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.

 

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.

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.

700 MHz D Block Spectrum Allocated to Public Safety - Legislation includes NG9-1-1 funding as well

It appears that Congress is poised to allocate the long awaited and long overdue public safety spectrum. Though nothing has officially been released to this point, sources close to Congress have confirmed that new legislation is being rolled out that will allocate the 700 MHz D Block spectrum to public safety and provide $7 billion in federal funding for the deployment of a nationwide Public Safety broadband LTE network. D Block contains the 10 MHz of spectrum immediately adjacent to that which is already licensed to the Public Safety Spectrum Trust (PSST) to first responders across America. The Public Safety Broadband Network (PSBN) will reside in the full 20 MHz of broadband spectrum necessary to meet current and future needs. Further, it appears that this will come without public safety having to forfeit its existing 700 MHz narrowband spectrum.

It is also reported that the legislation would create an independent First Responder Network Authority to develop the public safety network. The Authority will be housed under the National Telecommunications and Information Administration (NTIA), but will have separate leadership, including a board with public safety, commercial, federal, state and local expertise to oversee the D-Block license and development of the network.

Additionally, the legislation includes a provision for $115 million in funding to support the build-out of Next Generation 9-1-1 technologies and reauthorization of the National 911 Office.

Senator Rockefeller, who was an instrumental player in developing this legislation and who has led the charge for allocation of the spectrum, was quoted as saying,

“This is sort of a huge day for America…Days like this don’t come around very often. This doesn’t cost the taxpayers a dime. It will save endless numbers of lives of first responders. ...With this new high-tech capability, firefighters will be able to instantaneously download floor plans before they go into the buildings to see what they’re up against. Cops will have access to criminal histories before they approach a suspect all on handheld devices which will be available at every level all across the country in one, integrated, truly national first responders communications system. EMTs will be able to communicate potentially life-saving information to doctors in the emergency room before they get there — descriptions and pictures of the wounded. It’s the best kind of reform.”

This legislation is reportedly set to be voted on in the upcoming days as part of a bill that will extend the payroll-tax cut and unemployment benefits — legislation for which there is a looming deadline and heated partisan debate.¹

Download a copy of the proposed legislation (see Section 6000) here: http://docs.house.gov/billsthisweek/20120213/CRPT-112hrpt-HR3630.pdf

There remain a number of questions; however, keep an eye on this blog for updates.

 

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¹ D-Block allocation to public safety is 'done.’ Police Senior Editor Doug Wyllie. http://www.policeone.com/police-products/communications/articles/5098920-D-Block-allocation-to-public-safety-is-done/

Network & Remote Access

By Lori Kleckner

This installment of our security series focuses on section 9 of NENA Security for Next-Generation 9-1-1 Standard (NG-SEC), designed to be used by public safety agencies as a guideline for securing their systems. As today’s emergency services networks are implemented, it is important to identify, document and protect them. Solutions should also be in place to address equipment and circuit fail-over. Network and remote access security addresses several security issues and strategies for mitigation.   

As part of this series, L.R. Kimball has been sharing some common findings of non-compliance with NG-SEC as observed during our PSAP assessments. In the area of network and remote access it is prevalent to find both the absence of firewalls and firewalls that are not properly configured. Accurate network diagrams are generally not made available to the PSAPs. Network redundancy is minimal. This is obviously problematic.

It is difficult to protect the network and associated assets without first defining the network. Once the boundaries of the network are understood (and documented), actions should be taken to secure those boundaries. Firewalls should be in place at each boundary of the network. Firewalls should be configured based on business need of traffic, minimizing the number of ports open and protocols permitted to ingress and egress the network. Following a defined process for maintaining the firewall to assure only appropriate network traffic is entering or leaving the network, is a defense against issues arising from both known and emerging threats.

Remote access to the network is an area requiring close scrutiny to determine the business need. Any access to the network has the potential to introduce malicious activity both intentional and unintentional. Remote access, whether for third-party maintenance access or remote employees, must adhere to polices and the intent of the firewall must not be circumvented.

Network redundancy and diversity often requires consideration of the options available to the PSAP. Redundancy includes duplication of equipment and circuits. Advantages of redundancy are realized during maintenance of equipment and in the event of an unforeseen failure. Redundancy will provide the resources to remain operational while repairs are enacted. In the same manner, the ability to provide an alternate route for network circuits to achieve diversity in the event of an outage, supports maintaining high availability needed to provide emergency call services.

The importance of network and remote access, as well as addressing availability through redundancy and diversity are issues facing today’s IP-connected PSAPs. With strong policies in place and the commitment to follow through, the availability of emergency call services is greatly increased.

Visit our blog next month to gain an overview of change control and documentation.

The NG-SEC Series Continues... Physical Security

By Lori Kleckner

This installment in the NG-SEC series discusses physical security guidelines. Although one may not think of physical security as a topic in a cyber security arena, without physical security, network devices are left unprotected from the surrounding environment. All NG9-1-1 information resources must be kept physically secured and protected from theft, misappropriation, misuse, unauthorized access and damage. NG-SEC section 8, Physical Security Guidelines includes:

• Building and Physical Access Control
• Authorized Physical Entry
• Storage Media and Output
• Mobile Devices
• Environmental Controls
• Server Room
• Data Communications Network

During PSAP assessments L.R. Kimball observes PSAPs are generally cognizant of physical security. Among positive findings are closed circuit cameras, keypad entry, attended reception area, and logging visitors. However, once access is gained to the facility, it is common to find the doors to the call center and equipment rooms left open and unattended.

A particular concern for physical security is third-party vendors with open access to the facility. While it is understood that there is a need for certain vendor employees to gain access to the facility on a 24 hour basis, it is not to say that their presence should be completely unattended. It is recommended that such personnel be logged in and their actions while in the facility monitored. It is important that the PSAP is aware of tasks that are performed by all personnel who have access to sensitive areas to prevent mishaps and to remain informed of actions taken.

Another point of concern during assessments is minimal concern afforded to areas with environmental controls. Physically securing the environmental controls is an important and often overlooked aspect of security. With server rooms and workstations that are reliant upon proper temperature and humidity control to operate, environmental controls are necessary. If equipment is not properly cooled, it will overheat resulting in system shutdown, data loss and possible equipment and software damage.

Similar areas of physical concern are:

• Commercial power rooms
• Emergency power rooms
• Communications rooms
• Cable vaults
• Switch rooms
• HVAC equipment rooms
• Operations control rooms

As PSAPs become connected via IP enabled networks, physical security is a growing responsibility that requires further attention. Unattended areas provide the opportunity for data theft and network interruptions. PSAPs should address physical security throughout the facility to assure restricted areas are available only to personnel with a business need.

Our next post will discuss network and remote access security.

Talking Consolidation - with Mike Fischel

By Mike Fischel, ENP - Vice President, Business Development

Last month, I had the pleasure of talking to a group of public safety communications professionals from New England and New York about 9-1-1 and dispatch center consolidation  at the Atlantic Coast Association of Public Safety Communications Officials Conference .  This is an important and growing issue in the public safety field because of the challenges that 9-1-1 and  centers face to improve service, coordinate services, and achieve cost efficiencies in the face of a difficult economy,  new technologies, and a growing expectation from the public about the capabilities of  the “9-1-1 System” to protect life and property.  

The expertise of our staff members have lead us to believe that 9-1-1 consolidation initiatives can provide significant benefits to the public, telecommunicators and first responders if approached in the right way.

These initiatives typically are comprised of three phases:  Feasibility Study, Implementation Planning, and the actual transition to consolidated operations.  The feasibility study phase is a critical step in any initiative because it examines current operations, service, cost, technologies, and facilities in order to determine options, requirements, political environment, and will to support a consolidation among potential municipalities and/or agencies. This study usually is the basis for making decisions regarding the practicality to move forward with detailed planning for the consolidation of 9-1-1/dispatch  centers.  

If the decision is made to move forward with a consolidation, there are several key requirements that are essential to the planning process.  They include development of a governance agreement that addresses authority, control, and policies for the consolidated organization.  A funding approach will be required to establish the source of funds to establish the new organization and its continued operations.  Service offerings and levels of performance must be established. Staffing and human resources including pay, benefits, position classifications, training, and quality assurance programs must be determined.  Finally facility and technology requirements must be specifically defined and secured. 

In our work supporting these initiatives, we have found there are some common lessons to be considered. 

• First, consolidation initiatives based solely on the expectation of saving money are not typically successful.  Successful initiatives are more often based on the desire to improve service, capacity, coordination, and interoperability among agencies and municipalities. 
• Another important lesson is that leadership and program management established early in the consolidation process is a key predictor of a successful consolidation process. 
• Finally, we have found it is helpful to view a consolidation  initiative as a once in a lifetime opportunity to establish an organization and program of services that will bring substantial improvement to the delivery of emergency communication services to the public and first responders.

To discuss consolidation further, sign up for our webinar to be held November 10. 

 

FCC releases Notice of Proposed Rulemaking (NPRM)

The Federal Communications Commission (FCC) continues to demonstrate it's dedication to Next Generation 911 (NG911) with it's latest Notice of Proposed Rulemaking (NPRM) released September 22. The NG911 NPRM seeks comment on a number of issues related to accelerating the development and deployment of NG911 technology that will enable the public to send emergency communications to 911 Public Safety Answering Points (PSAPs) via text, photos, videos, and data and enhance the information available to PSAPs and first responders for assessing and responding to emergencies.    

The NPRM is based on information the FCC received in response to a Notice of Inquiry released December 2010.  That NOI was the first time the FCC publicly requested information related to NG911. L.R. Kimball responded to the NOI with detailed comments that provided the FCC with information gleaned from our industry experience and highlighted our positions on NG911 concepts, particularly SMS for emergency communications. 

As a result of L.R. Kimball's response to the NOI, the latest NPRM specifically requests comment on L.R. Kimball's proposal regarding SMS to 911 that recommends a different point of interconnection between the SMS system and 911. 

L.R. Kimball will continue to stay engaged in these landmark proceedings as the FCC accelerates the development and deployment of NG911. Public comments in response to the NPRM are due on December 12, 2011 and reply comments are due January 10, 2012.