Aligning APCO’s Advocacy Priorities With Our Members’ Needs

By Jeff Cohen

Back in January, we posted a blog outlining our top legislative and regulatory priorities for 2021. Now that we are six months into the year, and with APCO’s Annual Conference right around the corner, we’re writing to reflect on the “why” behind our advocacy. APCO is driven by the needs of its public safety membership. Here are a few examples of how our advocacy priorities are rooted in our members’ needs.

Reclassification of Public Safety Telecommunicators

Our members are particularly passionate about fixing the classification of public safety telecommunicators in the federal Standard Occupational Classification (SOC) – changing from “Office and Administrative Support Occupations” to “Protective Service Occupations.” When congressional offices ask us why this is important, given that changing the classification will not directly impact salaries or benefits, we share what we’ve heard from our members: when a 9-1-1 call comes in, and it’s your job to coach someone through CPR or convince a suicidal person not to harm themselves or others, how is that clerical work? The stories our members share help expose the inaccuracy of the current SOC classification and fuel our advocacy.

Since 2014, APCO has been pushing for the SOC to be revised to more accurately reflect the protective nature of the work performed by public safety telecommunicators. In April 2021, the 9‑1‑1 SAVES Act (H.R.2351/S.1175), a bill that would direct the Office of Management and Budget to correct the SOC, was reintroduced in Congress with bipartisan support. APCO has worked to increase support for the bill by launching a grassroots advocacy campaign and sharing the many lifesaving stories we’ve heard from our members with representatives in Congress.

Federal Funding for Next Generation 9-1-1

APCO has been advocating for legislation that would provide federal funding in the form of $15 billion to modernize emergency communications centers (ECCs) across the country to Next Generation 9-1-1 (NG9-1-1). From listening to our members, we know that funding and new technologies are only part of what’s needed. That’s why APCO has pushed for a comprehensive approach to NG9-1-1 that ensures ECCs have all the resources they need – including for appropriate training – to fully modernize their systems in an end-to-end, secure, interoperable, and non-proprietary manner.

9-1-1 Location Accuracy

Locating wireless 9-1-1 callers is a universal challenge, especially when callers are in multistory buildings. For several years APCO has pressed wireless carriers and the FCC for improved location information. Our focus has been on what will be the most useful, actionable information for the 9-1-1 professional: dispatchable location (meaning the street address, floor, and room or suite number). This is what 9-1-1 directors say they need, but at times, APCO has been the lone voice at the FCC pushing for dispatchable location rather than an x/y/z coordinate-based (think “point in space”) approach.

We have heard many stories from our members about the importance of quickly locating a 9-1-1 caller and the type of information that they need. Information such as “101 Main Street, Suite 700” is much more useful than what carriers are presently set to provide: for example, “101 Main Street, 20 meters “Height Above Ellipsoid” +/- 3 meters.” An x/y/z coordinate-based approach presumes that ECCs would be able to use the “Height Above Ellipsoid” information, which could entail the nearly impossible task of developing 3D maps of every building to make this information useful. Dispatchable location information is what 9-1-1 needs, regardless of the preferences or plans of wireless carriers and vendors. (For more information about the difference between dispatchable location and Height Above Ellipsoid click here.)

Wellness for 9-1-1 Professionals

In a way, many of APCO’s advocacy goals can be connected to the challenging nature of working in 9-1-1, whether it’s about recognizing the lifesaving work or providing the right resources to make the job a little easier. Working in emergency communications has a significant impact on these professionals’ health and wellness. Research has shown that one in seven public safety telecommunicators has contemplated suicide in the past year. While many agencies have developed wellness programs for 9-1-1, more support is needed. APCO is raising awareness of these issues and exploring legislative opportunities to include public safety telecommunicators in public safety wellness programs and provide dedicated resources for ECCs.

Understanding the challenges our members face and being able to explain why their work is so important to policymakers is extremely helpful. We are especially eager to reconnect with our members at the APCO Annual Conference in San Antonio this August, and we encourage all of you to reach out at any time to share information about the challenges you face and how we can help. Please contact [email protected] to share your thoughts on these issues or to connect with us at the Annual Conference.

About the TabletopX Blog

A “Tabletop Exercise,” often shortened as “TTX,” is a discussion-based exercise frequently used by emergency planners. Led by a facilitator using a planned scenario, TTX participants describe the actions they would take, and the processes and procedures they would follow. The facilitator notes the players’ contributions and ensures that exercise objectives are met. Following the exercise, the facilitator typically develops an after-action report and conducts a debrief discussion during which players and observers have an opportunity to share their thoughts, observations, and recommendations from the exercise without assigning fault or blame.

Many of the attributes of a TTX are the same we seek to promote in the discussion generated from our blog posts. The goal is to capitalize on the shared experiences and expertise of all the participants to identify best practices, as well as areas for improvement, and thus achieve as successful a response to an emergency as possible.

TabletopX blog posts are written by APCO’s Government Relations team and special guests.

APCO International’s Public Safety Communications Priorities for the New Year

By Jeff Cohen

In 2020, public safety communications professionals faced an extraordinary year, dealing with the COVID-19 pandemic, record-breaking natural disasters, and major civil unrest, in addition to their “routine” work protecting and saving lives.

From an advocacy perspective, 2020 was a mixed bag. We witnessed some progress with federal legislation, but there’s a lot more work to be done in the new Congress. And under the previous FCC leadership, we had an unusually difficult time, with APCO needing to challenge three public safety-related decisions, including one in federal court. We’ve certainly had disagreements with the FCC before, mostly over how aggressive to be in making improvements for public safety, but we never had to be concerned that FCC actions would have the potential to directly threaten public safety. 

Like Congress, the leadership and composition of the FCC is changing, and with that comes new opportunities to collaborate with the FCC and work with Congress to pass laws that will improve public safety communications. The following is a list of our legislative and regulatory priorities.

Legislative Priorities

1. Reclassification of 9-1-1 Public Safety Telecommunicators

What’s the issue?

The federal government’s catalogue of occupations, the Standard Occupational Classification (SOC), categorizes 9-1-1 Public Safety Telecommunicators (PSTs) as an administrative/clerical occupation, but there is a much more appropriate “protective” category. The SOC is supposed to group occupations by the nature of the work performed. 9-1-1 professionals save and protect lives every day. Therefore, instead of being considered clerical personnel, they should be with the “Protective Service Occupations” – a broad group that includes several occupations that perform work that is less protective than PSTs’. 

What needs to be done?

The easiest path is for the new leadership of the Office of Management and Budget, which controls the SOC, to simply correct the SOC by reclassifying PSTs into the protective service category. This would come at no cost, promote good government by ensuring that the SOC is accurate, and signal the Administration’s recognition of the life-saving roles performed by PSTs.

As an alternative, legislation could direct OMB to fix the SOC. The 9-1-1 SAVES Act would do just that. In the prior session of Congress, this bill had strong bipartisan support in both the House and the Senate but was held up by the respective committees – House Education and Labor and Senate Homeland Security and Governmental Affairs – we believe based on a request from Department of Labor staff to maintain the status quo. In the new session of Congress, APCO will work with the original co-sponsors of the 9-1-1 SAVES Act to get this bill reintroduced quickly into both Houses of Congress, and vigorously pursue passage. 

2. Next Generation 9-1-1 Funding

What’s the issue?

The nation’s 9-1-1 networks are in dire need of modernization. 9-1-1 is reliable and widely available but is based on 50+ year-old technology and thus limited to voice calls and some texting capabilities. We need to deploy Next Generation 9-1-1 throughout the country, in a comprehensive, secure, innovative, cost-effective, and interoperable manner. This would enable 9-1-1 centers to receive and process voice, text, and multimedia content and share it with other 9‑1‑1 centers or with first responders in the field. While some states and jurisdictions are making partial progress towards NG9-1-1, these efforts are costly and proprietary, and do not support multimedia or interoperability.

What needs to be done?

A significant federal grant program is needed to spur nationwide deployment of NG9-1-1 in a secure, innovative, cost-effective, and interoperable manner. A broad coalition of national public safety associations has developed legislative language, building on earlier bills, to accomplish these goals. (See this separate blog for background on the coalition.) NG9-1-1 is a natural fit for any infrastructure bill, as 9-1-1 is the most critical of critical infrastructure. It is the lynchpin for public safety and national security, from the most local to the most widespread emergencies.

3. Wellness for 9-1-1 Professionals

What’s the issue?

Health and wellness is a huge challenge in 9-1-1, both physically and mentally. For example, research has shown that the stress of working in emergency communications dramatically increases the risk of suicidal thinking. Based on one study, approximately one in seven 9-1-1 professionals reported having suicidal thoughts in the past year. That’s comparable to rates for fire/rescue and more than four times the rate in the general population. Dealing with this serious challenge to our community will require significant efforts, including raising awareness, creating guidance for mental health professionals, and supporting resources like peer support programs.

What needs to be done?

Dealing with such a significant problem will take an “all hands” approach. APCO will continue to pursue federal legislation that would help by establishing a nationwide approach for tracking suicide, developing wellness resources, and supporting resources like peer support programs specific to 9-1-1 professionals. 

4. Network Outages Impacting 9-1-1 Service

What’s the issue?

When network outages occur impacting the ability of service providers to deliver 9-1-1 calls, 9‑1‑1 center managers need to have immediate notice of the scope, nature, and anticipated duration of the outage in order to take action to protect their communities, such as advising the public to use a 10-digit number if 9-1-1 is unavailable. There are some basic regulatory requirements for notifications, but ECCs rarely get timely or actionable information. Sometimes they don’t get notified at all, and they are left to discover problems on their own and communicate what limited information they have to the public. APCO has repeatedly pressed the FCC, to no avail, to adopt rules to improve the outage information that is provided to ECCs. 

What needs to be done?

The FCC should adopt rules that require service providers to provide timely notifications of service outages impacting the ability of the public to contact 9-1-1, in an easily accessible format (like the maps used to track some electric utility outages).

Because the FCC’s prior leadership failed to act, APCO pursued a legislative approach that would direct the FCC to do this. Late last year, the House passed a bill, H.R. 5918, that would require the FCC to adopt rules that describe the circumstances in which service providers must submit notifications to ECCs about network disruptions that prevent the origination of 9-1-1 calls or the delivery of automatic location identification (ALI) or automatic number identification (ANI). Importantly, such notifications must be “timely” and in a format that’s “easily accessible” to facilitate ECCs’ situational awareness. A companion bipartisan bill, S. 4667, was introduced in the Senate. The House and Senate bills will need to be reintroduced and passed in the new Congress.

FCC Regulatory Priorities 

1. 9-1-1 Location Accuracy

What’s the issue?

9-1-1 professionals require actionable location information for 9-1-1 calls made indoors. Ideally, they would know the caller’s “dispatchable location,” meaning the correct building address, floor, and room or suite number. Back in 2015, following successful negotiations among APCO, NENA, and the nation’s major wireless carriers, the FCC established rules to accomplish just that. Unfortunately, through a combination of broken promises on the part of the wireless carriers, little is left of the promise of the 2015 rules. 

Rather than receive a dispatchable location, 9-1-1 professionals are poised to receive only a vertical location estimate expressed as a “Height Above Ellipsoid (HAE).” HAE is different from height above ground or sea level. For HAE to be used by ECCs, specialized software and maps for the millions of buildings throughout the United States would have to be developed – a questionable, significant, and costly undertaking. It might be possible for responders in the field to attempt to match the reported HAE with their own devices, but this process has not been tested, and the FCC has not analyzed if it would even be possible with the technologies available. 

At every turn, APCO and 9-1-1 directors from across the country asked the FCC to do better, and adopt stricter rules to at least require carriers to provide the floor label. APCO has repeatedly pointed out that several technologies could be leveraged to support the provision of dispatchable location, and some carriers are making initial efforts to deploy them voluntarily. We also filed a Petition for Clarification and a subsequent Petition for Reconsideration at the FCC pointing out major loopholes in the rules that carriers might exploit to avoid making any improvements to 9-1-1 location accuracy. 

Prior FCC leadership essentially ignored the issues raised in the Petition for Clarification and rejected the Petition for Reconsideration. We are months away from the FCC’s April 2021 location accuracy benchmark. Wireless carriers have signaled that they will not meet the accuracy requirements, but the FCC has declined to close loopholes or provide guidance on how ECCs should proceed when 9-1-1 location information is failing to meet expectations. 

What needs to be done?

The FCC should adopt reasonable rules to get 9-1-1 location back on track based on what 9-1-1 professionals truly need. This should include a requirement that a certain percentage of indoor calls are delivered with a dispatchable location and an expectation that carriers will leverage a variety of technologies, such as “5G Home” offerings.

2. 6 GHz Frequency Band

What’s the issue?

Public safety agencies throughout the country make extensive use of the 6 GHz frequency band for emergency dispatching, first responder radio communications, and connectivity with other jurisdictions. This is the only band that provides the reliability and interference-free coverage that public safety needs.

Despite significant technical debate and public safety concerns, the FCC voted to permit hundreds of millions of potentially interfering new devices to share this band. These devices are not licensed, and thus not easily trackable, and are expected to be just as ubiquitous as the Wi-Fi equipment presently found throughout homes and businesses.

APCO didn’t oppose sharing this band per se. But APCO reasonably asked the FCC to 1) ensure that real-world tests are conducted to inform the rules and measures for preventing/mitigating interference, and 2) require mechanisms to rapidly detect, identify, and eliminate any interference. The proponents of unlicensed devices argued that the risk of interference is small, but neither they nor the FCC expects zero interference to public safety communications. So we must ask – why wouldn’t the FCC or any of the manufacturers of these unlicensed devices want to conduct real-world tests to make sure they got the new rules right? Why shouldn’t the FCC adopt rules that require the immediate detection and elimination of harmful interference to public safety?

Unfortunately, the FCC ignored public safety concerns and opened the band, and is currently considering a proposal to further expand unlicensed use. Many concerns held by APCO and other incumbent users – for example, how much interference the new devices will cause and how it will be quickly eliminated – were punted to the industry to consider, with the FCC simply encouraging stakeholders to collaborate going forward. The “multistakeholder” group that formed has so far proved to be little more than an exercise in futility, with companies that will benefit from the FCC’s new rules resisting efforts to explore even basic questions such as whether the FCC’s assumptions on the potential for interference prove true in the real world. 

APCO was left with no other option than, for the first time in its history, to sue the FCC in federal court due to the potential for interference that will cause unrecoverable harm to public safety by operation of these new unlicensed devices. APCO, along with other aggrieved incumbents including in the utility, telecom, and broadcast industries, have filed an initial brief with the court. APCO will continue to ensure public safety’s perspective is represented in the litigation, which is expected to run well into 2021. In the meantime, APCO will closely monitor the situation and take every available action as new devices are introduced and there’s evidence of harm to public safety operations. We’ll also continue making a good-faith effort with the multistakeholder group in hopes that the companies pushing the new devices will accept their responsibility and stop blindly pushing a framework that threatens public safety.

What needs to be done?

The FCC should not adopt the proposed further expansion of unlicensed use of 6 GHz. And regardless of the outcome of the court appeal, the FCC should right its wrongs from the original expansion. As part of a sweeping funding law, Congress recently expressed concern that the new 6 GHz rules could result in interference to incumbent users and harm critical communications infrastructure. In March 2021, the FCC must deliver a report to Congress on its progress in “ensuring rigorous testing related to unlicensed use of the 6 GHz band.” The FCC should use this as an opportunity for a reset: it should pause any new authorizations of unlicensed devices and require testing and institute rules that protect public safety. We are very worried that it will soon be too late to reverse the harmful effects of this order, particularly as more and more of these new devices are unleashed into the consumer marketplace.

(Click here for a separate blog describing the status of the 6 GHz proceeding.)

3. 4.9 GHz Frequency Band

What’s the issue?

This band is uniquely suited to serve public safety’s exclusive spectrum for local broadband communications – Wi-Fi hot spots, fixed point-to-point connections, robot control, or bandwidth-intensive applications like high-resolution streaming video. But while the need is there, public safety hasn’t been able to make the most of this band because equipment costs are high, there are inadequate protections against interference, and the marketplace for devices is uncompetitive and sparse.

For many years, APCO, among other public safety groups, has been asking the FCC to make reasonable rule changes to enable public safety to make increased use of this band. Yet the FCC, in a divided vote, shocked the public safety community by adopting a recent order that effectively hands this band over to the states for commercial leasing, and removes any guarantees of interference-free and priority use of the spectrum by public safety. 

When the previous FCC Chairman made a draft of the order public, APCO joined numerous other major public safety associations in expressing strong opposition to the draft order and asking the Chairman to remove it from consideration and start over. Yet a narrow majority of the FCC nevertheless voted to approve this order. On December 29, APCO submitted a petition for reconsideration and intends to pursue formal options to undo these new rules.

What needs to be done?

The FCC should reverse course and adopt measures that the public safety community has recommended for increasing use of the band. Unlike the 6 GHz matter, the 4.9 GHz decision was split, and thus we are hopeful that the new FCC will promptly reverse course. 

4. Network Outage Reporting to 9-1-1 Emergency Communications Centers

What’s the issue?

When network outages occur impacting the ability of service providers to deliver 9-1-1 calls, 9-1-1 center managers need to have immediate notice of the scope, nature, and anticipated duration of the outage in order to take action to protect their communities, such as advising the public to use a 10-digit number if 9-1-1 is unavailable. There are some basic regulatory requirements for notifications, but ECCs rarely get timely or actionable information. Sometimes they don’t get notified at all, and they are left to discover problems on their own and communicate what limited information they have to the public. For years, the FCC’s prior leadership ignored APCO’s repeated requests to improve the outage information that is provided to ECCs, as well as suggestions to establish a two-way contact database for ECCs and service providers. 

What needs to be done?

The failure of the FCC to implement such basic requirements prompted APCO to pursue a legislative solution, and we will continue to press for such an outcome. But the FCC should take prompt action on its own to establish related rules.

5. Carrier/ECC Contact Database

What’s the issue?

In service provider/customer relationships, it is normal for service providers to ensure they know how to contact their customers, and that their customers know how to contact them, whenever a service problem arises. That should especially be the case when the service at issue is one of the most important services out there – connecting 9-1-1 calls to ECCs. Yet the wireless carriers responsible for delivering 9-1-1 calls to ECCs have continually refused to create this needed database. And the FCC’s prior leadership ignored APCO’s repeated calls for rules requiring service providers to create a secure, two-way contact database. When an outage occurs that impacts the ability of the public to reach 9-1-1 and/or communicate the caller’s phone number and location, carriers should know exactly who and how to contact the impacted ECCs. And when ECCs detect outages on their own, which happens often, they need to know how to immediately contact the relevant service provider.

What needs to be done?

The FCC must act to require wireless providers to promptly create a secure, two-way contact database. For example, this can take the form of a web-based portal that enables ECCs to populate and maintain their contact information (and a preference to be contacted via email, text, etc.) and for service providers to include ways to reach them 24/7/365. 

The FCC should not permit the carriers to transfer this responsibility and any associated costs to the public safety community. Doing so would set a bad precedent for service providers to seek to avoid additional responsibilities that rightfully belong to them. 

6. Wireless Emergency Alerts

What’s the issue?

Marginal enhancements have been made in recent years (longer message length, state/local testing, geotargeting, etc.), but the FCC has gone silent on the need to support multimedia in alerts (such as the photo of a missing child in an AMBER alert, or a photo of a dangerous suspect at large) and seems to be watering down the promised geotargeting improvement. Under the geotargeting rule, as of Dec. 13, 2019, new devices and devices capable of being upgraded are supposed to be limiting alert delivery to the target area plus 0.1 mile overshoot. (This change was supposed to eliminate the traditional problem of people receiving alerts that were only relevant for communities that were many miles away.) It seems that the FCC’s prior leadership either was letting carriers ignore the requirements or took a watered-down view of what it means to be capable of upgrading devices.

What needs to be done?

The FCC should hold carriers to the plain-reading of the geotargeting requirement, and add a requirement for alerts to support photos and other multimedia. 

7. Upgrades to Universal Licensing System

What’s the issue?

The FCC’s Universal Licensing System (ULS) is the FCC’s official database for licensing spectrum. It contains extensive technical data such as transmitter and receiver locations, frequencies, bandwidths, antenna height, etc. Public safety frequency coordinators like APCO rely on ULS when determining which frequencies are suitable for a given need in a particular location. With the introduction of spectrum sharing technologies, ULS is likely to play a key role for making real-time determinations of what spectrum can be used in certain areas, and at what power level. The problem is that ULS is old, and it wasn’t designed for the modern era and real-time operational use cases. The system can be glitchy, and it isn’t always reliable. In fact, during one of the government-wide shutdowns during the last administration, ULS went dark altogether. That’s a big inconvenience if you’re an agency trying to get a new spectrum license, but it’s a recipe for disaster if ULS is being used to ensure dynamic spectrum sharing technologies avoid interfering with public safety systems. 

What needs to be done?

Modernizing ULS is a major undertaking that the FCC has been discussing for several years. The technology is available to improve reliability, access, and functionality, but the FCC needs a solid plan and dedicated resources to carry it out.  

You can contact APCO’s Government Relations Office with any feedback by emailing [email protected].

About the TabletopX Blog

A “Tabletop Exercise,” often shortened as “TTX,” is a discussion-based exercise frequently used by emergency planners. Led by a facilitator using a planned scenario, TTX participants describe the actions they would take, and the processes and procedures they would follow. The facilitator notes the players’ contributions and ensures that exercise objectives are met. Following the exercise, the facilitator typically develops an after-action report and conducts a debrief discussion during which players and observers have an opportunity to share their thoughts, observations, and recommendations from the exercise without assigning fault or blame.

Many of the attributes of a TTX are the same we seek to promote in the discussion generated from our blog posts. The goal is to capitalize on the shared experiences and expertise of all the participants to identify best practices, as well as areas for improvement, and thus achieve as successful a response to an emergency as possible.

TabletopX blog posts are written by APCO’s Government Relations team and special guests.

Update on New FCC Spectrum Rules: Why APCO is suing the FCC

By Jeff Cohen

Last year, I wrote a blog titled “New FCC Spectrum Rules Put Public Safety Communications at Risk.” As I explained, the FCC adopted new rules to allow Wi-Fi routers to freely operate throughout a major spectrum band that is heavily relied upon by public safety agencies for “microwave” communications. APCO and other parties protested and asked the FCC to repeal the new rules. Unfortunately, the FCC rejected our requests. Now, I’m writing with an update to describe APCO’s decision to sue the FCC in federal court to reverse the new rules and where things stand.

A Quick Refresher on 6 GHz Spectrum

The 6 GHz spectrum band is the backbone of emergency communications throughout the country. Think of it as a system of major highways connecting public safety networks and agencies to each other. For example, 6 GHz links are used to transmit 9-1-1 dispatch information to fire stations, and to connect public safety land mobile radio communications towers, linking first responders to each other. 6 GHz links span many miles and thus are key to supporting communications in remote areas where there are few, if any, alternatives.

To give you an idea of how pervasive public safety use of the band is, here’s a view of the public safety microwave links in my home state of Virginia:

All across the country, 6 GHz links hum every minute supporting communications for 9-1-1 centers and first responders. If there’s interference to 6 GHz systems, communications critical to the safety of life are put at risk. For decades, public safety has relied upon this band, which is subject to careful prior frequency coordination and intended for extreme reliability. In fact, these links are designed to prevent interruptions longer than 30 seconds per month, with some not tolerating more than 30 seconds of downtime per year. It is this reliability that makes the spectrum so important for public safety.

What the FCC Did

In April 2020, the FCC changed the spectrum rules. Whereas before, using 6 GHz spectrum generally required a formal license from the FCC (making it relatively straightforward to avoid and resolve interference), now the entire band is available for unlicensed use by devices like Wi-Fi routers. What motivated this drastic change? Some tech companies say they need more spectrum to support Wi-Fi and other consumer electronics. Since spectrum is a finite natural resource, attention has turned to ways to share spectrum presently in use with new applications. Proponents of Wi-Fi and 5G products and services turned their eyes to the 6 GHz band.

As a general matter, APCO is not totally against having public safety share spectrum with other users, in the interests of helping to promote overall spectrum efficiency. But APCO has been clear that any mechanism to be deployed to share public safety spectrum must be tested and proven to work in advance. That is an entirely reasonable position to hold, given the potential harm to public safety if something were to go wrong or not work as expected. Spectrum sharing technologies are nascent and up to this point haven’t been applied to public safety bands.

In addition to requiring spectrum sharing technologies to be proven to work before they’re used in the real world, APCO has held another entirely reasonable stance: even if proven effective in advance, no sharing mechanism will be reliable enough to completely prevent interference. And when it comes to public safety, you just can’t take unnecessary risks. So, in addition to a successfully-tested-in-advance spectrum sharing technology being used to prevent interference, there needs to be an additional mechanism to detect, identify, and eliminate interference that does occur.

Unfortunately, despite APCO’s repeated advocacy in support of these two entirely reasonable propositions, the FCC declined to require testing in advance, and did not adopt any additional protective measures. Making matters worse is that the new uses being introduced into the 6 GHz band are of the kind that will be nearly impossible to track or recall. There are going to be hundreds of millions, if not more, of these new “unlicensed” Wi-Fi and similar devices flooding the marketplace. They will be bought at consumer-oriented e-commerce and brick-and-mortar stores, and deployed throughout homes and businesses, freely transmitting over the same spectrum that public safety microwave systems use.

Suing the FCC

After APCO exhausted its remedies at the FCC, we made the decision to appeal the FCC’s order in the U.S. Court of Appeals for the D.C. Circuit. Filing a lawsuit was a drastic step. This isn’t the first time APCO has disagreed with an FCC decision, but this is a unique situation with a significant risk of irreversible harm to public safety. Indeed, multiple parties are suing the FCC over these rules.

Public safety users aren’t the only “incumbents” in this band that are threatened by the FCC’s decision. There are commercial operators like AT&T, electric utilities, and broadcasters that also use this band for their own specific purposes and filed suit. For the sake of efficiency, the Court ordered us all to join together and write a common brief to make our legal arguments.

While working with these other parties, it became clear that the potential impacts on public safety users are unique from the risks other parties face. APCO is the sole litigant that directly represents the 9-1-1 centers and police, fire, and EMS departments that depend on the 6 GHz band to literally save and protect lives. Even though the other parties have safety-related concerns, such as the potential problems of interference to electric utilities, APCO was responsible for making sure that the arguments being made to the court reflected the unique requirements of public safety.

What Happens Next?

Pursuant to a court-mandated timeline, the parties suing the FCC filed their primary legal brief in December. The FCC’s response is due in February.

Be on the lookout for interference. It’s important to note that, while APCO and others are suing the FCC to reverse the new 6 GHz rules, the FCC is already starting to allow the marketing and sale of new devices that will take advantage of the rules. Wi-Fi routers using the same spectrum as public safety agencies could soon be in any office, apartment, or house. Given the lack of FCC-backed protections, some experts have suggested that existing 6 GHz users take measurements of the spectrum environment now so it will be easier to demonstrate that interference is a result of the new unlicensed devices. This takes time, money, and in some cases resources that agencies don’t have. Hopefully, before too many of the new devices roll out we’ll get the court to force the FCC to adopt a better approach to prevent and eliminate interference before it’s too late.

Also, as part of a sweeping funding law, Congress recently expressed concern that the new 6 GHz rules could result in interference to incumbent users and harm critical communications infrastructure. In March, the FCC must deliver a report to Congress on its progress in “ensuring rigorous testing related to unlicensed use of the 6 gigahertz band.”

We will continue to vigorously pursue the court case, which will extend for many months into 2021, and we’ll seek the strongest possible interpretation of the FCC’s new obligation to ensure rigorous testing is performed to protect critical communications. We will also advocate in public safety’s best interests as the FCC explores additional rule changes that could further threaten public safety operations. In the meantime, we will also carefully monitor the introduction of new unlicensed devices for any signs of interference.

You can contact APCO’s Government Relations Office with any feedback by emailing [email protected].

About the TabletopX Blog

A “Tabletop Exercise,” often shortened as “TTX,” is a discussion-based exercise frequently used by emergency planners. Led by a facilitator using a planned scenario, TTX participants describe the actions they would take, and the processes and procedures they would follow. The facilitator notes the players’ contributions and ensures that exercise objectives are met. Following the exercise, the facilitator typically develops an after-action report and conducts a debrief discussion during which players and observers have an opportunity to share their thoughts, observations, and recommendations from the exercise without assigning fault or blame.

Many of the attributes of a TTX are the same we seek to promote in the discussion generated from our blog posts. The goal is to capitalize on the shared experiences and expertise of all the participants to identify best practices, as well as areas for improvement, and thus achieve as successful a response to an emergency as possible.

TabletopX blog posts are written by APCO’s Government Relations team and special guests.

Forming the Public Safety Next Generation 9-1-1 Coalition

Looking back at 2020, one of the bright spots for APCO was joining with other leading public safety associations to advocate for legislation that would establish a significant one-time federal grant program to achieve Next Generation 9‑1‑1 (NG9‑1‑1) nationwide.

Following months of collaboration between various public safety associations and congressional staff, the Next Generation 9-1-1 Act of 2019 (H.R. 2760; S. 1479), was introduced in May 2019. The bill would authorize $12 billion in federal funding to help state and local governments deploy NG9-1-1, preserve state and local control, modernize definitions of key terms such as NG9-1-1, interoperability, and Emergency Communications Center (ECC), and place conditions on grant recipients to achieve interoperability, prevent 9‑1‑1 fee diversion, and have a sustainable funding mechanism in place for ongoing operational needs. The introduction of this bill was a great starting point for building momentum in Congress and raising awareness of the need for significant federal support to update 9‑1‑1 systems across the country.

After the bill was introduced, APCO joined with national public safety organizations representing fire/rescue, emergency medical service, and law enforcement professionals to establish a formal coalition for ongoing advocacy known as the Public Safety Next Generation 9-1-1 Coalition. This cross-section of public safety will be more effective than any one group alone at building support in Congress, and the broad participation helps to convey the fact that NG9‑1‑1 upgrades will benefit all areas of public safety.

The Coalition is committed to advancing legislation to enable a nationwide upgrade to NG9‑1‑1 that is interoperable, competitive, innovative, and secure. The member organizations united behind legislative principles that will address the needs and concerns of public safety. For example, NG9‑1‑1 should be technologically and competitively neutral, and use commonly accepted standards that do not lead to proprietary solutions that hamper interoperability, make mutual aid between agencies less effective, limit choices, or increase costs. With principles like this in mind, the Coalition developed several additional measures to make the legislation more impactful, including increasing the level of funding, establishing a public safety advisory board, creating additional measures on cybersecurity, and bolstering the interoperability provisions.

The Coalition is advocating for federal grant funding in the amount of $15 billion. Achieving NG9‑1‑1 uniformly throughout the United States will require a significant influx of federal funding, particularly in light of the anticipated budget shortfalls as a result of the COVID-19 pandemic. To assist with the development of grant program requirements, a new Public Safety Advisory Board would be established with representatives from 9‑1‑1 and other public safety disciplines. Among other things, the board would provide a variety of recommendations regarding the importance of deploying NG9‑1‑1 in both rural and urban areas, ensuring flexibility for technology improvements, and the value of enabling effective coordination among government entities.

Part of the advocacy effort entails promoting a common vision that achieving NG9‑1‑1 will result in true interoperability and multimedia capabilities across the emergency communications ecosystem. ECCs still have interoperability problems when it comes to transferring voice calls to other ECCs, even when both centers have deployed Emergency Services IP Networks. And NG9‑1‑1 should go beyond voice-only calls and enable ECCs to receive, process, and analyze all types of 9‑1‑1 requests for emergency assistance and share relevant information with other ECCs and emergency responders.

A joint public safety effort like this has not been undertaken since the Public Safety Alliance (which included many of the same organizations as the new Coalition) came together nearly a decade ago and successfully lobbied Congress to pass the law that created FirstNet, established a $115M 9‑1‑1 grant program, and provided hundreds of millions of dollars for public safety communications research. As 2021 begins, APCO and its Coalition partners will continue to make NG9‑1‑1 a legislative priority and press for a similar success.

You can contact APCO’s Government Relations Office with any feedback by emailing [email protected]

About the TabletopX Blog

A “Tabletop Exercise,” often shortened as “TTX,” is a discussion-based exercise frequently used by emergency planners. Led by a facilitator using a planned scenario, TTX participants describe the actions they would take, and the processes and procedures they would follow. The facilitator notes the players’ contributions and ensures that exercise objectives are met. Following the exercise, the facilitator typically develops an after-action report and conducts a debrief discussion during which players and observers have an opportunity to share their thoughts, observations, and recommendations from the exercise without assigning fault or blame.

Many of the attributes of a TTX are the same we seek to promote in the discussion generated from our blog posts. The goal is to capitalize on the shared experiences and expertise of all the participants to identify best practices, as well as areas for improvement, and thus achieve as successful a response to an emergency as possible.

TabletopX blog posts are written by APCO’s Government Relations team and special guests.

New FCC Spectrum Rules Put Public Safety Communications at Risk

By Jeff Cohen

APCO recently filed two formal petitions with the FCC regarding a major change it made to regulations that govern the use of spectrum that is relied upon by public safety. One was a Petition for Reconsideration, urging the FCC to repeal the new rules and fix numerous problems; the other was a Petition for Stay, asking the FCC to prohibit anyone from taking advantage of the new rules while the Petition for Reconsideration is under review. Together, these petitions are just one step short of challenging the FCC’s rules in federal court. This is a rare move for APCO, but it was necessary given the real risk of irreparable harm to public safety.

How Did We Get Here?

In April, the FCC made a major change to its rules governing the 6 GHz band. The goal was to make more spectrum available for unlicensed use to support things like “next generation Wi-Fi.” To do this, the FCC decided to open up a large pool of spectrum in the 6 GHz band, which is predominantly used for licensed point-to-point microwave links. Several stakeholders, including multiple public safety organizations, voiced concerns with the FCC’s plan for sharing the 6 GHz band.

Public safety agencies extensively use the 6 GHz band for mission critical systems that support operational needs such as dispatching first responders and maintaining land mobile radio communications during incidents. Disruption to these systems could have dire consequences. Assistance to the public could be delayed. Law enforcement officers, emergency medical technicians, and firefighters might lack the ability to transmit emergency calls for assistance and other information essential for protecting life and property. Other current users of the 6 GHz band use links for coordination of railroad train movements, control of natural gas and oil pipelines, management of electric grids, and telephone service.

These microwave links require prior frequency coordination and an FCC license to operate, and they’re extremely dependable, on the order of 99.999% reliability or better (which means less than ~5 minutes of downtime a year). If the 6 GHz band becomes unreliable for mission critical communications, public safety agencies will not have good options. In the best-case scenario, public safety agencies would have to pay to switch to fiber connections or less suitable microwave links that would likely involve much higher costs (and it’s not clear that such options would even be available). That’s not fair to public safety, and there’s a way to share spectrum without so much risk.

In APCO’s advocacy to the FCC, we made clear that we weren’t completely opposed to the idea of public safety sharing spectrum with unlicensed users, provided that the spectrum sharing approach was thoroughly evaluated and proven effective before putting public safety communications at risk. That’s not what happened. In fact, the FCC adopted the new rules without directly addressing public safety’s concerns at all, which federal judges have said the FCC is required to do by law.

A High-Level Description of the FCC’s New Rules

The FCC’s new rules allow operation of unlicensed “standard power” and “low power” transmitters (“access points”). The expectation is that hundreds of millions of these devices would eventually be used for hotspot networks, rural broadband, and Wi-Fi routers in homes, schools, businesses, etc. The FCC established different rules for the two types of access points to reduce the likelihood of interference to licensed users like public safety.

For standard power devices, the ability to prevent interference depends on an automated frequency coordination (AFC) system’s ability to assign frequencies to unlicensed access points by defining exclusion zones that restrict transmissions in locations that could interfere with licensed users. The AFC is a relatively new concept that has never been used for sharing spectrum with public safety. One of APCO’s basic concerns has been that a new spectrum sharing tool like the AFC needs to be thoroughly tested before being launched for real-world use where there could be harm to public safety. This would be an entirely reasonable approach. Yet, before testing to prove this kind of spectrum sharing can work, the FCC decided to allow deployment of these new devices, and it’s not clear what testing requirements will ever be imposed. To make matters worse, there are several major gaps in the plan for how an AFC would work that make it unlikely that it will be able to prevent interference to public safety.

For low power devices, there wouldn’t even be an AFC that would attempt to prevent unlicensed access points from using the same frequencies being used by public safety. Instead, the FCC made a rule that these devices stay indoors, and the FCC assumes they’ll be too weak to cause interference. APCO expressed concern that nothing will prevent people from using these devices outdoors on balconies and rooftops, and even if the devices stay indoors, we don’t necessarily agree with the assumption that building walls and windows will prevent the signals from causing interference.

But there’s even a more fundamental problem with the entire FCC scheme. Instead of establishing requirements we would expect to ensure that interference caused to public safety is promptly identified and eliminated, the FCC abandoned this obligation in favor of only “encouraging” the very same unlicensed companies that are benefiting from the new rules to voluntarily address these key issues. When interference occurs, the only information available to public safety agencies will be that the microwave link has stopped providing the mission critical communications it was designed for. These systems are not designed to detect interference and are incapable of attributing it to a particular source. Attempting to identify the source(s) of interference is a long, resource-intensive, expensive process – particularly when dealing with unlicensed devices – and many questions remain regarding how to promptly eliminate interference after the source has been identified.

APCO raised many concerns during a formal public comment period and after the FCC released a draft of the rules it planned to adopt. For whatever reason – maybe the significant amount of debate on technical issues, maybe the intense pressure from companies like Apple, Facebook, Google, and Microsoft that were lobbying for the new rules – the Commission overlooked public safety.

If the rules move forward uncorrected, public safety will suffer irreparable harm. Protecting public safety communications will be more difficult every day that the rules are in effect, and eliminating the hundreds of millions of problematic devices after they have begun operating will be nearly impossible.

What Happens Next?

This is the beginning of what could be a very long process. Ideally, the FCC would immediately hit Pause on the new rules and rethink the approach to protecting public safety like APCO requested. The FCC also has the discretion to just deny APCO’s petitions. In either case, we will remain engaged and pursue a solution that meets the needs of public safety.

Remaining Vigilant

While we’ve been dealing with this problem in 6 GHz, we’ve also been monitoring a separate proceeding to address the 4.9 GHz band, which is a much smaller pool of spectrum that is dedicated to public safety. In 2018, the FCC proposed rule changes that would make the 4.9 GHz band more useful to public safety agencies in many ways, including making the band more flexible for microwave links. This was something APCO supported, along with other aspects of the proposal. We’ve been waiting for years for the FCC to revise its rules to make the 4.9 GHz band more useful for public safety. Unfortunately, there have been rumors that the FCC is considering reallocating this band, which would be a blow to public safety. If the 6 GHz band becomes less reliable, it will be even more important for public safety to have dedicated 4.9 GHz spectrum to turn to.

Expect to hear more about APCO’s efforts to protect public safety spectrum in the near future.

About the TabletopX Blog

A “Tabletop Exercise,” often shortened as “TTX,” is a discussion-based exercise frequently used by emergency planners. Led by a facilitator using a planned scenario, TTX participants describe the actions they would take, and the processes and procedures they would follow. The facilitator notes the players’ contributions and ensures that exercise objectives are met. Following the exercise, the facilitator typically develops an after-action report and conducts a debrief discussion during which players and observers have an opportunity to share their thoughts, observations, and recommendations from the exercise without assigning fault or blame.

Many of the attributes of a TTX are the same we seek to promote in the discussion generated from our blog posts. The goal is to capitalize on the shared experiences and expertise of all the participants to identify best practices, as well as areas for improvement, and thus achieve as successful a response to an emergency as possible.

TabletopX blog posts are written by APCO’s Government Relations team and special guests.

Federal Report Estimates Extent of Interoperability Challenges for 9-1-1

This won’t come as news to anyone working in public safety communications, but 9-1-1 faces significant interoperability challenges.  While ECCs are generally able to transfer basic voice 9-1-1 calls to neighboring ECCs, they often cannot share other types of communications and data important for emergency response.

What might be surprising is that ECCs face these interoperability challenges even in areas that are making progress deploying Next Generation 9-1-1 technologies.  Perhaps that is why there has been increased attention to solving interoperability for 9-1-1 in recent years.  As consumers, we take for granted that two people can communicate with all kinds of data, regardless of where they live, which companies provide the connectivity, the types of phones they’re using, or even whether one person is on a phone while the other is using a tablet.  You would think that modernizing 9-1-1 technology would result in similar benefits, but that’s not proving to be the case.  Now, a federal report helps to quantify the extent of interoperability problems in 9-1-1.

At APCO’s suggestion, the Federal Communications Commission directed the Communications Security, Reliability, and Interoperability Council (CSRIC) VII to survey the current state of interoperability for the nation’s 9-1-1 systems.  CSRIC’s mission is to provide recommendations to the Commission on a variety of topics.  On March 17, CSRIC adopted a “Report on the Current State of Interoperability in the Nation’s 911 Systems.”  You can download the report on the CSRIC webpage.

The report describes the degree to which ECCs are able to share voice 9-1-1 calls, location data, SMS text-to-911, CAD data, and other types of data with other ECCs and (where appropriate) with emergency response providers.  It relied on publicly available data, as well as responses to surveys distributed by APCO and the National Association of State 9-1-1 Administrators.  APCO’s Chief Technology Officer served on the working group that developed the report.

This graphic from the report tells the story.  Red and orange are bad – they represent zero or limited interoperability between ECCs for each type of communication/data.  Green and blue are good – they represent interoperability statewide and interstate.  There’s a lot more red and orange here than blue and green.  In fact, unless you’re talking about the ability to transfer voice calls, ECCs are more likely than not to have an interoperability problem.  That shouldn’t be the case.

ECCs should be able to receive location information with every transferred 9-1-1 call.  They should be able to transfer texts to 9-1-1, CAD data, and other useful data relevant to an incident.  The red and orange in this graphic represent obstacles to emergency response for public safety telecommunicators, police officers, EMTs, and firefighters.  An already difficult job becomes harder.

What’s standing in the way of interoperability for 9-1-1?  Proprietary technology.  No doubt that the public safety communications community has benefited from some technology providers, including a number of newcomers, who are truly driven to introduce new innovations and make a difference.  But we need to accept the reality that interoperability is a problem and work toward a solution.

One of APCO’s strategies has been to provide a Sample RFP Template for NG9-1-1 Capabilities to assist 9-1-1 directors and authorities with their procurement activities, whether for a statewide or local effort.  The RFP Template covers all aspects of a complete NG9-1-1 deployment, regardless of the stage any state or locality is in concerning the transition to NG9-1-1.  It offers recommendations, guidance, and specific operational requirements toward achieving several goals:

  • Achieving interoperability among NG9-1-1 systems regardless of technology or jurisdiction;
  • Promoting competitive and innovative solutions;
  • Enabling the most cost-effective and operationally efficient solutions; and
  • Ensuring these solutions include more than just an upgrade from analog based voice-only systems to true IP-based, multimedia capable systems and architectures.

Another strategy has been to advocate for federal funding to support the transition to NG9-1-1 nationwide, with requirements on funding recipients to achieve and maintain interoperability.  This approach aligns with legislation that was introduced last year in the House and Senate that would create a $12 billion grant program for NG9-1-1.  It’s worth noting that the definition of interoperability used in that legislation is identical to the definition in the CSRIC report.

Thanks to the FCC’s willingness to examine interoperability for 9-1-1 and the work of CSRIC’s members, we’re in a better position to solve this problem.  APCO will continue working with policymakers at the Commission and Congress and pursuing every opportunity to ensure that ECCs can seamlessly exchange 9-1-1 calls and related data with other ECCs and on to responders in the field, regardless of jurisdictional boundaries, service provider, or other factors.

 

About the TabletopX Blog

A “Tabletop Exercise,” often shortened as “TTX,” is a discussion-based exercise frequently used by emergency planners. Led by a facilitator using a planned scenario, TTX participants describe the actions they would take, and the processes and procedures they would follow. The facilitator notes the players’ contributions and ensures that exercise objectives are met. Following the exercise, the facilitator typically develops an after-action report and conducts a debrief discussion during which players and observers have an opportunity to share their thoughts, observations, and recommendations from the exercise without assigning fault or blame.

Many of the attributes of a TTX are the same we seek to promote in the discussion generated from our blog posts. The goal is to capitalize on the shared experiences and expertise of all the participants to identify best practices, as well as areas for improvement, and thus achieve as successful a response to an emergency as possible.

TabletopX blog posts are written by APCO’s Government Relations team and special guests.

2020 Legislative Priorities

By Jeff Cohen

We just started a new year, but there are only a few months left to achieve a number of public safety legislative objectives before Congress enters into election mode.

Click on the topics listed below to read background info and talking points for raising these matters, especially if you have plans to visit with your representatives in Washington, DC, or perhaps during a local meeting or ECC visit. APCO will continue to push for progress on these important public safety matters, but elected officials need to hear from their constituents, too. You can always reach us by email for updates or to discuss any of these issues: [email protected].

 

Reclassification as 'Protective Service Occupations'

APCO has long been championing a needed change to the federal government’s Standard Occupational Classification (SOC) system, which is managed by the U.S. Office of Management and Budget (OMB). The SOC is used by federal agencies to categorize occupations across the U.S. for statistical purposes, and its classification of 9-1-1 professionals is completely wrong. OMB must correct the SOC to reclassify public safety telecommunicators (PSTs) from the “Office and Administrative Support” category to the “Protective Service” category.

In my experience, this is one of the most logical and straightforward asks we could ever make. The SOC is supposed to classify occupations by the work performed. PSTs protect and save lives every day. The SOC’s Protective Service category is very broad – including law enforcement officers, lifeguards, casino gambling monitors, playground monitors, and parking enforcement officers (aka – “meter maids”). Reclassifying PSTs into the Protective Service category is entirely appropriate and would lead to more accurate data for federal agencies that utilize the SOC. Yet OMB staff have refused to fix the classification. For some reason, they’re unfazed by how wrong it is to consider the work performed by PSTs as similar to the clerical work of secretaries and taxicab dispatchers.

We have been successful in having legislation, the 9-1-1 SAVES Act, introduced in Congress that would require OMB to fix its mistake. We have strong bipartisan support, but we should continue to add more cosponsors. If you haven’t already done so, or not yet asked everyone you know, Contact your U.S. Rep/Senator.

It is also important to press key Members who control the 9-1-1 SAVES Act’s progress through the required committees:

Outside of Congress, there remains the option of getting the attention of OMB or the President himself. OMB has complete discretion to correct its own error any time it wants. Contact OMB.

We will continue to try to make inroads with all of these key actors in finally getting 9-1-1 professionals the recognition and respect they deserve by reclassifying PSTs into the SOC”s “Protective Service” category.

Talking Points

  • The federal government’s classification of 9-1-1 professionals as clerical workers is wrong and fails to recognize the lifesaving work performed by our nation’s 9-1-1 call-takers and dispatchers (collectively known as Public Safety Telecommunicators).
  • Congress can fix this by passing the 9-1-1 SAVES Act, which would direct the Office of Management and Budget to update the Standard Occupational Classification (SOC), a vast catalog of occupations relied upon by federal agencies for statistical purposes.
  • The current version of the SOC categorizes Public Safety Telecommunicators as administrative/clerical in nature, in the same group for secretaries, office clerks, and taxicab dispatchers, which is inaccurate and a disservice to the lifesaving work and dedication of 9-1-1 professionals.
  • Public Safety Telecommunicators should be categorized as Protective Service Occupations, which includes a broad range of occupations: lifeguards, gambling surveillance officers, fish and game wardens, parking enforcement workers, firefighters, and playground monitors, among others.
  • Occupations are supposed to be classified according to the nature of the work performed. Every day, Public Safety Telecommunicators provide lifesaving emergency medical instruction, deal with suicidal persons, assess scene safety for arriving responders, and play a critical role for active shooter incidents and a variety of other emergencies.
  • The 9-1-1 SAVES Act would correct the federal classification by appropriately grouping Public Safety Telecommunicators with other “protective” occupations. As a result, federal statistical activities would be more accurate.
  • Reclassifying these professionals as Protective Service Occupations has broad support from the 9-1-1 community and others familiar with the lifesaving work of Public Safety Telecommunicators, and bipartisan support in the House (H.R. 1629: 113 cosponsors) and Senate (S. 1015: 25 cosponsors).
  • This is a simple, zero-cost solution that would have no direct impact on salaries or benefits.
  • Reclassification is common sense, and about getting Public Safety Telecommunicators the recognition they deserve for the work they do every day to protect and save the lives of the public and first responders.

If you get any tough questions or even opposition, please let us know. So far there has not been a question or concern that we don’t have a strong rebuttal to.

Next Generation 9-1-1

While many areas are making progress, APCO has been concerned that the lack of desperately needed funding, combined with the lack of interoperability and multimedia capabilities in early “next gen” deployments, has made progress towards NG9-1-1 slow and uncertain.

Last year, APCO collaborated with other public safety groups to formulate legislation that would establish a significant one-time federal grant program to achieve Next Generation 9-1-1 nationwide.

The Next Generation 9-1-1 Act of 2019 is bipartisan in the House. An identical version has been introduced in the Senate. It’s an excellent bill that would:

  • Preserve state and local control of 9-1-1 and responsibility for ongoing funding;
  • Establish a $12 billion federal grant program (the cost came from a federal study);
  • Provide a modern, comprehensive definition of NG9-1-1 that would lead to a complete, end-to-end capability for 9-1-1 emergency communications centers (ECCs) to receive, process, analyze, and share all forms of communications including multimedia;
  • Require interoperability, to ensure that ECCs can share all incident data with other ECCs and responders in the field, regardless of vendor, equipment, jurisdictional boundaries, etc.; and
  • Require states to develop a sustainable funding mechanism so that ECCs continue to have the resources needed for operations, maintenance, and upgrades once the federal grant program expires.

Talking Points

  • The communications technologies available to the general public significantly outpace what is available to 9-1-1. As a result, consumer expectations concerning the capabilities of the nation’s 9-1-1 systems are far from reality.
  • Congress should pass the Next Generation 9-1-1 Act of 2019 (H.R. 2760; S. 1479), which provides funding and accomplishes several other important goals for NG9-1-1.
  • Federal funding is needed to quickly and efficiently modernize ECCs across the country for the benefit of public safety and national security, and to have the U.S. serve as a model for the rest of the world. At the same time, the Act would preserve state and local control over 9-1-1 operations, as well as responsibility for ongoing costs.
  • The Act’s comprehensive definition of NG9-1-1 will lead to a complete solution and uniform experience throughout the country.
  • A requirement for interoperability is essential to effective and efficient emergency response and will help drive innovative, competitive, and cost-effective solutions.
  • 9-1-1 is among the nation’s most critical infrastructure. Congress should consider standalone funding sources (such as spectrum auction revenue) and include NG9-1-1 funding in any major infrastructure package.
T-Band (470-512 MHz)

Spectrum known as the “T-Band” is used in a number of metropolitan areas to support critical public safety communications and provide regional interoperability among first responders. Current federal law mandates that the FCC begin a process to relocate public safety users and auction the T-Band for commercial use by February 2021. This provision of law was enacted as part of the 2012 legislation that created FirstNet. While at the time it may have been expected that public safety would have other options for mission critical radio communications, that has not turned out to be the case.

There are identical bills in the House and Senate that would change the law so public safety can keep using the T-Band. Public safety should not have to make any “trades” or other concessions because, according to a federal study, moving current users off the T-Band would actually cost much more than the potential value of the spectrum for commercial use.

Talking Points

  • 9-1-1, law enforcement, fire, and EMS agencies depend on spectrum known as the T-Band in a number of major metropolitan areas to meet their mission-critical communications needs.
  • Congress should pass the Don’t Break Up the T-Band Act (S. 2748; H.R. 451) to repeal an existing law that would require public safety to vacate this spectrum. Public safety agencies operating in the T-Band would be left with few if any viable alternatives.
  • A federal study showed that the cost of relocating current T-Band users would be much greater than the potential revenue from auctioning the spectrum. Thus, letting public safety keep the T-Band would have no impact on the federal budget.
  • Spectrum is not a luxury for public safety, but rather a necessary tool to carry out their mission to save and protect lives. Public safety should not have to make any concessions.
9-1-1 Fee Diversion

States that assess 9-1-1 fees on phone bills should spend this revenue on 9-1-1. Unfortunately, some states persistently raid these funds for other purposes. This practice not only harms 9-1-1 professionals, many of whom already struggle with insufficient funding and staffing, but is deceptive and unfair to those who pay these fees. Pursuant to federal law, the FCC annually reports on the collection and use of 9-1-1 fees, which mostly has the purpose of “naming and shaming” states that engage in 9-1-1 fee diversion. This has resulted in at least some diverter states changing their ways.

There have been some efforts in Congress to help prevent 9-1-1 fee diversion. However, there does not yet seem to be an effective solution to the problem. The best approach so far has been to prevent diverter states from being eligible for federal 9-1-1 grants. Absent any real “pain” (such as loss of major grant funding) there is little chance that states will put an end to this very unfortunate practice.

Talking Points

  • States that divert 9-1-1 fees for other purposes do a disservice to 9-1-1 professionals and the citizens they serve.
  • A significant federal grant program, such as the Next Generation 9-1-1 Act of 2019, that would disqualify states that divert 9-1-1 fees, could be very helpful for ending 9-1-1 fee diversion.
  • Ending fee diversion is important but is not a solution for meeting the funding needs of states and localities to make a full transition to Next Generation 9-1-1 because the funding needed for NG9-1-1 far exceeds the amount of fees being diverted.
  • Ultimately, the focus should be on ensuring 9-1-1 has the funding it needs, whatever the source of that funding.
6 GHz Microwave Band

Public safety heavily uses and relies upon the 6 GHz band for fixed point-to-point microwave links essential to public safety services. The Wi-Fi (unlicensed spectrum) industry has made a strong push at the FCC to require public safety and other incumbents to share their 6 GHz spectrum. The FCC has proposed to allow sharing, and would to some extent require a new frequency sharing technology to attempt to prevent interference to public safety users. The problem is whether the sharing technology would apply to all new sharing of the spectrum and whether the technology can be proven in advance to truly prevent interference and detect and eliminate any sources of interference that occur. APCO has weighed in to express significant concern with the FCC’s proposal.

While this proposal remains pending at the FCC, this issue has also gotten the interest of Congress. No legislation has been introduced yet, but it’s possible that Congress would take action before the FCC.

Talking Points

  • Public safety makes heavy use of the 6 GHz band to support critical 9-1-1 dispatch and first responder radio communications.
  • Outside of the prospect of using the federal 7 GHz band, public safety has no other spectrum options to satisfy these communications needs.
  • If the 6 GHz band is opened for sharing, the spectrum sharing technology must be proven to work before putting it to use with hundreds of millions of unlicensed devices that could cause interference to public safety communications.
  • There is no turning back once unlicensed devices are permitted to share this spectrum – if interference occurs that cannot be immediately addressed, there will be irreparable adverse consequences to emergency communications and response.

About the TabletopX Blog

A “Tabletop Exercise,” often shortened as “TTX,” is a discussion-based exercise frequently used by emergency planners. Led by a facilitator using a planned scenario, TTX participants describe the actions they would take, and the processes and procedures they would follow. The facilitator notes the players’ contributions and ensures that exercise objectives are met. Following the exercise, the facilitator typically develops an after-action report and conducts a debrief discussion during which players and observers have an opportunity to share their thoughts, observations, and recommendations from the exercise without assigning fault or blame.

Many of the attributes of a TTX are the same we seek to promote in the discussion generated from our blog posts. The goal is to capitalize on the shared experiences and expertise of all the participants to identify best practices, as well as areas for improvement, and thus achieve as successful a response to an emergency as possible.

TabletopX blog posts are written by APCO’s Government Relations team and special guests.

FCC on the Verge of a Major Setback to 9-1-1 Location Accuracy

By Jeff Cohen

This Friday, the FCC will vote on new rules that are supposed to ensure that first responders can locate someone who calls 9-1-1 from inside a multi-story building.  Unfortunately, the rules will not only fail to produce meaningful improvements, the FCC will let wireless carriers continue to avoid pursuing much better options for 9-1-1 location accuracy.

Imagine a 9-1-1 professional receiving a call from someone having a heart attack or stroke in a high-rise apartment building or office.  Seconds matter.  The caller passes out before reporting his location, and it’s the 9-1-1 dispatcher’s job to make sure paramedics arrive quickly enough to save his life.  The FCC requires the wireless carrier to provide the caller’s horizontal location (usually “x/y” GPS coordinates), which the 9-1-1 center uses to plot a street address for the building.  The FCC has similar rules that, starting in 2021, would require the wireless carrier to provide vertical (“z-axis”) information about the caller’s location.  The goal was for 9-1-1 to know the floor number if not the actual apartment number of the caller.  But that’s not going to happen anymore if the FCC adopts these new rules.  Instead, the FCC will require the wireless carrier to deliver an estimated height in terms of a technical measurement of altitude called “height above ellipsoid” (HAE).  If you’re already thinking this doesn’t make sense, you’re right.  Whether and how 9-1-1 could use this information – and what information carriers should provide instead – to save the caller’s life is a subject of fierce debate.

Dozens of 9-1-1 center directors have weighed in directly with the FCC, asking that wireless carriers be required to provide better location information for 9-1-1 than what the FCC has proposed.  APCO, the world’s largest association of public safety communications professionals (who work in or manage 9-1-1 centers), has been voicing a variety of concerns on behalf of 9-1-1 experts across the country.

Problem #1: The FCC’s Approach Isn’t What 9-1-1 Professionals Want

“Height Above Ellipsoid” (HAE) is a raw technical format for altitude.  While trying to save a life, the 9-1-1 dispatcher would receive something like “101 Main Street; 76 meters, +/- 3 meters HAE” instead of “101 Main Street, 7th floor” or “101 Main Street, Apt. 702.”  When someone’s life is at stake, there is no question about which kind of information would be more effective.  The largest 9-1-1 centers in the country have said that even they don’t have the resources to turn “HAE” data into actionable information because it would require significant time and money to create and maintain 3D maps for the millions of buildings across the country, and then specialized software to translate the HAE readings onto the maps.

The FCC assumes that responders in the field – police, fire, EMS – would have devices and apps that provide HAE measurements that could be matched to the caller’s.  This, too, 9-1-1 experts have said is unacceptable.  It adds extra time to the response while responders go up and down the stairs or elevator attempting to match their HAE measurements to the HAE reported to 9-1-1.  Plus, the FCC’s rules will only require accuracy of +/- 3 meters (equivalent to 10 feet) for the 9-1-1 caller’s HAE measurement (and only for 80% of calls), and the rules don’t take into account the additional error that could arise from responders’ devices producing their own HAE measurements.  Google submitted a letter to the FCC that has a picture that explains this problem well:

And in some emergencies – ex: police have their guns drawn or firefighters are in a burning building – it is hard to imagine how a responder would be able to safely look at a device while trying to navigate to the caller.

Problem #2: The FCC’s Rules Don’t Ensure Improvements in the Real World

APCO has repeatedly cautioned the FCC that the new rules might not produce the expected benefits.  Carriers will be able to comply with the rules through technicalities, even though many handsets will not provide vertical location information and major handset manufacturers might refuse to support the specialized location technologies that are necessary to meet the FCC’s accuracy requirements.  The FCC is mostly ignoring these concerns but has unspecific plans to take further action sometime after the new rules are in place.

Problem #3: The FCC is Letting Carriers Ignore Better Options

Instead of focusing on getting 9-1-1 the best possible location information, the FCC is ignoring the advice of 9-1-1 experts, taking an unnecessarily narrow approach, and giving the wireless carriers a pass.  The FCC’s rules should be moving us closer to the best possible location information for 9-1-1, which would be the street address of the building plus the apartment or office number (or whatever else is needed to locate the caller).  If it’s too hard to identify the apartment number, the carriers should at least provide the floor number as a starting point.  That’s what APCO and 9-1-1 center directors are asking for.  But if the FCC’s rules allow carriers to take the easy way out and send a raw altitude (HAE) estimate, we’ll probably never get that better location information.

But the FCC is blindly pressing forward.  They’ve lined up support, playing the political “beltway game,” while ignoring concerns that its order will fail public safety.

Why is the FCC Ignoring 9-1-1 Experts?

Lobbying by specialized vendors.  Unsurprisingly, some of the loudest supporters of the FCC’s proposal – the vendors who provide HAE solutions – will benefit from it financially.  Only one company, maybe two, demonstrated the ability to meet the FCC’s proposed vertical accuracy requirements.  One of those companies, NextNav, has been marketing a solution that is aimed at solving a different problem – tracking the locations of responding police, fire, and EMS officials.  There’s obviously a great interest in being able to track responders, for example, to help locate incapacitated firefighters.  NextNav staged a demo for those in the fire service years ago, under ideal conditions with mocked up devices and software the first responders might not ever have.  But there are many flaws with NextNav’s technology – perhaps most notably that Apple refused to even permit testing of it on iPhones and has expressed concern over privacy and battery drain associated with the technology.

Forgetting to focus on the 9-1-1 location problem.  No one disagrees that 9-1-1 should receive the most accurate and actionable location information possible.  The disconnect seems to be that APCO is pressing the FCC to require more of the carriers and believes that the FCC’s 9-1-1 rules should focus on the best outcome for 9-1-1 calls, rather than try to provide a responder tracking solution.  Besides, the government has separate efforts underway to improve responder location tracking, including FirstNet and a recently-announced $8M R&D program.  The FCC has no business shirking its responsibility for solving a 9-1-1 problem and departing from years of its own precedent to pivot to a completely different purpose.

Distractions of wishful thinking.  There are a few “true believers” in the FCC’s proposal who think that the best possible information for locating a 9-1-1 caller is an x/y/z coordinate, meaning a 3D point in space.  We’ll just have to agree to disagree.  Part of the disconnect is that even the largest 9-1-1 centers in the country have said they don’t have the resources to create 3D maps of every building and specialized software to visualize the caller’s location.  (Many 9-1-1 centers are struggling just to keep up their staffing levels.)  9-1-1 centers shouldn’t have to shoulder this responsibility when the FCC’s rules are all about imposing requirements on the carriers and there are more efficient options.  The other part of the disconnect seems to be a concern that if 9-1-1 centers could receive estimated floor levels that are sometimes incorrect, responders might be worse off than if they were relying on coordinate-based information.  APCO has pointed out that, regardless of whether the information provided is a floor level or x/y/z coordinate, 9-1-1 centers will need supplemental information that helps them understand how accurate that estimated location information is and what to do if it’s wrong.

Narrowmindedness regarding technologies that exist today.  Some have also argued that it’s impossible to estimate the floor level of a 9-1-1 caller.  We know it’s possible.  (Google is even on the record urging the FCC to modify the proposed rules to allow the provision of a floor label rather than mandate sole reliance on measurements of HAE.)  The disconnect seems to be that there’s a difference between being able to convert a z-axis elevation to a floor label – which requires resources that do not exist – and being able to provide z-axis information that includes a floor label – which is possible today.  (In a separate letter, Google confirmed that its approach to deriving a floor label would not require converting an estimated altitude in terms of HAE.)  There are several ways carriers could deliver a floor level to 9-1-1.  They could partner with a company like Google, or they could leverage their own in-home products (like Internet access, 5G products) and a host of other viable methods.

The silence of the wireless carriers.  The wireless carriers have been suspiciously quiet (except for a subtle refrain that complying with the FCC’s rules might not be possible).  Why?  Because they are being let off the hook.  Maybe they will hire the specialized vendors and pursue other options for improving 9-1-1 location accuracy, but I bet they won’t.  My guess is they’re biding their time and hoping that Google and Apple will solve the problem for them.

It Gets Worse

It’s hard to understate the problems with the FCC’s proposal, but APCO has been raising alarm bells about several compounding factors (which you would think would motivate the FCC to reconsider its approach):

  1. The rules do not apply to 9-1-1 calls nationwide – only to the 25 largest metropolitan areas in 2021 and then the 50 largest in 2023. So if you happen to have an emergency in Atlantic City, Gainesville, FL, or any multi-story structure outside of the 50 most populous areas, hopefully the FCC considers solving indoor location accuracy for you at some point.
  2. The FCC has not been clear about which types of cellphones the new rules apply to but it’s obvious from the proposal that many handsets will not even be covered by the rules.
  3. Due to loopholes in how the FCC’s rules work, the new rules would effectively remove incentives for wireless carriers to provide more detailed location information such as an apartment number or at least the floor number of a 9-1-1 caller.

APCO has asked the FCC to think long-term (beyond lining up uniforms and putting out a celebratory press release about supposed improvements for public safety), and consider that no one wants to look back a few years from now and realize that we missed a chance to solve the critical problem of locating those in desperate need of emergency assistance.  The wireless carriers promised the FCC and public safety much better and must be held accountable.  The FCC can and must do better.

About the TabletopX Blog

A “Tabletop Exercise,” often shortened as “TTX,” is a discussion-based exercise frequently used by emergency planners. Led by a facilitator using a planned scenario, TTX participants describe the actions they would take, and the processes and procedures they would follow. The facilitator notes the players’ contributions and ensures that exercise objectives are met. Following the exercise, the facilitator typically develops an after-action report and conducts a debrief discussion during which players and observers have an opportunity to share their thoughts, observations, and recommendations from the exercise without assigning fault or blame.

Many of the attributes of a TTX are the same we seek to promote in the discussion generated from our blog posts. The goal is to capitalize on the shared experiences and expertise of all the participants to identify best practices, as well as areas for improvement, and thus achieve as successful a response to an emergency as possible.

TabletopX blog posts are written by APCO’s Government Relations team and special guests.

New Progress for Getting Wireless 9-1-1 Calls to the Right ECC

By Mark Reddish

Apple recently announced that devices running iOS 13 will enable location fixes quickly enough to be used for routing wireless 9-1-1 calls.  This is a significant development because routing 9-1-1 calls based on the device’s estimated location, rather than relying on the location of the cell sector serving the caller, will allow more calls to be delivered to the correct emergency communications center (ECC) on the first try.  (Google has reportedly enabled a comparable capability for Android devices.)  This will make it possible to decrease emergency response times, and thereby save lives.

Background on “Misrouted” Wireless 9-1-1 Calls

When someone calls 9-1-1 from a cellphone, the call is sometimes delivered to the wrong ECC.  These “misroutes,” are not necessarily due to a technical error in the routing process.  They can occur because the 9-1-1 system is configured to route wireless calls to an ECC based on the cell tower sector that handles the call, which may not lead to the appropriate ECC for the caller’s actual location.  Misroutes occur more frequently near ECC service boundaries and in areas where multiple jurisdictions are in close proximity, such as the Washington, DC, region.

In March 2018, the Federal Communications Commission (FCC), in a Notice of Inquiry, sought public comments on how frequently misrouting occurs for wireless 9-1-1 calls, how it impacts emergency response, and how to prevent it.  Quantifying the scope of the problem is difficult because ECCs may have different policies and capabilities for transferring as well as tracking misrouted calls.  As part of the FCC’s public comment process, APCO made clear that the delays in response can mean the difference between life and death.  Further, the problems created by misrouted 9-1-1 calls are made worse by the fact that – despite the sophistication of modern communications technology – even basic call transfers (regardless of the reason to transfer a call) are not universally possible.  There are still instances in which ECCs have to manually call each other to convey the information about an emergency.  Even when ECCs are able to transfer the voice portion of a 9-1-1 call, they too often cannot include ANI and ALI, let alone data contained in the computer-aided dispatch system.

Eliminating misroutes is challenging, in part, because the network routes a wireless 9-1-1 call within a matter of seconds of the caller pushing “send,” but estimating the location of a caller historically required 20-30 seconds.  That’s changing.  Modern location technologies are making it possible to estimate a device’s location within seconds, at least with enough accuracy for routing purposes.  According to Apple’s announcement, iOS 13 offers wireless carriers the option to enable location-based routing (LBR) and to fall-back to the cell sector routing mechanism if a device-based location estimate cannot be provided quickly enough.

A Rough Estimate of the Impact of Misrouting

To estimate the impact of misrouting, we can modify an equation used by the FCC to estimate the impact of improving the accuracy of location information delivered with 9-1-1 calls.1  The FCC looked at how many 9-1-1 calls for ambulances resulted in deaths that could have been prevented by a one-minute reduction in response time, the percentage of wireless 9-1-1 calls that would experience a one-minute reduction in response time with improved location accuracy, and the percentage of 9-1-1 calls that come from wireless devices.  Based on this, the FCC estimated more than 10,000 lives a year could be saved by improving 9-1-1 location accuracy.

For estimating the impact of misrouted 9-1-1 calls, the inputs for the equation are slightly different.  We’ll still use 80% as the percentage of 9-1-1 calls from wireless phones, but we insert new numbers for the percentage of misrouted calls and the number of lives that could be saved by eliminating misroutes.  A study by the Alliance for Telecommunication Industry Solutions estimated that an average of 12% of wireless calls are misrouted nationwide.[2]  According to a study cited by the FCC, transferring a call between ECCs could add an average of 40 seconds to the call time.  Thus, compared to the FCC’s estimate of lives saved by improving 9-1-1 location accuracy, a larger percentage of calls are at issue, but the reduction in response time per call is smaller.

 

The FCC ‘s Math for 9-1-1 Location Accuracy   The Math for Location-based Routing
0.8 % 9-1-1 calls from wireless   0.8 % 9-1-1 calls from wireless
0.05 % of wireless 9-1-1 calls that would see a one-minute reduction in response from improved location info   0.12 ATIS estimate of % of misrouted wireless 9-1-1 calls
x 253,000 # of deaths that could have been prevented by a one-minute reduction in response time   x 168,575 # of deaths that could have been prevented by a 40 second reduction in response time[3]
10,120 estimated lives saved by reducing response times by one minute by improving location accuracy   16,183 estimated lives saved by reducing response times by eliminating wireless misroutes

This equation estimates that more than 16,000 lives could be saved by eliminating misroutes altogether, but no LBR solution will be perfect.  Therefore, we still need to factor in an estimate of how many misroutes LBR solutions would prevent.  The ATIS study provided estimates of how many misrouted calls could be prevented by various degrees of accuracy in a location-based routing decision.  For a horizontal uncertainty of 300 meters, which is what ATIS recommended for providers of positioning technologies to be used in LBR solutions to strive for, the estimated reduction would be 50%.[4]  Thus, according to a modified version of the FCC’s equation for calculating the impact of 9-1-1 location accuracy improvements, achieving the ATIS recommendation for LBR would save more than 8,000 lives a year.

Of course, this is a rough estimate.[5]  There’s no way to know how many lives could be saved by eliminating “misrouted” 9-1-1 calls, but if we can rely on the FCC’s equation for a reasonable estimate, there should be no shortage of motivation to adopt LBR solutions.

What Happens Next?

More needs to happen before ECCs start seeing the benefits of LBR.  For one thing, wireless carriers need to update their networks to make routing decisions with the device-based location when it’s available, rather than routing based on the cell sector.  Devices and operating systems will need to be modified, similar to Apple’s, to make a quick location available for LBR, and the entire industry should work to improve the accuracy of quick location fixes as well as ALI.  This issue will ultimately return to the FCC for further consideration of creating rules to ensure 9-1-1 calls are routed to the ECC that serves the caller’s location.


[1] See footnotes 70 and 71 of the 2014 Notice of Proposed Rulemaking.

[2] Note, the ATIS report uses the term “sub-optimally routed” to distinguish a network error from the situation in which the network performs how it’s designed but due to inaccurate location information delivers the call to the wrong ECC.  For simplicity and consistency with the FCC proceeding, we’ll use the term “misroute.”

[3] This number was derived from the FCC’s assumptions, based on emergency medical response research, showing that: for 73,706 observed incidents, a one-minute delay in response time caused a mortality increase of 746 deaths (from 4,386 to 5,132 deaths, a 17% increase); the relationship between response time and mortality is linear, meaning that if a one-minute delay causes a 17% increase in mortality, a one-minute decrease could cause a 17% decrease in mortality; and that there are 25 million calls for an ambulance each year.  If the relationship between response time and mortality is linear, a 40 second reduction in response time would save 2/3 the number of lives that a 60 second reduction would: 497 lives per 73,706 incidents (instead of 746 lives).  For 25 million calls for an ambulance, that translates to 168,575 lives that could be saved by a 40 second reduction in response time.

[4] ATIS’s estimates of the percentage of misrouted calls that could be mitigated using an LBR solution were based on findings that if, for example, 81.1% of misrouted calls were within 1,000 meters of the routed ECC boundary, an LBR solution with position estimates with horizontal uncertainty values of 1,000 meters could potentially resolve 19% of misrouted calls.  50 meters of accuracy corresponded to 15.4% of misrouted calls (which means approximately 85% preventable by an LBR solution with 50 meters uncertainty).  It isn’t clear how accurate the quick location from Apple devices will be, but the device-based hybrid location technology used by Apple devices is capable of providing location estimates for an ALI fix that are much more accurate than 300 meters, even for indoor environments in urban areas.

[5] For example, a study by RapidSOS provided estimates that differed from those the FCC relied on in the location accuracy proceeding – a larger percentage of 9-1-1 calls that would be affected by better indoor location technology, but a more conservative estimate of how many lives could be saved by an overall reduction of one minute in response time.  It’s also worth considering that the FCC’s equation only takes into account the potential lives saved for EMS calls, but reducing response times would certainly save lives for other types of 9-1-1 calls.

About the TabletopX Blog

A “Tabletop Exercise,” often shortened as “TTX,” is a discussion-based exercise frequently used by emergency planners. Led by a facilitator using a planned scenario, TTX participants describe the actions they would take, and the processes and procedures they would follow. The facilitator notes the players’ contributions and ensures that exercise objectives are met. Following the exercise, the facilitator typically develops an after-action report and conducts a debrief discussion during which players and observers have an opportunity to share their thoughts, observations, and recommendations from the exercise without assigning fault or blame.

Many of the attributes of a TTX are the same we seek to promote in the discussion generated from our blog posts. The goal is to capitalize on the shared experiences and expertise of all the participants to identify best practices, as well as areas for improvement, and thus achieve as successful a response to an emergency as possible.

TabletopX blog posts are written by APCO’s Government Relations team and special guests.

Quick Updates for the 2019 Annual Conference

By Jeff Cohen, Chief Counsel & Director of Government Relations

APCO’s Annual Conference and Expo is fast approaching.  We have the remaining program updates for the Cutting Edge Developments track to share.  APCO’s Government Relations Office chooses content for this track, and we make a habit of holding one or two sessions open as close to the conference as possible to make sure we’re delivering truly “cutting edge” content.  The new sessions include:

  • The Role of Social Media in Crisis Communications for the ECC
    Sunday, August 11, 10:45 a.m. – 11:45 a.m.
    Hear from the director of the Washington, D.C., Office of Unified Communications Karima Holmes as she discusses the use, benefits, and impacts of social media in Emergency Communications Centers and strategies for executing social media crisis communications and navigating its challenges and limitations.
  • Legislative and Regulatory Issues Impacting APCO Members
    Monday, August 12, 2:00 p.m. – 3:00 p.m.
    APCO’s Senior Counsel Mark Reddish will provide an overview of three legislative/regulatory issues: the 9-1-1 SAVES Act, the Next Generation 9-1-1 Act of 2019, and 9‑1-1 location accuracy, and a panel of 9-1-1 directors will share their views of the real-world impacts.
  • Android ELS: Locating Emergency Calls in a Wireless World
    Monday, August 12, 4:30 p.m. – 5:30 p.m.
    Representatives from Google will discuss improvements to wireless 9-1-1 location accuracy, and how Android Emergency Location Service is delivering more accurate location, both indoors and outdoors, to ECCs.

I can also provide a little more detail on two of my own presentations.  In the Exhibit Hall Presentation Theater on Monday, August 12, 10:30 a.m. – 11:00 a.m., I’ll be providing brief updates on APCO’s top legislative priorities, including reclassifying public safety telecommunicators as “protective service occupations” and securing significant federal funding for NG9-1-1. And for the Cutting Edge track session, “The Ground Truth: Perspectives of 9-1-1 center leaders facing the challenges of evolving technology” (Wednesday, August 14, 10:15 a.m. – 11:15 a.m.), I will have the honor to be joined by:

  • Captain Scott Brillman, Director, City of Baltimore 9-1-1
  • Jason Kern, Executive Director, Southeast Emergency Communications (IL)
  • Maureen Will, Director of Communications, Newtown Emergency Communications Center (CT)
  • Captain Jeremy Hill, Co-Manager and Fire Captain, Amarillo Emergency Communications Center (TX)
  • Daniel Dunlap, 911 Director, Augusta 911 Center (GA)

The annual FCC update in the Cutting Edge track (Tuesday, August 13, 2:45 p.m. – 3:45 p.m.) will benefit from being a short drive from FCC headquarters.  A number of staff from the Public Safety and Homeland Security Bureau will be on hand to give an overview of the Bureau’s work on 9-1-1, emergency alerts, and spectrum issues:

  • David Furth, Deputy Chief
  • Michael Wilhelm, Division Chief, Policy and Licensing
  • Chris Anderson, Division Chief, Operations and Emergency Management
  • Austin Randazzo, Division Chief, Cybersecurity and Communications Reliability
  • John Evanoff, Deputy Division Chief, Policy and Licensing
  • Elizabeth Cuttner, Staff Attorney, Policy and Licensing
  • Nellie Foosaner, Staff Attorney, Policy and Licensing

APCO will also continue the tradition of hosting senior federal government officials throughout the event, which is key because it demonstrates their commitment to understanding and supporting our members’ public safety mission. During the Distinguished Achievers Breakfast, attendees will hear from FCC Chairman Ajit Pai and FirstNet Chair Ed Horowitz, and the Food for Thought Luncheon will feature remarks from FCC Commissioner Jessica Rosenworcel. Finally, as in past years, the Second General Business session will include updates from APCO’s partners at the FCC and DHS: Lisa Fowlkes of the FCC’s Public Safety Bureau, Ron Hewitt of DHS’s Cybersecurity and Infrastructure Security Agency, and John Merrill of DHS’s Science and Technology Directorate.

It’s going to be a great conference. You can click on this link to see the fill list of Cutting Edge Developments track sessions, and be sure to take a look at the new FirstNet track for recent speaker additions as well.

I hope to see you in Baltimore.

About the TabletopX Blog

A “Tabletop Exercise,” often shortened as “TTX,” is a discussion-based exercise frequently used by emergency planners. Led by a facilitator using a planned scenario, TTX participants describe the actions they would take, and the processes and procedures they would follow. The facilitator notes the players’ contributions and ensures that exercise objectives are met. Following the exercise, the facilitator typically develops an after-action report and conducts a debrief discussion during which players and observers have an opportunity to share their thoughts, observations, and recommendations from the exercise without assigning fault or blame.

Many of the attributes of a TTX are the same we seek to promote in the discussion generated from our blog posts. The goal is to capitalize on the shared experiences and expertise of all the participants to identify best practices, as well as areas for improvement, and thus achieve as successful a response to an emergency as possible.

TabletopX blog posts are written by APCO’s Government Relations team and special guests.