The end of Airwave and the truth about TETRA and LTE for UK emergency services (Act 3)
ESMCP/ESN: Optimism bias or something more sinister – there must be a better way
During the first two Acts of this tragedy describing “the End of Airwave”, the author has laid out the case for maintaining the nationwide public safety TETRA network. I have also pointed out a number of reasons for being concerned about the likely negative outcomes of the ESMCP/ESN process being carried out by the UK Government, led by the Home Office with the Cabinet Office and HM Treasury playing a key role in the background by emphasizing the need for costs to be kept strictly under control. However, why should the reader trust the author’s opinion & version of events versus a national Government with access to the best possible advice?
Let us take a look at the UK Government’s own methodology for large public procurements to see if we can find serious contradictions in their own arguments which would invalidate or at least seriously undermine ESMCP and require an urgent, high-level review to see if any alternative approaches can be found which will deliver better results for emergency services users and provide better protection for the public, when disaster strikes, as sadly we know it will at some indeterminate time in the future.
The Israeli-American psychologist, Daniel Kahneman, was awarded the Nobel Prize in Economics in 2002 for work he carried out with his colleague, Amos Tversky, into human decision making, for identifying an optimism bias at the heart of many human projects, particularly large-scale government projects. Time after time, managers underestimate the true cost of delivering these projects; think they can complete them in less time than is actually necessary; fail to identify the full extent of the risks involved and tend to exaggerate their benefits.
Such wise, common sense, but seemingly radical findings by Kahneman and his fellow researchers were quickly seized upon by progressive Governments trying to manage large, complex, risky infrastructure projects. HM Treasury’s own “Green Book” published in 2003 recognizes the work undertaken by Kahneman in the following quote:
“There is a demonstrated, systematic tendency for project appraisers to be overly optimistic. To redress this tendency appraisers should make explicit, empirically based adjustments to the estimates of a project’s costs, benefits and duration…[It] is recommended that these adjustments be based on data from past projects or similar projects elsewhere.” (p.1).
The Danish economist, Bent Flyvbjerg, the founding director of Oxford University’s BT Centre for Major Programme Management, has extended Kahneman’s studies on optimism bias - which is modelled as a fairly innocent consequence of human evolution - to another related category – strategic misrepresentation – which also leads to inaccurate forecasts but is caused by intentional deception from participants, both managers and suppliers, when there are strong political and organizational pressures driving a process.
Flyvbjerg’s solution to this Planning Fallacy is a method classified as Reference Class Forecasting, where the most likely outcome of a specific project, i.e. ESMCP, is predicted by analysing as large a number of projects as possible in a similar class already executed in the past and adjusting the current process based on the observed results of these projects. This procedure allows an “outside view” of the project which is likely to be subject to less bias than the “inside view” of a project team focused on a single, highly uncertain and risky project. The UK Government has indicated that it has used Reference Class Forecasting for the Airwave replacement process. Of course, within this very process, there is the danger that optimism bias and strategic representation might be at work in the selection of “similar projects” that justify the very result that the Government is trying to engineer. So let us provide them with some information of our own to help them.
To begin our evaluation of the likely success or failure of ESMCP/ESN, let us take a look at the current arguments regarding the use of commercial mobile networks by emergency services for mission-critical voice and data and whether they should be awarded dedicated, or at least harmonised spectrum to fulfil their duties. I remind the reader that the current position of the UK Government is that commercial mobile network operators will provide service to public safety users using existing LTE networks being built out across the UK, and that no new spectrum is to be set aside for emergency services.
SCF Associates undertook a study for the European Commission on the “use of commercial mobile networks and equipment for mission-critical high-speed broadband communications in specific sectors” which was published in late 2014. This study highlighted a number of conditions (5 to be precise) that would need to be met before commercial networks could be chosen: truly enforceable regulation; the hardening of networks to achieve 99.999% availability – at a reasonable price – for all 3 main sectors (public safety, transportation and utilities) – potentially modifying the legal framework in a number of European states that currently refuse to allow private companies to provide such mission-critical services for clear reasons of national security.
Recent terrorist attacks in Europe and the increasing threat of damage to life and property by natural disasters is focusing minds across Europe, making ESMCP look more and more like an outlier, rather than a trend-setter.
In the case for dedicated or harmonised spectrum for PPDR (Public Protection and Disaster Relief), considerable work has been carried out at the European level and globally ahead of the World Radiocommunication Conference 2015 (WRC-15) being held in Geneva in November. ECC Report 199 has recommended at least 2 x 10 MHz of spectrum at 700 MHz if possible, or at 450 MHz at a national level if 700 MHz is unavailable. ECC Report 218 focuses on 5 different, compatible and complementary options for administrations in the 700 MHz band to be opened up for mobile broadband after WRC-15. There have been studies carried out by the London School of Economics on behalf of TETRA + Critical Communications Association that demonstrate the considerable social value that would be generated in the UK and across Europe by assigning frequencies to emergency services in 700 MHz, which, of course, would be lost forever if the UK Government follows its current course.
Next, let us briefly compare the UK Government’s approach with other countries’ plans for emergency services communications:
After several years of deliberations and active lobbying by emergency services representatives, the United States government passed an Act in 2012 setting up the First Responder Network Authority (FirstNet) to develop a nationwide public safety LTE network with dedicated spectrum (2x10 MHz) in Band 14 (700 MHz) with an allocation of $US 7 billion paid for from the receipts of the recent AWS-3 auctions. The whole process appears to be taking longer than originally planned, showing how hard it is to deliver such a complex project and perhaps some signs of that dreaded optimism bias mentioned earlier. There are no plans in the foreseeable future to switch off existing P25 public safety networks, which will continue for mission-critical voice services until public safety users feel comfortable to trust their lives to the new network. Canada looks like following a similar frequency band plan to its southern neighbour, although the lack of similar funds could lead it down the path of a public-private partnership model.
Qatar Ministry of Interior has deployed an LTE network in 800 MHz solely for use by public safety and for high-speed non-mission-critical data. It will continue to use its TETRA network for mission-critical voice and data until such time as LTE is able to offer similar Quality of Service as TETRA, which it expects to take perhaps 10 more years. Early experience indicates considerable additional value for its users, even though the underlying technology itself has clearly not been designed for mission-critical operations and is currently not recommended for such use until the relevant standard bodies complete their work over the coming years.
Back in 2012, Australia’s regulatory authority, ACMA, was one of the first in the world to assign dedicated spectrum to public safety in 800 MHz, although the precise frequencies are still being debated. Australia’s No. 1 mobile operator, Telstra, has been conducting trials for public safety users using dynamic prioritisation and public safety-optimised devices over its LTE network with a service called LANES (LTE Advanced Network for Emergency Services) using a model which is perhaps the closest to ESMCP, although Telstra has also stated that it would be happy to combine its own spectrum with the dedicated spectrum awarded to public safety by ACMA to offer additional resources in times of emergency.
During late 2014, South Korea, one of the most advanced mobile communications markets on the planet, set aside 2 x 10 MHz of prime spectrum in the prized Band 28 700 MHz band for public safety use, recognizing the importance of dedicated spectrum for the delivery of key services to protect its society. This decision looks likely to generate significant interest from equipment suppliers based in South Korea and around the world, allowing interesting economies of scale that will benefit those countries who adopt similar decisions before or after WRC-15 decisions later this year.
Mexico has announced its intention to procure a single, nationwide public safety LTE network that is separate from commercial networks for sole use by emergency services, which could also benefit from the economies of scale mentioned in the previous paragraph. This is a model that is being looked at by other Latin American countries.
Huawei has deployed a number of pre-standards, professional eLTE networks in 1.4 GHz in China for use by public safety in large events such as 2013 Asian Youth Games in Nanjing, allowing authorities to have access to services that cannot be provided by narrowband technologies such as TETRA or PDT. However, there are no immediate plans by Chinese authorities to switch off existing TETRA and PDT networks and Huawei has signalled its intention to work closely with critical communications equipment suppliers to provide the best possible integrated solutions for users.
As I have mentioned in an earlier post, the majority of Western European countries have been refreshing and upgrading their TETRA networks recently to the most advanced IP-based versions of the standard in order to make sure they have at least another 10 years of service or perhaps more, while setting up MVNOs with commercial operators to trial additional data services for emergency services users. Police Unions in Germany and other nations have been actively coming out in support of additional resources for public safety communications in light of recent incidents in France, Belgium and Denmark; harmonised spectrum is now a clearly stated goal for many administrations across Europe. In fact, Germany and Norway are still in the process of building out nationwide TETRA networks that will not be switched off until 2030 at the earliest. Finally, let’s compare the current ESMCP to PSRCP (Public Safety Radio Communications Project), its predecessor in the 1990s:
Following a number of incidents during the late 1980s – the King’s Cross fire, the Hillsborough FA Cup tragedy and Bradford City stand fire - where the lack of interoperability between emergency services personnel was mentioned as contributing to poor outcomes, a decision was taken around 1993 to set up PSRCP. In 1996, the emerging TETRA standard – still unproven and not deployed anywhere in the world - was chosen as the technology in order to encourage its further development. It was also decided to go for one big nationwide deployment rather than regional ones. Due to its complexity and the enormous improvements in service which were expected from the new system, it took many more years to be fully implemented and ended up over budget with further delays before other services such as Fire and the Ambulance Service were incorporated years later.
The three original bidding consortia for PSRCP were reduced to a single monopoly bidder, Airwave – first BT Airwave and then O2 Airwave by the time the contract was signed in February 2000. The Fire Service declined to be included in the original procurement because of the high cost. The Private Finance Initiative (PFI) model chosen at the time had many critics because of the complexities of accurately pricing a specialised communications service that would evolve over time. Airwave’s pricing structure upon signature of the contract more than doubled the expenditure on mobile communications of the police at the time. Airwave failed to convince any other European country to follow a similar path reducing the potential future cost savings for the UK Government which was also unable to claw back significant future cost savings because of flaws in the contract design.
Initial PSRCP/Airwave trials carried out in Manchester in 2001 had patchy results, but following the September 11, 2001 attacks in New York and Washington D.C., the UK Government accelerated the deployment schedule which was completed in 2005; the Fire Service procurement procedures were modified to provide a nationwide TETRA deployment which was rolled out for 2007. The Ambulance Service and a large number of other Tier 1 and 2 services also joined the Airwave network. Airwave’s interesting ownership structure has already been described in Act 1. After over a decade of developments, Airwave had become the world’s premier nationwide TETRA network by the time of 2011 London Riots and 2012 London Olympic Games, well respected within the global critical communications community, although considerably more expensive than similar deployments.
We have now gathered quite a lot of evidence that suggests that the UK Government has fallen victim to its own form of Optimism Bias, or should that be Strategic Misrepresentation. Is it simple excessive optimism driven by a desire to provide better outcomes for the UK public that has led to this situation or is the impending disaster facing emergency services communications provision in the UK caused by the relentless drive by an ideologically-driven Government to reduce costs at all costs, thereby, as a consequence, short-changing the emergency services of this country?
The UK Government’s rush towards a new regime also means that it may not be able to take advantage of further technology advances that are likely to occur over the coming decade and beyond. These advances should allow narrowband, wideband and broadband solutions to be combined in order to take advantage of each one’s strong points (if the TETRA network is switched off prematurely this will not be an option in UK). Aggregating the spectrum allowances of other professional users such as transport & utilities could also open up new possibilities of greater operational efficiencies for emergency services achieving greater coverage and capacity than can realistically be provided by commercial operators. New economic & governance models will be developed. New business and value models are becoming possible in the digital economy that are leading to greater transparency & accountability at a local level for public services. New mobile operators and models are likely to become available, challenging the perennial dominance of existing mobile operators and bringing down costs for users even further.
The new group set up by 3GPP, SA6, to deal with public safety related matters in the global standardisation process has been put under extreme pressure by the tight schedule being forced through by the UK Government. There is the possibility that this could create tensions within SA6 as different suppliers and users have different priorities and are working to different timetables. Standardisation naturally takes time. Any delay that is introduced into the process during 2015 will inevitably mean that certain deadlines within contractual agreements between UK Government and winning ESN Lot bidders cannot be reached, leading to penalties, escalating costs, delays in the implementation of a solution for emergency services and increased dissatisfaction among these users as TETRA contracts come to an end and the service is discontinued.
Responsible Governments need to implement a sensible mix of short-term, medium-term and long-term projects. Public safety communications is a long term affair that needs to be managed with care. The full economic and social benefits of a secure, resilient critical communications infrastructure available to public safety, basic services, transport and utilities in a coordinated, planned manner accrue after a number of years, so Governments need to be careful when calculating the costs and benefits of socially-valuable projects employing exaggerated discount rates and unhealthy, unnecessary private gain.
We are trapped in an austerity mentality caused by a lack of ambition, a lack of trust of Government in the capabilities of a well-educated, highly motivated young workforce and a lack of understanding of what is really required to build a better future society. The privatisation mind-set where only economic value counts has been engraved into our consciousness by the ghosts of Governments past. We cannot organise ourselves collectively anymore. We can no longer deliver projects with enormous social value, with enormous rates of return to society far out in the future. Surely we can do better.
Now, at this precise moment in time in February 2015, when all the pros and cons of ESMCP/ESN are weighed up, it is surely not too late to take a step backwards, to take a close look at the facts and the most likely outcome of this process. We can keep the best of what we have today, while working collectively to build a better future. We can refresh our TETRA networks at a fraction of the cost of the original Airwave contract, while working purposefully and decisively towards the delivery of new broadband capabilities to our emergency services following the more sensible timetable of our colleagues from the rest of Europe and around the world. It is time to put an end to this madness and start a “common-sense revolution”.
Maybe I am suffering from my own form of optimism bias by believing that a political process in 21st century Britain can produce the optimal result. I hope not. I believe not.
So is the end of Airwave also the end of TETRA for the emergency services in the United Kingdom? A quote comes to mind from a previous, more illustrious incumbent of the office of Prime Minister, who warned the nation against complacency at a key turning point during the Second World War in 1942: “This is not the end; this is not even the beginning of the end; this is just perhaps the end of the beginning.”
