Talking Points for APCO’s Legislative Priorities

By Jeff Cohen

APCO members often contact us to ask for talking points to prepare for meetings with their U.S. Senators and Representatives. Having accurate talking points to speak from – or leave with the congressional staffers you meet with – can ensure that you use your meeting time efficiently and are prepared to answer key questions about the issues. Following up on the blog describing APCO’s advocacy priorities for 2022, here are talking points for our top legislative issues: 1) securing federal funding for Next Generation 9-1-1; 2) correcting the federal classification of public safety telecommunicators; and 3) funding health and wellness programs for 9-1-1 professionals.  

Please feel free to contact our team ([email protected]) if you have questions. If you are able to secure a meeting with any members of Congress or their staffers, we are happy to assist with additional prep (such as more detailed talking points) and meeting follow-ups as well.

  1. Secure major federal funding to implement Next Generation 9-1-1 (NG9-1-1) nationwide.
    • Modernizing our nation’s 9 1 1 systems with strong cyber protections and advanced broadband capabilities should be a national security priority. The need to upgrade the nation’s 50+ year old 9-1-1 systems grows more urgent by the day. Unfortunately, these mission critical systems are increasingly vulnerable to cyber attack, and outdated technologies inhibit emergency response.
    • We need to deploy NG9-1-1 throughout the country in a comprehensive, secure, innovative, cost-effective, and interoperable manner. ECCs should be able to receive and process voice, text, and multimedia content and share it with other ECCs or with first responders in the field. Some states have made partial progress, but a significant federal funding program is needed to achieve this vision of comprehensive and interoperable NG9-1-1 service.
    • Public safety groups have developed legislative language and are calling for a $15 billion federal grant program to deploy NG9-1-1 nationwide.
    • Funding NG9-1-1 has bipartisan support.
    • Lives will be saved by ensuring that our nation’s 9-1-1 systems are secure and that our communities have access to advanced communications tools during emergencies.

  2. Fix the federal classification of Public Safety Telecommunicators.
    • Public safety telecommunicators should be categorized as Protective Service Occupations. The federal government maintains a catalogue of occupations, the Standard Occupational Classification (SOC), for statistical purposes. The SOC categorizes Public Safety Telecommunicators as an administrative/clerical occupation, but this is outdated. There is a much more appropriate “protective” category.
    • Under the SOC’s classification rules, occupations are supposed to be grouped based on the work performed. 9-1-1 professionals save and protect lives every day. Therefore, instead of being classified as clerical personnel, they should be with the ”Protective Service Occupations” – a broad group that includes playground monitors, parking enforcement workers, and several other occupations.
    • The 9-1-1 SAVES Act (HR 2351/S 1175) is a bipartisan, zero-cost bill that would correct the classification. The 9-1-1 SAVES Act would direct the Office of Management and Budget (which controls the SOC) to correct the federal classification of Public Safety Telecommunicators from “Office and Administrative Support Occupations” to “Protective Service Occupations.”
    • Correcting the classification of public safety telecommunicators would make the SOC a more accurate and useful statistical resource.  
    • 9-1-1 professionals deserve recognition for their lifesaving roles. Correcting the SOC would have no direct impact on salaries or benefits.

  3. Fund health and wellness programs for 9-1-1 professionals.
    • 9-1-1 professionals suffer substantial impacts to their mental health as part of their work in emergency response. Imagine the stress of coaching a panicked caller through CPR, responding to cries for help during an assault, or dealing with other traumatic events.
    • Depression, anxiety, and PTSD are serious problems for this community. Research has shown that one in seven 9-1-1 professionals admitted to recent suicidal thinking. Supporting these professionals is the right thing to do, and it will help to address the staffing shortages in 9-1-1.
    • The PROTECT 9-1-1 Act (HR 4319) would provide much-needed assistance for 9‑1‑1 professionals. This legislation has four key elements:
      • establishing a grant program to fund wellness programs (such as peer support programs) in ECCs;
      • developing best practices to identify, prevent, and treat posttraumatic stress disorder in public safety telecommunicators;
      • developing resources to help mental health professionals better treat these personnel; and
      • developing a system for tracking public safety telecommunicator suicides.
    • This legislation already has bipartisan support in the House of Representatives. APCO is working with offices in the Senate to introduce a companion to the House bill.

About the TabletopX Blog

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

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

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

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

By Jeff Cohen

The following is a list of our advocacy priorities for the coming year. Despite much progress and several wins that APCO members should be proud of since we announced our 2021 legislative and regulatory priorities, there is still significant work to be done for public safety communications. Click each topic to learn about recent developments and where things stand.

Legislative Priorities

1. Secure major federal funding to implement Next Generation 9-1-1 nationwide.

The nation’s 9-1-1 networks are in dire need of modernization. 9-1-1 is largely based on 50+ year-old technology and thus limited to voice calls and some basic texting capabilities. Implementing modern technology would save lives. We need to deploy Next Generation 9-1-1 (NG9-1-1) throughout the country in a comprehensive, secure, innovative, competitive, cost-effective, and interoperable manner. This would enable 9-1-1 centers to receive and process voice, text, and multimedia content and share it with other 9-1-1 centers or with first responders in the field. While some states and jurisdictions are making partial progress toward NG9-1-1, no part of the country can be described as having achieved this vision of NG9-1-1 with end-to-end broadband communications for emergency communications centers (ECCs).

The Public Safety Next Generation 9-1-1 Coalition (which includes APCO), is a group of national public safety associations representing 9-1-1, fire, law enforcement, and EMS. The Coalition estimates that $15 billion is needed to fully achieve NG9-1-1 nationwide, and our associations developed language for an NG9-1-1 grant program that has been included in several legislative proposals. Other associations, including NASNA, NENA, and iCERT have expressed support for these proposals.

In 2021, the House passed the Build Back Better Act – which included the majority of the Coalition’s proposal. The main difference is that the funding level was far short of the proposed $15 billion. The Coalition has cautioned that under-funding the grant program will jeopardize the legislation’s goals and could result in “haves” and “have-nots” across the country. At the time of this writing, the House version of the Build Back Better Act is unlikely to pass, and both the House and the Senate are working on revising the legislation.

As Congress considers changes to the Build Back Better Act and other legislative packages, APCO will continue working with the Coalition to advocate for inclusion of the NG9-1-1 provisions (which have bipartisan support).

2. Fix the federal classification of Public Safety Telecommunicators.

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

The easiest path to make this fix is for the Office of Management and Budget (OMB), which controls the SOC, to simply correct the SOC by reclassifying PSTs into the protective service category. This would come at no cost, promote good government by ensuring that the SOC is accurate, and align the SOC with other federal data efforts, including congressionally-mandated suicide tracking programs that group PSTs with other public safety professionals. APCO has been working to fix the classification since 2014, but so far OMB has opted to maintain the status quo.

As an alternative to OMB voluntarily changing the classification, legislation could direct OMB to fix the SOC. The 9-1-1 SAVES Act (HR 2351/S 1175) would do just that. While not having any direct impact on salaries, benefits, or state-level job classifications, this is a common-sense change that would signal the Administration’s recognition of the life-saving work performed by PSTs.

In 2021, APCO worked with members of Congress to get the 9-1-1 SAVES Act reintroduced in both the House and the Senate with bipartisan support. Near the end of 2021, the reclassification language was included in the U.S. House of Representatives version of the National Defense Authorization Act (NDAA) of 2022, but unfortunately the House and Senate moved forward with a slimmed down version of the NDAA that did not include the reclassification provision.

APCO will continue to vigorously pursue passage of the 9-1-1 SAVES Act. Adding to the already-strong bipartisan support is important for creating pressure on congressional leadership to pass the bill. If you haven’t already done so, you can send a letter to your representatives in Congress asking them to support the 9-1-1 SAVES Act here.

3. Fund health and wellness programs for 9-1-1 professionals.

Health and wellness is a huge challenge in 9-1-1, both physically and mentally. Research has shown that the stress of working in emergency communications dramatically increases the risk of suicidal thinking. In fact, one 2019 study found that one in seven 9-1-1 professionals had experienced suicidal thinking in the 12 months prior to the study. That’s comparable to rates for fire/rescue and more than four times the rate in the general population.

Unfortunately, for a variety of reasons, people experiencing mental health issues or suicidal thinking might not be seeking the help they need. There is growing attention in public safety to the need to eliminate the stigma around mental health and wellness, but dealing with this serious challenge to our community will require significant efforts, including raising awareness, creating guidance for mental health professionals, and supporting resources like peer support programs.

In 2021, APCO worked closely with Congresswoman Robin Kelly’s office to develop legislation that would provide support for 9-1-1 professionals. The bipartisan PROTECT 9-1-1 Act (HR 4319) includes several measures to advance health and wellness for 9-1-1 professionals, including: establishing a system for tracking PST suicides; developing best practices to identify, prevent, and treat posttraumatic stress disorder in PSTs; developing resources to help mental health professionals better treat these personnel; and establishing grants for health and wellness programs in ECCs.

The introduction of the PROTECT 9-1-1 Act is an important acknowledgement of the stressful, lifesaving nature of the work performed by PSTs and a helpful step toward addressing the critical need for support. APCO is working to build support for the PROTECT 9-1-1 Act in the House and to get a companion bill introduced in the Senate, both of which are essential for getting the bill passed into law.


FCC Regulatory Priorities

1. Improve location accuracy for wireless calls to 9-1-1.

9-1-1 professionals require actionable location information for 9-1-1 calls, and obtaining an accurate location is especially challenging for calls made indoors. Ideally, ECCs would know the caller’s “dispatchable location,” meaning the street address, plus (if applicable) the floor level and apartment/suite number.

The FCC’s rules impose several requirements on wireless carriers to provide location information for 9-1-1 calls made indoors. One of these requirements is to provide information about the vertical position of a caller through either dispatchable location or a “z-axis” location estimate expressed as a “Height Above Ellipsoid (HAE).” HAE is a height measurement that’s different from height above ground or sea level.

APCO has consistently expressed a strong preference for dispatchable location information. Setting aside the issue of whether the estimate is accurate, for HAE to be used by ECCs, specialized software and 3D maps have to be developed – a technically challenging, time-consuming, and costly undertaking that places more responsibility on ECCs with an uncertain payoff.

Unfortunately, the carriers favored an approach focused on z-axis information and largely abandoned efforts toward dispatchable location. This could be because modern smartphones provide z-axis estimates, and if they’re accurate enough, the carriers could piggyback on those capabilities to comply with the FCC’s rules. However, when the first deadline for providing accurate z-axis information came in April 2021, the carriers were unable to comply because the z-axis information wasn’t accurate enough. In response, the FCC fined the carriers and adopted several measures for increased oversight. Wireless carriers were also required to start providing any available z-axis information for 9-1-1 calls, even if the information failed to comply with the FCC’s accuracy requirements and regardless of whether ECCs are able to use the information.

In April 2022, the carriers face a second chance for complying with the vertical location benchmark they missed in 2021. And a separate FCC rule, effective January 6, 2022, required the carriers to begin providing dispatchable location for 9-1-1 calls when feasible – a standard that has yet to be clearly defined. These benchmarks are important developments that present an opportunity to press the carriers for meaningful improvements. ECCs will play an essential role in evaluating real-world 9-1-1 location and reporting concerns that carriers are failing to meet their obligations.

APCO will continue to push the FCC to adopt stricter rules and to hold the carriers accountable for improving location information. Among other things, we’d like to see a clear requirement that a certain percentage of indoor calls are delivered with a dispatchable location and an expectation that carriers will leverage a variety of technologies, such as “5G Home” offerings, to deliver the best possible location information for 9-1-1 calls.

2. Protect public safety users of the 6 GHz band from harmful interference.

Public safety agencies throughout the country make extensive use of the 6 GHz spectrum band for emergency dispatching, first responder radio communications, and connectivity with other jurisdictions. In 2020, despite significant technical debate and public safety concerns, the FCC changed the 6 GHz rules to expand unlicensed (ex – Wi-Fi) use of the band, effectively permitting hundreds of millions of potentially interfering new devices to share this band. These devices are not licensed, and thus not easily trackable, and are expected to be just as ubiquitous as the Wi-Fi routers presently found throughout homes and businesses.

APCO didn’t fundamentally oppose spectrum sharing as a concept, but reasonably asked the FCC to 1) ensure that real-world tests are conducted to inform the rules and measures for preventing/mitigating interference, and 2) require mechanisms to rapidly detect, identify, and eliminate any interference. Unfortunately, the FCC declined to implement our requests and, after exhausting all other remedies at the FCC, APCO sued the FCC in federal court. APCO took this extraordinary measure due to concerns that interference from these new devices will cause irreversible harm. Several other parties – representing utilities, telecom, and broadcast industries – sued the FCC as well, but APCO was the sole party representing public safety.

Throughout 2021, APCO and the other parties suing the FCC engaged in arguments at the U.S. Court of Appeals for the D.C. Circuit. Unfortunately, given the legal rule to grant federal agencies like the FCC significant deference, the court ultimately sided with the FCC. This does not mean that the court determined that there wouldn’t be interference or the FCC should have taken better steps to protect public safety communications. 

In parallel to the court case, the FCC continued to move forward with its new 6 GHz framework. Some “low power” Wi-Fi devices were approved and have entered the stream of commerce already, and the FCC is working through a process to permit “standard power” devices that will operate under the control of soon-to-be-established Automated Frequency Coordination systems (AFC). Even before the court case was decided, APCO joined with other parties to urge the FCC to pause and revisit the rules governing the 6 GHz band through a pending petition for rulemaking and request for stay. One of the important factors the FCC must address is that real-world testing has demonstrated that the FCC’s assumptions were wrong and that interference is much more likely to occur than we originally feared. APCO will remain in contact with public safety users of the spectrum and continue urging the FCC to act before there’s harm to public safety.

3. Revise the rules for the 4.9 GHz band to enhance public safety use.

The 4.9 GHz band has long been dedicated to public safety and is uniquely suited to serve public safety’s needs for local broadband communications – Wi-Fi hot spots, fixed point-to-point connections, robot control, or bandwidth-intensive applications like high-resolution streaming video. But while the need is there, public safety hasn’t been able to make the most of this band because equipment costs are high, there are inadequate protections against interference, and the marketplace for devices is uncompetitive and sparse.

For many years, APCO, among other public safety groups, has been asking the FCC to make reasonable rule changes to enable public safety to make increased use of this band. Under previous leadership, the FCC adopted rules that effectively handed the band over to the states for commercial leasing and removed any guarantees of interference-free and priority use of the spectrum by public safety. In a win for public safety last year (after substantial pushback from APCO and others), the FCC’s new leadership reversed the earlier rule change and granted APCO’s petition to reconsider the rules and chart a new course for the band.

The FCC sought input on how to expand public safety use of the band while exploring options to spur innovation, improve coordination, and drive down costs. We’re in the midst of reviewing this input and will engage with the FCC and other public safety stakeholders to find a path forward to optimize this spectrum for public safety users. Ultimately, we need rules that improve public safety use of the 4.9 GHz band. This might entail some type of spectrum sharing framework so long as we ensure that any non-public safety use does not interfere with public safety’s use of the band, which may require the development of new tools to ensure public safety users have priority and preemption over other users. 

4. Improve the information provided to ECCs during network outages.

When network outages impact the ability of service providers to deliver 9-1-1 calls, ECCs need timely information about the scope, nature, and anticipated duration of the outage in order to take action to protect their communities, such as advising the public to use a 10-digit number if 9-1-1 is unavailable. There are some basic regulatory requirements for notifications, but it’s all too common that ECCs receive unhelpful information or don’t get notified at all. Furthermore, when ECCs detect outages on their own they need to know how to immediately contact the relevant service provider. 37,000 outages were reported in 2020, but we have no idea how many more went unreported because they didn’t meet the FCC’s high reporting thresholds.

For years, APCO has been asking the FCC to make improvements to the timeliness, format, and content of outage notifications so that they provide actionable information for ECCs. Additionally, we’ve asked the FCC to hold the wireless carriers to their prior commitment to develop and maintain a secure, two-way contact database that would make it easier for carriers and ECCs to contact each other about known or suspected outages.

In April 2021, consistent with APCO’s advocacy, the FCC proposed new rules on outage reporting and inquired about changes to the reporting thresholds that trigger an outage notification to an ECC. As APCO also suggested, the FCC sought comment from the carriers on their ability to provide graphical information about outages, such as maps of the affected areas, and establish a contact database. In response to these proposals, APCO asked the FCC to require the service providers to provide more information about the outages they experience, including how many go unreported and the average amount of time for restoration. This information would be useful in determining whether and how the FCC’s outage reporting thresholds should be altered to keep ECCs informed without an overload of unhelpful notifications.

The FCC seems convinced that action is needed. (Indeed, the FCC issued record-breaking fines on service providers last year for failing to comply with the existing outage reporting requirements.) We will continue evaluating the options for improving outage information and work with the FCC to develop rules for timely, actionable outage notifications.

Improving outage reporting has also been the subject of legislative activity. Before the FCC proposed updating its rules, as described above, APCO helped develop legislation that would direct the FCC to conduct such a rulemaking. Even with the FCC’s recent action, the Emergency Reporting Act (HR 1250/S 390) would be helpful for ensuring the FCC makes many of the changes we’ve requested. The bill passed in the House last year and has bipartisan support in the Senate. Passage of the law would make it easier to achieve a favorable outcome in the FCC proceedings.


These advocacy priorities are not the only issues for us in 2022. APCO will work with the FCC and Capitol Hill on several additional issues important to public safety, including, for example, improvements to Wireless Emergency Alerts, protecting ECCs from unwanted robocalls, legislative proposals for alternative dispatch programs, and enhancing cybersecurity for ECCs.

Our goal is to do what is best for public safety, and we rely heavily on input from our members. We encourage you to contact [email protected] to share your thoughts and experiences on these topics or any issues important to your ECC.

 

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.

Aligning APCO’s Advocacy Priorities With Our Members’ Needs

By Jeff Cohen

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

Reclassification of Public Safety Telecommunicators

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

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

Federal Funding for Next Generation 9-1-1

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

9-1-1 Location Accuracy

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

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

Wellness for 9-1-1 Professionals

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

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

About the TabletopX Blog

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

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

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

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

By Jeff Cohen

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

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

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

Legislative Priorities

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

What’s the issue?

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

What needs to be done?

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

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

2. Next Generation 9-1-1 Funding

What’s the issue?

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

What needs to be done?

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

3. Wellness for 9-1-1 Professionals

What’s the issue?

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

What needs to be done?

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

4. Network Outages Impacting 9-1-1 Service

What’s the issue?

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

What needs to be done?

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

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

FCC Regulatory Priorities 

1. 9-1-1 Location Accuracy

What’s the issue?

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

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

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

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

What needs to be done?

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

2. 6 GHz Frequency Band

What’s the issue?

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

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

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

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

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

What needs to be done?

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

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

3. 4.9 GHz Frequency Band

What’s the issue?

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

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

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

What needs to be done?

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

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

What’s the issue?

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

What needs to be done?

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

5. Carrier/ECC Contact Database

What’s the issue?

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

What needs to be done?

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

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

6. Wireless Emergency Alerts

What’s the issue?

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

What needs to be done?

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

7. Upgrades to Universal Licensing System

What’s the issue?

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

What needs to be done?

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

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

About the TabletopX Blog

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

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

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

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

By Jeff Cohen

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

A Quick Refresher on 6 GHz Spectrum

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

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

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

What the FCC Did

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

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

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

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

Suing the FCC

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

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

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

What Happens Next?

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

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

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

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

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

About the TabletopX Blog

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

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

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

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

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

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

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

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

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

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

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

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

About the TabletopX Blog

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

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

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

TabletopX Archives

All TabletopX Blog Posts

About the TabletopX Blog

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

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

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

New FCC Spectrum Rules Put Public Safety Communications at Risk

By Jeff Cohen

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

How Did We Get Here?

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

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

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

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

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

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

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

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

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

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

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

What Happens Next?

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

Remaining Vigilant

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

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

About the TabletopX Blog

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 

About the TabletopX Blog

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

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

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

2020 Legislative Priorities

By Jeff Cohen

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

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

 

Reclassification as 'Protective Service Occupations'

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

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

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

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

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

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

Talking Points

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

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

Next Generation 9-1-1

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

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

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

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

Talking Points

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

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

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

Talking Points

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

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

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

Talking Points

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

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

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

Talking Points

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

About the TabletopX Blog

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

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

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