Position Statements
Index
Issue/White Papers
Operation of Low Power Auxiliary Stations Within the 700 MHz Band
APCO International strongly supports rules that would prohibit further
operation of low power auxiliary stations within the 700 MHz band after
February 17, 2009; and prohibit the manufacture, import, sale, offer for
sale, or shipment of devices that operate as low power auxiliary stations in
the 700 MHz band.
APCO International believes that there is a very real danger of interference
from the low auxiliary devices to public safety land mobile radio systems.
APCO International believes there is a danger when wireless microphones are
used for auxiliary broadcast operations at large group events it could
interfere with first responders' 700 MHz public safety radios in the
vicinity. Indeed, one can imagine an emergency at a public gathering where
somebody uses a wireless microphone to direct an evacuation, not realizing
that they are disrupting radio communications for first responders arriving
on the scene.
APCO International is also very concerned with the substantial number of
wireless microphones that are now being used in the 700 MHz band without
proper FCC authorization.
APCO International urges the FCC to take aggressive steps to eliminate those
nonconforming uses as quickly as possible.
National Emergency Communications Plan (NECP)
APCO International appreciates the hard work that was done by the Department of Homeland Security (DHS) Office of Emergency Communications (OEC) in developing the National Emergency Communications Plan.
APCO International believes the plan provides a good first step in identifying the goals and objectives that could become the building blocks to improving local, state, and federal interoperable communications.
APCO International believes the NECP must be flexible enough to accommodate special needs of local and state governments.
APCO International believes there has to be considerable outreach by the Department of Homeland Security Office of Emergency Communications (OEC) and other organizations to promote the NECP and educate local, state, and federal officials about the goals of the plan.
APCO International believes the plan should not create unreasonable expectations on public safety agencies or local governments that cannot be met. The plan should also provide adequate funding measures to ensure all local and state governments are able to contribute to the national goal of improving interoperable communications.
APCO International believes the OEC must take a lead role in cataloging current standards and working with nationally accredited standards setting organizations to provide a clear road map for local public safety agencies to follow. The OEC must be adequately funded so that it can provide the necessary resources to accelerate the development of technical and operational communications standards that are identified in the NECP.
APCO International’s primary concern about the NECP is that the OEC may not have the necessary funding and resources to accomplish the objectives of the plan. APCO International believes that unless the NECP gets the full backing of Congress to appropriate the necessary funds the plan will not accomplish its goals.
ADOPTED BY THE APCO INTERNATIONAL BOARD OF OFFICERS SEPTEMBER 3, 2008
The Warning, Alert and Response Network (WARN) Act
APCO International supports the Warning, Alert, and Response Network (WARN) Act
(P.L. 109-347) that enables commercial mobile service alerting capability for
commercial mobile service providers that voluntarily elect to transmit emergency
alerts to subscribers.
APCO International supports standardized and well governed implementation of
commercial mobile alerting services as required by the WARN Act.
APCO International believes that all emergency alerts by commercial mobile
service providers must provide adequate information to manage the publics’
concerns during a large scale incident. APCO International is concerned that
inadequate information, which requires the thousands of subscribers to call a
number to get additional information about an emergency, could result in a
bottleneck of the telecommunications and 9-1-1 systems. APCO International does
not support the use of call back numbers.
APCO International strongly believes that before commercial mobile service
providers deploy alerting systems they should work with local, regional and
state government authorities to ensure the information being transmitted is well
communicated and coordinated with the appropriate public safety agencies
including public safety communications centers who will have to respond to
publics’ inquiries about the emergencies.
APCO International believes that the alerting system boundary should be at the
smallest geographic area that is technically possible, but at the very least the
alerting system’s geographic boundary should be a county within a state.
APCO International believes that such systems should have priority status to
transmit alerts as long as this priority does not interfere with other emergency
service transmissions using the commercial mobile service provider’s networks.
APCO International believes that such systems should be able to transmit
emergency alerts to subscribers in languages in addition to English, to the
extent practicable and feasible.
APCO International strongly supports the provision in the WARN Act that requires
a commercial mobile services provider that elects not to offer emergency
alerting services to its subscribers to receive from the subscriber
acknowledgement that service is not available.
ADOPTED BY THE APCO INTERNATIONAL BOARD OF OFFICERS DECEMBER 12, 2007
APCO Petitions for Declaratory Ruling on Wireless
Location Accuracy
WHEREAS, The deployment and effective operation of wireless enhanced 9-1-1 is
crucial to the public’s safety; and
WHEREAS, Effective leadership is needed to advance the continual improvement of
deployed wireless enhanced 9-1-1 systems; and
WHEREAS, APCO International is a national leader in public safety communications
issues involved in advocating for the improvement of enhanced wireless 9-1-1;
and
WHEREAS, The APCO International Executive Council has determined that
coordination of wireless enhanced 9-1-1 deployment and operation is a priority
for the Association by creating Project LOCATE; and
WHEREAS, Project LOCATE has coordinated Association and industry activities
related to supporting the deployment and improving the operation of wireless
enhanced 9-1-1 throughout the country; and
WHEREAS, In 2004, APCO International filed a Petition for Declaratory Ruling
with the Federal Communications Commission addressing the measurement of
accuracy in deployed enhanced 9-1-1 systems; and
WHEREAS, Project LOCATE has undertaken a variety of activities to examine the
effectiveness of deployed enhanced wireless 9-1-1 including a comprehensive
testing project in selected markets across the country; and
WHEREAS, Project LOCATE has concluded its testing project and has made specific
operational and policy recommendations to the APCO Board of Officers; Now,
therefore, be it
RESOLVED, That the APCO membership quorum, here assembled, strongly
encourages the Board of Officers of APCO International to seek positive action
by the Federal Communications Commission to rule in favor of the APCO 2004
Petition for Declaratory Ruling, specifically Section IIIA of the NPRM.
Adopted by unanimous vote by the APCO International quorum, August 5, 2007,
Baltimore, Maryland.
National 9-1-1
Education Month
(Click
here to download PDF version)
Whereas 9-1-1 is nationally recognized as the number to call in an emergency
to receive immediate help from police, fire, EMS or other appropriate emergency
response entities;
Whereas in 1967, the President's Commission on Law Enforcement and
Administration of Justice recommended that a "single number should be
established" nationwide for reporting emergency situations and other Federal
Government Agencies and various governmental officials also supported and
encouraged the recommendation;
Whereas in 1968, the American Telephone and Telegraph Company (AT&T)
announced that it would establish the digits 9-1-1 as the emergency code
throughout the United States;
Whereas 9-1-1 was designated by Congress as the national emergency call
number under the Wireless Communications and Public Safety Act of 1999 (P.L.
106-81);
Whereas the ENHANCE 911 Act of 2004 (P.L. 108-494) established enhanced 9-1-1
as “a high national priority” as part of our Nation’s homeland security and
public safety;
Whereas it is important that policy makers at all levels of government
understand the importance of 9-1-1, how the system works today and steps that
are needed to modernize the 9-1-1 system;
Whereas the 9-1-1 system is the connection between the eyes and ears of the
public and the emergency response system in the U.S. and is often the first to
know of emergencies of all magnitudes making 9-1-1 a significant homeland
security asset;
Whereas there are over 6,000 9-1-1 public safety answering points (PSAPs)
serving more than 3,000 counties and parishes throughout the United States;
Whereas PSAPs answer more than two hundred million 9-1-1 calls each year in
the United States and a growing number of 9-1-1 calls are made using wireless
and IP-based communications services;
Whereas a growing segment of the population, including the deaf and hard of
hearing and individuals with speech disabilities, are increasingly communicating
with non-traditional text, video and instant messaging communications services
and expect these services to be able to connect directly to 9-1-1;
Whereas the growth and variety of means of communications, including mobile
and IP-based systems, impose challenges for accessing 9-1-1 and implementing
enhanced 9-1-1 and require increased education and awareness about their
capabilities;
Whereas numerous other N-1-1 and 800 number services exist for non-emergency
situations, including 2-1-1, 3-1-1, 5-1-1, 7-1-1, 8-1-1, poison control centers
and mental health hotlines, and the public needs to be educated on when to use
these services in addition to or instead of 9-1-1;
Whereas people of all ages use 9-1-1 and it is critical to educate the public
of all ages on the proper use of 9-1-1;
Whereas senior citizens are at high risk for needing access to 9-1-1 and a
large segment of this population is learning to use new technology;
Whereas thousands of 9-1-1 calls are made every year by children properly
trained on the use of 9-1-1 resulting in lives saved which underscores the
critical importance of training children early in life about 9-1-1;
Whereas there is widespread misuse of the 9-1-1 system, including prank and
non-emergency calls, which can result in costly and inefficient use of 9-1-1 and
emergency response resources and a need to reduce this practice;
Whereas parents, teachers, and all other care givers need to play an active
role in 9-1-1 education for children, but will do so only after being first
educated themselves;
Whereas there are many avenues for 9-1-1 public educations such as safety
fairs, school presentations, libraries, churches, businesses, PSAP tours or open
houses, civic organizations and senior citizen centers;
Whereas children, parents, PTA and teachers are important groups to educate
about the importance of 9-1-1 through targeted outreach efforts to public and
private school systems;
Whereas we as a nation should strive to annually host at least one
educational event in every school in the country every year regarding the proper
use of 9-1-1;
Whereas an established National 9-1-1 Education Month could include public
awareness events, including conferences and media outreach, training activities
for parents, teachers, school administrators, other care givers and businesses;
educational events in schools and other appropriate venues; and production and
distribution of educational content on 9-1-1 designed to educate people of all
ages on the importance and proper use of 9-1-1;
Whereas Americans deserve the finest education we can offer regarding 9-1-1
education: Now, therefore be it
Resolved,
That the APCO International Board of Officers recognizes April as “National
9-1-1 Education Month” And be it
Further resolved, That the APCO International Board of Officers urges the U.S. Congress
and the governors of all states and territories to recognize April as “National
9-1-1 Education Month”
ADOPTED BY THE APCO INTERNATIONAL BOARD OF OFFICERS June 25, 2007
SPECTRUM TO BUILD OUT A PUBLIC/PRIVATE NATIONAL BROADBAND NETWORK TO IMPROVE FIRST RESPONDER COMMUNICATIONS
Association of Public-Safety Communications Officials (APCO) International believes that new and emerging technologies will greatly improve the way emergency services are able to protect and serve the public.
APCO International believes that today’s emergency services require the collection and processing of large amounts of data, images, and high speed two way video during mission critical operations.
APCO International believes that in order to provide a secure and reliable next generation broadband network for public safety communications, sufficient spectrum is needed. APCO International also believes that there is benefit to be gained by fostering a viable public/private partnership that will allow the sharing of spectrum resources between public and private networks.
APCO International supports the allocation of federal spectrum in the 700 MHz D-Block range to establish a private/public partnership to build out a national wide-area broadband communications network to improve first responder interoperable voice, data and video communications capabilities.
APCO International strongly believes that the Federal Communications Commission (FCC) should continue to set requirements on the sale of the D-Block spectrum to meet public safety’s communications needs.
APCO International believes Congress and the FCC must continue to take action to ensure public safety has access to adequate spectrum and federal funding to improve emergency response services by building a public/private partnership for broadband networks.
Support Ending Misuse and Abuse of 9-1-1
Funds
APCO International support withholding federal 9-1-1 and E9-1-1 grant monies
from States and political subdivisions who misappropriate, mis-allocate and
divert 9-1-1 monies from their intended purpose. We encourage advising of
Congress and publishing of information regarding States that divert 9-1-1 funds
from intended purposes. Recognizing the authority of the Federal Communications
Commission, we support improved reporting by all States and political
subdivisions on the diversion of 9-1-1 funds, but caution against burdensome
audits or reporting obligations.
APCO encourages all states and local governments that collect funds for the
purposes of wireless E9-1-1, to use those funds for the express purpose of PSAP
readiness for wireless E9-1-1. If any funds are found to be in surplus of the
amount needed for initial readiness, funds should be reserved for future
upgrades and enhancements of the emergency telephone system. PSAPs must be able
to receive and process location and call back information from wireless phone
devices. Any use of such funds other than for this purpose is not supported by
APCO and are in contrast to good sound public safety policy. APCO believes that
the public is at risk in those situations whereby funds are collected, yet used
for purposes other than PSAP needs for 9-1-1. Furthermore, APCO believes that
consumers are being misled by state and local government organizations that use
911 funds for other purposes. This must not be permitted to continue.
Internet Telephony (VoIP) 9-1-1
The public has an expectation that telephone services will provide 9-1-1 and
Enhanced 9-1-1 capability (which includes caller location information),
regardless whether the telephone operates on the public switched telephone
network, wireless networks, or the Internet. Yet, at present there is a very
real likelihood that a “ 9-1-1 ” call from a VoIP telephone will be lost,
delayed, or misrouted.
Some VoIP providers have recently agreed to voluntarily work towards
permanent solutions and, in the interim, to begin routing “ 9-1-1 ” calls to
ten-digit emergency numbers within three to six months. That is not an
acceptable solution, as it takes a 21 st century technology (IP telephony) and
shoves it into a 1960’s method of reporting life-threatening emergencies.
Routing VoIP “ 9-1-1 ” calls to ten-digit emergency numbers will also disrupt
and strain the limited resources of Public Safety Answering Points (PSAPs),
which are already struggling to provide wireless E9-1-1 capability.
The voluntary efforts of VoIP providers to address 9-1-1 issues are certainly
welcome. However, enforceable regulation is necessary to ensure that solutions
are sufficient to satisfy the public interest and apply to all VoIP providers.
Such 9-1-1 requirements are needed even if the FCC determines that application
of other telecommunications regulation to VoIP is unnecessary.
APCO International supports the FCC t Report and Order in WC Docket Nos.
04–36 and 05–196 (“Order”). APCO International strongly opposes any effort that
would prevent the FCC from enforcing rules that require 9-1-1 and E9-1-1
capability for all new VoIP customers. We believe that the FCC’s ability to
enforce existing rules is in the best interest of the public’s safety.
APCO International strongly encourage all VoIP services take action to ensure
that when an emergency 9-1-1 call is placed from a telephone using IP telephony,
the call is completed to the appropriate Public Safety Answering Point (PSAP)
and the physical address of the caller’s location is displayed via the Automatic
Location Identification (ALI) database.
APCO International recognizes the authority of state and local government to
assess 9-1-1 fees, where authorized by valid statutes, against VoIP subscribers
and the responsibility of VoIP providers to collect and submit the 9-1-1 fees.
APCO International recognizes the authority of the PSAP to determine 9-1-1
call routing, including routing of 9-1-1 calls placed utilizing VoIP technology,
based upon its jurisdictional requirements and policies; and be it finally
resolved
APCO International does not support routing 9-1-1 calls, including those
placed utilizing VoIP, to an agency’s ten-digit administrative lines, except as
necessary in a short term interim solution, with the agreement of the PSAP.
APCO International strongly believes that VoIP providers should not be able
to offer services to new customers in geographic areas where the provider is not
able to comply with the FCC’s 9-1-1 and E9-1-1 requirements contained in the
FCC’s Order.
Telematics
APCO strongly encourage the continual development of life saving devices
through telematics services.
APCO is not in favor of requiring direct connect from Automatic Crash
Notification (ACN) devices directly to Public Safety Answering Points (PSAP)
through legislative/regulatory mandates.
APCO continues to work with telematics industry experts in the development of
training standards for information gathering and dissemination from
the telematics call center to the public safety emergency communications center.
APCO embrace the new technologies brought forth by the telematics industry
for the benefit of public safety.
APCO recognize that a close working relationship between the telematics
industry and the public safety community is necessary for the development and
implementation of the standards and support of the new technologies.
Plain Speech in Public Safety
Communications
Plain speech for public safety communications operations has been a matter of
considerable discussion within the first responder community for several years.
With the requirement to implement the National Incident Management System
(NIMS), an effort by the Department of Homeland Security (DHS) to better
coordinate emergency response between different jurisdictions and disciplines,
APCO International has considered this issue in the context of sharing
information by first responders.
Due to a number of important factors, APCO International renews its assertion
that plain speech communications over public safety radio systems is preferred
over the traditional 10-Codes and dispatch signals used by a majority of law
enforcement agencies across the country. It is recognized that valid concerns
about officer safety or confidential information being jeopardized should be
resolved between the local agency(s) and the serving public safety
communications center.
The impact of plain speech communications upon the public safety
communications center allows the dispatcher and the field responder to use
common language descriptors to indicate the nature of the event, situation, and
person(s) that is the topic of the radio transaction. The abandonment of agency
specific 10-Codes and dispatch signals support the incident command concepts to
effectively coordinate response activity not only in multi-agency disaster
situations but in routine intra-agency operations. APCO International asserts
that the routine practice of effective radio protocol and discipline is the best
form of disaster preparation.
APCO International recognizes that the lack of consistent, reliable
communication services and/or poor performance are often cited in after action
reports as a major failure during disaster situations. The fundamental
principles of prompt, effective, competent communication will be dramatically
improved, particularly when resources are deployed that originate from outside
the primary response area, with implementation of plain speech procedures by all
public safety agencies.
APCO International agrees with the NIMS Integration Center that the use of
plain speech in emergency response situations is a matter of public safety,
especially the safety of first responders and those affected by the incident. To
best assure the use of this common, universal language during a major event, its
daily use is required.
The entire Incident Command System (ICS), an effort of NIMS to provide a
common organizational structure for the immediate response to emergencies
involving the coordination of personnel and equipment on-site at an incident,
requires resources being managed and functioning under a planned, approach that
diminishes the risk created by unclear, unfamiliar or misunderstood codes and
signals. Using plain speech is a simple remedy to reduce communication failures.
This common approach is essential to achieving functional interoperability
across all jurisdictions and disciplines.
APCO International encourages the use of sensible plain speech alternatives for
common 10-Codes. For example:
- 10-4 – copy or acknowledge or understood
- 10-20 – my location is
- 10-28 – registration check – reg. check
APCO International believes that officer safety will be enhanced through
thoughtful development of plain speech alternatives to codes/signals that
protect the sensitivity of confidential information.
APCO International strongly supports the autonomy of local, county, state and
other law enforcement agencies to make operational decisions. However, NIMS
compliance is important and this fundamental communication procedure will have a
dramatic affect on interoperability across the nation. APCO International
supports the goal of NIMS of good faith efforts at all levels nationwide to move
to plain speech for all emergency operations.
TCS and HBF Petition to Waive Part 52 of Commission Rules
Position Statement
APCO International is concerned that some providers of VoIP Position Centers (VPC) may have to discontinue services to VoIP Service Providers (VSP) if they are denied access to pseudo Automatic Number Identification (p-ANI) codes.
APCO International respectfully requests that the Federal Communications Commission (Commission) fully examine the impact of a decision to deny VPC access to p-ANI codes and its affect on the ability of public safety answering points (PSAP) to locate VoIP 9-1-1 callers using current VPC services.
APCO International believes that if VPCs are forced to discontinue services to VSPs VoIP consumers may be at risk when calling 9-1-1.
APCO International takes no position on the technology used by VPCs to provide services to VoIP carriers as long as such services meet the requirements set in the Commission’s VoIP 9-1-1 Order.
