L.R. Kimball

House Bill 3630

The Federal Communications Commission (FCC) announce it is waiving the Jan. 1, 2013 deadline to migrate to12.5 kilohertz or narrower technology for public-safety and business/industrial land mobile radio networks operating on T-Band (470–512 MHz) spectrum. The waiver comes in response to the recently enacted Middle Class Tax Relief and Job Creation Act of 2012 (Act). The Act requires the FCC to reallocate the T- band and auction the spectrum within nine years and requires public-safety entities to vacate the T-band within 11 years.  (full details of the T-Band giveback requirements and supporting information is described in further detail in L.R. Kimball’s recent white paper T-band Giveback.

Public-safety entities with narrowband systems in the T-Band petitioned the FCC for waivers following the enactment of the Act, stating that it would be impossible for agencies narrowbanding this year to use the new equipment for its full life cycle within the 11 year period. The FCC concluded that it would be unfair to continue to require licensees in the T-band to invest in narrowband systems that may have to be relocated in the near future.

The FCC also waived a related rule that prohibited vendors from manufacturing or importing 25 kHz-only equipment that operates in the T-Band. The FCC reaffirmed its commitment to the narrowbanding transition in the 150 – 174 MHz and 421 – 470 MHz bands because of the continued demand for private land mobile radio.

Additionally, the FCC announced a limited suspension of certain applications for Part 22 and 90 services operating in the T-band spectrum. The T-band suspension applies only to applications for new or expanded use of T-band frequencies and does not apply to radio services that pertain only to operations on spectrum other than the T-band. The freeze will help maintain a stable spectral landscape while the FCC determines how to implement the Act.

The suspension applies to applications for the following radio services in the 470 – 512 MHz band:

• Part 22 public mobile services: paging and radiotelephone (radio service code CD) and offshore radiotelephone (radio service code CO)

• Part 90 industrial/business pool: conventional (radio service code IG); commercial, conventional (radio service code IK); trunked (radio service code YG); and commercial, trunked (radio service code YK)

• Part 90 public-safety pool: conventional (radio service code PW) and trunked (radio service code YW).

The FCC will no longer accept applications for new licenses that;

• seek to modify existing licenses by adding or changing frequencies or locations;
• seek to modify existing licenses by changing technical parameters that expand the station’s spectral or geographic footprint, such as, but not limited to, increases in bandwidth, power level, antenna height or area of operation.

Pending applications for these services will not be processed until the FCC decides how the Act will be implemented.

This suspension does not apply to applications that

• would not destabilize the licensing landscape, including applications to renew existing licenses without modification;
• seek to modify existing licenses by deleting frequencies or locations;
• seek to modify existing licenses by changing technical parameters that do not expand the station’s spectral or geographic coverage, such as decreases in bandwidth, power level or antenna height;
• seek to modify existing licenses by changing the number of associated mobile units or temporary fixed stations;
• seek to modify existing licenses by adding or moving control points;
• assign, transfer or lease existing licenses; notices of construction or consummation; requests for extensions of time to construct or consummate previously granted applications;
• cancel licenses;
• request special temporary authority for short-term operations.  

The FCC Order that waives the narrowband deadline can be found at: http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db0426/DA-12-642A1.pdf

The FCC Public Notice that suspends certain applications can be found at: http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db0426/DA-12-643A1.pdf

The GIS Data Challenge – GIS Planning for PSAP Operations

GIS data is a vital component to the 9-1-1 system and will become even more important with the arrival of Next Generation 9-1-1 (NG9-1-1).  Just like the human body and automobiles, testing the components and preventative care often pinpoint symptoms that may need to be corrected to avoid a sudden breakdown or long-term issues. Within a 9-1-1 system, equipment and components are tested for performance and reliability.  GIS data should be no different as it provides important information to help 9-1-1 call takers determine the location of a 9-1-1 caller. 

As L.R. Kimball outlined in a recent white paper, many 9-1-1 directors have concerns about the accuracy of their GIS data.  Accurate data is paramount to assuring that first responders are sent to the correct location, errors in datasets could raise the risk of potential delays or misrouted emergency response.  News stories have described incidents when emergency responders are sent to an incorrect address, causing critical delays that have led to loss of property and even loss of life.   

GIS data plays an important role in helping to locate 9-1-1 callers, yet many PSAPs do not know the level of accuracy of their GIS data or know what symptoms exist that could put them at risk.  Examples of addressing errors include duplicate road names and addresses, incomplete address ranges, overlapping ranges, unaddressed road, standardization issues, misspellings and/or inconsistent road names and addresses across databases. 

GIS data will become increasingly more important in NG9-1-1, which is being built on Internet Protocol (IP)-based technology.  GIS data will play an additional role in NG9-1-1 as it will be the GIS data that will be used to route the call, where data accuracy will be more important than ever. 

Rather than waiting to discover an address error during a 9-1-1 call, there are ways for 9-1-1 directors and staff to assess the accuracy of their datasets and pinpoint symptoms that can be corrected in a pro-active manner. 

1.  Data checks can be performed to pinpoint existing issues within data systems, either in-house or by contracting outside help.  This assessment provides a starting point for effective GIS planning.  Once the types and numbers of errors are known, a PSAP can devise a plan to correct them. 
2. Another important aspect of data accuracy and data maintenance is the adherence to the most current database standards for 9-1-1 addressing.   Adhering to the latest industry standards allows data to be formatted in a way that will work most effectively across many of the 9-1-1 systems that rely on GIS data. 
3. Establishing an effective maintenance plan is critical to long term sustainability of data accuracy levels.  An effective maintenance plan covers all of the processes from the time a new address is assigned to the time the data is added to the GIS datasets and those updates reflected in the CAD systems for 9-1-1 calls.  

GIS experts at L.R. Kimball urge public safety officials to consider investing in GIS data and to perform an assessment of GIS data to gain a starting point and uncover any issues that might exist.  This is the best first step to begin planning and prioritizing for any required improvements to achieve long-term success, minimize overall risks, and advance towards the accuracy needed in NG9-1-1.

 

Change Control and Documentation

by Lori Kleckner

This month we look at section 10 of the NENA Security for Next Generation 9-1-1 (NG-SEC) document for direction regarding change control and documentation. 

Changes to the NG9-1-1 environment can cause rippling effects throughout the network and to any other connected resources. What may appear to be an innocuous change to an application could cause connecting applications and the network to stop functioning. A change which has not been documented may be unknown to others. This causes troubleshooting to be much more difficult. Without effective change control an organization may not ever truly know what exists in their environment or how their systems are configured. The lack of change control also makes upgrading more complicated.

 During assessments L.R. Kimball typically finds that change control processes are either incomplete or non-existent. By our accounts only about 15% of the sites assessed utilize an adequate change control process. 

Change Process

NG-SEC requires a formal change control process to be in place which includes a team of subject matter experts to review and approve proposed changes to architecture, design and functionality, prior to implementation. Basic change control includes:

• Change request
  • Description, justification, impact
• Change review
  • Possible conflicts and risks, complete information, approval
• Implementation timeline
  • Step – by – step process with dates
• Pre-change testing
  • Test environment which mimics production environment, test all steps in the process, update change request if needed
• Back out procedure (in case of failure)
  • Process required to return to the pre-cutover state
• Post change testing
  • List of systems or processes to test, assuring the production environment is functioning as expected
• Document and retain

All documents generated during the change process including lessons learned to aid future changes

Summary

Without a change control process in place, who knows what is going on with the network? What applications are installed, have patches been applied, what the firewall is filtering. It can be a confusing mess. You may end up purchasing a product and find out you already have one installed, but you do not know that because information was not shared, changes were made in pockets and not everybody was informed.

Our next NG-SEC blog will cover compliance audits and reviews; always a fun topic. Actually, if you do not have a change control process in place, an audit could be a good way to find out what is on your network.

DB's Corner - Aluminum Finishes

by Dennis Buirge

After being volunteered to write specifications approximately 25 years ago, I am still amazed at the knowledge base one must have to prepare accurate specifications.  This relates to not only knowing original material, but also keeping up with changes to industry standards and company mergers.  Feeling my oats regarding the knowledge of the aluminum finish standards, specifications for exterior sheet aluminum wall panels were prepared referencing AAMA 2605.  The manufacturer’s representative, upon review of the draft, politely informed me that the finish specification was improperly referenced.  Do you know why?

Decades ago while still a neophyte to writing specifications, someone was kind enough to explain potential finishes on aluminum products using American Architectural Manufacturers Association (AAMA) standards.  At that time, the AAMA standards used 3 digit numbers; however, the standards were revised to 4 digits around 1998.  A ‘good’ system coating currently referencing AMMA 2603 - Pigmented Organic Coatings on Aluminum Extrusions and Panels, formerly 603, uses thermosetting acrylics, polyamides (Nylon), polyolefins (polyethylene or polypropylene), and PVC (PolyVinyl Chloride) and essentially covers the lower end coating systems.  The ‘better’ and ‘best’ systems use PVDF (PolyVinyliDene Fluoride) or fluoropolymers, better known by their trade names of Kynar or Hylar and according to an internet website are the number one specified architectural coating for aluminum in the world. These systems use higher performing coatings such as aliphatic urethanes, super-durable siliconized polyesters, and PVDF powder coatings. AAMA 2604 - High Performance Organic Coatings on Aluminum Extrusions and Panels, formerly 604, contains a minimum of 50% by weight of either Kynar 500 or Hylar 5000 resin, while AAMA 2605 - Superior Organic Coatings on Aluminum Extrusions and Panels, formerly 605, contains a minimum of 70% by weight of either resin. These superior coatings exhibit superior color retention, chalk resistance, corrosion resistance, flexibility, stain resistance, and overall durability over AAMA 603 coatings.

 It was only several years ago that a lesson was learned regarding the difference of aluminum finishes and standards.  Wanting a superior two coat 70% fluoropolymer finish on the exterior sheet aluminum wall panels and related sheet trim, AAMA 2605 was specified.  The ‘draft’ version of the specification was transmitted to the manufacturer’s representative for technical review.  It was then of learning why AAMA 2605 finish does not always apply to aluminum.  But why?  The AAMA 2603 - 2605 series relates to an extruded aluminum substrate (ASTM B 221 - Aluminum and Aluminum-Alloy Extruded Bars, Rods, Wire, Shapes, and Tubes) … it does not apply to a sheet coil coated aluminum substrate (ASTM B 209 - Aluminum and Aluminum-Alloy Sheet and Plate).  So then, what is the proper reference?  Specify AAMA 620 for sheet aluminum substrates and AAMA 621 for sheet steel substrates.  As Ricky Nelson sang in the 1972 chorus of Garden Party, “I learned my lesson well”.

HR 3630 Requires Giveback of T-Band (470 - 512 MHz) Licenses by Public Safety Users

Much of the attention on HR3630 from the Public Safety community in recent weeks has been focused on the funding and governance provisions for a nationwide broadband network, assignment of the “D Block” to Public Safety, and on the NG9-1-1 provisions previously summarized here. One potentially negative aspect of the legislation however is the mandated “give-back” of T-Band spectrum. T-Band refers to the 470 - 512 MHz frequency band, is shared with the television broadcasters (hence the T-Band designation) and was made available on a shared use basis by the FCC for LMR systems such as public safety in 13 major metropolitan areas of the country.

Section 6103 of the legislation requires giveback of UHF T-Band spectrum by Public Safety licensees. The language in the legislation indicates the spectrum must be reallocated no later than 9 years after enactment of the legislation, with relocation of users to be completed 2 years after the spectrum is competitively bid. The expectation is that this spectrum will be reallocated and auctioned to commercial use (likely used for TV broadcast). Proceeds from this future auction are to be used to cover the costs to relocate affected Public Safety licensees, with the remainder going to the U.S. Treasury.

The legislation does not provide any language regarding potential spectrum for relocating existing public safety LMR systems, nor does it identify any funding for pursuing spectrum or migration plans other than the reference indicating proceeds from the future auction are to be used to cover the relocation costs.

The language regarding the T-Band “giveback” in HR 3630 is fairly brief and does not spell out the specifics or detailed rules on how it will happen. We expect the FCC will now take the language and develop the detailed rules or processes needed to effect the legislation. Generally the first step in that process is a release of a Notice of Proposed Rulemaking (NPRM) indicating the FCC’s planned rules and approach, as well as providing an opportunity for comment and inputs.

In the meantime, L.R. Kimball echoes the comments that other industry leaders are advocating…i.e. “don’t panic.” First, a lot can happen over the course of nine years, and there is some speculation that things could change on the mandate. However, at the moment, we do need to take the legislation at face value and do recommend that clients currently using T-Band spectrum begin assessing their specific situation and investigating potential replacement spectrum. Even though the legislation indicates that costs for moving off T-Band are to be covered by the auction proceeds, those funds are somewhat meaningless if there’s no available suitable spectrum to move to.

To clarify, we are recommending that in the near term, clients begin investigation of potential available spectrum, and exploration of the applicable ideas presented, but not necessarily begin actively spending a large amount of funding on a new system. Although the legislation indicates the costs to move these systems is to be covered by the auction proceeds, the details of the process for getting funding, what items will be eligible, etc. are not yet defined. It’s expected the FCC will develop this guidance, a process that might take a year or more to be finalized.

In the meantime, make your politicians and decision makers aware of the likelihood of replacing your existing T-Band system, and potential that some local capital costs may be incurred in the process.

L.R. Kimball is actively monitoring the activity on the T-Band givebacks, and will continue to inform our clients as further information is released, and as the opportunities are presented to submit comments and inputs to the FCC or other bodies.

We have prepared a more detailed briefing, with recommendations and ideas for impacted jurisdictions to consider. Click here to download our white paper, “Key Elements of HR 3630 Impacting Public Safety: T-Band (470 - 512 MHz) Giveback.”

911 Funding Available to Bridge the Rural Telecommunications Divide

A new 911 funding source was recently adopted that could help to spur NG9-1-1 activity in rural areas where funding is sparse and business cases are hard to build. Congress authorized the United States Department of Agriculture (USDA) Rural Utilities Service (RUS) to expand or improve 911 access and integrated emergency communications systems in rural areas in the Food, Conservation, and Energy Act of 2008, but the agency never promulgated rules to implement that authorization, until now. Recently, the RUS adopted an interim rule released in September. The final rule, effective as of March 16, expands the RUS’s existing Telecommunications Loan Program to include loans to rural areas for:

• 911 Access
• Integrated interoperable emergency communications, including multi-use networks that provide commercial or transportation information services in addition to emergency communications services
• Homeland security communications
• Transportation safety communications
• Location technologies used outside of urbanized area

The Telecommunications Loan Program is not competitive and applications are accepted year round. RUS will consider State or Local 911 fees as security if they are pledged to the repayment of a loan.

Eligible Entities

1	Rural utilities; municipalities; commercial corporations; limited liability companies; public utility districts; and cooperative, nonprofit, limited-dividend, or mutual associations
2	State or local governments
3	Indian tribes
4	Emergency communications equipment providers that offer adequate security for a loan where the State or local government that has jurisdiction over the proposed project is prohibited from acquiring debt

The loan program is only available to expand access in rural areas. For the purpose of the loan program, a rural area is any area which is not located within a city, town, or incorporated area that has a population of greater than 20,000 inhabitants; or an urbanized area contiguous and adjacent to a city or town that has a population of greater than 50,000 inhabitants. When making credit decisions, the RUS will consider the extent to which the emergency communications capability or emergency communications benefits already exist in the affected area and the need expressed by the proposed user of the emergency communications technology. A carrier’s competitive situation will be considered in evaluating whether a provider can repay its loan.

USDA is committed to helping rural communities obtain high-quality broadband service that can be used by emergency responders. The new eligibility criteria allows the USDA to leverage public and private resources to speed the rural deployment of dual-use public safety/commercial wireless networks, finance 911 capabilities for carriers and communities and also address homeland security communications needs.

Next Generation 9-1-1 & Cyber Security -- A Year Later

L.R. Kimball recently conducted a second survey on cyber security issues to gain an understanding of how the awareness, attitudes and issues regarding cyber security have changed in the last year. Here are some of the survey highlights:

• 65% of respondents are aware of NENA’s new cyber security standards indicating that while awareness has increased to a decent sized majority, there are still a significant number of folks who are simply not aware of these standards from NENA.
• Overall awareness and recognition of the importance of cyber security in a NG9-1-1 environment continues to be very high at around 71%.
• Approximately 57% of respondents suggested that cyber security is a high priority, while 16% indicated that this is their #1 priority. This is increase of about 3% of each measurement from the preceding survey.
• Respondents believe their IT department is responsible for the security of their organization. While it is true that the IT department is responsible for executing the efforts related to cyber security, it is the management of the call center who is ultimately responsible for the entire center – including cyber security.
• The number of respondents who believe the public is concerned about the security of public safety systems has dramatically risen to 61%. We believe this to be a result of the many high profile attacks that have been highly publicized, including those on public safety systems.
• 50% of respondents (an increase of nearly 40%) have started the planning and budgeting process. The compelling urgency of protecting against cyber attacks appears to be growing.

In an effort to understand where respondents were on the migration continuum for NG9-1-1, we asked questions related to what stage of the process folks were in. L.R. Kimball’s new survey showed that 28% of those surveyed are implementing NG9-1-1. This is a 6% change from our previous survey indicating that the transition to NG9-1-1 continues to occur. Approximately 57% indicated they were still in the planning phases for NG9-1-1.

It is here, during the NG9-1-1 planning stages, that L.R. Kimball believes the journey to effective cyber security begins.

1. Organizations can start the planning and compliance process with a security assessment which will provide a formal and accurate picture of what they have in place.
2. Following the security assessment, an organization should then create a Security Plan which documents its intentions to execute due diligence and defines how it intends to secure its NG9-1-1 system.
3. The Security Plan ultimately leads into the next set of steps necessary to secure a call center: implementing safeguards (e.g. antivirus software, firewalls, policies, etc) and then monitoring and maintaining what's been put in place.

Funding was noted by respondents to our survey as an important issue. 60% felt that lack of budget/funding was a moderate to significant problem. In fact, of all of the potential obstacles to success, funding was the only one that was denoted as a real problem. This is a difference from the previous survey where lack of standards, leadership, and other priorities were identified as obstacles.

What can we do about it? L.R. Kimball believes this is an opportunity for Congress to act -- by providing funding via a grant program specifically targeted at securing public safety agencies. Public safety systems are part of our nation’s critical infrastructure. Funding improvements in their security will bolster its ability to withstand attacks while potentially creating jobs (e.g. the new role of security administrator for public safety agencies).

The nation is currently undergoing one of the most important transformations of its public safety infrastructure as it evolves its legacy 9-1-1 system to NG9-1-1. In this new interconnected, IP-enabled world, the need for cyber security has never been more critical. We know that, the industry knows it, and so do the hackers. Now what?

Click here to download our white paper, "Next Generation 9-1-1 & Cyber Security -- A Year Later."

NG9-1-1 Public Education at NENA Development Conference in Orlando Florida

The National Emergency Number Association (NENA) Public Education & Training Committee held two breakout sessions on NG9-1-1 Public Education during the NENA Development Conference in Orlando Florida on February 5-8, 2012. The sessions focused on developing a 9-1-1 public education program on NG9-1-1 in order to identify current resources available as well as establish priorities for NG9-1-1 educational materials that can be developed by NENA and other partners.

The sessions were facilitated by Christi Eskew with the North Central Texas Council of Governments, Sonya L. Clauson with Greater Harris County 9-1-1 Emergency Network and Sherri Griffith-Powell with L.R. Kimball. The facilitators kicked off the first session by discussing NG9-1-1 and why there is a need for educational campaigns.

Several areas, including North Central Texas Council of Governments, shared examples of current programs utilized to educate public officials, at the local, regional and state levels on the importance of funding NG9-1-1. An NG9-1-1 informational booklet is available on the NENA web site and is being used by Ms. Eskew as part of her educational program.

The first session utilized input from attendees to create a list of target audiences. In addition to elected officials, one of the first groups targeted was public safety employees. It was noted that as the true first responders, they need to be educated on NG9-1-1 in order to field questions from 9-1-1 callers and the public. They also will be the audience for NG9-1-1 training as that is developed.

The second session recapped the information covered in the first session and continued with a short brainstorming session to identify some key messages for an NG9-1-1 public education campaign and to identify potential partners in that campaign. The session was much more of a working session with great participation from attendees. Several of the attendees volunteered to form a committee to continue working on the NG9-1-1 educational campaign.

If you are interested in being a part of the NG9-1-1 education and training group to help establish a recommended guide for implementing a public education plan for this critical issue, please contact Sherri Griffith-Powell at sherri.powell@lrkimball.com.

Federal Grant Funding for NG9-1-1 on the Horizon

The 9-1-1 industry tirelessly educates law makers about the dire need to update antiquated 9-1-1 systems, and continuously calls for sustainable funding to pull that off. The Next Generation 9-1-1 Advancement Act of 2012, signed by President Obama last Wednesday, starts to answer that call. The Act provides a onetime appropriation of $115 million for 9-1-1 implementation grants.

It is expected to take as long as three years for the grant funding to become available. The funding for the grants will come from the proceeds of a TV spectrum auction. The Federal Communications Commission (FCC) has to design and implement that auction before any proceeds will become available. Once auction proceeds start to flow, a waterfall funding model will be used to distribute the auction funds to six different funding initiatives in addition to the 9-1-1 implementation grants. The waterfall model distributes money to initiatives in order of priority, funneling money to the first initiative until it is satisfied, and then funding the second initiative, and so on. The 9-1-1 implementation grants are ranked sixth on that list. This means five other initiatives totaling over $29 billion need to be satisfied before the 9-1-1 implementation grants are funded and assumes that the auction will generate more than $29 billion.

Funding Priorities for Auction Proceeds

1.	Repayment of borrowing authority for public safety broadband network	$2 billion
2.	State and local broadband implementation grants	$135 million
3.	Public Safety Broadband Network build-out	$7 billion
4.	Public Safety Communications Research Program	$100 million
5.	Deficit Reduction	$20.4 billion
6.	9-1-1 implementation grants	$115 million
7.	Additional public safety research	$200 million

The 9-1-1 implementation coordination grants will fund training, IP networks and NG9-1-1 services and will continue to fund basic and enhanced 9-1-1 implementation. Both state and local entities are eligible grant recipients under the Act and grants will require a 40% local match.

Take advantage of your opportunity to comment on the selection criteria for the 9-1-1 implementation grants. Proposed regulations on the selection criteria will be published within the next few months by the National Highway Traffic Safety Administration and the National Telecommunications and Information Administration. The Act requires a public comment period prior to the release of final regulations.

Congress continues to crack down on the diversion of 9-1-1 funds by deeming any entity that diverted 9-1-1 funds for other purposes ineligible for grant funding. Additionally, Congress directs the Government Accountability Office to conduct a study on 9-1-1 fund diversion. This study will be separate from the FCC report that provides Congress with self-reported diversion activity annually.

The Act puts into motion a number of proceedings and studies that will go far to advance 9-1-1 into the next generation including; a proceeding on 9-1-1 location capabilities of multiline telephone systems, a proceeding to create a specialized Do-Not-Call registry for public safety answering points (PSAPs), a report on the legal and statutory framework needed to support the deployment of NG9-1-1 and a report on detailed costs for NG9-1-1 requirements. Additionally, the Act extends immunity from liability to NG9-1-1 service providers and PSAPs.

The passage of this Act is a testament to the hard work of the 9-1-1 industry to educate lawmakers about the importance of 9-1-1 services and the critical funding needed to upgrade and maintain the high level of 9-1-1 service that Americans expect.

Pat Kane Wins ASCE Engineer of the Year

ASCE named M. Patrick Kane as their 2012 Engineer of the Year. Pat is a manager of the Transportation Division at L.R. Kimball, a position he has held since January 2000. Pat is responsible for business development, sales strategy, and execution in the transportation sector, as well as transportation operations management for the regional office. Pat has an MBA from Robert Morris University and a Bachelor of Science in Mechanical Engineering Technology from the University of Pittsburgh at Johnstown.

Pat has been a member of ASCE since 1990. He served as president of the Pittsburgh Section from 2004-2005. He also chaired the Construction Legislative Council of Western PA from 2004-2005, where he represented ASCE, as one of thirteen member organizations, on behalf of the construction industry. He is currently serving as a board member of the American Society of Highway Engineers.

Pat is a licensed professional engineer in Maryland, New Jersey, New York, Ohio, Pennsylvania, and West Virginia. His other professional affiliations include ASHE- American Society of Highway Engineers; ABCD – Association for Bridge Construction and Design; and ACEC-PA – American Council of Engineering Companies (Pennsylvania).