergency Services Consulting
International (ESCi) Board. He also is on the Editorial Board of
FireRescue Magazine.
Chief Johnson holds a Bachelor of Science Degree in Business and
Associate Degrees in Fire Science and Criminal Justice Administration.
During his leisure time, Jeff enjoys spending time with his wife, Kay,
and their two children. As an avid outdoorsman and student of Oregon
history, Jeff enjoys camping, fishing, and motorcycling in Oregon's
back country.
Chairman Wu. Thank you very much, Chief Johnson.
And now it is in order for the panel to ask questions, and
the Chair recognizes himself for five minutes.
Mr. Orr, in your written testimony you raise a point that
only a limited portion of the Project 25 system is truly
standards based. What is the practical impact of that
statement?
Mr. Orr. Standards, at the most basic, are blueprints to
allow multiple manufacturers to build a product in a similar
way which will allow those products to interoperate. In the
absence of that blueprint, in the absence of those standards,
you cannot have that common implementation that allows
interoperability and, therefore, you cannot have open
competition and you cannot have multi-vendor interoperability
in the field. The impact of the lack of standards in this
situation is that the standards that remain undefined in
Project 25 make it difficult for a common implementation to
occur which will increase the likelihood of non-operability in
the field and increases the difficulty of open competition.
Chairman Wu. So Mr. Orr, what you are saying is that lack
of completeness of those standards has an impact on competition
levels and also on safety for emergency responders?
Mr. Orr. Absolutely.
Chairman Wu. Are any of the panelists, are any of the
witnesses aware of any situation in recent years where public
safety folks using P25 labeled systems and believing them to be
compliant were unable to communicate with other first
responders using P25 systems? And if so, do you know what
caused that to happen? And in no particular order. Dr. Boyd.
Dr. Boyd. Our experience, both after 9/11 and during
Katrina, was that systems which were labeled P25 where the
interpretation of the standard has deviated a little bit
between manufacturers meant they couldn't communicate directly.
But probably the best single example we have is the testing we
did among systems which were in the field, and the important
element there is that it tells you there are systems in the
field that were labeled P25 that--because of those minor
variations in interpretation--cannot communicate with each
other, sometimes within one manufacturer's line. So what you
have to worry about is what happens if they are called on to
provide mutual aid in other jurisdictions because while they
both have P25 systems, they may not be able to communicate with
each other because of minor differences. As any engineer
designs a system, he has to interpret what amounts to a text-
based standard.
Chairman Wu. And that interpretation, if there is differing
interpretation, that is where conformance testing and
compliance testing, that is what those forms of tests can
address. Is that----
Dr. Boyd. Absolutely. The only way you arrive at common
interpretation is through a standardized test. At the end of
the day, a standard is not operationalized until there is a
test.
Chairman Wu. Going back to any other examples of lack of
communication between P25 labeled systems? Okay. Very good.
Mr. Muench, I am not getting this quite right. You know, my
high school German would tell me that that is Muench, but can
you say it for me?
Mr. Muench. Muench, bench with an M.
Chairman Wu. Thank you very much, sir.
Mr. Muench, in your testimony, you said that the technical
specifications for P25 phase 1 systems are functionally
complete. Can you explain to us what you mean by that?
Mr. Muench. Yes. Functionally complete means that there is
enough information in the standard for manufacturers to build
product and deploy product, actually do interoperability
testing with other manufacturers. As I said in my testimony,
there have been over a million units sold of Project 25. All
participate within interoperability testing throughout the
informal programs that Motorola has within our facility in
Schaumburg.
Chairman Wu. Well, I don't know if this is in comparison or
in contrast or the same thing, but Dr. Boyd, in your testimony
you state that comprehensive standards do not yet exist. Can
you explain to us what you mean by that?
Dr. Boyd. Right now there are four primary components we
are concerned with, such as the common air interface and the
ISSI standard. Some of the standards--while they have been
tested at some level--are not really fully complete and have
not yet been accepted entirely by the community. Until the
final vote is taken and a test is developed--some tests are
already in place--no standard is complete, because at the end
of the day, it is the test that determines whether variations
in interpretation are creating an interoperability problem.
Chairman Wu. Now, my time is expired, but I don't know if
we have a disagreement here or not. Can we have Harris and
Motorola on one hand and DHS and NIST on the other hand, can
you address whether there is a difference of opinion about
this?
Dr. Hofmeister. Thank you, Mr. Chairman. Speaking for
Harris, we have 50 systems deployed and we have systems that
have different vendor radios. We have a system that was
deployed with none of our radios, and we have achieved the full
level of the customer satisfaction in daily operations with
those systems. We have interoperated with Motorola systems, as
John just said. We have gone to Schaumburg to test during our
development as an assurance. This illustrates informal
development practices that have been developed over time. They
have come to our lab for testing their developments. So over
the last few years we have actually developed a more
cooperative relationship in the industry. I believe the
standards are functionally complete, as John said. We have
implemented them. We have tested them.
Now, are the last little bits of the standards complete? I
think the common air interface is very solid. I think the
baseline ISSI, which is coming out, is very solid. The console
interface is a subset of that. That is a little bit in the
future. The fixed station interface I believe is very solid.
Products are starting to emerge from that. So I actually think
the picture is a little bit better than my colleagues here
would present for fielded systems.
Chairman Wu. Thank you.
Mr. Smith.
Mr. Smith. Thank you, Mr. Chairman. I am trying to myself
get a grasp of how widespread the problem is.
Dr. Boyd, you mentioned that within one manufacturer, one
product is not compatible with another or interoperable with
another?
Dr. Boyd. Yes. In fairness to the manufacturers, remember
that this process started in 1989. That is 21 years ago. So
manufacturers' equipment that was labeled as P25 compliant, and
that, in many cases was produced long before any of these
interfaces were really finished, often didn't communicate with
other manufacturers or even with newer equipment in their own
line. Both Motorola and Harris and others have increasingly
applied more and more stringent applications in order to make
sure that this equipment comes closer to those standards. I
think one way to picture how well things are going is, that in
2008 when Congress finally authorized the development of the
Compliance Assessment Program, that really started the ball
rolling, even though it had started in 1989 at a time before
Bluetooth and before people texted and all those kinds of
things we are now used to. We are now looking at a real
compliance test probably in two more years. That is an amazing
change over time. But I think what you have to remember is that
this development over time is something that is reflected in
one of my colleague's----
Mr. Smith. Are you saying that it might have been
interoperable at one point but maybe not as interoperable today
as it once was?
Dr. Boyd. Oh, absolutely. In fact, it is important to
remember there are legacy systems out there that aren't going
to be changed out for a long time.
Mr. Smith. Right, so what is the solution there? I mean,
how are we any better off today with a standard or hopefully
not a mandate that would paint a picture that is ultimately
going to change due to industry coming with a better way of
doing things that meets the standard at one point, you know,
the previous standard but yet throws in a few other bells and
whistles along the way?
Dr. Boyd. The way we talk about standards is that there
ought to be some core set of functionalities that we make sure
remain in place. Otherwise what happens if we don't----
Mr. Smith. Right. Are we without those today?
Dr. Boyd. I think we are getting close to having those but
if we don't----
Mr. Smith. We are not there?
Dr. Boyd. --have those, then every new generation moves
away from that and creates exactly the same problem we have
been trying to fix. I think the manufacturers are working very
closely with us to develop that core set of functionalities.
That is why----
Mr. Smith. I mean, that is in the best interest of everyone
involved.
Dr. Boyd. Absolutely.
Mr. Smith. Even if it might lead to a profit that I think
is a good thing. Sometimes I wonder around this place.
When we get to the larger issue here, I just hope that we
don't have the heavy hand of government establishing a mandate
that ultimately I think will shut down innovation. Can you
assure me that that is not going to happen?
Dr. Boyd. Well, I would hope not. I think that both the
challenge and the strength of the standards process in the
United States are kind of interesting. The challenge is that
consensus is probably best spelled S-L-O-W. The strength is
that it makes sure everybody gets heard, it makes sure we leave
open potential for innovation as the standards are developed,
and it also ensures we don't have lots of diverging paths, that
we have paths that allow innovation and move in the same
direction so the road gets wider, but doesn't diverge.
Mr. Smith. I appreciate that. That is actually a good
analogy.
Now, from an agency perspective, Chief Johnson, if you
could tell me or tell us how you would go about verifying the
interoperability of a particular product. Do you have to do
that only after you purchase it? How do you verify?
Chief Johnson. Well, I think the assessment that most
public safety officers look at is whether it is P25 compliant
or not and make their purchasing decision based upon that is
pretty accurate. Very, very few departments, individual
departments possess the individual ability to test the
compliance of their system, plus, even if you bought it
thinking it was compliant on day one, it doesn't mean that the
radio network that you used couldn't change out to a different
manufacturer a year later or that your mutual aid agency that
you are running into changes theirs, and I think that
illustrates why it is so important to make sure that compliance
assessment testing is done and that it is accurate so that we
can buy with confidence. I mean, let's face it: Public safety
wireless communication devices are expensive. But there are
reasons they are expensive. They are largely bulletproof. They
are intrinsically safe. They don't cause an explosion. You
know, they are waterproof. They are firefighter-proof, and that
is saying something. And I think, you know, we forget those
elements that lead the price of the product, and frankly, the
public safety market is a pretty small market when you compare
it to the Blackberry market or some of the others.
Mr. Smith. I just want it to be Congress-proof, too.
Chief Johnson. Thank you, but to a great extent, sir, we
are relying on the certification.
Mr. Smith. Thank you.
Chairman Wu. Thank you very much, Mr. Smith.
Chief Johnson, you said that you are relying upon the
certification, in essence you are relying upon the
representation that P25 is interoperable, that equipment
labeled P25 is interoperable.
Chief Johnson. Mr. Chairman, that is correct, and I think
also many of the grants today require that you purchase P25
equipment.
Chairman Wu. Well, I thought I heard earlier that sometimes
P25 equipment won't talk with each other, that they are not
truly interoperable and that different generations of P25
equipment may not be interoperable. It seems to me that if it
is not interoperable, one of the two systems should not be
labeled P25 so that Chief Johnson isn't mislead, that two items
bearing a P25 sticker really work with each other.
Dr. Boyd. I think in fairness I should note that I am
talking about systems that label themselves as P25 but because
there was no test process to ensure it really did comply around
these core functionalities, like the common air interface or
other interfaces. What we are after is a core set of functions.
We want them to be able to develop lots of bells and whistles
that go beyond core capabilities, that may later become
necessities. I like to point at the cell phone, for example,
which in 1970 was hardly anybody's idea of a necessity. I would
challenge that view today.
Mr. Smith. Now it is an entitlement.
Chairman Wu. Chief Johnson, given the knowledge that the
standards are arguably not complete, how much confidence do you
and you colleagues have in those purchasing decisions without
the certifications?
Chief Johnson. Mr. Chairman, I think most public safety
responders trust the P25 standard and are purchasing equipment
expecting reliable communication with other systems, and I
think that is the current standard of field today.
Chairman Wu. So the confidence level is reasonably high or
do you have some residual concerns?
Chief Johnson. I think within our industry, the confidence
level is reasonably high, but I think there is always the
question mark of making sure that it operates across systems
and that is why we reach out to our other colleagues, you know,
fire chiefs reach out to other fire chiefs and police chiefs
that may be operating similar types of equipment and then we
actually check with other chiefs to make sure that they are
having a good experience with the products we are about to buy,
and that is frankly the benefit of an association like the
International Fire Chiefs is, you can reach out to a large
group. And candidly, I think this is true with the public in
general, we are more likely to trust another fire chief's
experience than we are the representation of the manufacturers,
and that is just the state of the market in any product, not
just in radio communications.
Chairman Wu. I would like to ask the panel, and this is
really aimed, I suppose, at the other four witnesses. What
factors have delayed the development of technical standards and
what factors have delayed the implementation of compliance or
conformance tests? In any particular order.
Dr. Boyd. I think there are three major things that have
delayed them, and I think they are all the kinds of things we
are all working on. The first one is that it is a consensus
process, and I think it ought to remain a consensus process,
but that means it is slow. The second one is that the
technology has changed pretty dramatically since we first
started this in 1989, and so that means that we have had to
make lots of adjustments as we developed the standard to take
into account all of the other things that have been happening
technologically, because the standard you would have designed
in 1989 is not what you are going to design now. So the
standards process probably is never going to be fully finished,
but we can arrive at something that allows rational migration.
The third one is that there is a huge installed infrastructure
that no community can afford to simply throw away, and we are
going to have to keep that in mind as we implement any of these
that we make sure we don't implement technologies that have the
effect of isolating communities that can't afford to buy into
newer systems. We always have to think about how we keep those
legacy systems able to communicate with the newer equipment,
and I think the manufacturers in fact have done a pretty good
job of developing some of those bridging technologies that
permit that to happen.
Chairman Wu. Mr. Muench? Dr. Hofmeister?
Mr. Muench. I would actually say that the standards based
on--since it is a voluntary process and it requires significant
expertise in the area with the limited resources in the
industry, we have been moving along at a fairly good pace and
keeping up with technology. We are just about to embark upon
the second phase of the standard.
Chairman Wu. Now, it has been 21 years.
Mr. Muench. Absolutely, and we have significant progress.
Over 70 percent of the U.S. population are covered by Project
25.
Chairman Wu. Well, covered by Project 25 apparently is
different from knowing that these P25 systems are actually
fully interoperable or, you know, functional with each other.
Mr. Muench. So maybe I can go back to the point that was
made earlier, a lot of the general statements about
interoperability issues. Since 2005, we haven't had the reports
that have come in about interoperability challenges. Motorola
has investigated all of them, and the majority of the time it
is how the actual equipment is configured. This is a complex
technology. This isn't like plug-and-play that you would have
on your Apple computer. This takes--you know, there is
configuration of the equipment, there is the execution of the
test or the pass and fail criteria that are set up. So some of
the issues that have come up and they have called them
interoperability issues are really configuration issues, and it
has not related back to conformance or compliance to the
standard.
Chairman Wu. Dr. Hofmeister and Mr. Orr, I want to give you
a chance to address this, although my time has expired.
Dr. Hofmeister. Thank you, Mr. Chairman. I think as I said
in my testimony, in terms of the pace of the standards, before
2005 or the gap between 1995 and 2005, things were pretty slow.
Since 2005, the standards pace has picked up, and as I
testified, I believe it is at the pace that we have the
capacity to support with the number of engineers that have the
capability and the quality to develop the standards. In terms
of interoperability across these systems (some are legacy
systems), I will say the interop testing that is going now
under P25 CAP and the posting of SDOCS [Supplier's Declaration
of Compliance], these systems are complex. Every system that
you test against has a hardware revision number, a software
revision number, whether that is infrastructure or your radio,
and you need to make sure that those are known. Now, as a
result of that process, both Harris and Motorola--and we
release products or product software about every six months or
so. We then have an obligation to tell the major manufacturers
whose radios are operating our system: look, we are having this
new release, we don't think it is going to affect anything but
you might want to check to make sure that your radios operate
this way. So I think we are going to get much better going
forward so we won't have this issue that maybe there are
generations of the product in the field with interoperability
challenges.
Chairman Wu. Thank you.
Mr. Orr, would you care to address this topic before we go
to Mr. Smith?
Mr. Orr. Sure, Mr. Chairman. I think I would like to point
out something which is, I understand, the consensus process can
be slow and it can be cumbersome. Simply building consensus is
difficult. However, I think it needs to be pointed out and what
is important in this case is that it has been since 1989 that
we have gotten to the state where we are where we have one and
a half of the eight interfaces complete. In that same period of
time since 1989, we have had 2G cellular standards developed,
systems deployed, 3G cellular standards developed, systems
deployed, 4G cellular standards developed and now systems are
being deployed. So standards don't have to be slow. The
standards process doesn't have to be slow. In addition to that,
every one of those wireless technologies, cellular, Wi-Fi,
Bluetooth, as an industry knew that it is imperative as an
industry to be successful in that deployment of that technology
was to wrap an incredibly rigorous compliance assessment
program around it. So every single one of those technologies
has an industry-led compliance assessment and certification
program. P25 is the only one, that I am aware of, that has not
done that in a major wireless industry. So I think the key is
here that it doesn't have to take forever but we do need to
move the process forward and we do need to complete the first
suite of standards.
Chairman Wu. Does anyone know why P25 is uniquely different
in this respect?
Dr. Boyd. I don't really think it is uniquely different. I
think the only complexity for--and it is not for P25, but for
interoperability in general is that there is so much legacy
gear out there. But P25 looks to the future. It is what we are
going to be doing as we build out new equipment and put it into
place. I really don't think ultimately that it is uniquely
different. I think there hasn't been a lot of focus on it. I
know the first time we started working on interoperability some
time ago when I was in the Justice Department back in 1993,
there wasn't a whole lot of interest other than in public
safety, and even then it was a very slow, very cumbersome
process. I can't say that folks were energized in the same way
they have been since 9/11 and Katrina.
Dr. Hofmeister. Just a comment on the question you asked, I
believe the difference is the scale of the industry. This, by
any sense, is a fairly small, specialized industry. The scale
of people involved, the scale of income, the scale of R&D, the
scale that can be devoted to development of standards in my
view is much different than the commercial industry where you
are selling millions of these things. We are selling thousands
of these radios and so on. So I believe the scale makes a
difference in the amount of resources that can be devoted to
development of standards.
Chairman Wu. Thank you.
Apologies, Mr. Smith. Please proceed.
Mr. Smith. Thank you.
I am just trying to again get a grasp of what all that
takes place here. Now, in terms of meeting P25 standards, Mr.
Muench, could you mention what takes place in meeting those
standards?
Mr. Muench. First, the industry participates in the
standards development process actually defining the technical
definitions and producing the documents required for
standardization to be published by a recognized standards
development organization. This also includes the actual tests
to validate the compliance to the standard. Once that standard
is published, then manufacturers build the products in
adherence to the standard. We test--we go through rigorous
testing through our development process and then once our
products are complete and ready to deploy out in the market, we
do interoperability testing not only with ourselves but with
other manufacturers to ensure that we have the Project 25
interoperability so when we deploy these products, they are not
going to have any issues. Then beyond that, there are external
programs such as the Compliance Assessment Program by DHS that
provides even further confidence that the products that have
been manufactured and are beginning to be deployed are
complaint to the Project 25 standard.
Mr. Smith. So when you say testing, can you give us--I
mean, especially in light of what Dr. Hofmeister said, we are
not talking about the same number as we have cell phones and so
obviously the whole bus there moves a little more slowly.
Mr. Muench. Right.
Mr. Smith. But in terms of testing, what is placed on
industry in terms of the burden of testing?
Mr. Muench. At this point in time, beyond the DHS CAP
program, industry itself does the testing on its own within our
internal labs because the end goal here is total customer
satisfaction. We don't want to have an issue where public
safety lives are in danger because a product doesn't work
regardless of manufacturer. We understand the mission-critical
aspect of our business.
Mr. Smith. Okay. And so moving forward, what do you think
should or should not be done so that perhaps there is the
flexibility necessary for industry to innovate and yet sustain
the necessary functions of communication?
Mr. Muench. Thank you. Good question. I think things are
going along relatively good right now. When we look at external
programs and supporting these external programs, again to Dr.
Hofmeister's comments on the scale of the industry, we would
prefer to have a wider breadth of external testing as opposed
to depth, and when I talk about depth of testing, it is, ``Do
you really want to know if the ones and zeros are in the right
place in your message,'' or do you want to ensure that ``can
you hear me now'' tests between different manufacturers works,
and that is the ultimate, in Motorola's view, that is the
ultimate test is when you get out in the field and multiple
manufacturers are able to talk to each other on the radio
system and inherently by providing interoperability testing you
are testing the other aspects such as conformance which
industry continues to do internal in their development.
Mr. Smith. Anyone else wishing to elaborate? Mr. Orr.
Mr. Orr. I think, to follow up John's comments, first of
all, those ones and zeros can be incredibly important to
determine whether or not when you hit the emergency button on
the radio whether the emergency alarm on the radio goes off or
not. So the ones and zeros in a radio and implementing the
protocol that is published in the standard is critical because
that was built to do a certain function so you have to follow
the protocol to get the functionality that it is expecting. So
checking the ones and zeros is important, but I think, Mr.
Smith, you bring up a very important issue, which is
understanding what burden this may place on industry, and that
is something we have taken very seriously from the very
beginning. We realize that any additional testing that is
placed upon industry is going to cost money and so we have done
everything within this program to ensure that we are minimizing
the burden on industry, minimizing the financial requirements
that are needed to put the program in place, but our threshold
at any moment always has to be that we can look a fireman or a
policeman in the eye and tell them we created a program that
will give them the confidence necessary that when they hit the
button on that radio, that it is going to do what it is
supposed to do. Every wireless industry knows in a multi-vendor
environment that problems can occur. Find those problems in the
lab. Do not find them in the field.
Mr. Smith. Now, when you say confidence, is there
confidence lacking in the field today?
Mr. Orr. Yes, because right now--the traditional testing in
Project 25 until the Compliance Assessment Program was
developed was manufacturer testing in their own individual
laboratories and the P25 logo stating that that manufacturer
themselves believes that they have implemented the P25 standard
in a way that is consistent with the protocol. In every other
wireless industry, you have to take your radio to a third-party
lab, have it certified by a third-party body to get a logo that
say you are going to actually interoperate in the field. That
is a level of confidence that we are used to in Bluetooth
devices, Wi-Fi devices, cellular devices. That is the kind of
confidence that public safety is assuming and wanting in that
P25 logo that just doesn't exist.
Mr. Smith. That is not necessarily a government agency,
that certifying agency, or is it?
Mr. Orr. No, it is not a government agency. In all of those
industry cases, that is industry itself creating a body to do
that in all of those other industry cases.
Mr. Smith. But we have got the masses that are--the numbers
are quite different. Is that----
Mr. Orr. The numbers are different but the end result and
the need for the same end result, which is interoperability and
proper functionality, is not different.
Mr. Smith. Okay. Chief Johnson, do you feel that there is
confidence lacking in the field?
Chief Johnson. Mr. Smith, you know, I don't have any
personal knowledge that there is widespread lack of confidence.
I don't dispute his observations. And probably the reason for
that is, is that most of the systems I am familiar with are
purchased through a Request for Proposal [RFP] in a competitive
bid process and the procurement process in and of itself
requires that the compliance testing at the end of it
demonstrates that it is working and it is operable across the
system. So it is very common for us to say I am looking for
this kind of a system, and you don't get your money until you
prove that it works. So I think that kind of an environment
reduces my exposure to people that may be lacking confidence
but I wouldn't dispute his observation.
Mr. Smith. Back to Mr. Muench, there has been mention of
other products, other wireless products that are subject to a
third-party review. Obviously your company makes a lot of items
that probably would be subject to those third-party reviews.
Can you tell us the difference? What can we take away from that
for the good of this discussion?
Mr. Muench. Absolutely. To Dereck's point on compliance
testing, we believe that compliance testing is vital to making
sure that you have developed to the standard. The real issue
is, do you need to do these tests outside of the development
testing or do you need to validate them within development.
That is really what it comes down to. Motorola does the testing
today. And the litmus test or how Motorola determines whether
this is important to share with customers is when customers go
out to RFP, request the type of testing that the tests that
they require are interoperability tests. Customers can come to
us today and ask for, you know, before we give you our money,
we want to see your conformance tests and Motorola would be
happy to. We just haven't had those requests from our
customers, you know, outside the process for that level of
detail. So again, we look to the market, in this case the
public safety market, to request that of industry.
Mr. Smith. Thank you, Mr. Chairman.
Chairman Wu. I thought the chief said that as part of the
process that compliance testing is always asked for, and Mr.
Muench, I thought you said that conformance tests aren't
performed because customers don't ask for it. What am I not
understanding here?
Mr. Muench. So industry absolutely does conformance testing
during the development process. That is when you are developing
the software.
Chairman Wu. Mr. Muench or Mr. Orr, can you explain to me
later on the difference between developmental tests and, if you
will, tests after the----
Mr. Muench. Assessment tests, correct.
Chairman Wu. Go ahead with your answer.
Mr. Muench. I was just going to say, Motorola absolutely
supports and does compliance testing during the development
process to make sure that we adhere and are compliant to the
Project 25 standard as written. Motorola writes the actual
conformance tests and publishes them along with the other
industry within the P25 TIA process. So we have those
conformance tests. We run those conformance tests. The issue
is, once we develop a product, if there is--there hasn't been a
need to increase confidence around conformance. The customers
are looking for confidence around interoperability because that
makes sure that their emergency button when it is pushed on our
system goes through every time and that can be done through an
interoperability test with other manufacturers, and we do that
within our testing labs before we release products. We also do
them when customers come to pick up their systems and test them
within our factory. We will bring other manufacturers' radios
in and they can go and push the emergency button and make sure
it goes through and gets through.
Chairman Wu. Mr. Orr, would you care to address this issue,
and also the emergency button or distress button issue, whether
there is a problem or an issue there?
Mr. Orr. Sure. And if you would like, I can address the
development versus interop issue as well.
Chairman Wu. Go ahead.
Mr. Orr. I think the issue has come up in the past in
discussing how to implement the Compliance Assessment Program.
The question has been, when does the testing have to occur. The
manufacturers, as Mr. Muench has stated, believe that they
already do the testing in the development phase, so why do they
want to retest the equipment again after development phase? We
have recognized that and we have actually reached out to all
the manufacturers and said we are happy to allow the Compliance
Assessment Program to wrap into the development phase so that
you can do that testing in development and count that as your
compliance assessment. You just have to wrap the quality system
around it and have auditing, paperwork. You have to have the
right equipment and the right personnel doing the testing. The
equipment has to have been proven to actually work correctly,
the test equipment does. So you can do certain things but count
the tests going on in development as your compliance assessment
test. So we want to work with the manufacturers to make this
work for them. That is our goal. We want this to work but we
want to have a successful program.
As to the issue of conformance tests versus
interoperability tests, I think a very important point needs to
be made here. Again, and I hate to belabor this point, every
other wireless industry believes that conformance and
interoperability tests are necessary to ensure interoperability
in the field, not one or the other, both. It is not take one,
take the other. It is take both. The other issue for us that I
think is incredibly important for cost purposes is the
interoperability testing simply tests whether Manufacturer A's
works with Manufacturer B's product. You cannot infer that
because A works with B that A works with C. You have to test A
to C. That is the only way an interoperability test proves that
something works. Conformance test looks at----
Chairman Wu. Let me ask you, so if I have a product and I
can talk with you, Mr. Orr, and you have a product and Mr.
Smith has a product and you can talk with Mr. Smith, and even
though they are both P25 compliant, it may be that Mr. Smith
and I cannot talk with each other even though we can and you
can but Mr. Smith and I cannot communicate?
Mr. Orr. Absolutely, an interoperability test, if you and
Mr. Smith and I were the only ones that did our
interoperability test----
Chairman Wu. Well, that was the gist of my question
earlier. If that is the case, shouldn't one of our radios be
required to have the P25 sticker removed?
Mr. Orr. Well, and that is the importance of conformance
tests. How do you know who is not conforming? There is a couple
of cases that could have occurred here. One is, one of the
people making the radios didn't conform to the protocol
document so somebody is not P25 compliant. There is another
completely legitimate scenario which is both are complying with
the protocol document, which means the protocol document itself
has a problem and needs to be addressed. Those are legitimate
issues that can exist in any standards body, and that is why
these kind of programs are put in place.
Now, one more point, if I may, I want to make about
interoperability testing. Because it requires me to test
against every manufacturer, the permutations of tests against
all other manufacturers becomes quite large. Our program only
requires a manufacturer to test against three other
manufacturers. We don't require them to test against every
other manufacturer because what happens is, with every new
version and firmware revision that comes out years and years
down the line, that would mean you would have to do
interoperability testing back with every existing system that
is still in the field. If you get ten years down the line, you
would be looking at 8,000 interoperability tests. That is
financially impossible. Conformance testing allows each
individual manufacturer to prove adherence to the standard and
traceability to the standard without testing against another
product in the market.
Chairman Wu. Mr. Muench, you are not opposed to conformance
testing?
Mr. Muench. Absolutely not. We do it. We perform it today.
Chairman Wu. Mr. Smith.
Mr. Smith. So I guess I am still unclear. You are saying
that A and B might be compatible but A and C aren't, the users,
so how do you go about requiring and mandating tests without
having this huge burden that you just said you can't go back to
thousands of other points? Unless I am missing something.
Mr. Orr. So how do you find out whether A or B or A or C is
implementing correctly? Well, there are two things you have to
do to improve the confidence that it is going to work in the
field, in the labs. One is, you have each manufacturer run the
tests that show they have implemented the standard correctly,
the protocol. They have done it right. They look at the ones
and zeros and make sure they are in the right order, they are
in the right place, they have all met the standard correct. You
then do a series of interoperability tests to increase the
confidence that people are implementing correctly, but what we
have not done is said you have to go out and do
interoperability testing against every other manufacturer
because of the permutations of tests required and because of
the financial burden that would place on the burden.
Dr. Boyd. Basically what you are doing is what amounts to a
statistical series of tests. When you add the second test, I
can't be certain that my triangle--A, B, and C--works. When I
add the third test, I dramatically increase the likelihood that
you will be able to communicate with lots of other systems in
addition to the three we talk to. There is a point when testing
against more and more systems provides very, very small
diminishing returns. It is just the reality that I am far less
likely to have a conformance problem that creates an issue once
I have tested three or four systems. I don't have to test a
thousand systems.
Mr. Smith. Okay.
Chairman Wu. But if you test against the standard, you
don't have to guess about the number? You don't have to do
three to interpret that five also works. If you test against
the standard, then you know that it works?
Dr. Boyd. That is exactly right.
Mr. Smith. I am still trying to get a grasp of how urgent
this situation is, because I want to be sensitive to the use of
public funds, taxpayer dollars that are oftentimes in huge
amounts and having served at the local government level, these
are big hits to a budget and you want it to be effectively
spent and also have the opportunity in the future to acquire
maybe some updates and things like that that work and build
even greater confidence.
So Dr. Boyd, Mr. Orr, on a scale of one to ten, what is the
urgency for taking action? Ten being extremely urgent.
Dr. Boyd. I would say it approaches ten, and the reason
that I say that is, the reason this whole program started is
because the public safety community kept asking us how they
could know what works and what they ought to invest their very,
very precious and limited grant money on so they would not end
up in three years behind the eight ball because the standards
that were going to be required as part of the grant process
created new issues for them. In fact, I think it actually helps
industry because by providing that confidence to first
responders, they are much more likely now to begin to free up
and make those investments and they don't get challenged nearly
as much by county commissions or city councils who are
understandably very concerned that their first responders not
buy into a system that is going to turn out to not be
interoperable in three years.
Mr. Smith. Right. Okay. So you say it is extremely urgent
that action be taken.
Mr. Orr, same question.
Mr. Orr. I agree completely with Dr. Boyd.
Mr. Smith. Okay. Thank you, Mr. Chairman.
Chairman Wu. Thank you.
Ms. Biggert, would you care to ask questions?
Ms. Biggert. Yes. Thank you, Mr. Chairman, and I am sorry I
missed the testimony.
So I understand that you all have been discussing a little
bit of what I wanted to ask, and I am sorry I missed that, but
I am from Illinois and I know, Dr. Hofmeister, you work with
Naperville, which is in my district, and Mr. Muench, Motorola
has been a longstanding company in Illinois. Both do fine jobs.
I just wanted to ask you both, does there need to be an
industry-led formal compliance assessment program in place as
Mr. Orr has testified? Does either of your companies offer your
facilities to other vendors to validate interoperability across
multi-vendor product platforms prior to formal interoperability
testing under DHS and NIST guidelines?
Dr. Hofmeister. Thank you for the question. Certainly
Harris, as I think I mentioned earlier, has an interoperability
lab in our facility in Lynchburg, Virginia, as a result of
putting that together for the Compliance Assessment Program. We
also offer that for informal testing for other radio vendors to
come in. Motorola has been there testing some products they are
developing in terms of data. So yes, that is happening, and we
fully support that.
To your first question, whether it should be an industry-
led compliance assessment effort, sort of on the scale I think
of what other industries are doing, we at Harris have a hard
time thinking about that because of the size and scale of the
industry. We just can't afford to do everything to the scale
that cellular and other industries do. We have to make the best
judgments we can. I think the P25 Compliance Assessment Program
that is in place is moving in that direction. We support
conformance testing, as Mr. Muench mentioned, during product
development. We are less supportive of repeating that testing
afterwards but we are trying to work through the issues with
Mr. Orr and others to make sure that we meet those
requirements. So if you take a Wi-Fi system or something like
that, take WiMAX, for example, I believe it costs somewhere in
the neighborhood of $100,000 to $300,000 to put your product
through that testing. That is a scale, if you set that up. We
just can't support; and we don't believe the industry can
support that. Thank you.
Ms. Biggert. Thank you.
Mr. Muench, would you care to comment?
Mr. Muench. Thank you. Yes. Motorola absolutely supports
the informal testing. We have a lab set up. We visit the other
manufacturers' labs so very similar to what Dr. Hofmeister just
spoke of. As far as the first question, you know, the industry
that we work in is fairly small. There are 13 manufacturers,
and I can tell you from the DHS Compliance Assessment Program,
we have had 10 of the 13 manufacturers participate in our
interoperability testing and it is referenced on our Supplier
Declaration of Compliance that is loaded up onto the DHS site,
so I think participation is very good. I think confidence level
is fairly high. So at this point in time, I don't believe that
a formal program led by industry is necessary.
Ms. Biggert. Do you work with other manufacturers in your
testing or do you rely solely on your internal tests?
Mr. Muench. No, we absolutely work with other
manufacturers.
Ms. Biggert. Is it possible that a communication device
could pass the test but fail to operate, interoperate
seamlessly with a third vendor's product?
Mr. Muench. In the extreme case where a manufacturer either
didn't have the expertise or was trying deliberately not to
conform, yes. The experience that we have had with deploying
product, we have not come across that yet. The industry, we
have a good working relationship with each other and we--it is
in all of our best interests to make sure that these products
interoperate together as specified in the Project 25 standard.
Ms. Biggert. Thank you very much. I yield back, Mr.
Chairman.
Chairman Wu. Thank you.
I think what I just heard is some concern about a formal
compliance testing process. In the written testimony, there was
testimony to the fact that the European standard, TETRA
[Terrestrial Trunked Radio], requires a formal testing process
and that American manufacturers which sell in Europe actually
go through this compliance testing process. What distinguishes
the approach you take in Europe where there is this testing
versus your position here in the United States?
Mr. Muench. The first point is that it is actually mandated
by the E.U. that you perform this level of testing, which right
now the tests are over 300 tests and take a significant amount
of time to get a product certified through that process. The
concern here would be that by putting those rigorous tests and
that amount, as I said, depth into the testing in a formal
process, and again, looking at the permutations of how many
products you bring to market as well as a number of
manufacturers, you could slow down the adoption of Project 25
and actually create larger barriers of entry to smaller
companies.
Chairman Wu. But we heard concerns about the cost of
testing and yet you still find it worthwhile to be in the
European market where this testing has to be performed?
Mr. Muench. Absolutely. We support standards that are
defined by their marketplace.
Chairman Wu. Dr. Hofmeister or Mr. Orr?
Dr. Hofmeister. Just a quick comment on the TETRA testing.
We don't actually participate in that market with the TETRA
testing, but we do sense that there are some second thoughts in
that marketplace and they are sort of thinking of the cost and
there is one document with a recommendation that you actually
do conformance testing along with interoperability. You do
interoperability testing and do some conformance monitoring as
part of that to maybe help reduce the impact, and that is
something we have talked about with Mr. Orr and his colleagues
about--maybe that is something that we could consider as a way
of doing interoperability testing and doing conformance
monitoring as part of that process.
Chairman Wu. Any comments from either Mr. Orr or Dr. Boyd?
Mr. Orr. I would just like to reiterate, we certainly
looked at the TETRA model. We heard loud and clear the
manufacturers in Project 25 concerns about the costs, and like
I said before, we have truly tried in every way possible to
make this as least burdensome a process on the U.S.
manufacturers. We do not want to negatively impact the U.S.
manufacturers. We do want to create a higher level of
confidence for our public safety users that the products are
going to work when they are in the field and they need those
radios to work. So I do want to make that very clear, and I
also would like to make the point that I think both of these
companies have pointed out in the past, it was the Compliance
Assessment Program itself that really started to open up these
multi-manufacturer laboratories and create the atmosphere where
multiple manufacturers began to travel to other manufacturers'
labs and test within them. So it has had a beneficial impact
but we do pay attention to their concerns and we continue to
work with them to make this a beneficial but cost-reducing
program.
Dr. Boyd. I think that is an important point, which is why
the program very consciously decided that we ought to use
existing manufacturers' laboratories, not invent a new Federal
laboratory to drive all of this. That is really the foundation
piece of the model.
Chairman Wu. Thank you. I believe, Mr. Smith, you have some
further questions.
Mr. Smith. Let me ask Chief Johnson, on a scale of one to
ten on urgency for action in terms of where we are today and
what needs to be done, on a scale of one to ten, how urgent is
this?
Chief Johnson. Thank you, Mr. Smith. Pursuing this where we
are today in the Project 25 standard has not been my primary
area of study, so I really do not have a feel for it, sir. I
think reflecting back on my comment about how in public safety
we make sure that we are buying compliant products, I think the
larger the purchase, the larger the scale and the more likely
you are to use a request for proposal bid system where you can
hold people accountable on the back end for functional testing,
the safer you are as a public safety responder. If you buy one
or two radios, you are more subject to the certification and
having to trust the certification. I think to reiterate a
component of my testimony, and I really appreciate where the
Committee is coming from in this regard is, at the end of the
day, I think it is unreasonable to expect a police chief or a
fire chief to be conversant enough in the technical details,
and I think you basically want to be able to look at a standard
and trust that that standard says it will work from provider to
provider to provider in case you are not doing an RFP-based
system where you can actually test in a field.
Chairman Wu. Chief, it is awfully hard for a Congressman to
be conversant in this area also.
Mr. Smith. Here, here. Thank you, Chief.
On the European model then, is that a more desirable
situation, Dr. Boyd?
Dr. Boyd. I don't think we want a mandated system that in
fact is very, very government heavy and very, very government
driven, and quite frankly is much more expensive than anything
we think is really appropriate to put into place here. I think
we want the kind of voluntary consensus-based assessment
program that we have.
Mr. Smith. Mr. Orr, is that European model more desirable
than what we have now?
Mr. Orr. No, I believe what I would like to see happen is
for the program we have in place to become fully functional,
and if that meets the requirements and we see in the field what
needs to happen and the result is that we have equipment that
meets the standard and we don't have any significant problems
in the field, then the program is working and there is no
reason to do anything more than that.
Mr. Smith. Dr. Hofmeister, would TETRA testing be the
reason Harris is not in Europe?
Dr. Hofmeister. No, I don't think that is the full reason.
I think it is just a full business reason. That would be a
component but not----
Mr. Smith. Contributing factor?
Dr. Hofmeister. A contributing factor but not a full
reason, right.
Mr. Smith. Anyone else wishing to weigh in? Thank you.
Chairman Wu. If none of the Members of the Subcommittee
have any further questions, I would like to offer folks this
opportunity because you all have come a long ways and also done
a lot of preparation for this hearing, so if there is anything
that we have not asked but you would like to contribute to this
hearing, I would like to give you an opportunity going from
left to right to add that now. Dr. Boyd?
Dr. Boyd. Just one brief point, and that is to remember
that while we have been talking about land mobile radio, the
movement of the world into a digital arena means that we are
now really talking about interoperability across all of these
digital systems and so over the long haul we have to remember
that as we look at interoperability, we have to think beyond
just voice into data maps, imagery, video and all the rest that
public safety requires in large-scale emergencies like so many
of these we have unfortunately seen in the last few years.
Chairman Wu. Mr. Orr?
Mr. Orr. I would simply end on the fact that I would point
out that over the last few months, like I said in my testimony,
we have been having some healthy discussions with our industry
partners in Project 25 and we are moving forward and deciding
what are the appropriate interoperability performance and
conformance tests for each of the existing interfaces right
now, and I feel confident and I want to remain confident that
when we report back to the Committee at some point that we will
have seen progressed and moved forward in this issue, but I
think the momentum over the last few months has been a positive
one.
Chairman Wu. Dr. Hofmeister?
Dr. Hofmeister. Yes, thank you, Mr. Chairman. Just a couple
points that didn't come out and were in my written testimony in
terms of recommendations. One, there is an array of mandatory
and standard option features that are part of the standards
suite. One suggestion would be to get the user community and
manufacturers to work together to define those into packages,
baseline level zero, baseline level one, so that you could
refer to them as packages and not have to constantly refer to a
whole array of these things. I think that would help with
simplification of what it is compliant with and what the
functionality is. But even more than that, and it gets back to
Dr. Boyd's testimony, the interoperability, again, to define
levels of interoperability from very baseline level zero, what
functions are required there, level one, and make sure those
are rock solid. Right now, I think there could be much progress
in making sure that you define what those levels of
interoperability are and make sure those are present and tested
for in every product. Thank you.
Chairman Wu. Thank you.
Mr. Muench.
Mr. Muench. Thank you, Mr. Chairman. Yes, I would just like
to reiterate that significant progress has been made in Project
25 and we continue to stay up with technology maybe making it
look like we are not making progress but we continue to adopt
new technology. As we move forward, Motorola absolutely
supports the formal Compliance Assessment Program but we would
like to make sure that industry representation is part of that
process since it is industry that are the ones that write the
standards, we are the ones that develop the equipment,
manufacture the equipment and actually perform the testing. So
again, having these industry experts as part of the process and
providing, you know, the recommendations, we have been making a
lot of progress as of late and we are going to continue to make
progress.
Chairman Wu. That is a good thing. Thank you, Mr. Muench.
You know, these are consensus standards developed by multiple
parties, mostly private industry, and my understanding is that
Underwriter Laboratories and such testing efforts are also
joint ventures of private industry. Thank you.
Chief Johnson?
Chief Johnson. Thank you, Mr. Chairman and Members of the
Committee. We have spent a great deal of time today talking
about the technical standards and how functional the radio
system is. As Oregon's governor asked me to solve Oregon's
interoperability problem, I found myself in front of the House
and the Senate trying to explain what the national standard was
for interoperability in a radio network, and it was then that I
discovered there wasn't one, that there was no national
recommendation for radio network, and I think that part of our
problem is, of course, the technical matters we talked about
today, but that is only one of the swaths in terms of solving
interoperability. I think what we need next to truly move past
our interoperability challenges in this country is, we need a
predictable national architecture for public safety
communications, and that means that we combine the public
safety broadband spectrum which is allocated today with the D
block and that will create an adequate enough swath that we can
foresee and predict that public safety will move into what I
will call a radio over Internet protocol, and OEC [Office of
Emergency Communications] has actually identified this in their
dual path strategy about moving from this land mobile radio-
based environment that we have today, moving out of--(frankly,
there are still systems out there today operating on crystal
radios and many system operating on stamp chip sets) to moving
to an Internet protocol-driven radio system.
Now, this will take time. Moving from LMR today to IP
[Internet protocol] radio is going to take many, many years but
it is the only way to identify a national architecture that
will draw industry to a common place and give fire chiefs and
police chiefs a predictable system that we can move to and move
out of interoperability being this connection sideways to this
disparate radio spectrums, and if we don't identify an adequate
enough path moving forward, we are going to address our
frequency spectrum limitations by adding yet another small
swath out of yet another spectrum, and that will perpetuate the
interoperability problems that we have faced for the last 30
years. I hate to quote Dr. Phil, but I would just ask, ``How is
that working for us?'' We have 30 years of giving us little
slice by little slice by little slice and we haven't got the
job done. It is time to take this one-time opportunity, Mr.
Chairman, when we vacated these TV stations to allocate the D
block to public safety. That will give us a predictable swath
that will move us toward radio over Internet protocol.
Mr. Chairman, Members of the Committee, I appreciate the
opportunity to be heard.
Chairman Wu. Thank you very much, Chief.
This has been a steep technical hill for the Committee to
climb, for Members to climb, for staff to climb, and I want to
thank you all for helping us understand that. It still seems
that there is some differences in viewpoint or perhaps we are
talking about technical standards in a slightly different way.
What it comes down is, I remain concerned that Mr. Smith and I
can both have handhelds and each of us can talk with the chief
and yet we can't talk with each other and all three of us have
P25 certified systems Project 25 systems. It seems to me that
if it is P25 certified, we should have taken the standards and
the testing to a point where these three P25 certified devices
will all talk with each other rather than two of them not
communicating, and I remain concerned about that. And evidently
there is consensus in the panel that progress has been made and
that some important progress has been recently made, and I
encourage all the parties which are active in this industry,
the government players and the end user community, to work
together in the best spirit of doing what is good for customers
and shareholders and especially the general public to develop
systems which are interoperable and dependably so and permit
additional layers to be added on without dire problems. It is
in that spirit that I want to seriously consider holding a
follow-up hearing to see where we are on this and to clarify
issues that remain unclear, and I will take responsibility for
the fact that perhaps we haven't dug deeply enough in this
particular hearing.
Again, I want to thank each and every one of you for
appearing, for your travel time, for your preparation time. The
record will remain open for two weeks for additional statements
from Members and for questions, additional questions and your
answers to follow-up questions that the Committee may ask.
The witnesses are excused and the hearing is adjourned.
Thank you very much.
[Whereupon, at 11:45 a.m., the Subcommittee was adjourned.]
Appendix 1:
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Answers to Post-Hearing Questions
Responses by Dr. David Boyd, Director, Command, Control and
Interoperability Division, Science and Technology Directorate,
Department of Homeland Security (DHS)
Questions submitted by Chairman David Wu
Q1. P25 equipment purchased with DHS grant dollars must follow the CAP
testing and evaluation requirements. How does DHS monitor the grant
programs to ensure that grantees follow this requirement?
A1. The DHS Office of Emergency Communications (OEC) and the Office for
Interoperability and Compatibility (OIC) support SAFECOM's development
of guidance, research, testing, and standards of communications
technology. SAFECOM issues an annual document titled ``Recommended
Guidance for Federal Grant Programs'' to provide a point of reference
for Federal grant programs that fund interoperable emergency
communications activities. The guidance is intended to ensure that
Federal grant funding for interoperable communications aligns with
national goals and objectives and ensures alignment of state, local,
and tribal investment of Federal grant funding to statewide and
national goals and objectives.
The SAFECOM guidance specifically states that when a grantee
procures P25 equipment and systems they should, at a minimum, ``ensure
the vendor has participated in equipment testing consistent with the
Project 25 Compliance Assessment Program (P25 CAP).''
FEMA/GPD acknowledges this guidance and incorporates it by citation
into all grant guidance and application kits, ``States that are using
FY 2010 HSGP funds to purchase Interoperable Communications Equipment .
. . must consult SAFECOM's coordinated grant guidance, which outlines
standards and equipment information to enhance interoperable
communications.''
FEMA/GPD does not monitor its grantees to ensure they follow the
P25 CAP requirement. However, in an effort to assist grantees
purchasing communications equipment, information related to the P25 CAP
has been incorporated into the Responder Knowledge Base (RKB) website,
which maintains the DHS Authorized Equipment List. P25 vendors can now
include test result summary reports and a Supplier's Declaration of
Compliance (SDoC) on the RKB for grantees to reference.
The grant program that most directly addresses the P25 CAP is the
Public Safety Interoperable Communications (PSIC) grant program, which
is administered by both FEMA/GPD and the National Telecommunications
and Information Administration (NTIA). Approximately 90 percent of all
available PSIC funding ($848 million out of the available $968 million)
is being used by grantees to acquire and deploy equipment to improve
interoperable communications.
As background, the PSIC Grant Program Guidance and Application Kit
released in August 2007 stated that:
``Agencies purchasing Project 25 (P25) compliant equipment
must obtain documented evidence from the manufacturer that the
equipment has been tested to and passed all of the applicable,
published, normative P25 compliance assessment test procedures
for performance, conformance, and interoperability as defined
in the ``Grant Guidance--Project 25 Explanatory Addenda,''
which can be found at www.safecomprogram.gov/SAFECOM/grant/
defaults.htm.''
In June 2009 with the designation of the initial eight laboratories
approved to test equipment under the P25 CAP, PSIC program managers and
officials from the Office of Emergency Communications (OEC) met with
the National Institute of Standards and Technology (NIST) Office of Law
Enforcement Standards and received guidance on the program. The PSIC
Grant Program included language in its technical assistance offering in
the National Preparedness Directorate Technical Assistance Catalog.
Q2. Acknowledging that P25 is a work in progress, at the end of his
testimony, Dr. Hofmeister suggested that defining the standard
functions and features included within a ``package'' may offer public
safety a clearer picture of the functionality of the LMR systems they
are choosing. What are your thoughts on this recommendation or on other
ways of providing agencies with a better window into the status of P25
and the implications the status may have on functionality?
A2. Defining the standard functions and features required to identify a
product as P25 compliant would provide greater transparency to the
public safety community. A common definition for the sets of features
offered by manufacturers could be beneficial, but only if it better
informs the public safety community's procurement process and defining
these feature sets does not cause additional delays. When there is a
common definition of features across manufacturers, public safety
officials can directly compare equipment based upon its functionality
and how it will meet their requirements. This transparency combined
with a robust compliance assessment program, including conformance
testing, will provide increased confidence that equipment will meet the
needs of the public safety community. (Conformance testing demonstrates
how equipment conforms to the standard and will interoperate with all
compatible equipment that correctly implements the standard, including
equipment that was not tested.)
The Office for Interoperability and Compatibility (OIC) and the
National Institute of Standards and Technology (NIST) are actively
working to provide more information on P25 to the public safety
community. The P25 Document Suite Reference identifies the current
status of the highest priority P25 standards. Manufacturers are also
required to submit Suppliers' Declaration of Compliance (SDoC) and
Summary Test Reports. The SDoC is the manufacturer's formal, public
attestation of compliance with the standards for the equipment. The
Summary Test Reports provide the equipment purchaser with a summary of
the tests conducted on the equipment along with the testing outcome.
All of these documents are available to the public safety community
through the Federal Emergency Management Agency's Responder Knowledge
Base Web site (https://www.rkb.us/) and through NIST's Public Safety
Communications Research Program Web site (http://www.pscr.gov/).
Q3. In your testimony you mentioned that there are products in the
field that were built in the early phases of P25 and that these
systems, though labeled P25, may not interoperate. How widespread is
this problem and how well aware are public safety agencies that their
older P25 systems may not interoperate with newer systems?
A3. There are more than 50,000 public safety agencies throughout the
United States, each with its own local and state government regulations
and requirements that can impact interoperability. It is difficult to
assess how widespread the problem is. Often responders do not know
whether they can truly communicate until the need to interoperate with
different agencies arises. Based on our work in the field, there is a
perception in the public safety community that buying P25 equipment
does not guarantee interoperability. The perception that P25 equipment
does not interoperate has impacted the pace of adoption. The best way
to ensure P25 systems can communicate and also improve the public
safety community's confidence in these systems is to have a robust
compliance testing program that includes conformance testing.
The Department of Homeland Appropriations Act, 2007, (P.L. 109-295,
Title VI, Sec. 672(a)) (October 4, 2006) amended the Homeland Security
Act of 2002 (Act), by adding a new section 314 to that Act. Under
section 314, codified at 6 U.S.C. 195, the Director of the Office for
Interoperability and Compatibility is required to, among other things,
in coordination with the Federal Communications Commission, the
National Institute of Standards and Technology, and other Federal
departments and agencies with responsibility for standards, support the
creation of national voluntary consensus standards for interoperable
emergency communications. P25 CAP provides a process through which
equipment can demonstrate that it correctly follows the standard and is
able to interoperate with other equipment following the standard. When
interoperability testing is combined with conformance testing, the
public safety community can be assured that equipment conforms to the
standard and will interoperate with all compatible equipment that
correctly implements the standard, including equipment that was not
tested. Conformance testing helps provide increased confidence that
equipment developed in the future will retain compatibility with legacy
systems.
Q4. One issue raised at the hearing was that some of the
interoperability problems that have emerged were not due to a failure
to conform or comply with the standard, but were due to configuration
issues. Do you agree with this? What is the role of the P25 process
and/or the Federal Government in ensuring that configuration issues do
not hinder interoperability?
A4. Radio systems are complex and include many features and functions
that need to be configured. The way a radio is programmed varies from
manufacturer to manufacturer. When public safety practitioners respond
to an emergency and attempt to use their own equipment to communicate
with responders from different agencies they may be forced to
reconfigure their radios. This effort can waste valuable time and
expend limited resources during an emergency. Additionally, improperly
configuring a radio can prevent interoperability. Configuration issues
could be addressed either through the voluntary consensus process or
directly by manufacturers.
To date, P25 has focused on standardizing interfaces instead of
internal functions of equipment, such as the method for configuration.
Communication standards focus primarily on standardizing the interfaces
because that is critical to ensuring devices can communicate across
manufacturers. Internal device functions allow for product
differentiation and manufacturers are free to be innovative with their
product as long as they correctly implement the interface, allowing for
interoperability.
Questions submitted by Representative Ben R. Lujan
Q1. I am glad to see that we are having this important discussion, and
I look forward to working with you all and my colleagues on policy that
supports effective, high-tech public safety equipment. As a border
state, New Mexico is faced with unique public safety challenges. Can
you elaborate on how interoperability can affect border security? How
can we support interagency coordination as well as coordination with
state and local governments on establishing interoperability standards
and technology to assist border security efforts?
A1. Since its creation, the Office for Interoperability and
Compatibility (OIC) has supported user driven processes such as P25.
Recognizing the need for an open and transparent compliance process,
OIC established a P25 Compliance Assessment Program Governing Board to
represent the collective interests of organizations that procure P25
equipment. The Governing Board consists of local, state, and Federal
Government employees who are active in the operation or procurement of
communication systems. Members of the Governing Board represent states
and communities on the northern and southern border. Their input into
the Governing Board helps ensure the work benefits interoperability on
the border.
Questions submitted by Representative Gary C. Peters
Q1. First responders in Michigan and other border regions must be
prepared to coordinate with foreign first responders should an
emergency occur at border crossings. Has the effort to increase
compliance and interoperability of public safety LMR systems included
coordination with international entities, such as Canadian first
responders and regulators?
A1. As part of its efforts to improve interoperability, the Office for
Interoperability and Compatibility (OIC) is coordinating with
responders from Canada. Representatives from OIC have participated in
the Canadian Voice Interoperability Workshop to discuss the need to
accelerate P25 standards and use a robust compliance process.
Additionally, the P25 Compliance Assessment Program provides a
universal method for testing for compliance to P25, which is used
internationally.
Q2. First responders in Michigan tell me that radio communication
would be one of the most significant challenges in communicating with
Canadian personnel in case of emergency and that they currently lack
the capability to communicate in the event of a large scale disaster
such as a tunnel failure or bridge sabotage at the border. Has there
been any effort to develop or provide first responders at border
regions with specialized shared radio units that would provide seamless
cross border communication? Have government regulators worked with
Canadian regulators to discuss how to create radios that would be
interoperable and meet both countries' regulatory requirements?
A2. One of the goals of Office for Interoperability and Compatibility's
(OIC) Multi-Band Radio (MBR) Project is the advancement of MBR
technology to improve key communications between local, tribal,
regional, state, and Federal agencies. To do this, OIC is collaborating
with practitioners and industry to develop MBR technology that will
enable a single radio to operate across disparate radio bands in use by
the emergency response community in both the United States and Canada.
OIC is funding the test and evaluation (T&E) of a single handheld MBR
through three phases of pilot testing. Phase One involved T&E by U.S.
and Canadian emergency response organizations along the Seattle/Blaine,
WA border region and other Canadian emergency response agencies (e.g.,
Vancouver Transit Police) during the 2010 Olympics. During Phase Two,
representatives of various emergency response disciplines in Michigan
will use the MBRs, which have already been deployed and programmed.
Upon the completion of full software development, OIC plans to conduct
another pilot with cross-border potential in Phase Three with DHS's
Customs and Border Protection in the Greater Detroit area. Pilot
planning remains underway and is expected to include Canadian
counterpart agencies. Additionally, OIC is collaborating with
practitioners in Nogales, Arizona to conduct MBR T&E along the
southwest border.
U.S. and Canadian regulators have a close working relationship and
have worked together for many years to share radio spectrum along the
border region. This is no simple task, as radio signals do not stop at
the border and each nation has equal access to all radio spectrum. The
State Departments of both Nations, the U.S. Federal Communications
Commission, the National Telecommunications and Information
Administration, and the Canadian spectrum regulatory body, Industry
Canada, have all been actively engaged in solving regulatory issues,
including the sharing of the radio spectrum along the border region.
Answers to Post-Hearing Questions
Responses by Mr. Dereck Orr, Program Manager, Public Safety
Communications Systems, National Institute of Standards and
Technology (NIST)
Questions submitted by Chairman David Wu
Q1. Acknowledging that P25 is a work in process, at the end of his
testimony, Dr. Hofmeister suggested that defining the standard
functions and features included within a ``package'' may offer public
safety a clearer picture of the functionability of the LMR systems they
are choosing. What are your thoughts on this recommendation or on other
ways of providing agencies with a better window into the status of P25
and the implications the status may have on functionability?
A1. Public safety users today have great difficulty understanding what
P25 is or means as they are procuring equipment. Part of that confusion
stems from the fact that not all of the P25 interface standards are
complete. Additionally, there is no set of standardized features
required for a product to be labeled P25. The definition of a feature
set required for the use of the P25 logo would give public safety
increased confidence that a system labeled as P25 at least meets a
minimum set of requirements and promotes interoperability.
Public safety users also benefit from the clear definition of each
feature's completion status. With this information, public safety can
determine which features of a system are truly standardized, and thus
make better-informed procurement decisions.
In response to the absence of these initiatives within the P25
process, NIST and the Department of Homeland Security's (DHS) Office
for Interoperability and Compatibility (OIC) have instituted the P25
Document Suite Reference (P25 DSR) and the P25 Compliance Assessment
Program (P25 CAP). The P25 DSR identifies the current status of each of
the five standards that make up the P25 interfaces. This information is
updated following each P25 standards meeting, or faster as needs
dictate. The P25 DSR can be found on the Public Safety Communications
Research (PSCR) program's website (www.pscr.gov).
Addressing the lack of a standard feature set required for the use
of the P25 label, NIST and the Department of Homeland Security launched
the P25 Compliance Assessment Program, a voluntary program that allows
P25 equipment suppliers to formally demonstrate their products'
compliance with a select group of requirements by testing it in
recognized labs. The output, Suppliers' Declarations of Compliance and
Summary Test Reports, from the P25 CAP are available on DHS's
Responders Knowledge Base website (www.rkb.us). All agencies (Federal,
state, and local), however, have a unique set of requirements or
operating conditions, and as such, each agency should require test
information for those unique requirements, beyond those provided by the
P25 CAP, during their procurement process (i.e., through Request for
Proposals (RFPs), etc.).
Q2. One issue raised at the hearing was that some of the
interoperability problems that have emerged were not due to a failure
to conform or comply with the standard, but were due to configuration
issues. Do you agree with this? What is the role of the P25 process
and/or the Federal Government in ensuring that configuration issues do
not hinder interoperability?
A2. NIST does not know the degree to which configuration issues lead to
radio problems in the field, but in our experience, the difficulty in
configuring or programming a public safety radio, which varies from
manufacturer to manufacturer, can be considerable. One variable that
plays a large role in the complexity of radio configuration is the
number of features incorporated into each radio. Additionally, each
manufacturer has a different physical method of programming the radios
along with a different software interface. In other words, there is no
common method of configuring radios across multiple manufacturers.
This complexity, and the lack of a standardized method for
programming radios across different vendors, can lead to operability
and interoperability issues. However, in discussions with public safety
organizations responsible for the provisioning of radios operating on a
system, we have been informed that many of the issues found in the
radios also require software upgrades to the radios themselves rather
than a simple reconfiguration. Thus we are confident that some issues
found in the field are due to problems beyond configuration and
programming, and are instead due to non-conformance to the standard or
problems with the standard itself.
That said, we do believe that configuration issues could become
critical, hindering interoperability during an event where agencies
from surrounding areas bring their own equipment into a response. If
each radio used in an event requires configuration prior to use, and
reconfiguration is complex and difficult, then the ability to
communicate could become compromised.
If configuration issues are indeed contributing to interoperability
issues, as has been identified by Mr. Hoffmeister, then it behooves
those involved in the P25 process to address this issue given that the
purpose of P25 is to standardize interfaces to facilitate
interoperability.
Questions submitted by Representative Gary C. Peters
Q1. First responders in Michigan and other border regions must be
prepared to coordinate with foreign first responders should an
emergency occur at border crossings. Has the effort to increase
compliance and interoperability of public safety LMR systems included
coordination with international entities, such as Canadian first
responders and regulators?
A1. Coordination among American and Canadian first responders is
critical should an incident occur at the border. It is important that
both American and Canadian public safety agencies are able to leverage
P25 standards to increase confidence in interoperability among their
systems. It is also important that PSCR and other Federal emergency
communications agencies work closely with their Canadian counterparts.
For the last several years, PSCR staff have been invited to
participate in the Canadian Voice Interoperability Workshop to speak on
issues such as P25 and voice quality in land mobile radio systems.
During these presentations, PSCR staff speaks to the status of P25
standards development and points out the fact that Canadian public
safety agencies can also use the P25 CAP given the public distribution
of the information. PSCR anticipates continuing its participation in
such events as long as invited. In addition to direct participation in
Canadian interoperability events, PSCR has committed to sharing all
work product that can be shared publicly with the Canadian first
responder community.
In addition to this direct cooperation with Canada, other
organizations are working directly on border interoperability issues
with both Mexico and Canada. These organizations include the Department
of Homeland Security's Office of Emergency Communications (OEC) and its
Border Interoperability Demonstration Project as well as the National
Public Safety Telecommunications Council's Border Issues Working Group.
Q2. First responders in Michigan tell me that radio communication
would be one of the most significant challenges in communicating with
Canadian personnel in case of emergency and that they currently lack
the capability to communicate in the event of a large scale disaster
such as a tunnel failure or bridge sabotage at the border. Has there
been any effort to develop or provide first responders at border
regions with specialized shared radio units that would provide seamless
cross border communications? Have government regulators worked with
Canadian regulators to discuss how to create radios that would be
interoperable and meet both countries' regulatory requirements?
A2. While PSCR works directly with the Canadian first responder
community (through Industry Canada and the Canadian Interoperability
Technology Interest Group), it does not work with specific border
agencies in either the U.S. or Canada. Both DHS OEC and DHS OIC have
direct relationships with their Canadian counterparts and are likely
better informed to answer this question.
Answers to Post-Hearing Questions
Responses by Dr. Ernest L. Hofmeister, Senior Scientist, Harris
Corporation
Questions submitted by Chairman David Wu
Thank you Chairman Wu for your sincere interest in the Hearing
subject and related topics. Harris appreciates the opportunity to
provide additional information in response to your questions.
Q1. At the end of your testimony you suggested that ``there could be
much progress in making sure you define what those levels of [baseline
and above] of interoperability are and make sure those are present,
tested for and present in every product.'' What would be required to
implement this type of product labeling?
A1. The intent of this comment was to reference one of the Harris
recommendations in the written testimony that: ``Agreement among public
safety agencies on the features for interoperability, as defined by
several levels of interoperability, would be beneficial. These levels
could include: P25 Interoperability Capability 0 (baseline); P25
Interoperability Capability 1 (Capability 0 plus more features), etc.
This grouping of interoperability capability features would make
specification and testing of interoperability simpler, more efficient,
and adaptable to the interoperability needs of various public safety
agencies.'' Within the P25 suite of standards, there is an array of
mandatory and standard option features.\1\ As the name implies,
mandatory features are those features that must be included in every
P25 radio and system product. For example, Unaddressed Voice Call is a
mandatory feature for the conventional mode of operation and Group Call
Voice is a mandatory feature for the trunked mode of operation. For the
current published suite of P25 standards, there are approximately 10
mandatory conventional features and 13 mandatory trunked features.
However, for standard option features, there are approximately 30
standard option conventional features and 34 standard option trunked
features. A standard option feature is a feature that the user has the
option of purchasing/deploying and the manufacturer has the option of
providing in its P25 radio and system product. With the 10-13 mandatory
features representing the most basic level of operation and the 30-34
standard option features variably implemented in public safety P25
systems according to the buying needs/requirements of the user and the
manufacturers option to provide, the range of P25 features varies
significantly from P25 system to P25 system. The reason for the
relatively large number of standard option features is to allow
flexibility for various size public safety agencies to implement
systems with capability scaled to their needs from relatively small,
lower capability to very large, high capability needs. While such
flexibility is good to allow adaption to user needs, it does create
challenges when attempting to define one or more standard
interoperability profiles (levels of capability) that can be tested and
practiced with high assurance that the needed interoperability will
work well when needed.
---------------------------------------------------------------------------
\1\ The official definitions of mandatory and standard option
features are included in the Project 25 Statement of Requirements (P25
SoR, Mar 3, 2010 Approved Version) as:
GA Mandatory service, feature, or capability
supported by the suite of P25 standards is to be supported
by all P25 systems. Implementation of the so-designated
services, features, or capabilities shall comply with the
---------------------------------------------------------------------------
P25 standards defined by TIA.
GLikewise, a Standard Option service, feature, or
capability is supported by the suite of P25 standards. The
user has the option of deploying so designated services,
features, or capabilities. Likewise, manufacturers have the
option of offering so designated services, features, or
capabilities. If deployed in a particular P25 system,
implementation of the Standard Option shall comply with the
P25 standards defined by TIA.
It is Harris' view that with such variability and flexibility in
P25 features supported, interoperability in terms of features/
capability means something quite different from public safety agency to
public safety agency and especially from smaller, more likely rural
agencies to larger, more likely metropolitan agencies. As noted in the
Harris written testimony, ``although challenging and having been
discussed a number of times by users and manufacturers in the P25
standards community, the array of P25 mandatory and standard option
features could be grouped or packaged into levels of increasing
capability; i.e., P25 Level 0 (baseline); P25 Level 1 (Level 0 plus
more features); P25 Level 2; etc. This grouping of features could make
the product marking of features supported and the P25 CAP testing of
features packages more simplified and efficient.'' A similar grouping
or packaging of features into levels or profiles of interoperability
would reduce the large variability in terms of interoperability
features supported to a reduced set levels or profiles. Such grouping
of interoperability capability features would make specification,
testing, and marking of interoperability capability simpler, more
efficient, and adaptable to the interoperability needs of various
public safety agencies.
Harris views that the steps needed to implement such a
specification, testing, and marking of interoperability levels or
profiles would include:
a. P25 knowledgeable public safety agencies working together
for consensus to define the P25 features for several levels of
interoperability capability. These levels or profiles could
include: P25 Interoperability Capability 0 (baseline and
probably just the mandatory features); P25 Capability 1
(Capability 0 plus more features); P25 Capability 2 (Capability
1 plus more features), etc. Harris would envision that there
should be five or fewer capability levels.
b. Once the Capability Levels are defined in item a, the P25
community (industry and users) would select or develop the
interoperability test standards corresponding to the features
specified in the Capability Levels. This could be a selection
of a subset of tests in the current trunked voice
interoperability and the conventional voice interoperability
standards. For the higher level(s) of interoperability, it may
be necessary to develop supplemental interoperability tests for
the standards.
c. The results of item b could be provided to the P25
Compliance Assessment Program Governing Board for their
consideration to incorporate into the formal P25 Compliance
Assessment Program interoperability tests through a Compliance
Assessment Bulletin (CAB).
d. The current or additional Recognized P25 Compliance
Assessment Laboratories could be assessed as necessary and
recognized for these Interoperability Capability Levels.
e. Manufacturer's products could then be tested in the P25 CAP
Recognized Laboratories per the CAB.
f. Based on the results of the P25 CAP interoperability
testing, the posted Summary Test Reports (STRs) and the
Supplier's Declaration of Compliance (SDoCs) could reflect the
Interoperability Capability Level(s) passed.
f. If desired, a suitable P25 Interoperability Capability
Level sticker or marker could be developed and used to visually
show the P25 Interoperability Capability Level of the subject
P25 product.
This approach could be consistent with the testimony during the
Hearing of Dr. Boyd, ``The way we talk about standards is that there
ought to be some core set of functionalities that we make sure remain
in place. I think the manufacturers are working very closely with us to
develop that core set of functionalities.'' \2\
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\2\ From 5.27 hearing transcript for Dr. Boyd statements at lines
874 and 883.
Q2. One issue raised at the hearing was the difference between
performing conformance testing while the product is in development and
doing so after the product has been developed. Can you please comment
on Mr. Orr's statement that testing during development meets
conformance testinq requirements if done with the ``right'' equipment
and quality system in place? What is involved in developing the testing
---------------------------------------------------------------------------
equipment and quality system?
A2. As a preface before answering the question and specifically on ISSI
conformance testing, Harris views ISSI conformance testing as a design
verification method used on software subsystems during product
development in engineering laboratories. Harris does conformance
testing as part of product development in engineering laboratories and
at various stages of development (e.g., unit test, integration test,
and SVT) to verify subsystem design. The testing is less formal, but
done. In general, Harris does not feel that repeating conformance tests
on a formal basis after complete product development adds significant
value compared to the effort required. Harris is on public record
several times in comments \3\ \4\ to the P25 CAP Governing Board
regarding its position on formal P25 CAP ISSI conformance testing. That
being said, Harris recognizes that the P25 CAP Governing Board issued a
P25 CAP ISSI Compliance Assessment Bulletin (CAB) that specifies
approximately 30 conformance and 27 interoperability tests and that
this CAB is in effect.\5\
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\3\ Harris Comments on DHS OIC P25-
CAB-ISSI-REQ--December 2009, Ernest L.
Hofmeister, Harris Corporation, January 18, 2010.
\4\ Harris Comments to DHS P25 CAP Governing Board--March 31, 2010,
Ernest L. Hofmeister, Harris Corporation
\5\ P25 Compliance Assessment Bulletin, Baseline Inter-RF Sub-
System Interface Testing Requirements, P25-CAB-
ISSI-TEST-REQ, Office for Interoperability and
Compatibility, U.S. DHS, March 2010.
---------------------------------------------------------------------------
In terms of answering the question, Harris agrees with Mr. Orr's
statement that there is a provision in the P25 Compliance Assessment
Laboratory guidelines that would allow ``recognized'' conformance
testing during product development if done with the ``right'' equipment
and quality system in place. The Guide \6\ ``discusses an approach of
integrating recognized P25 CAP compliance test activities with the
Product Development organization design validation testing activities.
However, in order for this integrated approach to be successful, the
recognized P25 CAP laboratory and product development must ensure that
the provisions of NIST Handbook 153 \7\ are completely satisfied.''
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\6\ P25 CAP Laboratory Testing: Guide for Integration With Product
Development Organizations, issued by P25 CAP, June 26, 2009, file
Integration of P25 lab testing with product development r10.pdf.
\7\ NIST Handbook 153, 2009REV Edition, ``Laboratory Recognition
Process for Project 25 Compliance Assessment,'' Kurt B. Fischer and
Andrew Thiessen, Editors, Office of Law Enforcement Standards,
Electronics and Electrical Engineering Laboratory, National Institute
of Standards and Technology, U.S. Department of Commerce, June 2009.
---------------------------------------------------------------------------
While Harris continues to evaluate the integrated approach, Harris
is concerned about the operational practicality of integrating the
product development environment into the P25 Compliance Assessment Lab
environment in compliance with the Guide and NIST Handbook 153 and the
business investment impact to do so. The practicality and investment
challenges include establishing the ``right'' test equipment (including
software test tools) and the quality system per NIST Handbook 153.
a. ``Right'' Test Equipment
Regarding the ``right'' test equipment, for conformance testing for
interfaces like the Common Air Interface (CAI) where commercial off-
the-shelf test equipment like protocol analyzers and RF test equipment
exists that can be readily validated per NIST Handbook 153,
establishing the ``right'' test equipment is not a challenge. However,
for conformance testing for interfaces like the Intra-RF SubSystem
Interface (ISSI) where the ISSI product is primarily software and where
commercial off-the-shelf software test tools that can be readily
validated per NIST Handbook 153 do not exist, establishing the
``right'' test equipment is a significant challenge. Conformance
testing for software products like the ISSI by its nature is tedious
and labor intensive without some automated and validated test tool.
Harris is not aware of such a tool, but maintains a high interest level
in sources or information on such a tool. An R&D version of an
automated tool has been offered by NIST, but it has not been validated
to our knowledge and especially not per the NIST Handbook 153
requirements for software test tools. Similarly, an ISSI software test
tool offered a small company, Valid8, has been evaluated by Harris. Our
assessment is that while this tool is promising for the future, a
sizeable amount of continued development, maturation, and validation
would be required before it could be considered a ``right'' test tool.
Harris and industry experience with software and products from R&D labs
and small companies is that much effort is often required to finish the
development to a product and to validate and then to support.
Harris also notes that formal ISSI conformance testing will likely
not be a onetime event where tedious, labor intensive testing might be
more supportable. As with many complex P25 products, Harris expects
that ISSI product releases will occur over time with successive
releases supporting more and more of the ISSI features. ISSI
conformance testing would be required for each successive ISSI product
release.
Harris cannot afford to be both an LMR P25 equipment manufacturer
and a test equipment/tool manufacturer. The public safety LMR P25
industry is just not like the cellular industry where we understand
formal conformance tests are done. The much higher product mix and the
much, much smaller volumes means that Harris, and likely the industry,
must do things differently than the cellular industry. The orders of
magnitude difference in scale between the LMR P25 industry and the
cellular industry was identified and discussed during the hearing.
Thus, for ISSI conformance testing, the lack of a validated,
automated software test tool (``right'' equipment) represents a
significant practical technical and business investment challenge. This
challenge applies independent of whether the formal conformance testing
is integrated with product development or whether it is done separate
from product development after the product is complete in a recognized
P25 CAP lab. Development and validation of an automated ISSI
conformance test tool by the Public Safety Communications Research
(PSCR) \8\ program (or another NIST/OLES or NTIA/ITS) group or
validation of a 3rd party tool by PSCR for use by industry is an area
where the DHS (or PSCR, NIST/OLES, NTIA/ITS) could make a significant
contribution toward reducing the burden on the small P25 industry
consistent with their intent indicated in the statements of Mr. Orr
during the hearing.\9\ A rough order of magnitude (ROM) estimate for
Harris to develop and validate an automated ISSI test tool is $1.4 MUSD
with a recurring expense of about 10% to maintain the tool. This amount
represents a substantial portion of the R&D cost to develop the ISSI
product itself. In the resource constrained R&D environment,
development of an automated ISSI test tool by Harris would require
diverting critical software engineering resources from ISSI product
development to test tool development. The result would affect Harris'
ability to compete in the marketplace through reduced ISSI product
innovation and longer time to market for ISSI features in order to
implement formal ISSI conformance tests. Such an investment and
diversion of resources would not be justified or acceptable for normal
business considerations and practices and especially for the formal
testing that Harris believes provides little added value or compliance
assurance beyond that already provided by the normal in-formal
conformance testing as part of product development.
---------------------------------------------------------------------------
\8\ Per Mr. Orr's written testimony for this hearing, ``The PSCR
program serves as the technical lead for several Administration
initiatives focusing on public safety communications, most importantly
the Department of Homeland Security's (DHS) Office for Interoperability
and Compatibility (OIC) within the Science and Technology
Directorate.'' For more information on PSCR see the website: http://
vvww.pscr.gov.
\9\ Mr. Orr's statement starting at line 1201 of the 5.27 hearing
transcript: ``We realize that any additional testing that is placed on
industry is going to cost money and so we have done everything within
this program to ensure that we are minimizing the burden on industry,
minimizing the financial requirements that are needed to put the
program in place''. . . .
---------------------------------------------------------------------------
b. Operational Practicality and Quality System
Harris understands the need for the rigor and careful formal
control in the P25 CAP as defined in the Guide and NIST Handbook 153
for such testing to be recognized by DHS/NIST. While not impossible,
the rigor and careful formal control is more challenging to implement
for the case where the product development environment is integrated
with the separate P25 CAP lab environment than when the P25 CAP lab is
maintained as a separate and self-sustaining environment.
For Harris, the Product Development environment, while controlled,
is very dynamic, flexible, fast-paced, and less formal with hardware
and especially software changes rapidly implemented, tested, and
revised leading to a final hardware and software configuration. The
final hardware and software configuration is then released to the
System Verification & Test (SVT) environment within the Product
Integrity organization for more rigorous, controlled, and formal
product and system verification testing. There is interaction and
iteration between the SVT and product development groups for items
found in SVT testing that could be problems or unexplained behavior
leading to a final version of hardware and software that is releasable
for products and systems. The SVT testing often extends over a period
of months and usually includes Beta testing at one or more customer
installations. Harris has formal product releases indicated as PR-AB-C
and system releases indicated as SR-DE-F.
Establishing a Quality Management System for integrating elements
of the product development and SVT environments into the Harris P25 CAP
lab environment can be done with suitable effort, care, and due
diligence. The challenge Harris sees is the operational practicality of
the integrated environments. The concern is the coordination and
interruption of the flow and interaction of the normal activities in
the product development and SVT environments to accomplish the P25 CAP
conformance testing. Repeated interruptions for P25 CAP conformance
testing for the various near-final versions of software before final
release could have an undesired impact on the product and system
software release schedule. While still under evaluation, Harris, at
this point, would likely favor performing the P25 CAP conformance
testing after the product has been developed and ready for release in
the separate P25 CAP lab environment. An earlier concern about CAP
testing of the final product because some P25 CAP conformance tests are
invasive and require special software test code that would undesirably
reside in the final product has been alleviated. The recent practice in
the TIA-P25 and NIST/OLES groups has been to not include any invasive
tests in the P25 CAP.
c. Harris Summary and Business Perspective for P25 CAP ISSI Conformance
Testing
Harris supports a solid, practical DHS P25 Compliance Assessment
Program (P25 CAP) and associated testing for the benefit of our
customers, other public safety agencies/users, and manufacturers.
Harris agrees with Mr. Orr's statement that there is a provision in the
P25 Compliance Assessment Laboratory guidelines that would allow
``recognized'' conformance testing during product development if done
with the ``right'' equipment and quality system in place. The Guide
\10\ ``discusses an approach of integrating recognized P25 CAP
compliance test activities with the Product Development organization
design validation testing activities.'' While Harris continues to
evaluate the integrated approach, Harris is concerned about the
operational practicality of integrating the product development
environment into the P25 Compliance Assessment Lab environment in
compliance with the Guide and NIST Handbook 153 and the business
investment impact to do so. The practicality and investment challenges
include establishing the ``right'' test equipment (including software
test tools) and the quality system per NIST Handbook 153. Regarding the
``right'' test equipment, for conformance testing for interfaces like
the Common Air Interface (CAI) where commercial off-the-shelf test
equipment like protocol analyzers and RF test equipment exists that can
be readily validated per NIST Handbook 153, establishing the ``right''
test equipment is not a challenge. However, for conformance testing for
interfaces like the Intra-RF SubSystem Interface (ISSI) where the ISSI
product is primarily software and where commercial off-the-shelf
software test tools that can be readily validated per NIST Handbook 153
do not exist, establishing the ``right'' test equipment is a
significant challenge. Establishing a Quality Management System for
integrating elements of the product development and SVT environments
into the Harris P25 CAP lab environment can be done with suitable
effort, care, and due diligence. The challenge Harris sees is the
operational practicality of the integrated environments. The concern is
the coordination and interruption of the flow and interaction of the
normal activities in the product development and SVT environments to
accomplish the P25 CAP conformance testing. Harris, at this point,
would likely favor performing the P25 CAP conformance testing after the
product has been developed and ready for release in the separate P25
CAP lab environment.
---------------------------------------------------------------------------
\10\ P25 CAP Laboratory Testing: Guide for Integration With Product
Development Organizations, issued by P25 CAP, June 26, 2009, file
Integration of P25 lab testing with product development r10.pdf.
---------------------------------------------------------------------------
In terms of a Business perspective to establish and maintain a
recognized P25 CAP ISSI conformance testing laboratory, Harris has
conducted a ROM scoping analysis of the total ISSI market and the
investment to establish and maintain a recognized P25 CAP ISSI
conformance testing laboratory. The ROM scope investment to establish
and maintain a recognized P25 CAP ISSI conformance testing laboratory
ranges from a substantial portion of the total estimated annual ISSI
market to several times the total estimated annual ISSI market. The
range corresponds to the situations of establishing and maintaining a
recognized laboratory integrated with the product development
environment and establishing and maintaining a recognized laboratory
separate from the product development environment. Such an investment
for either situation would not be justified or acceptable for normal
business considerations and practices and especially for testing that
Harris believes provides little added value or assurance beyond that
already provided by the normal conformance testing as part of product
development. Harris believes that a validated 3rd party automated ISSI
conformance software test tool as a minimum and likely a 3rd party
recognized P25 CAP lab for ISSI conformance testing are critical for
the practical implementation of formal ISSI conformance testing per the
P25 ISSI CAB in effect and cited earlier. Development and validation of
an automated ISSI conformance test tool by the Public Safety
Communications Research (PSCR) \11\ program (or another NIST/OLES or
NTIA/ITS) group or validation of a 3rd party tool by PSCR for use by
industry is an area where the DHS (or PSCR, NIST/OLES, NTIA/ITS) could
make a significant contribution toward reducing the burden on the small
P25 industry consistent with their intent indicated in the statements
of Mr. Orr during the hearing.\12\
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\11\ Per Mr. Orr's written testimony for this hearing, ``The PSCR
program serves as the technical lead for several Administration
initiatives focusing on public safety communications, most importantly
the Department of Homeland Security's (DHS) Office for Interoperability
and Compatibility (OIC) within the Science and Technology
Directorate.'' For more information on PSCR see the website: http://
vvww.pscr.gov.
\12\ Mr. Orr's statement starting at line 1201 of the 5.27 hearing
transcript: ``We realize that any additional testing that is placed on
industry is going to cost money and so we have done everything within
this program to ensure that we are minimizing the burden on industry,
minimizing the financial requirements that are needed to put the
program in place''. . . .
Additional Comments
Harris offers the following additional comments to clarify certain
areas brought out during the course of the hearing:
P25 Equipment Interoperability:
It was implied that not all P25 certified (vendor self-
certification) equipment can interoperate. An example was given where
you have three P25 radios from different systems and only two could
talk to each other. Harris believes that this is not the norm and that
the status of interoperability among P25 equipment from various vendors
is very good and we testified to that fact. Land Mobile Radio systems
are complex and one could say that each system deployed is custom to
that user. This presents challenges in how a particular system is
configured. We have testified that many times inconsistencies are a
result of how a radio system is configured versus whether or not the
equipment meets the standard. We should also point out that currently
P25 systems of one frequency can not interoperate with P25 systems of a
different frequency regardless of whether they pass testing. This is
being addressed by the in-place ISSI standard.
Completion Status of P25 Standards:
In the context of the hearing subject, ``Interoperability in Public
Safety Communications Equipment,'' Harris believes it is important to
state the completion status in terms of the interfaces that are
critical and fundamental to system and equipment interoperability.
Harris agrees with Dr. Boyd's DHS S&T testimony that the CAI
(conventional and trunked) and the ISSI are the interfaces critical and
fundamental to system and equipment interoperability. Per Mr. Orr's
PSCS testimony, ``To date, only the conventional portion of the CAI and
the Inter-RF-Subsystem Interface have a completed suite of documents as
defined above. The more complex trunked CAI continues to lack
conformance test documents (crucial for uniform implementation)
although trunked CAI products have been sold for almost a decade.''
From this view and using the five standards documents per interface for
completion per the Mr. Orr written testimony, the P25 standards
completion status for the interfaces critical and fundamental to system
and equipment interoperability is pretty solid:
Conventional CAI--5 of 5 documents complete--100%
Complete
Trunked CAI--4 of 5 documents complete with
conformance to be completed--80 % Complete
ISSI--5 of 5 documents complete--100% Complete.
For this analysis, 14 of 15 standards documents are complete; i.e.,
93 % Complete.
In addition, for the trunked CAI interoperability as reported in
the Harris written testimony, multiple radio products and
infrastructure radio products have demonstrated a high functional level
of interoperability through the formal CAI interoperability testing as
part of the P25 Compliance Assessment Program (CAP) over the last year.
As of May 2010, twenty vendor radio products (or radio model classes)
from four vendors (EF Johnson, Harris, Motorola, and Tait) have
approved Suppliers Declaration of Compliance (SDoCs) and Summary Test
Reports (STRs) posted to the official RKB website for information and
review by public safety agencies and practitioners. To have passed the
trunked voice interoperability standard for these tests, each P25 radio
needed to pass 20 tests in the standard on at least three different
manufacturer's system infrastructure. It is for these reasons of
standards completion status above and the cited trunked
interoperability testing results that Harris stated in its testimony
that the P25 product standards, the testing standards, and the product
features are in place or soon will be in place to enable a solid level
of P25 trunked and conventional systems interoperability.
Standards pace is at full industry support capacity:
While some not involved in the standards development process might
comment that standards development takes a long time, the TIA process,
like other Standards Development Organizations, is a consensus-based
process by design. The standards are developed by top engineers from
industry who have the knowledge and perspective to assure successful
product implementation to the standard. Getting to consensus and
developing the requisite detail of the standard takes time, but the
resultant standard product is technically solid and long lasting.
Harris believes that since 2005, the standards pace is at full
industry/user support capacity. As a rough estimate, there are less
than 25 top engineers in this industry with the knowledge, perspective,
and capability to develop credible Project 25 standards. Since 2005,
there have been approximately 23 week-long, face-to-face TIA & P25
meetings with over 40 working attendees per meeting amounting to
37,000 person hours or over 23 person years. In addition, there have
been over 10 hours of subcommittee or task group conference calls per
week over this period with over 10 people participating amounting to
28000 person hours or over 17 person years. In addition, the
preparation time of technical document contributions is done outside of
the conference call and meeting time. Since 2005 over 13,000
contributions toward the TIA-P25 suite of standards have been submitted
for review, critique, and edit. Without researching the TIA records for
years 2005-2007, over 75 documents have been formally balloted as a
standards documents and over 60 documents have been published as TIA-
P25 standards in the 2 1/2 years since 2008 through the present time in
2010. Hence, the Harris view that the standards pace is at full
industry/user support capacity.
On-site Compliance Assessment Labs:
There was testimony about voluntary testing programs for P25
systems. Both Harris and Motorola testified to the fact that they both
have established Compliance Assessment Laboratories and have hosted
multiple vendors. Harris testified that it has invested significant
resources in support of the P25 standards process. We should highlight
that in addition to time, personnel and the costs associated with these
standards activities, Harris spent close to $2M to establish an in-
house test capability including capital and operating/development
costs. It is in the vendor's best interest to deploy compliant
equipment. As Chief Johnson testified, most systems are procured
through a process that ensures that all equipment is operational before
the system is approved for first responder use.
Established testing paired with the strict requirements of the
procurement process ensures positive results.
As noted during Harris' oral testimony, the P25 industry is small
by comparison to the commercial industries of cellular, WiFi, and
Bluetooth mentioned by Mr. Orr in his written and oral testimony. To
illustrate the total 2009 North American Land Mobile Radio market is
estimated to support 12 million users of which 4 million represent
public safety users. The P25 industry is estimated to be about half of
the total with about 1.5 million users. In contrast, the total 2009
U.S. cellular market is estimated to support about 270 million users/
subscribers. The P25 market is about 0.5% of the commercial users/
subscribers. Given the scale difference of the P25 industry with a
commercial industry like cellular, Harris believes that comparisons and
expectations for the P25 industry in terms of the rate of standards
development and industry-led compliance assessment are not relevant.
Beyond P25:
Complete ubiquitous interoperability among existing narrowband LMR
systems will not be achieved through deployment of P25 equipment alone.
As Dr. Boyd testified, public safety has an installed base of radio
systems equal to approximately $100 Billion. These systems are of
varying ages, operating frequencies, mode, etc. . . . Other than cost,
there are many considerations when procuring a radio system; some of
which are size, use, geography, spectrum availability, future proof,
etc. . . . There are smaller, rural entities today that do not have the
funds to upgrade to an expensive digital system yet may be the central
site of a manmade or natural disaster and will need to interoperate
with other first and second responders during an incident. To address
the unique needs of public safety entities and to achieve varying
levels of interoperability, vendors provide a wide array of products
from P25 radios and infrastructure to Internet Protocol (IP) networks
that connect disparate systems through standardized network
architecture.
Answers to Post-Hearing Questions
Responses by Mr. John Muench, Director of Business Development,
Motorola Inc.
Questions submitted by Chairman David Wu
Q1. One issue raised at the hearing was the difference between
performing conformance testing while the product is in development and
doing so after the product has been developed. Can you please comment
on Mr. Orr's statement that testing during development meets
conformance testing requires if done with the ``right'' equipment and
with a quality system in place? What is involved in developing the
testing equipment and quality system?
Q1a. Can you please comment on Mr. Orr's statement that testing during
development meets conformance testing requirements if done with the
``right'' equipment and with a quality system in place?
A1a. Any testing within the Department of Homeland Security (DHS)
Compliance Assessment Program (CAP), be it Performance, Conformance or
Interoperability testing, is required to be done in a lab that has been
formally assessed by National Institute of Standards and Technology
(NIST) and as a result, is formally recognized by the DHS CAP for
specific types of testing, such as Conformance testing. The formal
assessment of the lab includes providing the assessment team with Lab
Management and Lab Quality manuals. These describe the management and
quality practices of the lab. According to the NIST Handbook on CAP Lab
Assessment, the assessment does not concern itself with the maturity of
or adequacy of these practices. Instead, the assessment only ensures
that evidence exists that these practices are documented by the lab and
followed by the lab.
Mr. Orr's statement is based on an observation that conformance
testing may occur in a recognized lab that is dedicated to DHS CAP
testing or that conformance testing may occur in a manufacturer's
``development'' lab that is not dedicated to DHS CAP testing. Note that
some types of conformance tests are intrusive to the physical product
and so, it may be more practical to execute such tests in a product
development lab that essentially ``opens up'' the equipment under test.
Mr. Orr's statement about ``a quality system in place'' means that
if conformance testing is to be done in a development lab that is not
dedicated to DHS CAP testing, the management and quality practices of
that lab must meet the expectations of the NIST Handbook on CAP Lab
Assessment in order for the development lab's test results to be
accepted by the DHS CAP.
The nature of conformance testing is validation that the
standardized messages are sent under specified conditions and that when
standardized messages are received, the resulting reaction to the
standard message content is as specified. Conformance tests require
validation of specified stimulus conditions, specified message content
and specified reaction to the message content. This requires test
equipment that can capture messages exchanged, and display the message
sequence and content.
The NIST Handbook for Lab Assessment identifies four categories of
test equipment that may be used by a recognized lab for DHS CAP
testing. For each category, the Handbook also identifies certain
requirements for each category of equipment. During assessment, the lab
is required to provide evidence supporting the categorization of the
equipment to be used and to provide evidence that the equipment is
meeting the requirements specific to that categorization.
Mr. Orr's statement about ``done with the ``right'' equipment''
means that the equipment used to produce the test results has been
assessed and approved during lab assessment.
Q1b. What is involved in developing the testing equipment and quality
system?
A1b. The quality system is a document describing the policies and
practices of the lab intended to produce quality results. This
documentation also typically describes how these policies and practices
will be monitored and enforced. This documentation is created and
maintained by the management of the lab and provided to the assessors
during NIST lab assessment.
As previously noted, the NIST Handbook on Lab Assessment identifies
4 categories of test equipment:
Commercial Off the Shelf (COTS) test tools--Test
equipment is not modified in any way after purchase and prior
to use.
Modified Off the Shelf (MOTS) test tools--Test
equipment is modified to some extend after purchase and prior
to use.
Custom test tools--Test equipment is not commercially
available and is custom made for specific use.
Open Source/Freeware test tools--Test equipment is
available to the general public under an open source license
agreement and is not modified prior to use.
Only test equipment falling into the ``MOTS'' or ``Custom''
categories requires any sort of development. In these cases, the
developer determines the requirements for the test equipment imposed by
the test methodology and using a documented design and development
process, builds or modifies the equipment capabilities to meet the
requirements of the test methodology. Once the custom or modified
capabilities have been implemented, per the documented design and
development processes, these capabilities are validated the against the
design requirements prior to actual use.
Q2. Acknowledging that P25 is a work in progress, at the end of his
testimony, Dr. Hofmeister suggested that defining the standard
functions included with a ``package'' may offer public safety a clearer
picture of the functionality of the system they are buying. What are
your thoughts on this recommendation, or other ways of better
communicating the status of P25 to purchasers?
A2. The reality of the P25 market is for P25 compliant products to be
designed and manufactured for flexibility in order to meet the diverse
mission needs of the users. Standardized packaging of P25 features is
something that can be done, but in my opinion will not ultimately
satisfy the end user requirement for better information on the status
of P25.
Public Safety Practioners commonly ask for Project 25 status and
feature information as outlined by these four questions:
1. What features are in P25?
2. Where can a definition for these features be found?
3. What features have been implemented by a manufacturer?
4. What features have been tested for multi-manufacturer
interoperability?
The answers to four questions help them determine, what set of P25
features meet their specific communications needs, which manufacturers
provide the desired set of P25 features that meet their specific needs
and whether the desired P25 feature set has been successfully tested
for interoperability with the desired manufacturers.
The answers to the first two questions can be found in the P25
Statement of Requirements document published by the P25 User Needs
Subcommittee and in TIA-102 Standard documents. The Public Safety
Practioners develop and publish the ``P25 Statement of Requirements''
themselves. Public Safety Practioners receive free access to the
published TIA-102 Standard documents through a special TIA web access.
Normally, the TIA Standard documents have to be purchased.
Each manufacturer markets the information as to what features and
functions their company has implemented in their product lines. Among
the supported features and functions are those claimed to be compliant
to the Project 25 standard. If this information is not readily
available, purchasers can get insight as to which P25 features have
been implemented by a manufacturer by issuing either a Request for
Information or a Request For Proposal.
Information on which features and functionality have been tested
for interoperability and between which manufacturers, has not been
publicly available in the past. The driving force for formal
interoperability testing is the DHS grant monies. The grant guidance
outlines a requirement for manufacturers to produce a P25 Suppliers
Declaration of Compliance (SDoC) and Summary Test Report (STR). These
documents include the results of formal interoperability testing.
Purchasers can obtain information describing what P25 functionality has
been tested by which manufacturers by requesting SDoC/STRs from the
manufacturers or obtaining them from the Responder Knowledge Base (RKB)
website.
The P25 Standard will never be comparable to the 3G/4G or WIMAX
standards when it comes to public recognition or when a user is looking
for information. The P25 manufacturers are not selling equipment to
multiple global cellular service companies-each with massive marketing
departments, operating worldwide cellular networks. P25 manufacturers
are not shipping hundreds of millions of hand held radios every year.
The P25 manufacturers sell products to a unique marketplace that
values products based on the Project 25 standard and implemented to
provide guaranteed performance, long-term durability, security and
features necessary for mission critical communications. Project 25
actively involves and uses the input of Public Safety Practioners
(Police, Fire, EMS personnel, as well as State, Local and Federal
agencies) when determining the needs and the scope of the P25 standard.
Public Safety Practioners are members of P25 committees, they can
submit comments on draft P25 standard documents and they can attend
meetings in person and on conference calls. They are free to comment on
the priorities of the P25 standard. Public Safety Practioners have
always been involved with the development of the P25 Standard. Although
the P25 market is smaller, the involvement of the user community in the
standard development enables an informed user community without the
massive marketing departments like the cellular marketplace.
There have been discussions within P25 about structuring specific
features into packages to make ordering easier with the assumption that
this would make it easier for the purchaser to understand what he is
purchasing. One of the challenges of offering prepackaged P25 features
for `mission critical' communications equipment and systems is that the
size, mission and communication needs of public safety agencies vary
dramatically. It is this variation that limits the value and utility of
standardized feature packages.
The size of a public safety agency can vary from 6 officers to over
35,000 officers; who serve populations from a few thousand to a few
million. This size variation impacts the features needed and how the
system operates. The different communication needs of the fire fighter
all geared-up with breathing masks at the fireground, the metropolitan
patrol police officer walking a beat, the state trooper patrolling the
highways at high and slow speeds, Federal law enforcement patrolling
remote borders and the military communicating at forts and bases
require different communication features and operations. The frequency
bands in which these agencies operate are different, with different FCC
and NTIA licensing requirements that directly impact the design and
operation of the equipment and system. These public safety practioners
use some of the same P25 services and features but may also require
services and features with special behaviors, or various combinations
of features, services and accessories that make their operations
unique. For example, Federal law enforcement using P25 equipment have
wireless security requirements that are not imposed on state and local
users.
Motorola does not envision a future where there is just one model
of a P25 radio, nor should there be a P25 radio limited to only the P25
features fully-defined by published P25 standards. Today, there are
many radio models and configurations that are P25-complaint and also
support other standards or proprietary operations. Manufacturers offer
product tiers at different price points and are free to configure
feature sets to meet particular marketplaces. A manufacturer offers
feature variations that are marketed to meet the individual business
opportunities for that manufacturer. Customers continue to request
features for their equipment that are not part of P25.
It has been Motorola's experience that purchasers of P25 equipment
are most concerned with the status of multi-manufacturer
interoperability. Aside from having a defined TIA Standard, P25
purchasers want to know what features, with what P25 portable and
mobile radios, are interchangeable with what P25 fixed radio systems.
The only action that resolves this concern is documented
interoperability testing. The faster more features are added to the P25
CAP interoperability test suites, the faster users will know the
interoperability status of products that can meet their feature needs.
The P25 CAP could be expanded to cover more features faster, if the
expansion first focused on interoperability testing of functionally-
defined features with follow-on testing expansion to include
conformance testing of these same features. The current P25 CAP testing
approach is more vertical in nature. The current approach defines
conformance and interoperability testing feature by feature. This
provides a complete testing profile by feature but slows the initial
interoperability testing for all features. Conformance testing is part
of P25, but it is not a substitute for interoperability testing.
Also, the current `rule of 3' for posting interoperability testing
maybe keeping some vendors from posting interoperability performance
status on the RKB. The 'rule of three' requires that the P25 equipment
from one vendor be interoperability tested with three P25 equipment
vendors. It is difficult, and can take many calendar months, for
multiple manufacturers to schedule interoperability testing considering
the multiple product development schedules of P25 manufacturers.
Motorola would suggest that the `rule of 3' for posting
interoperability testing results be relaxed, allowing posting results
with just one other manufacturer, but maintaining the `rule of 3' for
equipment to be eligible for DHS grant monies.
Appendix 2:
----------
Additional Material for the Record
Statement for the Record from Skyterra Communications
PROGRESS ON P25: FURTHERING INTEROPERABILITY AND COMPETITION FOR PUBLIC
SAFETY RADIO EQUIPMENT
----------
THURSDAY, SEPTEMBER 23, 2010
House of Representatives,
Subcommittee on Technology and Innovation,
Committee on Science and Technology,
Washington, DC.
The Subcommittee met, pursuant to call, at 2:00 p.m., in
Room 2318 of the Rayburn House Office Building, Hon. David Wu
[Chairman of the Subcommittee] presiding.
hearing charter
COMMITTEE ON SCIENCE AND TECHNOLOGY
SUBCOMMITTEE ON TECHNOLOGY AND INNOVATION
U.S. HOUSE OF REPRESENTATIVES
Progress on P25: Furthering
Interoperability and Competition
for Public Safety Radio Equipment
thursday, september 23, 2010
2:00 p.m.-4:00 p.m.
2318 rayburn house office building
I. Purpose
The Project 25 standard for digital land mobile radios is intended
to further seamless communications interoperability among America's
first responders, enable competition among radio equipment
manufacturers, and provide for the efficient use of limited spectrum
resources. In May of 2010, the Science and Technology Committee's
Subcommittee on Technology and Innovation held a hearing to discuss the
status of the Project 25 standard and the remaining challenges. This
hearing will discuss these challenges further and explore how the
status of Project 25 affects an array of stakeholders.
II. Witnesses
Mr. Tom Sorley, Deputy Director Radio Communication
Services, City of Houston Information Technology Department
Ms. Ellen O'Hara, President, Zetron
Mr. Marvin Ingram, Senior Director, ARINC, Public
Safety Communications
Mr. Russ Sveda, Manager of the Radio Technical
Service Center, Department of the Interior
III. Brief Overview
In 1989, the public safety community joined together to address the
lack of interoperability between digital radios supplied by different
vendors through the development of the Project 25--or P25--technical
standard for digital land mobile radios (LMRs). For over a decade, the
P25 process made minimal progress in completing the standards. However,
major disaster events (including the September 11th attacks and
Hurricane Katrina) renewed motivation to drive the process forward and
eliminate the technical barriers that prevent public safety officials
from different agencies and jurisdictions from communicating during an
emergency response.
In a May 2010 hearing, the Subcommittee heard testimony on this
progress, as well as on what some viewed as remaining challenges. For
example, witnesses disagreed on the status of the P25 standards.
Whereas witnesses representing two federal agencies claimed that many
of the technical documents within the suite of P25 standards were not
yet completed, those representing equipment manufacturers argued the
standards were ``functionally complete,'' enabling engineers to build
interoperable equipment. Witnesses also debated the degree and rigor of
testing that should be required to verify manufacturers' claims that
radio systems are P25-complaint.
This hearing will continue the Technology and Innovation
Subcommittee's examination of the P25 standard, and explore how the
status of the standards documents and the testing requirements impact
P25 stakeholders. This hearing will also review the role of the P25
standard in ensuring radio systems are interoperable and that there is
competition among vendors.
IV. Background
Project 25
The lack of interoperability--often defined as the ability of
emergency responders to communicate with whom they need to, when they
need to, and as authorized--has long challenged America's public safety
community. Interoperability problems between responding agencies were
documented in the response efforts to the 1995 Oklahoma City bombing,
the September 11th attacks, and Hurricane Katrina, making response
efforts more chaotic, less efficient, and even more dangerous. In the
World Trade Center attacks, firefighters did not receive the New York
Police Department message to evacuate the building immediately,
contributing to the deaths of those firefighters. In the response to
Hurricane Katrina, officials in helicopters could not communicate with
responders in boats, slowing rescue efforts. First responders in these
cases, and other large-scale events, ended up employing message
runners, which limited the flow of information to incident
commanders.\1\
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\1\ Tristan Weir, Federal Policy Toward Emergency Responder
Interoperability: A Path Forward. Thesis submitted for a Masters of
Science in Technology Policy from the Massachusetts Institute of
Technology, 2006.
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While planning, governance, and training are essential components
of interoperability, standards-based technology is generally accepted
as critical to achieving seamless interoperability either in an
emergency or during day-to-day operation.\2\ The emergence of digital
technology in the late 1980s highlighted the importance of standards in
ensuring interoperability. These digital radio systems used proprietary
protocols and technology which, unlike their analog forbearers, were
incompatible with the proprietary technologies of other vendors, even
when those radios were deployed within the same spectrum band.\3\
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\2\ Department of Homeland Security, SAFECOM Program's
Interoperability Continuum tool, available at: http://
www.safecomprogram.gov/NR/rdonlyres/54F0C2DE-FA70-48DD-A56E-
3A72A8F35066/0/
Interoperability-Continuum-Brochure-2.p
df.
\3\ COPS Interoperable Communications Technology Program, May 2007
Issue Brief, Project 25: The Quest for Interoperable Radios, by Dan
Hawkins, available at: http://www.dps.mo.gov/homelandsecurity/
documents/SEARCHP25Primer.pdf.
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In 1989, to escape proprietary systems and promote
interoperability, the Association of Public-Safety Communications
Officials (APCO) and the National Association of State
Telecommunications Directors (NASTD), along with several federal
agencies, began work on the P25 suite of standards for digital LMR
systems. The originators of P25 sought to develop a user-defined and
user-driven standard that would allow for interoperability, multi-
vendor procurement, and the transition from legacy analog equipment to
digital equipment, as well as promote greater spectrum-use
efficiency.\4\
---------------------------------------------------------------------------
\4\ Id.
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The APCO process eventually led to a partnership between the public
safety community and the Telecommunications Industry Association (TIA)
\5\ to collaborate on standards. Through a process agreed to by TIA and
the participating representatives from the public safety community,
public safety users define the requirements for the standard and the
standards documents are then produced by engineers from TIA and digital
radio manufacturers who volunteer their expertise.
---------------------------------------------------------------------------
\5\ The Telecommunications Industry Association is an ANSI-
accredited standards development organization.
---------------------------------------------------------------------------
Representatives from several federal agencies were among the
original participants in P25. However, the slow rate of progress toward
greater interoperability spurred Congress to direct the Department of
Homeland Security to take a more active role in promoting
interoperability and hastening the development of the P25 standards.
The 2004 Intelligence Reform and Terrorism Prevention Act (P.L. 108-
458) directed the Secretary of Homeland Security to establish a program
to improve the state of interoperable communications capabilities for
first responders. Among other requirements and activities, the
legislation directed the Department of Homeland Security to work--in
consultation with NIST, the private sector, and others--to ``accelerate
the development of national voluntary consensus standards for public
safety interoperable communications.'' Since the passage of the Act,
NIST, through the Public Safety Communication Research Program (a joint
program between NIST and the National Telecommunications and
Information Association), has taken leadership roles in the P25
standards development process, particularly in areas of testing and
certification.
A 2007 Government Accountability Report (GAO) report \6\ noted
that, despite over $2 billion of federal spending to advance
interoperability, communities across the country were still far from
achieving that goal. GAO identified a number of barriers to
interoperability, but also cited the slow rate of P25 standards
development as among the factors hindering faster adoption of
interoperable public safety communications systems.
---------------------------------------------------------------------------
\6\ GAO Report 07-301, April 2007. First Responders--Much Work
Remains to Improve Communications Interoperability.
---------------------------------------------------------------------------
GAO noted that while the P25 standards developers took four years
(from 1989 to 1993) to develop the Common Air Interface (defined
below), they did not complete any additional standards between 1993 and
2005. GAO found that P25 participants had made ``significant progress''
on the standards for interoperability after 2005, but that many
standards were still incomplete. Further, GAO reported that tests
conducted between 2003 and 2006 showed that inconsistent
interpretations of the standards caused P25 radios to fail aspects of
interoperability tests.
P25 encompasses a suite of standards, each of which defines the
technical requirements necessary for components of the radio system
infrastructure to interface--or interoperate--with one another. Public
safety land mobile radio (LMR) systems include the portable handheld
and car-mounted radios used by emergency responders, as well as fixed
infrastructure such as towers, base stations, and console. Those P25
standards identified as most critical to interoperability are listed
below: \7\
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\7\ COPS Interoperable Communications Technology Program, May 2007
Issue Brief, Project 25: The Quest for Interoperable Radios, by Dan
Hawkins, available at: http://www.dps.mo.gov/homelandsecurity/
documents/SEARCHP25Primer.pdf.
The Common-Air Interface (CAI), which defines the
communication protocols between radio transmitters and
receivers. This standard is intended to ensure that a portable
radio from one manufacturer can communicate with a portable
---------------------------------------------------------------------------
radio from a different manufacturer.
The Console Subsystem Interface (CSI), which defines
how radio frequency components of the system and console (such
as the equipment used by dispatchers) connect with one another.
The Fixed Station Interface (FSI), which defines how
components of the radio system that are fixed in place (such as
base stations) connect with other components of the system.
The Inter-RF subsystem Interface (ISSI), which
defines the connection between different radio system networks.
Compliance Assessment Program (CAP)
Standards are technical documents, but engineers may vary in their
interpretation of the protocols included in the documents. Ultimately,
this variability in interpretation can impact the functionality of
equipment. For this reason, in the case of many telecommunications
standards--such as Wi-Fi or BlueTooth, the relevant industry
stakeholders develop testing and certification processes to ensure
products meet the specifications of the standards and that the standard
is being interpreted consistently among vendors.
For many years, P25 lacked a formal testing process to validate
that manufacturers had correctly and uniformly implemented the
standards in their equipment and were not misappropriating the P25
label. In 2005, in response to reports of failed interoperability tests
of P25-labeled equipment (between different manufacturers, and even
between different models from the same manufacturer), Congress directed
the Department of Homeland Security (DHS), working with the Department
of Justice (DOJ) and the National Institute of Standards and Technology
(NIST), to develop a P25 Compliance Assessment Program (CAP).\8\ The
DHS CAP certifies laboratories and specifies which tests must be
conducted to show compliance with the standard. The DHS CAP is a
voluntary program, but any P25 digital radio systems purchased with DHS
grants must meet the requirements of the program.
---------------------------------------------------------------------------
\8\ Directed in the FY2006 Department of Homeland Security
Appropriations Act (H. Rept. 109-241)
---------------------------------------------------------------------------
The P25 CAP sought to specify testing requirements for performance,
interoperability, and conformance.\9\ Conformity assessment tests
whether manufacturers have correctly and consistently interpreted and
implemented the standard. It is generally more rigorous than
interoperability and performance testing and it is arguably the best
mechanism for ensuring that all standardized functions will
interoperate across all manufacturers. Conformance testing is also
considered particularly important in ensuring backwards compatibility
of new technology, which must connect and interoperate with legacy
systems, some as many as 20 years old or older.
---------------------------------------------------------------------------
\9\ Charter for the P25 Compliance Assessment Program, April 2008,
available at: http://www.safecomprogram.gov/NR/rdonlyres/D295A545-44A4-
4226-AAF7-56A33684908E/0/
Project25ComplianceAssessmentProgramCharter.pdf
May 2010 Hearing
On May 27, 2010, the Subcommittee on Technology and Innovation of
the House Committee on Science and Technology held a hearing on the
status of interoperability for public safety communications equipment.
The Subcommittee heard testimony from the public safety community,
federal agencies, and major manufacturers of radio equipment.\10\ The
hearing addressed the status of the P25 standards and the degree of
testing needed to ensure that P25 products conform to the applicable
standards.
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\10\ Witnesses at May 27th Hearing: Dr. David Boyd, Director of the
Command, Control, and Interoperability Division of the DHS Science and
Technology Directorate; Mr. Dereck Orr, Program Manager for public
Safety Communication Systems, at NIST; Dr. Ernest Hofmeister, Senior
Scientist at the Harris Corporation; Mr. John Muench, Director of
Business Development for Motorola, Inc.; and Chief Jeffery Johnson,
President of the International Association of Fire Chiefs, and Chief of
Tualitin Valley Fire and Rescue, Aloha, Oregon.
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The witnesses made different arguments on the scope of P25 and the
impact the status of the process had on digital radio equipment being
fielded today. Witnesses from DHS and NIST identified eight interfaces
(i.e., standards) encompassed by P25, and according to NIST's
testimony, only one and a half of the eight interfaces were complete.
The witness testified that:
To date, only the conventional portion of the CAI and the
Inter-RF-Subsystem Interface have a completed suite of
documents [\11\] . . . The more complex trunked [\12\] CAI
continues to lack conformance test documents . . . although
trunked CAI products have been sold for almost a decade. The
remainder of the six interfaces is in various stages of
document completion.
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\11\ From testimony provided by Dereck Orr: for P25, each complete
interface, or standard, includes five documents--a protocol document,
which provides the details to implement the particular interface, and
three test documents (tests for performance, interoperability, and
conformance), which allow manufacturers to ``comprehensively test their
implementations in a common way'' to limit variants in interpretation
of the protocol. All of these documents are developed via a consensus
process.
\12\ Trunked radios are considerably more complex than
conventional. In a trunked radio system, users are not assigned to
particularly frequencies, but instead have access to any frequency that
is open, and are connected automatically via the system. Not being
confined to assigned channels allows more efficient use of the
frequencies because more users can be on the system at any given time.
The witness further testified that because the P25 standards remain
incomplete, radio systems that are sold as P25 are in actuality only
partially standards-based.
LMR industry representatives did not dispute that P25 was
technically incomplete, but they stressed that the standards needed to
change as technology evolved and argued that the available standards
actually enable interoperability across vendors. Motorola, a major
manufacturer of LMR equipment, held that ``the technical specifications
for Project 25's Phase 1[\13\] systems are functionally complete.''
Accordingly, the industry representatives pointed out that the P25
standards documents completed to date enable two important functions:
(1) ensuring that a P25 portable radio can communicate directly with
any other P25 portable radio in the same spectrum band; and (2)
allowing a first responder, within the coverage area of a neighboring
network, to communicate with his/her home network (e.g., dispatchers)
through the neighboring network.
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\13\ As noted in the testimony provided by Motorola and Harris,
Phase 1 of Project 25 refers to enabling communication at bandwidth's
of 12.5 kHz to comply with FCC ``narrow-banding'' requirements. Phase 2
will further reduce the width of the communication channel to 6.25 kHz
in anticipation of future FCC mandates to use limited spectrum
resources more efficiently.
---------------------------------------------------------------------------
The manufacturer representatives also noted that P25 developers
have generated approximately 69 published standards, with an additional
13 in the ballot phase and 15 in the draft phase. Given that the
standards development process relies on the voluntary efforts of expert
engineers, and consensus amongst all of the stakeholders, Harris'
testified that ``the standards pace is at full industry and user
capacity.''
Witnesses at the hearing also disagreed about the degree of testing
that should be required to validate that products meet the standards.
NIST testified that the CAP attempted to create a rigorous and formal
testing program, while minimizing the burden the testing requirements
would impose on industry. NIST noted that not only does the CAP not
require third-party certification, CAP developers leverage the testing
standards developed and published by the P25 standards developers
themselves.
Federal Government witnesses also noted that, although the CAP as
originally planned was to include interoperability, performance, and
conformance testing for all completed interfaces, the first P25 CAP
requirements (which were issued in 2008) did not include conformance
testing. Those requirements covered only the CAI standard, which--at
the time--was incomplete and included no conformance testing documents.
NIST and DHS further testified that manufacturers strongly objected to
a proposal to include conformity testing for the ISSI standard, which
had a completed conformance testing document, in the CAP in 2009. The
agency witnesses voiced strong support for including conformance
testing, arguing it was the best tool to ensure interoperability and
backwards compatibility with legacy systems.
At the hearing, the manufacturer representatives noted that both of
their companies follow rigorous internal testing procedure, and had
worked extensively with other companies, and within the P25 process, to
resolve identified interoperability problems. Harris noted that past
interoperability problems reflected ambiguities within the P25
standards, which have subsequently been resolved, and should no longer
pose problems. Motorola contended that any interoperability problems
found today are likely a result of differences in equipment
configuration between radio systems.\14\
---------------------------------------------------------------------------
\14\ As noted by NIST in response to Questions for the Record
(located in the Appendix to this charter), methods for the
configuration, or programming, of radios vary across manufacturers.
Such programming is complex, and made more complex by the number of
features present in a particular radio. The lack of standardized
methods for programming can lead to interoperability, as well as
operability, problems, particularly in an emergency response setting,
where time is critical. However, NIST further noted that ``. . . in
discussions with public safety organizations responsible for the
provisioning of radios operating on a system, we have been informed
that many of the issues found in the radios also require software
upgrades to the radios themselves rather than a simple reconfiguration.
Thus we are confident that some issues found in the field are due to
problems beyond configuration and programming, and are instead due to
nonconformance to the standard or problems with the standard itself.''
---------------------------------------------------------------------------
While the manufacturers were supportive of the P25 CAP, they
questioned whether the benefit of more rigorous testing would outweigh
the cost. Both Harris and Motorola pointed to the costs of developing
the needed equipment to perform the tests. They also noted that while
conformance testing is routinely done in the telecom industry, the
public safety equipment industry and market is significantly smaller
and testing would therefore be more burdensome.
The charter, witness testimony, and webcast to the May hearing can
be found on the Science and Technology Committee's website (http://
science.house.gov/publications/
hearings-markups-details.aspx?NewsID=2866).
700 Mhz and Public Safety Broadband Networks
The P25 standards cover interoperability for voice communications
over digital LMR systems. With the availability of broadband, many
public safety agencies are seeking to integrate data functions into
their operations. Generally, public safety agencies that seek to
integrate these functions now must rely on commercial carriers to
provide broadband service. However, the National Broadband Plan
recommended the creation of a nationwide interoperable public safety
wireless broadband network, which would allow data and extra voice
capacity for public safety.
Many policy and technology issues may need to be resolved before
more widespread implementation of public safety broadband networks is
possible. In addition to questions about the fate of the ``D-Block''
(an additional 10 Mhz of the 700 band spectrum) and debate on how to
govern, finance, and build a network for public safety, significant
issues arguably remain with respect to standards and testing. NIST and
the National Telecommunications and Information Administration (NTIA)
have worked with the public safety community over the past three years
to define the technical requirements needed for a public safety
broadband network. Working with the broadband industry, NIST and NTIA
are also developing a test-bed to test broadband technology against
public safety needs. Testing will begin early next year. Public safety-
specific standards for broadband technology have not yet been addressed
in an organized fashion.
V. Issues and Concerns
Even in their current state, the P25 standards have improved
interoperability for public safety radios. LMR vendors have shown that
handheld and portable radios from different manufacturers can
communicate with one another. However, there are unanswered questions
on whether further progress is still needed to address two key goals of
the P25 process: (1) ensuring seamless and reliable interoperability,
and (2) fostering competition for public safety communications
equipment.
Although representatives from industry claim that the P25 standards
are ``functionally complete'', concerns persist that currently fielded
P25 systems are not completely standards-based. In addition, questions
remain on the extent to which testing should be required to validate
that products meet the standard.
Though there are clear disagreements over these technical matters,
it is less clear what the consequences of these disagreements are for
the interoperability of the equipment and for ensuring competition
among vendors in the P25 equipment market. Further discussion of the
practical impacts of these issues should help provide more insight into
whether, and to what extent, the P25 process is meeting its original
goals.
Chairman Wu. Good afternoon. This hearing will now come to
order. I would like to welcome everyone, and everyone who has
joined us this afternoon for our hearing.
This is the second hearing the Subcommittee has held on the
interoperability of public safety communications equipment, and
I am glad we have the opportunity to revisit this important
topic.
The ability of first responders to communicate with each
other during an emergency is absolutely vital. In many major
disasters, including 9/11, response efforts have been hindered
or imperiled because emergency officials responding from
surrounding jurisdictions could not use their equipment to
communicate with each other.
While many factors contribute to this lack of
interoperability, proprietary technology makes the situation
far worse. Without a common technical standard, there is no
assurance that equipment from one manufacturer will work with
equipment from another manufacturer. This means that first
responders may not be able to communicate with each other when
it matters most, and it means that public safety agencies may
be forced into buying components of their public safety
communications systems from a single manufacturer, limiting
competition and driving up prices.
In 1989, the public safety community and other stakeholders
set out to create a common technical standard for public safety
radios, known as P25. Although progress has been made over the
last 20 years, the P25 standard is not yet complete.
At our hearing in May, we learned about disagreements among
some of the players in the P25 standard-setting process over
the status of the standard and the degree and rigor of testing
that should be required. While these disagreements are on
highly technical and complicated issues, they have real-world
implications for our first responders and for those in harm's
way. Simply put, our local public safety officials need the
certainty that open standards provide. Right now that certainty
does not exist.
I am pleased that we have the opportunity today to hear
from people who build, test and operate P25 equipment. I hope
to learn from our panel about how technical disagreements over
document status and testing affect interoperability and
competition for public safety radio systems.
Local, state and federal public safety agencies spend
billions of dollars on communications equipment. The size of
this investment and the mission-critical nature of this
equipment make it imperative that P25 fulfill its goals.
I would now like to recognize Ms. Biggert for her opening
statement.
[The prepared statement of Chairman Wu follows:]
Prepared Statement of Chairman David Wu
Good afternoon. I would like to welcome our witnesses, and
everybody who has joined us, to today's hearing.
This is the second hearing the Subcommittee has held on the
interoperability of public safety communications equipment, and I am
glad we have the opportunity to revisit this important topic.
The ability of first responders to communicate with each other
during an emergency is vital. As reports have shown, in many major
disasters, including 9/11, response efforts have been hindered or
imperiled because emergency officials responding from surrounding
jurisdictions could not use their radios to communicate with each
other.
While many factors contribute to this lack of interoperability,
equipment based on proprietary technology makes the situation far
worse. Without a common technical standard, there is no assurance that
equipment from one manufacturer will work with equipment from another
manufacturer. This means that first responders may not be able to
communicate with each other when it matters most. And it means that
public safety agencies may be forced into buying the various components
of their public safety communications systems from a single
manufacturer, limiting competition and driving up prices.
In 1989, the public safety community and other stakeholders set out
to create a common technical standard for public safety radios, known
as the P25 standard. Although progress has been made over the last 20
years, the P25 standard is not yet complete.
At our hearing in May, we learned about disagreements among some of
the players in the P25 standard process over the status of the standard
and the degree and rigor of testing that should be required. While
these disagreements are on highly technical and complicated issues,
they have real-world implications for our first responders and those in
harm's way. Simply put, our local public safety officials need the
certainty that a standard provides and, right now, that certainty does
not exist.
I am pleased that we have the opportunity today to hear from people
who build, test, and operate P25 equipment. I hope to learn from our
panel about how technical disagreements over document status and
testing impact interoperability and competition for public safety radio
systems.
Local, state, and federal public safety agencies spend billions of
dollars on communications equipment. The size of this investment and
the mission-critical nature of this equipment make it imperative that
P25 fulfill its goals.
Ms. Biggert. Thank you, Chairman Wu, and thank for you
calling today's hearing on the interoperability of public
safety communications equipment, specifically Project 25, or
P25 standards.
A previous hearing on this topic in May highlighted the
fact that though the Project 25 process has been ongoing for
more than 20 years, progress on standards for communication
interoperability has been slow.
Today's hearing will focus on the process to ensure that
communications equipment not only incorporates the existing P25
standards but also performs at the level anticipated by the
National Institute of Standards and Technology (NIST) and the
other stakeholders developing the standards. I hope we will
also learn about P25 standards that have not been fully
completed and how we can encourage the advancement of that
process.
One of the challenges faced by improving public
communication interoperability is the inherent friction between
our free market system and the desire for multi-vendor
equipment to work seamlessly together. In the interest of
public safety, it is obvious that the first responders must
have functional, interoperable equipment. The public expects
that in times of emergency, whether it is fire, a crippling
winter snowstorm or a terrorist attack that public safety
communications will work across geography and jurisdictions
without a hitch. But when the public safety agencies and
vendors do not work closely together on standards confirmation,
the end result may be equipment that works perfectly in some
situations but fails miserably in others.
So I look forward to learning more about the standard-
setting process and how we can encourage innovation,
competition and truly interoperable products available to the
men and women working so hard to protect our safety.
So with that again, Chairman Wu, thank you, and I welcome
our witnesses and look forward to an informative hearing. I
yield back the balance of my time.
[The prepared statement of Ms. Biggert follows:]
Prepared Statement of Representative Judy Biggert
Thank you, Chairman Wu, for calling today's hearing on the
interoperability of public safety communications equipment--
specifically Project 25, or P25, standards.
A previous hearing on this topic in May highlighted the fact that
though the Project 25 (P25) process has been ongoing for more than 20
years, progress on standards for communications interoperability has
been slow. Today's hearing will focus on the process to ensure that
communications equipment not only incorporates the existing P25
standards, but also performs at the level anticipated by the National
Institute of Standards and Technology (NIST) and the other stakeholders
developing the standards. I hope we will also learn about the P25
standards that have not been fully completed and about how we can
encourage the advancement of that process.
One of the challenges faced by improving public communication
interoperability is the inherent friction between our free market
system and the desire for multi-vendor equipment to work seamlessly
together. In the interest of public safety it is obvious that first
responders must have functional, interoperable equipment. The public
expects that in times of emergency--whether it is fire, a crippling
winter snow storm, or a terrorist attack--that public safety
communications will work across geography and jurisdiction without a
hitch. But when public safety agencies and vendors do not work closely
together on standards conformance, the end result may be equipment that
works perfectly in some situations, but fails miserably in others.
I look forward to learning more about the standards-setting process
and how we can encourage innovation, competition, and truly
interoperable products available to the men and women working so hard
to protect our public safety.
With that, thank you again Chairman Wu, and welcome to our
witnesses. I look forward to a informative hearing and I yield back the
balance of my time.
Chairman Wu. Thank you very much, Ms. Biggert.
If there are other Members who wish to submit additional
opening statements, your statements will be added to the record
at this point.
[The prepared statement of Mr. Mitchell follows:]
Prepared Statement of Representative Harry E. Mitchell
Thank you, Mr. Chairman.
Communication among first responders is critical in an emergency
response situation. However, to communicate effectively and
efficiently, it is essential that first responders have compatible
technology that will allow them to communicate with their counterparts
from other agencies and jurisdictions.
Today we will continue to discuss the P25 standard, including how
the status of the standards documents and the testing requirements
impact P25 stakeholders. We will also examine the role of the P25
standard in ensuring radio systems are interoperable and that there is
competition among vendors.
I look forward to hearing more from our witnesses today on the
issue of public safety interoperability.
At this time, I yield back.
And now it is my pleasure to introduce our witnesses. Mr.
Tom Sorley is the Deputy Director of the Radio Communication
Services for the City of Houston Information Technology
Department. Ms. Ellen O'Hara is the President of Zetron. Mr.
Marvin Ingram is the Senior Director of ARINC, Public Safety
Communications. And our final witness is Mr. Russ Sveda, who is
the Manager of the Radio Technical Service Center of the
Department of Interior.
You will each have five minutes for your spoken testimony.
Your written testimony will be included in the record for the
hearing in its entirety, and when all of you complete your
testimony, we will begin with questions. Each Member will have
five minutes to question the panel. Mr. Sorley, please proceed.
STATEMENT OF TOM SORLEY, DEPUTY DIRECTOR, RADIO COMMUNICATION
SERVICES, CITY OF HOUSTON INFORMATION TECHNOLOGY DEPARTMENT
Mr. Sorley. Hello. My name is Tom Sorley. I am the Deputy
Director of Radio Communications for the City of Houston. I
also serve as the Chair of the Technology Committee for the
National Public Safety Telecommunications Council and as Vice
Chair of the Governing Board for the Department of Homeland
Security's Project 25 Compliance Assessment Program.
I am leading the city's efforts to implement one of the
largest P25 radio systems in the country. The system will be
one of the first to implement the newest version of the P25
standard known as Phase 2. Phase 2 will operate with double the
spectral efficiency of currently deployed Phase 1 systems,
which is critical to large metropolitan areas such as Houston
where we suffer from severe spectrum shortages.
Designing and purchasing a P25 system can be a challenge.
The P25 standard is actually a suite of standards that has many
sub-elements. Most people who write specifications do not know
enough about the suite of standards to properly document their
requirements. Thus, the result is systems are sold as P25
compliant when many parts of the systems remain proprietary.
As a large agency, the City of Houston has more resources
than most other agencies in the country. However, even with our
expertise, items were missed related to the Project 25
standards. Imagine the challenges facing small rural agencies
trying to buy these systems.
The P25 process has been ongoing for more than 20 years. As
years passed, the rate of technology change increases. While it
is true that technology standards must be constantly updated,
some better way of delineating the project standard should be
deployed.
Over the years, public safety involvement in P25 has paled
to that of vendors. Most of the major vendors have several
people that dedicate a substantial portion of their work time
to participation in the process. In reality, this means that
the standard is being driven by those that actively
participate: the vendors.
A good start to improving the process could be to provide
more public safety representation on the Steering Committee
that makes the rules on how the process functions and then
creating limited staggered terms for those representatives.
P25 manufacturers often sell proprietary features on top of
the basic P25 operation. The standard has provisions that allow
vendors to do this in cases where there is not an equivalent
feature mandated by the standard. However, radios on systems
are almost never replaced en masse so an initial decision on
proprietary options has far-reaching impact for years to come.
The biggest barrier, in my opinion, to P25 competition is a
lack of knowledge within the public safety agencies themselves.
I believe a group needs to be established that is focused
solely on the education and the success of the public safety
agencies using or contemplating the use of the P25 equipment.
Therefore, the DHS and OEC [Office of Emergency Communications]
partnership that is in place for the DHS Compliance Assessment
Program should be expanded to include this new role. However,
in order for it to be effective, it needs to be undertaken
seriously and funded appropriately.
Years ago, the P25 participants produced a paper regarding
what compliance assessment should be made of, and it specified
three types of test to prove compliance: performance,
conformance and interoperability. Recently, the P25 Compliant
Assessment Process Procedures Task Group--bear with me, I have
to give you an acronym--CAPPTG, changed its stance and said
that conformance testing in most cases should be replaced with
enhanced interoperability testing. The CAP Governing Board and
several leading public safety agencies objected to this change.
I believe that was one of the subjects of your hearing you had
before. Eventually the CAP Governing Board established the
requirement to include conformance testing over the objection
of the manufacturers.
The vendors are continuing to assert that conformance
testing is too burdensome, even though NIST recently created a
test, developed a test tool, and published all the applicable
test codes. If developing conformance tests and tools to do
them are too onerous, DHS should charge NIST to develop all
future test tools and then make them available directly to the
test laboratories.
The CAPPTG is charged with making recommendations on
appropriate compliance tests. These recommendations are used as
input documents into the CAP program. NIST participates and
provides input into that process. However, like public safety,
NIST is outnumbered on this group. In the past two years,
several critical votes have been divided down the line of
vendors versus public safety. Each one decided in favor of the
vendor position.
The development of these recommended tests is sometimes
delayed. As an example, P25 trunk radio systems have been sold
for more than ten years but yet there is not a single
recommended test available that includes conformance tests for
this functionality, not one test. The CAP Governing Board would
like to release compliance assessment bulletins for P25
equipment features prior to these features entering the
marketplace. To meet this goal, the CAP may need to develop an
alternate process that is not dependent on the P25 process to
recommend the test.
In closing, I would like to thank Chairman Wu for inviting
me to testify today, and on behalf of public safety and the
City of Houston, I would like to commend the work of the
Subcommittee as it relates to public safety communications and
encourage you to continue to weigh in on this very important
topic.
[The prepared statement of Mr. Sorley follows:]
Prepared Statement of Tom Sorley
Hello, my name is Tom Sorley. I am the Deputy Director of Radio
Communication Services for the City of Houston. I also serve as the
Chair of the Technology Committee for the National Public-Safety
Telecommunications Council and as Vice-Chair of the Governing Board for
the Department of Homeland Security Project 25 Compliance Assessment
Program.
I am leading the City of Houston's efforts to implement one of the
largest P25 radio systems in the Country. Once completed, the system
will be one of the first to implement the newest version of the P25
standard known as Phase 2. This newest version of the standard was
created to operate with double the frequency efficiency of the
currently deployed Phase 1 systems. This efficiency is paramount for
large metropolitan areas such as Houston which suffer from severe
spectrum shortages.
Designing, building, and operating a P25 radio system can be a big
challenge. The standard is actually a suite of standards that has
hundreds of sub-elements. Most people that are writing specifications
to buy a new system do not know enough about the P25 suite of standards
to even properly document their requirements. In fact, most just
specify that the technology must be P25 compliant. They fail to specify
individual elements that must be complaint and the result is that
systems are sold as P25 complaint when many parts of the system that
could be standards-based remain proprietary.
The City of Houston has more resources than most agencies in the
country and therefore we were able to employ one of the largest
consulting firms in the public safety communications industry. However,
even with our expertise and the assistance of our consultant, there
were still items that we missed related to the P25 standard. Imagine
the challenges facing small rural public safety entities. I believe
this is due to the complexity of the standard and the ever changing
elements that make up the standard.
The P25 standards development process has been going on for more
than 20 years. As mentioned previously, there are many elements to the
standard and several interfaces that all must be fully defined. While
this work is being done, technology continues to change. In fact as the
years pass, the rate of technology change is increasing. Further
complicating the process are regulatory changes, such as frequency
efficiency rules, that must be addressed in the standards development
process. While it is true that technology standards must be constantly
updated, some better way of delineating the P25 standard must be
developed.
It would be very helpful if the P25 process created versions that
could be easily summarized. (example P25 version 3) This version number
would allow agencies to know what is included as part of the P25
standard and more importantly what is not included. This is done in
other technology standards such as IEEE 802.11 which is a widely
accepted standard for wireless local area networks. The 802.11 standard
has many versions delineated by different letters of the alphabet.
Although consumers don't necessarily understand the difference between
802.11a and 802.11n, they can easily understand that a product is
compliant to one version or the other. The bottom line is that P25 has
so many moving parts comprised of many different standards within the
suite of standards that the lay person would have no real way of
determining if the products they are buying really conform.
The three key aspects of Project 25 that make it particularly
important for improved communications interoperability:
1. The initiative was begun and is driven by public safety
agencies and organizations.
2. It proceeds with both a vision of forthcoming technological
change and the need for graceful migration between technologies
used by public safety.
3. Competition founded on open standards would produce the
best technology, at the best prices for pubic safety agencies.
Driven by Public Safety Agencies and Organizations
Over the years, public safety involvement in the P25 standards
development process has become harder and harder to maintain. Some key
public safety representatives have been involved virtually from the
beginning of the process. However, the number is small and the
involvement of others is limited at best. Vendor representatives vastly
outnumber public safety. Most of the major vendors have several people
that dedicate a substantial portion of their work time to participate
in P25. In reality, this means that the standard is being driven by the
active participants--vendors.
The P25 standard development process is set up to encourage
consistent participation from both vendors and public safety officials.
While this seems like a valid approach, travel restrictions on local
public safety representatives often leave them unable to consistently
attend making them ineligible to vote on key items. Also, the P25
Steering Committee only has two of the initial public safety
representatives who have never been rotated, leaving the impression
that they have become more partial to the vendors' perspectives on key
issues.
The process could be improved by providing more public safety
representation on the Steering Committee and by creating limited,
staggered terms for those representatives.
Technology Change and Graceful Migration
As previously discussed, the pace of the standards development
process is slow. The rapid pace of technology change further slows the
completion of this complicated suite of standards. Also, in some cases,
it is in the best interest of the vendor community to have parts of the
standard lag as this creates an unmet need that must be filled with a
proprietary option. For example: The P25 standard has provisions that
allow vendors to offer proprietary features/functions provided there is
not an equivalent feature/function mandated by the standard. This
serves as a motivator to slow the process down.
P25 Competition
Competition is hampered by a lack of understanding by public safety
agencies. The only consistent P25 education effort is conducted by the
P25 Technology Interest Group (PTIG). This group is made up of vendors
and public safety representatives that are charged to promote the
success of Project 25 and educate interested parties on the benefits
that the standard offers. As indicated in their purpose statement, this
group is focused on the success of the standard. I believe that a group
needs to be established that is focused solely on the education and
success of public safety agencies using or contemplating the use of P25
equipment.
This public safety education effort should be focused around
helping local, state, and federal agencies understand the standard by
creating outreach materials, draft requirements language, draft
purchasing language, and draft contract language. It would seem that
the existing partnership between DHS and OEC in the P25 CAP could be
expanded to include this new role. However, to be effective this effort
must be undertaken seriously and appropriately funded.
Competition is not encouraged by manufacturers. P25 manufacturers
often try to sell proprietary features that reside on top of the basic
P25 operation of the radios in order to force future sales of their
products. Some examples include very simple encryption algorithms that
are proprietary and appear to solve a problem for local agencies by
providing a cost-effective alternative to standards-based encryption
that typically costs several hundred dollars more. However, new
entrants into that system, or existing agencies on that system that
need radios, are forced to remain with that particular vendor to
maintain interoperability with the existing radios that utilize the
proprietary encryption. Radios on systems are rarely replaced in mass.
Therefore, an initial decision on proprietary options has far-reaching
impact for years to come.
Another example of this practice is making accessories that are
dependent on particular radios and/or other related items. Years ago,
siren controls in police cars were integrated into mobile radios to
make the user experience easier. However, compatibility ultimately
became an issue as a result most public safety agencies de-coupled
siren controls and radios in the late 1980's. Recently, our vendor
proposed that we consider using a new integrated control head for our
radios. The users were very interested in the device as the
functionality and ease of use met most of their needs. However, the
control head would only operate that particular vendor's siren control
package. This would have forced us into a proprietary relationship with
radios and related sirens limiting our future buying options. We chose
to pass on the option.
P25 Compliance Assessment Program
The DHS CAP is a relatively new program that endeavors to ensure
that products marketed and sold to public safety as P25 actually adhere
to the standard. Years ago, the P25 participants produced a paper on
compliance assessment that established three types of tests to prove
compliance:
1. Performance--This test ensures the device performs to the
specifications.
2. Conformance--This test ensures the device adheres to the
P25 standard.
3. Interoperability--This test ensures the device seamlessly
interacts with similar devices.
The P25 Compliance Assessment Process and Procedures Task Group
(CAPPTG) drafts Recommended Compliance Assessment Tests (RCAT). These
RCATs are used as input documents into the DHS CAP program. The
National Institute of Standards and Technology (NIST) participates in
P25 and provides input to the CAPPTG to consider in the development of
RCATs. However, like public safety representatives, NIST is outnumbered
by vendors on this task group. In the past two years, several critical
votes have been divided down the line of vendors versus public safety.
Each of these votes was decided in favor of the vendor position.
The DHS CAP program created and published the first Compliance
Assessment Bulletin that was based substantially (but not completely)
on the RCAT from the CAPPTG. Subsequently, the CAPPTG changed its
stance and said that Conformance testing was no longer needed. Instead,
they advocated replacing conformance testing with enhanced
Interoperability testing. The CAP Governing Board and several leading
public safety agencies objected to this change. Eventually, the
manufacturers acquiesced on this in regard to the Inter Subsystem
Interface (ISSI). In fact, some of them testified earlier this year at
this sub-committee stressing that they were committed to the CAP
program and would continue to participate even if conformance testing
were required.
Over the last several months, those same vendors are reverting back
to their previous stance on Conformance testing. They have asserted
that the testing is too complicated, expensive and burdensome. This is
their position even though NIST has created a test and developed a test
tool that is easily adopted. In meetings earlier in the year, one
vendor stated that they already run ALL the conformance tests during
development making the need to repeat them unnecessary. None of the
other vendors in attendance at that meeting raised an issue with that
statement. If the vendors already run ALL the conformance tests during
development and NIST has develop a test while publishing all the
applicable test code, why is it that conformance testing is still too
complicated, expensive, and burdensome? If developing a test tool to
perform conformance tests is too onerous for the vendors, DHS should
charge NIST to expand their support of the CAP program by developing
the tests and making them available to the test laboratories.
The DHS CAP work plan has been largely driven by the availability
of RCATs from the CAPPTG. This is based on the assumption that the P25
process contained the largest collection of P25 experts making it the
logical place for test requirements development. Again, NIST and public
safety representatives are involved in that process. However,
development of RCATs can be delayed based on any number of factors. As
an example, P25 trunked radios have been sold in the market place for
more than 10 years but there is not one RCAT available that includes
conformance tests for trunking functionality. The CAP governing board
would like to develop and release Compliance Assessment Bulletins
establishing the testing of P25 features prior to or in concert with
those features entering the market place. We have a great deal of
catching up to do, but it clear to us that we may have to develop an
alternate process that is not dependent upon the P25 CAPPTG developed
RCATs.
Most major public safety associations have publicly advocated for
retaining all three types of tests: performance, conformance, and
interoperability as each play a key role in determining if a product is
compliant. First responders must be able to predict with certainty what
the device they use will perform as expected. It is imperative that
each type of test be performed to make sure.
One complicating factor in the DHS CAP is the fact that it is
voluntary. No vendor is forced to participate. To date, most vendors do
participate, but during the disagreement over conformance testing of
the ISSI several vendors informally indicated that if conformance
testing was pursued, they would simply not participate. If all the
vendors chose to opt out of the process, the process dies. DHS has
included a requirement in the Federal Grant Guidance that requires any
P25 equipment purchased with grant funds must have a Suppliers
Declaration of Compliance (SDOC) on file on the Responder Knowledge
Base (RKB) website. However, there are creative ways to get around this
requirement. For instance, I heard a story last month that a vendor was
willing to give away certain features as ``add-ons'' to avoid the SDOC
requirement. I am not sure if making P25 CAP a mandatory requirement is
practical, but it should be investigated.
Why not just use Cell Phones?
Recently, Reuven Carlyle a State Representative from the Seattle,
Washington area posted an entry into his blog entitled, ``Want
Government Reform? Idea #3: A new public safety communication
strategy.'' (Attachment A). In this blog post, Representative Carlyle
asserted (among other things) that P25 radios are too expensive and
public safety would be better served using cell phones. He asserts that
US public safety agencies pay many times more for their equipment than
do their counterparts in other countries. While some points in the blog
on the surface appear to be true, they are not presented in context.
Several days after Rep. Carlyle's blog, Bill Schrier, CIO of the
City of Seattle drafted his own blog entry in response. (Attachment B).
In Mr. Schrier's post, he points out many of the flaws in the original
post by Rep. Carlyle. I agree with all of Mr. Schrier's points. Simply
put, public safety has several requirements that can't possibly be met
by cellular devices. Network priority, reliability, availability during
disasters or weather events, talk-around mode, and ruggedness are
several of the requirements that public safety radios need and cellular
devices and systems can't provide.
I have the responsibility of buying these devices for the City of
Houston. I would love to be able to purchase a cellular phone that met
the needs of public safety. However, one does not exist and it is quite
unlikely that one will exist in the foreseeable future.
I would like to thank Chairman Wu for inviting me to testify today.
On behalf of public safety and the City of Houston, I would like to
commend the work of the sub-committee as it relates to public safety
communications and encourage you to continue to weigh in on this
important topic.
Attachment A
Have you ever noticed how police officers carry both a cellular
phone and a hand-held radio? It might surprise you to learn that you
are paying hundreds of times more for the radio than the cell phone.
And you're about to pay millions more unless we have the courage to
change course. Even the New York Times is starting to agitate.
When I joined McCaw Cellular Communications in the early 1990s--one
of the world's most entrepreneurial companies--less than 10 million
Americans had mobile phones. They were big, clunky and had no data
capability. Today there are as many mobile phones as people, prices
have fallen and consumers have benefitted from innovation that led to
iPhones, Windows Mobile, Droid and other robust platforms. The change
has been technically disruptive and positive. In that same time, the
nation's public safety community--law enforcement, fire, EMS--has also
spent billions of public tax dollars on new infrastructure and yet the
quality, cost and functionality of their expensive, proprietary, two-
way radios has not materially improved since the 1970s.
Now, the taxpayers of Seattle, King County and Washington State are
being asked to spend up to hundreds of millions more for a brand new
radio system for police, fire, EMS and other emergency workers.
In Seattle and King County alone my gut check is that the cost will
be in the $50 million to $250 million range. Since I'm not on the
inside I don't know if this is close or far from the truth, but my gut
is that it's uncomfortably in that range. And that says nothing of our
friends in Pierce, Snohomish and other communities who are struggling
through a similar journey. And Oregon is much further down the same
pathway and is now politically panicking in the face of a $600 million
bill.
It's time for courageous honesty: In my personal view, the decision
is the wrong direction technically, politically, and financially.
The uncomfortable truth is that for city, county and state
governments public safety radio equipment costs between 10x and 100x
more than it does in most other countries, despite the U.S. leadership
position for wireless technologies such as smartphones, WiFi, WiMax and
more. Even Seattle, in many ways the hometown of the consumer wireless
industry, will pay tens of millions for a proprietary new police radio
system.
The reason is that the nation's public safety communications market
does not enjoy healthy, vibrant, market-based competition in any way
comparable to consumer mobile services
First of all, it is important to acknowledge that we must ensure
our police, fire and EMS officials have access to high quality
emergency communication systems. Unfortunately, we must upgrade the
hardware-based system because the current vendor for the Seattle and
King County system, Motorola, has made a business decision to end
support for the current network.
In fairness, they told us long ago they would eventually turn off
our system, and we needed to buy their next generation system (or
conceptually their competitor's system). Unlike in the consumer market,
we may have purchased the equipment, but the company retains the right
to determine how long our system is supported. It's not much of an
exaggeration to say that it's sort of like Verizon asking consumers to
directly fund new cell towers and network and then forcing everyone to
buy new mobile phones because the company wants to upgrade their
internal network capabilities.
Second, our nation's first responders and 9-1-1 dispatchers
aggressively moved to establish an industry standard for first
responders called ``P25'' to get better radios at lower prices, to
break the monopoly of the current structure. Unfortunately, more than
25 years later, P25 is still not available, still not implemented and
even the Chainnan of the FCC recently jolted Members of Congress by
acknowledging ``. . . [P25] has taken more than 20 years to develop and
is still not complete'' and ``the protracted development of P25 has
allowed vendors to take advantage of selling proprietary solutions.''
The industry knows that P25 isn't, in fact, truly standards-based
and has resulted in even more expensive radios, not the other way
around. If our state's march toward P25 continues, it will be more
business as usual--and first responder radios will still cost $5,000
each. (Did you catch that? Just one P25 radio for one police officer
costs $5,000 and yet it has less processing power and functionality
than an iPhone, Windows Mobile or Droid phone).
Yet with few exceptions that is exactly where our current `group
think' in Seattle and King County is leading.
Third, some local Seattle and King County officials have recently
applied for the Obama Administration's plans for broadband across the
nation utilizing ``4G'' or ``LTE'' technology on 700 MHz . . . for the
Seattle area. Their position is inspired in part because the broadband
system would help first responders. And yet The National Broadband
Plan, as written, doesn't help with voice communications--the most
essential element for police, fire and EMS officials.
This isn't a modest technical decision, it's a major policy choice
facing King County Executive Dow Constantine and the county council as
well as Mayor Michael McGinn and the city council.
Here's a picture of where Seattle and King County are headed if we
don't change direction: The first 4G or LTE system built in the U.S.
for first responders is already underway, in the San Francisco Bay
Area--a geography and population similar to our own. The federal
government is fronting the $50 million it will cost, and the result is
that 300 public safety vehicles will be equipped with 4G data modems.
That is $167,000 per police car and fire truck, for video to and from
the scene.
At the same time the consumer marketplace--AT&T, Verizon, Sprint
and T-Mobile--provides virtually the same mobile service at a fraction
of the cost at equal or higher service quality levels in many cases.
Public safety is building their own mirror system to commercial
services. A mirror system that is on track to be proprietary, closed,
and expensive like our existing first responder radio systems.
Of course consumer cellular phones are not perfect nor always a
technically viable alternative, and they are by no means a simple
alternative, but philosophically they demonstrate the profound value of
market-based competition.
I am willing to bet a private tour of the State Capitol building
that if you ask 20 police, fire and EMS officials to choose between
their cellular phones and their two way radios, the majority will
choose to hold onto the former. Their mobile phones are easier, more
flexible, equally as reliable in most cases and now support data.
Without question it's important to acknowledge that technically
cell phones do have limitations--in basements, rural and other ``out of
coverage'' areas they won't provide essential voice communications for
first responders. But the very important and dirty little secret is
that neither do the P25 radio systems, or the 4G/LTE systems. Our first
responders need handsets that utilize the high feature/low cost
advantages of open market cell phone systems, but also work in
basements ``peer to peer'' when out of range of the system. And that
solution still shouldn't cost $5,000 for each and every single radio.
While it is true public safety radios need to be heavy duty, it
doesn't inherently mean they should cost 10 times as much as commercial
systems that have more processing power, more technical flexibility and
more application functionality.
Yes this is a bit technical and wonky but the financial
implications are stunning in scale--as Oregon is experiencing,
approaching $1 billion when the costs of all local agencies are
included with the first $600 million buildout.
Is it too late? There is a way forward if we have the courageous
honesty to tackle old assumptions and myths.
1. We should stop buying P25 radios at literally $5,000 per
radio and start buying TETRA radios. TETRA is similar to P25,
but it is truly open standard radio used by police and fire
departments in Europe and Asia . They offer more features and
are tested around the globe . . . and cost less than $500 each.
They are essentially ``Nextel-like'' in their capability but
are a fraction of the cost of the non-open standard P25.
2. We should absolutely back a national broadband plan--but
not this one. Not until it is legally bound to an open, public
standard that enables true, free market participation from any
and all vendors. Not a penny of federal or state funding should
go towards any proprietary 4G/LTE solutions, and Seattle and
King County public safety leaders should insist on an open
standard before launching any 4G/LTE 700 MHz construction in
Washington.
3. Let's ask line officers and regular firefighters what they
need to do their jobs. They are the users and yet we rarely ask
them firsthand what they need to succeed.
4. Investigate the real-deal of the $50 million pilot project
in San Francisco, which puts the proprietary 4G/LTE technology
in the lead for another 20-year monopoly. Let's understand the
implications before Seattle goes down the same expensive
route--but likely without the pot of federal money provided to
San Francisco.
5. We're not the only ones with this issue. We should ask
other regions and states to join us in asking for a market that
gives our first responders what they really need, at a price
that we can afford.
6. We should have the courage to explore a stronger
partnership with commercial mobile operators in underserved
areas. We could subsidize the expansion of their networks and
provide cell tower sites, for example, in exchange for more
sophisticated `priority access' for public safety--and improved
service level agreements--and pricing breaks.
Perhaps a stronger partnership with Oregon could save us both
hundreds of millions of dollars or more. We can no longer afford a
world where each state, each county, each city `goes it alone' in the
delivery of `utility' services such as communications. Imagine our
buying power united by a technical vision and strategy?
Unfortunately, at the end of the day, we acknowledge we have to buy
a new radio system for our faithful and hard-working police,
firefighters, and EMTs in the Seattle and King County area.
We as a city, county and state are more innovative, entrepreneurial
and technically sophisticated than this. If we believe in government
reform and want to display to the public that we have the courageous
honesty to seize the opportunity of this crisis, we need to change
course even in sacred areas like public safety. We have to question old
assumptions, challenge monopolies inside and outside of government, and
demand that when taxpayers are paying the bill, there is value for our
dollar.
It's the right thing for the public who are served by our
courageous law enforcement, firefighters and EMS officials. And it's
right for taxpayers.
Your partner in service,
Reuven.
Attachment B
Biography for Tom Sorley
Tom Sorley is the Deputy Director Radio Communications Services for
the City of Houston. He is currently leading the City's efforts to
implement a $125+ million P25, public safety radio system. Mr. Sorley
is a nationally recognized leader in public safety communications with
over 25 years experience in many facets of the field. Mr. Sorley serves
on several national and international committees including the
Governing Board Vice-Chair of the Department of Homeland Security P25
Compliance Assessment Program and as the Chair of the Technology
Committee for the National Public Safety Telecommunications Council
(NPSTC).
Chairman Wu. Thank you, Mr. Sorley.
Ms. O'Hara, please proceed.
STATEMENT OF ELLEN O'HARA, PRESIDENT, ZETRON
Ms. O'Hara. Chairman Wu and Members of the Subcommittee,
thank you for this opportunity to offer testimony on Project 25
standards and their implementation in public safety radio
systems.
I am the President and CEO of Zetron, a manufacturer of
public safety communications equipment. Zetron has been serving
the communication needs of public safety agencies in our Nation
for over 30 years. With several thousand installations
worldwide, we are the largest independent manufacturer of
interoperable dispatch consoles in the Nation.
I appreciate the opportunity to testify to the Subcommittee
regarding the P25 standards. We feel that Project 25, or P25,
is critically important to public safety. Zetron is in
agreement with the goals of P25. Our company was one of the
early signers of the Memorandum of Understanding that created
the project, and we have been an active participant in the
standards process for the last 10 years.
Chairman Wu, you asked me to address two questions
concerning P25. First, what challenges has Zetron faced in
integrating our products with those of other vendors? And
secondly, how has this impacted our customers? In addition, you
asked what recommendations would Zetron make to ensure that the
P25 process helps foster competition in the marketplace.
Now, in order to put my answers into context, I would like
to refer you to the following graphic. This is a highly
simplified depiction of a P25 system. It includes the P25
network and connection to another P25 network, the dispatch
console, radios that are used on the system and the critical
interfaces that connect these components: the wireless Common
Air Interface, or CAI, the Inter Subsystem Interface, which is
a wireless interface, ISSI, and the wireline Console Subsystem
Interface, or CSSI.
Now, in your first hearing in May, you focused on radio-to-
radio interoperability and competition, which is achieved in
P25 through the wireless Common Air Interface, CAI. All P25
network manufacturers today in the United States have adopted
the CAI standard. As a result, their systems are compatible
with all P25 radios regardless of the radio vendor. In this
case, competition is well served. It gives customers more
choices and better value.
Now, different circumstances affect competition on the
wireline side where dispatch consoles are connected to the
network. To support competition on the wireline side, two
standards have been created. One is the Inter Subsystem
Interface, which provides an interface between two different
vendors' P25 networks, and the other is the Console Subsystem
Interface. The CSSI provides a seamless wired interface between
the dispatch consoles of one vendor, such as Zetron, and
another manufacturer's P25 network. The CSSI ensures that the
customer has a choice in their selection of dispatch consoles.
Now, this is important because the dispatch console is the
heart of a public safety communications system. It connects
first responders such as police officers on their beat with a
public safety communication center. The console also supports
interoperability among radios by patching together radios that
use different frequency bands.
Because dispatch consoles play such a critical role in the
communications center, customers are best served when they have
the freedom to choose the console that best meets their needs
and cost requirements. Without a CSSI standard and the adoption
of that standard by the P25 network vendor, the customer's
choice is limited to the proprietary consoles provided by the
network vendor.
There are several reasons why the adoption of the CSSI
standard by P25 network vendors has been slow. Now, each P25
interface, as Mr. Sorley mentioned, is defined by a suite of
standards documents that specify how the interface is to be
implemented, tested and verified. These are critical documents,
and the most important ones which define the CSSI and define
how that is to be implemented are indeed complete. Due to other
priorities in the standards process, however, the
Telecommunications Industry Association, TIA, that manages the
process has not yet finalized the testing and verification
documents. This situation has given some P25 network
manufacturers reason to delay the implementation of the CSSI in
their network offerings. A customer who purchases a P25 network
from one of these vendors today has no choice but to purchase
the network manufacturer's own proprietary console.
Zetron has invested considerable resources to implement the
P25 CSSI written standard but today our CSSI-enabled consoles
are currently able to connect to the networks of only three of
the seven network vendors' equipment: Tait Radio
Communications, EADS North America, and Raytheon. The other
network manufacturers have not yet publicly adopted the CSSI
and thus proprietary consoles are the only choice available to
customers of their networks.
We are concerned that competition and customer choice are
limited by the slow adoption of the open standards CSSI.
Indeed, the lack of widespread adoption of the CSSI has led
some of Zetron's customers to delay their transition to P25,
which in turn negatively impacts both competition and
interoperability.
We feel that incentives are needed to solve this problem.
To that end, I would like to offer two recommendations that
could help eliminate some of the obstacles to competition.
First, we believe that the completion of the full suite of
published standards for P25 wireline interfaces would remove a
significant roadblock to their adoption. To hasten this
process, we recommend that the Federal Government consider
issuing grants to manufacturers so that they can allocate the
resources necessary to complete the standards. This would allow
a manufacturer such as Zetron to provide dedicated engineering
resources to the TIA for the purposes of completing the testing
and verification documents of the CSSI, thereby completing the
full suite of standards for this P25 wireline interface.
We also recommend that the Federal Government set a date
within the next 12 dates after which it will no longer fund
through grants the purchase of P25 networks that offer only
proprietary consoles rather than the open standard CSSI. This
means that if the offered P25 network equipment can support
consoles, then that equipment must also support the open
standard CSSI. Otherwise it is ineligible for purchase using
interoperability grants.
In closing, I would like to reiterate Zetron's strong
support for these two objectives of Project 25. We believe that
policies that support the completion and adoption of open
standards, wireline interfaces such as the CSSI will help
ensure that P25's goals of interoperability and competition
will be fully realized.
Chairman Wu and Members of the Subcommittee, thank you
again for this opportunity to testify before you on these
important matters.
[The prepared statement of Ms. O'Hara follows:]
Prepared Statement of Ellen O'Hara
Chairman Wu and members of the Committee, thank you for this
opportunity to offer testimony on Project 25 standards and their
implementation in public safety radio systems.
I am President and CEO of Zetron, a manufacturer of public safety
communications equipment.
Zetron has been serving the communications needs of our nation's
public safety agencies for over 30 years. With several thousand
installations worldwide, we're the largest independent manufacturer of
interoperable dispatch consoles in the nation.
I appreciate the opportunity to testify to the Committee regarding
the Project 25 standard. We feel that Project 25 (P25) is critically
important to public safety. Zetron is in agreement with the goals of
P25. Our company was one of the early signers of the P25 Memorandum of
Understanding (MOU), and we have been an active participant in the P25
standards-development process for the past decade.
Chairman Wu, you asked me to address two questions concerning P25:
First, what challenges has Zetron faced integrating our products
with those of other vendors, and how has this impacted our customers?
Second, what recommendations would Zetron make to ensure that the
P25 process helps foster competition in the marketplace?
In order to put my answers into context, I'd like to refer you to
the following graphic.
This is a highly simplified depiction of a P25 system. It includes
the P25 network, the dispatch console, radios that are used on the
system, and the interfaces that connect these components: the Common
Air Interface (CAI), the Inter Subsystem Interface (ISSI), and the
Console Subsystem Interface (CSSI).
In your first hearing in May, you focused on radio-to-radio
interoperability and competition, which is achieved in P25 through the
wireless Common Air Interface.
All P25 network manufacturers in the United States have adopted the
CAI standard. As a result, their systems are compatible with all P25
radios, regardless of the radio vendor. In this case, competition is
well served--it gives customers more choices and better value.
Different circumstances affect competition on the wireline side,
where dispatch consoles are connected to the network.
To support competition on the wireline side, two standards have
been created. One is the Inter Subsystem Interface--which provides an
interface between two different vendors' P25 systems.
The other is the Console Subsystem Interface. The CSSI provides a
seamless wireline interface between the dispatch consoles of one vendor
(such as Zetron) and another manufacturer's P25 network.
The CSSI ensures that the customer has a choice in their selection
of dispatch consoles. This is important because the dispatch console is
the heart of a public safety communication system. It connects first
responders, such as police officers on their beat, to the public safety
communications center. The console also supports interoperability among
radios by patching together radios that use different frequency bands.
Because dispatch consoles play such a critical role in a
communication center, customers are best served when they have the
freedom to choose the console that best meets their needs and cost
requirements. Without a CSSI standard and the adoption of that standard
by the P25 network vendor, the customer's choice is limited to the
proprietary console provided by that network vendor.
There are several reasons why the adoption of the CSSI standard by
P25 network vendors has been slow.
Each P25 interface is defined by a ``suite'' of standards documents
that specify how the interface is to be implemented, tested and
verified. The critical documents, which define the CSSI and how to
implement the standard, are complete. Due to other priorities in the
standards process, the Telecommunications Industry Association (TIA)
has not yet finished the testing and verification documents.\1\
This situation has given some P25 network manufacturers reason to
delay the implementation of the CSSI in their network offerings. A
customer who purchases a P25 network from one of these vendors today
has no choice but to purchase the network manufacturer's own
proprietary console.
Zetron has invested considerable resources to implement the P25
CSSI wireline standard. But today our CSSI-enabled consoles are
currently able to connect to the networks of only three of the seven
network vendors' equipment--Tait Radio Communications, EADS North
America, and Raytheon. The other network manufacturers have not yet
publicly adopted the CSSI, and thus proprietary consoles are the only
choice available to customers of those networks.
We are concerned that competition and customer choice are limited
by the slow adoption of the open-standard CSSI. Indeed, the lack of the
widespread adoption of the CSSI has led some of Zetron's customers to
delay their transition to P25, which in turn negatively impacts both
competition and interoperability.
We feel that incentives are needed to solve this problem. To that
end, I would like to offer two recommendations that could help
eliminate some of the obstacles to competition.
First, we believe that the completion of the full
suite of published standards for P25 wireline interfaces would
remove a significant roadblock to their adoption. To hasten the
completion of these standards, we recommend that the federal
government consider issuing grants to manufacturers so that
they can allocate the resources necessary to complete the
standards. This would allow a manufacturer such as Zetron to
provide dedicated engineering resources to the TIA for the
purposes of completing these standards.
We also recommend that the federal government set a
date within the next 12 months, after which it will no longer
fund, through grants, the purchase of P25 networks that offer
only proprietary console interfaces rather than the open-
standard CSSI. This means that if the offered P25 network
equipment can support consoles, that equipment must also
support the open-standard CSSI; otherwise, it is ineligible for
purchase using interoperability grants.
In closing, I would like to reiterate Zetron's strong support for
the objectives of Project 25. We believe that policies that support the
completion and adoption of open-standards wireline interfaces such as
the CSSI will help ensure that P25's goals of interoperability and
competition will be fully realized.
Chairman Wu, and members of the Committee, thank you again for the
opportunity to testify before you on these important topics.
Note
\1\ Why Are the P25 Standards Taking So Long?
This is perhaps the most frequently asked question regarding P25.
When asked, it is often in comparison to other wireless communications
standards, such as cellular or even Europe's narrow-band public safety
standard called TETRA.
We believe that a significant portion of the answer to this
question lies in the scope of P25. P25 is unique among all other
wireless communications standards in that it includes open, published
standards not only for over-the-air protocol and data dispatch consoles
to P25 networks (via the CSSI), and to accommodate the unique need of
cross-band interoperability (via the ISSI).
While other standards may identify similar interface points, only
P25 has gone to the extent of creating standards for these interfaces.
This is to ensure that the needs of our nation's public safety agencies
are met. Thus the scope of the P25 standard is at least twice that of
other wireless communications protocols. In addition, some of the other
wireless standards, particularly cellular, were able to leverage the
substantial number of existing telephony standards. Land mobile radio,
with its unique push-to-talk and selective signaling characteristics,
is not able to use telephony standards to the same extent.
Another reason it has taken longer to produce P25 standards is the
collaborative, cooperative, and consensus-based approach used. While
P25's requirements are identified by its users, as it should be, the
actual development of standards to meet those requirements is done
mostly by manufacturers.
P25 may not be unique in this approach; some cellular standards
have also developed in this way. But being a much smaller market with
smaller revenue potential and fewer participants, the amount of
resources applied by P25 manufacturers has been relatively small
compared to those of cellular manufacturers. In the case of European
mobile radio standards, many of these have had external funding and
participation by European governments.
Finally, the needs of our nation's public safety users are not
static, but continue to evolve. For this reason, Project 25 has always
been dynamic, with standards that can be extended and modified to meet
emerging needs.
Thus P25 has grown beyond its original vision of the 90's which is
``complete,'' (Phase 1), and is now nearing completion of a Phase 2. In
this sense, P25 will not be complete until it is replaced.
Biography for Ellen O'Hara
Ellen O'Hara is currently the president and CEO of Zetron, Inc.,
which is headquartered in Redmond, Washington.
Zetron provides mission-critical communication solutions for
clients in the fields of public safety, transportation, utilities,
manufacturing, healthcare, and business. With offices in Basingstoke,
England; and Brisbane, Australia; as well as a growing network of sales
representatives in Europe, Asia and Latin America, Zetron's reach is
worldwide.
Throughout her career, Ms. O'Hara has served in positions of
leadership and management for some of the country's leading
communications technology companies. Prior to joining Zetron, she
served as president and COO of EF Johnson Company in Irving, Texas; and
also held senior-level management positions at Motorola, including vice
president and general manager of its Radio Products Division, and vice
president and director of subscriber operations in its Radio Network
Solutions Group. During the 1980's, she also worked for General
Electric's Mobile Communications Division (now a division of Harris) in
business development, operations and product management.
Ms. O'Hara began her career in the field of organizational
development at the Massachusetts Institute of Technology, where she
also attended the Sloan School of Management.
Ms. O'Hara has served on several industry association and non-
profit boards, including the International Telecommunications
Association and the American SMR Network Association. She was
Motorola's representative on the FCC's National Coordinating Committee
in the late 1990's.
Ms. O'Hara holds an MBA with a Baker Scholar distinction from the
Harvard Graduate School of Business, and a BA with distinction from
Mount Holyoke College.
Chairman Wu. Thank you, Ms. O'Hara.
Mr. Ingram, please proceed.
STATEMENT OF MARVIN INGRAM, SENIOR DIRECTOR, ARINC, PUBLIC
SAFETY COMMUNICATIONS
Mr. Ingram. Chairman Wu, Members of the Subcommittee, thank
you for the opportunity to appear before you today to talk
about this very critical subject. In my testimony today, I
would like to leave you with three points for your
consideration. One, standards drive innovation and competition
in any marketplace, and it will do so in public safety. Two,
technology is not a barrier to the finalizing of the P25
standards, such as CSSI. Three, finalizing communications
standards and adoption of compliance and conformance testing is
imperative to fully solving the interoperability problem.
I represent a company that has a long history of radio
communications, stretching back over 80 years. ARINC was
originally formed to manage aeronautical radio frequencies used
by the airline industry, and we will perform that task today.
ARINC has participated in creating interoperability of
communications within the aviation industry and has built and
manages a global mission-critical network that is used by
airlines all over the world.
The tragic events of 9/11 motivated some people at ARINC to
evaluate the problem of public safety communications
interoperability and to see how we could leverage our expertise
in solving the problem. That is when the business unit I
represent, which is the Public Safety Communications Business
Unit, was started.
ARINC supports the full adoption and the competition of the
current published standards within P25. Over the past few
years, the P25 standard has evolved to the point where more
manufacturers are making P25-compliant components such as
subscriber units, console systems, system control software and
repeaters. These smaller companies make very capable products.
However, they don't make complete systems. As an integrator, we
now have the ability to take these components from these
manufacturers and build systems using a ``best of breed''
approach. Many of these manufacturers seek ARINC out due to our
unbiased approach to designing and implementing public safety
systems. ARINC has invested and will continue to invest
substantially in the testing and delivery of systems that
conform to the P25 standard.
I want to address the questions that you asked, Chairman
Wu, of ARINC and me: What challenges has ARINC encountered in
integrating P25 digital land mobile radio equipment from
different vendors, and in our experience, how can these
technological challenges impact the customers of this
equipment? It is a good question. ARINC has integrated
technology from several different P25 equipment manufacturers
including Zetron, EASDS, EF Johnson, Kenwood, Tait and Thales.
We are working with several others to get their equipment in
our labs so that we can include them in our proposals to our
customers. We found these manufacturers to be enthusiastic in
working with each other and working with us. We have all
collaborated to increase interoperability of the various
products. Many of these manufacturers have expressed the desire
to participate in ARINC-delivered systems as they feel they
will be able to compete with one another on a level playing
field.
However, as standards have been delayed, competition has
been stifled. Costs have remained high and the full potential
for interoperability has not been achieved. Vendors of
proprietary systems are taking advantage of the delay in
standards development to advance their gain in market share.
Customers have had to purchase or extend the life of their
existing system or systems with proprietary features and
functions, often at a hefty price, until the standards are
complete. As Mr. Dereck Orr of the National Institute of
Standards and Technology testified before this Subcommittee on
May 27, 2010, only small but critical portions of the standard
have been ratified and it has only been in the last two years
that a compliance testing program has been implemented.
The first few years of P25 deployments had many failures
with respect to multi-vendor interoperability and finger
pointing as to who was at fault. This instilled a level of
doubt in the minds of many first responders that has not been
fully overcome. In several procurements we have been asked, how
can we guarantee that components from various vendors will
interoperate? Even today, as CAP labs attest to
interoperability, the customer base uses the past as an excuse
to stick with the status quo of a single vendor solution. To be
sure, there are still ways to purposefully deploy a P25 system
such that another vendor's equipment will not function on it,
but there are also ways to deploy it so that it will.
The next question that you asked, what would you recommend
to ensure that P25 standards are implemented consistently? I
believe that open standards in public safety communications
will increase competition and provide innovative and cost-
sensitive solutions. We have witnessed this in other
industries, but the pace of the current public safety
communications standards development process has in fact
frustrated equipment manufacturers who wish to invest in the
development and enhancement of their products. ARINC supports
accelerating the adoption and implementation of the most
critical public safety communication standards and
technologies, along with compliance and conformance testing.
Finally, ARINC recommends federal funding be established
and managed by a dedicated governing body to provide grants to
public safety personnel, technology vendors and others to
participate in the ratification of the published P25 standards.
ARINC recommends a schedule be established and maintained by
the dedicated governing body to ensure completion of the
standards in a timely manner. ARINC also recommends the
standard be released in manageable phases. Finally, ARINC
recommends that this initiative be closely monitored by this
and other legislative and regulatory bodies charged with
solving the problem of public safety communications.
Chairman Wu, Members of this Committee, thank you again for
inviting me to testify before you today.
[The prepared statement of Mr. Ingram follows:]
Prepared Statement of Marvin Ingram
Chairman Wu, Members of the Subcommittee, thank you for the
opportunity to appear before you today to discuss the current state of
interoperability and competition in the marketplace in Public Safety
radio equipment. It is truly an honor to speak with you today, thank
you for the invitation. ARINC support the full adoption of the P25
standards. In my testimony today, I would like to leave you with 3
items for your consideration:
1. Standards drive competition and innovation in any
marketplace and it will in Public Safety communications
2. Technology is not a barrier to finalizing the P25
standard--several manufactures are anxiously awaiting
completion of several elements of the standards
3. Finalizing communications standards and adoption of
compliance and conformance testing is imperative to fully
solving the interoperability issue.
I represent a company that has a long history in radio
communications stretching back almost 80 years. ARINC was originally
formed to manage aeronautical radio frequencies used by the airline
industry and we still perform that role today. ARINC has participated
in creating interoperability of communications within the aviation
industry. ARINC has built and manages a global mission critical network
that is used by airlines around world to communicate.
In the aviation industry, many of the communications standards are
referred to as ``ARINC'' standards and they enable voice and data
communications interoperability as well as physical equipment
interoperability. The standards are far reaching with everyone from
airframe manufacturers to rental car companies utilizing them. They
enable a pilot to bring you weather forecasts for the destination
airport at 35,000 feet, lets a rental car company know you will be
late, and enables an engine manufacturer to know when a jet needs
servicing automatically.
The tragic events of 9/11 motivated some smart people at ARINC to
evaluate how we could leverage our expertise in aviation communications
to contribute in solving the public safety communications
interoperability problem. That's when the business unit I represent was
formed.
While a relative newcomer to public safety, our track record
demonstrates our ability to solve complex problems and deliver mission
critical solutions. In the industries and markets where we participate
we are viewed by our customers as a thought leader and partner. For the
most part we do not manufacture hardware; we use existing components to
create new or integrated solutions.
From this background you might infer how important standards are to
ARINC. Standards are what enable ARINC to build the integrated
solutions we provide to our customers. This is true in every market
vertical we participate. The market confusion regarding P25 standards
is one factor that has slowed our ability to add real value to public
safety customers. Until recently, there were only two vendors where
customers could purchase a trunked P25 system. These vendors provide a
complete end-to-end system sold through a direct sales model with
little to no room for additional vendor participation.
Over the past few years the P25 standard has evolved to the point
where more manufacturers are making P25 compliant ``components'' such
as subscriber units, consoles, system control software, and repeaters.
These smaller companies make very capable products, however they don't
make a complete system. As an integrator, we now have the ability to
take the components from these manufacturers and build complete systems
using a ``best of breed'' approach. Many of these manufacturers seek
ARINC out due to our unbiased approach to designing and implementing
public safety systems. ARINC has invested and will continue to invest
substantially in the in the testing and delivery of systems that
conform to the P25 standard.
This transition from a single vendor solution to the integrated
multi-vendor solution is nothing new. The IT industry went through this
very transition in the early 90's. The real question from our
perspective is why has it taken so long for public safety to get where
it is? And why does it seem that it still has a very long way to go?
The P25 standard, started in 1989 just celebrated it's 20th
anniversary and it's still not complete. To put this in perspective,
twenty years ago the Internet was limited to universities and research
companies, PC's were very expensive, slow, and very few people had
them, there were no mobile phones, and ``high speed'' connections were
56kbps dialup. If other industries moved at the same pace as the P25
standard, almost no one would have a portable phone, ``portable
computers'' would cost $10,000 weigh 20lbs, with less than 1MB of disk
space, and wireless broadband would still be a pipe dream regardless of
the spectrum availability. I say this with some risk of offending the
many good folks who put so much effort into the standards as they exist
today, for they have developed a worthy baseline. But in large part,
many are just as frustrated as we are regarding the pace of
development. Overall this has had a negative impact on the ability of
first responders to communicate and put the public at risk on both a
daily basis and during times of crisis such as on 9/11 and during
hurricane Katrina.
``What challenges has ARINC encountered in integrating P25 digital
land mobile radio equipment from different vendors? In your experience,
how can these technological challenges impact the customer of this
equipment?''
ARINC has integrated technology from several P25 equipment
manufacturers, including EADS, Zetron, EF Johnson, Kenwood, TAIT and
Thales. We are working with several others to get their equipment in
our labs so that we can then include them in proposals to customers. We
have found these manufactures to be enthusiastic in working with us and
each other. We have all collaborated to increase the interoperability
of all the products. Many of these manufactures have expressed the
desire to participate in ARINC delivered systems as they will be able
to compete with one another on a level playing field.
However, as standards have been delayed, competition has been
stifled, costs have remained high, and the full potential for
interoperability has not been achieved. Vendors of proprietary systems
have taken advantage of the delay in standards development to advance
their gain in market share. Customers have had to purchase or extend
the life of their existing system or systems with proprietary features
and function, often at a hefty price tag, until the standard is
developed enough to use. As Mr. Dereck Orr of the National Institute of
Standards and Technology testified before this committee on May 27th,
2010 only small but critical portions of the standard have been
ratified, and it's only been in the last 2 years that a compliance
testing program has been implemented.
The first few years of P25 deployments had many failures with
respect to multi-vendor interoperability and finger pointing as to who
was at fault. This instilled a level of doubt in the minds of many
first responders that has not been fully overcome. In several
procurements we've been asked `How can guarantee that components from
various vendors will interoperate?' Even today, as CAP labs attest to
interoperability the customer base uses the past as an excuse to stick
with the status quo of a single vendor end-to-end solution, of which
there are still only two. To be sure, there are still ways to
purposefully deploy a P25 system such that another vendor's equipment
will not function on it, but there are also ways to deploy it so that
it will and it has been possible for quite a number of years.
To once again draw a parallel to another industry, most of you know
who manufactured your mobile phone, and what carrier you pay your
service charges too. How many of you know who made the infrastructure
at the local tower site? Do you worry that it's not compatible? Of
course not. The reason is the testing that other industries go through
to ensure compatibility and the zeal with which they want to ensure
their product is accepted in the marketplace.
Another challenge is dealing with the idiosyncrasies of how each
manufacturer interprets the standards. This has the potential to cause
issues with deployments. ARINC maintains a test and demonstration lab
at our headquarters in Annapolis Maryland to ferret out troublesome
configuration issues before we deploy systems to the field. We also
work with vendors during their development cycles to test new
functionality or products in a ``private'' environment that isn't as
sterile as their lab, yet won't impact customers. These vendors also
test among themselves to see if they have each come to the same
conclusion regarding how to implement technology. The level of activity
in this arena has increased over the last two to three years due to
more vendors in the space and recognition that the procurement process
if finally starting to shift from single to multi-vendor solutions.
What we have seen is that vendors with smaller market share must
and will work harder to prove to the larger vendors and the market in
general that their radio will interoperate with the ``big guys''. They
also work harder to innovate in areas such as ease of configuration,
battery life, fireground features, and packaging.
``What would you recommend to ensure that the P25 standards are
implemented consistently?''
I believe open standards in public safety communications will
increase competition and provide innovative, cost sensitive solutions.
We have witnessed this in other industries, but the pace of the current
public safety communications standards development process, has in fact
frustrated equipment manufacturers who wish to invest in the
development and enhancement of their products. ARINC supports
accelerating the adoption and implementation of the most critical
public safety communication standards and technologies, along with
compliance and conformance testing.
ARINC recommends federal funding be established and
managed by a dedicated governing body, to provide grants to
public safety personnel, technology vendors and others to
participate in the ratification of the published P25 standards.
ARINC recommends a schedule be established and
maintained by the dedicated governing body to ensure completion
of the standards in a timely manner.
ARINC recommends portions of the standards be
released in manageable phases.
Finally, ARINC recommends that this initiative be
closely monitored by this and other legislative and regulatory
bodies charged with solving the problem of Public Safety
interoperability.
Chairman Wu, Members of the Subcommittee, thank you again for
inviting me to testify on this very critical issue, I am honored.
Biography for Marvin Ingram
Marvin Ingram has served as the Senior Director for ARINC's Public
Safety Communications business unit since 2004. ARINC is a
Communications Engineering and Systems Integration firm based in
Annapolis Maryland. Mr. Ingram has led the development of the strategic
plan, technical roadmap and go-to-market strategy for the ARINC
Wireless Interoperable Network Solutions (AWINS).
AWINS was developed to provide architecture for a standards
platform to provide interoperable communications between Public Safety
and Homeland Security agencies. It is designed to provide greater
flexibility, resiliency, a choice of vendors, lower costs, and the
capability for future expansion. As an industry leader in legacy radio
systems interoperability using IP and VoIP, ARINC is known as an
integrator that delivers mission critical solutions. In addition to
traditional legacy radio integration, AWINS includes APCO P25 radio
technology. Focused on standards compliant systems, ARINC is able to
deliver end to end communications interoperability.
Mr. Ingram has provided leadership for over 20 years in program
management, engineering, quality assurance, customer satisfaction,
sales and marketing for Public Safety Communications and IT solutions.
Mr. Ingram started his career serving in the U.S. Air Force as an
Electronic Intelligence engineer. Mr. Ingram's career includes network
engineering and executive management in several information technology
organizations prior to joining ARINC.
Chairman Wu. Thank you very much, Mr. Ingram.
Mr. Sveda, please proceed.
STATEMENT OF RUSS SVEDA, MANAGER OF THE RADIO TECHNICAL SERVICE
CENTER, DEPARTMENT OF THE INTERIOR
Mr. Sveda. Thank you. Good afternoon, Mr. Chairman and
Members of the Subcommittee. I appreciate the opportunity to
appear before you today to discuss the Department of Interior's
testing program for Project 25. My name is Russ Sveda. I am the
Manager of the Radio Technical Service Center for the
Department of the Interior, where we provide land mobile radio
system engineering and product testing. I have almost 30 years
of military and civilian government experience in radio
communications and look forward to sharing my experiences with
the Subcommittee.
To provide you with a little background, because of the
Department's broad land management portfolio, the Department
has land mobile radios and systems in use across nearly all of
the 50 states and U.S. territories. Our operations,
particularly in law enforcement and wildland fire fighting,
require a high degree of interoperability with other federal,
tribal, state and local agencies. Our law enforcement officers
and fire fighters work in remote locations across the country
supporting various incidents, whether it is a wildland fire in
Alaska, a joint operation with the Border Patrol along the
southwest border or hurricane relief efforts in the Southeast,
and often we do all these things in one summer. A clear and
concise standard for land mobile radio, and confidence in the
products' adherence to those standards, are extremely important
to us.
The Department of the Interior adopted the Project 25
Standards in 1996 and has been buying and using products that
purport to adhere to those standards since then. Unlike many of
the other organizations who contract the design and
implementation of a turnkey radio system, we typically design
and install our own land mobile radio systems with components
purchased from multiple vendors in order to minimize our costs.
Our interest in the Project 25 standards and
interoperability goes beyond whether vendor A's radio works
with vendor B's radio and down into the land mobile radio
system itself. Our mission demands that not only must radio A,
B and C interoperate and work together on our local system, but
that our users' handheld and mobile radios must also work
effectively on any system in the country. With our in-house
system engineering and implementation, we must further ensure
that system equipment from vendor A works with system equipment
from vendor B and vendor C.
The slow pace of the development of the Project 25
standards has created some frustration in the radio user
community. While I applaud the industry for the success in
establishing a solid Common Air Interface, or CAI, so that
different radios can talk to each other, most of the standards
are still in development. We have invested 14 years in this
technology, and today we are still not able to design and
install a Project 25 compliant system without significant
engineering and customization.
The Department started testing Project 25 products in 2002
as part of a Department-wide radio contract. We found this
necessary because of the experiences we and our users had with
what I would call the first generation Project 25 products.
Since that time, we have evolved our testing along with the
evolution of the standards. Today, we test the Project 25
products offered under yet another contract that supports both
the Department of the Interior and the Department of
Agriculture.
Our current testing is based on the Project 25 Standards
and specifically targets performance, conformance and
interoperability. To use resources effectively, though, we
select specific tests based on the risks and the impacts to our
users, meaning we don't test absolutely everything that is in
the standards.
Since 2002, we have seen a drastic improvement in the
Project 25 products and a significant increase in the number of
vendors that can provide these products. There is still a long
road ahead, though.
We envision continuing to test Project 25 products until
all the standards are published and the industry has matured in
complying with those standards.
The Department of Interior is committed to supporting the
Project 25 Standards, and we welcome your support and attention
to this topic. It is in the best interest of the government and
in particular of those who place themselves in harm's way to
continue the standards development and independent testing of
Project 25.
This concludes my testimony. I am happy to answer any
questions you or the Members of the Subcommittee may have.
Thank you.
[The prepared statement of Mr. Sveda follows:]
Prepared Statement of Russ Sveda
Good Morning, Mr. Chairman and Members of the Subcommittee, I
appreciate the opportunity to appear before you today to discuss the
Department of the Interior's testing program for Project 25. My name is
Russ Sveda. I am the Manager of the Radio Technical Service Center for
the Department of the Interior (Department), where we provide land
mobile radio systems engineering and product testing for the
Department. I have almost 30 years of military and civilian Government
experience in radio communications and look forward to sharing my
experiences with the Subcommittee.
To provide a little background, because of the Department's broad
land management portfolio, the Department has land mobile radios and
systems in use across nearly all of the 50 states and U.S. territories.
Our operations, particularly in law enforcement and wildland fire
fighting, require a high degree of interoperability with other Federal,
Tribal, State and local agencies. Our law enforcement officers and fire
fighters work in remote locations across the country supporting various
incidents, whether at a wildland fire in Alaska, a joint operation with
the Border Patrol in the Southwest, or a hurricane relief effort in the
Southeast. A clear and concise standard for land mobile radio, and
confidence in the products' adherence to those standards, are extremely
important to us.
The Department of the Interior adopted the Project 25 Standards in
1996 and has been buying and using products that purport to adhere to
this standard since then. Unlike many of the other organizations who
contract the design and implementation of a turnkey system, we
typically design and install our own land mobile radio systems with
components purchased from multiple vendors in order to minimize costs.
Our interest in the Project 25 standards and interoperability goes
beyond whether vendor ``A's'' radio works with vendor ``B's'' radio and
into the land mobile radio ``system.'' Our mission demands that not
only must Radio ``A'', ``B'' and ``C'' interoperate on our local
system, but our users' handheld and mobile radios must also work
effectively on any system in the country. With our in-house system
design and implementation, we must further ensure that system equipment
from vendor ``A'' works with equipment from vendor ``B'' and vendor
``C''.
The slow pace of the development of the Project 25 Standards has
created some frustration in the radio user community. While I applaud
the industry for the success in establishing a solid Common Air
Interface so that different radios can talk to each other, most of the
standards are still in development. We have invested 14 years into this
technology and today, we are still not able to design and install a
Project 25 compliant ``system'' without significant engineering and
customization.
The Department started testing Project 25 products in 2002 as part
of a Department-wide contract. We found this necessary because of the
experiences we and our users had with what I would call the ``first
generation'' Project 25 products. Since that time, we have evolved our
testing along with the evolution of the standards. Today, we test the
Project 25 products offered under yet another contract that supports
both the Department of the Interior and the Department of Agriculture.
Our current testing is based on the Project 25 Standards and
specifically targets performance, conformance, and interoperability. To
use resources efficiently, we select specific tests based on the risk
and impact to our users.
Since 2002, we have seen a drastic improvement in the Project 25
products and a significant increase in the number of vendors that can
provide those products. There is still a long road ahead.
We envision continuing to test Project 25 products until all the
standards are published and the industry has matured in complying with
those standards.
The Department is committed to supporting the Project 25 Standards,
and we welcome your support and attention to this topic. It is in the
best interest of the government and in particular of those who place
themselves in harms' way to continue the standards development and
independent testing of Project 25.
This concludes my testimony. I am happy to answer any questions
that you or the members of the Subcommittee may have.
Biography for Russ Sveda
In December 2008, Russell A. Sveda was assigned to the Department
of the Interior Radio Technical Service Center as Manager, assuming
oversight responsibility for the Department's radio technical services
and support. The Department has approximately 2,000 radio systems and
some 25,000 users located in approximately 2,400 locations across the
United States, Puerto Rico, U.S. territories, and Native American
Lands. He has nearly thirty years experience in the field of radio
communications and information technology, including nine years of
which are with the Department of the Interior.
As the Technical Service Center Manager, Mr. Sveda is responsible
for providing leadership and technical advice to the Office of the
Chief Information Officer for the Department and the subordinate
bureaus on the effective use of radio technology and providing
technical support. Mr. Sveda is focused on radio infrastructure
modernization and ensuring that investments in radio are cost
effective, scalable, interoperable and aligned to DOI's mission and
strategic direction. In doing so, radio equipment and their compliance
to the agency adopted Project 25 standard are a key concern. Mr. Sveda
has established a formal testing program for radio products to assure
that those used by the Department meet the mission and user
requirements.
Before accepting this position, Mr. Sveda served as the Radio
Program Manager at the Bureau of Land Management, a bureau within the
Department, where he provided leadership for and technical expertise in
radio, as well as, policy development and project management for
several key radio initiatives.
Prior to his assignments in the Department of the Interior, between
1981 and 2001, he served as an Electronics Maintenance Officer in the
United States Marine Corps. His last three years in the Marine Corps
were devoted to developing and maintaining the radio communications
systems and dispatch centers for the Marine Corp Bases in California.
Mr. Sveda provided technical leadership and field support to military
training, law enforcement, fire, and logistical support organizations
within these bases. He further developed radio interoperability
solutions and techniques with local city, county, state and federal
organizations, as well as local amateur radio organizations, to improve
joint response to incidents. The previous 17 years involved designing
and supporting tactical radio, telephone, computer, radar, and weather
systems for various combat operations. During this period, Mr. Sveda
was also involved in defining test methods and conducting lab and field
testing of various communications and electronics equipment.
Mr. Sveda is a graduate of McDowell High School in Erie,
Pennsylvania where he specialized in electronics and has held or holds
various certifications related to Radio, IT Service Management, and
Project Management.
Chairman Wu. Thank you very much, Mr. Sveda.
I have been advised that the proceedings on the Floor are
such that we expect perhaps five or six votes coming up in just
a little bit, and these votes will take about an hour, so it is
my intention to get through one, perhaps two rounds of
questions, and if there are any remaining questions, the staff
will submit them to the witnesses in writing, and with that,
the Chair recognizes himself for five minutes.
These hearings have been focused on the progress of
standards development for P25, and I am especially interested
in the lack of standards or the lack of progress across the
suite of standards, the impact on safety and on price, on
safety and competition. I would like to encourage the witnesses
to go across the board and address how the slow pace of
standards development has affected competition and price on the
one hand and the safety of equipment stemming from lack of
interoperability on the other.
Mr. Sorley. Tom Sorley. I guess I will start. We just
completed in October of 2008 a very lengthy procurement process
for our $100 million plus system, and even though I spent
months out canvassing vendors and trying to get interest into
our process, we ultimately ended up with two manufacturers
making an offering. They happened to be the two largest in the
state. That could be because the size and complexity of the
procurement. I understand that. But it was a little
disheartening that we couldn't have at least three or more. So
I think it has a big impact on competition, the fact that we--
--
Chairman Wu. And this is for all the different components
of the system?
Mr. Sorley. All the different components. It was a large--
you know, it is a soup-to-nuts radio system.
Chairman Wu. Right. And it was not two vendors for each
individual component, this is two total, the whole suite of
components?
Mr. Sorley. Correct. And I think that, had the standard
been more fully developed, we could have had more vendors come
in and give proposals. Many elements are still proprietary in a
system as large as mine, and it is just too much risk for the
other vendors to come in.
Chairman Wu. Mr. Sorley, what is the impact of some of that
proprietary technology on someone like you who may be acquiring
further equipment which may be interoperable or not
interoperable with that proprietary technology?
Mr. Sorley. Let me give you an example. There is a vendor
that offers a very low-cost encryption algorithm--sometimes
they give it away for free--that is proprietary, and if you as
an agency or a system owner go with that technology, then
anyone else that wants to buy radios and join your system, if
they want to talk to your people, guess what? They have to buy
from that manufacturer. I was talking to a gentleman in Boise,
Idaho, last week who has this exact situation. I was suggesting
that because of the number of vendors out there for mobile and
portable radios they ought to go do a competition for the
price. He said, well, we can't do that because we have to talk
to everyone else and they all have this encryption. That is
just one example. There are a lot of examples like that.
Chairman Wu. So if the encryption is not supported across
the board, then there is no competition for further sales?
Mr. Sorley. Correct.
Chairman Wu. And one surmises that when you are trapped,
then the vendor might be able to achieve a slightly higher
price for future sales.
Mr. Sorley. So let me just illustrate that. In my
competitive process, I am buying the radio that he wanted to
buy. I am buying it for around $3,000. He is going to have to
buy it for around $5,500. That is just an example.
Chairman Wu. Yes, quite a premium.
Ms. O'Hara, it is my impression that Zetron, at least in
certain instances, has been precluded from competing in the
console business. Is that correct?
Ms. O'Hara. Yes, sir. Whenever there is a network vendor
that doesn't provide either the standard interface to our
consoles or perhaps they might offer a proprietary interface
that we then have to go do development work for, it means that
either we cannot or it is a pretty onerous burden for us to
provide a console on that system. So in many cases customers
just go with a vendor that is providing the network and their
proprietary interface, and if today they decide to do that
because that vendor doesn't have the standards interface and
later on down the road they decide they have another operation
and they would like to use our consoles, even if the vendor has
at that point developed the CSSI, it may not--they may be
locked in because of the network that they have already
purchased, sort of like Mr. Sorley mentioned.
Chairman Wu. And pricing is a function of whether you are
locked in or not?
Ms. O'Hara. That is correct, pricing and features, feature
capabilities which we may be able to offer, and there are
customers who come to us who know our systems and like what we
do who say I have no option, and some have delayed their
purchases as a result of that.
Chairman Wu. If you want that particular feature, it may
not be available from a competing vendor?
Ms. O'Hara. That is correct.
Chairman Wu. Mr. Sorley.
Mr. Sorley. If I may amplify that, we are in exactly that
situation. Our radio system--we could not buy their consoles.
The console system interfaces with something called fire
station alerting, and the consoles that we have to buy because
they are proprietary do not have this interface that we need.
Their consoles do, but I can't buy them because our vendor
doesn't support CSSI.
Chairman Wu. Thank you.
My five minutes has expired, so let me recognize Ms.
Biggert, and if we have time, we might go another round of
questions. Ms. Biggert, please proceed.
Ms. Biggert. Thank you, Mr. Chairman.
This question is for all of you. Let us suppose that a
vendor sold P25 equipment that was proven for interoperability,
compliance and conformance. If that was the case, wouldn't all
the public safety agencies want to purchase that equipment,
thereby advancing that company to the top of the competition?
How do we design a voluntary standards process that drives
innovation and competition? Ms. O'Hara, you seem to be smiling.
Ms. O'Hara. So let me understand. So your question is, if a
company does provide that standards interface they are going to
be preferred? And I think that is true. I think the other
aspect of your question, which is interesting, is whether the
standard covers all of the capabilities and features that a
customer may want, and there may be customers who decide that
they want a proprietary feature and that is their right and
their ability to do that. They just need to understand that
unless that vendor offers that proprietary feature or a license
for that feature to other, say, console manufacturers, they
will be locked in in the future. I don't believe that it is
right to tell customers not to buy features, but to Mr.
Sorley's point, they really need to be well educated on the
impact of buying a proprietary feature, and if they can have
influence on the vendor that is providing that feature to
influence them to offer that capability or interface to other
vendors, that would be an ideal situation, I think.
Ms. Biggert. Would anybody else like to address that? Mr.
Ingram.
Mr. Ingram. I would just like to add to that point. First
of all, in my testimony I talked about ARINC as an integrator.
ARINC is not a product manufacturer. We don't have a dog in the
fight. We work with everyone. And our point here is to build
the best solution possible to address the customer needs. But
oftentimes we do find that some of these proprietary features
preclude us from selecting the best product available, and that
is something that is systemic at the core of the system and
then out to the edges of the system, the radio units
themselves, the networks, all the devices. We find that the
manufacturers that we work with typically--it is very important
for them to be as interoperable as possible, right, because
they don't build end-to-end solutions so they have to work with
everyone, so there is a very organic sort of relationship
between the product manufacturers that we work, ARINC and our
customers.
Chairman Wu. Let us be very clear about that. They want to
fit onto someone else's, but if they get something special, if
they can keep that to themselves, then it is to their business
advantage to be able to do that.
Mr. Ingram. It is to their business advantage to build the
best product or best component possible, so I will use Zetron
as an example. They conform to the CSSI standard. They are
capable of interfacing to any public safety network, P25
network, that is available. It is to their advantage to be able
to integrate with any system, as many systems as possible. So
we view this objectively. We view this almost from a customer's
perspective. The technology is not the hurdle. It is really the
standard. And I want to make it very clear. The completion of
the standard isn't absolutely necessary. The standards are
developed in stages, right, so you can have a version of a
standard, version 1, version 1A, version 2, version 3, and
those standards can be released in ways that manufacturers----
Ms. Biggert. You talked about being released in
manageable----
Mr. Ingram. In manageable phases.
Ms. Biggert. What do you mean by that?
Mr. Ingram. Well, there are standards out there like ISSI,
CSSI and other very important standards that we are waiting for
as the industry, the market is waiting for the full completion
of the standard, but it is not absolutely necessary. The
standards could be released in phases so product manufacturers
know, okay, I can build up until that point, right, I can
invest and build up to that point and delivery technology to
meet up to that certain point within the standard, and as time
goes on, that component within the standard will evolve to
include other features of functions or capabilities. So we
don't have to wait until the end, and I think that has been
part of the problem with the delay or how long this process has
taken with P25. We don't have to wait until the end. We can
release the standard in manageable phases so manufacturers can
build technologies, and the point is that the customers who are
receiving that technology won't--that standard will still be
compliant as it is upgraded so it won't lock them out or lock
them in to any particular technology.
Ms. Biggert. Thank you.
I yield back.
Chairman Wu. The gentlelady's time has expired.
This standard-setting process has been extraordinarily
slow, and I would like to invite this panel to speculate as to
the causes for the slow process and what the impact of this
slow process has been on competition, price and safety. Mr.
Sveda?
Mr. Sveda. Yes. Thank you. I would like to speak first to
the success of the process, in particular in that since our
testing since 2002 that today with the Common Air Interface
standard published completely, that there is significant
competition. The competition has creased significant price
reductions or variations so the competition piece has worked
now that the Common Air Interface standard has been published
and manufacturers are building to it.
Chairman Wu. That is for that piece?
Mr. Sveda. That piece. Now, when you get to the system
pieces where we are talking the ISSI and things like that,
there is where the challenges are. But I wanted to point out a
success that the system does provide or the process has
provided us if we could just now speed it up, I guess. Thank
you.
Chairman Wu. Mr. Sorley.
Mr. Sorley. I would like to comment, or speculate, as you
said, on the possible cause. I think there are a couple of
things. One, public safety attempted to drive the standard, and
because of the funding for travel and all kinds of other
things, public safety's participation has not been as
consistent as maybe it could have been or perhaps even should
have been so I think that is partly a contributing factor. The
other contributing factor is, this marketplace is very small
and it is dominated mostly by two or three vendors who happen
to have most of the imbedded business on proprietary systems.
Chairman Wu. What is the market share, Mr. Sorley?
Mr. Sorley. I am sorry?
Chairman Wu. Any idea what the market share is of the two
or three leading providers?
Mr. Sorley. I would say between three of them they have
over 80 percent of the market. And so what motivates----
Chairman Wu. Let me pause you just for a second here.
Ms. O'Hara, in the console business that you are competing
in, for that line of work you said you could compete for three
but not for four of the vendors. What share of the market do
those four vendors that----
Ms. O'Hara. About the same that----
Chairman Wu. About the same?
Ms. O'Hara. Yes.
Chairman Wu. Seventy plus?
Ms. O'Hara. Yes.
Chairman Wu. Thank you.
Please proceed, Mr. Sorley.
Mr. Sorley. So my point to that was that basically we are
asking people to cooperatively work together to develop a
standard that negatively impacts their business.
Chairman Wu. Because once it is interoperable, then it is a
commodity product and prices come down?
Mr. Sorley. Yes. You have new entrants into the market and
you have lower prices. That is what the goal is, and so if that
is the goal, why would I want that?
Chairman Wu. Mr. Sorley, let me ask you this. I have been
told equipment with a P25 sticker on it is actually sold for a
premium. Can you explain that to me?
Mr. Sorley. No, sir, I can't.
Chairman Wu. Is it that it is allegedly P25-compliant but
once you are into it, you are supposed to buy P25-compliant
equipment. The sticker says so, so that is what the federal
appropriations permits you to buy?
Mr. Sorley. Yes, sir. Current grant guidance does call for,
or in effect mandates, P25 equipment.
Chairman Wu. So you can actually charge more for P25-
compliant equipment that may not be interoperable?
Mr. Sorley. I am not sure if that is the case. I do know
that with digital radio and the evolution of radio, there is a
whole lot more in the box than, say, conventional analog radio.
So inherently it is going to be higher cost. You know, there
are many elements, technical elements in there that have to be
there to guarantee the performance.
Chairman Wu. But if it says P25, it is supposed to be
interoperable?
Mr. Sorley. Yes, sir.
Chairman Wu. Does anyone know if the grant guidance says
that you have to buy P25-compliant equipment and then you have
this equipment that has a P25 sticker on it? At what point does
it arise to fraud, to fraud on the government that this
allegedly compliant equipment is not compliant?
Ms. O'Hara. Well, I will clarify that the interoperability
grant funding today only applies to the Phase 1 Common Air
Interface, and indeed today, as I mentioned in my testimony,
there are many vendors that provide those radios and they do
work on the network vendor systems, all of the systems, and
that is where we have talked about is a success.
Chairman Wu. On the voice. Yes.
Ms. O'Hara. And where it is not--interoperability funding
is not dependent on P25 on the system side, and that is the
second recommendation I made is, let us apply that across the
board, not just on the radio interface.
Chairman Wu. And Ms. O'Hara, one of your recommendations is
that if the standards process does not move forward, that
federal funding be withheld for any equipment that is not
compliant?
Ms. O'Hara. Yes. Basically I am just saying let us apply
that same logic that was very successful on the CAI side to the
wireline interfaces as well.
Chairman Wu. Thank you all very, very much. I am told that
we are down to just a couple of hundred folks not having voted
on the Floor, so I am going to have to get over there to
perform my Floor voting duties, and I want to thank you all for
appearing before the Subcommittee this afternoon.
The record will remain open for two weeks for additional
statements and additions to the record and witnesses to answer
questions that the Committee may ask. The witnesses are
excused. Thank you all very, very much for being here this
afternoon.
[Whereupon, at 2:50 p.m., the Subcommittee was adjourned.]
Appendix:
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Additional Material for the Record
Letters to Chairman David Wu and Representative Adrian Smith from John
Suzuki, Senior Vice President of Sales, EF Technologies, Inc., dated
September 22, 2010