1. Support legislation that will (1) allocate an additional 10 MHz of spectrum in the 700 MHz band (D-Block) to public safety and (2) provide funding to build and maintain a nationwide interoperable public safety broadband network.
Allocation of the D-Block spectrum to public safety, along with funding to build and maintain a nationwide 4G public safety communications network is critical to first responders. Such a framework will provide the speed and capacity needed to transmit mission critical real-time high-resolution video, voice and data. Unless Congress passes legislation to allocate the D-Block spectrum to public safety this year, the Federal Communications Commission will be required to auction this spectrum to the highest bidder. The public safety community, as a series of taxpayer supported enterprises, lacks the funding necessary to bid for this spectrum on an open market.
2. Support legislation that will provide federal funding for public safety research toward the development of new open-source broadband communications technologies, devices and applications.
A federally funded research and development program in partnership with private manufacturers will provide the impetus to propel public safety communications technology to new levels of efficiency and capability.
The convergence of telecommunications technology with information technology will change the way public safety is able to communicate today and for years to come. To make sure every community across the country is able to benefit from this ongoing technological revolution, the federal government must invest in research and development programs that foster greater competition and reduced prices for public safety communications equipment and applications. Such investment must include the expedited development of open-source 4G broadband equipment and applications that are able to provide peer-to-peer and one-to-many, mission-critical voice capabilities that can augment, and if need be, replace existing land mobile radio (LMR) systems.
By developing open-source and non-proprietary devices, the cost of purchasing communications equipment will be greatly reduced. Local police, fire and emergency medical services agencies are currently experiencing budget reductions, which will likely hamper their procurement capabilities for some time. These cuts make it nearly impossible for first responders to acquire the devices they desperately need. With readily available technologies, these same agencies may once again be able to afford the equipment needed to save lives and property.
Now is the time for our nation to invest in new technologies that will enhance voice communication and provide our first responders with superior equipment to perform the tasks that protect our nation each and every day. This small investment by the federal government will also allow new and innovative companies to enter the public safety communications marketplace, thereby increasing competition, and creating new high-tech jobs.
3. Support full funding for the Interoperable Emergency Communications Grant Program (IECGP) with explicit funding mechanisms to allow for public safety broadband deployment.
APCO International strongly supports Title III of the Implementing Recommendations of the 9/11 Commission Act of 2007 (P.L. 110-53) that established a $1.6 billion ($400 million annually for 4 years) Interoperable Emergency Communications Grant Program (IECGP) administered through the Federal Emergency Management Agency (FEMA). One of APCO's top priorities is to work with the Administration and Congress to ensure this grant program is fully funded.
Since its establishment, this grant program has been grossly underfunded at $50 million dollars annually. While many communities have benefited from the grant program, the goal of the program - to advance interoperable communications - cannot be achieved without full funding.
In addition, Congress should also ensure that state and local governments are able to use the funds to build 4G wireless broadband networks in the 700 MHz band. The $400 million that is authorized for the grant program will go a long way in assisting early deployments across the country.
4. Support legislation that will authorize the use of existing federal grant programs for local, state and Tribal public safety agencies or other government entities to support building and maintenance of a nationwide public safety broadband network.
State and local governments should be able to use current federal grant programs such as the State Homeland Security Program (SHSP), the Urban Area Security Initiative Grant Program (UASI), the Metropolitan Medical Response System (MMRS), Emergency Management Performance Grants (EMPG), the Regional Catastrophic Preparedness Grant Program (RCPGP), the Community Oriented Policing Services (COPS) Technology, the Department of Justice's State, Local, and Tribal Terrorism Prevention Training and Technical Assistance National Initiative Program, or the Justice Assistance Grant (JAG) Program to assist in building public safety wireless broadband networks.
Congress should also fully fund all authorized grant programs established to help local and state public safety agencies improve their operable and interoperable communications infrastructure. Without adequate federal funding for extensive upgrades to emergency communications systems, local public safety agencies will face daunting challenges in improving their systems.
With increasing threats to our nation due to climate change, natural disasters, and terrorism, our local communities need help from the federal government more than ever.
Today, many local communities facing considerable economic hardships do not have the resources needed to ensure their emergency communications systems are able to survive and sustain operations before, during and after a natural or manmade disaster. These communities need the help of the federal government in ensuring their emergency communications are capable of survivability, sustainability and interoperability.
Federal funding for state and local government infrastructure can help achieve greater operational efficiencies and effectiveness by improving situational awareness, establishing a common operating picture, and providing force multipliers at a time when staffing and personnel budgets are shrinking.
5. Support legislation that will authorize the use of existing federal grants for local, state and Tribal public safety agencies or other government entities to expedite the migration of public safety systems to narrowband operations prior to the currently mandated January 2013 deadline.
There are approximately 79,000 public safety licensees operating on frequencies between 150-512 MHz that have not converted from wideband (25 KHz channels) operations to narrowband (12.5 kHz bandwidth or to a technology that provides one voice path per 12.5 kHz of bandwidth or provides a data rate of 4800 bps/6.25 kHz) operations. If these licensees do not comply with the narrowbanding deadline of January 1, 2013, they will be in jeopardy of losing their license to operate their LMR communications. This is simply not acceptable for public safety communications.
Congress must take immediate action to authorize the use of existing federal grant programs such as the State Homeland Security Program (SHSP), the Urban Area Security Initiative Grant Program (UASI), the Metropolitan Medical Response System (MMRS), Emergency Management Performance Grants (EMPG), the Regional Catastrophic Preparedness Grant Program (RCPGP), the Community Oriented Policing Services (COPS) Technology, Department of Justice's State, Local, and Tribal Terrorism Prevention Training and Technical Assistance National Initiative Program, or the Justice Assistance Grant (JAG) Program to expedite the migration of wideband equipment to narrowband equipment.
6. Support legislation to authorize the use of federal grant programs to deploy next generation 9-1-1 networks where funding will be used specifically by Public Safety Answering Points (PSAP's) to receive inputs of video, data, text and voice from individuals that contact 9-1-1. Funding will be divided equally for the output (i.e. dispatching) of video, data, voice communications and information to public safety and first responders in the field.
Public safety agencies across the country have started the process of transitioning from the current 9-1-1 system to broadband-enabled, next-generation 9-1-1 systems. These systems will provide public safety agencies greater flexibility in being able to receive 9-1-1 data from various sources. In the future, the potential exists for these same next-generation 9-1-1 systems to transmit critical voice, video, and data to first responders in the field, which would help mitigate the severity of certain emergencies. However, a nationwide transition to a next generation 9-1-1 network and computer aided dispatch systems will require considerable investment by local and State governments. Public safety agencies will also need to be eligible to receive federal grants to upgrade and purchase new equipment.
While some federal grants can and are being used to upgrade 9-1-1 systems, Congress should make 9-1-1 funding a priority for existing grant programs, such as the State Homeland Security Program (SHSP), the Urban Area Security Initiative Grant Program (UASI), the Community Oriented Policing Services (COPS) Technology, the Department of Justice's State, Local, and Tribal Terrorism Prevention Training and Technical Assistance National Initiative Program, and the Justice Assistance Grant (JAG) Program.
As consumer technology evolves, it places a considerable burden on our nation's 9-1-1 infrastructure to keep pace with technological innovation. Consumers' expectations regarding the capabilities of the current 9-1-1 system far outpace the technological capacity of many state and local PSAPs. Only a handful of public safety answering points have the ability - highly limited as it is - to receive a text message from an individual in an emergency situation. Without direct Federal assistance, many of our country's most vulnerable communities will be hard pressed to make the necessary financial investment to transition to next generation 9-1-1 networks.
7. Support legislation and regulations that place strong cyber-security requirements on wired and wireless broadband networks providing services to public safety agencies.
Public safety agencies increasingly rely on internet applications to receive and transmit data in order to mitigate emergency incidents; however, there is a growing danger that such reliance could place public safety communications systems and 9-1-1 services at risk from cyber attacks. Recent trends in cyber attacks on commercial and government networks clearly demonstrate that such unprotected systems will put public safety communications at risk and may cause network outages during emergency incidents.
The FCC's National Broadband Plan (NBP) states that "the country needs a clear strategy for securing the vital communications networks upon which critical infrastructure and public safety communications rely." APCO International's members concur with the FCC's proposal and believe that such a strategy must ensure that the security of our nation's public safety communications infrastructure is not put at risk from malicious cyber attacks.
8. Support legislation and regulations that require redundancy, reliability and survivability for commercial broadband networks (as defined by public safety users) providing services to public safety agencies.
Public safety communications systems are designed and built to operate to "six-nines" (99.9999% availability which is equal to 31.5 seconds downtime per year, 2.59 seconds downtime per month, and 0.605 seconds downtime per week). In order to meet the six-nines standards, public safety systems are required to have considerable backup power, redundant systems and a high level of security to ensure that they are capable of surviving all hazards. If a public safety agency relies on a private carrier to provide its mission critical broadband services, the carrier should be required to meet the six-nines of network availability in their geographic service area, and must be able to provide sufficient backup and redundant network operations to ensure any scheduled or unscheduled outage does not impact incident management.
APCO International's members are concerned about a 2009 ruling handed down by the DC Circuit Court, vacating an FCC rule that mandated backup power for commercial services. The rule was successfully challenged by both commercial wireless carriers and interest groups. This ruling calls into question the FCC's overall ability to place additional regulations on commercial carriers that support mission critical public safety broadband operations. Unless this issue is resolved quickly, public safety agencies will continue to rely on dedicated networks for their mission critical communications needs.
9. Support legislation and regulations that require location and callback information on all phones that are part of a Private Branch Exchange (PBX) system.
Private Branch Exchanges (PBX) must be able to provide accurate location and callback information for any phone that is linked to the system. This information should include the address where the phone is located and if it is necessary, the floor and suite number of the office or room. Conditions should also be placed on companies that sell these systems requiring them to educate their customers about the 9-1-1 features of the PBX equipment.
While some states have passed laws and regulations that require callback and location information, there is still considerable disparity among states regarding how best to regulate PBX systems. Since some PBX systems also operate across state lines, the FCC - under the Commerce Clause - should examine potential regulations for these systems to ensure that the public's safety is not put at risk.
10. Support legislation and regulations that require non-initialized mobile phones to provide location and callback information when used to call 9-1-1.
Public safety answering points are being inundated by an increasing number of malicious calls being made to 9-1-1 from non-initialized phones that cannot be traced since they are not connected to any service provider and therefore do not provide public safety with automatic number identification (ANI) and callback features. These malicious calls are capable not only of clogging up community 9-1-1 systems, but can also put at risk the lives of individuals experiencing a legitimate 9-1-1 emergency.
In 2006, PSAPs in Tennessee reported more than 10,000 fraudulent 9-1-1 calls from non-initialized phones in a period of three months. In Florida, several PSAPs reported about 8400 fraudulent calls from such phones in just one month.
The FCC should quickly act to set new regulations and guidelines that will help local public safety agencies combat the rise of malicious 9-1-1 calls from non-initialized phones.
11. Oppose any legislation and/or regulation that would either mandate reallocation of the 700 MHz narrowband spectrum or that would authorize "flexibility" in the band until broadband networks are established to provide coverage and reliability comparable to, if not better than, current public safety narrowband networks.
Flexible use of the 700 MHz narrowband channels is not a viable option for meeting the spectrum needs of public safety agencies when deploying a nationwide 20 MHz LTE broadband network. Any regulation that would allow such use would cause interference with current mobile radio communications systems operating in, or being deployed in, the narrowband spectrum. Such interference could put the lives of first responders at risk. Public safety agencies across the country have spent billions of dollars deploying 700 MHz narrowband radio systems to meet their current voice communications needs and these systems will be in operation for the foreseeable future (10 - 20 years).
While broadband offers many advantages for public safety, it is not yet capable of replacing current mission critical voice communications. Before Congress and the FCC takes any action that puts current communications systems at risk by allowing flexible use on 700 MHz narrowband channels, a thorough examination of the impact on existing and future public safety broadband networks must be completed.
Instead of looking to establish arbitrary rules for flexible use of the narrowband spectrum, the FCC should develop a viable migration plan that promotes a parallel track upon which future broadband voice communications systems can be used to augment existing narrowband operations; until such time when broadband systems can replace narrowband technologies.
12. Support legislative and regulatory efforts (i.e., Emergency Response Interoperability Center) that look to foster greater cooperation and partnership among local, State, Tribal, and federal agencies while developing programs that promote public safety communications operability and interoperability.
APCO International's members strongly believe that our federal partners can do more to assist our nation's public safety agencies in their efforts to improve their communications systems. APCO International is strongly committed to working with all federal agencies to improve coordination and cooperation.
APCO International is encouraged by the Federal Communications Commission's recent steps to establish the Emergency Response Interoperability Center (ERIC) and its members are committed making sure that this program will have the resources needed to fulfill its charter.
APCO International's members are also committed to working with the Department of Homeland Security's Office of Emergency Communications to ensure that the goals of the National Emergency Communications Plan (NECP) are achieved and that these goals work in concert with efforts to be undertaken through ERIC.
13. Advance APCO International 's position as the leading accredited standards setting organization in public safety communications and ensure federal efforts to establish technical and operational standards in public safety communications are vetted through the American National Standards Institutes process.
APCO International intends to work closely with the Office of Science and Technology Programs (OSTP), the Department of Commerce's National Institute of Standards and Technology (NIST), the Department of Justice's National Institute of Justice (NIJ), and the Department of Homeland Security's Office of Science and Technology (S&T) as well as other standards setting bodies to develop the technical and operational standards for the nationwide public safety broadband network. APCO International's members strongly believe that all technical and operational standards, which are developed for the public safety broadband network, must go through the American National Standards Institute's (ANSI) certified process.
14. Support legislative and regulatory efforts aimed at combating illegal use of mobile phones in prisons, to ensure that these unauthorized communications do not interfere with public safety land mobile radio communications systems and 9-1-1 calls.
APCO International's members recognize that the problem of mobile phones being smuggled into correctional facilities and used to conduct and direct illegal activities (in some cases allegedly involving murder) continues to grow. To combat this difficulty, some companies have developed radio frequency jamming equipment and have marketed that equipment to correctional facilities. However, the use of this equipment is illegal in the US (except by the federal government in certain situations) and the Federal Communications Commission (FCC) has determined that it cannot grant an experimental authorization for its use.
As consideration is given to provisions that might address how radio frequency jamming equipment may be deployed in correctional facilities in the United States, APCO International strongly urges Congress and the FCC to require that vendors of such devices demonstrate that use of such equipment will have no harmful impact on public safety radio systems.
APCO International strongly recommends that prior to any deployment of radio frequency jamming devices in correctional facilities, the administrators of these facilities provide a detailed accounting of what actions they are taking to prevent the smuggling of contraband mobile phones into the facility and the procedures that are employed by the institution to locate and confiscate them from prisoners.
APCO International also recommends that the Director of the Federal Bureau of Prisons or the chief executive officer of a State work with the FCC to determine if other technical solutions such as call blocking by carriers at the network level through the use of micro-cells in correctional facilities, and/or legitimacy verification (white listing) of mobile phones in the vicinity, can be deployed in lieu of radio frequency jamming equipment.
APCO International's members believe that while allowing radio frequency jamming equipment in correctional facilities may seem like a viable solution to combating the use of contraband mobile phones by prisoners, there is considerable risk of interference with public safety mobile radio systems. The solution to this problem should not put our first responders at risk. All other options should be considered before allowing the use of radio frequency jamming equipment.
