APCO’s Regulatory Priorities for 2023

By APCO’s Government Relations Office.

The following is a list of APCO’s regulatory priorities for the coming year. As a general matter, APCO’s advocacy is driven by the best interests of our public safety members. That means we’re often arguing for a regulatory approach that: avoids shifting costs from service providers to ECCs; ensures that information being delivered to ECCs will best serve the operational needs of 9-1-1 professionals; and when it comes to spectrum, protects public safety users from interference and new costs.

Click each topic below to learn about recent developments and where things stand.  

1. Ensure wireless 9-1-1 calls are routed to the correct 9-1-1 center.

What’s the issue?

Traditionally, wireless 9‑1-1 calls have been routed to an emergency communications center (ECC) based on the cell tower sector that handles the call. This method of routing often results in a call being sent to an ECC that does not serve the caller’s actual location. These “misroutes” delay emergency response and waste ECC resources. In recent years, advances in location technology have created an opportunity to route wireless 9-1-1 calls more accurately, using “location-based routing,” which means using the location of the device making the call to route the call to the appropriate ECC. Some wireless carriers have even taken steps to implement location-based routing voluntarily.

In January, the FCC sought comment on proposed rules that would require wireless carriers to implement location-based routing nationwide. At the time of this writing the FCC was still reviewing public comments on its proposal.

What needs to be done?

APCO has urged the FCC to require carriers to provide location-based routing. We have pushed back on suggestions that 9‑1‑1 authorities should be responsible for enabling location-based routing or bear some costs, and explained that location‑based routing is not, and need not be, dependent on the deployment of pre‑NG9‑1‑1 technologies such as Emergency Services IP Networks or ESInets. Given that some carriers are voluntarily providing location‑based routing without placing additional costs on ECCs, and regardless of the technology an ECC has in place, we are hopeful to see positive action from the FCC soon.

2. Improve 9-1-1 outage reporting, reliability, and resiliency.

What’s the issue?

In the past year, the FCC has taken several steps to enhance network resiliency and reliability. Chairwoman Rosenworcel and Commissioner Carr visited areas where public safety communications had been impacted by natural disasters, and in May 2022 Commissioner Carr participated in an APCO webinar and shared a proposal to improve emergency communications resiliency. In July 2022, with APCO’s support, the FCC adopted new rules regarding arrangements among the major wireless carriers to increase coordination and information sharing during emergencies. For example, the new rules require all wireless service providers to execute roaming agreements with each other and to share resources in emergency situations.

In November 2022, the FCC took additional steps to address the timeliness, format, and content of outage notifications so that they provide actionable information for ECCs. APCO has been highlighting ECCs’ need for timely, actionable information about outages impacting 9-1-1 for several years. There are some basic regulatory requirements for notifications, but it’s all too common that ECCs don’t receive the timely information they need (if at all) for their situational awareness. APCO has been advocating that the FCC adopt rules to require timely notifications for outages that impact ECC operations but may not trigger the FCC’s presently very high thresholds. APCO has also urged that service providers provide outage information in a graphical format, much like how electric utilities and other service providers do today. Further, service providers should be required to provide a two-way contact database so that ECCs are promptly contacted or have the information they need to report outages they discover. To address some of these issues, the FCC’s Public Safety and Homeland Security Bureau will obtain information on the number of outages that go unreported under the current thresholds and consider modifying the thresholds. The Bureau will also collect information on the feasibility and utility of incorporating graphical information like outage maps into the notifications.

What needs to be done?

APCO will continue highlighting ECCs’ needs for mitigating outages and stands ready to support the Public Safety and Homeland Security Bureau’s further work. We will also continue pressing the FCC to hold the wireless carriers to their 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.

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

What’s the issue?

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 require wireless carriers to provide dispatchable location when feasible, and carriers are also providing “z-axis” location to comply with a separate rule on vertical location information. Z-axis is generally viewed as an alternative to dispatchable location information because, when combined with the x/y coordinate information carriers have been providing for years, having the z-axis theoretically makes it possible to identify a caller’s location indoors.

APCO has consistently expressed a strong preference for dispatchable location information, which is feasible today, because it’s more actionable for ECCs than z-axis information. Carriers are delivering z-axis information as a “Height Above Ellipsoid (HAE),” which is not the same as height above ground or sea level. Setting aside the issue of whether z-axis estimates are accurate (which is a major issue), for HAE to be used to identify a specific location, specialized software and 3D maps will need to be developed. This will be technically challenging, time-consuming, and costly. It isn’t fair to expect ECCs to spend years and significant resources trying to make HAE work when it’s the wireless carriers’ responsibility to provide a caller’s location. Indeed, APCO has challenged the notion promoted by some that the responsibility (and costs) for developing ways to make use of HAE should be shifted from wireless carriers to the public safety community.

What needs to be done?

We’re seeking more transparency about the steps wireless carriers have taken to provide dispatchable location information, and considering the additional steps they can and should be taking. For example, wireless carriers should leverage a variety of technologies, such as “5G Home” offerings, to increase their ability to provide dispatchable location information. APCO also has insight into the carriers’ location technology test bed, and we are working to ensure the test results accurately represent real world performance. We’re hopeful that, by working with the FCC, we’ll develop an effective approach to increasing transparency and putting the right incentives in place for carriers and other stakeholders to improve 9-1-1 location accuracy.

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

What’s the issue?

Historically, the 4.9 GHz band has been dedicated to public safety for broadband communications. 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.

In January 2023, the FCC adopted new rules that incorporate several of APCO’s recommendations to promote innovative technological approaches to the band. Importantly, the FCC reconfirmed the 4.9 GHz band as a dedicated public safety band and adopted a requirement for frequency coordination. The FCC also created a framework in which a band manager will be able to coordinate use of excess spectrum by non-public safety entities so long as public safety users are protected and maintain priority and preemption rights.

What needs to be done?

As part of the January 2023 rule change, the FCC sought input on how to increase and protect public safety use of the band, spur innovation, improve coordination, and drive down costs. There are a number of complex questions to address concerning how to enable spectrum sharing without sacrificing the reliability of the band for public safety users. APCO is examining these issues closely and will engage with the FCC to find a path forward to optimize this spectrum for public safety users.

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

What’s the issue?

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. The FCC did not adopt these suggestions.

Since the FCC adopted its order, new information has come to light that raises concerns that public safety operations will be subject to harmful interference. Accordingly, APCO and others submitted formal requests to the FCC to stop authorizing new unlicensed devices and to re-evaluate how to share the spectrum while protecting public safety from interference.

In the past year the FCC has continued to move forward with its new 6 GHz framework. Many “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 (AFC) systems.

What needs to be done?

APCO is working with other stakeholders to urge the FCC to address our interference concerns. APCO has also put out a Technical Bulletin for current 6 GHz operators concerning steps they must take now to prepare for expected interference. APCO will remain in contact with public safety users of the spectrum and continue urging the FCC to act before it’s too late.

 

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’s 2023 Advocacy Priorities (with one-pagers of talking points)

By APCO’s Government Relations Office

During the prior session of Congress, APCO made substantial progress on its legislative goals, including coming closer than ever to securing significant federal funding for Next Generation 9‑1‑1. With the start of a new Congress, legislation APCO had been championing will need to be reintroduced, and we’ll seek to build upon the momentum to get these bills passed into law. This blog describes APCO’s legislative priorities, APCO’s efforts, and next steps. Downloadable one‑pagers with talking points that can be used when speaking to members of Congress about these issues are also included. 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.

Download talking points on NG9-1-1 funding legislation.

Download talking points on the 9-1-1 SAVES Act.

Download talking points on the PROTECT 9-1-1 Act.

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.

Funding for Next Generation 9-1-1

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 mostly 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, no part of the country can be described as having achieved this end-to-end vision of NG9-1-1 for emergency communications centers (ECCs).

APCO’s Efforts

The Public Safety Next Generation 9-1-1 Coalition, which includes APCO and the nation’s leading law enforcement, fire/rescue, and emergency medical service associations, developed legislation to establish a significant one-time federal grant program to achieve NG9-1-1 nationwide. The Coalition agreed to key public safety principles and built upon earlier bills to develop legislative language that would:

  • Provide significant federal funding (targeting $15 billion).
  • Create efficiencies and leverage the opportunities afforded by the innovation and competition of the commercial marketplace.
  • Establish modern, comprehensive definitions for key terms like NG9-1-1 and interoperability.
  • Support training for public safety telecommunicators (PSTs).
  • Support increased cybersecurity measures.
  • Ensure seamless interoperability between ECCs and with first responders in the field.
  • Ensure resiliency and avoid single points of failure.

This language received bipartisan support in the House of Representatives and the Senate and has been included in several legislative packages. Last year, the language was included as part of the Spectrum Innovation Act, a bill that would have directed the revenue from spectrum auctions managed by the Federal Communications Commission (FCC) to fund NG9-1-1 implementation. Unfortunately, the bill did not pass due to reasons unrelated to the NG9-1-1 provisions.

Next Steps

This year, APCO is focused on achieving enactment of the Coalition’s carefully crafted NG9-1-1 legislation, and providing NTIA (the agency responsible for implementing the grant program) with borrowing authority to allow the grant program to be implemented as soon as possible. APCO would support passage of the bill through reintroduction of the Spectrum Innovation Act or as part of any legislative vehicle. We are focusing our advocacy on key House and Senate offices to sustain and grow support for the bill language.

Download these talking points on NG9-1-1 funding legislation.

Reclassification of Public Safety Telecommunicators

What’s the issue?

The federal government’s catalogue of occupations, the Standard Occupational Classification (SOC), categorizes PSTs as an administrative/clerical occupation, but there is a much more appropriate “protective service” 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 classified as 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’. While not having any direct impact on salaries, benefits, or state-level job classifications, fixing the federal classification is a common-sense, zero-cost change that would recognize the life-saving work performed by PSTs.

APCO’s Efforts

The Office of Management and Budget (OMB) controls the SOC and has the authority to classify PSTs as a protective service occupation. 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. Simply put, classification within the Office and Administrative Support group is inappropriate given the stress, training, and lifesaving nature of the work performed by PSTs. APCO has explained this in formal comments to OMB, and even provided rebuttals to several of OMB’s justifications for not correcting the classifications, but so far OMB has been intent on maintaining 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 (in the last session of Congress, bill numbers HR 2351/S 1175) would do just that. APCO worked closely with congressional staff in the House and Senate to introduce the 9-1-1 SAVES Act in 2019 and again in 2021. During both of those prior sessions of Congress, the bills received bipartisan support and the language from the 9-1-1 SAVES Act was included in a larger piece of legislation, the National Defense Authorization Act (NDAA). Unfortunately, each time the House and Senate ultimately moved forward with a version of the NDAA that did not include the reclassification provision.

Next Steps

In the new session of Congress, APCO will work to get the 9-1-1 SAVES Act reintroduced quickly and vigorously pursue passage. Simultaneously, APCO will continue to push OMB to correct the classification on its own.    

Download talking points on the 9-1-1 SAVES Act.

Health and Wellness Resources for ECCs

What’s the issue?

Health and wellness are huge challenges in 9-1-1. A recent report identified PSTs as one of the top ten most stressful occupations, and research has shown that the stress of working in emergency communications dramatically increases rates of suicidal thinking. Based on one study, approximately one in seven 9-1-1 professionals reported having suicidal thoughts. That’s comparable to rates for fire/rescue personnel and more than four times the rate in the general population.  

Dealing with this serious challenge to the 9-1-1 community will require significant efforts, including raising awareness, creating guidance for mental health professionals, and supporting resources like peer support programs.

APCO’s Efforts

APCO supports health and wellness in numerous ways, particularly through the work of its Health and Wellness Committee. On the legislative front, APCO worked closely with Congresswoman Robin Kelly’s (IL) office to develop legislation that would provide support for 9‑1‑1 professionals. The bipartisan PROTECT 9-1-1 Act (in the last session of Congress, bill number HR 4319) includes several measures to advance health and wellness for 9‑1‑1 professionals, including:

  • 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.

Next Steps

Last Congress, the PROTECT 9-1-1 Act received bipartisan support in the House. APCO is working to get the bill reintroduced and seeking additional sponsors to grow support and get this legislation passed.

Download talking points on the PROTECT 9-1-1 Act.

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.

Regulatory Update from APCO’s Chief Counsel at APCO 2022

By Jeff Cohen

On August 7, during APCO’s Annual Conference, Chief Counsel Jeff Cohen provided the following report on APCO’s advocacy efforts at the Federal Communications Commission (FCC):

APCO has continued to press for regulatory actions at the FCC to promote public safety communications. I will touch on some key points of interest, but please feel free to reach out to discuss these issues or any others in greater detail. 

Since last year’s conference, Jessica Rosenworcel was sworn in as Chair of the FCC. Chairwoman Rosenworcel is a long-time champion of public safety issues and has taken action on several public safety communications items in the past year. The Chairwoman has also been an advocate for reclassification of public safety telecommunicators at the federal level and has been instrumental in building support for major NG9-1-1 funding legislation.

The FCC remains a 2-2 split of democrat and republican commissioners as we are still awaiting confirmation of a 5th commissioner. This can have the effect of hindering some action yet there has been support from both sides on several public safety issues.

Before I get into details, let me explain how as a general matter APCO’s advocacy distinguishes itself from other stakeholders. First, public safety should not bear any new or additional costs or responsibilities that more properly rest with service providers and vendors. Second, when it comes to 9-1-1, we advocate from the perspective of what will best serve the operational needs of 9-1-1 professionals. Third, when it comes to spectrum, it is the responsibility of new entrants and the FCC to ensure that public safety operations remain protected from interference.

Ok I’ll now address a few areas where we’ve seen modest, but overall positive improvements in the past year.

9-1-1 Outage Reporting, Reliability, and Resiliency

ECCs need timely, actionable information when network outages impact the ability of the public to reach 9‑1‑1.

We have pressed for rule changes that would require service providers like wireless carriers to share timely information about outages with ECCs in an easily accessible format. APCO has also called for the carriers to establish a two-way contact database to ensure that ECCs and service providers know who to contact in the event of an outage.

While we await action on these needed changes, the FCC has taken some steps toward enhancing network resiliency and reliability. Last September, Chairwoman Rosenworcel and Commissioner Carr visited Louisiana to investigate the impacts of Hurricane Ida on emergency communications. The FCC then proposed rules to improve outage notifications, including the information provided to ECCs. And just a few months ago Commissioner Carr participated in an APCO webinar on improving emergency communications resiliency where he announced support for certain reliability enhancements.

In July, and with APCO’s support, the FCC adopted new rules regarding arrangements among the major wireless carriers to increase coordination and information sharing during emergencies. For example, the new rules require all wireless service providers to execute roaming agreements with each other and to share resources in emergency situations. 

Location-Based Routing

I’ll now turn to location-based routing, which means routing wireless 9‑1‑1 calls based on the location of the device instead of the location of the cell tower handling the call. Until recently, location-based routing hasn’t been considered technically feasible, but now AT&T is implementing location-based routing nationwide, and T-Mobile has implemented it in some areas. The FCC recently sought public comment on requiring location-based routing.

APCO has advocated that the FCC should require carriers to provide location-based routing and explained that the time saved without needing to transfer a call to another ECC could save thousands of lives each year. Also, because some carriers are voluntarily providing location‑based routing, we have pushed back on suggestions that 9‑1‑1 authorities should be responsible for enabling location-based routing or bear some costs, and explained that location‑based routing is not, and need not be, dependent on the deployment of pre‑NG9‑1‑1 technologies such as Emergency Services IP Networks or ESInets.

In another proceeding, the FCC sought feedback on a request that the agency begin a proceeding to adopt rules to facilitate the transition to NG9‑1‑1. APCO challenged assumptions made in the request about how NG9‑1‑1 costs should be allocated between the industry and public safety, cautioning against developing rules based on how NG9‑1‑1 has been envisioned in the past or how service providers want to be deploying NG9‑1‑1. We also advocated for more concrete ways the FCC could facilitate NG9‑1‑1, to require interoperability of 9‑1‑1 service providers, and location-based routing.

We await further FCC action.

Wireless 9-1-1 Location Accuracy

Next I’ll discuss wireless 9‑1‑1 location accuracy. APCO has continued efforts to ensure ECCs receive the best possible location information with 9‑1‑1 calls.

In April 2021, the wireless carriers failed to meet an FCC requirement to provide vertical location information with 9‑1‑1 calls. The FCC fined the carriers and gave them an additional year to comply. The carriers could comply by providing either dispatchable location such as 123 Main St., Apartment 501, or “z-axis” information represented as an estimated “height above ellipsoid,” which is not the same as height above ground or sea level. The focus must be on dispatchable location because that’s far more actionable than the z-axis approach, which – even if the vertical estimate is accurate – would require agencies to obtain 3D maps of all buildings and new software to use the information. And again, we have pushed back on stakeholders who believe 9‑1‑1 should bear such responsibilities.

This summer the carriers announced that they were compliant with the z-axis rules. We’re making sure the carriers are truly compliant, but we’re also staying focused on the bigger picture to get the location information that ECCs need.

Spectrum

Now I’ll pivot to some updates on spectrum issues.

First, the 6 GHz band, which is heavily used for long haul microwave links essential to public safety communications. In 2020, the FCC opened the 6 GHz band to widespread use by unlicensed devices, such as Wi-Fi routers, despite significant concern over the threat of interference to public safety communications. We continue to pursue a number of efforts at the FCC in light of mounting evidence, including real-world testing, that validated our interference concerns.

Last fall, APCO and others asked the FCC to stop authorizing new unlicensed devices and to re-evaluate how to share the spectrum while protecting public safety from interference. These filings remain pending with the FCC.

APCO is closely monitoring developments with the band, including ensuring that interference protection mechanisms are as effective as claimed, and will continue to urge the FCC and industry to take the necessary steps to protect public safety operations from harmful interference.

Next an update on the 4.9 GHz band. The vision for this spectrum was to give public safety a dedicated option for new broadband communications. In 2020, the FCC adopted rules that would have effectively given this band to states to lease for commercial use. APCO was successful in convincing the FCC to reverse that rule change, and in September 2021, the FCC proposed an alternative approach that would refocus on public safety use of the band. APCO offered recommendations that would improve public safety use, spur innovation, improve coordination, and only allow other entities to use the band if public safety retains priority and preemption rights. Presently, we are exploring options for the best path forward.

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.

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

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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.