Position Statements

Index

APCO International Commends TSAG Report on NG9-1-1

The Association of Public-Safety Communications Officials (APCO) International endorses the architecture of Next Generation 9-1-1 as described by the National Emergency number Association (NENA) in the "Detailed Functional and Interface Standards for the NENA i3 Solution."

APCO supports the development and implementation of geospatial, policy based 9-1-1 call routing as described in the Emergency Call Routing Function and Emergency Service Routing Proxy within NENA i3. APCO understands that the i3 Stage 3 architecture is not yet a build-to specification and that development efforts will continue to evolve as has been the case with other complex, open standard communication's architectures. It is critical that the design of future NG 9-1-1 systems be based upon open standards that will allow for multimedia, non-voice emergency service capabilities.

APCO believes that the current method of static location validation via legacy MSAG and ALI databases must be replaced by more sophisticated concepts such as the Location Validation Function (LVF) and Location Information Server (LIS) functionality within the NENA i3 architecture. The move will be a great advantage to the public and to public safety. It is critical that NG9-1-1 location validation and location acquisition take into account the dynamic nature of mobile IP devices.

APCO is cognizant that regions may opt to consider transitional implementation of alternative IP based emergency communication systems such as described in the Alliance for Telecommunications Industry Solutions (ATIS) Request For Assistance Interface (RFAI) standard before they migrate to a fully featured NG9-1-1. (October 31, 2011). Back to top

H.R. 2629: Next Generation 9-1-1 Advancement Act of 2011

The Association of Public-Safety Communications Officials (APCO) International endorses the provisions of H.R. 2629 that focus Federal policies and funding programs to ensure a successful migration from the Public Switch Telephone Network (PSTN) 9-1-1 system to a robust IP-enabled emergency communications system that is able to receive and transmit voice, data, and video services to greatly enhance the capability of 9-1-1 and emergency services. APCO International believes that technological advances in 9-1-1 and emergency communications systems must be universally available and adequately funded to protect and serve all Americans.

APCO International believes that all public safety agencies, including Public Safety Answering Points (PSAPs), must have access to high-speed wireless and wireline broadband networks, priority access to interconnected IP backbones and secure and redundant services and applications.

APCO International believes the migration of PSAPs to IP enabled emergency communications systems should occur in conjunction with the build out of a nationwide public safety broadband network. This legislation, along with legislation to allocate the D Block and fund the nationwide broadband network, is critical to our nation's first responders. The full benefit of the Next Generation of 9-1-1 will not be fully realized without the ability to transmit the data, images and video that may be received during a 9-1-1 call to the emergency responders at the scene of an incident.

APCO International is cognizant that local, state and Federal public servants in the field, both sworn and civilian, generate emergency and preventative, non-emergency communications every day. These communications would be equally enhanced by their ability to access and utilize IP- and broadband communications devices, applications and networks for both mission-critical emergency communications and non-emergency communications, including both the receipt and transmission of texts, video, pictures and other forms of data.

APCO International believes that IP enabled emergency communications will revolutionize the way our public safety professionals respond to 9-1-1 calls, but this will only happen if advances and consumer expectations in 9-1-1 technology do not outpace the capabilities of our public safety agencies.

APCO International urges Congress to quickly move H.R. 2629 through the legislative process. Back to top

Operation of Low Power Auxiliary Stations Within the 700 MHz Band

APCO International strongly supports rules that would prohibit further operation of low power auxiliary stations within the 700 MHz band after February 17, 2009; and prohibit the manufacture, import, sale, offer for sale, or shipment of devices that operate as low power auxiliary stations in the 700 MHz band.

APCO International believes that there is a very real danger of interference from the low auxiliary devices to public safety land mobile radio systems.

APCO International believes there is a danger when wireless microphones are used for auxiliary broadcast operations at large group events it could interfere with first responders' 700 MHz public safety radios in the vicinity. Indeed, one can imagine an emergency at a public gathering where somebody uses a wireless microphone to direct an evacuation, not realizing that they are disrupting radio communications for first responders arriving on the scene.

APCO International is also very concerned with the substantial number of wireless microphones that are now being used in the 700 MHz band without proper FCC authorization.

APCO International urges the FCC to take aggressive steps to eliminate those nonconforming uses as quickly as possible. Back to top

National Emergency Communications Plan (NECP)

APCO International appreciates the hard work that was done by the Department of Homeland Security (DHS) Office of Emergency Communications (OEC) in developing the National Emergency Communications Plan.

APCO International believes the plan provides a good first step in identifying the goals and objectives that could become the building blocks to improving local, state, and federal interoperable communications.

APCO International believes the NECP must be flexible enough to accommodate special needs of local and state governments.

APCO International believes there has to be considerable outreach by the Department of Homeland Security Office of Emergency Communications (OEC) and other organizations to promote the NECP and educate local, state, and federal officials about the goals of the plan.

APCO International believes the plan should not create unreasonable expectations on public safety agencies or local governments that cannot be met. The plan should also provide adequate funding measures to ensure all local and state governments are able to contribute to the national goal of improving interoperable communications.

APCO International believes the OEC must take a lead role in cataloging current standards and working with nationally accredited standards setting organizations to provide a clear road map for local public safety agencies to follow. The OEC must be adequately funded so that it can provide the necessary resources to accelerate the development of technical and operational communications standards that are identified in the NECP.

APCO International's primary concern about the NECP is that the OEC may not have the necessary funding and resources to accomplish the objectives of the plan. APCO International believes that unless the NECP gets the full backing of Congress to appropriate the necessary funds the plan will not accomplish its goals.

ADOPTED BY THE APCO INTERNATIONAL BOARD OF OFFICERS SEPTEMBER 3, 2008. Back to top

The Warning, Alert and Response Network (WARN) Act

APCO International supports the Warning, Alert, and Response Network (WARN) Act (P.L. 109-347) that enables commercial mobile service alerting capability for commercial mobile service providers that voluntarily elect to transmit emergency alerts to subscribers.

APCO International supports standardized and well governed implementation of commercial mobile alerting services as required by the WARN Act.

APCO International believes that all emergency alerts by commercial mobile service providers must provide adequate information to manage the publics' concerns during a large scale incident. APCO International is concerned that inadequate information, which requires the thousands of subscribers to call a number to get additional information about an emergency, could result in a bottleneck of the telecommunications and 9-1-1 systems. APCO International does not support the use of call back numbers.

APCO International strongly believes that before commercial mobile service providers deploy alerting systems they should work with local, regional and state government authorities to ensure the information being transmitted is well communicated and coordinated with the appropriate public safety agencies including public safety communications centers who will have to respond to publics' inquiries about the emergencies.

APCO International believes that the alerting system boundary should be at the smallest geographic area that is technically possible, but at the very least the alerting system's geographic boundary should be a county within a state.

APCO International believes that such systems should have priority status to transmit alerts as long as this priority does not interfere with other emergency service transmissions using the commercial mobile service provider's networks.

APCO International believes that such systems should be able to transmit emergency alerts to subscribers in languages in addition to English, to the extent practicable and feasible.

APCO International strongly supports the provision in the WARN Act that requires a commercial mobile services provider that elects not to offer emergency alerting services to its subscribers to receive from the subscriber acknowledgement that service is not available.

ADOPTED BY THE APCO INTERNATIONAL BOARD OF OFFICERS DECEMBER 12, 2007. Back to top

APCO Petitions for Declaratory Ruling on Wireless Location Accuracy

WHEREAS, The deployment and effective operation of wireless enhanced 9-1-1 is crucial to the public's safety; and

WHEREAS, Effective leadership is needed to advance the continual improvement of deployed wireless enhanced 9-1-1 systems; and

WHEREAS, APCO International is a national leader in public safety communications issues involved in advocating for the improvement of enhanced wireless 9-1-1; and

WHEREAS, The APCO International Executive Council has determined that coordination of wireless enhanced 9-1-1 deployment and operation is a priority for the Association by creating Project LOCATE; and

WHEREAS, Project LOCATE has coordinated Association and industry activities related to supporting the deployment and improving the operation of wireless enhanced 9-1-1 throughout the country; and

WHEREAS, In 2004, APCO International filed a Petition for Declaratory Ruling with the Federal Communications Commission addressing the measurement of accuracy in deployed enhanced 9-1-1 systems; and

WHEREAS, Project LOCATE has undertaken a variety of activities to examine the effectiveness of deployed enhanced wireless 9-1-1 including a comprehensive testing project in selected markets across the country; and

WHEREAS, Project LOCATE has concluded its testing project and has made specific operational and policy recommendations to the APCO Board of Officers; Now, therefore, be it

RESOLVED, That the APCO membership quorum, here assembled, strongly encourages the Board of Officers of APCO International to seek positive action by the Federal Communications Commission to rule in favor of the APCO 2004 Petition for Declaratory Ruling, specifically Section IIIA of the NPRM.

Adopted by unanimous vote by the APCO International quorum, August 5, 2007, Baltimore, Maryland. Back to top

National 9-1-1 Education Month

Whereas 9-1-1 is nationally recognized as the number to call in an emergency to receive immediate help from police, fire, EMS or other appropriate emergency response entities;

Whereas in 1967, the President's Commission on Law Enforcement and Administration of Justice recommended that a "single number should be established" nationwide for reporting emergency situations and other Federal Government Agencies and various governmental officials also supported and encouraged the recommendation;

Whereas in 1968, the American Telephone and Telegraph Company (AT&T) announced that it would establish the digits 9-1-1 as the emergency code throughout the United States;

Whereas 9-1-1 was designated by Congress as the national emergency call number under the Wireless Communications and Public Safety Act of 1999 (P.L. 106-81);

Whereas the ENHANCE 911 Act of 2004 (P.L. 108-494) established enhanced 9-1-1 as "a high national priority" as part of our Nation's homeland security and public safety;

Whereas it is important that policy makers at all levels of government understand the importance of 9-1-1, how the system works today and steps that are needed to modernize the 9-1-1 system;

Whereas the 9-1-1 system is the connection between the eyes and ears of the public and the emergency response system in the U.S. and is often the first to know of emergencies of all magnitudes making 9-1-1 a significant homeland security asset;

Whereas there are over 6,000 9-1-1 public safety answering points (PSAPs) serving more than 3,000 counties and parishes throughout the United States;

Whereas PSAPs answer more than two hundred million 9-1-1 calls each year in the United States and a growing number of 9-1-1 calls are made using wireless and IP-based communications services;

Whereas a growing segment of the population, including the deaf and hard of hearing and individuals with speech disabilities, are increasingly communicating with non-traditional text, video and instant messaging communications services and expect these services to be able to connect directly to 9-1-1;

Whereas the growth and variety of means of communications, including mobile and IP-based systems, impose challenges for accessing 9-1-1 and implementing enhanced 9-1-1 and require increased education and awareness about their capabilities;

Whereas numerous other N-1-1 and 800 number services exist for non-emergency situations, including 2-1-1, 3-1-1, 5-1-1, 7-1-1, 8-1-1, poison control centers and mental health hotlines, and the public needs to be educated on when to use these services in addition to or instead of 9-1-1;

Whereas people of all ages use 9-1-1 and it is critical to educate the public of all ages on the proper use of 9-1-1;

Whereas senior citizens are at high risk for needing access to 9-1-1 and a large segment of this population is learning to use new technology;

Whereas thousands of 9-1-1 calls are made every year by children properly trained on the use of 9-1-1 resulting in lives saved which underscores the critical importance of training children early in life about 9-1-1;

Whereas there is widespread misuse of the 9-1-1 system, including prank and non-emergency calls, which can result in costly and inefficient use of 9-1-1 and emergency response resources and a need to reduce this practice;

Whereas parents, teachers, and all other care givers need to play an active role in 9-1-1 education for children, but will do so only after being first educated themselves;

Whereas there are many avenues for 9-1-1 public educations such as safety fairs, school presentations, libraries, churches, businesses, PSAP tours or open houses, civic organizations and senior citizen centers;

Whereas children, parents, PTA and teachers are important groups to educate about the importance of 9-1-1 through targeted outreach efforts to public and private school systems;

Whereas we as a nation should strive to annually host at least one educational event in every school in the country every year regarding the proper use of 9-1-1;

Whereas an established National 9-1-1 Education Month could include public awareness events, including conferences and media outreach, training activities for parents, teachers, school administrators, other care givers and businesses; educational events in schools and other appropriate venues; and production and distribution of educational content on 9-1-1 designed to educate people of all ages on the importance and proper use of 9-1-1;

Whereas Americans deserve the finest education we can offer regarding 9-1-1 education: Now, therefore be it

Resolved, That the APCO International Board of Officers recognizes April as "National 9-1-1 Education Month" And be it

Further resolved, That the APCO International Board of Officers urges the U.S. Congress and the governors of all states and territories to recognize April as "National 9-1-1 Education Month"

ADOPTED BY THE APCO INTERNATIONAL BOARD OF OFFICERS June 25, 2007. Back to top

USE OF RADIO FREQUENCY JAMMING EQUIPMENT IN CORRECTIONAL FACILITIES

APCO International continues to strongly oppose the general use of radio frequency jamming equipment. We are deeply concerned that these devices may interfere with public safety mobile radio communications and can result in endangering the lives of first responders and the general public.

APCO International recognizes 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 the problem, some companies have developed cell jamming equipment and have marketed that equipment to correctional facilities. However, the use of radio frequency jamming 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 this equipment.

The Safe Prisons Communications Act of 2009 (S. 251 and H.R. 560) is pending in Congress and would allow the FCC to authorize radio frequency jamming devices for use only in correctional facilities - subject to restrictions - to ensure that there is no unintended interference with legitimate cell phone use or public safety radio communications.

Given the difficulties derived from interference caused by Nextel Communications' use of spectrum adjacent to public safety bands, and the subsequent costly rebanding process, APCO International is concerned about allowing another technology to be deployed that could create harmful interference on public safety communications systems.

APCO International believes that any such legislation should require vendors to conduct bench testing and limited field testing to determine potential impact prior to having the equipment installed in correctional facilities.

As consideration is given to provisions for radio frequency jamming equipment to 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 cell phones into the facility and the procedures that are employed by the institution to locate and confiscate cell phones 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 cell phones in the vicinity, can be deployed in lieu of radio frequency jamming equipment.

APCO International believes that while allowing radio frequency jamming equipment in correctional facilities may seem like a viable solution to combating the use of cell phones by prisoners in the conduct of illegal activities 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 options should be considered before allowing the use of radio frequency jamming equipment. Back to top

Misuse and Abuse of 9-1-1 Funds

APCO International support withholding federal 9-1-1 and E9-1-1 grant monies from States and political subdivisions who misappropriate, mis-allocate and divert 9-1-1 monies from their intended purpose. We encourage advising of Congress and publishing of information regarding States that divert 9-1-1 funds from intended purposes. Recognizing the authority of the Federal Communications Commission, we support improved reporting by all States and political subdivisions on the diversion of 9-1-1 funds, but caution against burdensome audits or reporting obligations.

APCO encourages all states and local governments that collect funds for the purposes of wireless E9-1-1, to use those funds for the express purpose of PSAP readiness for wireless E9-1-1. If any funds are found to be in surplus of the amount needed for initial readiness, funds should be reserved for future upgrades and enhancements of the emergency telephone system. PSAPs must be able to receive and process location and call back information from wireless phone devices. Any use of such funds other than for this purpose is not supported by APCO and are in contrast to good sound public safety policy. APCO believes that the public is at risk in those situations whereby funds are collected, yet used for purposes other than PSAP needs for 9-1-1. Furthermore, APCO believes that consumers are being misled by state and local government organizations that use 911 funds for other purposes. This must not be permitted to continue. Back to top

Internet Telephony (VoIP) 9-1-1

The public has an expectation that telephone services will provide 9-1-1 and Enhanced 9-1-1 capability (which includes caller location information), regardless whether the telephone operates on the public switched telephone network, wireless networks, or the Internet. Yet, at present there is a very real likelihood that a " 9-1-1 " call from a VoIP telephone will be lost, delayed, or misrouted.

Some VoIP providers have recently agreed to voluntarily work towards permanent solutions and, in the interim, to begin routing " 9-1-1 " calls to ten-digit emergency numbers within three to six months. That is not an acceptable solution, as it takes a 21 st century technology (IP telephony) and shoves it into a 1960's method of reporting life-threatening emergencies. Routing VoIP " 9-1-1 " calls to ten-digit emergency numbers will also disrupt and strain the limited resources of Public Safety Answering Points (PSAPs), which are already struggling to provide wireless E9-1-1 capability.

The voluntary efforts of VoIP providers to address 9-1-1 issues are certainly welcome. However, enforceable regulation is necessary to ensure that solutions are sufficient to satisfy the public interest and apply to all VoIP providers. Such 9-1-1 requirements are needed even if the FCC determines that application of other telecommunications regulation to VoIP is unnecessary.

APCO International supports the FCC t Report and Order in WC Docket Nos. 04-36 and 05-196 ("Order"). APCO International strongly opposes any effort that would prevent the FCC from enforcing rules that require 9-1-1 and E9-1-1 capability for all new VoIP customers. We believe that the FCC's ability to enforce existing rules is in the best interest of the public's safety.

APCO International strongly encourage all VoIP services take action to ensure that when an emergency 9-1-1 call is placed from a telephone using IP telephony, the call is completed to the appropriate Public Safety Answering Point (PSAP) and the physical address of the caller's location is displayed via the Automatic Location Identification (ALI) database.

APCO International recognizes the authority of state and local government to assess 9-1-1 fees, where authorized by valid statutes, against VoIP subscribers and the responsibility of VoIP providers to collect and submit the 9-1-1 fees.

APCO International recognizes the authority of the PSAP to determine 9-1-1 call routing, including routing of 9-1-1 calls placed utilizing VoIP technology, based upon its jurisdictional requirements and policies; and be it finally resolved

APCO International does not support routing 9-1-1 calls, including those placed utilizing VoIP, to an agency's ten-digit administrative lines, except as necessary in a short term interim solution, with the agreement of the PSAP.

APCO International strongly believes that VoIP providers should not be able to offer services to new customers in geographic areas where the provider is not able to comply with the FCC's 9-1-1 and E9-1-1 requirements contained in the FCC's Order. Back to top

Telematics

APCO strongly encourage the continual development of life saving devices through telematics services.

APCO is not in favor of requiring direct connect from Automatic Crash Notification (ACN) devices directly to Public Safety Answering Points (PSAP) through legislative/regulatory mandates.

APCO continues to work with telematics industry experts in the development of training standards for information gathering and dissemination from the telematics call center to the public safety emergency communications center.

APCO embrace the new technologies brought forth by the telematics industry for the benefit of public safety.

APCO recognize that a close working relationship between the telematics industry and the public safety community is necessary for the development and implementation of the standards and support of the new technologies. Back to top

Plain Speech in Public Safety Communications

Plain speech for public safety communications operations has been a matter of considerable discussion within the first responder community for several years. With the requirement to implement the National Incident Management System (NIMS), an effort by the Department of Homeland Security (DHS) to better coordinate emergency response between different jurisdictions and disciplines, APCO International has considered this issue in the context of sharing information by first responders.

Due to a number of important factors, APCO International renews its assertion that plain speech communications over public safety radio systems is preferred over the traditional 10-Codes and dispatch signals used by a majority of law enforcement agencies across the country. It is recognized that valid concerns about officer safety or confidential information being jeopardized should be resolved between the local agency(s) and the serving public safety communications center.

The impact of plain speech communications upon the public safety communications center allows the dispatcher and the field responder to use common language descriptors to indicate the nature of the event, situation, and person(s) that is the topic of the radio transaction. The abandonment of agency specific 10-Codes and dispatch signals support the incident command concepts to effectively coordinate response activity not only in multi-agency disaster situations but in routine intra-agency operations. APCO International asserts that the routine practice of effective radio protocol and discipline is the best form of disaster preparation.

APCO International recognizes that the lack of consistent, reliable communication services and/or poor performance are often cited in after action reports as a major failure during disaster situations. The fundamental principles of prompt, effective, competent communication will be dramatically improved, particularly when resources are deployed that originate from outside the primary response area, with implementation of plain speech procedures by all public safety agencies.

APCO International agrees with the NIMS Integration Center that the use of plain speech in emergency response situations is a matter of public safety, especially the safety of first responders and those affected by the incident. To best assure the use of this common, universal language during a major event, its daily use is required.

The entire Incident Command System (ICS), an effort of NIMS to provide a common organizational structure for the immediate response to emergencies involving the coordination of personnel and equipment on-site at an incident, requires resources being managed and functioning under a planned, approach that diminishes the risk created by unclear, unfamiliar or misunderstood codes and signals. Using plain speech is a simple remedy to reduce communication failures. This common approach is essential to achieving functional interoperability across all jurisdictions and disciplines.
APCO International encourages the use of sensible plain speech alternatives for common 10-Codes. For example:

10-4 - copy or acknowledge or understood
10-20 - my location is
10-28 - registration check - reg. check
APCO International believes that officer safety will be enhanced through thoughtful development of plain speech alternatives to codes/signals that protect the sensitivity of confidential information.

APCO International strongly supports the autonomy of local, county, state and other law enforcement agencies to make operational decisions. However, NIMS compliance is important and this fundamental communication procedure will have a dramatic affect on interoperability across the nation. APCO International supports the goal of NIMS of good faith efforts at all levels nationwide to move to plain speech for all emergency operations. Back to top

TCS and HBF Petition to Waive Part 52 of Commission Rules Position Statement

APCO International is concerned that some providers of VoIP Position Centers (VPC) may have to discontinue services to VoIP Service Providers (VSP) if they are denied access to pseudo Automatic Number Identification (p-ANI) codes.

APCO International respectfully requests that the Federal Communications Commission (Commission) fully examine the impact of a decision to deny VPC access to p-ANI codes and its affect on the ability of public safety answering points (PSAP) to locate VoIP 9-1-1 callers using current VPC services.

APCO International believes that if VPCs are forced to discontinue services to VSPs VoIP consumers may be at risk when calling 9-1-1.

APCO International takes no position on the technology used by VPCs to provide services to VoIP carriers as long as such services meet the requirements set in the Commission's VoIP 9-1-1 Order. Back to top

Use of Satellite Services for Public Safety Communications

APCO International believes that satellite services are critical for redundancy of public safety communications networks and for providing gap coverage in severe emergencies or in scenarios where terrestrial coverage is not available or possible.

APCO International believes the FCC should investigate the potential of a requirement for equipment designed to operate on the 700 MHz public safety broadband network be capable of communicating directly and seamlessly with communications satellites.

APCO International believes that access to satellite services may greatly improve public safety's capability, interoperability, and redundancy at a comparable cost to terrestrial-only devices, and will be a great step in our nation's efforts to improve public safety communications in rural areas. Back to top