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.

What Does Interoperable Mean in the Real World?

By Steve Leese

In the field of public safety, interoperability has several specific meanings that apply to the tools used in our profession.  For instance, fire apparatus hose fittings are commonly standardized so that departments from different jurisdictions can provide mutual aid effectively.  Merriam Webster defines interoperability as the “ability of a system to work with or use the parts or equipment of another system.”  This article will focus primarily on communication tools such as land mobile radio (LMR) and computer aided dispatch (CAD) in addition to illustrating the overall need for an interoperability-based approach to any communications technologies intended for use by public safety.

Emergency incidents can occur anywhere, and do not respect jurisdictional borders.  When this happens, responders from more than one agency have to respond and work together.  Agencies set themselves up for failure and put lives at risk when interoperability is not carefully considered and built into the purchase and implementation of equipment and programs they utilize to communicate, both with the public and with other agencies.

Providing a few real-world examples of problems that public safety faces today may help illustrate how vitally important interoperability is.  The following examples are drawn from a career that has spanned over thirty years as a first responder and a director of two Public Safety Answering Points (PSAPs).

When I was a law enforcement officer, our jurisdiction, like many across the country, was bordered on three sides by another jurisdiction that had a disparate LMR system.  Some LMR systems in the United States are typically referred to as proprietary, meaning that they do not talk to systems of a different brand or frequency range.  Our jurisdiction had such a system, as did those that bordered and responded with us.  During an incident that required multi-jurisdictional response, our only solution was to partner with another patrol vehicle from the neighboring agency and manually relay the necessary information over the air to the disparate system.  This occurred frequently and had the undesirable side effects of taking two scarce patrol units away from the primary task of responding to the incident.  In addition, because communications were relayed, it was easy to miss important information.  This costs time and efficiency and it can put both the responders and the public at risk.

Serving as a communications director, my centers faced a similar challenge to the previous example.  What made it different, was that the officers in the jurisdictions that commonly worked together across a jurisdictional border personally purchased commercial cellphones with a push to talk feature.  While this allowed them to communicate with each other, their solution had many shortcomings: they did not connect to our recording system in the PSAP; they were not monitored so if the responders were using personal phones instead of department radios to communicate emergency information, the communications center would not know about the emergency traffic; and the handsets were not mission critical.  While this solution was problematic at best, the fact that responders tolerated these shortcomings illustrates the level of frustration public safety experiences with the inability to seamlessly connect.

My final case in point is again derived from my time as a communications director.  Because public safety responder jurisdictions sometime overlap PSAP boundaries it became necessary to implement a CAD to CAD solution to dispatch fire department incidents.  When the agencies developed the plan everything seemed simple because both PSAPs purchased CAD from the same vendor, and had the same version running on the same type of equipment.  Imagine our surprise when the vendor required both PSAPs to purchase very expensive interfaces for our CADs to exchange information.  Of course, there were also expensive maintenance contracts for the interfaces every year after we made the purchases.  Ultimately the only options were to pay the price, or spend literally millions of dollars to change vendors.

These examples are not unique.  Every day public safety officials and responders deal with similar issues, and it strains the operations and puts lives in danger.  Less important, but significant, are the burdensome costs associated with connecting disparate systems.  When consumers are faced with an unexpected or undesirable cost, they turn to a competitor.  Public safety agencies don’t have that luxury.  They are typically locked into contracts that package multiple services with proprietary solutions, making a change to a competitor a major expense.

These technology challenges seemed difficult to overcome years ago, but today it is common to see inexpensive commercially available devices that can transfer multimedia seamlessly to disparate devices on different platforms.  If this technology and capability is in the hands of the consumer today, why can’t public safety benefit in a similar way?

The vision for seamless interoperability that I’m trying to explain is described in the APCO P43 report on “Broadband Implications for the PSAP” in the following way:

Fully interoperable voice and data communications allow the units who arrive first on scene to provide up to date, real-time information to additional units responding to the scene regardless of which agency they are from. PSAPs, though they have different CAD and radio systems, can communicate and receive common updates via interoperable, standardized CAD interfaces.

Pushback to this vision demonstrates how entrenched we are in the sometimes regressive traditional thinking.  Approaches that worked in the past will no longer work today.  Engaging the public safety community to help define the problem and providing innovative solutions is essential.  Public safety was not somehow put in this precarious position overnight.  These concerns are not new, and have been real-life concerns for several decades.  Entire careers have started and ended with the attitude that this problem is too large to ever overcome.

While FirstNet offers promise on the responder communications front, and solutions are being deployed to address much of what has been problematic, challenges still remain for the full emergency communications ecosystem, including LMR and 9-1-1 systems.  APCO, with the help of the US Department of Homeland Security and industry partners, will continue to work to fix interoperability problems for LMR.  However, it is critical that we take the same approach to Next Generation 9-1-1 and ensure that it includes requirements for interoperability at all levels.[1]  From the ability of the public to send multimedia communications to PSAPs, to the ability of PSAPs to process and share that data with each other – regardless of vendor, equipment, and jurisdiction – we cannot afford to ignore the importance of interoperability in this realm.  Working together, the public safety community, technology designers, manufacturers, network and service providers, and fellow standards development organizations can assure that both citizens and responders are made safer by addressing this important concern.   As our industry moves toward Next Generation 9-1-1 and IP based systems and services, now is the time to learn from the past and move forward in a positive direction.  Anything less is a disservice to our profession and the public we serve.

[1] APCO President Martha Carter recently authored a member message with an update on efforts to achieve fully interoperable NG9-1-1, including questions to consider asking of NG9-1-1 equipment and service providers.


Steve began work with APCO International in 2013, and served as the Director of Communications Center and 9-1-1 Services until 2020.  Steve has worked in public safety for 34 years as a Telecommunicator and Police Officer in Dearborn, MI, Emergency Management Director, and 9-1-1 Director in Huron and Eaton County MI.  Steve is a University of Michigan graduate, a Marine Corps veteran having served as a Military Police Sergeant, and Presidential Guard at the White House.  Steve is a former President of the Michigan Communication Directors Association.

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.

9-1-1: Nearing 50 Years of Dependable Emergency Assistance

By Martha Carter, President, APCO International

February 16, 2018 will mark 50 years since the first 9-1-1 call was placed in Haleyville, Alabama.  In the decades since, 9-1-1 has become one of the most well-known brands of all time.  Children are taught at the earliest possible age to call 9-1-1 in an emergency.  And the people who answer these calls embody one of the most special, life-saving professions in the world.  I know this from my own experience working nearly 30 years in 9-1-1.

People call 9-1-1 in their most desperate, dangerous, and scary moments. If you are fortunate, you never need to call.  But if you must, you are connected to a highly-trained, calm voice who provides life-saving instruction, and ensures that first responders arrive as quickly and safely as possible.

In fact, the 9-1-1 system is so second-nature and reliable that it’s easy to underappreciate. The 9-1-1 professionals who answer your calls, dispatch responders, and protect lives and property are not often seen on TV or in the movies.  They undergo extensive training, may work 12-hour shifts, and at any moment’s notice become immersed into an emergency, such as to coach a parent through life-saving infant CPR, or to talk a person through suicidal tendencies.  They also warn approaching responders of any dangers, coordinate incident response, and serve as a lifeline to injured police and firefighters.  They finish one call, often without closure or knowledge of outcomes, and must be ready to answer the next call.  Although it takes a very special kind of person to do this job, they are continuously exposed to a high level of stress that is hard to imagine.

The occasion of the 50th anniversary of the first 9-1-1 call is a great opportunity to raise awareness and celebrate the amazing work that 9-1-1 professionals from every corner of the U.S. perform every day.  They are true heroes – the first of the first responders – at times the only and best hope to save a life.

The 50th anniversary is an opportune time to confront the fact that 9-1-1 profoundly lags behind in technology.  It may come as a great surprise to many that as dependable and life-saving as the 9-1-1 system is, it is essentially based on the same technology of many decades ago.  The network itself relies upon technology that was long ago abandoned by just about every other commercial and critical infrastructure industry.  Today’s wireless communications options available to the public vastly exceed what’s available at 9-1-1 centers.  This is why, despite public expectations to the contrary, 9-1-1 can still only accept basic voice calls and in some cases, limited texts (always call if you can, text if you can’t).  Sending photos, videos, or other data to 9-1-1 is rarely possible, and we are nowhere close to such a capability in a uniform manner throughout the country.

This means that the 50th anniversary should also be a call to action.  We need to modernize our 9-1-1 systems, and prepare 9-1-1 professionals to meet the challenges of these new technologies.  The gulf between the current status of 9-1-1, and today’s state-of-the art commercially available communications, is so vast that it requires action by Congress to provide the funding needed to close this gap.

APCO has been a leader in seeking to raise awareness of the protective roles 9-1-1 professionals play, and secure federal funding to modernize the 9-1-1 system.

But what it all comes down to is the professional workforce that is there to help every day, every hour, every holiday, and throughout any disaster that may impact them and their families as well. As we celebrate this milestone, let’s be sure to thank those “behind the headsets” for their service.  APCO plans a number of initiatives, so stay tuned for more announcements.

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.

Achieving the True Promise of Next Generation 9-1-1

9-1-1 is part of America’s critical infrastructure, but it profoundly lags behind in technology. Public safety communications professionals across the country deserve to have the best tools available to protect and save lives.  Next Generation 9-1-1 promises to deliver many benefits, including putting 9-1-1 on par with technology used in the commercial sector, which for today means seamlessly exchanging texts, photos, videos, multimedia, and other data.  What will it take to finally make good on this promise and achieve fully deployed NG 9-1-1 service throughout the United States?

We Need to Work from a Comprehensive Definition of NG 9-1-1

Some states and localities are making progress towards NG 9-1-1 by replacing legacy networks with IP-based connectivity, referred to as ESInets or Emergency Services IP Networks. To be fully deployed, NG 9-1-1 has to mean an end-to-end, all-IP network that includes not only the connectivity afforded by ESInets but also the equipment and services needed to enable every 9-1-1 Public Safety Answering Point (PSAP) to process new forms of data.  To illustrate, this means when a member of the public can send a multimedia message such as a photo or video to a PSAP that in turn is capable of receiving, analyzing, and forwarding this information to a field responder to render an emergency response.  This is not yet possible anywhere in the country.

Defining NG 9-1-1 in this comprehensive manner will best ensure that all stakeholders work in unison to effectively implement NG 9-1-1 across the United States. This includes innovators, technology companies, federal, state and local government officials, and 9-1-1 professionals.  It also helps better identify the need and urgency to modernize 9-1-1 particularly for elected officials, and mitigate confusion on the part of the general public, whose expectations about the capabilities of 9-1-1 are increasingly far from reality.

APCO has suggested a comprehensive definition to the FCC for use in its annual reports on 9-1-1 fee diversion, and the definition will be refined for APCO’s upcoming report on Broadband Implications for the PSAP (to be released at our annual conference this August).

The True Promise of NG 9-1-1: Interoperability and Innovation

The real opportunity for NG 9-1-1 goes beyond end-to-end connectivity for advanced, multimedia communications. Seamless interoperability will improve emergency response operations and expand the market so that public safety benefits from the competition and innovation enjoyed in the commercial sector.  “Seamless interoperability” means avoiding expensive integrations or specialized interfaces for every NG 9-1-1 use case:

  1. PSAP-to-PSAP: seamless hand-off of calls such as for transfers, overloads, or mutual aid.
  2. ESInet-to-ESInet: seamless exchange of data between connecting networks, including across state boundaries, to facilitate mutual aid, disaster recovery, or data sharing.
  3. ESInet-to-origination networks: naturally, we need a seamless way for the public and other sources of data (including smart city, Internet of Things, and intelligent highway networks) to flow into NG 9-1-1 networks.
  4. NG 9-1-1-to-FirstNet: similarly, one network cannot fully function without the other, and a seamless interface to exchange data between these two vitally important public safety networks is a must.

While it’d be natural to expect seamless interoperability given the value to public safety’s mission, we are concerned that NG 9-1-1 deployments are on course to lack interoperability, at least without costly after-the-fact integrations. Failing to realize the true promise of NG 9-1-1 would be a great disservice to 9-1-1 professionals and the communities they serve.

In the commercial sector, we take interoperability for granted. For example, consumers can freely exchange multimedia content and data with each other, regardless of device, manufacturer, operating system, software, service provider, etc.  This is because the consumer marketplace uses commercial standards – such as those created by the Third Generation Partnership Project (3GPP) (including IP-Multimedia Subsystem, IMS), the Alliance for Telecommunications Industry Solutions (ATIS), the Internet Engineering Task Force (IETF), and the Institute of Electrical and Electronics Engineers (IEEE) – and because the market generally demands it.  NG 9-1-1 can and must benefit from these same commercial standards and expectations.

In addition to commercial standards, there are a number of complementary efforts underway by the public safety community and industry to improve interoperability and flexibility for NG 9-1-1. For example, earlier this year APCO and NENA received final approval from the American National Standards Institute (ANSI) for an American National Standard that identifies standard specifications for the exchange of NG 9-1-1 emergency data between disparate manufacturers’ systems (Computer Aided Dispatch, Record Management Systems, etc.) located within one or more public safety agencies.  Standards are also in progress to address NG 9-1-1 network architecture.  ATIS, the ANSI-accredited standards development organization partnered with 3GPP, has produced a standard for implementation of an IMS-based NG 9-1-1 service architecture.  Also, NENA plans to make the next version of its “i3” architectural vision for NG 9-1-1 an ANSI standard.

Standards are critical, but we also need a mechanism to ensure that NG 9-1-1 systems achieve interoperability for the use cases above, both when they’re deployed and on an ongoing basis. This may require action by Congress, as explained below.  In the meantime, for those states and jurisdictions that have deployed, or are seeking to deploy, ESInets or other NG 9-1-1 elements, we recommend you ask the following questions of your existing or prospective vendors:

  • Can you guarantee that our ESInet and other IP-based equipment will be seamlessly interoperable with other ESInets and equipment, including across state boundaries?
  • Can you guarantee that our ESInet will be seamlessly interoperable with origination networks? With FirstNet?
  • If a solution complies with a particular standard, how have you ensured that your implementation of the standard aligns with others in the industry to achieve interoperability?
  • Will you guarantee your solution to be interoperable without additional upgrades and new costs to the PSAP?

What We Can Learn and Apply from the FirstNet Legislation

With the right vision in mind for NG 9-1-1, a look at the problems that the FirstNet legislation aimed to solve for first responder communications can help set the path for NG 9-1-1.

Many of the challenges facing 9-1-1 are similar to those encountered with public safety land mobile radio communications:

  • Networks, services, and equipment are costly, siloed, and proprietary.
  • The vendor community is specialized and small.
  • 9-1-1 authorities have little bargaining power and few options.
  • Interoperability is difficult and expensive to achieve, especially after-the-fact. (As explained above, this is becoming a growing concern for pre-NG 9-1-1 deployments.)
  • Innovation is limited and disconnected from advances in the consumer marketplace.
  • Upgrades are disruptive.
  • Consumer/user expectations are far removed from reality.

In addressing the communications needs of first responders, Congress sought to leverage the opportunities afforded by the innovation, experience, expertise, infrastructure, and breadth of the commercial marketplace. In particular, by defining and requiring use of “commercial standards” in all network components, the FirstNet legislation is achieving the following for the nationwide public safety broadband network:

  • Substantially expanded range of companies producing innovative solutions;
  • Seamless interoperability and data sharing without the need for additional interfaces or costly integration; and
  • Significant economies of scale.

We must accomplish the same outcomes for NG 9-1-1.

Where Do We Go from Here?

When Next Generation 9-1-1 and FirstNet are fully deployed throughout the country, the PSAP’s role as the nerve center of a broader emergency response ecosystem will be even more critical than it is today: receiving data and multimedia content from the public and exchanging broadband-rich content with field responders via a dedicated wireless public safety broadband network. Fortunately, there have been some promising developments for NG 9-1-1 of late.

Looking at NG 9-1-1 and FirstNet as the two main pillars of the nation’s future emergency response capabilities, we start to see a path forward. The 9-1-1 community may not have the bargaining power, on its own, to match the economies of scale and innovation prevalent in the commercial marketplace and ensure needed interoperability for NG 9-1-1.  Accordingly, and similar to how the FirstNet legislation achieved these goals for first responder communications, the opportunity exists for Congress to provide strong incentives for NG 9-1-1 implementation to use commercial standards and achieve full interoperability.  For example, Congress can help ensure use of commercial standards and ongoing interoperability as conditions of federal grants, through certifications by grant recipients, and with oversight by the 9-1-1 Office.

Thus, full NG 9-1-1 deployment requires a significant federal grant program for a one-time capital expenditure to upgrade 9-1-1 networks, equipment, and PSAPs AND to create the mechanism needed to ensure interoperability and position PSAPs to stay on par with commercial technology.

In February, Senators Bill Nelson (FL) and Amy Klobuchar (MN) released a discussion draft of federal legislation that would advance NG 9-1-1.  This draft bill addresses critical needs for the 9-1-1 community, and aligns with priorities APCO has long advocated for accomplishing a full transition to NG 9-1-1.  For the reasons discussed above, APCO is especially supportive of provisions recognizing the need for standards and resources to support PSAPs while appropriately reserving governance and control to states and localities.  The Communications and Technology Subcommittee in the House of Representatives also recently held an informative hearing entitled “Realizing Nationwide Next Generation 9-1-1,” during which several Representatives expressed interest in connectivity between PSAPs and interoperability with broader networks such as the Internet of Things.

These expressions of interest in NG 9-1-1 in both the Senate and House are a welcome sign. A modernized 9-1-1 system is a national public safety and homeland security priority, and APCO looks forward to continued work on the draft bill and other initiatives with members of Congress.

All In: Betting Against Opt-Out

With FirstNet’s historic announcement of its selection of AT&T as its partner, we are about to achieve the promise of a state-of-the-art, nationwide, interoperable public safety broadband network.  Each state will soon be presented with the opportunity of FirstNet’s proposed network build – one that will forever transform and improve emergency response.  States would receive this at no cost and with no need to assume financial, technical, cybersecurity, public safety, or operational risks.  Unless governors want those costs and risks.

If a governor seeks to “opt out,” pursuing construction of the state’s portion of the network through an arduous process that Congress strongly discouraged, states face significant costs and risks.  APCO has said publicly that “opt-out is a false choice,” and here I offer a detailed explanation of why.

Let’s First Review History

In 2012, after years of a united public safety community, led by APCO and the Public Safety Alliance, advocating for the tools to improve communications for first responders, Congress created FirstNet.  Along with needed spectrum and funding, the public safety community supported the notion of a single nationwide governance body to implement the network.  Public safety leaders, and eventually Congress, agreed that to provide advanced communications capabilities, nationwide interoperability, rural coverage, cybersecurity, and national-level economies of scale, the way public safety communications networks are built had to change significantly.  Thus, FirstNet emerged, and so far it has proven quite effective.

As part of a political compromise, the law carved out a mechanism for states to “opt-out” of FirstNet’s plan and build their own portion of the radio access network, meaning the infrastructure that connects individual devices to FirstNet’s core network.  The rationale for this was partly philosophical, that states should have additional options, and some thought that this would provide FirstNet with an additional incentive to develop the most effective network design to meet public safety’s requirements.  In creating the opt-out provision, Congress took steps to strongly discourage states from building their own RANs.

For states attempting to opt-out, Congress imposed aggressive, unforgiving timeframes.  It established three separate approval stages – the FCC, NTIA, and FirstNet – each with demanding requirements.  Congress also made clear that there is no financial benefit to states of opting out.  To the extent that revenue can be gained from the excess spectrum capacity, any and all such revenue must be reinvested back into the network.

Let me pose a few rhetorical questions.  Has a promise of profit for opt-out states been accompanied by an explanation of how to get around the law’s requirement that any revenue be reinvested into the network?  Can a company offer better coverage or service than FirstNet, with its statutory mandate to cover rural areas, nationwide economies of scale, billions in federal funding, and the mandate to do what’s best for public safety?

I haven’t heard satisfactory answers to either of these questions.  FirstNet conducted a fair and competitive RFP process.  Some companies didn’t participate at all, and some were unsuccessful.  States should be skeptical of opt-out, to say the least.

Why Opting Out is a False Choice

I understand that when faced with deciding whether to accept FirstNet’s proposed RAN plan or attempt to opt-out, states want that decision to be based on a well-informed comparison of the options.  But I don’t see any scenario in which pursuing an alternative RAN build benefits a state’s citizens or its first responders.

FirstNet Has Inherent Advantages, Unmatchable by Individual States.

Due to its nationwide scope, partnership with AT&T, and statutory obligations, FirstNet will be able to achieve and sustain national-level economies of scale and purchasing power, rural coverage, greater spectrum capacity, and wireless broadband network expertise that are beyond the reach of any state acting alone.  FirstNet has already consulted extensively with state and local agencies.  This means that FirstNet knows what the priorities for each state (and its local components) are, as does AT&T.

Not only is FirstNet going to be based upon the most advanced wireless broadband communications technology available (including through the evolution to 5G technology and beyond), it will also meet public safety-specific requirements.  FirstNet is designed for this purpose, and has a proven partner in AT&T.  In contrast, a state would have to acquire and fund the workforce needed to manage a highly advanced, mission critical public safety network (including vendor oversight, marketing, customer care, disaster recovery, etc.), and find a qualified partner.  This would require a long-term commitment[1] of the state and its vendor to remain current with an evolving and increasingly complex cybersecurity threat landscape and to keep up with the rapid pace of innovation in order to remain interoperable with FirstNet.

FirstNet is also designed to maximize its public-private partnership with AT&T, and can assess fees upon its subscribers, its partner, and opt-out states.  A governor electing to reject FirstNet’s RAN build would face uncertain funding from NTIA for its own network build, pay fees to FirstNet to access FirstNet’s core network, pay its vendor, charge its own user fees (which must be competitively priced), and ensure that it has a sustainable financial model.

States also cannot guarantee sustainability.  State governors, policies, politics, funds, and priorities constantly change.  In 2018 alone, gubernatorial elections will be held in 36 states and three territories.  Opting out is a substantial commitment, yet no state can guarantee to its first responders and citizens that it will be able to remain sufficiently and continuously committed to the state RAN.  There is no rescue plan in the law for failed opt-out RANs.  If something goes wrong, the entire state could lose service indefinitely, leaving first responders without the service they will increasingly come to depend on.

Passing the opt-out review process is nearly impossible.

By congressional design, states seeking to opt out must hurdle three separate high bars in short order.  The law’s stringent provisions speak for themselves.

It’s no longer a question of control.

You don’t need to construct your own RAN to ensure you have the level of local control public safety expects.  LTE technology is completely different than land mobile radio networks, and offers numerous features that permit local customization.

States can’t profit from opting out.

The law is clear, despite any promises made by misguided vendors:

“Any revenue gained by the State… shall be used only for constructing, maintaining, operating, or improving the radio access network of the State.”[2]

Congress also recognized the need for FirstNet to charge states that opt-out a fee to access the core network, which Congress reserved exclusively to FirstNet to implement:

“If a State chooses to build its own radio access network, the State shall pay any user fees associated with State use of elements of the core network.”[3]

The amount of this fee will not be known at the time a decision to pursue opt-out is required.

Grant funding from NTIA for constructing opt-out RANs (in lieu of what FirstNet would spend to implement its proposal) has not been determined, and there is no guarantee of what amount opt-out states may receive.

Yet the ink was barely dry on the FirstNet legislation when vendors and consultants began preying on states to convince them to opt-out, often with false promises of revenue from monetizing the spectrum dedicated to public safety.  These businesses see more profit in keeping public safety divided than helping to achieve the goals of the FirstNet legislation.

Certain vendors have been quite public about trying to convince states to opt-out and hire them.  One in particular is promoting its dynamic spectrum exchange technology, which has not yet been proven in practice, let alone in a public safety environment.  A cardinal rule of public safety communications is that public safety shouldn’t be a proving ground for a proprietary, untested technology.

Further, the spectrum exchange model may bring a number of substantial financial risks to governors.  A recent economic analysis by NERA Economic Consulting explains that “the deployment of a state-owned RAN is costly,” consisting of initial capital investment, operating expenses, and upgrading or incremental capital expense.[4]  Among states that have issued RFPs to explore opt-out, its author, Christian Dippon, estimates that New Hampshire, Alabama, and Arizona can expect to pay as much as $48 million, $269 million, and $524 million, respectively.[5]

Against this backdrop, Dippon states that “a closer examination of the potential profit that the states could earn from opting out from the FirstNet program demonstrates that demand will likely be weak, leading to low revenue expectations and thus negative profits.”[6]  As Dippon explains, carriers tend to account for capacity needs in their network designs, and it is thus “not realistic that a mobile wireless service provider would expend such large amounts on solutions that are not permanent.”[7]  As a result, “states will incur substantial deficits, which they will only be able to cover by an increase in taxes.”[8]

Dippon casts further doubt on the economics of dynamic spectrum access, such as the complexities of formulating the roaming agreements that both public safety and commercial users would require (“the inability to place a call outside the opt-out state would make the opt-out network one of very low value to its subscribers”), the experimental nature of such a system (“no country has a working spectrum-exchange system”), and the strength of existing secondary markets for spectrum (“strong and thriving”).[9]  I would recommend any state considering opt-out to review this entire report as part of its overall due diligence efforts.

How Opting Out Will Harm Public Safety

Fragmented networks will add unnecessary costs and complexity to FirstNet.

Any opt-out state RAN adds complexity, operational risks, and integration costs to FirstNet and the remainder of the country.  At the same time, first responders are at a disadvantage as they await the conclusion of the opt-out process, and then the state’s network build.

Fragmented networks will imperil nationwide interoperability.

The most important goal of FirstNet is to create and preserve a nationwide level of interoperability for public safety broadband communications.  Historically, the state and local network build model has failed the country in this regard.  All it takes is for one state RAN to fail, and there goes interoperability within that state, with adjoining states, and nationwide.

Fragmented networks will introduce unnecessary cybersecurity risks.

Public safety broadband networks will be an attractive target for cyber attacks.  Congress knew this and incorporated a number of requirements of FirstNet to build in protections against cyber attacks.  Even one separate opt-out RAN introduces an external vulnerability that can impact the entire network.

The Good News

Thanks to a dedicated and talented Board and staff, FirstNet has accomplished its major statutory responsibilities to date: extensive consultation with states, localities, and public safety professionals across the country, and a well-executed procurement process that achieved what Congress had in mind for this public-private partnership – an expert wireless industry partner in AT&T, that, as Congress intended, permits FirstNet to leverage the experience and infrastructure of a commercial wireless service provider.

Indeed, in just the short amount of time since the Department of Commerce and FirstNet announced their partnership with AT&T, AT&T has shown how much value they can contribute to the public safety community.  AT&T will be making available quality of service, priority, and preemption services to states once a governor opts-in, without the need to wait on the build-out of Band 14, FirstNet’s dedicated spectrum.  In other words, as soon as governors opt in, the first responders in their states can benefit from priority access over AT&T’s existing network.

Our nation’s first responders deserve the best, and we owe it to them to achieve the vision of FirstNet. The entire country needs to band together to realize the efficiency, sustainability, interoperability, reliability, and security made possible only by a single nationwide network.  This is a chance to get things right for public safety, and I’m all in.


[1] The agreement between FirstNet and AT&T is for 25 years.

[2] 47 USC § 1442(g)(2).

[3] 47 USC § 1442(f).

[4] FirstNet: An Economic Analysis of Opting In vs. Opting Out, By Christian Dippon, PhD, NERA Economic Consulting (March 2017) at page 7, https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2939764.  This report responds to a paper prepared for Rivada Networks by Peter Cramton and Linda Doyle.

[5] Id.

[6] Id.

[7] Id. at 8.

[8] Id.

[9] Id. at 10-21.

FirstNet Works to Foster Innovation in Public Safety Apps

By Jeff Posner, FirstNet Senior Applications Architect

If you know FirstNet, then you know we are focused on putting broadband technology into the hands of public safety personnel nationwide. What you may not know is that FirstNet also is leading the way on a host of public safety-focused technologies, not the least of which is in bringing to market the best possible software applications for public safety to use in emergencies and day to day scenarios.

“The excitement surrounding FirstNet not only is in its broadband capabilities, which will be a game-changer, but also in the competition for public safety apps that we expect it to spark,” FirstNet Chief Technology Officer Jeff Bratcher said. “If FirstNet can help foster that kind of technical innovation, we will open up a new world in which first responders are more prepared, safer, and in better position to serve the public, from the apps they will be able to access.”

When speaking about the technology FirstNet will enable at the APCO Emerging Technology Forum in Seattle recently, Jeff Johnson, Vice Chairman of the FirstNet Board said, “That device will change every aspect of life and work for public safety.”

Preceding the Technology Forum, APCO International hosted its third technology workshop; this session’s topic was App Interoperability. The APCO workshop brought together members of FirstNet’s applications team, based in Boulder, Colorado, with representatives from public safety, government agencies, telecommunications and app designers.

In this workshop, participants called for the creation of a tool for developers to use for testing their apps for interoperability and cybersecurity on FirstNet’s network. Open, transparent, and objectives based self-test tools are critical to innovating quickly within the applications ecosystem for several reasons. Transparent tools enhance confidence in the reliability, stability, and security of applications. Such tools enhance the productivity of application developers in validating their efforts prior to further, typically costlier, testing procedures. Finally, online tools are a very cost effective way for demonstrating the functionality of an underlying solution.

Efforts like APCO’s AppComm website and collaborations with FirstNet have helped to increasingly involve public safety in the dizzying pace of app development. Law enforcement, firefighters, paramedics and others have been quick to tell FirstNet the kind of apps that would vastly improve public safety.

Some of those include:

  • Distributing images of suspects, lost children, or evidence reliably and in real-time
  • Viewing 3D floorplans of structure fires with all critical infrastructure such as firehose connections, real-time images of hot-spots, locations of panic alarms including all three dimensions of location
  • Real-time 12-lead ECG under mission critical, congested conditions
  • Access to a virtually unlimited collection of critical data from the field whether it be health information, law enforcement records, or licensing data

There is virtually no limit to the variety of applications and information that can be built once a mission critical, broadband data network is constructed to demanding needs of public safety. Even now, participants in FirstNet’s Early Builder program have deployed and are actively using mobile broadband solutions including situational awareness, collaboration, and push-to-talk (PTT) to support and enhance their operational posture.

Captain Chris Lombard, a Seattle firefighter, is among many who are excited about the prospects FirstNet holds. “We can’t even begin to imagine the opportunities that are going to be available for public safety. Who would have thought, even five years ago, that we would have been able to exchange the types of information or the amount of information that we are able to exchange today?

“What excites me is that there is some firefighter, EMT, patrol officer out there that right now has an idea and they’re just looking for the mechanism to be able to get that idea in motion,” Lombard added. “Whether it is passing or sharing information, whether it’s finding out what would make their jobs easier, better, orhelpful to other people. I think those are the things that excite me about the potential or the opportunities that FirstNet is going to enable for us.”

FirstNet continues to search for new and innovative ways to exploit the intersection of public safety needs, mobile broadband, and the revolutionary change in software development created by mobile devices.  By opening the doors to more developers, providing them with the tools and support commonly afforded open development environments, and promoting our vision of a fully integrated development ecosystem, public safety personnel will have access to more focused apps and more timely data than ever before possible.