Interoperability Subcommittee Final Recommendations
Regarding SIEC Name, Structure and Expanded Authority; Channel Nomenclature
Standardization for
DRAFT
The
following recommendations are provided in language similar to that which the
I/O Subcommittee believes the FCC could use in presenting these proposed Rule
change recommendations in a Public Notice.
SIEC Name, Structure and Expanded Authority
In the 4th Report
and Order on Docket 96-86, the Commission recognized that the states were the
appropriate place to administer the interoperability
channels. We highlight the word
administer because there are emerging examples where state governments are
using their SIEC to control the interoperability channels. Additionally, some states have expanded the
role of their SIECs to include other state-level functions such as
procurement. We believe certain changes
and clarifications need to be added to the existing FCC rules concerning the
SIEC’s to ensure that their primary role, as envisioned by the NCC, is
met. First, we recommend that the
name State Interoperability Executive Committee be changed to Statewide
Interoperability Executive Committee to be more inclusive of all agencies in
the state. Second, the rules need to
clearly define the role of the state within the SIEC as one of coordination
and management, rather than control of the interoperability channels. Finally, the Rules need to require that the
SIEC’s, or RPC’s where no SIEC is formed within a
particular state, be inclusive of representatives from all public safety
disciplines at all levels of government, should they desire to participate, and
that meetings must be open to any public safety representative who desires to
attend.
As the
Commission provided States with the opportunity to notify the Commission of
each state’s intent to initiate State Interoperability Executive Committee’s at
the recommendation of the National Coordination Committee in 1999 in the Third
RO&O, some states elected not to develop and promote such a body to be
empowered to facilitate the designated 700 MHz interoperability channels within
that state.
Of the
states that did not notify the Commission of their intent to initiate a SIEC,
many had existing committees that the state felt would be appropriate to accept
the responsibility of facilitating the 700 MHz implementation and
coordination. In addition, other states
simply did not respond to the Commissions request for notification of acceptance
of the responsibility to form an SIEC, thus allowing this responsibility to
default to the Regional Planning Committee(s) in those states.
Since the
Commission provided no guidelines for promoting inclusion of county/parish and
local agency participation within SIEC membership, some existing state
committees were assigned the SIEC role without an appropriately broad range of
public safety agency members. The
potential of little or no input to statewide interoperability solutions from
county/parish/local agencies in the various public safety disciplines
throughout a state causes great concern and can potentially yield policies that
are not reflective of the concerns of all public safety entities within a
state.
As the Commission
feels strongly that interoperability must be inclusive of the entire public
safety community, we are requiring the following:
RPCs who have assumed the
role of the SIEC where no such committee has been designated for that region
shall form an SIEC Subcommittee. All
SIECs and all RPC SIEC Subcommittees shall examine their membership to ensure
that it is representative of all public safety disciplines and all levels of
government (local,county/parish,state,
tribal and federal.) Within the remainder of this
document, the term SIEC shall refer to a formal SIEC or RPC SIEC Subcommittee
interchangeably. Requirements delineated
herein apply equally to both.
Years ago,
the FCC required in its rules that state level plans be developed for certain
inter-service interoperability channels (e.g., 155.475 MHz, the “National Law
Enforcement Emergency Channel”).
Unfortunately, over the years, neither the individual states nor the
Commission, where most of the plans were filed, have maintained most of these
“state plans”. Even if maintained, there
has been no mechanism for nearby or adjacent states to view a “state plan”, nor
is there a requirement for states to retain an updated, current plan on file
for viewing by agencies requiring information on interoperability. For the most part, these plans have not been
updated or modified to reflect more recent public safety communications
interoperability needs and, as a result, these channels are currently used in a
manner that fails to maximize their potential at all levels of government. The current practice of states retaining
these plans has proven not to be effective in providing guidelines for the
effective use of interoperability resources in communities across the
country. A mechanism to retain these
plans, such as a repository allowing agencies within a state, neighboring
states and federal users to access a current version of the plan, is
required. The National Public Safety
Telecommunications Council (NPSTC) CAPRAD database is an example of a tool that
can retain these plans.
Thus, the Commission is
requiring each state’s SIEC to provide to the Commission or its designee an
updated version of its state Interoperability Plan every three years. This plan shall provide detailed information
on public safety communications interoperability useful to agencies within
their state, local agencies in bordering states, and with tribal/federal users
regarding all FCC designated interoperability channels. Example templates for such plans are provided
by the NCC’s Implementation Subcommittee Regional Planning Committee
Guidelines.
In addition, we adopt the
recommendations of the National Coordination Committee on issues surrounding
standardized channel nomenclature and expansion of the SIECs to include all
public safety bands. Current FCC-designated
interoperability and intersystem channels suffer from a nationwide lack of cohesiveness
and coordination that inhibits the implementation of, and fails to promote,
consistent public safety interoperability within communities across the nation.
This issue is consistent with
the FLEWUG petition now pending before the Commission recommending centralized
interoperability in states and a consistent nationwide implementation of
interoperability channels. Parameters
established for Part 90 interoperability channels by SIEC’s appear to be
applicable to NTIA Red Book Interoperability channels that may be available by
2005. The Commission recommends that any
use by Part 90 eligibles of these channels pursuant
to Federal agency agreements should follow these same interoperability
guidelines.
Clearly, a fresh look at all
interoperable spectrum as a single, unique public safety band (resource) that
can offer tremendous benefits to the first responders community is needed to promote effective use of these
public safety resources.
Furthermore, during the
transition to the Commissions Universal Licensing Service (ULS), records of
many specific channel license conditions, (ex. Limitation 19 inter-system
sharing) that were in many areas the building blocks of locally developed
unique interoperability conditions in a given area, were lost. In many cases, the regionally developed and
accepted discipline specific qualities of these channels, which were in many
cases coordinated by states, were not recognized by neighboring states and led
to reduced public safety communications interoperability within the
region. This caused interference to
first responders using these channels to solve interoperable solutions in their
community.
An example of ULS not
offering the criteria of regional use for certain inter-system sharing channels
would be the licensing of a frequency to one discipline, in a community where
another discipline of public safety users has for years established long term,
multi-agency interoperable conditions on the same channel. The standardization of technical parameters
for all interoperability/inter-system sharing channels and the commissions re-emphasis on the nature of channel usage in a
particular region is needed to rectify problems that may arise in the public
safety community.
The mandatory development of
regional/state plans for all interoperability/inter-system sharing channels by
a Statewide Interoperability Executive Committee is crucial to successful
interoperability implementation between users.
The plans will document technical and operational parameters within a
state/region for all interoperability channels and the availability of these
plans to users in adjacent states and regions is necessary to maintain
interoperability. Keeping
interoperability parameters (operational and technical) a secret from other
public safety agencies benefits no one.
It is the unanimous opinion
of the Interoperability Subcommittee that these resolutions will address two of
the greatest impediments to effective public safety interoperability. Furthermore, these issues are consistent with
the FLEWUG petition now pending before the Commission which states that there
be must be minimal standardization of interoperability for public safety
communications to be effective nationwide.
Recommendations:
The use of mandatory, nationwide all-band interoperable channel nomenclature and associated display characteristics. This finalized list is provided in I/O Subcommittee document IO-0107D-20030716 and is based upon recommendations approved by the NCC Steering Committee in response to recommendations presented in IO-0106A-20021121..
The
Standardized operational
and technical standards intended to promote seamless interoperability
throughout all bands, nationwide were addressed in the letters provided to NCC
Chairman Wallman by the I/O subcommittee at its last two meetings. Reference IO-0106A-20021121
and IO-0115A-20030221.
Mandatory SIEC creation in
each state, expanded authority and SIEC renaming
The establishment of FCC
Required, all band interoperability plans authored by the SIEC’s along with the
requirement they be retained online on a database (such as CAPRAD) and updated
every three years in PDF form for viewing by agencies within the state,
adjacent state public safety users along federal responders..