NFPA Technical Committee on Public Emergency Service ......624 Hammer Lane North Aurora,...

NFPA Technical Committee on Public Emergency Service

Communication

NFPA 1225 (NFPA 1221) First Draft Meeting

AGENDA January 27-29th, 2020

8:00 AM Start Time (Local Time)

I. Chair Charles Berdan calls meeting to order on January 27th, 2020.

II. Welcome and Opening Remarks.

III. NFPA Committee Training and Presentations.

IV. Introduction of attendees.

V. Approval of minutes from the NFPA 1221 Supplemental meeting January 18, 2018

VI. Review purpose of meeting and document schedules.

VII. Old business: • Recap on process items.

VIII. New business:

• Review Task Group Reports/Public Inputs and develop First Revisions. IX. Date and location of next meeting.

X. Adjournment.

Address List No PhonePublic Emergency Service Communication PUF-AAA

Robert Fash12/12/2019

PUF-AAACharles M. BerdanChairSmokeater Consulting8698 Elk Grove Boulevard, Suite 1FMB 115Elk Grove, CA 95624Alternate: Don R. Wise

SE 4/1/1997PUF-AAA

Douglas M. AikenPrincipalLakes Region Mutual Fire Aid9 Bentley RoadMoultonborough, NH 03254

E 1/1/1992

PUF-AAAWilliam AmbrefePrincipalCity of BeverlyMunicipal Inspection56 Water StreetBeverly, MA 01915-5027

E 7/29/2005PUF-AAA

Joseph Francis BrooksPrincipalBoston Fire Department83 Sheppard AvenueBraintree, MA 02184International Association of Fire Fighters

L 08/08/2019

PUF-AAAJay Dornseif, IIIPrincipalPriority Dispatch Corporation110 South Regent Street, Suite 500Salt Lake City, UT 84111

SE 7/28/2006PUF-AAA

Jerry EisnerPrincipalRedSky Technologies Inc.333 N. Michigan Avenue, #1600Chicago, IL 60601

IM 07/29/2013

PUF-AAAJohn A. FacellaPrincipalPanther Pines Consulting, LLCPO Box 1295Raymond, ME 04071

SE 10/27/2009PUF-AAA

Kevin J. FossoPrincipalDane County Public Safety Communications201 Martin Luther King Jr. Blvd.#109Madison, WI 53703

U 11/30/2016

PUF-AAAJonathan FranklinPrincipalSignal Communications LLC6820 Lyons Tech Circle, Suite 115Coconut Ccreek, FL 33073

IM 11/30/2016PUF-AAA

Mark KrizikPrincipalMotorola, Inc.Sales Specialist224 S. Michigan Ave.Chicago, IL 60604-2501

M 3/15/2007

PUF-AAASteve LeesePrincipalAPCO International351 North Williamson BoulevardDaytona Beach, FL 32114Association of Public-Safety Communications OfficialsInternational Inc.

U 10/23/2013PUF-AAA

Minfei M. LengPrincipalTX RX Systems Inc./Bird Technologies GroupTXRX Systems 8625 Industrial Parkway Angola, NY 14006

M 04/05/2016

PUF-AAAKenneth J. Link, Jr.PrincipalUS Department of Homeland SecurityFederal Emergency Management AdministrationNDMS HHSN16 Parkerson Road Edison, NJ 08817


Tony R. LocatelliPrincipalIntrepid Electronic Systems400 Market StreetOakland, CA 94607

IM 08/08/2019

1



PUF-AAAChristopher H. LombardPrincipalSeattle Fire DepartmentSpecial Operations/Communications301 2nd Avenue SouthSeattle, WA 98104Alternate: Benjamin Mellon

U 4/5/2001PUF-AAA

Scott McCauleyPrincipalSiemens Building Technologies6617 St. Anne StreetDallas, TX 75248National Electrical Manufacturers AssociationAlternate: Raymond Patterson

M 04/04/2017

PUF-AAANathan D. McClure, IIIPrincipalAECOM Building Engineering20715 Timberlake Road, Suite 106Lynchburg, VA 24502

SE 7/29/2005PUF-AAA

Carolina Y. MilanPrincipalVandenberg AFB Emergency Communication Center1172 Iceland Avenue, Bldg. 10660Vandenberg AFB, CA 93437

U 03/07/2013

PUF-AAACharles PackardPrincipalITS5981 Arapaho Road, #107Dallas, TX 75248

IM 04/04/2017PUF-AAA

Thomas J. ParrishPrincipalTelgian Corporation15771 W-M36Pinckney, MI 48169-9717Alternate: Warren Burns

SE 8/2/2010

PUF-AAARichard Jay RobertsPrincipalHoneywell Fire Safety624 Hammer LaneNorth Aurora, IL 60542-9155Automatic Fire Alarm Association, Inc.

M 08/08/2019PUF-AAA

Timothy RuizPrincipalCode Consultants Inc2043 Woodland ParkwaySuite 300St Louis, MO 63146

SE 04/04/2017

PUF-AAAToivo SariPrincipalCypress Creek Emergency Medical Services7111 Five ForksSpring, TX 77379

U 07/29/2013PUF-AAA

Lawrence J. ShudakPrincipalUL LLC333 Pfingsten RoadNorthbrook, IL 60062-2096

RT 08/08/2019

PUF-AAAEvan E. Stauffer, Jr.Principal2800 Larkin RoadUpper Chichester, PA 19061-2204

SE 1/01/1982PUF-AAA

David ThompsonPrincipalHoneywell6503 Colonial AvenueEvansville, IN 47725

M 04/03/2019

PUF-AAAWilliam J. WattersPrincipalVerisk Analytics/Insurance Services Office, Inc.545 Washington BoulevardJersey City, NJ 07310-1607

I 04/08/2015PUF-AAA

Richard WoolfPrincipalXtech Systems Inc.PO Box 147Scarsdale, NY 10583-0147

IM 08/08/2019

2



PUF-AAATy WootenPrincipalNational Emergency Number Association1700 Diagonal Road, Suite 500Alexandria, VA 22314

U 10/23/2013PUF-AAA

Jeffrey G. KnightVoting AlternateCity of Newton Fire Department1164 Centre StreetNewton Centre, MA 02459-1539International Municipal Signal Association

U 10/20/2010

PUF-AAARandy RichmondVoting AlternateZetron, Inc.P.O. Box 97004Redmond, WA 98073

M 11/30/2016PUF-AAA

Warren BurnsAlternateTelgian Corporation10230 South 50th Place, Suite 100Phoenix, AZ 85044Principal: Thomas J. Parrish

SE 08/17/2015

PUF-AAABenjamin MellonAlternateSeattle Fire Department301 2nd Avenue SouthSeattle, WA 98104Principal: Christopher H. Lombard

U 03/07/2013PUF-AAA

Raymond PattersonAlternateSiemens Building Technologies8600 North Royal Lane, Suite 100Irving, TX 75063National Electrical Manufacturers AssociationPrincipal: Scott McCauley

M 08/17/2017

PUF-AAADon R. WiseAlternateDC Wise LLCPO Box 691867Los Angeles, CA 90069Principal: Charles M. Berdan


Robert FashStaff LiaisonNational Fire Protection AssociationOne Batterymarch ParkQuincy, MA 02169-7471

10/24/2016

3

Technical Committee on Public Emergency Services Communication

NFPA 1221 SUPPLEMENTAL SECOND DRAFT MEETING

Web-Teleconference January 18, 2018

Meeting Minutes

Attendees:

Steve Verbil (Chair) Doug Aiken Charles Berdan Tom DiBernardo Jay Dornseif Jonathan Franklin Steve Leese Minfei Leng Christopher Lombard Nathan McClure

Carolina Milan Randy Richmond Keith Simpkins Evan Stauffer Bob Fash – NFPA Staff

Chair Verbil called the meeting to order at approximately 1:10 PM Eastern time. Introduction of members and guests.

Chair Opening Statement Chair thanked all the members for making the call. Scope of the supplemental meeting was stated. Based on comments received during the first balloting process of the 2nd draft of the document, some errors were brought forward by the TC.

All comments, both positive and negative, will be reviewed.

Meeting Minutes Meeting minutes for the September 27, 2017 second draft meeting were approved by the TC members on the call.

Liaison Report A full PowerPoint presentation, as normally presented at meetings, was not given to the members on the call, but the TC members were advised that all regulations governing the standards development process applied to this supplemental meeting, especially pertaining to conflicts of interest.

First item discussed was the figures associated with (SR- 3), Annex A,

Section 7.4.1(a) and (b).

o TC agreed to change the time line associated with each figure to

include “<= 20 seconds 95%.”

No action taken on (SR-6), Annex A, Section 7.4.4

No action taken on (SR-1), Section 8.3.9

Revisions made to (SR-2) , Annex C

o Section C.2.2.2 Deleted

o Address updated for IMSA

Deletion of the definition for Pathway Survivability (SR-30) to stay in

place. Section 5.10 is deleted, removing the need for the definition.

Second Revision 30 (SR-30) was modified as follows:

o 9.6.3 Spelling corrected

o A.9.6.7 Spelling correction

o 9.6.7 modified

o 9.6.8 signal strength modified

Meeting adjourned at 1500 hours.

Process Stage Process Step Dates for TCDates for TC

with CC

Public InputStage (First Draft)

Public Input Closing Date* 11/15/2019 11/15/2020

Final Date for TC First Draft Meeting 2/01/2020 2/01/2020

Posting of First Draft and TC Ballot 4/27/2020 4/27/2020

Final date for Receipt of TC First Draft ballot 5/07/2020 5/07/2020

Final date for Receipt of TC First Draft ballot ‐ recirc 5/12/2020 5/12/2020

Posting of First Draft for CC Meeting 5/26/2020

Final date for CC First Draft Meeting 6/09/2020

Posting of First Draft and CC Ballot 6/30/2020

Final date for Receipt of CC First Draft ballot 7/10/2020

Final date for Receipt of CC First Draft ballot ‐ recirc 7/14/2020

Post First Draft Report for Public Comment 7/28/2020 7/28/2020

Comment Stage(Second Draft)

Public Comment Closing Date* 10/09/2020 10/09/2020

Notice Published on Consent Standards (Standards that received no Comments)Note: Date varies and determined via TC ballot.

Appeal Closing Date for Consent Standards (Standards that received no Comments)

Final date for TC Second Draft Meeting 11/13/2020 11/13/2020

Posting of Second Draft and TC Ballot 1/02/2021 1/29/2021

Final date for Receipt of TC Second Draft ballot 2/08/2021 2/08/2021

Final date for receipt of TC Second Draft ballot ‐ recirc 2/12/2021 2/12/2021

Posting of Second Draft for CC Meeting 2/19/2021

Final date for CC Second Draft Meeting 3/05/2021

Posting of Second Draft for CC Ballot 3/15/2021

Final date for Receipt of CC Second Draft ballot 3/25/2021

Final date for Receipt of CC Second Draft ballot ‐ recirc 3/29/2021

Post Second Draft Report for NITMAM Review 4/05/2021 4/05/2021

Tech SessionPreparation (&

Issuance)

Notice of Intent to Make a Motion (NITMAM) Closing Date 4/26/2021 4/26/2021

Posting of Certified Amending Motions (CAMs) and Consent Standards 5/24/2021 5/24/2021

Appeal Closing Date for Consent Standards

SC Issuance Date for Consent Standards

Tech Session Association Meeting for Standards with CAMs 6/24/2021 6/24/2021

Appeals andIssuance

Appeal Closing Date for Standards with CAMs

SC Issuance Date for Standards with CAMs

TC = Technical Committee or PanelCC = Correlating Committee

As of 10/9/2019

https://www.nfpa.org/codes-and-standards/all-codes-and-standards/list-o...

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Standards for Emergency Services

Communications (PUF-AAA)

Public Inputs

Public Input No. 102-NFPA 1225-2019 [ Global Input ]

Throughout the document, replace communications system and communications center withemergency services communications systems and emergency services communications center.

Statement of Problem and Substantiation for Public Input

It is important when using relatively common terms such as "communications systems" and "communications centers" to be as precise as possible. The term "communications" has very broad meaning and is used in many NFPA documents, including NFPA 110, 101, 72 and 1225 in several differing contexts. For example, "communications" in differing documents might reference any of the following:

Emergency communications system – Like an in-building fire phone systemOccupant notification – like fire alarm or voice notification system which advises one to evacuate or take coverPublic safety communications system – Like 911In-building emergency responder radio communications systemElectronic communications between alarm devices or between alarms and fire panels and monitoring stationsCommunications between the protected premise and monitoring stationsCommunications between monitoring stations and emergency facilities

We are in the information/communication age, and the increasing number of types of communications and types of networks, causes some confusion. Unless precise language is used, it can be easy to read requirements out of context and miss-apply them. In particular, a communication center can be misread to mean a telecommunications central office (AKA a telephone exchange). A communications system can be misinterpreted to mean the public switched telephone network. When read in full context, the intent of NFPA 1225 is clear with respect to how it intends to reference emergency services communications systems and emergency services communications centers, however, there is still room for improvement throughout the document. To assure the terms are clear and consistently applied as intended, it would best to add specificity wherever the terms "communications services" and "communications centers" are used.

The proposed edits are consistent with PIs made regarding iIn-Building Emergency Responder Communication Enhancement Systems submitted by the NFPA 1 task group. Similar clarification edits regarding the use of "communications systems" have been submitted and accepted in NFPA 72 and NFPA 110.

Submitter Information Verification

Submitter Full Name: Richard Kluge

Organization: Ericsson

Affiliation: Alliance for Telecommunications Industry Solutions

Street Address:

City:

State:

Zip:

Submittal Date: Thu Nov 07 14:52:25 EST 2019

Committee: PUF-AAA

National Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPar...

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Public Input No. 162-NFPA 1225-2019 [ Global Input ]

Change the term "Two-Way Radio Communications Enhancement Systems" to "In-building Two-Way Emergency Responder Communication Enhancement System"Throughout the document as an editorial change.


This public input revises the terminology for these communications to harmonize with the current descriptions in the UL 2524 standard, NFPA 1 and the International Fire Code (IFC). The changes are to emphasize these systems are specific to use within buildings and are intended to cover all public safety emergency responders; fire service, EMS and law enforcement.

This is a global change intended to capture any place the phrase “two-way radio communication enhancement system(s)” appears in this standard, including any definitions.

This is one of 5 public inputs being submitted as a package relating to technical changes proposed for section 17.6 of NFPA 1225.

While the NFPA 1225 Technical Committee will consider each public input independently, the intent is for approval of all public inputs in this package of related items which have been submitted as a correlated set of companion change proposals.

This public input was written by a Task Group of stakeholders including representatives of industry, fire service and AHJs through a series of e-mails and conference calls to reach consensus on this package of public inputs.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 161-NFPA 1225-2019 [Section No. 17.6]


Submitter Full Name: Kelly Nicolello

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Nov 12 09:34:00 EST 2019

Committee: PUF-AAA


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Public Input No. 15-NFPA 1225-2019 [ Section No. 2.3 ]

2.3 Other Publications.

2.3.1 ASTM Publications.

ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.

ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2016.

2.3.2 FCC Publications.

Federal Communications Commission, 445 12th Street SW, Washington, DC 20554.

FCC 13-21, Use and Design of Signal Boosters Report and Order, 2013.

2.3.3 IEEE Publications.

IEEE, 3 Park Avenue, 17th Floor, New York, NY 10016-5997.

IEEE C2, National Electrical Safety Code, 2017.

2.3.4 IESNA Publications.

Illuminating Engineering Society of North America, 120 Wall Street, Floor 17, New York, NY 10005.

HB-9-00 IES Lighting Handbook , Lighting Handbook, 9th - Reference and Application 10th edition,2009 2011, errata,, 2015 .

2.3.5 NENA Publications.

National Emergency Number Association, 1700 Diagonal Road, Suite 500, Alexandria, VA 22314

NENA-ADM-000.21-2017, NENA Master Glossary of 9-1-1 Terminology, August 8, 2017.

NENA/APCO ANS 2.105.1-2017, NG9-1-1 Emergency Incident Data Document (EIDD), 2017.

2.3.6 TIA/EIA Publications.

Telecommunications Industry Association/Electronic Industries Alliance, 1320 North Courthouse Road,Suite 200, Arlington, VA 22201.

ANSI/TIA-102.BAAA, FDMA Common Air Interface, 1998 revision B, 2017 .

TIA-102.BBAB, Project 25 Phase 2 Two-Slot Time Division Multiple Access Physical Layer ProtocolSpecification, 2009 .

TIA-102.BBAC, Project 25 Phase 2 Two-Slot TDMA Media Access Control Layer Description, 2010,amendment 1, 2013 .

TIA-603-D E , Land Mobile FM or PM Communications Equipment Measurement and PerformanceStandards, 2010 2016 .

2.3.7 UL Publications.

Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.

ANSI/UL 752, Standard for Bullet-Resistant Equipment, 2005, Revised 2015.

2.3.8 Other Publications.

Merriam-Webster’s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003.

NIMS/ICS, Emergency Responder Field Operations Guide, U.S. Department of Homeland Security, U.S.Government Publishing Office, Washington, DC, October 2010.

Additional Proposed Changes

File Name Description Approved

Public_Input_No._5-NFPA_1221-2018_Section_No._2.3_.pdf



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PUBLIC INPUT NO. 15 is assigned to the TC on Public Safety Telecommunicator Professional Qualifications (PQU-PST) but is included in this agenda for the TC on Public Emergency Service Communication (PUF-AAA) for a recommended action.

jdepew

Highlight

Referenced current national consensus standard editions.


Submitter Full Name: Aaron Adamczyk

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Wed Oct 09 15:22:05 EDT 2019

Committee: PQU-PST


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Public Input No. 164-NFPA 1225-2019 [ Section No. 2.3.7 ]

2.3.7 UL Publications.

Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.

ANSI/ UL 752,Standard for Bullet-Resistant Equipment, 2005, Revised 2015.

UL 2524, In-building 2-Way Emergency Radio Communication Enhancement Systems, 2019.


UL 752 is now being referred by its short title and the ANSI designation in the title has been removed. The standard is still an ANSI consensus document, only the title has changed to eliminate confusion that these documents can be purchased through ANSI.

UL 2524 is added provided the related PI is approved by the committee.



Public Input No. 163-NFPA 1225-2019 [New Section after 17.6.2.1]




Street Address:

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Committee: PQU-PST


4 of 22 12/18/2019, 1:47 PM

PUBLIC INPUT NO. 164 is assigned to the TC on Public Safety Telecommunicator Professional Qualifications (PQU-PST)

but is included in this agenda for the TC on Public Emergency Service Communication (PUF-AAA) for a recommended action.

jdepew

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Public Input No. 178-NFPA 1225-2019 [ New Section after 2.3.7 ]

TITLE OF NEW CONTENT

ANSI/UL 2524 Standard for In‐building 2‐Way Emergency Radio Communica on Enhancement Systems , First

Edi on, Dated October 19, 2018


This is the one of two Public Inputs that seek to require two-way radio communications enhancement systems to be listed to UL 2524, Standard for In-building 2-Way Emergency Radio Communication Enhancement Systems. This Public Input is adding UL 2524 to the list of referenced standards. The other Public Input is requiring two-way radio communications enhancement systems to be listed to UL 2524.

Requiring two-way radio communications enhancement systems to be listed to UL 2524 will ensure the products used in two-way radio communications enhancement systems have the necessary performance, fire and shock safety requirements specified in this Standard. ANSI/UL 2524 is a new product performance standard that covers the repeaters, transmitters, receivers, signal boosters and battery charging systems used in two-way radio communication enhancement systems.

Conformity assessment procedures provide a means of ensuring the products, or systems produced have the required performance characteristics, and that these characteristics are consistent from product to product, or system to system.



Public Input No. 177-NFPA 1225-2019 [Section No. 17.6.11.1]


Submitter Full Name: Richard Roberts

Organization: Honeywell Fire Safety

Affiliation: Automatic Fire Alarm Association (AFAA)

Street Address:

City:

State:

Zip:


Committee: PQU-PST


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jdepew

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3.3.10* Backbone.

A communications cable in an in-building radio enhancement system that carries wideband signalsimportant to the entire building, from the The key components including the donor antenna, through theamplifiers, and to distribution antenna lines repeaters, signal processing equipment, optical fiber interfacesand circuits between floors of an emergency responder radio enhancement system .



Public_Input_No._28-NFPA_1221-2019_Section_No._3.3.10_.pdf


This PI mirrors a TIA submitted to NFPA 1221 following the 2019 edition and is part of a series of related PI.

Emergency Responder radio Enhancement Systems (ERRES) are intended to ensure first responders have theability to communicate during fire ground activities or other emergencies. ERRES requirements were formerlylocated in NFPA 72, National Fire Alarm and Signaling Code. ERRES requirements were removed from NFPA 72,modified, and relocated to NFPA 1221, Standard for the Installation, Maintenance, and Use of Emergency ServicesCommunications Systems during the 2019 revision cycle. The 2013 and 2016 editions of NFPA 72 required Level 1or Level 2 survivability for ERRES cabling. Level 1 survivability essentially requires circuits in metal raceways infully sprinklered buildings. Level 2 survivability requires 2-hour rated cable or a 2-hour enclosure. Since there is nolisted 2-hour rated CI coaxial cable available for ERRES in the marketplace, the proposed requirements specify a2-hour enclosure, rather than using the undefined and unenforceable term “the building’s fire rating”.The requirements found in NFPA 1221-2019 are not enforceable as written, and do not ensure any level ofprotection for ERRES system. This proposed Tentative Interim Amendment essentially requires the same levels ofprotection that previously existed in NFPA 72, without using terminology used in NFPA 72 or requiring a referenceto NFPA 72. These proposed changes seek to provide a minimum level of performance and to make therequirements more easily understood and enforceable in the field.

This PI seeks to lessen a known hazard by improving the requirements for systems that improve communicationsfor first responders. NFPA 1221-2019, as it currently exists is confusing, because “the building’s fire rating” is notdefined and is not enforceable. This will lead to confusion by designers and enforcement officials. This PI makesprovisions to protect the backbone cables for a period of two hours, where the existing text in NFPA 1221-2019 hasno minimum time limit. This PI makes NFPA 1221 much clearer and enforceable. This PI provides requirementsfor essential communications for first responders and ensures a minimum level of performance for the system.






Public Input No. 38-NFPA 1225-2019 [Section No. A.3.3.10]


Submitter Full Name: Merton Bunker

Organization: Mba

Street Address:

City:

State:

Zip:


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jdepew

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Committee: PQU-PST


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jdepew

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Public Input No. 38-NFPA 1225-2019 [ Section No. A.3.3.10 ]

A.3.3.10 Backbone.

Damage to a backbone cable will disable the radio enhancement system through much or all of thebuilding, and as a result it should be identified and protected. The backbone could be fiber-optic, copper, orcoaxial cable, but it does not radiate RF energy along its path.

Backbone circuits do not include distribution circuits on each floor or zone of a structure.

Add an illustration to the annex material such as the Bird Technologies image below (show the signalchain from the

donor antenna through the interface at each floor):

<<Insert Figure Here>>>



Public_Input_No._29-NFPA_1221-2019_Section_No._A.3.3.10_.pdf

NFPA_1221_Graphics_A.3.3.10.1547823703910-1.pdf










Public Input No. 37-NFPA 1225-2019 [Section No. 3.3.10]



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jdepew

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Organization: Mba

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jdepew

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Add to definitions

Directory. A printed or virtual lis ng of telephone numbers.


Need to add the definition of a directory as it pertains to telephone numbers.



Public Input No. 229-NFPA 1225-2019 [New Section after A.3.3.41]



Submitter Full Name: Charles Berdan

Organization: Smokeater Consulting

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 15 12:22:45 EST 2019

Committee: PQU-PST


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jdepew

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3.3.45 Distribution Antenna.

A radio antenna that is specifically designed to radiate RF energy into a building area, and is typically non-descript in appearance so as not to disturb the décor of the area .


The second clause of the definition reads like annex material. I suggest relocating this to an annex for this definition.





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3.3.47 Donor Antenna.

Antennas used with two-way radio way emergency responder communications enhancement systems thatprovide the connection between the wide-area communications system of interest and the in-buildingsystem.


This public input adds new definitions that correspond to terms within the body of the standard. These definitions are consistent with other documents, such as NFPA 72, NFPA 1 and UL 2524.

This is one of a number of public inputs being submitted as a package relating to technical changes proposed for section 17.6 of NFPA 1225.





Public Input No. 173-NFPA 1225-2019 [New Section after 3.3.114]






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jdepew

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Emergency Services Communications System - See Public Safety Emergency Communications System.


The term Emergency Services Communications System is not defined. If it is not distinct from Public Safety Emergency Communications System, a pointer to that definition can be used.





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A.3.3.56 Event.

All incoming calls on designated emergency telephone lines should be considered emergency events untilanswered by a telecommunicator. If a telecommunicator determines that the reason for the call is not anemergency as defined in 3.3.49, the call will not count against the performance requirements of 15.4.2. Atrouble or supervisory signal is not an indication of an event. (See also 3.3.119, Trouble Signal.)





Incorrect standard number is referenced. This change corrects the number from 3.3.48 (the definition for "donor site") to 3.3.49 (the definition of "emergency")


Submitter Full Name: Jenna Diplacido

Organization: Broward County

Street Address:

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Committee: PQU-PST


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jdepew

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3.3.92 Public Switched Telephone Network. An assembly of communications equipment and telephone serviceproviders that utilize managed facilities-based voice networks (MFVN) to provide the general public with theability to establish communications channels via discrete dialing codes.


The term public switched telephone network and PSTN are both used in section 16.6 but are not defined in the standard. The definition provided here is taken from NFPA 72 with the acronym added.




Affiliation: Alliance for Telcommunications Industry Solutions

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jdepew

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Qualified Telecommunicator.

A person that has completed the dispatch training components required by the AHJ.



1221_PI_50.pdf 1221_PI_50


See PI 49 (New PI 24) defines qualified telecommunicator




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3.3.95 * Radio Frequency.

The number of electromagnetic wave frequency cycles transmitted by a radio in 1 second A measurementrepresenting the oscillation rate of electromagnetic radiation spectrum, or electromagnetic radio waves,from public safety frequency bands as specified by the fire code official .














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3.3.103 RF-Emitting Device.

An active device or passive device that emits a radio frequency signal as part of a two an in -building two-way radio emergency responder communications enhancement system.

3.3.103.1 Active R F E mitting Device

Any type of circuit component that requires an ac or dc power source with the ability to electrically controlelectron flow and/or amplification of RF signal, including but not limited to signal boosters, repeaters, bi-directional amplifiers, and fiber distributed antenna systems.

3.3.103.2 Passive RF Emitting Device

A device that does not require an external ac or dc source of power for its operation and does not provideamplification of the RF signal, including but not limited to coax, couplers, splitters, and passive antennas.














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3.3.114 In-building Two-Way Radio Emergency Responder Communications EnhancementSystem. A combination of components, RF-emitting devices, antennas, cables, power supplies, controlcircuitry, and programming installed at a specific location to improve wireless communication at thatlocation.














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jdepew

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Add new definition

Telephone Number A 10‐digit number corresponding to a specific voice circuit for purposes of accessing that circuit.


Need a definition




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jdepew

Highlight


Add to Definitions

Voice Circuit. A physical or virtual audio connec on


Need definition of a voice circuit








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17 of 22 12/18/2019, 1:47 PM



jdepew

Highlight


Alternate Means

The alternate means shall be readily available to the telecommunicator in the event of failure of the primarycommunications system.



1221_PI_32.pdf 1221_PI_32


See input 31 - removed second requirement and placed in new section




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Public Input No. 1-NFPA 1225-2019 [ Section No. 12.2.5.1 ]

12.2.5.1

Each center shall be provided with an alternate means of communication that is compatible with thealternate means of communication provided at the ERFs. The alternate means shall be readily available tothe telecommunicator in the event of failure of the primary communications system.



1221_PI_31.pdf 1221_PI_31


Two requirements in one section.




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12.3.3*

The lowest floor elevation of the communications center shall be above the 100 500 -year flood plainestablished by the Federal Emergency Management Agency.



1221_PI_33.pdf 1221_PI_33


Flood plain number needs to be in agreement with 4.3.5




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Comply with 101

Communications centers located below grade shall comply with 11.7.3 of NFPA 101 and be specificallydesigned for the location.



1221_PI_35.pdf 1221_PI_35


Inserting text removed from Input 34.




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12.4.5*

Communications centers shall not be located below grade unless the elevation of the lowest floor in thefacility is above the 500-year flood plan. Communications centers located below grade shall comply with11.7.3 of NFPA 101 and be specifically designed for the location.



1221_PI_34.pdf 1221_PI_34


There were two requirements in one section. Moved deleted material to new section.




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Emergency Fire Plan.

There shall be a management-approved, written, dated, and annually tested emergency fire plan that ispart of the CEMP.



1221_PI_37.pdf 1221_PI_37


Section belongs under CEMP




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12.6.6 * Emergency Fire Plan.

There shall be a management-approved, written, dated, and annually tested emergency fire plan that ispart of the CEMP.



1221_PI_36.pdf 1221_PI_36


This section belongs in 4.1.2 under CEMP




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Damage Control Plan.

There shall be a management-approved, written, dated, and annually tested damage control plan that ispart of the CEMP.



1221_PI_39.pdf 1221_PI_39


This section belongs under CEMP




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12.6.7 * Damage Control Plan.

There shall be a management-approved, written, dated, and annually tested damage control plan that ispart of the CEMP.



1221_PI_38.pdf 1221_PI_38






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Each jurisdiction shall develop a tactical interoperable communications plan (TICP) utilizingTIA-603-D, Land Mobile FM or PM Communication Equipment Measurement and PerformanceStandards, or a similar reference.



1221_PI_41.pdf 1221_PI_41


section belongs under CEMP




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12.6.8 *

Each jurisdiction shall develop a tactical interoperable communications plan (TICP) utilizing TIA-603-D,Land Mobile FM or PM Communication Equipment Measurement and Performance Standards , or a similarreference.



1221_PI_40.pdf 1221_PI_40






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12.8.6 Surge Arresters Protective Devices (SPDs) .

12.8.6.1*

Surge arresters SPDs shall be provided in accordance with NFPA 70.

12.8.6.2

Transient voltage surge suppression (TVSS) SPDs shall be provided Installed in accordance with NFPA70 for protection of telecommunications equipment, two-way radio systems, computers, and otherelectronic equipment determined by the AHJ to be essential to the operation of the communications center.


This is a task group input based on work being developed by NEMA in order to clarify the SPD verbiage throughout the code and to clarify the use of SPDs for less then 1kV.





Submitter Full Name: Thomas Parrish

Organization: Telgian Corporation

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12.8.8 Uninterruptible Power Supply (UPS) and Battery Systems Energey Storage Systems (ESS) .

12.8.8.1*

In addition to the required engine-driven generators, an uninterruptible power supply system shallESSshall be provided. It shall comply with the requirements of 12.8.8 and NFPA 70.

12.8.8.2

The UPS ESS shall provide conditioned, uninterrupted power to telecommunications equipment, two-wayradio systems, IT equipment, and other sensitive electronic equipment determined by the AHJ to beessential to the operation of the emergency communication systems.

12.8.8.3*

The UPS ESS shall be sized to carry the connected load for the length of time required to transferoperations to the alternate communications center as determined by the AHJ in connection with the CEMP,but in no case less than 15 minutes (Class 0.25.)

12.8.8.4

The UPS ESS shall provide performance equivalent to Type O or Type U stored emergency power supplysystem (SEPSS) as specified in Table 4.2.2 of NFPA 111.

12.8.8.5

The UPS ESS shall meet the SEPSS requirement for Level 1 as defined by NFPA 111.

12.8.8.6

Each UPS ESS shall be provided with a bypass switch that maintains the power connection duringswitchover and that is capable of isolating all UPS ESS components while allowing power to flow from thesource to the load.

12.8.8.7

The following UPS ESS conditions shall be annunciated in the operations room:

(1) Source power failure, overvoltage, and undervoltage

(2) High and low battery voltage

(3) UPS ESS in bypass mode


This is a task group proposal to update the term UPS Changes were made in NFPA 72 changing UPS to ESS confirm which term is the proper one.




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Public Input No. 18-NFPA 1225-2019 [ New Section after 12.11.3.5 ]

Facilities located below grade shall comply with NFPA 101 , Section 11.7, "Underground andLimited Access Structures," and shall be specifically designed for the location.



1221_PI_44.pdf 1221_PI_44


See PI 43 (New PI 17)




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12.11.3.5*

Remote communications facilities shall not be located below grade unless the elevation of the lowest floorin the facility is above the 500-year floodplain. Facilities located below grade shall comply with NFPA 101 ,Section 11.7, “Underground and Limited Access Structures,” and shall be specifically designed for thelocation.



1221_PI_43.pdf 1221_PI_43


creating new section to eliminate multiple "shall"s




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12.11.3.7*

Interior floor finish inside a remote communications facility shall be of noncombustible material or shallcomply with the requirements following:

(1) Rrequirements of NFPA 101 interior floor finish testing and classification and shall be

(2) Be Class I as established by NFPA 101

(3) or shall have a minimum critical radiant flux of 0.1 W/cm2.



1221_PI_42.pdf 1221_PI_42


Editorial changes to remove multiple "shall"s




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The AHJ shall determine which type of door is most appropriate for each location.



1221_PI_46.pdf 1221_PI_46






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12.11.6.3

Doors furnishing access shall be protected by listed, self-closing fire doors that have a fire resistance ratingof not less than 1 hour or by doors that are rated for bullet resistance to Level 4 as defined in ANSI/UL 752,Standard for Bullet-Resistant Equipment. The AHJ shall determine which type of door is most appropriatefor each location.



1221_PI_45.pdf 1221_PI_45


Moving Section "shall" to 4.10.6.3.1




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12.11.7.7 Surge Arresters. protective Devices (SPDs)

12.11.7.7.1

Surge arresters SPDs shall be provided in accordance with NFPA 70.

12.11.7.7.2*

Transient voltage surge suppression (TVSS) SPDs shall be provided in accordance with NFPA 70 forprotection of telecommunications equipment, two-way radio systems, computers, and other electronicequipment determined by the AHJ to be essential to the operation of the remote communications facility.


This is a task group input based on work being developed by NEMA in order to clarify the SPD verbiage throughout the code and to clarify the use of SPDs for less then 1kV.



Public Input No. 200-NFPA 1225-2019 [Section No. 12.8.6] Parallel requirements




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13.3.6

Cable joints shall be made to provide and maintain conductivity, optical continuity for fiber-optic cableinsulation installations , and protection that is at least equal to that afforded by the cables that are joined.


Seems like this word should be installation not insulation. Fiber optic cables don't require insulation.





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Public Input No. 117-NFPA 1225-2019 [ Section No. 13.5.1 [Excluding any Sub-Sections]

]

At the emergency services communications center, all conductors, cables, and fiber-optic cables shallextend that extend to the operations room in shall be installed in conduits, ducts, shafts, raceways, oroverhead racks and troughs that are listed or identified as suitable to provide protection against physicaldamage.


Improved clarity. Original text implies all conductors and cables shall extend to the operations room, but this is not the case. The intent, as I understand, is to require protection for all conductors and cables that do go to the operations room. Emergency Services added before communications center for additional clarity.



Public Input No. 102-NFPA 1225-2019 [Global Input]





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13.5.5.3

Communications and signal circuits where installed in junction terminal boxes, enclosures, or otherapproved temination devices, shall be identified by the use of a distinctive color on covers or doors of suchdevices .


As written the requirement looks incomplete as it is not clear what doors and covers are being referenced. The added text is based on 13.5.5.1.





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Public Input No. 241-NFPA 1225-2019 [ New Section after 13.6 ]

13.6 In-building Radio Enhancement System Wiring

13.6.1 Where a two-way radio communications enhancement

system is used in lieu of a two-way in-building wired

emergency communications system, it shall have a pathway

survivability of Level 1, Level 2, or Level 3 as determined by the type of building construction or a riskassesment.

Exception: Where leaky feeder cable is utilized as the antenna, it shall

not be required to be installed in metal raceway.

13.6.2 The feeder and riser coaxial cables shall be rated

as plenum cables.

13.6.3 Where required the feeder coaxial cables shall be connected to

the riser coaxial cable using hybrid coupler devices of a value

determined by the overall design.

13.6.4 The connection between the riser and feeder coaxial

cables required in 13.6.3 shall be made within the rated enclosure,

and passage of the feeder cable in and out of the rated

enclosure shall be firestopped to ratings. The rating of this enclosue shall match the survivability rating asdetermoned in 13.6.1

13.6.5 Where a two-way radio communications enhancement

system is used in lieu of a two-way in-building wired

emergency communications system, the design of the system

shall be approved by the authority having jurisdiction.


This is an effort to include a level of survivable wiring for the two way radio systems. These are to be used for fire operations and for firefighter safety are required to have wiring installed such that it can continue to operate during an emergency. Some felt that a TIA that was proposed last cycle was restrictive. This proposal allows for the designer and AHJ to utilize either a fire separation rating or a risk assessment to determine the required level of survivability.




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13.6 Circuit Protection.

13.6.1

Circuit Overvoltage protection required at the communications center shall be provided in all buildings thathouse communications center equipment.

13.6.1.1

All surge arresters protective devices shall be connected to the single-point facility ground in accordancewith NFPA 70.


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13.6.

2

The protective devices shall be located in proximity to or shall be combined with the cable terminals.

13.6.3

All protective devices designed and approved for the purpose shall be installed at a location accessibleonly to qualified persons, marked with the name of the manufacturer and the model designation, and shallbe accessible for maintenance and inspection.

13.6.4 *

Wired communications circuits shall have fast-acting surge suppression installed at the point of entranceto the communications center.

13.6.5

Surge arresters shall be designed and listed for the specific application.

13.6.6

Each conductor that enters a communications center from a partially or entirely aerial line shall beprotected by a surge arrester.

13.6.

7

At the junction points of open aerial conductors and cable, each conductor shall be protected by a surgearrester in accordance with 13

.

6.7.1 and 13.6.7.

2

. 13.6.7.1

13.6.7.2

The surge arrester shall be weatherproof or protected from the weather.

A connection shall be provided between the

surge arrester

surgeprotective device ground and any metallic sheath and messenger wire.

13.6.8

Aerial open wire and non-messenger-supported, two-

Two- conductor cable circuits shall be protected by surge

arresters

protective devices at intervals of approximately 2000 ft (610 m).

13.6.9

Wired portions of a radio dispatch circuit shall be protected in a manner that is consistent with theprovisions of Sections

13.

1 through 13.8 .

13.

6.10

Buildings that house communications equipment shall have lightning protection that complies withNFPA 780.


This is a task group input to clarify the SPD verbiage throughout the code and to clarify the use of SPDs and to clean up past code verbiage, This PI deletes sections that will be replaced by a companion PI


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Public Input No. 204-NFPA 1225-2019 [New Section after 13.6.1.1] Complimentary

Public Input No. 205-NFPA 1225-2019 [New Section after 13.6.3] Complimentary










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13.6 Circuit Surge Protection.

13.6.1

Circuit surge protection required at the communications center shall be provided in all buildings that housecommunications center equipment.

13.6.1.1

All surge arresters protective devices (SPDs) shall be connected to the single-point facility ground inaccordance with NFPA 70.

13.6.2

The surge protective devices shall be located in proximity to or shall be combined with the cable terminals.

13.6.3

All surge protective devices designed and approved for the purpose shall be installed at a locationaccessible only to qualified persons, marked with the name of the manufacturer and the model designation,and shall be accessible for maintenance and inspection.

13.6.4*

Wired communications circuits shall have fast-acting surge suppression a surge protective device installedat the point of entrance to the communications center.

13.6.5

Surge arresters protective devices shall be designed and listed for the specific application.

13.6.6

Each conductor that enters a communications center from a partially or entirely aerial line shall be protectedby a surge arrester protective device .

13.6. 6.1

A surge protective device is required on all AC electrical power circuits providing power to communicationscenter equipment.

13.6.6.2

Surge protective devices for AC power circuits are required to have either audible alarm status notificationor a dry contact circuit for remote notification status.

13.6.6.3

A surge protective device is required on all external metallic antenna cabling that directly terminates tocommunications center equipment.

13.6.6.4

A surge protective device is required on any data or signal communication circuits that are terminatedbetween the fire alarm control system and communications center equipment.

13.6. 7

At the junction points of open aerial conductors and cable, each conductor shall be protected by a surgearrester protective device in accordance with 13.6.7.1 and 13.6.7.2.

13.6.7.1

The surge arrester protective device shall be weatherproof or protected from the weather .

13.6.7.2

A connection shall be provided between the surge arrester ground and any metallic sheath and messengerwire only if installed on the outside of the building .

13.6.8

Aerial open wire and non-messenger-supported, two-conductor cable circuits shall be protected by surgearresters protective devices at intervals of approximately 2000 ft (610 m).


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13.6.9

Wired portions of a radio dispatch circuit shall be protected in a manner that is consistent with theprovisions of Sections 13.1 through 13.8.

13.6.10

Buildings that house communications equipment shall have lightning protection that complies with NFPA780.


Lack of specific guidance in regard to properly protecting communications center equipment from the effects of transient voltages and spikes generated from lightning and utility company sources.


Submitter Full Name: Michael Molinari

Organization: DITEK Corporation

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13.6.1.1

13.6.1.1 Grounded and ungrounded conductors that enter a communica ons center shall be protected by a Surge

Protec ve Device (SPD). Equipment grounding conductors and bonding jumpers shall not be connected to the SPD.


Task group work to clarify the use of SPDs and clean up past verbiage.



Public Input No. 203-NFPA 1225-2019 [Section No. 13.6]deleted sections that this proposal isreplacing

Public Input No. 205-NFPA 1225-2019 [New Section after13.6.3]

Complimentary

Public Input No. 206-NFPA 1225-2019 [New Section after13.6.7.2]

Complimentary


Complimentary



Public Input No. 206-NFPA 1225-2019 [New Section after13.6.7.2]





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13.6.1.3

Surge protec ve devices shall be listed and iden fied for the specific applica on.






Public Input No. 203-NFPA 1225-2019 [Section No. 13.6] Complimentary










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All protective devices shall be accessible for maintenance and inspection.



1221_PI_48.pdf 1221_PI_48






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13.6.3

All protective devices designed and approved for the purpose shall be installed at a location accessible onlyto qualified persons, marked with the name of the manufacturer and the model designation, and shall beaccessible for maintenance and inspection.



1221_PI_47.pdf 1221_PI_47


Removing multiple "shall" statements




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13.6.2

13.6.2 Signal protec on: The surge protec ve devices shall be located in proximity to or shall be combined with the

cable terminals.


Task group work to clarify the use of SPGs and clean up past verbiage.



Public Input No. 203-NFPA 1225-2019 [Section No. 13.6] complimentary

Public Input No. 204-NFPA 1225-2019 [New Section after 13.6.1.1] complimentary

Public Input No. 205-NFPA 1225-2019 [New Section after 13.6.3] complimentary








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13.6.3 Maintenance and Inspec on

13.6.3.1 All SPDs shall be accessible for maintenance and inspec on.

13.6.4 Loca ons

13.6.4.1* Outdoor Loca ons

Where the surge protec ve devices are located in damp or wet loca ons, their enclosures shall be water ght or

protected from the weather.

A.13.6.4.1 The term water ght is typically used in conjunc on with Enclosures Types 4, 4X, 6, and 6P. [70: Table

110.28 Informa onal Note No. 1]

Note: Add two Reference documents: UL 50E and NEMA 250

13.6.4.2 Indoor Loca ons

All SPDs shall be installed in a NEMA Type 1 enclosure.








Public Input No. 203-NFPA 1225-2019 [Section No. 13.6] Complimentary







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New Section after 13.6

Pathway Survivaability

13.7 Pathway Survivability. All pathways shall comply with

NFPA 70, National Electrical Code.

13.7.1 Pathway Survivability Level 0. Level 0 pathways shall not

be required to have any provisions for pathway survivability.

13.7.2 Pathway Survivability Level 1. Pathway survivability

Level 1 shall consist of pathways in buildings that are fully

protected by an automatic sprinkler system in accordance with

NFPA 13, Standard for the Installation of Sprinkler Systems, with

any interconnecting conductors, cables, or other physical

pathways installed in metal raceways.


Level 2 shall consist of one or more of the following:

(1) 2-hour fire-rated circuit integrity (CI) cable

(2) 2-hour fire-rated cable system [electrical circuit protective

system(s)]

(3) 2-hour fire-rated enclosure or protected area

(4) 2-hour performance alternatives approved by the authority

having jurisdiction


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Level 3 shall consist of pathways in buildings that are fully

protected by an automatic sprinkler system in accordance with

NFPA 13, Standard for the Installation of Sprinkler Systems, and

one or more of the following:

(1) 2-hour fire-rated circuit integrity (CI) cable

(2) 2-hour fire-rated cable system [electrical circuit protective

system(s)]

(3) 2-hour fire-rated enclosure or protected area

(4) 2-hour performance alternatives approved by the authority

having jurisdiction


if we are going to cite a requirement for survivability wiring we need to define the levels in this standards to maintain a separation from NFPA 72. This was not captured in the last edition and has led to confusion as to what is required.




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Public Input No. 24-NFPA 1225-2019 [ Section No. 15.3.1 [Excluding any Sub-Sections] ]

There shall be a minimum of two qualified telecommunicators on duty and present in the communicationscenter at all times.



1221_PI_49.pdf 1221_PI_49


Common practice is to have a qualified telecommunicator and a trainee, which, in a high call volume time means that there is only one person doing work and watching what their trainee is doing. Another practice is to have a field officer "watch" the board, when that officer isn't trained to perform all dispatch functions.




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15.4.1*

Ninety- percent of events received on emergency lines shall be answered within 15 seconds, and95 percent of alarms shall be answered within 20 seconds. (For documentation requirements, see 20.5.2.)

The appendix A7.4.1(b) includes transfer times not excedd 30 seconds. (However our text from revision

2016 to 2019 was removed).

15.4.1.1

Compliance with 15.4.1 shall be evaluated monthly using data from the previous month.



Public_Input_No._56-NFPA_1221-2019_Section_No._7.4.1_.pdf


As a TC Member, during our revision fro 2016 to 2019 we relocated the operation call processing time standardfrom area to another. Need to add original 2016 back to primary language. As a note the Appendix did keep theproper language.


Submitter Full Name: Thomas DiBernardo

Organization: Seminole Tribe Fire Rescue

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]

Emergency alarm processing for the highest prioritization level emergency events listed in 15.4.3.1 through15.4.3.2 shall be completed within 60 seconds, 90 percent of the time.

Calls requiring emergency medical dispatch questioning shall be completed within 90 seconds 90 percentof the time nd within 120 seconds 95 percent of the time.

Or centers using an EMD call processing system shall report call processing times to the medical oversitecommittee for their center.


Reinstate call processing times for EMD as gathering patient information takes longer to process.


Submitter Full Name: Jay Dornseif

Organization: Priority Dispatch Corporation

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Emergency alarm processing for the highest prioritization level emergency events listed in 15.4.3.1 through15.4.3.2 shall be completed within 60 seconds, 90 percent of the time.

See Public Imput for 7.4.1, to add back Transfer times not to exceed 30 seconds - the lanuage wasmistakenly removed from 2016 to 2019. See also A7.4.1 Where the time standard remained.



Public_Input_No._57-NFPA_1221-2019_Section_No._7.4.3_Excluding_any_Sub-Sections_.pdf


as a TC member the text from 2016 to 2019 was inadvertently removed when relocating sections. Language remained in appendix A 7.4.1(b)



Organization: Seminole Tribe Fire Rescue

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15.4.3.1

The following types of calls where there is an imminent threat to life shall be included in the highestprioritization level:

(1) Trauma (penetrating chest injury, GSW, etc.)

(2) Neurologic emergencies (stroke, seizure)

(3) Cardiac-related events

(4) Unconscious/unresponsive patients

(5) Allergic reactions

(6) Patient not breathing

(7) Choking

(8) Other calls as determined by the AHJ



Public_Input_No._3-NFPA_1221-2018_Section_No._7.4.3.1_.pdf


GSW conflicts with 7.4.3.3 which exempts measuring joint law/ Fire-Rescue calls with a weapon. This may also be conflicting to other weapon events resulting in a trauma.

*Note- I had a conversation with one of the NFPA members prior to this release. He mentioned that joint Law/ Fire- Rescue calls with a weapon was meant to refer to "barricaded-subject" type calls where Fire/ Rescue stages. If that was the intent, it is not clear through the verbiage used. To a PSAP, joint calls with a weapon would be any event where both disciplines respond and there is a weapon involved in the incident (e.g., domestic, shooting, stabbing,assault/ battery, suicide, etc.).




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Alarm monitoring

7.4.21 Alarm, supervisory, and trouble signals shall be permitted to be received at the Listed fire station orat the Listed governmental agency that has public responsibility for taking prescribed action to ensureresponse upon receipt of an alarm signal.



Public_Input_No._30-NFPA_1221-2019_New_Section_after_7.4.20_.pdf


Alarm monitoring by governmental agencies should be held to the same Standard as private monitoringcompanies. While NFPA 1221 does refer to NFPA 72 for operational guidance, in NFPA 72 section 26.5.3.1 acommunications center receiving alarms has to comply with NFPA 1221. In NFPA 1221, there is no third partyoversight by a Nationally Recognized Testing Laboratory (NRTL) to make sure that the governmental agency iscomplying with NFPA 72 (or 1221 for that matter). The building owners and managers are entitled to make surethat their service provider is providing Standards complying service. The only assurance to this can be when thereis third party oversight. By adding section 7.4.21, it clearly states that if governmental agencies want to providemonitoring services, their monitoring center should be "Listed," as defined in NFPA 72 section 3.2.4, by a NationallyRecognized Testing Laboratory (NRTL).


Submitter Full Name: Richard Kleinman

Organization: AFA Protective Systems Inc

Street Address:

City:

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Zip:


Committee: PUF-AAA


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15.7.1 Compliance with 15.7 shall be evaluated monthly using data from previous month.

15.7.2 Monthly compliance shall incude measure individual performance, and shift or center performance.


There are currently no stated measurable performances for QA.


Submitter Full Name: Jay Dornseif

Organization: Priority Dispatch Corporation

Street Address:

City:

State:

Zip:


Committee: PUF-AAA


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Add 16.1.1

Voice Receiving Equipment. Voice receiving equipment shall apply to facili es and equipment that are needed to

receive incoming requests for assistance or other informa on by voice.


New material to support changing technologies.




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New 16.1.2

Text to 9‐1‐1. Incoming requests for assistance from devices capable of sending text characters.


New material to support new technology




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Committee: PUF-AAA


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Add 16.1.3

Video. Incoming requests for assistance using a video‐based communica ons device/system.


New material to support new technologies




Street Address:

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Committee: PUF-AAA


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Add new 16.1.4

Digi al. Addi onal informa on on a request for assistance via the Automa c Loca on Informa on (ALI) link






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16.1* Telephone Receiving Equipment.

The provisions of Chapter 16 shall apply to emergency services communications facilities and equipmentthat are needed to receive events.


Text added to clarify the facilities to which the requirements apply.








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16.1* Telephone Receiving Equipment.

The provisions of Chapter 16 shall apply to facilities and equipment that are needed to receive events.

Requests from ci zens for emergency response shall come in on a method as described in 8.1.1 through 8.1.4.


Updating this section considering new technologies.




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16.2 Directory Listing. 9‐1‐1

16.2.

1 1 9‐1‐1 (or another dedicated three‐digit number for emergencies outside of the United States) shall be designated

as the primary emergency telephone number for use of any person seeking police, fire, medical, rescue, and other

emergency services.

16.2.2

Where 9‐1‐1 service is not provided available or in case of a failure of the 9‐1‐1 system , all of the following

requirements in 16.2.2.1 through 16.2.2.2 shall be met:

A specific telephone number shall be assigned for calls requesting emergency services.

The telephone number shall be publicized as such.

A separate number shall be assigned for business (non-emergency) use.

16.2.1 2 .1

A separate specific telephone line with a number that is not listed shall be maintained for

communication with other emergency service agencies and receipt of central station alarms assigned for

calls reques ng emergency services .

16.2.1 2 .2*

A separate

The telephone number shall be assigned for business (nonemergency) use publicized as an emergency

telephone number .

16.2.2

Where 9-1-1 service is provided, the telephone

.3

The directory listings shall indicate that 9-1-1 is the number to call for all emergencies.

16.2.3

Telephone directory listings shall be as specified in 16.2.3.1 through 16.2.3.5 .

2.4

A separate telephone circuit with a telephone number that is not publicly listed shall be maintained for

communica on with other emergency service agencies and receipt of central sta on alarms.


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16.2.3.1 Directory Listings


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The text and symbols shown in Figure 16.2.3.1(a) through Figure 16.2.3.1(c) shall appear on the insidefront cover or the page facing the inside front cover of the white pages directory the directory .

Figure 16.2.3.1 (a) Telephone Directory Listing for Fire Department.

Figure 16.2.3.1 (b) Telephone Directory Listing for Police Department.

Figure 16.2.3.1 (c) Telephone Directory Directory Listing for Emergency Medical Services.


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16.2.3.2 1

The emergency services listing shall appear in the directory under the name of the jurisdiction, includinggovernment listings, and under the headings for police, fire, and ambulance where provided.


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16.2.3.

3 2 The following lis ngs and telephone numbers shall appear as follows

in the white pages directory:Fire departmentTo report an emergency

in any directory lis ng emergency telephone numbers:

(1) Fire and Rescue Services

(a) To report an emergency 9‐1‐1 or, [fire number]

or, where available,

if 9‐1‐1

Nonemergency

is not available

(b) Nonemergency purposes [business number]

Police departmentTo

(2) Law Enforcement

(a) To report an emergency 9‐1‐1 or, [police number]


if 9‐1‐1

Nonemergency

is not available


Emergency

(3) Emergency medical services

To

(a) To report an emergency 9‐1‐1 or, [emergency medical number]


if 9‐1‐1 is not available


16.2.3.

4 3 If the directory covers an area that is protected by more than one emergency service, each agency or district shall

appear in the lis ng as specified in 16.2.3.1 .

16.2.3.

5 4 If the emergency service protects an area that is covered by more than one directory, each directory shall list the

agency or district as specified in 16.2.3.1 through 16.2.3.

3

2 .

16.2.3.

65 *

Where an ERF that is not con nuously staffed by trained telecommunicators is listed in

the telephone directory


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the directory , callers shall be provided with a recorded message that refers them to 9‐1‐1 or the appropriate

emergency telephone number when calls to the listed telephone number are not answered.


Updated material to support new technologies.




Street Address:

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]

Where 9-1-1 service is not provided, all of the following requirements shall be met:

(1) A specific telephone number shall be assigned for calls requesting emergency services.

(2) The telephone number shall be publicized as such.

(3) A separate number shall be assigned be listed in the telephone directory and assigned for business(non-emergency) use.


Relocation of requirement text from Annex to body of standard.




Public Input No. 121-NFPA 1225-2019 [Section No. A.16.2.1.2]





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Committee: PUF-AAA


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16.2.1.2 *

A separate number shall be assigned for business (nonemergency) use.


This requirement is addressed in 8.2.1 (3). The annex material can be linked to 8.2.1 and reference list item (3).



Public Input No. 121-NFPA 1225-2019 [Section No. A.16.2.1.2]

Public Input No. 122-NFPA 1225-2019 [Section No. 16.2.1 [Excluding any Sub-Sections]]





Street Address:

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Committee: PUF-AAA


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16.2.3.1


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The Where issued, the text and symbols shown in Figure 16.2.3.1(a) through Figure 16.2.3.1(c) shallappear on the inside front cover or the page facing the inside front cover of the white pages directory.

Figure 16.2.3.1(a) Telephone Directory Listing for Fire Department.

Figure 16.2.3.1(b) Telephone Directory Listing for Police Department.

Figure 16.2.3.1(c) Telephone Directory Listing for Emergency Medical Services.


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Unclear if white pages are issued anymore. Maybe requirement should be conditional./



Public Input No. 124-NFPA 1225-2019 [Section No. 16.2.3.3] Same issue






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16.2.3.3

The Where a white pages directory is provided, the following listings and telephone numbers shall appearas follows in the white pages directory :

(1) Fire department

(2) To report an emergency [fire number] or, where available, 9-1-1

(3) Nonemergency purposes [business number]

(4) Police department

(5) To report an emergency [police number] or, where available, 9-1-1


(7) Emergency medical services

(8) To report an emergency [emergency medical number] or, where available, 9-1-1



Many local telecommunications providers no longer provide a white pages directory. The requirement should be made to be conditional where such directories are provided.



Public Input No. 123-NFPA 1225-2019 [Section No. 16.2.3.1] same issue






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Add new section 16.3

16.3 Reliability.

16.3.1 The 9‐1‐1 system shall be designed so that no single point of failure can prevent calls from being answered.

16.3.2 Under failure condi ons, the full‐feature complement shall not be required to be maintained but the calling

party shall be able to communicate with the telecommunicator.

16.3.3* Circuit Diversity. At least two 9‐1‐1 call delivery paths with diverse routes arranged so that no single incident

interrupts both routes shall be provided to each communica ons center.

16.3.4 The communica ons center shall be capable of receiving automa c number informa on and automa c

loca on informa on (including Wireless Phase II data) from sources iden fied in Sec on 16.1.






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16.3

Equipment and Opera ons.

At the communica ons centers,

telephone lines

voice circuits shall be provided as follows:

(1) 9‐1‐1” shall be the primary method of no fica on of emergency calls.

(2) 9‐1‐1 circuits shall be provided as required for the volume of calls handled to provide a P.01 Grade of Service

(GOS).

( 2 3) * At least two telephone lines shall be assigned exclusively for receipt of emergency calls.

( 2 3) Addi onal emergency telephone lines shall be provided as required for the volume of calls handled to

provide P.

01

01 Grade of Service ( GOS ) .

( 34 ) Addi onal telephone lines shall be provided for the normal business (nonemergency) telephone number(s)

as needed.

At

( 4 5) At least one

outgoing-only

unlisted line shall be provided for outgoing calls only .

A separate telephone line

( 5 6) Separate telephone lines shall be provided as required in 16.2. 1.1 2 .

16.3.1

The AHJ shall ensure that the published

emergency lines

emergency telephone numbers are answered prior to

nonemergency lines

nonemergency telephone numbers .

16.3.1.1

When all emergency

lines

telephone numbers are in use,

emergency calls shall hunt to

requests for emergency assistance shall be routed to either other predetermined telephone lines that are

approved by the AHJ or to a pre‐designated PSAP/alternate site .

16.3.1.2

Calls

Overflow C calls to the business telephone number shall not hunt to the designated emergency telephone lines.

16.3.2


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When a PSAP receives

an emergency call for

a n request for emergency assistance for a loca on that is not in its jurisdic on or a call for an agency not under

the control of the PSAP,

the PSAP

the telecommunicator shall transfer the call directly to the responsible

communications center, when possible

primary or secondary PSAP .

16.3.2.1

The PSAP shall remain on the line

The telecommunicator shall remain connected to the voice circuit un l it is certain that the transfer has been made

to the primary or secondary PSAP .

16.3.2.2

* The

transfer procedure shall not rely on the PSAP personnel relaying the information to the responsiblecommunications center

telecommunicator shall transfer the caller, and not take the event informa on and relay ing it to the responsible

primary or secondary PSAP, unless it is not possible to transfer the caller .

16.3.3

All

incoming calls on

designated emergency telephone lines shall be recorded in accordance with Chapter 12 of this standard.

16.3.4 *

If an incoming call on any designated emergency

line is

telephone circuit is not answered within

60 seconds, an alarm indication

60 seconds, no fica on shall be

automatically transmitted to a location

automa cally sent to a device or worksta on approved by the AHJ.

16.3.5 *

Where

Automated voice alarms (as permi ed by the AHJ

permits

) received by the communica ons

center

center shall adhere to

receive automated voice alarms,


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the following requirements

shall apply

:

A separate

(1) Separate , unlisted telephone line(s) shall be provided to receive such alarms.

Such

(2) Such voice alarms shall not be permi ed to connect to the telephone lines required by Sec on 16.

2.1 and Section 16.

3 .

16.3.6

Where

Automated data alarms that are received by the communica ons center

is permitted to receive automated data alarms

through a dial‐up telephone service

, the

(as permi ed by the AHJ) shall adhere to the following requirements

shall apply

:

A separate

(1) Separate , unlisted telephone line(s) shall be provided to receive such alarms.

Such

(2) Such data alarms shall not be permi ed to connect to the telephone lines required by Sec on 16.

2.1 and Section 16.

3 .

16.3.7

Published emergency numbers shall meet the requirements of Section 16.5 .

Where the communica ons center is permi ed to receive automated data alarms through electronic means, the

requirements in APCO/CSAA ANS 2.101.2‐2014 Alarm Monitoring Company to Public Safety Answering Point (PSAP)

Computer‐Aided Dispatch (CAD) Automated Secure Alarm Protocol (ASAP) shall apply.

16.3.8

All telecommunicator posi ons that are available for receiving emergency calls shall be equipped with

TDD/TTY equipment.

16.3.9 *

The communication center shall accept non-voice emergency events from sources approved by the AHJ.

equipment capable of receiving and transmi ng text data.


Revised material to reflect new technologies



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Street Address:

City:

State:

Zip:


Committee: PUF-AAA


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16.4 Universal Emergency Number 9-1-1 Service.

16.4.1 General.

Universal emergency number 9-1-1 service shall meet the minimum requirements as specified inSection 16.4 .

16.4.2 Reliability.

16.4.2.1

The universal emergency number service equipment shall be designed so that no single point of failure canprevent calls from being answered.

16.4.2.2

Under failure conditions, the full-feature complement shall not be required to be maintained but the callingparty shall be able to communicate with the telecommunicator.

16.4.3 Circuits.

16.4.3.1 *

At least two 9-1-1 call delivery paths with diverse routes arranged so that no single incident interrupts bothroutes shall be provided to each communications center.

16.4.3.2 *

Where multiple communications centers that serve a jurisdiction are not located in a common facility, atleast two circuits with diverse routes, arranged so that no singular incident interrupts both routes, shall beprovided between communications centers.

16.4.4

Where enhanced 9-1-1 services are provided, the communications center shall be capable of receivingautomatic number information and automatic location information (including Wireless Phase II data) fromsources identified in Section 16.1 .


Material has been revised and relocated.




Street Address:

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Committee: PUF-AAA


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16.5 Published Emergency Number Alternative Routing.

16.5.1*

Communications centers shall maintain a plan as part of the CEMP for rerouting incoming calls onemergency lines when the center is unable to accept such calls.

16.5.2

Where the AHJ requires that overflow calls to emergency lines be routed to alternative telephone lineswithin the PSAP, the alternative telephone lines shall be monitored for integrity and recorded as required bythis standard.

16.5.3

Where a PSAP operates on a part-time basis, an automatic alternative routing plan shall be put in placethat ensures the rapid transfer of calls to the designated backup PSAP, even if the transfer switch, whereprovided, is not turned on.

16.5.4

Any call that has not been answered after 20 seconds shall be automatically routed as required by one ofthe following:

(1) A designated alternate PSAP

(2)

(3)

(4)

(5)


Revision to reflect new technologies




Street Address:

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Committee: PUF-AAA

* A holding queue

When in queue, the callers shall receive a recorded message informing them that they havereached the PSAP, including a TDD/TTY recorded message.

The system shall periodically remind callers to the PSAP who are in queue that they areconnected during their wait.

There shall be an audible and visual indication within the operations room that unanswered callsare waiting in the queue.


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16.6.3.1*

The ALI associated with the ANI used by the MLTS extension shall be sufficient to direct a response to the9-1-1 caller in an efficient manner and include, at a minimum, the civic address, building number, and floor,except as provided in 16 . 6.3.2.


No exceptions are allowed.




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16.6.3.2 *

Paragraph 16.6.3.1 shall not apply to any MLTS serving a facility of less than 7000 ft 2 .


No exceptions




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Committee: PUF-AAA


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Public Input No. 74-NFPA 1225-2019 [ Section No. 17.3.1.2.2 ]

17.3.1.2.2*

Radio system outdoor coverage shall be sufficient to provide a delivered audio quality (DAQ) of 3.0 foranalog or digital systems.



NFPA_3.4.docx Outdoor Coverage Should Be DAQ 3.4


Using a DAQ of 3.4 instead of 3.0 would require less "Radio Enhancement Systems" which are usually the source of interference. DAQ 3.0 is equal to -112 dBm; DAQ 3.4 is equal to -110 dBm for P25. If you use DAQ 3.0 (Speech understandable with slight effort. Requires occasional repetition due to noise or distortion.), you could be near the AMBE Vocoder Digital Cliff where it stops working; at DAQ 3.4 you are not.


Submitter Full Name: Joseph Sekula

Organization: Pasco County

Street Address:

City:

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Zip:


Committee: PUF-AAA


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17.3.4.1.5*

Mobile and portable units shall be capable of scanning trunked talkgroups and conventional channels witha user-selectable priority .



Public_Input_No._58-NFPA_1221-2019_Section_No._9.3.4.1.5_.pdf


Using (user-selectable) priority between conventional channels and trunking talkgroups is a potentially unreliable function. The amount of time a radio would take to move back and forth between a conventional channel and a trunked system with active talkgroup transmissions would most likely result in large audio 'holes' and missed audio transmissions. Therefore, the standard stating that the radio should have a user-selectable priority implies that allradios should do this.


Submitter Full Name: Mark Krizik

Organization: Motorola, Inc.

Street Address:

City:

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Zip:


Committee: PUF-AAA


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The glove size tested shall be large.



1221_PI_54.pdf 1221_PI_54






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Committee: PUF-AAA


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17.3.6.6

Portable radios shall be designed to allow channels to be changed and other radio functions controlledwhile emergency response personnel are wearing gloves of the type used in emergency responsefunctions. The glove size tested shall be large.



1221_PI_53.pdf 1221_PI_53


Use of multiple "shalls" in one statement.




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Cell Phones


Cell phones need to be added to the list of equipment to be used for communication


Submitter Full Name: Ryan Murray

Organization: Cleveland Fire Department

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 01 10:36:40 EDT 2019

Committee: PUF-AAA


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17.4.1.1

Radio alerting systems shall include one or more of the following:

(1) Voice receivers

(2) Coded receivers

(3) Noncoded receivers

(4) Numeric receivers

(5) Alphanumeric devices

(6) Two-way alphanumeric devices

(7) Cellular phone devices


Lack of communication with firefighters. Old RF pager systems are not as good as new cellular service. There are more cell towers now and have better coverage.



Public Input No. 61-NFPA 1225-2019 [Section No. 17.4.2.2] Internet and cell phones


Submitter Full Name: Shelton Foster

Organization: Holdenville Fire Dept

Street Address:

City:

State:

Zip:

Submittal Date: Thu Oct 24 09:48:27 EDT 2019

Committee: PUF-AAA


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17.4.1.1


(1) Voice receivers

(2) Coded receivers







NFPA_revision_10.19.docx communication REVISIONS


CURRENTLY WE HAVE CELL PHONE PROVIDERS PROVIDING PRIORITY FOR FIRST RESPONDERS THEREFORE THE TEXTING CAPABILITIES AND USAGE OF CELL PHONES NEED TO BE INCLUDED AS A ALLOWED MEANS OF COMMUNICATING FIRE CALLS.


Submitter Full Name: Paul Simpson

Organization: COEDD

Street Address:

City:

State:

Zip:


Committee: PUF-AAA


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17.4.1.1


(1) Voice receivers

(2) Coded receivers





(7) cell phones


Cell phones need to be allowed to use in paging for better response from first responders.


Submitter Full Name: kevin green

Organization: Wewoka FIre Dept

Street Address:

City:

State:

Zip:

Submittal Date: Fri Oct 25 12:41:07 EDT 2019

Committee: PUF-AAA


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17.4.1.1


(1) Voice receivers

(2) Coded receivers





(7) Cell phone Text message

(8) Cell phone notification by app


In Rural areas like ours, cell phone coverage is more reliable than the coverage we get with our radio repeater towers. For our volunteers, it is easier to get text alerts by text than having to keep track of a pager or radio while on their "day/paying" Job.


Submitter Full Name: Melody Carpenter

Organization: Lamar Vol Fire Dept

Street Address:

City:

State:

Zip:


Committee: PUF-AAA


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17.4.1.1

Radio alerting Alerting systems shall include one or more of the following:

(1) Voice receivers

(2) Coded receivers





(7) Cell phones


Radios and pagers are not a good way to communicate in areas where radio reception is poor due to terrain. Cell phone reception is better in our area. Our volunteer firefighters all carry cell phones. Texting is the most reliable way to get everyone notified quickly. There are also internet based paging systems that allow tracking firefighters on their way to the fire. I-pads in fire trucks to locate fires and keep track of weather conditions could be life-saving.




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Committee: PUF-AAA


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17.4.1.1


(1) Voice receivers

(2) Coded receivers





(7) Cell phones


RF pagers are out dated and expensive. We need to use cell phones for paging. Everyone carries their phones in their pockets at all times.


Submitter Full Name: Edward Powers

Organization: Holdenville FD

Street Address:

City:

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Zip:


Committee: PUF-AAA


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17.4.2.2

No part of the The paging system shall may utilize the public Internet for any portion of its operationwhen used as a method of emergency dispatch.


The mountains and hills in Oklahoma block the radio signals around our county. 7 of the 12 departments in Hughes county are restricted by the hills in some way. The county nor the departments have the funding to construct more towers for repeaters. The cell phone company's have already placed towers for their customers and every firefighter has a phone in their pocket. It works much better then the old pagers ever did. The cost of keeping up the pagers themselves is cost prohibited. I know no system is perfect. There was a time we had no choice. The time has come and technology has improved to the point where we can utilize it. Hughes county has 3 repeaters now (just got the central repeater in 2017) only the central repeater is actually located in Hughes County. The north and south repeaters are up to 20 miles outside Hughes county. Its all we had so we used it. Now we have a choice and we need the standard changed so ISO wont penalize us for it.





Submitter Full Name: Shelton Foster

Organization: Holdenville Fire Dept

Street Address:

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State:

Zip:


Committee: PUF-AAA


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17.4.2.2

No part of the paging system shall utilize the public Internet for any portion of its operation when used as amethod of emergency dispatch.



NFPA_revision_10.19.docxUSAGE OF CELL TOWERS SEAM TO PROVIDE BETTER RESULTS THAN RADIO REPEATER TOWERS.


RADIO BROCAST RANGE AND BETTER COVERAGE USING CELL PHONES AND TEXTING.


Submitter Full Name: Paul Simpson

Organization: COEDD

Street Address:

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Zip:


Committee: PUF-AAA


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17.4.2.2



The repeaters do not give ample enough coverage in our area like the cell towers do. It is very essential that we maintain the usage of cell towers for our paging system. It has worked for years. Please let us to continue using cell phones for paging and other communication uses.


Submitter Full Name: kevin green

Organization: Wewoka FIre Dept

Street Address:

City:

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Zip:


Committee: PUF-AAA


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17.4.2.2



There are good apps for cell phones that will page out the firefighters, and allows the fire chief to track where his guys are after being called out to a fire. This way the chief can call in more assistance if he sees some of his firefighters are too far out. In our area the cell phone reception works better than the radio reception from our county repeaters. In this day and age, most everyone carries a cell phone with them. We need to be able to use this technology.




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17.4.2.2

No part of the

paging system shall utilize the public Internet for any portion of its operation when used as a method ofemergency dispatch.


Radio Frequency Technology works in some places but the cost of up keep is prohibited for many years with storms and lightning. Even the fact of having towers to place repeaters on for the departments to use is cost prohibited. Cell towers companies keep their equipment up and going much more effectivly than radio shops do. Cell companys also have more towers creating better coverage.


Submitter Full Name: Edward Powers


Street Address:

City:

State:

Zip:


Committee: PUF-AAA


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17.4.2.2




.1572296699610

Radio frequency technology works in some places but the cost of up keep is prohibited for many areas with storms and lightning. Evanthe fact of having towers to place repeaters on the departments to use is cost prohibited. Cell tower companies keep their equipment up and going much better than radio shops do. Cell companys have many more towers for better coverage also.


Radio frequency technology works in some places but the cost of up keep is prohibited for many areas with storms and lightning. Evan the fact of having towers to place repeaters on for the departments to use is cost prohibited. Cell tower companies keep there equipment up and going much better than radio shops do. Cell companys have many more towers for better coverage also.


Submitter Full Name: rusty carter


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Submittal Date: Mon Oct 28 17:02:55 EDT 2019

Committee: PUF-AAA


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17.4.2.2

No part of the The paging system shall utilize may utilize the public Internet for any portion of its operationwhen used as a method of emergency dispatch.


There are more Cell towers around to ping signals off of, also the cell phones are easier to maintain and keep charged which chargers are more readily available the pager chargers. and its cheaper for the department and staff.


Submitter Full Name: Benjamin Wood

Organization: Holdenville Fire Department

Affiliation: Fireman

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17.4.2.2

No part of the The paging system shall may utilize the public Internet for any portion of its operation whenused as a method of emergency dispatch.


Cell phones are Easier to use, The cellular range is alot better, most people have cell phones in their pockets ready to be used. Cell phones would be a more reliable source then the old pagers.


Submitter Full Name: Mathew Peters

Organization: Holdenville Fire Dep

Affiliation: A Chief

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17.4.2.2

No part of the paging system shall utilize the public Internet for any portion of its operation when used as amethod of emergency dispatch. Cell towers have better coverage than the repeaters. Firefighters are ableto recive pages and calls where ever they are.


Cell towers have better coverage than the repeater towers, personel can receive a call no matter where they are at. Also departments that are not on a repeated system that are out of the area of radio coverage can receive the call and respond.


Submitter Full Name: Ryan Murray

Organization: Cleveland Fire Department

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Submittal Date: Fri Nov 01 10:30:45 EDT 2019

Committee: PUF-AAA


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Compressed air alerting devices shall have a distinctive tone. If coded, the duration of the blast shall beneither less than 0.5 second nor longer than 1.5 seconds, with silent intervals of 1 to 1.5 times the blastduration.



1221_PI_51.pdf 1221_PI_51


Too many "shalls" in one line.




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If coded, the duration of the blast shall be neither less than 0.5 second nor longer than 1.5 seconds,with silent intervals of 1 to 1.5 times the blast duration.



1221_PI_52.pdf 1221_PI_52






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New Paragraph 9.6.1.1

Additional bi-directional amphifiers or repeaters located in areas other than the designated fire commandarea at the protected premise shall be placed in a fire rated enclosure and conditioned room..

New paragraph 9.6.1.1.1

During periods when equipmentrt in paragraph 9.6.1.1 does not have conditioned ambient temperatures

maintained by building equipment due to lack of primasry utility power. The secondary energy source shall

operate on emergency energy within the equipment enclosure to maintain the design ambient temperateas

presented in the listed published instructions.

New paragraph 9.6.1.1.2 If the above equipment can operate at higher temperatures than published

ambient design documentrs indicate then the manufacture is obligated to have the NTL twest theequipment

for the required standby tim,e of secondary energy demand.



Public_Input_No._68-NFPA_1221-2019_New_Section_after_9.5.5.1_.pdf


In current published instructions some manufacturers stated their bi-directional amplifiers require an ambienttemperature of or +70F (+21C) to +80F (+26C) is required. During normal operation these units generate heat inthe neighbor of 0.55 KW and the the design ambient shall be maintained as outlined in the manufacturer'spublished instructions.


Submitter Full Name: Vic Humm

Organization: Vic Humm & Associates

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17.6.1 Where Required

Two-way Radio Communications Enhancement Systems shall be installed in buildings where the operationof two-way radio devices via direct connection to the emergency services communications center does notmeet the minimum performance standards of the AHJ.

17.6.1.1 Two-way Radio Communications Enhancement Systems shall not be required in locations such astelecommunications facility equipment rooms where the operation of two-way radio devices could impairtelecommunication services due to interference.



Responder_Radios_in_Telecom_Rooms.pdfSupporting documentation

1001194213-1001194188-1001194171_-_TCG_EMC_Investigative_Report_R1.pdf

TCG-UL-Test report


Telecommunications facilities are essential elements of the public safety network, providing communities with connectivity to 911, E911, as well as processing of alarms and other signals. The telephone network has a large embedded base of electronic equipment that is forty years old or older. This equipment has not been designed or tested for immunity at the power levels and frequencies commonly used in responder radios. As a result, the use of radios in telecommunications equipment rooms can result in a phone service outage. A 2010 joint study of the effects of responder radios on telecommunications equipment was sponsored by AT&T, Verizon and Qwest and performed by UL. This study confirmed that telecommunications equipment can be functionally impaired and damaged by close proximity radio operation at common frequencies. To help assure reliability of the phone network, it is recommended that responder radios not be utilized in telecommunications equipment areas.

Telecommunications equipment rooms are not publicly accessible areas and the number of incidents requiring responder access are relatively low compared to other commercial occupancies. As these facilities are unique occupancies with such an important role, close cooperation between the owner and the AHJ should be encouraged to assure responder activities are not unduly impaired.





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17.6 In-building Two-Way Radio Way Emergency Responder Communications Enhancement Systems.

17.6.1 General.

All system components shall be designed, installed, tested, inspected, and maintained in accordance withthe manufacturers’ published instructions and the requirements of Section 17.6.

17.6.2 Approval.

Where a two-way radio communications an In-building two-way emergency responder communicationsenhancement system is used, the design of the system shall be approved by the AHJ.

17.6.2.1

The backbone, antenna distribution, radiating, or any fiber-optic cables shall be rated as plenum cables.

17.6.2.2

The backbone cables shall be connected to the antenna distribution, radiating, or copper cables usinghybrid coupler devices of a value determined by the overall design.

17.6.2.3

Backbone cables shall be routed through an enclosure that matches the building’s fire rating.

17.6.2.4

The connection between the backbone cable and the antenna cables shall be made within an enclosurethat matches the building’s fire rating, and passage of the antenna distribution cable in and out of theenclosure shall be fire-stopped.

17.6.3 * Lightning Protection.

Systems shall have lightning protection that complies with NFPA 780.

17.6.4 Testing Requirements.

Systems that are used to comply with the requirements of Section 9.6 shall be tested in accordance with19.3.9 and 19.3.9.1.

17.6.5 Non-Interference and Non-Public Safety System Degradation.

17.6.5.1

No amplification system capable of operating on frequencies or causing interference to frequenciesassigned to the jurisdiction by the licensing authority of the country of jurisdiction shall be installed withoutprior coordination and approval of the AHJ.

17.6.5.2

The building manager/owner shall suspend and correct equipment installations that degrade theperformance of the public safety radio system or public safety radio enhancement system.

17.6.5.3

Systems that share infrastructure with non-public safety services shall ensure that the coverage andperformance of the public safety communications channels are not degraded below the level ofperformance identified in 17.6.7 and 17.6.8, regardless of the amount of traffic carried by the non-publicsafety services.

17.6.6 Approval and Permit.

17.6.6.1

Plans shall be submitted for approval prior to installation.

17.6.6.2

At the conclusion of successful acceptance testing, a renewable permit shall be issued for the public safetyradio enhancement system where required by the AHJ.

17.6.7 * Radio Coverage.


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17.6.7.1

Radio coverage shall be provided throughout the building as a percentage of floor area as specified in17.6.7.3 and 17.6.7.4.

17.6.7.2

The system shall adhere to the maximum acceptable propagation delay standard provided by the AHJ.

17.6.7.3

Critical areas, including fire command centers, fire pump rooms, exit stairs, exit passageways, elevatorlobbies, standpipe cabinets, sprinkler sectional valve locations, and other areas deemed critical by the AHJ,shall be provided with 99 percent floor area radio coverage.

17.6.7.4

General building areas shall be provided with 90 percent floor area radio coverage.

17.6.7.5

Buildings and structures that cannot support the required level of radio coverage shall be equipped with asystem that includes RF-emitting devices that are certified by the radio licensing authority to achieve therequired adequate radio coverage.

17.6.7.6

Radio enhancement systems shall be designed to support two portable radios simultaneously transmittingon different talk paths or channels, where the AHJ has required the radio enhancement system to supportmore than one channel or talk path.

17.6.8 * Signal Strength.

17.6.8.1 * Inbound.

17.6.8.1.1

A minimum inbound signal strength sufficient to provide usable voice communications, as specified by theAHJ, shall be provided throughout the coverage area.

17.6.8.1.2

The inbound signal level shall be sufficient to provide a minimum of DAQ 3.0 for either analog or digitalsignals.

17.6.8.2 * Outbound.

17.6.8.2.1

A minimum outbound strength sufficient to provide usable voice communications, as specified by the AHJ,shall be provided throughout the coverage area.

17.6.8.2.2

The outbound signal level shall be sufficient to provide a minimum of DAQ 3.0 for either analog or digitalsignals.


If a donor antenna exists, isolation shall be maintained between the donor antenna and all inside antennasto a minimum of 20 dB above system gain.

17.6.10 Frequencies.

The public safety radio enhancement system shall be capable of transmitting all radio frequencies, asrequired by the AHJ assigned to the jurisdiction, and be capable of using any modulation technology incurrent use by the public safety agencies in the jurisdiction.

17.6.10.1 List of Assigned Frequencies.

The AHJ shall maintain a list of all inbound/outbound frequency pairs for distribution to system designers.

17.6.10.2 * Frequency Changes.

Systems shall be upgradeable to allow for instances where the jurisdiction changes or adds systemfrequencies to maintain radio system coverage as it was originally designed.

17.6.11 System Components.

17.6.11.1 * Component Approval.


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17.6.11.1.1

RF-emitting devices and cabling used in the installation of the public safety two-way radio communicationsenhancement systems shall be approved by the AHJ.

17.6.11.1.2

All RF-emitting devices shall have the certification of the radio licensing authority of that country and besuitable for public safety use prior to installation.

17.6.11.2 Component Enclosures.

17.6.11.2.1

All repeater, transmitter, receiver, signal booster components, optical-to-RF and RF-to-optical converters,external filters, batteries, and battery system components shall be contained in a NEMA4- or NEMA4X-typeenclosure(s).

17.6.11.2.2

Batteries that require venting shall be stored in NEMA3R-type enclosures.

17.6.11.3 RF-Emitting Devices.

RF-emitting devices shall meet the following requirements in addition to any other requirements determinedby the AHJ:

(1) RF-emitting devices shall have the certification of the radio licensing authority prior to installation.

(2) All RF-emitting devices shall be compatible with both analog and digital communications, as requiredto be used by the radio licensing authority and the AHJ, simultaneously at the time of installation.

17.6.12 Power Sources.

At least two independent and reliable power sources shall be provided for all RF-emitting devices and anyother active electronic components of the system: one primary and one secondary.

17.6.12.1 Primary Power Source.

The primary power source shall be supplied from a dedicated branch circuit and comply with NFPA 72.

17.6.12.2 Secondary Power Source.

The secondary power source shall consist of one of the following:

(1) A storage battery dedicated to the system with 12 hours of 100 percent system operation capacity

(2) An alternative power source of 12 hours at 100 percent system operation capacity as approved by theAHJ

17.6.12.3 Monitoring Integrity of Power Sources.

Monitoring the integrity of power sources shall be in accordance with 17.1.2.2.

17.6.13 System Monitoring.


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17.6.13.1 Fire Alarm System.

The system shall include automatic supervisory signals for malfunctions of the two-way radiocommunications enhancement systems that are annunciated by the fire alarm system in accordance withNFPA 72 and shall comply with the following:

(1) Monitoring for integrity of the system shall comply with Chapter 10 of NFPA 72.

(2) System supervisory signals shall include the following:

(3) Donor antenna malfunction

(4) Active RF-emitting device failure

(5) Low-battery capacity indication when 70 percent of the 12-hour operating capacity has beendepleted

(6) Active system component failure

(7) Power supply supervisory signals shall include the following for each RF-emitting device and activesystem components:

(8) Loss of normal ac power

(9) Failure of battery charger

(10) The communications link between the fire alarm system and the two-way radio communicationsenhancement system shall be monitored for integrity.

17.6.13.2 Dedicated Annunciation.

17.6.13.2.1

A dedicated annunciator shall be provided within the fire command center to annunciate the status of allRF-emitting devices and active system component locations. This device shall provide visual and labeledindications of the following for each system component and RF-emitting device:

(1) Normal ac power


(3) Battery charger failure

(4) Low-battery capacity (i.e., to 70 percent depletion)


(6) Active RF-emitting device malfunction

(7) Active system component malfunction

17.6.13.2.2

The communications link between this device and the two-way radio communications enhancement systemshall be monitored for integrity.

17.6.14 Technical Criteria.

17.6.14.1

The AHJ shall maintain a document of technical information specific to its requirements.

17.6.14.2

Technical information documents shall be kept in a secure place accessible to maintenance personnel butnot accessible to the public.


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17.6.14.3

Technical information documents shall contain, as a minimum, the following:

(1) Frequencies required for the in-building enhancement system

(2) Location and effective radiated power (ERP) of radio sites used by the public safety radioenhancement system

(3) Maximum propagation delay — in microseconds

(4) List of specifically approved system components

(5) Other supporting technical information necessary to direct system design


This public input revises the terminology for these communications to harmonize with the current descriptions in the UL 2524 standard, NFPA 1 and the International Fire Code (IFC). The changes are to emphasize these systems are specific to use within buildings and are intended to cover all public safety emergency responders; fire service, EMS and law enforcement.

This is a global change intended to capture any place the phrase “two-way radio communication enhancement system(s)” appears in this standard, including any definitions.










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9.6.1.1 Two-Way Radio Communications Enhancement Systems shall comply with ANSI/UL 2524,Standard for In-building 2-Way Emergency Radio Communication Enhancement Systems, or otherequivalent standards and shall be installed in accordance with the requirements of the listing.





The in building communication systems hardware on the market currently carry no listing (except the Honeywell product listed under the Outline of Investigation) and are all over the board with regard to manufacturing and design. The New UL 2524 standard creates a baseline of design and manufacturing that all in building two-way radio enhancement systems should be following.


Submitter Full Name: Matthew Mertens

Organization: North Shore Fire Department

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Purpose

The purpose of the in-building two way radio enhancement system is to allow effective communicationsbetween the emergency responders whithin the building and the Emergency Dispatch facilities.





This section will clarify the actual intent of the system and allow uniform application and enforcement of the standard.







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Purpose

The purpose of the in-building two way radio enhancement system is to allow effectivecommunications between the emergency responders whithin the building and the IncidentCommander on location at the incident site.





This section will clarify the actual intent of the system and allow uniform application and enforcement of the standard.







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17.6.1 General.

The radio enhancement system shall be designed installed, tested, inspected, and maintained to complywith Section 17.6. All system components shall be designed, installed, tested, inspected, and maintainedin accordance with the manufacturers’ published instructions.

The radio enhancement system shall in be installed in accordance with NEC Articles 810 Radio and

the requirements of Section 17.6 .

Television Equipment and 820 Community Antenna Systems and Radio Distribution Systems.

If used, donor antennas, mounts and antenna installation shall be designed to ANSI-TIA-222 StructuralStandard For Antenna Supporting Structures and Antennas, as appropriate for the installation location.


Clarify system compliance requirements versus compliance with manufacturers recommendations. The general installation requirements for radio distribution systems need to be stated in accordance with the NEC. Donor antenna systems need to be able to withstand wind and ice conditions encountered at the installation location.


Submitter Full Name: Richard Abbott

Organization: InbuildingRadio

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Submittal Date: Sun Nov 10 10:12:01 EST 2019

Committee: PUF-AAA


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]

Where a two-way radio communications enhancement system is used, the design of the system shall beapproved by the AHJ. If the AHJ is not the FCC Licensee, the FCC Licensee shall also approve the design,in accordance with FCC Part 90.219. The design submitted for approval shall consist of the following as amimimum:

1. Local Off-Air Signal Level Measurements

2. Local Code Requirements and Statement Of Compliance

3. Building Site Plan, Building Floor Plans and Elevation Plans

4. Donor RF Link Path Profiles, Link Budgets, Azimuths and Distances

5. Donor Antenna Mounting Details And Donor Antenna Cable Installation Details

6. Grounding And Surge Suppression Details

7. Riser Block and Level/Cable Diagrams

8. Device Locations On Floor Plans

9. Pathway Survivability Design As Applicable.

10. Primary and Backup Power Distribution Design and Wiring

11. Backup Power Calculations

12. Monitoring System Design Including FACP Interfaces and Annunciators

13. Donor/DAS Antenna Isolation Calculations

14. Signal Coverage Prediction (Heat) Maps On Floor Plans

15. Designer Qualifications

16. Installer Qualifications

17. Test Grids On Floor Plans (Or Walk Plan If Approved By AHJ)

18. Manufacturers Specification Sheets (Cut Sheets) For All Equipment and Cable


The FCC Licensee is required to exercise reasonable control over any design intended to retransmit the licensees frequencies. In many cases, the Fire Code AHJ is not the FCC licensee. The code needs to describe what it is that the AHJ and FCC Licensee need to approve.




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Submittal Date: Wed Nov 13 07:45:44 EST 2019

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]

Where a two-way radio communications enhancement system is used, the design of the system shall beapproved by the AHJ.

17.6.2.1 Where approved by the AHJ, a system utilizing mobile emergency responder communicationenhancement vehicles provided by the municipal emergency response agency(s) that meets therequirements of Section 17.6.7 (Radio Coverage) and 17.6.8 (Signal Strength) may be substituted for thein-building two-way emergence responder communication system .

A.17.6.2.1 The AHJ should consider the emergency communication needs for firefighters, EMS providersand law enforcement when determining their approval to allow a mobile system as a substitute for thepermanently installed in-building system.


This new language recognizes that some jurisdictions have opted to provide a mobile (vehicle based) emergency responder communication enhancement system of capability is lieu of the need for a building to be equipped with an internal (“in-building”) system, provided the mobile system is: 1) approved by the AHJ and meets the performance requirements for coverage and signal strength deemed essential to emergency responder safety.




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17.6.2.1 Listing. In-building Two-way Emergency Responder Communication Enhancement Systemequipment shall be listed to UL 2524.


This public input adds the requirement to test and list equipment installed to enhance emergency responder radio coverage in buildings to ensure the equipment meets basic fire and shock safety and performance requirements in compliance specified in NFPA 1225. This UL Standard is a Bi-national standard; published as a ANSI Consensus standard on October 19, 2018 and CSS approved on January 9, 2019.










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17.6.2.1.1 System components shall be installed, tested, inspected, and maintained in accordance withthe ir listing, manufacturer’s published instructions and this standard .


This public input adds the design, installation, inspection, maintenance and performance requirements that were recently approved by the NFPA 1 Technical Committee as 2nd draft for inclusion in NFPA 1225 for consistency. These requirements also harmonize with requirements in the International Fire Code (IFC) that references NFPA 1221 for the design and installation of in-building Two-way Emergency Responder Communication Enhancement Systems.










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17.6.2.1

The backbone, antenna distribution, radiating, or any fiber-optic cables shall be rated as plenumcables meet the requirements of Pathway Surivability Level 2, as defined in NFPA 72 .


The requirement that the cables be plenum rated cable addresses the flame spread and smoke developed performance of the cables. However, it does not address the ability of the cables to continue to perform when exposed to a fire. Whereas these systems are used during an emergency event, the cables need to be able to survive a fire exposure.

Pathway Survivability Level 2 requires two-hour protection. It should be noted that there is a First Revision to introduce a pathway survivability level in NFPA 72 that only requires one-hour protection. This level of protection may be appropriate in buildings having a one-hour fire resistance rating.


Submitter Full Name: William Koffel

Organization: Koffel Associates, Inc.

Affiliation: 3M Company

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17.6.2.1

The backbone, antenna distribution, radiating, fiber-optic, or any fiber-optic cables shall other means ofsignal conveyance cables, shall be rated as plenum cables.


Line seems to be prescriptive to a coaxial cable or fiber optic based distribution system, preventing other signal distribution methods.


Submitter Full Name: Connor Crowley

Organization: TowerIQ, Inc

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Submittal Date: Tue Oct 22 15:14:45 EDT 2019

Committee: PUF-AAA


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17.6.2.1

The backbone, antenna distribution, radiating, or any fiber-optic cables shall be rated as plenum cables.jacketed and listed for the specific installa on loca on and shall be installed in accordance with Ar cle 820.110 and

810.113 of NFPA 70.


Allowable cable types already defined in NFPA 70 conditioned spaces. Plenum rated cables should not be required in non-plenum locations. Plenum rated cables are more expensive and less flexible, more difficult to install than non-plenum cable. Horizontal cable runs installed in conduit should not require plenum cable, as might be the case with pathway survivability 1 installations.




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Public Input No. 167-NFPA 1225-2019 [ Sections 17.6.2.1, 17.6.2.2, 17.6.2.3, 17.6.2.4 ]

Sections 17.6.2.1, 17.6.2.2, 17.6.2.3, 17.6.2.4

17.6. 2 11 . 3. 1


17.6. 2 11 . 3. 2


17.6. 2 11 .3 3


17.6. 2 11 . 3. 4



Relocate and accommodate renumbering to move the material to a more appropriate location in light of the previous PIs that have been submitted.This public input proposes to change the general coverage requirement for in-building two-way emergency responder communication enhancement system coverage to 95% from 90%. This requirement provides the appropriate coverage areas to ensure that any first responder is in or very close to the area that will permit sending and receiving emergency radio signals. For l;arge floor areas, 90% coverage could levee large areas of floor space without signal capability and thereby lower first-responder safety. This requirement would also provide consistency with IFC requirements that have been in place since 2012.










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Public Input No. 197-NFPA 1225-2019 [ Sections 17.6.2.1, 17.6.2.2, 17.6.2.3, 17.6.2.4 ]

Sections 17.6.2.1, 17.6.2.2, 17.6.2.3, 17.6.2.4

This i=input is from the the TG

Cable and component survivability requirements need to be clarified and potentially modified

RF performance and testing criteria and measuring procedure needs to be clarified

Need to clarify secondary power source requirements

Need to clarify dedicated annunciator requirements, particularly as they relate to distributed fiber system

remote monitoring

Passive device monitoring needs to be discussed

17.6.2.1


17.6.2.2


17.6.2.3


17.6.2.4



• Cable and component survivability requirements need to be clarified and potentially modified• RF performance and testing criteria and measuring procedure needs to be clarified • Need to clarify secondary power source requirements• Need to clarify dedicated annunciator requirements, particularly as they relate to distributed fiber system remote monitoring• Passive device monitoring needs to be discussed



Organization: Florida Department of Health

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17.6.2.2

The backbone cables Where backbone cables are connected to antenna distribution, radiating, or coppercables, the backbonae cables shall be connected to the antenna distribution, radiating, or copper cablesusing hybrid coupler devices of a value determined by the overall design.


Sounds prescriptive and limiting alternative signal distribution methods.




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17.6.2.2

The backbone cables shall be connected to the antenna distribution, radiating, or copper cables usinghybrid coupler or splitter devices of a value determined by the overall design.


Propose the word "hybrid" be removed from this section. A hybrid coupler is a specific technology device to passively split RF signal unequally or equally. There are other types of devices including Wilkinson Splitters, reactive splitters and tappers that all split RF signals that are perfectly acceptable in a design but are not considered a hybrid coupler. Changing the wording to say "coupler or splitter" leaves it open to using a variety of technologies best determined by the designer.


Submitter Full Name: Mike Brownson

Organization: Westell

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17.6.2.2

The backbone cables shall be connected to the antenna distribution, radiating, or copper cables usinghybrid coupler devices of a value determined by the overall design Couplers used for distribution of signalsfrom the backbone to signal coverage areas shall be enclosed within the same fire rated enclosure as thebackbones cables, and shall be accessible through a fire rated access panel for maintenance .


The current statement does not impose any requirements, and couplers may not be hybrids. Since the couplers are part of the backbone signal distribution, they must have the same pathway survivability as the backbone cables. Since the couplers are subject to corrosion, vibration etc, they may require periodic maintenance for testing and/or replacement.




Affiliation: None

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17.6.2.3

Backbone cables shall be routed through installed totally within in an enclosure that matches the building’sfire rating or encased in a material (wrapped) that matches the building's fire rating .


The intention of "rated through" is not clear. Wrapping cables outside an enclosure should also be permitted.




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17.6.2.3

Backbone cables shall be routed through an enclosure that matches the building’s fire rating. listed with afire-resistance rating or shall be protected by an assembly having a fire-resistance rating in accordancewith the following:

1. Where the primary structural frame of a building is required to have a fire-resistance rating of 2 hours ormore or is classified as heavy timber construction, the minimum fire-resistance rating shall be 2 hours.

2. Where the primary structural frame of a building is required to have a fire-resistance rating of less than 2hours, the minimum fire resistance rating shall be 1 hour.

3. Where the primary structural frame of a building does not require a fire-resistance rating, a fireresisitance rating shall not be required.

A.17.6.2.3

The intent of the fire-resistance rating requirements in this section is to provide for survival of the radiosystem backbone components correlating to the design basis for structural integrity of the building in whichthe system is installed. The fire-resistance rating for the primary structural frame under NFPA 5000 isestablished by the required rating for structural columns. Other building codes established the fire-resistance requirements for the primary structural frame using the term "primary structural frame."


The current wording in this section states an enclosure that matches the building's fire rating. A building itself does not have a fire rating although components within the building do. By incorporating this proposed change it is easy to determine what specific rating the code is referring to. This proposed change provides clarification and makes it easier to understand what one is trying to accomplish. Additionally, as backbone cables achieve rated listings, it makes it clear that the cable is not required to be within a rated enclosure.


Submitter Full Name: Alan Perdue

Organization: Safer Buildings Coalition

Affiliation: Safer Buildings Coalition

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17.6.2.3

Backbone cables

shall be routed through an enclosure that matches the building’s fire rating.

and components shall be protected in accordance with 9.6.2.3.1 or 9.6.2.3.2.

9.6.2.3.1 Backbone cables and components installed in buildings that are fully protected by an automaticsprinkler

system in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems , shall be installedin metal

raceways.

9.6.2.3.2 Backbone cables and components installed in non-sprinklered buildings or buildings that arepartially

protected by a sprinkler system shall be installed in metal raceways and shall be installed in a minimum2-hour fire

rated enclosure or protected area.

9.6.2.3.3 Performance alternatives approved by the authority having jurisdiction shall be permitted.










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17.6.2.3

Backbone cables Where nackbone cables are not of a rating type matching the building's fire rating,backbone cables shall be routed through an enclosure that matches the building’s fire rating.


The requirement for installing backbone cable inside a rated enclosure seems to preclude the invention of fire rated coaxial cable or alternative methods of signal distribution as an example TowerIQ has a product that utilizes fire alarm cable for its backbone distribution.




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9.6.2.5 All penetrations of two-way radio communications enhancement systems cables and racewaysthrough

rated walls, floors, ceilings, and barriers shall be firestopped in accordance with NFPA 70, NationalElectrical

Code .
















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New Paragraph

9.6.2.4.1 Any components or connecting.equipment to the back bone communication pathway such as local

directional antennas, modules that uniquely identify the module and connections pathway to the back bone

link shall be rated to the same fire resistance value as the back bone comminicating pathway. Failure of the

connecting appurtenances to the back bone pathway shall not impair the remaining elements of thesystem

t operate normally..





Directional antenna located on a given floor connecting to the back bone communicating pathways, usually have aa small circuit board module enclosure with a communication cable link secured to the back bone communicatingpathway. Failure of one of these units should not impair the remainder f the system.




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17.6.2.4

The connection between the backbone cable and the antenna cables shall be made within an enclosurethat matches the building’s fire rating, and passage protected as required to meet Pathway SurvivabilityLevel 2 requirements, as defined in NFPA 72.

17.6.2.5 The passage of the antenna distribution cable in and out of the enclosure shall be fire-stopped asrequired by the applicable building code .


Requiring something to be rated as required for the building is not a clear requirement. Structural fire resistance ratings vary based upon the structural element and are not consistent within a building. Whereas these systems are used during an emergency event, the cables need to be able to survive a fire exposure.

Pathway Survivability Level 2 requires two-hour protection. It should be noted that there is a First Revision to introduce a pathway survivability level in NFPA 72 that only requires one-hour protection. This level of protection may be appropriate in buildings having a one-hour fire resistance rating.


Submitter Full Name: William Koffel

Organization: Koffel Associates, Inc.

Affiliation: 3M Company

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17.6.2.4

The connection between the backbone cable and the antenna cables shall be made within an enclosurethat matches the building’s fire rating, identified in Section 16.6.2.3 and passage of the antennadistribution cable in and out of the enclosure shall be fire-stopped to an equivelant rating of the enclosure .Connection of the antenna distribution cable to backbone cables listed with a fire-resistance rating shall notbe required to be made within an enclosure.


This proposed change correlates the changes proposed in Public Input #247 related to section 17.6.2.3. Additionally, it provides clarification on the connection between the backbone and the antenna distribution cables.





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17.6.2.4

The connection between the backbone cable and the antenna cables shall be made within an enclosurethat matches the building’s fire rating, and passage of the antenna distribution cable in and out of theenclosure shall be fire-stoppedAntenna cables shall be protected in accordance with 9.6.2.4.1 through 9.6.2.4.3.

9.6.2.4.1 Connections between backbone cables and antenna distribution cables shall be made in a minimum 2-hour

fire rated enclosure or protected area.

9.6.2.4.2 Antenna distribution cables shall be permitted to be installed in raceways.

9.6.2.4.3 Radiating antenna cables shall not be installed in metal raceways.”

9.6.2.4.4 Performance alternatives approved by the authority having jurisdiction shall be permitted .
















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17.6.3 System Design

17.6.3.1 Battery Enclosures .

Battery systems used for the emergency power source shall be contained in a NEMA 3R or higher-ratedcabinet.

17.6.3.1.1 All repeater, transmitter, receiver, signal booster components, optical-to-RF and RF-to-opticalconverters, external filters, batteries, and battery system components shall be contained in a NEMA4- orNEMA4X-type enclosure(s).

17.6.3.1.2 Batteries that require venting shall be stored in NEMA3R-type enclosures.

17.6.3.2 Oscillation Detection and Control.

Bi-directional amplifiers (BDAs) used in emergency responder radio coverage systems shall have oscillationdetection and control circuitry.

17.6.3.4 Mounting of the Donor Antenna(s).

17 .6.3.4.1 To maintain proper alignment with the system designed donor site, donor antennas shall meetone of the following:

(1) Antennas shall be permanently affixed on the building.

(2) Where approved, antennas shall be mounted on a movable sled with a visible sign stating

“Movement or repositioning of this antenna is prohibited without approval from the AHJ.”

17.6.3.4.2. If a donor antenna exists, isolation shall be maintained between the donor antenna and allinside antennas to a minimum of 20 dB above system gain.

17.6.3.4.3 The antenna installation shall also be in accordance with the applicable requirements of thebuilding code for weather protection of the building envelope.

17.6.3.5 Radio Communication Antenna Density.

17.6.3.5.1* In-building two-way emergency responder communication enhancement systems shall beengineered to minimize the near-far effect.

A.17.6.3.5.1 Near-far problem arises when a passive distributed antenna system (DAS) is not designedcorrectly and is caused when a transmission from a portable radio that is really close (near) to a DASantenna and it overpowers the uplink amplifier. When this occurs the near portable radio uses up theavailable gain of the bi-directional amplifier (BDA) so that another transmission that is happening at thesame time on a different frequency from a radio that is further away from a DAS antenna (far radio) wouldnot be amplified as much. The near-far problem can be an issue with an improperly design class Achannelized or Cass B broadband BDAs.

17.6.3.5.2 In-building two-way emergency responder communication enhancement system designs shall


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include sufficient antenna density to address reduced gain conditions.

17.6.3.6 Where an in-building two-way emergency responder communication enhancement system isrequired and such system, components, or equipment has a negative impact on the normal operations ofthe facility at which it is installed, the AHJ shall have the authority to accept an automatically activatedresponder system.


This public input adds the design, installation, inspection, maintenance and performance requirements that were recently approved by the NFPA 1 Technical Committee as 2nd draft for inclusion in NFPA 1225 for consistency. These requirements also harmonize with requirements in the International Fire Code (IFC) that references NFPA 1221 for the design and installation of in-building Two-way Emergency Responder Communication Enhancement Systems.










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17.6.3* Lightning Protection.

Systems shall have lightning protection that complies with NFPA 780.

Lightning Protection and Grounding

Where a donor antenna system is used, the donor antenna coaxial cable(s) shall be protected by antennadischarge units in accordance with Article 810.6 of the NEC. The antenna discharge units shall be listed toUL497E.

The antenna, antenna mast and antenna discharge unit(s) shall be grounded in accordance with Article810.21 of the NEC. Grounding of antenna discharge unit(s) shall be as close as practical to the point ofentrance point to the building.


Referencing NFPA780 is too broad of a requirement, and has been interpreted by some as to require a building lightning protection system is one is not installed. The NEC already addresses the requirements for surge protection and grounding. While other industry standards exist such as R56, the NEC requirements should be adequate.




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17.6.5.1

No amplification system capable of operating on frequencies or causing interference to frequenciesassigned to the jurisdiction by the licensing authority of the country of jurisdiction shall be installed withoutprior coordination and approval of the AHJ and the frequency license holder(s) .


Installing a public safety in-building communications enhancement system is vital to public safety responders. Equally important is maintaining the overall communications system for the entire community. If the frequency license holder(s) are not included in the process of review and installation as required by the governing radio licensing authority an entire public safety radio system can be negatively impacted. Therefore, it is necessary to obtain the frequency license holders written permission to retransmit frequencies as a part of an in-building communications enhancement system. Additionally, this is a mandatory requirement under FCC Part 90.219.





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17.6.5.1

No amplification system capable of operating on frequencies or causing interference to frequenciesassigned to the jurisdiction by the licensing authority of the country of jurisdiction shall be installed withoutprior coordination and approval of the AHJ. No amplification system capable of operating on frequenciesor causing interference to frequencies assigned to the jurisdiction by the licensing authority of the countryof jurisdiction shall be operated, for any reason, including testing, without the express written consent ofthe FCC licensee.


The FCC licensee is the only authority that can grant permission to re-transmit its licensed frequency channels.




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17.6.5.2

The building manager/owner owner or his/her authorized agent shall suspend and correct equipmentinstallations that degrade the performance of the public safety radio system or public safety radioenhancement system.


The term "manager/owner" is limiting to those individuals who may be responsible for suspending and/or correcting equipment installations that degrade the performance of the public safety radio system or enhancement system. By including the term "authorized agent" it could be anybody the owner designates to carry out the function. For example, it could be a third party contractor responsible for monitoring and maintaining the system.





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17.6.5.2

The building manager/owner and/or its contractors shall immediately suspend and correct equipmentinstallations that degrade the performance of the public safety radio system or public safety radioenhancement system, whether such degradation is observed by the building manager/owner and/or itscontractors, or reported by the FCC licensee .


The installing contractor is also responsible for shutting down equipment if degradation to the public safety radio system is observed. The immediacy of this requirement to stop interfering needs to be overtly stated.




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17.6.6.1

Plans, including but not limited to: specifications, uplink budget and other information required by the AHJor frequency license holder(s) shall be submitted for approval prior to installation.


This proposal is intended to clarify the information needed to review in-building public safety communications enhancement systems prior to installation.





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17.6.6.1

Plans shall be submitted for approval prior to installation. Request to retransmit the public safety licensee's

frequencies in accordance with FCC Part 90.219.(b)(1)(i) shall be submi ed with the plans for express wri en

approval. Opera on for any reason is not permi ed without this approval.


It needs to be made clear that approval of emergency radio system plans is not authorization to operate.




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17.6.6.2

At the conclusion of successful acceptance testing, a renewable permit shall be issued for the public safetyradio enhancement system where required by the AHJ. A renewable re-transmission permit shall beissued by the FCC licensee for the re-transmission of the licensees frequencies.


Express permission to re-transmit the FCC licensee's is required by Part 90.219 of the FCC rules, as well as reasonable control by the FCC licensee of the re-transmissions.




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17.6.7.1

Radio coverage shall be provided throughout the entire building as a percentage of floor area as specifiedin 17.6.7.3 and 17.6.7.4 . . Small areas that that cannot be occupied normally, such as small closets, andnormally unoccupiable spaces, such as elevator shafts, do not require coverage unless specificallyrequired by the AJH.


It should not be permissible for any part of a building not to have adequate radio coverage, unless the space is inaccessible by public safety personnel or that space is exempted by the AHJ.




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17.6.7.2 Time Delay Interference (TDI)

The radio enhancement system shall adhere to the maximum acceptable propagation delay standardprovided by the AHJ not cause unacceptable time delay interference to the public safety radio system,either inside the building or outside the building. The amount of time delay interference that may occur is afunction of the differential delay between the signals transmitted by the donor repeater and the radioenhancement system, and the relative magnitude of these two signals. The AHJ may specify themaximum signal propagation delay of public radio system components such as BDAs, and/or the delayintroduced by transmission lines if needed, as appropriate for the modulation technique used, and/or permitthe use of signal dominance by the radio enhancement system to mitigate TDI .


The requirements that needs to be controlled is Time Delay Interference. There are many ways of controlling this interference including macro signal dominance, and/or differential macro system versus building system delay. This TDI can be caused by components other than BDAs especially in campus environments with long fiber optic cable runs. This TDI can occur both inside and outside the building, both need to be addressed.




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17.6.7.3

Critical areas, including fire command centers, fire pump rooms, exit stairs, exit passageways, elevators,elevator lobbies, standpipe cabinets, sprinkler sectional valve locations, and other areas deemed critical bythe AHJ, shall be provided with 99 percent floor area radio coverage.


Because the current list of critical areas does not state specifically "elevators" there is confusion within the industry and the AHJ community as to the importance of covering elevators. It is important to identify that most elevators have firefighter operation capability and if we are putting firefighters, EMS and law enforcement inside elevators for emergency operations the emergency responders need to maintain mission critical communications. This code change will help clarify coverage requirements in critical areas.





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17.6.7.3

Critical areas, including fire command centers, fire pump rooms, exit stairs, exit passageways, elevatorlobbies, fire service access elevator cars, standpipe cabinets, sprinkler sectional valve locations, and otherareas deemed critical by the AHJ, shall be provided with 99 percent floor area radio coverage.





TWO Fire Service Access Elevators are required in each building over 120 feet per IBC Section 403.6.1. Sincewhere there is a Radio enhancement system installed in the building, Wired Phone-Jacks are no longer providedincluding inside elevator cars. The Fire-Service Access Elevators are an essential and critical tool for firefighting inhigh-rise buildings over 120 feet and therefore it is imperative that firefighters would be able to communicate fromthese cars to the fire command center, to the incident commander and with other firefighters located outside theelevators. This is required to replace the previously required elevator-car hard-wired phone jack which is no longerprovided when a radio enhancement system is installed. I'm aware that AHJs can specifically require this based onthe current language if they decide that FSAEs should be classified as critical areas, but it will greatly help AHJs, ifit will be specified in the code as a critical area.





Submitter Full Name: Sagiv Weiss-Ishai

Organization: San Francisco Fire Department

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17.6.7.3

Critical areas, including fire command centers, fire pump rooms, exit stairs, exit passageways, elevatorlobbies, elevator cars provided with firefighters' in-car emergency operation means, standpipe cabinets,sprinkler sectional valve locations, and other areas deemed critical by the AHJ, shall be provided with99 percent floor area radio coverage.





This is more conservative compared to the previous PI for Fire Service Access Elevators - This PI includes FireService Access Elevators since they must have in-car Phase II means, however, this PI is also intended to providefirefighters with means to communicate from the elevator cars even if the elevators are not classified as "FireService Access Elevators". Many passenger elevators in low-rise buildings (up to 75 feet high or 9 stories) areprovided with "Elevator Phase II In-Car Emergency Operation means" as required by the ASME A17.1 code. Thesecars are to be potentially used by firefighters to fight fires and rescue occupants in Phase II in-car operation -therefore, it is important to provide them means to communicate from within the cars while they are using theelevators in Phase II in-car emergency operation. If this will be added to this section as a specified critical area, theradio enhancement systems will have to be designed accordingly, otherwise, this is typically is not done and thereis no available radio communication for firefighters from within the elevator cars.This is the definition from ASME A17.1 (2016 Edition) for Phase II operation:Phase II Emergency In-Car Operation: the operation of an elevator by firefighters where the elevator is under theircontrol.Two sides notes related to this proposal:1) As a FPE working for SFFD - I proposed to add this requirement in our local SFFD administrative bulletin AB #2.01 Addendum G for "ERRCS" and it was accepted. Since March of 2018 when this bulletin was in effect, theSFFD is enforcing this requirement without any negative impact. We believe that this specific SFFD requirementincreases the life-safety level of our firefighters using elevators in Phase II In-Car emergency operation.2) As an AHJ member on both the ASME A17.1 Emergency Operation and Hoistways committees, we are in theprocess (for the next 2022 edition of ASME a17.1) of allowing leaky coaxial cables to be installed inside elevatorhoistways to provide in-car radio communication for firefighters to replace the no-longer-required elevator carsphone jacks.



Public Input No. 45-NFPA 1225-2019 [Section No. 17.6.7.3] Radio communication from elevator cars





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17.6.7.3

Critical areas, including fire command centers, fire pump rooms, exit stairs, exit passageways, elevatorlobbies, standpipe cabinets, sprinkler sectional valve locations, and other areas deemed critical by theAHJ, shall be provided with 99 percent floor area radio coverage.


There is no reason for radio coverage of less than 100%.




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17.6.7.4

General building areas shall be provided with 90 percent with 95 percent floor area radio coverage.


This public input proposes to change the general coverage requirement for in-building two-way emergency responder communication enhancement system coverage to 95% from 90%. This requirement provides the appropriate coverage areas to ensure that any first responder is in or very close to the area that will permit sending and receiving emergency radio signals. For l;arge floor areas, 90% coverage could levee large areas of floor space without signal capability and thereby lower first-responder safety. This requirement would also provide consistency with IFC requirements that have been in place since 2012.







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17.6.7.4

General building areas shall be provided with 90 percent 95 percent floor area radio coverage.


changing the requirement from 90 -95% brings the requirement into correlation with IBC section 510.




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17.6.7.4

General building areas shall be provided with 90 percent floor area radio coverage.


There is no reason for less than 100% coverage of a building. The 99% coverage requirement is perhaps meaningless with grid testing unless the critical coverage areas are subdivided and 99% of the subdivisions pass.




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17.6.7.5

Buildings and structures that cannot support the required level of radio coverage shall be equipped with asystem that includes RF-emitting devices that are certified by the radio licensing authority radioenhancement system to achieve the required adequate radio coverage. Bi-directional amplifiers used toas part of a radio enhancement system shall be certified by the FCC or other government authorityresponsible for certifying the radio re-transmission equipment.


If coverage is not adequate, a whole system is needed, not just an RF emitter.




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17.6.7.6

Radio enhancement systems shall be designed to support two portable radios simultaneously transmittingon different talk paths or channels, where the AHJ has required the radio enhancement system to supportmore than one channel or talk path all frequency channels simultaneously on both the downlink and theuplink .


If the public safety radio system is designed to support only two channels, the system may not operate adequately when more than two channels are in operation, especially if all of the system power is allocated to just two channels by the AGC. The system should be capable of supporting all channels simultaneously. If the BDA equipment is capable of allocating all power to a few channels based upon AGC mode, this should never be used in a test/acceptance mode, because it would lead to false results as compared to when the system is fully loaded.




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17.6.8.1.1

A minimum inbound signal strength sufficient to provide usable voice communications, as specified by theAHJ, shall be provided throughout the coverage area

17.6.8* Signal Strength .

17.6.8.1 * Inbound.

and Carrier To Noise Levels.

The downlink/talk-out or uplink talk-in radio coverage must be adequate to provide reliable understandableradio communications for public safety personnel. Depending upon a number of factors, the coveragefrom the existing public safety radio system may be adequate, or may require the installation of a radioenhancement system for the downlink, uplink or both .

17.6.8.1.2

The inbound signal level shall be

* Downlink/Talk-Out

A minimum median downlink signal with a faded carrier to noise plus interference (Cf/(N+I) sufficient toprovide a minimum DAQ of DAQ 3.0 for either analog or digital signals.

17.6.8.2 * Outbound.

17.6.8.2.1

A minimum outbound strength sufficient to provide usable voice communications, as specified by the AHJ,, with an adequate margin for fading, signal blockage, and portable antenna loss, shall be providedthroughout the coverage area, whether the signal is received directly from the public safety radio system,or through a radio enhancement system .

17.6.8.2.2

The outbound signal level shall be

* Uplink/Talk-in

A minimum median uplink signal with a faded carrier to noise plus interference (Cf/(N+I) sufficient toprovide a minimum DAQ of DAQ 3.0 for either analog or digital signals , with an adequate margin forfading, signal blockage, and portable antenna loss, shall be provided at a minimum of one public safetydonor site repeater or one voting receiver from the building coverage area, whether the signal is receiveddirectly from the public safety radio system, or through a radio enhancement system .


1. Signal levels alone cannot ensure that a DAQ of 3.0 can be achieved2. Acceptable signal levels will depend upon the type of modulation, the amount of fading, the amount of portable antenna loss including body blockage in accordance with TSB-88-1.3. The C/(N+I) determines performance. The building noise environment, the repeater uplink noise level, and the uplink and downlink TDI in the presence of radio enhancement systems all need to be considered.4. The median signal level in the presence of fading, is the signal level used by TSB-88-1 for all Carrier to Noise requirements.5. Different jurisdictions will have different requirements for signal margin, body blockage based upon wearer radio location, etc.6. The signal may be achieved either with or without a radio enhancement system. A radio enhancement system is not always required..7. The uplink signal throughout the coverage area is irrelevant, it depends upon the Cf/(N+I) at the donor receiver site.




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Public Input No. 171-NFPA 1225-2019 [ Sections 17.6.8.1.1, 17.6.8.1.2 ]

Sections 17.6.8.1.1, 17.6.8.1.2

17.6.8.1.1

A minimumThe inbound signal strength

sufficient to provide usable voice communicationsshall be a minimum of -95 dBm throughout the coverage area or an equivalent signal-to-interference-plus-noise ratio (SINR) , as specified by the AHJ,

shall be provided throughout the coverage areaapplicable to the technology for either analog or digital signals .

17.6.8.1.2 *

The inbound signal level shall be sufficient to provide a minimum of DAQ 3.0 for either analog or digitalsignals.

A .17.6.8.1.2 The DAQ metric is often used to quantify the quality of audio heard over a radio system.DAQ levels are defined by the following scale: DAQ 1 = Unusable. Speech is present but notunderstandable. DAQ 2 = Speech is understandable with considerable effort. Requires frequent repartitiondue to noise or distortion. DAQ 3 = Speech understandable with slight effort. Requires occasional repetitiondue to noise or distortion. DAQ 3.4 = Speech understandable without repetition. Some noise or distortionpresent. DAQ 4 = Speech easily understandable. Little noise or distortion. DAQ 5 = Perfect. No distortionor noise discernible.









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If a donor antenna exists, isolation shall be maintained between the donor antenna and all inside antennasto a minimum of 20 dB above system gain.

Self-Oscillation

The radio enhancement system design, including the equipment, shall be designed and tested to ensure

that the system does not self-oscillate due to any excessive RF feedback signal. The signal received at

the input to any amplifier received from the output of that same amplifier shall be at least 20 dB below the

amplifier output signal due to the coupling between the service antenna system and the donor antenna

system. Radio enhancement systems shall not be operated for any reason until this requirement has been

verified through on-site testing.


The system requirement is that the radio system not self-oscillate. The standard does not make it clear that the reason for an isolation specification is to ensure there is no self-oscillation.




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17.6.10.3 Mutual Aid Frequencies - Multi-juristictional response to public safety emergencies is commonlyrequired. Adequate radio coverage to/from distant juristictions is frequently not possible due to distancefrom the repeaters system of those juristictions. If deemed necessary by the AHJs, any installed radioenhancement systems shall include a conventional repeater capability for the mutual aid frequencychannels (ICALL/ITAC) for the band that the radio enhancement system was designed, to facilitateinteroperability beween agencies.


Provide a means for interoperability for emergency responders from different jurisdictions.




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17.6.10.1 List of Assigned Frequencies.

The AHJ shall maintain a list of all inbound/outbound frequency pairs, that the radio system enhancementsystem shall support, for distribution to system designers. This shall include both current frequencychannels and changes to the system currently planned. The frequencies of control channels shall beidentified where they exist, to facilitate coverage testing.


The purpose for maintaining this list needs to be identified, and known changes need to be provided to system designers to permit accommodation in the design.




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17.6.10.2* Frequency Changes.

Systems shall be upgradeable to allow for instances where the jurisdiction changes or adds systemfrequencies to maintain radio system coverage as it was originally designed. AHJs shall provideinformation pertaining to all planned changes to the frequency plan.


Facilitate the accommodation of planned changes




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17.6.10.2 * Frequency Changes.

Systems shall be upgradeable to allow for instances where the jurisdiction changes or adds systemfrequencies to maintain radio system coverage as it was originally designed.

1 7 . 6. 10.3. * In-building t wo-way emergency responder communication enhancement systemscapable of operating on frequencies licensed to any public safety agency by the FederalCommunication s Commission ( FCC ) or other radio licensing authority shall not be installed withoutprior coordination and approval of the AHJ and the license frequency holder(s) .

A. 1 7 . 6. 10.3. This requirement is in t en d ed to ensure that system installer is aware of therequirements in FCC Part 90.219 relating to use of emergency radio frequencies under theregulation of the FCC and the FCC radio frequency license issued to the public safety agency .









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17.6.11.1* Component Approval, Certification and Listing .

17.6.11.1.1

RF-emitting devices and cabling used in the installation of the public safety two-way radio communicationsenhancement systems shall be approved by the AHJ.

17.6.11.1.2

All RF-emitting devices shall have the certification of the radio licensing authority of that country and besuitable for public safety use prior to installation.

17.6.11.1.3 All repeaters, transmitters, receivers, signal booster components, remote annunciators andoperational consoles, power supplies and battery charging system components shall be listed and labled inaccordance with UL 2425


This is the one of two Public Inputs that seek to require two-way radio communications enhancement systems to be listed to UL 2524, Standard for In-building 2-Way Emergency Radio Communication Enhancement Systems. This Public Input is requiring two-way radio communications enhancement systems to be listed to UL 2524. The other Public Input is adding UL 2524 to the list of referenced standards.

Requiring two-way radio communications enhancement systems to be listed to UL 2524 will ensure the products used in two-way radio communications enhancement systems have the necessary performance, fire and shock safety requirements specified in this Standard. ANSI/UL 2524 is a new product performance standard that covers the repeaters, transmitters, receivers, signal boosters and battery charging systems used in two-way radio communication enhancement systems.

Conformity assessment procedures provide a means of ensuring the products, or systems produced have the required performance characteristics, and that these characteristics are consistent from product to product, or system to system.





Submitter Full Name: Richard Roberts

Organization: Honeywell Fire Safety

Affiliation: Automatic Fire Alarm Association (AFAA)

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17.6.11.1.1

RF-emitting devices and cabling All components used in the installation of the public safety two-way radiocommunications enhancement systems shall be approved by the AHJ.


The AJH needs to be able to approve all components, not just amplifiers and cables.




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17.6.11.1.2

All RF Bi -emitting devices directional Amplifiers shall have the certification of the radio licensing authorityof that country and be suitable for public safety use prior to installation.


All the devices in the radio enhancement system will be emitters of RF. Either Bi-Directional Amplifiers (Industry term) or signal booster (FCC term) should be used throughout.




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17.6.11.2.1

All repeater, transmitter, receiver, signal booster components, optical-to-RF and RF-to-optical converters,external filters, batteries, and battery system components shall be contained in a NEMA4- or NEMA4X-typeenclosure(s). Enclosure(s) shall be supervised for unauthorized access.


Given the potential consequences from a system failure and the effect it may have on jurisdictional first responder operations, at a minimum any active RF emitting device should be supervised for unauthorized access and component manipulation. Per the typical label:

"WARNING. This is NOT a CONSUMER device. It is designed for Installation by FCC LICENSEES and QUALIFIED INSTALLERS. You MUST have an FCC LICENSE or express consent of an FCC Licensee to operate this device."




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17.6.11.3 Component Requirements.

17.6.11.3.1 The backbone, antenna distribution, radiating, or any fiber-optic cables shall be rated asplenum cables .

17.6.11.3.2 The backbone cables shall be connected to the antenna distribution, radiating, or coppercables using hybrid coupler devices of a value determined by the overall design.

17.6.11.3.3 Backbone cables shall be routed through an enclosure that matches the building’s fire rating.

17.6.11.3.4 The connection between the backbone cable and the antenna cables shall be made within anenclosure that matches the building’s fire rating, and passage of the antenna distribution cable in and out ofthe enclosure shall be fire-stopped.








Public Input No. 167-NFPA 1225-2019 [Sections 17.6.2.1, 17.6.2.2, 17.6.2.3, 17.6.2.4]




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17.6.11.3 RF-Emitting Devices.

RF-emitting devices shall meet the following requirements in addition to any other requirementsdetermined by the AHJ:

(1) RF-emitting devices shall have the certification of the radio licensing authority prior to installation.

(2) All RF-emitting devices shall be compatible with both analog and digital communications, as requiredto be used by the radio licensing authority and the AHJ, simultaneously at the time of installation.


Duplication of requirements in the code.




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17.6.12.1 Primary Power Source.

The primary power source shall be supplied from a permanently connected dedicated branch circuit andcomply with NFPA 72. The primary power source shall be protected from overvoltage in accordance withUL 60950-1.


The dedicated power circuit(s) should not be capable of being accidentally disconnected. Surge protection of AC power supplies is needed.




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(2) An alternative power source of 12 hours at 100 percent system operation capacity as approved by theAHJ. If the alternate power source requires a start-up, such as a backup generator, a minimum 2-hrbattery shall be provided to supply power during the start-up.


There should not be a loss of power during the start-up of a generator used for backup power.




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(2) An alternative power source of 12 hours at 100 percent system operation capacity as approved by theAHJ

(3) The AHJ shall have the option to have a dobule pole double throw switch with indicator lights for echswitch position with provision to connect a standard extension chord or service chord from a firstresponders genertor connected for emergency input to the secondary power source for continuedservice in the event of on site secondary power source has a failure during an on site event.





For emergency secondary power, the first responders shall have the option to provide to a DPDT switch withindication lights so tht a basic emergency generator cn be connected using a standard service chord such as astandard extension chord.




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(11) A summary alarm may be provided to the fire alarm system, when interfacing to an existing FACPwithout adequate spare capacity for all alarms.


The expense of upgrading an entire FACP to provide discreet alarms in an existing system may not be cost effective, and necessary as long as the individual alarms are available at the radio equipment.




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(7) Passive system component failure








NFPA_1221-2019_TIA_by_Sagiv_Weiss-Ishai.-.pdf

San_Francisco_ERRCS_-_Concerns_on_Unsupervised_Components_Real-Life_Example.pdf


It is very important to monitor the integrity of the entire radio enhancement system including all active and passivecomponents as it is required for any other code required 2-way emergency communication system. This wasproposed as a TIA 1435. The technology is available and it will increase the integrity of the system and the lifesafetylevel for emergency respondents.

The 2016 edition of NFPA 1221 is currently adopted by many fire jurisdictions and is adopted by the 2018 IFCChapter 80 as a referenced standard. The NFPA 1221 2019 is NOT yet adopted by the current 2018 IFC as areference standard – it will only be adopted in the 2021 edition of the IFC and it would take a few more yearsbefore it would be applicable for enforcement by fire jurisdictions. Meanwhile and currently, the 2016 edition ofNFPA 1221 is adopted and enforced. The 2016 edition does not specify that only “Active” components must besupervised. Rather, it states in Section 9.6.13.1: “system component failure” as well as “Donor antennamalfunction” and “Active RF emitting device failure” – This means that in addition to the “Donor Antennamalfunction” and “Active RF emitting device failure” it is currently required by this section to monitor for integrity the“ System Component failure” – And the question is: What is a “system component” which is not the donor antennaand is not an RF emitting device ? The answer is : It could be any other system component including Passivesystem components. Since this 2016 edition is the currently adopted code, it must be currently enforced by firejurisdictions and NOT the new 2019 edition. Therefore the “System component failure” including Passivecomponents monitoring for integrity, is currently enforced. In addition to this, there was a specific inquiry sent to the


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NFPA 1221 which was officially answered by Mr. Fash indicating the intent of this section as to not limit anyNational Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPar...49 of 62 10/9/2019, 1:04 PMavailable technology for monitoring and to leave it up to the AHJs to enforce it. (The inquiry and Mr. Fash answerwere attached to the TIA proposal). So the main intent of this TIA is to prevent a great confusion, enforcementissues and inconsistencies between the currently adopted 2016 edition and the NEW non-adopted 2019 edition,when the 2019 edition will be adopted and become effective.. the 2019 edition will change the whole concept ofsystem component failure supervision after many ears of enforcing this concept by many fire jurisdictions… This isthe main issue that this TIA is trying to prevent and the disagree votes do NOT address this concern

9.6.13.1 Fire Alarm System. The system shall include automaticsupervisory signals for malfunctions of the two-way radiocommunications enhancement systems that are annunciated bythe fire alarm system in accordance with NFPA 72,and shallcomply with the following:(1) Monitoring for integrity of the system shall comply withNFPA 72, Chapter 10.(2) System supervisory signals shall include the following:(a) Donor antenna malfunction(b) Active RF emitting device failure(c) Low-battery capacity indication when 70 percent ofthe 12-hour operating capacity has been depleted(d) System component failure2. Regarding the Technical issue of “system component failure” supervision: The intent is to provide the samelevel of monitoring for integrity as required by NFPA 72 for any other 2-WAY ECS listed in NFPA 72 Chapter 24(The ERRCS is one of these systems). It shouldn’t be acceptable to have a lesser degree of integrity for the Radiosystem compared to all other 2-WAY Emergency Communications Systems. All life-safety systems should bemonitored for integrity as a complete system. This monitoring is feasible and currently done and enforced andshould not be changed to a lesser degree when the 2019 edition is adopted. This is the main technical issue thisTIA is addressing.3. While I’m aware that the Passive antenna itself is a simple component that typically does not fail, the intent isto monitor all Passive components as a whole, which means, the coax cables feeding the antennas, theconnectors, couplers, etc. It is common to have tenant improvement and remodel/renovation work in buildingsdone by different trades, If an electrical or mechanical, etc. contractors are performing electrical and mechanicalwork in the building and unintentionally cutting or damaging the coax cables feeding the antennas, if a connectorfails due to corrosion or mechanical damage, if an antenna have mechanical damage and needs replacement, etc.It is essential to know about this failure before the next annual test or before a Fire or Non-Fire Emergency mightoccur and there will not be first responders emergency communication… It is unacceptable to have an unknownLife-Safety system failure for a long time with no awareness for this dangerous situation..4. The 2016 and 2019 edition of NFPA 1221 require the monitoring for integrity of the donor antenna (Donorantenna malfunction) – This is also a passive component ? Why the donor antenna is required to be monitored forintegrity and the other passive antennas are not ? Why - If the donor antenna or the coax cable feeding it isdamaged/ cut, etc. there is a requirement for a trouble signal but not same level of supervision required for the floorantennas ? If either the donor antenna or floor antennas are disconnected or damaged – this will jeopardize theintegrity of the life safety radio system, this must be detected and fixed. There shouldn’t be a different between thedonor antenna and the floor antennas requirement to be monitored for integrity.5. Lastly, as a code enforcer, a Fire Protection Engineer and an NFPA 72 TC member – I am aware of differenttechnologies available to achieve the required “system components failure” supervision. I’m learning about NEWtechnologies every day by different companies. These technologies are feasible, available and not that expensive.(The cost should not be the main concern for increasing safety!). There is not one proprietary solution for thismonitoring. There are different companies that have already developed different solutions for achieving this goalas currently required and enforced. The code should help the AHJs to enforce it as they are interpreting it, asexplained by Mr. Fash on his response to the inquiry – make the code require a higher safety level, don’t limit thetechnology how to do it, and leave it up to the AHJs how to enforce it.

I urge the committee members to look at the big picture and accept this TIA. This will prevent inconsistencies,prevent enforcement issues and most importantly, will increase the integrity and reliability of this very importantLife-Safety system and ultimately, it will increase the level of safety for first respondents.




Public Input No. 48-NFPA 1225-2019 [Section No. 17.6.13.2.1]


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(10) The communications link between the fire alarm system and the two-way radio communicationsenhancement system shall be monitored for integrity. This communications link shall be provided withthe same pathway survivability as the backbone cable system.


If this status link is compromised by fire, public safety personnel will have no way to determine radio system status.




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17.6.13.2.1

A dedicated Fire Alarm Suystem annunciator or approved equivelent shall be provided within the firecommand center to annunciate the status of all RF-emitting devices and active system componentlocations. This device shall provide visual and labeled indications of the following for each systemcomponent and RF-emitting device:

(1) Normal ac power








The idea of a separate annunciation from the building fire alarm one is meant so that the communications system signals would not be lost in the potentially large amount of other fire alarm signals. This requirement was never meant to require a dedicated Annunciator from the amplifier manufacturer.




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17.6.13.2.1

A dedicated annunciator shall be provided within the fire command center to annunciate the status of allRF-emitting devices and active system component locations. This device shall provide visual and labeledindications of the following for each system component and RF-emitting device:

(1) Normal ac power







(8) Passive system component malfunction




San_Francisco_ERRCS_-_Concerns_on_Unsupervised_Components_Real-Life_Example.pdf

real case for passive component malfunction

NFPA_1221-2019_TIA_by_Sagiv_Weiss-Ishai.-.pdf TIA 1435


It should be required to monitor the entire system integrity including passive components such as antenna feeder cables and floor antennas. This could be a separate monitoring point. It does no have to be a specific (addressable) monitoring but could combine all the passive components failure into one monitoring point.



Public Input No. 47-NFPA 1225-2019 [Section No. 17.6.13.1] same issue





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Public Input No. 51-NFPA 1225-2019 [ New Section after 17.6.13.2.2 ]

9.6.13.2.3

When required by the AHJ, the dedicated annunicator shall be provided with the cabilty to display real time

location of firefighters within the building on a per floor basis. The real time firefighters location shall be

displayed on the dedicated annunciator upon active use (push to talk/ PTT) of the portable radio by the

firefighters including the specific use of the emergency/panic button located on the portable radio or when

mandown alarm signal has been initiated upon firefighter(s) incapacitation.



Public_Input_No._70-NFPA_1221-2019_New_Section_after_9.6.13.2.2_.pdf

Doc1.1560764020236-1.pdfExample of existing system for real time firefighters location monitoring


It is highly important for the incident commander to monitor the locations in real-time of the firefighters who arefighting fires and rescuing occupants within the building from the fire command center. This feature will highlyimprove the management and control of firefighting resources during a fire emergencies. This feature will alsoprovide specific location for firefighters who are incapacitated and are unable to use their portable radios. It willincrease the life safety level for responding firefighters and will increase the capability of the system to providebetter control and management of the emergency event by the incident commander. This real-time monitoringtechnology is already existing and available and even implemented in NYC. If required by fire authorities, this realtimemonitoring technology should be a required feature of the radio enhancement system monitoring.



Public Input No. 52-NFPA 1225-2019 [New Section after 17.6.13.2.2]




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Public Input No. 52-NFPA 1225-2019 [ New Section after 17.6.13.2.2 ]

9.6.13.2.3

The dedicated annunicator shall be permited to be provided with the cabilty to display real time location offirefighters within the building on a per floor basis. The real time firefighters location shall be displayed onthe dedicated annunciator upon active use (push to talk/ PTT) of the portable radio by the firefightersincluding the specific use of the emergency/panic button located on the portable radio or when mandownalarm signal has been initiated upon firefighter(s) incapacitation.



Public_Input_No._71-NFPA_1221-2019_New_Section_after_9.6.13.2.2_.pdf

Doc1.1560764020236-1.pdfexample of existing real-time firefighters monitoring location system


Same rational as the related PI # 70 but instead of having a mandatory language, this PI proposes to have a permissive language and have this feature as a non-required addition to radio enhancement systems.



Public Input No. 51-NFPA 1225-2019 [New Section after17.6.13.2.2]

Same issue but with permissivelanguage




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17.6.14.1

The AHJ shall maintain a document of technical information specific to its requirements , and provide thisinformation to system designers, sufficient to develop a complete radio enhancement system design .


The purpose and need for completeness of this technical documentation is not apparent from the current code.




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17.6.14.3


(1) Frequencies required for the in-building enhancement system and the point of contact for thefrequencies license holder(s).

(2) Location and effective radiated power (ERP) of radio sites used by the public safety radioenhancement system


(4) List of specifically approved system components necessary for system design & operation on thepublic safety communications system



Installing a public safety in-building communications enhancement system is vital to public safety responders. Equally important is maintaining the overall communications system for the entire community. If the frequency license holder(s) are not included in the process of review and installation as required by the governing radio licensing authority an entire public safety radio system can be negatively impacted. Therefore, it is necessary to identify very early in the process who that license holder contact is and by placing that requirement in the technical information documents it will limit the opportunity to have it overlooked.Additionally, in item #4 where it states " List of specifically approved system components" there is confusion in the industry and AHJ community as to what this means. There are some in the AHJ community that are believe this language allows them to require a specific brand, make or model of Bi-directional amplifier or Distributed Antenna System within the building. Adding the phrase "necessary for system design & operation on the public safety communications system" is intended to clarify the requirement.





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17.6.14.3


(1) Frequencies required for the in-building enhancement systemLocation and

(2) Identification of control channels

(3) Modulation Technique employed

(4) Relative power between control and traffic channels

(5) Location, effective radiated power (ERP), receive antenna heights, gains and directivity, noise floor, ofradio sites used by the public safety radio enhancement system all donor radio sites, both RFrepeaters and voting receivers.


(7) List of specifically approved system components



All channels are needed for system sizing, system bandwidth, BDA channel configuration etc.Repeater locations, design details, and voting receivers are needed for donor link design.Differences in power levels between control channels and traffic channels are needed because the control channels are the only channels normally used for RF testing and setup.




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18.1 General.

18.1.1*

Computer-aided dispatching (CAD) systems, when required by the AHJ, shall conform to the items outlinedin this chapter. This chapter & all related sub-sections should contain new verbiage which addresses Tier1, Tier 2, Tier 3, etc. CAD Systems whether by position size, call volume size or related criterion as tofunctionality and/or related systems (i.e,. mapping, MDC's, etc.). Additionally, this chapter & all relatedsub-sections should contain new verbiage related to the emergence of 'cloud' based CAD systems. I.e.,having redundant and diverse ISP providers and applications; redundant data centers for continuity ofoperations; expansion of secondary dispatch method section to include cloud-based scenarios; third partyapplications may not degrade nor interfere with core dispatching services, etc.

18.1.2*

Where a CAD system is used for emergency dispatch service operations, and an enhanced 9-1-1emergency number telephone system is in use, the CAD system shall contain all hardware and softwarecomponents necessary for interface with the 9-1-1 system.

18.1.2.1*

The CAD interface shall accept a transfer of 9-1-1 emergency call data from the customer premiseequipment (CPE) to the CAD system.

18.1.2.2

The CAD system shall be capable of populating a call-for-service data entry form with the 9-1-1 dataprovided by the CPE.


There is a new emergence of type of CAD system which relies on IP-based networks, i.e., cloud-based CAD's. The current chapter does not address these types of systems which are inherently different from the classic client-based CAD systems, situated locally within the Emergency Communications Center (ECC). There is also need to identify and define the various Tier levels for CAD systems to show that certain sized (number of positions and/or call volume) would require a certain tier-level CAD to support such number of positions/call volume).


Submitter Full Name: Don Wise

Organization: DC Wise LLC

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18.12 Integrated Mapping Interface.

18.12.1*

The CAD system shall have the ability to interface with a map display system. This section and relatedsub-sections should be expanded upon to include that all map atttributes are passed to and stored in theCAD database; and, a secondary method or other method of dispatch recommendation must be providedin the event of the loss of the mapping interface.

18.12.2

The map display system interface shall have the ability to accept spatial positioning data for calls for serviceand units from CAD.

18.12.3

The map display system interface shall have the ability to position an indicator on the map based on theprovided spatial information.


The current section for Integrated Mapping needs clarification that the mapping solution/product must provide all attributes to the CAD database. Some vendors do not provide this data, therefore workarounds are needed by the Emergency Communications Center (ECC) to match the CAD response data with e.g., a particular zone/district or other geospatial data. Additionally, the section needs to be supported with new language that affirms, in the event of loss of the integrated map which is providing the dispatch recommendation process, then the CAD shall support a secondary or tertiary method of unit dispatch recommendation.


Submitter Full Name: Don Wise

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New 13.3.9 Emergency equipment and supplies

Emergency equipment and supplies including Air packs, Flashlights and medical equiopment shall be testedat least annually or in accordance with the applicable NFPA code or standards.


Communications centers may have a vast amount of equipment that is not covered by any list. This section is an attempt to recognize that there may not be a one size fits all solution but to [provide guidance that all equipment shall be inspected or tested or at least check on at least annually.




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19.3.9.1.3

All systems initial acceptance testing documentation shall include a listing of the following:

(1) All system equipment utilized

(2) Manufacturer’s data sheets

(3) Installation, testing, and maintenance documentation

(4) As-built drawings showing all equipment locationsWritten documentation acceptable to the AHJ of the initial system testing, including the DAQ measured

(5) as-built system design documentation

(6) System isolation test results

(7) Off-Air measured signal levels from the donor antenna

(8) Measured RF signal levels (and DAQ if measured) at all locations in the building or areas covered bythe installed radio enhancement system

(9) Secondary power calculations

(10) List of assigned frequencies The settings of all frequency channels or bands/sub-bands, channel/bandgains, and filter bandwidths, AGC modes (all configurable parameters) used during the installation andtesting


Documentation of the system design should have been provided for approval before the system was installed. At system acceptance, as-built documentation should be provided, as well as the test results from the installation testing performed by the contractor.




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19.3.9.2.1

All systems that are connected to fire alarm systems that are not monitored for alarm, supervisory, andtrouble conditions off site as defined by NFPA 72 shall be visually inspected weekly for the followingconditions:

(1) Normal ac power



(4) Low battery capacity





(9) Loss of communication with the fire alarm control panel





Same issue in related PIs








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19.3.9.2.2

All systems that are connected to fire alarm systems that are monitored for alarm, supervisory, and troubleconditions off site as defined by NFPA 72 shall be visually inspected semiannually for the followingconditions:

(1) Normal ac power



(4) Low battery capacity





(9) Loss of communication with the fire alarm control panel

(10) Signs of physical damage to components that could affect proper system operation




NFPA_1221-2019_TIA_by_Sagiv_Weiss-Ishai.-.pdf TIA 1435


Same issue in related PIs







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19.3.9.2.

3 Periodic

3 Periodic Testing of Systems.

19.3.9.2.3.1

All

Radio enhancement systems shall be

operationally

tested

at least annually to confirm system operation during normal operations.

19.3.9.2.3.2

At least every five years systems shall be quantitatively tested to ensure that the system still provides therequired DAQ values in accordance with Section 17.6 .

19.3.9.2.3.3

The five-year test shall also confirm that there has been no deviation of coverage more than 5 percent fromthe initial installation documentation

periodically to ensure that the system will be operational when needed. This testing shall beaccomplished through automatic or manually on a 24/7 basis, and failures communicated to the AHJwhenever they are observed, so that they will be aware of coverage deficiencies, should they need torespond to that location. Deficiences shall be corrected within 48 hours or as established by the AHJ,failure to correct deficiencies on time shall be reported to the AHJ. The AHJ shall be notified when thedeficiences have been correct to arrange for restesting, if deemed necessary by the AHJ .


Annual testing is too infrequent to determine if a radio enhancement system is not working. Five year test is absurd.




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Public Input No. 140-NFPA 1225-2019 [ Section No. 19.3.9.2.3.1 ]

19.3.9.2.3.1

All systems shall be operationally tested at least annually to confirm system operation during normaloperations.


Systems need to be tested, repaired, and revised documentation issued annually, if not sooner.




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19.3.9.2.3.1

All systems shall be operationally tested at least annually to confirm system operation during normaloperations. Operational test shall include at least one quantitative test in each of the systems antennacoverage areas to ensure continuity of the system.


Waiting 5 years to perform any type of quantitative test limits the ability to evaluate the capability of system performance. This proposed change provides a bare minimum for quantitative testing on an annual basis with a complete test at the 5 year test.





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19.3.9.2.3.2

At least every five years systems shall be quantitatively tested to ensure that the system still provides therequired DAQ values in accordance with Section 17.6 .






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19.3.9.2.3.3

The five-year test shall also confirm that there has been no deviation of coverage more than 5 percent fromthe initial installation documentation.






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19.3.9.2.4

Deviation of more than 5 percent shall result in additional evaluations to determine if any systemmodifications are required to bring the system into conformance with the coverage required inSection 17.6 .






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19.3.9.2.5

The five-year test shall confirm that there have been no changes in the frequencies utilized for the properoperation of the system.






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19.3.9.2.6

The AHJ can require additional testing if the system fails to operate during normal operations atfrequencies shorter than five years or if radio system conditions change.






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19.4.1

Emergency and standby power systems serving the emergency services communications center shall betested in accordance with NFPA 110.


Statement added to clarify the location at which the testing of emergency and standby power systems apply.





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Public Input No. 145-NFPA 1225-2019 [ Sections 19.4.3, 19.4.4 ]

Sections 19.4.3, 19.4.4

19.4.3

To maximize battery life, the battery voltage for lead acid cells The battery voltage during operation,including charge, discharge and float, shall be maintained within the limits specified in Table 19.4.3 .

Table 19.4.3 Battery Maintenance Voltage

Float Voltage High-Gravity Battery (Lead Calcium) Low-Gravity Battery (LeadAntimony) Maximum 2.25 V/cell 2.17 V/cell Minimum 2.20 V/cell 2.13 V/cell High-rate voltage 2.33 V/cell —

Note: High- and low-gravity voltages are +0.07 V and –0.03 V, respectively.

19.4.4

To maximize battery life, the following battery-charging voltages shall be used:

(1) Float voltage: 1.42 V/cell ± 0.01 V

(2) High-rate voltage: 1.58 V/cell + 0.07 V – 0.00 V

recommended by the battery manufacturer.


The information provided is very incomplete. There are other sub-chemistries of lead acid besides lead-calcium and lead-antimony, and there are other chemistries such as nickel-cadmium which can be used for emergency and standby power. It would be safer to indicate battery charge, discharge and float voltages should be maintained as recommended by the battery manufacturer. The current information for lead-calcium and lead-antimony would be valuable in the annex.





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Public Input No. 128-NFPA 1225-2019 [ Section No. 20.3 [Excluding any Sub-Sections] ]

After completion of acceptance tests that have been approved by the AHJ, the following shall be provided:

(1) A set of reproducible, as-built installation drawings

(2) Operation and maintenance manuals

(3) Written sequence of operation

(4) Results of all operational tests and values at the time of installation

(5) A record of software licenses, software versions and patches utilized within the equipment.


Subsequent section addresses maintenance of ongoing software records and patches. It would be best to have a baseline of software installed at the time of commissioning included with the acceptance test records.





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Public Input No. 193-NFPA 1225-2019 [ Chapter 21 ]

Chapter 21 ICT Security (formerly Chapter 13 of 1221)

Chapter 21 (formerly 13) needs additional code language to cover: minimum required backup standards;training on phishing attacks for all comm center employees; ICT plan to ban the use of mission criticalcomputers for personal use including visiting unauthorized sites and use of thumb drives on comm centerequipment; protection of data to include medical HIPAA information; ICT plan to deal with images and textmessages that might be sent to the comm center but have viruses; ICT plan to have a password sectiondealing with expiration times, minimum complexity, and approved types of 2 factor authentication; ICT planto mandate use of firewalls, virus protection software .

21. 1* Information Communication Technology (ICT) Security Plan.

Communications centers shall develop, implement, and utilize a comprehensive defense in depth processand plan to ensure total data security. The defense in depth approach shall encompass people, technology,and operations and shall provide a framework for safeguarding the vital mission of public safetycommunications centers, including the CAD systems and IP-based NG9-1-1 systems, and the public safetywireless networks used by first responders, including any IP-enabled wireless devices, whether used onpublic safety or public wireless carrier networks.

21.1.1

The plan shall include the items required by 21.1.2 through 21.1.12.

21.1.2

The plan shall include a policy statement from the AHJ detailing the requirements and goals of the plan.

21.1.3*

The plan shall require the assignment of responsibilities for the performance of security functions.

21.1.4*

The plan shall specify training and education requirements for employees and shall include a continuingeducation plan component.

21.1.5*

The communications center shall implement control provisions for access to physical premises, access toradio subscriber units into the radio system, and personnel access to various portions of the networks andcomputers.

21.1.6*

The communications center shall implement network security provisions to prevent unauthorized personsfrom gaining access to the public safety IP network, the public safety phone network, the land mobile radionetwork, and any other networks that operate within or under the control of the communications center thatare required for the receipt or processing of events and to prevent unauthorized use of public safetyhandheld IP-enabled devices used on either a public safety network or a public wireless carrier network.

21.1.7*

The communications center shall implement computer security provisions to prevent attacks on the center’scomputers and servers.

21.1.8*

The communications center shall implement software patch management provisions to ensure that allsoftware is maintained with all updates released and recommended by the system manufacturer to facilitateimproved security and in accordance with the AHJ’s patch management policy.

21.1.9*

The AHJ shall implement data disaster recovery procedures to ensure rapid recovery of databases,servers, and similar equipment used in the communications center, in the public safety wireless network,and for local storage of important information.

21.1.10*

The communications center shall implement logging and auditing provisions to allow for the investigation ofsecurity or operational problems.


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21.1.11*

The AHJ shall implement a vulnerability management process to assess periodically the ability of the publicsafety communications systems, including communications centers, wireless networks, and wired ITnetworks.

21.1.12*

The communications center shall implement environmental and physical security provisions to ensure that itcan monitor various physical aspects of the public safety communications system at all locations, such asphysical entry, fire or smoke, power supply performance, base radio performance, and other parameters asjudged necessary by the AHJ.

21.2* Testing Security.

The plan shall include methods and procedures, including schedules, for testing of the system for securitybreaches or failures, with the frequency of testing to be determined by the AHJ.

21.3 Testing Records.

Testing records of the plan shall be maintained in accordance with Section 20.7.

21.4 Cyber Security Measures.

New systems or upgrades to existing systems shall be designed and implemented using a “security-by-design” process to incorporate cyber security measures as part of the system.


Many parts of chapter 21 need updating or review since the last edition.


Submitter Full Name: John Facella

Organization: Panther Pines Consulting, Llc

Affiliation: 1221/1225 TC

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Public Input No. 186-NFPA 1225-2019 [ Section No. 22.1 [Excluding any Sub-Sections] ]

Public alerting systems (PASs) shall meet the requirements specified in this chapter.

I think this paragraph or a newly added section should be included to denote what this chapter is meant tospecify versus what is already captured in NFPA 72. There is overlap, for sure, but NFPA 72 certainly hasmuch more detail pertaining to alarm notification systems, primarily meant for in-building use, as I see it. This chapter in NFPA 1225 should focus more on Reverse 911 systems and outdoor mass notificationsystems, such as tornado, hurricane or other types of mass notification systems as contrasted to thesystems NFPA 72 was designed to address. I think a paragraph here stating what this chapter covers anda reference to NFPA 72 for other types of systems is appropriate.

Additionally, from Larry Shudak, Section 14.4 appears to identify various emergency communicationsystems with no requirements. NFPA 72, chapter 24 address similar systems. Add a reference to NFPA 72for the wide area mass notification systems, including distributed mass notification systems. UL 2572,Mass Notification Systems aligns with NFPA72 and includes requirements for the various modality types ofa distributed mass notification system included in 14.4.1.


This chapter in NFPA 1225 needs to delineate on what it is specifying/defining versus what is defined in NFPA 72. Otherwise, consultants, end-users, administrators, manufacturers, etc. are not clear on which standard applies to what. I think NFPA 72 should be for in-building systems and for mass-notification systems when they are integrated with in-building systems. This chapter in 1225 should pertain to outdoor notification systems and reverse 911 systems when they stand-alone and are not tied to an in-building mass notification system.




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All PASs shall provide for the ability to operate in the event of a localized or widespread powerouttage for a period of time as determined by the AHJ. (From Tony Locatelli)


After experiencing widespread, long-term power outages in California in the midst of the wildfires burning there, it seems appropriate that Public Alerting Systems should inherently provide for the ability for some form of backup power for a period of time as required by the AHJ.




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I think a new section should be added that states something to the effect of "Public Alerting Systems usedover wireless networks shall employ some mechanism or procedure to prevent the PAS from being hackedto the point of being prevented from being activated or being activated unintentionally."

We can add to the Annex language that the expectation is that wireless systems are easily hacked if there isno security provisions in place to prevent an unauthorized user from tampering with the wireless systemdesigned to transmit the ADM and stopping it from reaching the PASAA or from capturing the unprotectedADM and retransmitting it to the PASAA at an unauthorized time, causing a false alerting of the PAS.


There have been real-world examples of Public Alerting Systems being hacked and misused as a result of the hacking, which was way too easy to do for systems that rely on analog, unencrypted methods of sending ADMs. In this day and age, mission critical alerting systems should not be prone to being easily hacked by someone with an analog receiver and not much else.




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22.4.1

The following types of systems shall be permitted:

(1) Automated telecommunications dial-out systems delivering recorded voice messages

(2) Automated telecommunications dial-out systems with signals transmitted to a PASAA

(3)

(4) Wireless systems with a PASAA

(5) Paging systems with a PASAA

(6) Siren systems with loudspeakers

(7) Integrated public alert and warning system (IPAWS)

From Raymond Patterson: We should consider adding these other types of systems to the list of permittedsystems:

(8) Integrated private fire alarm / Mass notification system with interface connections (NFPA 72)

(9) Private interior or exterior public address system with interface connections

(10) Private /Public Exterior Billboards or electronic message boards


Other means for sending alerts over Public Alerting Systems exist. The list should be more comprehensive.




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* Radio broadcast systems and tone alert systems using a PASAA


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22.5* Public Alerting System Alerting Appliances (PASAAs).

PASAAs shall be capable of the following:

(1) Receiving an alert data message (ADM) from a PAS

(2) Process, convert and re-transmit the alert data message (ADM) to a system or system of devices foraudible, visual or textual messaging. (From Raymond Patterson)

(3) Providing an audible alert in response to an ADM that meets the audible characteristics of an alarm asdefined in NFPA 72

(4) Providing a visual alert signal in response to an ADM that meets the following requirement (ifequipped) : (From Raymond Patterson)

(5) The signal shall be a flashing light that is red, clear, amber, or blue in color.

(6) Providing a textual alert message in response to an ADM (From Raymond Patterson)

(7) Providing a local trouble signal in response to a low-battery condition that meets the followingconditions:

(8) The trouble signal shall not use lights of the same color used for other purposes.

(9) The trouble signal shall have a battery source of power that can serve as either the primary orsecondary power supply.

(10) Providing a local visual and/or audible trouble alert that is distinctly different from that used with anADM, if the PASAA is capable of detecting loss of service or functions


A little more detail to the capabilities of PASAAs seem appropriate.




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Public Input No. 194-NFPA 1225-2019 [ Chapter A ]

Annex A Explanatory Material

Annex A is not a part of the requirements of this NFPA document but is included for informational purposesonly. This annex contains explanatory material, numbered to correspond with the applicable textparagraphs.


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A.1.3

Any AHJs incorporating NFPA 1061, NFPA 1221 or any combination of the two, can replace thosereferences with chapters and still reference similar content. For example, if an AHJ incorporated the 2018edition of NFPA 1061 (i.e. in accordance with 2018 edition of NFPA 1061), and they wish to update to thelatest information, they can do so by incorporating chapters 4 through 11 of the 2022 edition of NFPA 1225(i.e. in accordance with Chapters 4 through 11 of the 2022 edition of NFPA 1225).


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A.3.2.1 Approved.

The National Fire Protection Association does not approve, inspect, or certify any installations, procedures,equipment, or materials; nor does it approve or evaluate testing laboratories. In determining theacceptability of installations, procedures, equipment, or materials, the authority having jurisdiction maybase acceptance on compliance with NFPA or other appropriate standards. In the absence of suchstandards, said authority may require evidence of proper installation, procedure, or use. The authorityhaving jurisdiction may also refer to the listings or labeling practices of an organization that is concernedwith product evaluations and is thus in a position to determine compliance with appropriate standards forthe current production of listed items.

A.3.2.2 Authority Having Jurisdiction (AHJ).

The phrase “authority having jurisdiction,” or its acronym AHJ, is used in NFPA documents in a broadmanner, since jurisdictions and approval agencies vary, as do their responsibilities. Where public safety isprimary, the authority having jurisdiction may be a federal, state, local, or other regional department orindividual such as a fire chief; fire marshal; chief of a fire prevention bureau, labor department, or healthdepartment; building official; electrical inspector; or others having statutory authority. For insurancepurposes, an insurance inspection department, rating bureau, or other insurance company representativemay be the authority having jurisdiction. In many circumstances, the property owner or his or herdesignated agent assumes the role of the authority having jurisdiction; at government installations, thecommanding officer or departmental official may be the authority having jurisdiction.

A.3.2.4 Listed.

The means for identifying listed equipment may vary for each organization concerned with productevaluation; some organizations do not recognize equipment as listed unless it is also labeled. Theauthority having jurisdiction should utilize the system employed by the listing organization to identify alisted product.

A.3.3.1 Alarm.

Alarms are events received by electronic signal — that is, fire alarm boxes, central station alarms, andautomatic crash notifications.

A.3.3.1.1 Alarm Data.

Other explanatory information can include, but is not limited to, sensor types, alarm types, and accessinformation.

A.3.3.8 Automatic Location Identification (ALI).

Automatic location identification is typically associated with an enhanced 9-1-1 telephone call. ALI caninclude the civic street address, building, floor, and room numbers and/or the latitude and longitude.

A.3.3.9 Automatic Number Identification (ANI).

Automatic number identification is typically used in two disparate systems in emergency communications.First, ANI is a telephone number associated with the access line from which a call originates. Second, intwo-way radio communications, ANI can be associated with the radio device that is active on the voicecommunication channel.

A.3.3.10 Backbone.

Damage to a backbone cable will disable the radio enhancement system through much or all of thebuilding, and as a result it should be identified and protected. The backbone could be fiber-optic, copper,or coaxial cable, but it does not radiate RF energy along its path.

A.3.3.19 Call Server.

Call server is a generic term for a centralized, computer application–based telephone system. Call serversare the next generation of private branch exchange (PBX) systems. There are many advantages to using acall server over a legacy PBX, including the ability to add features via modification to the application codeand the ability to add extensions using either physical telephones or computer-based clients.

A.3.3.22 Circuit.

Specific types of circuits include dispatch, local, and tie circuits.


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A.3.3.25 Communications Center.

Examples of functions of a communications center are as follows:

(1) Communications between the public and the communications center

(2) Communications between the communications centers, the emergency response agency (ERA), andemergency response facilities (ERFs)

(3) Communications within the ERA and between different ERAs

A.3.3.26 Communications Officer.

The position is a function that falls under the logistics section of the incident command system (ICS).

A.3.3.27 Communications System.

Devices can include telephones, radios, sensors, cameras, and any other instrument capable of capturingand communicating data. Networks can include both hard-wired and wireless infrastructure. Applicationscan include computer programs that collect, aggregate, and disseminate information. Computers can be inany form factor including personal devices, tablets, laptops, desktops, servers, clusters, and main frameservers. Services can include private and commercially available voice and data transmission capabilitiesand applications as a commercially available service. A communications system can include multipleinterconnected and integrated communication systems.

A.3.3.28 Comprehensive Emergency Management Plan (CEMP).

In some jurisdictions a CEMP could also be known as a disaster management plan.

A.3.3.29 Computer-Aided Dispatch (CAD).

CAD systems have become the preferred method of providing dispatching services. These requirementsare intended to ensure that these critical resources are secure, reliable, and redundant.

A.3.3.37 Delivered Audio Quality.

(1) DAQ 1 Unusable: Speech present but not understandable

(2) DAQ 2 Speech understandable with considerable effort: Requires frequent repetition due tonoise/distortion

(3) DAQ 3 Speech understandable with slight effort: Requires occasional repetition due to noise/distortion

(4) DAQ 3.4 Speech understandable without repetition: Some noise/distortion present

(5) DAQ 4 Speech easily understood: Occasional noise/distortion present

A.3.3.41 Dispatch Circuit.

A dispatch circuit was formerly called an alarm circuit.

A.3.3.46 Distribution Antenna Cable.

It is typically a coax cable or radiating cable, and it is outside of the heat and fire protection provided byany firewalls or other means.

A.3.3.49 Emergency.

The AHJ of the responding agency can determine which types of events qualify as an emergency.

A.3.3.50 Emergency Event Processing/Dispatching.

This term includes caller interrogation and resource selection [determination of which emergency responseunit (ERU) will respond] up to the start of the ERF notification process.

A.3.3.52 Emergency Response Agency (ERA).

An ERA includes any public, governmental, private, industrial, or military organization that engages in theoperations specified in the definition.

A.3.3.53 Emergency Response Facility (ERF).

Examples of ERFs include a fire station, a police station, an ambulance station, a rescue station, a rangerstation, and similar facilities.

A.3.3.56 Event.

All incoming calls on designated emergency telephone lines should be considered emergency events untilanswered by a telecommunicator. If a telecommunicator determines that the reason for the call is not anemergency as defined in 3.3.49, the call will not count against the performance requirements of 15.4.2. Atrouble or supervisory signal is not an indication of an event. (See also 3.3.119, Trouble Signal.)


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A.3.3.57 Event Data.

Other explanatory information can include, but is not limited to, sensor types, alarm types, and accessinformation.

A.3.3.63 IP-Enabled Device.

An IP-enabled device is not a land mobile radio narrowband device; examples include smart phones,tablets, and laptop computers.

A.3.3.65 Logging Recorder.

Event and dispatch information could include voice, ANI, ALI, dispatch records, date, time, and otherincident specific details. A logging recorder is normally a multichannel device that keeps a semi-permanentrecord of all data and media associated with an event.

A.3.3.71 Multi-Line Telephone System (MLTS).

The term multi-line telephone system refers to any solution, independent of the technology used, thatallows an entity to use a group of voice communication channels from an exchange carrier to connect amultiplicity of end users for inbound, outbound, and intersystem telephone calls. An MLTS includes bothPBX-based and call server–based solutions, including network-based and premises-based systems (e.g.,Centrex, VoIP, as well as PBX, hybrid, and key telephone systems, as classified by the FCC under Part 68requirements).

A.3.3.73 Notification.

Notification can be made by either electronic or mechanical means.

A.3.3.82 Private Branch Exchange (PBX).

The PBX system was first developed to allow a private entity to connect the telephone company to manyusers, breaking the one phone–to–one phone line ratio. Originally, this process was a manual one, inwhich a switchboard operator would answer an incoming call and, using a physical patch cord, connect theincoming caller to the desired extension. When users wanted to make either an outbound or intersystemcall, they first had to notify the switchboard operator and verbally explain their request. As technologyprogressed, switchboard operators were replaced first by mechanical devices that could interpret a rotary

dial and later by dual tone multifrequency (DTMF) “Touch Tone®”.

A.3.3.88 Public Safety Answering Point (PSAP).

A PSAP is a facility at which emergency calls are first answered, assessed, triaged, classified, andprioritized. The FCC further defines a primary PSAP as a facility to which 9-1-1 calls are routed directlyfrom the 9-1-1 control office. A secondary PSAP is defined as a facility to which 9-1-1 calls are transferredfrom a primary PSAP.

A.3.3.90.2 Public Safety Communications Manager/Director.

The public safety communications manager/director supervises the coordination and prioritization of allactivities of the public safety telecommunications center. The managing of communications centeroperations includes but is not limited to preparation of documentation for contractual requirements,budgets, legislative actions, policies and procedures, and guidelines affecting public safetycommunications personnel.

A.3.3.90.3 Public Safety Communications Supervisor.

A supervisor promotes individual and organizational performance to achieve the agency mission,standards, and goals through leadership and training in order to provide the highest possible level of publicsafety communications services. First-level supervision indicates the person who provides direct oversightto the telecommunicators on the shift.

A.3.3.91 Public Safety Emergency Communications System.

A public safety emergency communications system consists of any technology or system utilized for thereporting, detection, coordination, dispatch, monitoring, or tracking of emergency incidents, emergencyresponse resources, and/or the support of related activities.

A.3.3.93 Radio Channel.

The width of the channel depends on the type of transmissions and the tolerance for the frequency ofemission. Channels normally are allocated for radio transmission in a specified type for service by aspecified transmitter. [72, 2019]

A.3.3.95 Radio Frequency.

The present practicable limits of radio frequency (RF) are roughly 10 kH to 100,000 MHz. Within thisfrequency range, electromagnetic waves can be detected and amplified as an electric current at the wavefrequency. Radio frequency usually refers to the RF of the assigned channel.


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A.3.3.97 Remote Communications Facility.

Remote communications facilities might be housed in buildings under the control of the AHJ, in buildingsnot under the control of the AHJ, on high land forms such as mountaintops, and at other locations asnecessary to ensure operation of a communications system over a geographic area designated by theAHJ. Remote transmitters, receivers, repeaters, and their associated antennas are frequently found atsuch facilities. When not housed in a building, equipment is usually located in prefabricated enclosures toprovide weather protection.

A.3.3.102 Response Unit.

Some examples of response units include patrol car, ambulance, rescue vehicle, pumper, ladder truck,elevating platform, service vehicle, marine unit, supervisor's vehicle, tow truck, motor assistance vehicle,construction equipment, mass transit vehicles, and personnel assigned a unique identification number orname used for dispatches.

A.3.3.107 Standard Operating Procedures (SOPs).

In some jurisdictions, SOPs are also known as standard operating guidelines (SOGs).

A.3.3.121 Two-Way Alphanumeric Devices.

Two-way alphanumeric devices do not have the capability of providing voice messages.

A.3.3.123 Uninterruptible Power Supply (UPS).

A UPS is a solid-state system relying solely on battery power as an emergency source. A static UPSconsists of a rectifier (a device for converting ac to dc), an inverter (a device for converting dc to ac, andan energy storage medium, for example, batteries. The inverter in the static UPS also includescomponents for power conditioning.

A.3.3.124 Voice Communication Channel.

The voice communications channel can be physically switched, as with wired circuits, wirelessly switched,as with radio channels; or virtually switched, as with circuits created for voice over Internet protocol (VoIP)network-based circuits.


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A.4.1.2.3

Organization and management responsibilities should be addressed by the agency that personnelrepresent. The authority having jurisdiction should define the agency requirements for progression topositions of management responsibility. The agency may delegate of additional duties or otherresponsibilities without being considered management.

A.4.1.2.6

The committee recognizes the importance of formal and continuing education and training programs toensure that personnel at the various response levels. Continuing education and training programs can bedeveloped or administered by local, state, provincial, or federal agencies as well as by professionalassociations and accredited institutions of higher education. The methods of learning would include areasof technology, refresher training, skills practices, and knowledge application to standards. The subjectmatter should directly relate to the requirements of this standard.

A.4.1.3.3

It is recommended, where practical, that evaluators be individuals who were not directly involved asinstructors for the requirement being evaluated.

A.4.1.3.4

The acceptance of nationally recognized governance, although not law, should be considered when thepractices and procedures are applied.

A.4.1.3.8(1)

Training requirements and certifications of individuals working in the public safety communications centershould be defined by this standard or any other industry standard that is applicable. All individuals fillingpositions defined by this standard, even on a part-time or temporary basis, should meet all minimumqualifications, training requirements, and standards applicable to the position and should meet all local,state, and/or federal certification requirements.

The intent of the committee is that all individuals filling the position defined, even on a part-time ortemporary basis, should meet all minimum qualifications and standards applicable to the position andshould meet all local, state, and/or federal certification requirements. The committee recognizes the needfor formal training programs to provide the necessary skills and knowledge to perform the job oftelecommunicator

These programs can be developed or administered by local, state, provincial, or federal agencies as wellas professional associations.

In many jurisdictions, part of this formal training includes some form of on-the-job training. (See Annex Ffor a discussion of the considerations of the training of enhanced telecommunicator skills.)


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A.4.1.3.8(4)

Medical and physical requirements shall be developed by the AHJ that are job-related and in compliancewith the Equal Employment Opportunity Act, the Americans with Disabilities Act, and other applicablelegal requirements. The AHJ is required under the Americans with Disabilities Act to identify the functionalrequirements for the performance of the job. The AHJ should consider the physical arrangement of theworkspace and the various pieces of equipment required for operation by the employee. Specific medicaland physical abilities are required in order to perform essential functions of the job.

They include, but are not limited to, the following:

(1) Hearing. Distinguish, differentiate, and respond to multiple audible stimuli from personnel orequipment, such as telephone, radio, or alarms

(2) Sight. Distinguish, differentiate, and respond to multiple visual stimuli such as printed documents,CRT displays, and indicator lights

(3) Manual dexterity. Operate radios, computers, and other equipment used in a telecommunicationscenter

(4) Speech. Clearly convey verbal messages utilizing telecommunication devices

The public safety telecommunicator is the initial contact in managing requests for services provided bypublic safety agencies. Decisions are made based on incoming and updated information. The ability toreceive information audibly is essential to the job. Additionally, much emphasis is placed on visual abilityand manual dexterity. Identification of audio and visual cues, incoming telephone lines, 9-1-1 screens,incident cards/screens, messages, requests, memorandums, and so forth, is imperative to performrequired job duties.

The committee has identified the following behavioral characteristics or traits the hiring or certifyingauthority might want a candidate to be able to exhibit:

(1) Adjust to various levels of activity

(2) Appropriate personal behavior

(3) Acceptance of constructive feedback

(4) Remember and recall information

(5) Tolerance

(6) Function under stress

(7) Maintain confidentiality


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A.4.1.3.8(5)

Individual shall have cognitive and psychomotor skill requirements for areas of reading, spelling, speech,mathematics, basic language, written communication, listening, and basic computer skills in addition toother requirements developed by the AHJ.

The committee recommends that the following skills be considered by the AHJ for the telecommunicatorcandidate:

(1) Ability to spell

(2) Basic reading skills

(3) Basic math calculation

(4) Ability to speak clearly

(5) Basic writing skills

(6) Manual dexterity

(7) Ability to follow written and verbal instructions

(8) Ability to alphabetize and catalog

(9) Keyboarding and mousing skills as required

(10) Multi-tasking

(11) Quick decision-making

(12) Teamwork

(13) Critical thinking

(14) Customer service skills

(15) Problem solving

(16) Interpersonal communication skills

A.4.3.2(A)

For additional information on the verbal communication process, see Annex D.

A.4.3.2(B)

The Public Safety Telecommunicator I should be capable of operating, testing, troubleshooting, andmaintaining the continuity of the communication system. The Public Safety Telecommunicator I might alsobe required to switch to and operate back-up components or alternative systems.

A.4.3.3(B)

This could also include managing situations such as excited or hysterical callers, callers speaking foreignlanguages, suicidal callers, and other calls requiring special handling, including mass casualty andweapons of mass destruction.

A.4.3.4(A)

Nonverbal communication protocols include American Sign Language (ASL) syntax. Thetelecommunicator should also know common abbreviations used in non-verbal communications.Individuals who are hearing or speech impaired often use ASL syntax while communicating via aTelecommunications Device for the Deaf/Teletype (TDD/TTY) or Text phone. ASL is a separate languagethat uses English words but has its own rules for syntax and sentence construction.

A.4.3.4(B)

The Americans with Disabilities Act (ADA) requires equal access to emergency services by individualswith speech and hearing impairments. This most often takes the form of a TDD/TTY or Text phone usingBaudot or ASCII code. Other nonverbal devices include computer communication, digital terminals,analog devices, alarm systems, FAX machines, or other mechanical or electronic media.

A.4.4.1

This should be done according to Section 16.3.2.1. The PSAP should remain on the line until it is certainthat the transfer has been effected.


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A.4.4.3(A)

The Public Safety Telecommunicator I is expected to question callers regarding potential threats, risks,and hazards that responders can encounter. Examples include details pertaining to the involvement ofweapons, hazardous materials, violent subjects at the scene, unsafe conditions en route to or at thescene, and so forth.

A.4.4.4

Special or unusual circumstances are most often typified by hang-up calls or silent calls. Thesecircumstances will be handled by following the procedures, policies, or guidelines of the AHJ.

A.4.5.1(A)

A pre-arrival instruction or information will be provided based on policies, procedures, or guidelines of theAHJ.

The functions of the Public Safety Telecommunicator might include the use of predetermined questions,pre-arrival telephone instructions, and pre-assigned actions that are an integral part of the responsibility toprioritize calls and assist in the stabilization of the situation.

A pre-arrival reference system should be in a uniform format that is an accessible and reproducibledocument based on current guidelines and administrative protocols.

A.4.5.1(B)

Voice control includes the ability to maintain balanced tone, modulation, volume, and inflection whilecommunicating.

A.4.5.2

In some jurisdictions the on-duty telecommunicator could be responsible for both call taking anddispatching. Other entities can include social service agencies, utilities, other emergency serviceproviders, or other governmental units. Resolution might be accomplished by referral to, or response by,one of these agencies.


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A.5.2.1

These sources can include other telecommunicators, field units, or electronic devices.

A.5.2.2

See Chapter 17 for information on alert tone.

A.5.2.2(A)

The Public Safety Telecommunicator II should be capable of operating, testing, troubleshooting, andmaintaining the continuity of the communication systems, including radio codes, unit identifiers,emergency alert tone, and phonetic alphabet. The Public Safety Telecommunicator II might also berequired to switch to and operate back-up components or alternative systems.

A.5.2.3

These systems might include computer-aided dispatch systems, recording systems, automatic vehicletracking systems, mobile data systems, and computer systems linking the telecommunicator with otheragencies.

A.5.2.3(A)

This can include familiarity with computer operations and technology.

A.5.2.3(B)

This can also include data system messages.

A.5.3.3

Deployable resources include those individuals, equipment, and specialized units that are dispatched bythe agency.

A.5.3.3(A)

See Chapter 15 on operations.

A.5.3.6

This action is not a static decision but rather a dynamic process that changes and evolves during thehandling of an event. The Public Safety Telecommunicator II is required to make many decisions thatmight not change the action originally initiated. Factors that cause changes to decisions or actions are thereceipt and processing of additional information, or updates. The Public Safety Telecommunicator IImakes necessary decisions and takes actions that will result in the appropriate assignment of resources,emphasizing the safety of the public and the response units. (See Figure A.5.3.6.)

Figure A.5.3.6 Model of Processing a Request for Service.


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A.5.4.1

The public safety telecommunicator should operate within the incident management system prescribed bythe AHJ such as defined in NFPA 1561. The telecommunications equipment used by public safetyagencies is widely varied. The term telecommunications equipment includes all equipment in use by anagency for the purpose of alerting or notifying response units and the continued exchange of informationbetween those units and the communications center. Examples include computer-aided dispatch (CAD)systems, mobile data terminals (MDT), two-way radios, paging systems, alerting devices, telegraphsystems, telephone systems, voice alerting and PA systems, and data terminals.

A.5.4.2

In the case of unfounded service requests, hang-up calls, or invalid locations, the telecommunicatorshould make every effort to reverify the accuracy of a location or the validity of a service request withinthe policies established by the AHJ.

A.5.4.4(B)

Supplemental information could include relevant databases and documentation that might be internal orexternal to the agency available to provide ongoing support to response units.

Emergency plans should be developed in accordance with NFPA 1600.

A.5.4.5

Situations beyond the normal scope of operation could include major crime occurrence, major fire, masscasualty incidents, weapons of mass destruction, and man-made or natural disasters.


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A.7.1

It is important to consider APCO ANS 3.101.2-2013, Core Competencies and Minimum TrainingStandards for Public Safety Communications Training Officer (CTO), when establishing the jobperformance requirements for this position.


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A.8.1

It is important to consider APCO ANS 3.102.1-2012, Core Competencies and Minimum TrainingStandards for Public Safety Communications Supervisor, when establishing the job performancerequirements for this position. It is recommended that the supervisor also meet the requirements of thePublic Safety Communications Training Officer.


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A.9.1

It is important to consider APCO ANS 3.106.1-2013, Core Competencies and Minimum TrainingStandards for Public Safety Communications Quality Assurance Evaluators, when establishing the jobperformance requirements for this position.


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A.10.1

It is important to consider APCO ANS 3.104.1-2012, Core Competencies and Minimum TrainingStandards for Public Safety Communications Training Coordinator, when establishing the jobperformance requirements for this position.


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A.11.1

It is important to consider APCO ANS 3.109.2-2014, Core Competencies and Minimum TrainingStandards for Public Safety Communications Manager/Director, when establishing the job performancerequirements for this position.


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A.12.1.3

Telematics provide emergency communications from either a person requesting emergency assistanceor an autonomous request such as an automatic crash notification (ACN). The communication requestis routed to a PSAP from a third-party telematics service provider. The TSP can contact the PSAPthrough dedicated 9-1-1 trunk or ALI-supported telephone system. Communications types to the PSAPcould include automatically generated incident location, automatically generated incident location withdata, or voice communications with automatically generated incident location with data.

A.12.2.1

Uninterrupted operation of emergency communications systems is critical to the safety and security ofthe community at large. In the event of a major natural or man-made disaster, the continued operationof the communications center will be an essential element in maintaining the continuity of government,thereby lessening loss of life and preventing the breakdown of law and order.

Most NFPA documents are written to furnish minimum requirements for the safety to life and propertyin any given individual building. However, survival and continued functioning of emergency servicescommunications systems are necessary for the health and safety of the entire community. Theemergency services communications systems infrastructure needs to be able to withstand the effectsof hurricanes, earthquakes, terrorism, wildfires, blizzards, tsunamis, and other disasters of similarscale. Because of that need, this document contains requirements that in some cases are morestringent than those for an otherwise similar business occupancy.

A.12.2.2

The CEMP should be exercised on a regular basis to ensure that the plan is workable and thatemployees are familiar with the procedures. The local emergency planning committee (LEPC)comprises emergency response agency representatives, local government, schools, emergencymanagement personnel, other governmental agencies, and the private sector. The CEMP is developedby this committee and used as part of the planning process in emergency management. NFPA 1600also outlines the requirements for emergency planning. The communications center is a criticalcomponent of any emergency plan and serves as a link between the emergency operations center(EOC) and ERAs. Where there is no local CEMP, or are no CEMPs applicable to the PSAP, the PSAPwould need to develop its own.

A.12.2.6

One means of meeting this requirement could be a mutual-aid agreement with another jurisdiction touse its communications center as the alternate center. This is dependent on whether the othercommunications center has enough capacity to handle the added call volume and enough workstations to accommodate personnel relocated from the evacuated center. It also is heavily dependenton the ability of another jurisdiction’s center to transmit and receive on the dispatch frequencies in useat the primary center. Such an agreement should be made in writing.

A.12.2.6.2

The alternate communications center should not be located in close proximity to the primary center. Indetermining the minimum geographical separation required between the primary communicationscenter and the alternate communications center, the AHJ should evaluate the potential for a singledisaster (terrorist attack, flood, tornado, etc.) to render both the primary and alternate centersinoperable. When preparing evacuation and continuity of operations plans, the AHJ should alsoconsider the length of time it will take center personnel to travel under adverse conditions to anunstaffed alternate center and place it in operation.

A.12.2.6.3.2

The CEMP should be exercised on a regular basis to ensure that the plan is workable and thatemployees are familiar with the procedures. The local emergency planning committee (LEPC)comprises emergency response agency representatives, local government, schools, emergencymanagement personnel, other governmental agencies, and the private sector. The CEMP is developedby this committee and used as part of the planning process in emergency management. NFPA 1600also outlines the requirements for emergency planning. The communications center is a criticalcomponent of any emergency plan and serves as a link between the emergency operations center(EOC) and ERAs.

A.12.2.6.4

This requirement is intended to ensure that emergency communications systems will continue tooperate, even if the primary communications center is completely destroyed.


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A.12.2.7

The decision to evacuate or to not evacuate the communications center in the event of a fire or threatof fire is not simple. It involves moving the telecommunicators to a backup dispatch center or to acooperating agency in a nearby jurisdiction. The communications center should be assigned dedicatedfire suppression resources in the event of a fire in the communications center or a fire in the buildinghousing the communications center. Decisions that involve continued operation or evacuation of thecenter should be made by the fire suppression officer and the telecommunicator supervisor.

A.12.2.9

During the planning and design phases, it is essential that sufficient space be allotted for bothpersonnel and equipment, to enable telecommunicators and supervisors to work efficiently. It is veryimportant to include the users of the facility(ies) in the planning process from its inception. These usersinclude telecommunicators, supervisors, and representatives of each emergency response agency tobe dispatched from the center. Fact-finding visits to centers in other jurisdictions should be undertaken.The number of personnel that must be accommodated within the center will be determined by the AHJin accordance with the requirements of this standard and other factors. Prior to design, a detailedanalysis of the tasks to be performed in the operations room is essential. Since electronic equipmentwill be replaced periodically throughout the life of the center, “swing space” needs to be provided toenable new equipment to be installed and commissioned before older equipment is decommissionedand removed.

A.12.3.2

Consideration should also be given to hazards associated with falling trees, antennas, or other similarstructures.

A.12.3.3

When siting communications centers, AHJs should consider increasing this requirement, to above the500-year floodplain. Over time, 100-year floodplains have tended to expand, and “freak” storms thatexceed the 100-year intensity have become more frequent. Therefore, depending on the flood dangerin the area, it would be wise to choose a site significantly above the 100-year floodplain elevation.

A.12.4.5

Design consideration for belowgrade centers should include the following:

(1) Special requirements for means of egress

(2) Depth of the local water table relative to the floor elevation

(3) Humidity control

(4) Sumps and pumps having the capacity to prevent flooding under the heaviest possible rainfall

(5) Smoke removal or control systems

(6) Additional backup power needs

(7) Employee morale

(8) Other pertinent issues

A.12.4.8.1

Such facilities can include an on-site drilled water well with pumping facilities provided with bothprimary and secondary power, and a septic system or adequately sized effluent holding tank. For smallcenters with few employees, the AHJ might determine that a chemical toilet and adequate stocks ofbottled water are sufficient. When relying on bottled water, consideration should be given to the factthat bottled water has an expiration date; therefore, stocks must be renewed accordingly.


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A.12.5.1.1.1

The cooling and heating loads of a communications center typically vary significantly, depending on thefunctions performed in each individual space. Computers, radio equipment, uninterruptible powersupplies, and similar equipment typically found in modern communications centers generate asignificant amount of heat that needs to be removed to prevent the equipment from overheating andshutting down. On the other hand, that same amount of cooling provided to the operations room, breakroom, conference rooms, and general office areas will make employees in those normally occupiedrooms uncomfortable.

When humans are uncomfortable due to room temperature, their first reaction is to adjust thethermostat. If the same thermostat also controls the amount of cooling provided to sensitive electronicequipment, equipment will overheat and systems failure may result. Therefore, for the reliableoperation of the communication systems (as well as comfort and morale of employees), it is essentialthat individual space temperature controls be provided.

A.12.5.1.2

For communications centers located in multi-use buildings, it is important to avoid drawingcontaminants (including smoke from a fire) from other parts of the building into the center. For theseand other reasons, it is necessary to provide the communications center with independent HVACsystems.

A.12.5.1.3

U.S. Army Technical Manual TM 5-602-01, Utility Systems Terrorism Countermeasures for Command,Control, Communications, Computer, Intelligence, Surveillance, and Reconnaissance (C4ISR)Facilities, furnishes additional guidance, which the AHJ might want to consider when planning a newcommunications center.

A.12.5.1.5

A backup heating, ventilating, and air-conditioning (HVAC) system is needed for use during routinemaintenance of the primary system and in the event of a primary system failure.

When HVAC systems fail and no backup is provided, the first casualty is usually security. Doors orwindows that are required to be closed are opened, often without the knowledge or consent of the AHJ.

A.12.5.1.7

Examples of equipment include packaged cooling systems and components such as chillers,compressors, condensers, supply air fans, and return air fans.

A.12.5.1.8

HVAC systems that cool essential electronic equipment are equally essential, as loss of cooling willcause equipment to shut down or fail outright. Therefore, backup power needs to be provided for bothprimary and backup HVAC systems that cool this equipment.

A.12.5.1.9

Air intakes should be installed and maintained in accordance with NIOSH Guidance for ProtectingBuilding Environments from Airborne Chemical, Biological, or Radiological Attacks, DHHS (NIOSH)Pub No. 2002-139.

A.12.6.6

A written emergency fire plan should be prepared and posted that assigns specific responsibilities. Thisplan should be coordinated with all responding emergency agencies. Personnel should receivecontinuing instructions in at least the following:

(1) Evacuation of personnel and designated assembly area

(2) The operations of all fire-extinguishing and automatic fire detection systems

(3) The use of portable fire extinguishers


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A.12.6.7

A damage control plan should provide guidance for the following:

(1) Preventing or minimizing damage to electronic equipment

(2) Preventing or minimizing damage to other operations and equipment For example, wheneverelectronic equipment or any type of record is wet, smoke damaged, or otherwise affected by theresults of a fire or other emergency, it is vital that immediate action be taken to clean and dry theelectronic equipment. If the water, smoke, or other contaminations are permitted to remain in theequipment longer than absolutely necessary, the damage can be grossly increased. In addition, ameans should be provided for preventing water damage to electronic equipment. The propermethod of doing this will vary according to the individual equipment design.

(3) Identifying procedures for a return to normal operations

A.12.6.8

Tactical Interoperable Communication Plan (TICP) templates are available atwww.safecomprogram.gov.

A.12.7.3

This requirement previously read “Entryways to the communications center that lead directly from theexterior shall be protected by a security vestibule.” However, when the center occupies just a portion ofa mixed-use building, and the building as a whole provides a lower level of security than required bythis standard, it will be necessary to establish a security boundary within the building around thecommunications center. Therefore the requirement for security vestibules applies to all entrances intothe center regardless of whether they are indoor or outdoor entrances. Note that doors that areprovided for emergency egress only and cannot be opened from outside the center should not beconsidered entrances and therefore need not be provided with security vestibules. Also, when thewhole building envelope provides the level of security required by this standard, the AHJ mightdetermine that internal security vestibules are not required.

A.12.7.4.5

For instance, a window facing a break area within the secure area assigned solely for the use of thecommunications center does not require bullet-resistant glass as long as a block wall surrounds thebreak area.

A.12.7.5

This applies whether the wall in question is provided with windows or not.

A.12.7.7

Refer to the Department of Defense Unified Facilities Criteria (UFC) 4-010-01, Minimum AntiterrorismStandards for Buildings; UFC 4-022-02, Selection and Application of Vehicle Barriers; UFC 4-023-03,Design of Buildings to Resist Progressive Collapse; UFC 4-023-07, Design to Resist Direct FireWeapons Effects; and UFC 4-024-01, Security Engineering: Procedures for Designing AirborneChemical, Biological, and Radiological Protection for Buildings, for additional guidance.

A.12.8.1.5

This connection provides a quick and safe way to provide power to the communications center during aworst-case scenario power failure. The socket should be physically located to allow easy access for atrailer-mounted generator that would be pulled to the site. The disconnect switch should be of themake-break-make (center-off) type and lockable. Connecting the wiring from the socket between theautomatic transfer switch and the electrical distribution panel for the communications center provides ameans to get power to the center in case of failure of the transfer switch. When the COPS is suppliedby a single generator, all wiring and equipment should be of sufficient ampacity to handle the entirecritical load of the center, as determined by the AHJ in accordance with the requirements ofChapter 12.

A.12.8.1.6

An example of control wiring that would be required to receive COPS treatment would be the remotegenerator annunciation wiring.

A.12.8.4

Engine-driven generators should be sized to supply power for the operation of all critical operatingfunctions of the remote communications facility and for any additional loads determined by the AHJ.


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A.12.8.4.3

For large communications centers, a spare generator should be provided so that the center canoperate with the largest single generator out of service. This will allow one generator to be taken offline for maintenance and testing without degrading the reliability of the overall system, as well asprevent degradation of communications center function in the event a generator fails during anextended commercial power outage. For smaller centers where this is not practicable as determined bythe AHJ, an exterior weatherproof connection for connection of a mobile (trailer or truck mounted)generator should be provided.

A.12.8.4.12

This is a minimum requirement. The AHJ should consider common local power failure scenarios andhistorical data on the length of power outages in the jurisdiction to determine if additional fuel storage isrequired. The possibility of extended power outages due to hurricanes, tornadoes, blizzards,earthquakes, wildfires, and other natural disasters should be considered. As part of the CEMP, the AHJshould evaluate the effect of natural disasters on the ability to resupply fuel tanks during such disastersto determine if additional fuel for operation for more than 72 hours needs to be stored on site. Recentdisasters such as Hurricane Katrina have shown that in some cases it could be necessary forcommunications facilities to operate for a week or more before primary power is restored. In theaftermath of such disasters, roads may be impassable and fuel delivery trucks may have beendamaged beyond immediate repair. Under such conditions, it could take many days to resupply fuel.

A.12.8.4.12.1

Commercial distillate fuel oils used in modern diesel engines are subject to various detrimental effects.The origin of the crude oil, refinement processing techniques, time of year, and geographicalconsumption location all aid in the determination of fuel blend formulas. Sulfur, naturally occurringgums, waxes, soluble metallic soaps, water, dirt, and temperature all begin to degrade fuel as it ishandled and stored. These effects begin at the time of fuel refinement and continue until consumption.Proper fuel storage is critical to engine start-up, efficiency, and longevity. Storage tanks should be keptwater free and have provisions for drainage on a scheduled basis. Water can contribute to steel tankcorrosion and the potential development of microbiological growth where fuel and water interface.Copper and its alloys, along with zinc or zinc coatings, should be avoided in fuel-handling systems.These elements can react with fuel to form certain gels or organic acids, resulting in clogging of filtersor further system corrosion. Stable storage temperatures are conducive to fuel health. Tanks that areaboveground and subject to extreme daily temperature variations cause fuel to degrade more rapidly.This is further exacerbated with large aboveground tanks that are less than full. Airspace allows forcondensation that can add to the contaminant levels. Reflective exterior tank coatings reduce but donot eliminate the solar heating effect.

Scheduled fuel maintenance and testing help to reduce or nearly eliminate fuel contamination. Fuelmaintenance filtration can remove contaminants and water and return fuel to the condition in which itwill provide reliability and efficiency for standby generators when in emergency conditions. Fuelmaintenance and testing should begin the day of installation and first fill to establish a benchmarkguideline for further comparison. Fuel monitoring and testing services are available nationwide frommany companies.

A.12.8.6.1

In addition to normal surge protection from electrical and lightning surges that can disrupt theoperations of a communications center, other electromagnetic disruptions can also occur.Communications centers that protect very large urban or regional population centers could become atarget of enemy military or terrorist attack and might want to consider taking additional measures toprotect against an electromagnetic pulse (EMP) event, which could occur as a result of detonation of anuclear device in the atmosphere. An EMP will create transient high induced surge currents in wiresand cables leading into a communications center and could even induce damaging currents insideelectronic equipment that is not suitably shielded, such that the equipment will fail. Additionalinformation can be found in a U.S. Army Technical Manual TM 5-690, Grounding and Bonding inCommand, Control, Communications, Computer, Intelligence, Surveillance, and Reconnaissance(C4ISR) Facilities, at http://140.194.76.129/publications/armytm/tm5-690/c-5.pdf, The Commission toAssess the Threat to the United States from Electromagnetic Pulse (EMP) Attack, Executive Report, orat other sources.

A.12.8.7

Additional guidance can be obtained from U.S. Army Technical Manual TM 5-690, Grounding andBonding in Command, Control, Communications, Computer, Intelligence, Surveillance, andReconnaissance (C4ISR) Facilities.

A.12.8.8.1

Storage batteries preferably should be located on the same floor as the operating equipment.


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A.12.8.8.3

When sizing a UPS, consideration should be given to the potential for increased electrical loads as thecenter grows over time.

A.12.10

U.S. Army Technical Manual TM 5-811-3, Electrical Design: Lightning and Static Electricity Protection,provides additional guidance.

A.12.11.2.2

Consideration should also be given to hazards associated with falling trees, antennas, and othersimilar structures.

A.12.11.2.4

When siting remote communications facilities, AHJs should consider increasing this requirement toabove the 500-year floodplain. Over time, 100-year floodplains have tended to expand, and “freak”storms that exceed the 100-year intensity have become more frequent. Therefore, depending on theflood danger in the area served by the communications center, it might be wise to choose a site abovethe 500-year floodplain elevation.

A.12.11.3.5

Design consideration for belowgrade facilities should include the following:

(1) Special requirements for means of egress

(2) Depth of the local water table relative to the floor elevation

(3) Humidity control

(4) Sumps and pumps having the capacity to prevent flooding under the heaviest possible rainfall

(5) Other pertinent issues

A.12.11.3.6

A common example of such material is gypsum wallboard.

A.12.11.3.7

Examples of noncombustible floor materials are concrete, aluminum, and steel.

A.12.11.5.4

An example of such a facility is a free-standing, prefabricated or site-built enclosure that housescommunications system equipment to protect it from precipitation, extremes in temperature, andvandalism.

A.12.11.5.6

FM Global Property Loss Prevention Data Sheet 9-19, Bushfire Exposure, provides additionalengineering guidance.

A.12.11.6.4

Such locations could include interior courtyards, light wells, and the like.

A.12.11.6.5

Department of Defense UFC 4-023-07, Design to Resist Direct Fire Weapons Effects, provides usefulguidance.

A.12.11.6.6

Department of Defense UFC 4-022-02, Selection and Application of Vehicle Barriers, providesadditional guidance.

A.12.11.6.7

Department of Defense UFC 4-023-03, Design of Buildings to Resist Progressive Collapse, providesadditional guidance.

A.12.11.6.8

For the more information on central stations, refer to NFPA 72. For guidance on intrusion detectionsystems (IDS) see Department of Defense UFC 4-021-02NF, Security Engineering Electronic SecuritySystems.


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A.12.11.7.5

If the public water supply is used for engine cooling, interruption of the supply will cause overheating ofthe engine and failure of the generator.

A.12.11.7.6

Examples are motorized intake air louvers, fans supplying cooling or combustion air, fuel transferpumps, and coolant pumps.

A.12.11.7.7.2

Refer to A.12.11.5.4.

A.12.11.7.8

Additional guidance is contained in U.S. Army Technical Manual TM 5-693, Uninterruptible PowerSupply System Selection, Installation, and Maintenance for Command, Control, Communications,Computer, Intelligence, Surveillance, and Reconnaissance (C4ISR) Facilities.

A.12.11.8.1.2

During the design of a lighting system for a normally non-staffed facility, consideration should be givento the fact that it is customary for maintenance personnel to bring portable lights with them.

A.12.11.9

U.S. Army Technical Manual TM 5-811-3, Electrical Design: Lightning and Static Electricity Protection,provides additional guidance that the AHJ might want to consider.


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A.13.1.1

Refer to NFPA 70 for examples of installations that are and are not covered by NFPA 70.

A.13.5.2

Environmental conditions could exist that necessitate the use of rigid nonmetallic conduit.

A.13.6.4

Examples of fast-acting surge suppression criteria for power lines can be found in the TelcordiaTechnologies publication TR-NWT-001011, Generic Requirements for Surge Protective Devices(SPDs) on AC Power Circuits. Examples of fast-acting surge suppression criteria for telephone linescan be found in the Telcordia Technologies publication TR-NWT-001361, Generic Requirements forGas Tube Protector Units (GTPUs).

A.13.8.1

Sensitive electronic equipment includes computers, telecommunications equipment, and two-wayradio systems.


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A.14.2.1

The ability to have access to a telephone system not maintained and operated by the AHJ allows forcontinuity of communication with ERFs. An AHJ's internal telephone system, using a system such asprivate branch exchange (PBX), is not considered a commercial telephone system.

A.14.2.2

Such an arrangement is not meant to apply to the office of the chief and other executive officers or tothe communications center, which can be housed in an ERF.

A.14.6

Local area network (LAN) computer and telephone cable are examples of communicationsconductors.


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A.15.1.2

In the case of equipment such as repeaters, transmitters, towers, and generators, access needs to beavailable at all times.

A.15.2.2

The AHJ can develop a certification program or use the certification programs of others. Examples ofother certification programs are Associated Public Safety Communications Officials International,International Municipal Signal Association, and National Academies of Emergency Dispatch andPower Phone.

A.15.3.1.1

In jurisdictions receiving fewer than 730 alarms per year (an average of two alarms per 24-hourperiod), provision of a dedicated telecommunicator might not be necessary where alternate meansapproved by the AHJ can affect the prompt receipt and processing of alarms in accordance withSection 15.4. Telecommunicator staffing is an important issue in achieving prompt receipt andprocessing of events. Consider the following two concepts of communications center operations:

(1) Vertical Center. A single telecommunicator performs both the call-taking and dispatchingfunctions.

(2) Horizontal Center. Different telecommunicators perform the call-taking and dispatching functions.

Telecommunicators working in a vertical center are known to engage in multitasking that can inhibittheir ability to perform assigned job functions. Routine evaluation of telecommunicator staffing,number of inbound emergency and nonemergency calls, and other operational statistics arenecessary to allow a prompt receipt and processing of events.

A.15.3.1.2

The processing of N-1-1 calls or other nonemergency 7- or 10-digit calls should not degrade or delaythe processing of any emergency calls.

A.15.3.2

The issue of communication capabilities and/or failures is cited by the National Institute forOccupational Safety and Health (NIOSH) as one of the top five reasons for firefighter fatalities. Theimportance of an assigned telecommunicator for specific incidents is a critical factor in incident scenesafety. The assignment process should be outlined in specific SOPs within each agency representedin the communications center. This assignment process is further assisted when acommand/communications vehicle is being staffed at the incident scene.

A.15.3.4

The supervisor position(s) in the communications center are provided in addition to thetelecommunicators positions. Although supervisory personnel are intended to be available forproblem solving, the supervisor position is permitted to be a working position.


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A.15.4.1

Statistical analysis for performance measurement should be completed over a period of 1 month asshown in Figure A.15.4.1(a) and Figure A.15.4.1(b).

Figure A.15.4.1(a) Event Timeline Where Primary PSAP Is Communications Center.

Figure A.15.4.1(b) Event Timeline Where Primary PSAP Is Other Than CommunicationsCenter.

A.15.4.2

PSAPs, 9-1-1 authorities, and responder agencies should look at the processing times in acomprehensive manner. Transfers, especially multiple transfers, have the impact of makingcompliance with the overall processing time standard nearly impossible. Given the life safetyimplications for critical incidents, PSAPs should make every effort to reduce/eliminate transfers,thereby reducing the amount of time required to answer, process, transfer, and dispatch alarms.Potential strategies to reduce transfers include consolidation, either physical or virtual, CAD to CADintegrations, improved wireless call routing, and improved compliance with call answering standards.See Figure A.15.4.1(a).

A.15.4.3

Events should be retransmitted to emergency response personnel as soon as the location andgeneral nature of the emergency have been ascertained by the telecommunicator. However, for someevents involving criminal activity, the safety of emergency response personnel could require thetelecommunicator to ascertain additional information from the caller, such as a description(s) of thesuspect(s), a description(s) of the vehicle(s), the direction of travel, and the weapon(s) involved,which could make compliance with the 60-second time limit impractical. Therefore, the AHJ for eachlaw enforcement agency served by the communications center should establish time frames for thedispatch of law enforcement personnel in accordance with the corresponding agency's SOPs.

A.15.4.4

The following types of calls where there is an imminent threat to public safety should be included inthe highest prioritization level:

(1) Active shooter/hostile event

(2) Domestic violence with weapons

(3) Officer-involved shooting

(4) Robbery in progress

(5) Other calls as determined by the AHJ

A.15.4.5

See Figure A.15.4.1(b).


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A.15.4.8

The first unit to arrive at an emergency incident is responsible for notifying the communications centerby radio of its arrival and for providing a brief description of the conditions observed and the preciselocation of the incident. The responding officer should report arrival and should establish the initialcommand post at the emergency. As soon as conditions allow, the incident commander should reportsupplementary information to the communications center and should make additional progressreports if operations keep the units at the emergency longer than a few minutes. An extended orcomplex emergency incident can necessitate the use of a communications unit for effectivecoordination, command, and control.

A.15.4.9

The audible warning or signal is typically a distinctive tone.

A.15.4.11

The assignment of a communications officer/unit leader to incidents that are more complex ensuresthat adequate communication is achieved using available telephone and radio systems. Such anassignment also ensures that the availability of existing frequencies or networks is maximized andthat system overloading is minimized. An assigned communications officer can be particularlyimportant and useful during multi-agency fires and other incidents. It can be necessary to establishspecific nets and monitoring systems to guarantee communications in some situations. In complexincidents, communications discipline is critical in avoiding system overload.

A.15.4.12

The common emergency organization, that is, the incident management system (IMS), includes twoimportant communications concepts as follows:

(1) Common Terminology. All participating departments and agencies use clear text and establishedstandard terms and phrases. In multi-agency emergencies, it is extremely difficult to guaranteethat all agency and department codes represent identical meanings. To avoid potentialmisunderstandings between telecommunicators, the IMS requires clear text or plain language forall radio messages. Although this is a significant departure from public safety agency tradition, ithas been found to be efficient in actual practice.

(2) Integrated Incident Communications. Participating departments and agencies plan in advance forthe use of integrated radio frequencies to tie together all tactical and support units assigned to anincident. To ensure the best possible use of all participating department and agency radios atmajor incidents, an Incident Radio Communications Plan matrix is developed. The matrix lists allavailable radio systems on an incident and aids in assigning them to provide command, tactical,and logistical coverage for a complete operation.

Preparation of the matrix necessitates training and a knowledge of cooperating department andagency frequencies and radio components. Use of the matrix is greatly enhanced by the existence ofa frequency-sharing agreement. (See Annex F.)

The Federal Communications Commission (FCC) has no prohibition against public agencies sharingfrequencies during emergencies, provided that the responsible agency has granted permission toassisting agencies to do so. The agreement specifies the mutual permission of participating agenciesto use other agency frequencies when providing assistance. The agreement lists the terms andconditions of use by others and includes all frequencies that can be made available under criticalconditions. Such agreements facilitate better multiagency dispatching and incident communicationsand can be prepared by groups or agencies who work together frequently.

A.15.4.12.2

These communications links can include but are not restricted to a number of methodologies,including radio, data communication, face-to-face, satellite communication, or telephone. Suchcommunication links permit units from multiple agencies to interact with one another and to exchangeinformation according to a prescribed method in order to achieve predictable results. These linkspermit communications between agencies when needed but not necessarily with every unit involvedat an incident at all times.

A.15.4.12.2(3)

Extended operations can include long-term disaster recovery, security at major events, or criminaljustice surveillance.


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A.15.4.16

Effective communication among emergency response personnel during the initial response to anymajor incident and throughout its extended operations has a significant impact on the rapid mitigationto the affected population.

A plan should lend itself to rapid activation in case of an incident. These incidents include majorstorms, conflagrations, hazardous materials incidents, wildland fires, mass transit accidents, domesticterrorism, and other incidents that can overwhelm the agencies serving the community and theirnormal resources.

The plan should include all agencies that normally would be utilized to mitigate any major incident.The plan should also include the communication integration of all agencies into a command structure.Additionally, the plan should include the communications path for transition to the next level ofsupport.

The plan should include SOPs that outline the following:

(1) Activation of such plan

(2) Radio systems to be utilized

(3) Assigned radio frequencies and bandwidth for conventional or trunked systems

(4) Talkgroups

(5) Unit/agency designations

(6) Talk paths to be utilized (e.g., gateway, cross band repeaters, and telecommunicator assisted)

The plan should define applicable continuous tone-coded squelch system (CTCSS) codes, incompliance with TIA-603-D, Land Mobile FM or PM — Communications Equipment — Measurementand Performance Standards, for analog channels designated for interoperability.

The plan should define interoperability channels designated for digital operation. These channelsshould be compliant with ANSI/TIA/-102.BAAA, FDMA Common Air Interface.

A.15.4.16.1

The key to the successful operation of the various resources into a region depends heavily upon theability of all public safety agencies to communicate effectively with each other in real time. At aminimum, interoperability should be supported at the command level. It is not required that everyresponder have total interoperability with every other responder.

A.15.4.16.2

Exercising this plan identifies areas that need improvement.

A.15.4.19

Procedures for handling telecommunication relay services (TRS) calls should be included in theSOPs.

A.15.6.1(3)

Recording by telecommunicator position, rather than by line, allows all telephone lines that are usedin the communications center to be taped using a minimum of recorder resources.

A.15.7

The purpose of the quality assurance program is to follow up and review calls with communicationscenter employees, improve procedures, and make the corrections needed to improve service andresponse. Generally accepted statistical methods should be used when selecting calls for review.


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A.16.1

Cellular or Internet personal communications services (PCS) systems include such devices aspersonal digital devices, advanced voice and data devices, and other cellular-based wirelesssystems. Text messaging, Internet access, cable modems, and other devices using wireless fidelity(WiFi) all use voice over Internet protocol (VoIP).

A.16.2.1.2

The separate business number listed in the telephone directory and used for nonemergencypurposes should terminate at a location where personnel are on duty at least 40 hours per week,Monday through Friday.

A.16.2.3.6

A telephone line terminating at an unstaffed ERF and provided with a recorded message should notbe used to meet the intent of the business line (nonemergency) listed in the directory and assignedfor business (nonemergency) use as specified in 16.2.3.4.

A.16.3(1)

In no case is it ever recommended that the telephone system be designed at less than P.01 GOS. Anindustry standard traffic study should be conducted that meets the public safety requirements of theAHJ.

A.16.3.4

The monitoring service is to be provided by the 9-1-1 vendor. Monitoring at the communicationscenter itself is not sufficient, since a failure at the communications center can also involve a failure ofthe monitoring and also does not cover situations where 9-1-1 calls are not completed due to cablefailure or intermediate central office failure.

A.16.3.5

Automated voice alarms, by their design, repeat their message many times and, therefore, canmonopolize an inbound line for a considerable time. Therefore, they are not permitted to connect withpublished emergency numbers, and their use is not encouraged. Many state and local statutesprohibit such connections to designated emergency lines or to 9-1-1.

A.16.3.9

There are 38 million people with hearing-related disabilities that depend on non-voicecommunications, such as SMS messaging, to access emergency services and others who utilize thismethod of communication.

A.16.4.3.1

Call delivery paths can include analog as well as IP call delivery.

A.16.4.3.2

Two circuits run in the same conduit, duct bank, or trench or run on the same pole line do not providethe level of safety intended by the committee.

A.16.5.1

See NFPA 1600 for additional guidance.

A.16.5.4(2)

The AHJ can approve a queuing system for calls on emergency lines. Such systems often require theadditional approval of regional, county, or state authorities.

A.16.6.1

The MLTS must be programmed to allow a user to dial 9-1-1 without first having to dial 9 or any othernumber to reach the public switched telephone network. For example, 9-9-1-1 is not permissible.

A.16.6.2

The dialable number is used by the Public Safety Answering Point to call the 9-1-1 caller back in theevent more information is needed or a call is dropped before sufficient information is obtained toinitiate a dispatch.


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A.16.6.3

There are multiple methods to meet this requirement. Incumbent and competitive local exchangecarriers offer private switch ALI, commonly known as PS/ALI services. PS/ALI allows the MLTSowner to manage the location associated with the extension’s telephone number. In addition,commercial services are available to both automate and act as an MLTS agent in providing andmaintaining ALI for extensions that have both static and dynamic locations.

A.16.6.3.1

This matches the location granularity stated within the proposed model MLTS legislation in NENA06-750 v3, “NENA Model Legislation E9-1-1 for Multi-Line Telephone Systems.”

A.16.6.3.2

This matches the location granularity exception stated within the proposed model MLTS legislation inNENA 06-750 v3, “NENA Model Legislation E9-1-1 for Multi-Line Telephone Systems.”


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A.17.1.1

Communications centers that dispatch for volunteers or paid-call personnel have the responsibility ofsummoning such personnel at any hour of the day or night. Personnel can be summoned by the useof the telephone or radio, supplementing sirens or horns that provide an outside alarm. Events canbe telephoned to the central telephone office where the telephone telecommunicator can start asiren or operate an air horn to indicate that there is an event. In areas where a communicationscenter is not attended 24 hours a day, telephone companies can provide a telephone line thatconnects to special telephones that are located in places of business or residences selected by thejurisdiction. The jurisdiction then arranges to activate the telephone lines. In emergency responseagencies that have an emergency response facility desk attendant, the telephone centraltelecommunicator can call the ERF, and the attendant can sound the outside alarm to callvolunteers. If there is a code-sounding siren or air horn, coded signals can be sent. Usually atransmitting apparatus is used to send out the code.

If radio equipment is used, a receiver with selective calling equipment can be placed in the home ofeach volunteer or call person. Selective signaling is accomplished on a group-call principle, allowingthe volunteer or call forces to be divided into several groups that can be summoned as a whole or asindividual groups to handle a particular incident. Pagers are commonly used for this purpose, sincethey can be carried anywhere. Pagers can include either a tone alarm, a voice receiver, or a digitaldisplay.

A.17.1.1.3.2

In jurisdictions receiving fewer than 730 events per year (average of two events per 24-hour period),a second dedicated dispatch circuit might not be necessary.

A.17.1.1.3.3

When an event is transmitted to an ERF, it should be audible throughout the ERF, without the timedelay caused by a responder going to a telephone instrument, picking up the handset, and thenrelaying the information to other affected responders.

A.17.1.1.4(2)

System elements can include but are not limited to transmitters, transceivers, repeaters, receiversand receiver comparators (where required), microphones, encoders, control circuitry, antennas, andappropriate ancillary devices to constitute a complete radio system. Audible monitoring for integritycan be accomplished by a receiver in the operations room operating on the dispatch channelproviding side tone audio. Visual monitoring for integrity can be accomplished by receiver moduleindication(s) of audio on the dispatch channel. It is not the intent of this requirement to requireduplicate equipment at each ERF for a voice radio primary dispatch circuit.

A.17.1.1.4(4)(a)

It is not the intent of this requirement to require a redundant digital data radio transceiver at eachERF, unless the ERF is a location that retransmits the signal to other ERF receivers, transceivers, orpagers. Transceivers designed for wide area coverage do not necessarily meet requirements forredundant transceivers.

A.17.1.1.5.1(2)

Where the primary dispatch circuit is provided through a radio system, regardless of whether thesystem is a conventional radio, a trunked radio, or a microwave radio, the system cannot also beused to provide the secondary means of dispatch.

A.17.1.1.5.1(2)(a)

In 17.1.1.5.1(2)(a)ii, a separate receiver is not required for each ERU.

A.17.1.1.5.1(3)(a)

In 17.1.1.5.1(2)(a)(i), the separate control/relay switching equipment connection ports in the ERF arepermitted to connect common audio alerting devices and auxiliary equipment such as audioamplifiers and loudspeakers, ERF response lights, and printer equipment.

A.17.1.1.6

The audible warning or signal is typically a distinctive tone.


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A.17.1.2

Portions of any dispatch system circuit can need a metal wire connection, such as a wired cablefrom a microphone to the transmitter/receiver equipment of a microwave/radio dispatch circuit. Suchwired circuit connections in a portion of a radio or telephone dispatch circuit do not constitute a wireddispatch circuit where all transmitting facilities are local to the communications center. Where suchconnections are between the communications center and one or more remote transmitting orrepeater facility sites, a connection between the communications center and the remote facility sitedoes constitute a wired dispatch circuit, requiring monitoring for integrity fault or failure trouble signalannunciation if signal transmission failure occurs.

A.17.1.2.1

Polling or self-interrogation is one of many methodologies that can monitor a dispatch circuit todetermine its integrity. Polling allows for remote and automatic querying of dispatch channelelements to verify their functionality periodically when the elements have not otherwise reported afault or failure. The self-interrogation feature of polling equipment allows the overall system todetermine and verify its own integrity.

A.17.1.2.6

Audible and visual indications of faults or failures annunciated to an off-site vendor support centerand pager signals of fault conditions to field technicians are ancillary to fault and failure indicationsbeing received at the communications center for the telecommunicator and any other location for theAHJ radio system manager, such as a county or regional microwave and radio system operationsfacility.

A.17.2.1.1

This refers to a Type B Automatic Telegraph System where several box/alarm circuits come into aremote location and pass through concentrator/identifier-like equipment. The signal is sent on to thecommunications center via a separate tie circuit. It eliminates having to run all box/alarm circuitsback to the communications center. (Refer to 27.5.2 of NFPA 72).

A.17.3.1.1

Frequencies, their assignment, and the widths of channels are regulated throughout the world. In theUnited States, the FCC provides this regulation through allocation, licensing, and rules for all exceptfederal government allocations. In Canada, the comparable regulating agency is Industry Canada.The National Telecommunications Information Administration (NTIA), under the U.S. Department ofCommerce, performs functions similar to the FCC, but only for federal agencies. Wire, line, and radiocommunications are subject to FCC rules and regulations, which govern many areas of radio usageknown as service. Of primary concern to emergency communications systems users are the publicsafety radio services, which provide for the use of radio communications systems by nonfederalgovernmental entities.

A.17.3.1.2.2

It is recommended that the system be designed for DAQ of 3.4.

A.17.3.1.3

The communications center should have the ability to monitor all radio communications, includingthose communications on tactical radio communications channels, where practical. The AHJ shouldcarefully evaluate the various communication solution alternatives available, providing the incidentcommanders with the appropriate mix of communications capabilities to address their specificscenarios, ranging from a small rural residence to a mammoth concrete and steel structure in anurban downtown area. The AHJ should provide a simplex radio communications channel for use inlocations outside the coverage area of any installed radio infrastructure.

If the simplex frequencies selected for tactical use are the same as the output frequencies of anyrepeaters used by the system, a method of positive lockout of automatic system use of thatfrequency should be provided, controlled from the responsible telecommunicator workstation.


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A.17.3.1.4

The AHJ should provide at a minimum a simplex radio communications channel for use in locationsoutside the coverage area of any installed radio infrastructure or for off-network operations such asincident tactical communications (e.g., “fireground”). Various communication solution alternatives areavailable for on-scene tactical communications. If a solution other than simplex analogcommunications is determined by the AHJ to best address that agency’s needs, requiring a simplexanalog channel requirement provides a secondary communications choice if for some reason thepreferred alternative becomes unusable. This requirement also allows for incidents such as mutualaid scenarios, when responding agencies might utilize a different methodology in their own day-to-day operations. Additionally, the communications center should have the ability to monitor all radiocommunications, including those communications on tactical radio communications channels, wherepractical.

A.17.3.1.5

The intent of 17.3.1.5 is to provide flexibility to the AHJ to use trunking, if desired, on the tactical on-scene channel, but there must be the provision of using simplex direct analog mode for any reason itmight be required.

A.17.3.1.6

This does not prohibit the use of field-deployed portable repeater systems.

A.17.3.2.3(3)

The public Internet is not acceptable because it is not under the control of the AHJ. The use of acommercially available network is acceptable if the network is dedicated to public safety orgovernment-only use.

A.17.3.3.1

Coded squelch systems could utilize a specific tone or digital code, transmitted continuously,simultaneous with the desired message traffic. Examples of such a tone or code are a continuoustone-coded squelch system (CTCSS) and a continuous digital-coded squelch system (CDCSS).Analog trunked radio systems utilize a digital code for system access, specific to that analog trunkedsystem, which accomplishes the same goal.

A.17.3.4.1

In a digital access radio system, all units turned on and unassigned within the radio system coveragearea monitor the signaling channel. Talkgroup assignments, emergency assignments, individualsignaling calls, and special signal calls are broadcast to all monitoring units on the signaling channel.Requests for service (e.g., talkgroup calls, emergency calls, selective alerting) from unassigned unitsare transmitted by the requesting unit, as data bursts, to the system on the signaling channel.

A.17.3.4.1.5

While it is possible to find units that will scan both trunked talkgroups and conventional channelssimultaneously, there are operational issues that must be understood in such operations. Anytime amobile or portable unit scans off its home trunked talkgroup to other conventional channels or othertrunking talkgroups, the radio runs the risk of missing some or all of new transmissions on the hometalkgroup during the time that the radio is off the home trunked talkgroup. For that reason, if userradios cannot afford to miss transmissions on the home trunked talkgroup, either scanning shouldnot be used, or a separate radio should be provided to allow one radio to scan and the other radio toremain on the home trunked talkgroup.

A.17.3.4.1.8

A system manager terminal allows the system supervisor to assign individual or talkgroup prioritylevels, or both, to all field units. The signaling language is structured so that access to the system isin accordance with the level of priority involved.

A.17.3.4.1.9

The emergency level of priority is intended for use only when immediate communications arenecessary to preserve safety or protect life.

A.17.3.4.1.10

Trunked radio systems often are configured with many more talkgroups than can be accommodatedby available voice channels. During a system controller failure, radios devolve to particular repeaterchannels and operate conventionally, which could result in overcrowding or busy channels. The AHJshould require emergency services units to devolve to channels reserved specifically for emergencydispatch.


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A.17.3.4.1.11

Handling requests by units that have been involved in recent conversations before processing andassigning channels to units not involved in any recent conversations is intended to keep currentconversations from becoming fragmented by any delays that could be caused by a new user requestfor a channel.

A.17.3.4.1.16

The alert should have a different sound from any other audible alert capable of being generated bythe field unit. This enables the end user to determine that the unit is out of contact with the system.

A.17.3.4.1.17

The disabling of a field unit should prevent the unit from monitoring any voice communications onany channel or talkgroup in the system. A disabled unit should not be able to transmit or otherwisejoin into any voice conversation on the system. This disabling function occurs while the field unit ison the system anywhere within RF coverage. The system should have the capability to automaticallysearch for the unit multiple times, if so requested by the telecommunicator, and indicate when itsucceeds in disabling the unit.

A.17.3.4.1.17.1

Several reasons for disablement can be a stuck microphone, the unit is out of frequency, or the unitis lost.

A.17.3.4.1.18

Remote talkgroup assignment is also known as dynamic regrouping. The system should include theability to perform this function manually, as well as with a stored software plan, to allow for theautomatic programming of many units into predetermined talkgroups. This preprogramming allowsthe saved plan to be initiated by the telecommunicator at any future time.

A.17.3.4.1.19

Telephone interconnect, while a popular selling point for trunked radio systems, represents asignificant load on the system because it monopolizes one RF channel of the trunked system for theduration of the call. Multiple telephone calls can cause two-way voice users to receive busyindications from the system.

A.17.3.4.1.24

In the design and operation of a trunked radio system, dispatching of events has to have priority overall other communications and is equal in priority to emergency messages from the field. For thisreason, when units are dispatched over radio, the necessary priority is high enough to require“ruthless preemption,” which is the seizure and re-use of channels already in use by otherconversations previously defined as lower in priority.

A.17.3.4.2

Digital trunked system subscriber units operating in the United States on the 700-MHz narrowbandpublic safety spectrum and complying with ANSI/TIA-102.AABF-A, Link Control Word Formats andMessages New Technology Standards Project — Digital Radio Technical Standards, andTIA-102.BBAC, Two-Slot TDMA MAC Layer, must also comply with ANSI/TIA-102.BAAA, FDMACommon Air Interface, in order to operate on the required designated nationwide 700-MHznarrowband interoperability channels.

A.17.3.5

The committee is monitoring the development of the nationwide FirstNet project. FirstNetdevelopment was established by Congress when it enacted the Middle Class Tax Relief and JobCreation Act of 2012. This act required the development of a nationwide interoperable broadbandnetwork to enable all emergency service agencies to have improved data communications utilizingthe new LTE broadband commercial technology. At the time this edition was being revised, thedevelopment of the FirstNet system was in the preliminary stages. The committee will monitor thedevelopment of FirstNet for future inclusion in this standard.

A.17.3.6

The committee is monitoring the development of the nationwide FirstNet project. FirstNetdevelopment was established by Congress when it enacted the Middle Class Tax Relief and JobCreation Act of 2012. This act required the development of a nationwide interoperable broadbandnetwork to enable all emergency service agencies to have improved data communications utilizingthe new LTE broadband commercial technology. FirstNet has a website: www.ntia.doc.gov/category/firstnet


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A.17.3.6.12

Intrinsic safety (IS) is a protection concept associated with the rating of equipment for operation inpotentially hazardous atmospheres. IS ratings take into account the nature of the explosiveatmosphere encountered — Class I being explosive gas atmospheres and Class II being explosivedust atmospheres — and the frequency or interval of the presence of such explosive atmosphere —continuously, intermittently, or abnormally. The frequency or interval of the presence of the explosiveatmosphere determines the proper division (Division 1 or Division 2) or zone (Zone 0, Zone 1, orZone 2) classifications that are applied to a particular IS rating. To determine the appropriate ISrating for portable radios, the AHJ identifies the expected explosive atmospheres likely to beencountered and the expected frequency or interval of the presence of such expected explosiveatmospheres.

A.17.3.7

Emergency situations that result from large fires, transportation accidents, floods, severe storms,and other disasters often create a need for a temporary communications center to be located closeto the scene of the disaster. Such a need is filled by a communications vehicle, sometimes called amobile command post. The vehicle, which is a mobile command and control headquarters, serves asthe hub from which the activities necessary to control an emergency situation can be directed andcoordinated without dependence on the department's fixed communications center. Such activitiesfor the control of emergencies include the efforts of local and outside departments and of otherpublic safety organizations, such as police departments and emergency management agencies, inaddition to public utilities. Proximity to the site of the disaster provides communications vehiclepersonnel and those in command with immediate access to the latest information in situations wherechanges occur rapidly. In addition, the ready availability of communications provides the means tocall for additional help or to inform other jurisdictions of the situation. A communications vehicleshould carry a variety of equipment that allows communication with other emergency responseagencies, public safety organizations, and utilities. Other equipment that can increase the flexibilityof the system includes cellular telephones. Some vehicles can be equipped for mobile relayoperation that allows them to pick up transmissions of mobile units and to retransmit them to thecommunications center at higher power levels or on different frequencies. The communicationsvehicle can provide the following:

(1) Ability to exchange data messages between vehicles and communications centers or ERFs

(2) Improved command and control by television transmission of emergency activity tocommunications centers or ERFs

(3) Facsimile transmission of maps, preplans, and other written data

(4) Vehicle tracking and geographical locations, which can include global positioning system (GPS)receivers


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A.17.3.8.1(2)

A star microwave system is a system in which one central site is common with all microwave pathsto multiple locations. See Figure A.17.3.8.1(2)(a).

Figure A.17.3.8.1(2)(a) Star Microwave System.

A ring microwave system is a system in which the individual sites are connected in a linear orcircular pattern. See Figure A.17.3.8.1(2)(b).

Figure A.17.3.8.1(2)(b) Ring Microwave System.

A.17.3.8.3.2

The intent of this requirement is to ensure that the design of the microwave system takes intoaccount the possible presence of commercial broadcast equipment in the vicinity of the proposedmicrowave location. The microwave equipment and the commercial broadcast equipment can be co-located on the same physical site with shared or independent antenna support structures. Themicrowave equipment and the commercial broadcast equipment also can be located in closephysical proximity of each other, with independent antenna support structures. In either case, thedesign of the microwave system at the site has to account for possible interference to and from thecommercial broadcast equipment.

A.17.3.8.5.1

Components, in this context, refers to modular elements such as transmitters, receivers, modems,power supplies, switching devices, multiplexers, and service channels/orderwire equipment.

A.17.3.8.5.4

Examples of alarms are input power failure, transmitter RF output, radio off frequency, and excessivebit error rate.


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A.17.4.2.1

Paging systems not under the direct control of the AHJ are permitted to be used for administrativepurposes but are not considered acceptable for use as a required dispatch system. Third-partypaging systems not under the control of the AHJ often do not have the redundant design architectureto comply with 17.1.1.4. Third-party paging systems often rely on satellite communications, whichhave proved faulty in the past. Third-party paging systems might also employ first-in-first-out (FIFO)hierarchy for message delivery that can cause significant delays during periods of high usage, whichis not considered suitable for emergency services communication.

A.17.4.2.7

This feature is implemented with an acknowledge/silence button, so that a user who is not presentwhen the initial alert is received by the device will be prompted regarding the call.

A.17.4.2.11

These pre-programmed pager buttons can be used to notify the operations room that the user isresponding, on-scene, or in service following the call.

A.17.4.2.12

The operations room, as the control point for the pagers, should have the ability to monitor theperformance of the paging system, as well as the ability to display the messages directed to thetelecommunicators.

A.17.4.3

Alerting receivers, sometimes also known as home receivers, can occasionally also be found atemergency responders' places of business. They typically operate from standard wall plug 120 VAC.The devices should include an integral backup battery with charging circuit to maintain operationwhen normal ac power is interrupted.

A.17.6.3

U.S. Army Technical Manual TM 5-811-3, Electrical Design: Lightning and Static ElectricityProtection, provides additional guidance.

A.17.6.7

The use of radio communication enhancement systems has become prevalent throughout the UnitedStates. Safety features and flexibilities of radio systems include the following:

(1) Full building coverage is allowed to facilitate communications from any point within the building,in case access to the wired two-way communications system is compromised.

(2) Communications can be conducted between emergency responders in the field to allow quickerdissemination of safety and emergency information.

(3) Emergency responders typically carry individual radios, allowing the responders to provideinformation or request assistance individually, which can be important if crew members becomeseparated during an incident.

(4) Radio systems permit “firefighter or public safety officer down” emergency calls in case of injury— by the push of a single button, a call is placed to a central location to initiate a roll call todetermine which emergency responder has been injured and requires assistance. Radiosystems can employ an emergency call where, by the push of a single button, an emergencyresponder call can be given prioritized system access to allow wide-range communication.

(5) The AHJ can determine whether the in-building coverage is for tactical on-site communications,for communications to an off-site dispatch center, or both.

A.17.6.8

Many radio systems are in use by public safety agencies in the United States. A number of themhave different operational characteristics. A prescribed signal strength measurement might notproduce usable voice communications for all systems (e.g., VHF, UHF, 700/800 MHz, analog, P-25,4 slot TDMA, 2 slot TDMA, etc.). Requiring the AHJ to provide operational parameters required forusable voice communications for the systems in use eliminates possible confusion regarding thespecified value, as determined by the AHJ. A better indicator of proper system performance andcoverage is to use the DAQ audio quality measurement system whether the signals are eitheranalog or digital.

A.17.6.8.1

Inbound (or downlink) is commonly referred to as base station to portable. It is recommended thatsystems be designed for DAQ 3.4.


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A.17.6.8.2

Outbound (or uplink) is commonly referred to as portable to base station.

A.17.6.10.2

There is an ongoing national effort to eliminate current interference issues between cellular carriersand public safety bands in the 800-MHz band. This effort could revise the actual frequencies forpublic agencies within this band. The public safety radio enhancement system design should becapable of being changed to accommodate updated frequencies to allow maintenance of theminimum system-design criteria. Two-way radio communication enhancement systems that are usedto comply with the requirements of Section 17.6 should be tested in accordance with 19.3.9 and19.3.9.1. Also note that this is not easily done at VHF because of filters and non-standard Tx and Rxspacings.

A.17.6.11.1

Radio licensing authorities in some countries have distinctions between consumer-grade andindustrial-grade two-way radio communications enhancement systems. The intent of thesedistinctions is to ensure that industrial grade devices are used in public facilities, instead ofconsumer devices, which are usually held to a lower technical standard, and cannot be required tobe certified by or registered with the radio licensing authority. The AHJ should become cognizant ofthese differences operating in his or her country and jurisdiction, and be certain that the devicesused in his or her system are suitable to the purpose of a system used and depended upon by publicsafety users. For example, in the United States, the FCC published Use and Design of SignalBoosters Report and Order 13-21, which took effect in March 2014, and established requirements forconsumer-grade and industrial-grade signal boosters. Additionally, under FCC regulations, someindustrial signal boosters are Part 90 signal boosters used for public safety land mobile radiosystems — as opposed to those used for public cellular wireless carriers— which include type Asignal boosters (i.e., channelized) and type B signal boosters (i.e., broadband). Type B devices mustbe registered with the FCC before being used because of the potential for broadband devices tocause interference if improperly installed.


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A.18.1.1

The AHJ should consider the performance requirements of this standard, particularly the timerequirements of Section 15.4, in their decision making regarding the use of CAD.

A.18.1.2

This will provide a seamless transition so that call tracking will be complete from the call receiptphase through the dispatch phase, permitting the performance objectives in Section 15.4 to be fullymeasured. The AHJ should work with the telecommunications providers to ensure that all dataelements required by the CAD are provided by the 9-1-1 system.

A.18.1.2.1

The CAD system should be capable of accepting text-based emergency call data. Where suchability is provided, the CAD system should incorporate the text-based emergency call data into theCAD call-for-service record.

A.18.2

A secondary dispatch method can include a separate isolated system, a manual system, printedbackup books, visual display boards, or other methods as approved by the AHJ.

A.18.3.5

There is a danger that routine traffic and unintended network faults can affect the ability of criticalparts of the CAD system to communicate with each other, unless the CAD system and any othercritical dispatch system components are segregated from the general network and a strict screeningprogram is in place to protect the CAD.

A.18.4.1.2

Other data elements that could be used, based on the functionality needed by the AHJ, are thefollowing:

(1) Units responding from sending agency

(2) Status changes from units (ongoing)

A.18.4.4

Other systems could include intelligent transportation systems, SMART building managementsystems, pre-fire/pre-incident software systems, and so forth.

A.18.5.3.2

Insufficiency can be the result of a brownout (defined as a condition where the voltage supplied tothe system falls below the specified operating range) or the loss of one or more but not all of thephases of the power supply.

A.18.5.6

Resources can include but are not limited to ERUs, individuals, equipment, or other assets.

A.18.5.6.1

Examples of safeguards include placing source code, documentation, and flow charts into escrow.

A.18.5.7.2

The requirements for audible notification for all text message activations regarding events applyeven if there are other methods of notification installed and used at the ERF.

A.18.6.1

Memory storage, random access memory (RAM), network throughput, etc., should accommodatethe call volume, call types, and other sizing parameters that are required by the AHJ.

A.18.6.4

The 2-second requirement envisions a worst-case scenario with a heavily loaded system during thebusiest periods. Response time under average conditions should be much less.

A.18.6.6

A power-fail recovery capability is the ability of the system, upon restoration of power, to reboot andarrive at its previous state. This allows restoration of system function without requiringtelecommunicators to leave their positions.


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A.18.7

Backups can be accomplished on tape, DVD writer, or disk storage arrays in a redundant array ofindependent disks (RAID) configuration. The AHJ should establish a schedule for the routine backupof data as well as periodic testing of the stored data system for effectiveness and completeness.Incorporating multiple backup methods is preferred, augmented by off-site storage of backup files.

Sufficient testing should occur on the backup systems to verify the completeness and accuracy ofthe backup and recovery data and process, including switching back to the primary system.

A.18.8.1.4

The AHJ should evaluate trends in the industry towards virtual environments. There are pros andcons to this approach that bear investigation. The CAD system can be designed to allow for thedeployment of virtual servers, workstations, and storage at the discretion of the AHJ.

A.18.8.1.6

Examples are commercial alarm monitoring centers and telematics centers. An alternate method ofreceiving alarms is needed in the event the system fails. This can be a telephone, a memorandum ofunderstanding (MOU) with another PSAP, or even a duplicate system within the PSAP.

A.18.8.3

The AHJ should determine the data required to be logged for use by the operations room.

A.18.8.5

For the purpose of this subsection, any administrative display screens and keyboards beyond thoserequired for telecommunicator workstations that are not considered essential to the receipt anddispatch of emergencies could be considered as spare display screens and keyboards.

A.18.9.1

The capability should exist to move data to alternate, long-term storage for retrieval. Access to thedata should be restricted through security measures enabled by the AHJ.

A.18.11.1

MDCs can include any IP-enabled device (e.g., smartphones, tablets, laptops).

A.18.11.2.2

Store and forward technology can provide this functionality.

A.18.11.5.4

Additional functionality could include the ability to download updates for the MDC operating systemand applications using a wireless data communication system that is secure in accordance with theprovisions of Chapter 21. The MDC should have the ability to present appropriate displays ofdaytime and nighttime for the protection of the user.

A.18.12.1

Integrated mapping can be a function available to the MDC with similar functionality as a CADworkstation.


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A.19.3.9


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Test Procedures. The test plan should ensure testing throughout the building. Test proceduresshould be as directed by the AHJ.

Note: Testing procedures typically are done on a grid system. A grid is overlaid onto a floor area toprovide 20 grid cells. Grid cells are provided with definite minimum and maximum dimensions. Formost buildings, using a minimum grid dimension of 20 ft (6.1 m) and a maximum grid dimension of

80 ft (24.4 m) will suffice to encompass the entire floor area. Where a floor exceeds 128,000 ft2

(11,900 m2), which is the floor area that can be covered by the maximum grid dimension of 80 ft(24.4 m), it is recommended that the floor be subdivided into sectors each having an area less than

or equal to 128,000 ft2 (11,900 m2), and each sector be tested individually with 20 grid cells in eachsector. Signal strength measurements should be taken at the center of each grid and should beperformed using standardized parameters as specified in the notes of “Measurement Parameters”of this section. The delivered audio quality (DAQ) scale is a universal standard often cited in systemdesigns and specifications, using the following measures:

(1) DAQ 1: Unusable, speech present but unreadable.

(2) DAQ 2: Understandable with considerable effort. Frequent repetition due to noise/distortion.

(3) DAQ 3: Speech understandable with slight effort. Occasional repetition required due tonoise/distortion.

(4) DAQ 3.5: Speech understandable with repetition only rarely required. Some noise/distortion.

(5) DAQ 4: Speech easily understood. Occasional noise/distortion.

(6) DAQ 4.5: Speech easily understood. Infrequent noise/distortion.

(7) DAQ 5: Speech easily understood.

The DAQ scale comes from TIA TSB-88, Wireless Communications Systems Performance in Noiseand Interference-Limited Situations. A DAQ test is preferred to absolute RF signal levels for tworeasons: the DAQ test is easier to administer than RF signal levels, and DAQ is useful regardless ofthe type of modulation or system technology used (analog or digital). It measures what reallymatters — how the signal sounds to the user — regardless of manufacturer specifications.

The minimum allowable DAQ for each grid cell typically is three. Not more than two nonadjacentgrid cells should be allowed to fail the test. In the event that three of the areas fail the test, or if twoadjacent areas fail the test, in order to be more statistically accurate the testing grid resolutionshould be doubled. This would require decreasing the size of the grids to one-half the dimensionused in the failed test to a minimum of 10 ft (3 m) and a maximum of 40 ft (12.2 m). Further, tocover the same floor area, the number of grids is quadrupled to 80 grids. No more than eightnonadjacent and/or five adjacent grid cells should then be allowed to fail the test.

In the event that nine or more nonadjacent and/or six or more adjacent grid cells fail the test,consideration should be given to redesigning and reinstalling the public safety radio enhancementsystem to meet the minimum system design requirements. Failures should not be allowed in criticalareas. Measurements should be made with the antenna held vertically at 3 ft to 4 ft (0.9 m to 1.2 m)above the floor. The DAQ readings should be recorded on small-scale drawings that are used fortesting with the AHJ. In addition, the gain values of all RF-emitting devices and system componentsshould be measured and the test measurement results should be kept on file with the buildingowner so that the measurements can be verified each year during annual tests.

Two Portable Testing. To test the in-building radio enhancement system with two portable radios,the following procedure can be used: One portable radio should be positioned no greater than 10 ft(3 m) from an indoor distribution antenna or leaky coaxial cable. The second portable radio shouldbe positioned at a distance that represents the farthest distance possible in that location of thebuilding from an indoor distribution antenna or radiating cable. Both portables should besimultaneously keyed up on different frequencies or talkgroups within the same radio band, andlisteners on those different frequencies or talkgroups should verify that the voice messagesreceived were intelligible to DAQ 3.0. It is useful when performing these tests to use unfamiliarwords, such as from the Harvard Sentences list, when determining reception intelligibility.

Measurement Parameters. DAQ levels should be measured to ensure the system meets thecriteria of 17.6.7 according to parameters as directed by the AHJ.

Note: Downlink measurements should be made with the following standardized parameters:

(1) Receive antennas of equal gain to the agency’s standard portable radio antenna, orientedvertically, with a centerline between 3 ft to 4 ft (0.9 m to 1.2 m) above floor

(2) Levels recorded while walking an “X” pattern, with the center of the pattern locatedapproximately in the center of each grid area


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(3) The linear distance of each side of the “X” equal to at least 10 percent of the length of the grid’sside and a minimum length of 10 ft (3 m)

(4) Measurements sampled in averaging mode to include a minimum of one sample per each 5 ft(1.5 m) traveled recorded with not less than five samples per measurement recorded per sideof the “X.”

Acceptance Test. An acceptance test of the two-way in-building wireless communication systemsshould be scheduled with the AHJ. Acceptance test procedures and requirements should be asdirected by the AHJ.

Note: Typically, acceptance tests are required by the AHJ prior to building occupancy. As-builtdrawings should be provided including all system design parameters, other information requiredfrom the DAQ level and commissioning tests, including a full report with grid locations, DAQmeasurements, and RF-emitting device or system component gain values. The acceptance testtypically entails a random test by the AHJ of radio communication in various portions of the building,especially including the critical areas. The AHJ can review any test documentation and ensure thatthe findings of the commissioning test with respect to DAQ levels and gain values are supported bythe acceptance test.

If RF-emitting devices are used in the two-way radio communications enhancement systems, aspectrum analyzer shall be used to ensure spurious oscillations are not generated nor areunauthorized carriers repeatedly in violation of radio licensing authority regulations. This testingshould be conducted at time of installation and during subsequent inspections. Downlink and uplinkspectrum should be recorded with a maximum-hold screen capture at the active system airinterfaces with the system under normal load and at least one uplink carrier active on the indoorportion of the system. Measurements should be analyzed for correct gains on both uplink anddownlink paths, noise floor elevation from active components, intermodulation, and otherparameters determined necessary by the AHJ. Gain values of all RF-emitting devices and systemcomponents should be measured and the results kept on file with the building owner and the AHJ.In the event that the measurement results are lost, the building owner will need to repeat theacceptance test to re-establish the gain values.

Where the two-way radio communications enhancement system is shared with other non-publicsafety services, the testing of the public safety system should be made under simulated heavytraffic load conditions of the non-public safety services to ensure that the DAQ values, noise floors,intermodulation, and other parameters, as described by the AHJ for both in-bound and out-bound,are met for the public safety portion of the system.

Annual Tests. The AHJ should be notified in advance and should direct annual test procedures andrequirements. Note: Typically, annual tests require several items to be checked. RF-emittingdevices and system components should be tested to ensure that the gain is the same as it was atinitial installation and acceptance. Backup batteries and power supplies should be tested under loadfor 1 hour to verify that they will operate properly during a power outage.

License or Certification of Personnel. All system designs, installation, testing, and maintenanceshould be conducted, documented, and signed by an acceptable manufacturer or person inpossession of a current radio licensing authority license, industry certification, professional electricalengineering license, or as required by the AHJ.

Note: Many manufacturers of two-way in-building wireless communications systems providecertification programs for installing contractors. Local adopting jurisdictions could requirecertification of two-way in-building wireless communications system training for the installingcontractors issued by a nationally recognized organization or school, or a certificate issued by themanufacturer of the equipment being installed.


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A.20.5.1

The CAD system should record a history (audit trail) of the following actions taken with the items:

(1) Creation

(2) Change, including modification, deletion, or supplementation

(3) Disposition, including close-out, archiving, and transfer

(4) Inquiry to external data sources

Each entry in the history should include the following:

(1) Coordinated universal time (UTC) of action

(2) Identification of the individual performing the action

(3) Identification of the device on which the action was performed

(4) Effects of action on the characteristics of the items

A.20.7.4.1

The AHJ needs to look at federal and state guidelines for records retention and be cognizant of thebalance between the cost of long-term records retention and the need for records to be availablefor possible future legal purposes.


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Annex information in chapter 21 (formerly 13) needs review in the following areas: Table A.21.1 ,and in A. 21.x the following issues are missing: ransom ware attacks; device software updatingand methods to track same; cloud computing dangers and references; other reference materialincluding the latest NIST security framework, the latest SANS guidelines, the latest guidelinesfrom APCO, IACP, and the NG 9-1-1 standard; 2 factor authentication but issues with regard tocell phone SIM hijacking that render this form of 2 factor not as good; growing importance ofbacking up data with the growing incidence of ransomware attacks.

A.21.1


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Security issues for communications center data systems include the following:

(1) Security of data from outsiders

(2) Security of data from inappropriate access and modification from insiders

(3) Denial-of-service attacks

(4) Equipment and infrastructure failures that impede or prevent access to data

Many jurisdictions are providing public access to departmental records, some including CADrecords, through web browser access. Such unprecedented live access to files presents securityissues not previously considered, including but not limited to the following:

(1) Accidental release of privileged data, such as data protected by the Health InsurancePortability and Accountability Act (HIPAA) of 1996

(2) Deliberate or inadvertent impacts on the system that affect data availability to any of the users

Data systems give employees access to a wide variety of departmental data that were not easilyavailable before. Agency rules and regulations should be modified to specifically address themisuse of data as a breach of the confidentiality agreement used by the agency. With the move toInternet protocol (IP)–based networks for both the core network for land mobile radio systems aswell as IP-based telephony and IP-based Next Generation 9-1-1, it is important that a new holisticapproach to data security be taken. “Defense in depth” is an approach in which security is notresolved purely on a technical level but is also addressed across personnel and operations in aholistic risk management methodology. Therefore it is imperative that agencies implement alayered defense that will span the entire enterprise and is not purely technology focused. Thesedefense-in-depth strategies are outlined in Table A.21.1.

Table A.21.1 Defense-in-Depth Strategies

Defense-in-Depth Strategies for

People Technology Operations

Assignment of roles andresponsibilities (administrator,console, etc.)

Defense in multipleplaces and layers

Continuity of operationsand disaster recovery

Training of critical personnel (IAtraining class)

Passive attacks:encryption

Certifying and accreditingchanges to the baseline(configurationmanagement)

Personal accountability (logging)Active attacks:firewalls

Managing the securityposture (patchmanagement)

Physical security and personnelsecurity measures to control andmonitor access to facilities andcritical elements

Layered defenses(network firewall,host firewall)

Key management

Role-based accessIncidentresponse

Intrusion detection certifiedproducts

Critical communication systems have incorporated IP backbones and commercial-off-the-shelf(COTS) technologies. These recent changes from proprietary to open systems have had thefollowing advantages:

(1) Frequent technology refreshes

(2) Integration with other IT applications

(3) Use of standard administrative skills

(4) Better customer pricing


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(5) Improved product flexibility

(6) Reuse of existing fiber for backhaul

With these advantages comes the security disadvantage of openness. The protocols are widelydocumented, and the hardware is inexpensive and widely available. To mitigate the inherentvulnerabilities, steps should be taken in a layered defense-in-depth approach to address the risksto the communications center’s systems.

Additional information relating to security issues can be found in Annex F.

A.21.1.3

All employees are responsible for maintaining security. Employment contracts, collectivebargaining agreements, personnel manuals, and departmental directives should enforce thisrequirement. However, some personnel have primary responsibility for security, and theseemployee positions should be specified in the plan. Duties of these employees should include thefollowing:

(1) Analyzing the agency's security exposure

(2) Regular and/or automatic monitoring for security compliance

(3) Routine auditing

(4) Archiving of security events or incidents for auditing or study

A.21.1.4

Recent events have revealed that a common thread in many attacks the adversary gains thecredentials (user name and password) of legitimate users and is able to gain unfettered access tothe IT systems as a result. This is especially true of agencies that have experienced advancedpersistent threats (APTs) from determined adversaries. The Department of Homeland Security(DHS) provides a user education program called “Stop. Think. Connect”(www.dhs.gov/stopthinkconnect), which can be used as a foundation for such user training.


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A.21.1.5

The goal of any information system is to restrict access to the following persons:

(1) Those who are authorized to use the system

(2) Those who have a need to know

(3) Those who are responsible for auditing the system to ensure that policies and regulations areimplemented appropriately

(4) Those who are accountable for the actions of users who use and administer the system

Access control seeks to ensure confidentiality of information and integrity of information with role-based access control. With the philosophy that access control should involve the implementation ofleast privileges with authentication, authorization, and accountability (AAA), it is imperative thatagencies leverage products and services that assist with access control and provide a layereddefense in addition to the system’s physical and environmental security. For very sensitive accessto the network or certain computers and databases, two-factor authentication (something you knowand something that you possess) is recommended.

Comprehensive procedures for the maintenance of data security should include the following:

(1) Policies and procedures that specify the process and that authorize or deny access to the datasystem

(2) Policies for reviewing access to the system when employment status changes (promotion,demotion, discharge)

(3) Password security rules (aging, privacy, sharing issues)

(4) Differentiated access control within the system for different users

(5) Encryption and key control

(6) Maintenance of data security during disposal (paper shredding, hard disk destruction)

Encryption. As used in P25, land mobile radios should follow the guidelines outlined in theDepartment of Homeland Security (DHS) Office of Emergency Communications Guidelines forEncryption in Land Mobile Radio Systems. Use of proprietary forms of encryption, or analogencryption on analog radios, is not of sufficient strength to meet law enforcement or EMS HIPAArequirements.

Impersonation/Inappropriate Use. A key component within information assurance and accesscontrol is identity assurance, which addresses the risk associated with identity impersonation andinappropriate account use. The communications system should integrate authentication appliancesand associated tokens to provide the confidence to system owners that users accessing the criticalinfrastructure or communicating remotely as in Virtual Private Network (VPN) Remote Access aretrusted entities through the use of two-factor (or strong) authentication by which the user mustprovide three bits of information: account name, account password (something they know), and thetoken ID (something they have).

Additionally, the system should log all transactions and user activity, allowing administrators toutilize it as an auditing, accounting, and compliance tool.

Subscriber Unit Authentication. The authentication of subscriber units (radios) before beingauthorized access to the critical communication system is necessary for several reasons, the mostsignificant being the primary method of communication and necessity of continuous availability, thewide geographical wireless mobility, and the use of data on today’s land mobile radio systems. Inthe past, concern has focused on the ability of nonagency personnel monitoring communications,which has pushed the capability of encrypted voice communications, but it only addresses the risksassociated with confidentiality and integrity to a small degree. Without ensuring that radios andtheir users are allowed to be on the network and the talkgroups assigned to them, the systemresponds with “denial of service” because a false radio is assuming a valid radio's identity (lack ofavailability), false information is being placed on a trusted network (lack of integrity), and data arebeing stolen remotely (lack of confidentiality). It is therefore necessary to authenticate radios to thewireless system at a minimum and that they be mutually authenticated with systems that have ahigh level of risk and/or interoperability.


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A.21.1.6

The core of an information system is the network that permits the sharing of information betweensystems. This makes it a prime medium for infiltration but also an excellent source for preventingand detecting unauthorized behavior. It is critical to implement multiple components of networksecurity to address the myriad risks associated with IP networks, including access control lists,perimeter firewalls, network intrusion detection, and link encryption. Many third-party integratedservice routers are also capable of supporting advanced security operating systems that permit notonly the link encryption but also a software-based full firewall for additional network security.

The use of IP-enabled devices has created a new class of threats to public safety because thedevices can provide unprecedented access to sensitive data. They can introduce malware into apublic safety IP-based system, causing numerous problems that affect the ability to dispatchefficiently, including denial-of-service attacks. As a result, IP-enabled public safety devices requireuser access controls to ensure only authorized use. Also, in the event that an IP-enabled publicsafety device is lost or stolen, that device needs to have provisions for disabling it, similar to thoseoutlined in 17.3.4.1.18. Further, IP-enabled public safety devices used by law enforcementagencies must also adhere to federal standards for access to sensitive law enforcementdatabases.


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A.21.1.7


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Computer systems have become not only the primary resource for storing information but also theprimary workhorse for users to perform their jobs; therefore they have also become a primaryobjective for intruders for either data gathering or destruction. This makes a computer system theend point for security, and it requires layers to be built around it to minimize the risks associatedwith intruders accessing the information contained within the computer or with the trusted capabilityplaced at their disposal.

Host-Based Security. Host-based security consists of a suite of software or software functionalityinside a single software that protects the host computer from malicious behavior. Antivirus softwareis a recommended minimum application to protect workstations and servers from malicious code,and it is one that most individuals accept even for their home computers. However, it does notprovide a complete solution for all the malicious behavior that can result from zero-day viruses,which are not found by antivirus software, intentional attacks through bugs, or even accidental useractions. A comprehensive host solution is necessary for ensuring proper protection from knownattack vectors and unallowable behaviors to anomaly detection for incident handling and chain ofevents.

Firewalls. Firewalls provide protection to the information system by enforcing policies, preventingabnormal network behavior, and integrating high-performance security features, includingapplication-aware firewall, secure socket layer (SSL) and internet protocol security (IPSec), VPN,intrusion prevention system (IPS), antivirus, anti-spam, anti-phishing, and Web-filtering services.These technologies deliver strong network and application-layer security, user-based accesscontrol, worm mitigation, malware protection, and improved employee productivity. Adaptivesecurity appliances integrate industry-leading firewalls, unified communications security, VPNtechnology, intrusion prevention, and content security in a unified platform to carry out the followingfunctions:

(1) Stop attacks before they penetrate the network perimeter

(2) Protect resources and data, as well as voice, video, and multimedia traffic

(3) Control network and application activity

(4) Reduce deployment and operational costs

(5) Have an adaptable architecture for rapid and customized security services deployment

(6) Provide advanced intrusion prevention services that defend against a broad range of threats

(7) Provide highly secure remote access and unified communications to enhance mobility,collaboration, and productivity

Network Intrusion Detection Systems (NIDS). In today’s communications environment, whereeverything is highly dynamic with new technologies and increased evolving and sophisticatedthreats, networks need to implement security measures that are just as dynamic and adaptive. Byplacing network intrusion detection system (NIDS) in line with the network configurations, thesystem can act as a preventative measure — placing it on the spanning (or sniffer) port of a switchallows it to act as a detection system on all traffic on the switch, even the network traffic that is notbeing routed outside the local area network. An enterprise NIDS solution can analyze networktraffic and prevent threats from damaging a network, including the following:

(1) Worms

(2) Trojans

(3) Backdoor attacks

(4) Spyware

(5) Port scans

(6) VoIP attacks

(7) Internet protocol version 6 (IPv6) attacks

(8) Denial-of-service (DoS) attacks

(9) Buffer overflows

(10) Statistical anomalies

(11) Protocol anomalies

(12) Application anomalies

(13) Malformed traffic

(14) Invalid headers


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(15) Blended threats

(16) Rate-based attacks

(17) Zero-day threats

(18) TCP segmentation and IP fragmentation

Cloud-Based Services. Agencies large and small are turning to cloud-based repositories forsoftware applications and file storage. The AHJ should ensure that any use of cloud-basedservices includes an encrypted virtual private network (VPN) connection to the cloud to preventsensitive data from being read, copied, or changed. Further, the AHJ should ensure that the cloudservices provider has adequate backup and restoration capabilities if real-time public safety datawill be put into the cloud. Agencies should be aware that in recent years several significant outagesof cloud-based services have left users of such services unable to operate properly for hours todays.

Emergency services agencies that include law enforcement should understand that theDepartment of Justice has specific requirements for information security with respect to criminalrecords, requiring that the cloud computing service provider be certified by IARC-JAXA InformationSystem (IJIS).

Additional sources of information on cloud computing:

Cloud Computing Security Reference Architecture, NIST http://collaborate.nist.gov/twiki-cloud-computing/pub/CloudComputing/CloudSecurity/NIST_Security_Reference_Architecture_2013.05.15_v1.0.pdf

Cloud Computing Reference Architecture, NIST www.nist.gov/customcf/get_pdf.cfm?pub_id=909505

Guidelines on Security and Privacy in Public Cloud Computing, NIST SP 800-144.http://csrc.nist.gov/publications/nistpubs/800-144/SP800-144.pdf

Mitigating Risks in the Application of Cloud Computing in Law Enforcement, APCO International.http://psc.apcointl.org/2013/01/07/mitigating-risks-in-the-application-of-cloud-computing-in-law-enforcement-2

A.21.1.8

A common approach to gaining unauthorized access to systems is to leverage a knownvulnerability within a software system, which is why it becomes important to ensure that the systemis properly maintained throughout its life cycle with up-to-date software versions and patches thatclose vulnerabilities and bugs. To help prevent existing vulnerabilities from being exploited, it isimportant to regularly patch an IT infrastructure. Because patch application can sometimesnegatively affect the performance of critical communications land mobile radio systems, securitypatches should be tested in a controlled environment prior to production rollout. Common softwareattacks can be divided into several flavors:

(1) Buffer overflows — an input is returned that is much larger than the variable that holds it andliterally overwrites a portion of system memory.

(2) SQL injection — an input is returned that will be used in an embedded structured querylanguage (SQL) statement. The input includes additional SQL such as “OR 1=1” that returnmore than the intended data.

(3) Authentication errors — applications accept incorrect user authentication or passauthentication credentials in clear text, which can be easily sniffed and reused.

(4) Privilege errors — applications give administrative privileges to regular user logins withoutrequiring additional authentication.

(5) Abort errors — applications encounter processing errors that cause them to abort, but theyleave the user logged in with the enhanced service login privileges in which they were running.

It is therefore important to find an enterprise backup solution that has been tested against theinformation system.


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A.21.1.9

To ensure continuity of services when the system data are corrupted or destroyed, or the centermust relocate because of fire, explosion, or natural disaster, disaster recovery provisions need tobe in place. System configuration, temporary data, and static data (such as voice traffic stored in avoice logging recorder) need to be retained. Data retention is needed for several purposes: forlegal records (voice logging recorders), for training and maintenance purposes, and to allowsystem recovery if the primary databases are corrupted or destroyed. Data retention should beguaranteed even during catastrophic failures such as network errors, hard-drive crashes,component failure, and server room obliteration. Database backups should be stored at aphysically separate location. Because much of the information might contain legal, criminal, ormedical information, the backups must be physically locked and secured to prevent copying,reading, or tampering. For first responder mission-critical communications systems, the importanceof quickly recovering systems to bring the users and the system functionality back to fulloperational status is a matter of life and death. It is therefore important to find an enterprise backupsolution that has been tested against the information system.

Backup and disaster recovery can be an expensive and time-consuming process. It is not just amatter of making regular backups and taking them offsite. Having the equipment and space torestore the off-site backups is often overlooked.

Disaster recovery procedures include fire service building preplans, incident response run cards,EMS preplans for certain high-risk individuals in the served community, and local law enforcementrecords.

A.21.1.10

Many computer security references and standards suggest implementing logging and auditingfunctions on computer networks. Without logs, investigating security breaches and incidents is afrustrating experience because there are very few data with which to reconstruct the incident.Additionally, legal action is impossible without the necessary proof. But functions implementinglogging thoughtlessly can cause its own problems. For instance, logs can overrun a computer,making it run slower and eventually stopping all processes. This can occur when the logs areallowed to get too large. The larger the underlying log file, the longer it takes to append data to thefile; eventually, the delay can become noticeable. This can happen when the logs have taken allthe available local hard drive space.

There are four approaches to prevent these self-inflicted DoS attacks. First, separate diskpartitions can be established for the system and application logs. This will not prevent the logs fromgrowing but will prevent them from interfering with the operating system. Although the solutionseems obvious, interestingly enough, logs default to writing to the operating system partition.

Second, logs can be set up to overwrite on a regular basis, effectively reducing the amount of logdata available. This approach sounds reasonable, except that it does not take into considerationthe effect of a security attack and/or network failure. Generally, when hardware is failing andapplications are not running properly, more logging is generated. So, right when logs are the mostvaluable, they will contain the least span of time because of the additional logging traffic beinggenerated.

Third, logs can be manually removed from machines on a regular basis. This works well ifimplemented meticulously, but the weak link is the human interaction required. What happenswhen resources change, other tasks become a higher priority, or someone takes a vacation? Logremoval needs to be automated.

Fourth, and finally, implementing automated log removal is the best — and the most expensive —approach. Basically, a system logging server that receives all the logs is added to the network.Then, each device (server, workstation, router, and switch) is set up to push logs to the new syslogserver. In addition to centralizing the log data, this approach allows for reporting across log sourcesand correlating log data. It also prevents the logs from potentially compromised machines frombeing easily “doctored” by the attacker.


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A.21.1.11

A key element of ensuring that the system maintains a proper security posture is the periodicauditing of the vulnerabilities inherent in the system to ensure that new vulnerabilities are beingaddressed and that previously closed vulnerabilities have not resurfaced as a result of changesmade to systems during normal business operations. Auditing can be done by individuallyscanning every asset on the system with a vulnerability management tool, or it can be doneautomatically by a centralized appliance that is capable of scheduled scans. Both are availablefrom industry leaders in the field. All vulnerability management tools should be used consistently toensure baseline security compliance.

Vulnerability management processes are used to ensure the survival in various scenarios asappropriate to the jurisdiction, including major storms, floods, earthquakes, wildfires, securitybreaches, and civil disturbances.

A.21.1.12

Environmental and physical security is a keystone to any security plan, and it is critical thatagencies have tools integrated into every system. The physical security system requirescapabilities for alarm monitoring and reporting of critical network functions, and it is designed tohandle a multitude of voltage and control alarms. The system should be used to monitor alarms orperform auxiliary voltage control functionality. The information collected should be forwarded forcentralized monitoring and alarm notification with the capability of forwarding alerts to notify theappropriate personnel of the issue. The centralized system should be capable of monitoring basicalarms for dispatchers and supervisors to keep them aware of important information, which wouldincluding the following:

(1) Power failure

(2) Excessive base station transmitter voltage standing wave ratio (VSWR)

(3) Shelter door alarms

(4) Cabinet door alarms

(5) Line power failure

(6) UPS failure

(7) Generator failure

(8) Smoke detector

(9) Humidity detector

(10) HVAC failure

(11) Low generator fuel

(12) Low battery

A.21.2

The 9-1-1 centers and the communications systems that support them are critical infrastructure(CI). Therefore, it is recommended that emergency services agencies conduct annual securityaudits, following the guidelines of one of the references listed in Annex C. Such audits are,however, reactive in nature.

It is also recommended that emergency services agencies contract with a reputable outside expertservice to conduct penetration testing. Such testing is best done annually or every 18 months. Thepurpose of such testing is to determine whether security procedures and controls are workingagainst common types of cyberattacks. Without this information it is impossible to know if thepreventive measures are working. A confidential report should be made and kept for seniormanagement of the emergency services agency to assist in long-term improvements.


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A.22.1.4

The education of the public and distribution of PASAAs need to be considered when planning ormaking a system improvement. The PAS should take into consideration the special needs ofindividuals in the community.

A.22.3

Alert systems are used to warn the public of dangers and to provide information andrecommended actions to the public regarding events that can be expected to result in loss of life,endanger public health, or destroy property. These events could include, but are not limited to,tornadoes, hurricanes, floods, fire, and chemical releases.

A.22.4.1(3)

Radio broadcast systems include systems identified as using public radio, private radio, television,cable, cellular, and pager technologies.

A.22.5

Reporting is an issue that varies greatly depending on the PAS solution used. A simple broadcastsystem could offer little to report, and a telecommunications-based system could offer theopportunity to identify specific locations or telephone lines to which a recorded message or analert data message (ADM) was sent, as well as information that a PASAA, a telephone answeringdevice, or a person has received the voice message or ADM.


Some of this material is outdated and needs a complete review,




Affiliation: NFPA 1221/1225 TC

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Public Input No. 229-NFPA 1225-2019 [ New Section after A.3.3.41 ]

Annex to new definition of Directory

Directories may cover mul ple jurisdic ons, so should indicate the name of the jurisdic on or community served.


New material to reflect changes in technology








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Public Input No. 211-NFPA 1225-2019 [ New Section after A.3.3.123 ]

Addendum to definition of a voice circuit

Examples of voice circuits are:

(1) Centralized Automatic Message Accounting (CAMA) trunks

(2) Voice over Internet Protocol (VoIP)

(3) Digital Subscriber Line (DSL )

(4) hot line

(5) land line

(6) line

(7) party line

(8) phone line

(9) private line

(10) subscriber line

(11) telephone line

(12) toll line

(13) trunk line

(14) WATS line


Need examples of voice circuits








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A.15.4.1

Statistical analysis for performance measurement should be completed over a period of 1 month as shownin Figure A.15.4.1(a) and Figure A.15.4.1(b).


Figure A.15.4.1(b) Event Timeline Where Primary PSAP Is Other Than Communications Center.


The notes for the figures refers to terms not used in the figures. Specifically: There are no references in the figure to alarm sounds. The terms CC, TC and IAW are not used in the figures. It seems all of these references can be removed. In addition, the third cell indicates: "Call is routed through public safety network". Public Safety Network is not widely used the standard and it is not defined. Maybe it should be defined or replaced with a defined term.





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A.15.4.1

Statistical analysis for performance measurement should be completed over a period of 1 month as shownin Figure A.15.4.1(a) and Figure A.15.4.1(b) .


Figure A.15.4.1(b) Event Timeline Where Primary PSAP Is Other Than Communications Center.

This figure depicts a transfer performance of 90% of calls <= 30 seconds, but there is no mention

of this requirement within the standard language. In the 2016 version there was a specific

standard related to transfers (2016 version: 7.4.4* Where alarms are transferred from the primary

public safety answering point (PSAP) to a secondary answering point, the transfer procedureshall

not exceed 30 seconds for 95 percent of all alarms processed). The previous standard appears to

have been removed from the 2019 version without any indication that transfers still have a

requirement or that the requirement has changed from 95% to 90%.




Capture.1539028279448.PNG


Either the standard should be added back with the corrected language change from 95% to 90% OR the diagram


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should not indicate a performance benchmark of 90% of calls within 30 seconds.




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Public Input No. 231-NFPA 1225-2019 [ New Section after A.16.1 ]

A.16.1.4

Examples would be telema cs or other interface to a data provider that provides personal informa on of a

subscriber.


New material to reflect changing technologies




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Public Input No. 230-NFPA 1225-2019 [ Section No. A.16.1 ]

A.16.1

Cellular or Internet personal communications services (PCS) systems include such devices as personaldigital devices, advanced voice and data devices, and other cellular-based wireless systems. Textmessaging, Internet access, cable modems, and other devices using wireless fidelity (WiFi) all use voiceover Internet protocol (VoIP).


No longer needed




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Public Input No. 121-NFPA 1225-2019 [ Section No. A.16.2.1.2 ]

A.16.2.1.2

The separate business number listed in the telephone directory and used for nonemergency purposesshould referenced in (3) should terminate at a location where personnel are on duty at least 40 hours perweek, Monday through Friday.


Removing requirement information to include in chapter 163. Moving link from duplicated requirement to proper location.




Public Input No. 122-NFPA 1225-2019 [Section No. 16.2.1 [Excluding any Sub-Sections]]





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A.16.2.1.2

The A separate business telephone number listed in the telephone directory and used for nonemergencypurposes should terminate at a location where personnel are on duty at least 40 hours per week, Mondaythrough Friday.That loca on may be the same communica ons center opera on.


Clarification of location of business line.




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A.16.2.3.6 4

A telephone line terminating voice circuit terminating at an unstaffed ERF and provided with a recordedmessage should not be used to meet the intent of the business line telephone number (nonemergency)listed in the directory and assigned for business (nonemergency) use as specified in 16.2.3.4 2 .


Reflects changing terminology




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A.16.3.9

There are 38 million people with hearing-related disabilities that depend on non-voice communications,such as SMS messaging, to access emergency services and others who utilize this method ofcommunication.


Not pertinent to the standard.




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Public Input No. 235-NFPA 1225-2019 [ New Section after A.16.3(1) ]

A.16.3.2.2

It is be er for the secondary PSAP to speak to the original caller rather than take the chance of relaying incorrect or

incomplete informa on. The only me a relay of informa on is appropriate would be if the caller disconnects or is

incapable of speaking to the telecommunicator at the secondary PSAP.


New clarifying material




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Public Input No. 234-NFPA 1225-2019 [ Section No. A.16.3(1) ]

A.16.3(1 2 )

In no case is it ever recommended that the telephone system be designed at less than P.01 GOS. Anindustry standard traffic study should be conducted that meets the public safety requirements of the AHJ.


Reflects new section.




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A.17.1.1

Communications Emergency services communications centers that dispatch for volunteers or paid-callpersonnel have the responsibility of summoning such personnel at any hour of the day or night. Personnelcan be summoned by the use of the telephone or radio, supplementing sirens or horns that provide anoutside alarm. Events can be telephoned to the central telephone office where the telephone emergecyservices communications center where the telecommunicator can start a siren or operate an air horn toindicate that there is an event. In areas where a communications center is not attended 24 hours a day,telephone companies can provide a telephone line that connects to special telephones that are located inplaces of business or residences selected by the jurisdiction. The jurisdiction then arranges to activate thetelephone lines. In emergency response agencies that have an emergency response facility desk attendant,the telephone central telecommunicator can call the ERF, and the attendant can sound the outside alarm tocall volunteers. If there is a code-sounding siren or air horn, coded signals can be sent. Usually atransmitting apparatus is used to send out the code.

If radio equipment is used, a receiver with selective calling equipment can be placed in the home of eachvolunteer or call person. Selective signaling is accomplished on a group-call principle, allowing thevolunteer or call forces to be divided into several groups that can be summoned as a whole or as individualgroups to handle a particular incident. Pagers are commonly used for this purpose, since they can becarried anywhere. Pagers can include either a tone alarm, a voice receiver, or a digital display.


Editing the annex language to be more consistent with the terminology used elsewhere in the standard. "Central telephone office" is not used elsewhere and can be misinterpreted to mean "telephone central office" which is not the intent. "Telephone central telecommunicator" in other parts of standard is identified simply as "telecommunicator."





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A.17.6.8

Many different types of radio systems are in use by public safety agencies in the United States

. A number of them have different operational characteristics. A prescribed signal strength measurementmight not produce usable voice communications for all systems(e.g., VHF, UHF, 700/800 MHz, analog, P‐25, 4 slot TDMA, 2 slot TDMA, etc.).

Requiring the AHJ to provide operational parameters required for usable voice communications for thesystems in use eliminates possible confusion regarding the specified value, as determined by the AHJ.They all have different performance characteris cs. A single prescribed signal strength measurement (such as ‐95

dBm) does not account for the differences in propaga on, modula on, equipment capability, and user opera ons.

A be er indicator of proper system performance and coverage is to use the DAQ audio quality measurement system

whether the signals are either analog or digital , as currently prescribed . However, DAQ is not an easily measured

quan ty and the results of any DAQ tes ng are subjec ve.

Un l DAQ tes ng becomes automated and objec vely implemented, it is recommended that AJHs use RF signal level

tes ng performed by the installa on contractor, supplemented with DAQ tes ng, usually of cri cal coverage areas.

It is recommended that the jurisdic on use a signal value based upon the specified performance of the their own

portable radio equipment, the manner in which the portable radio equipment is worn/used, and the confidence

margin that the AHJ requires for their jurisdic on. This value can be obtained based upon trial and error tes ng by

the AHJ in their jurisdic on, perhaps in consulta on with their portable radio supplier or with a radio consultant.

Current portable radios can provide a 1% BER (DAQ >3.0) with a signal input of less than ‐115 dBm, in an unfading

environment. Even with an allowance for indoor fading and body blockage, the signal objec ve for newer P25

technologies can be much less than the previous ‐95 dBm standard.

Note that the signal level objec ves for buildings that have a radio enhancement system are different from the signal

levels objec ves for a building that relies upon macro coverage.

If the building will be relying on the macro signal for coverage, the uplink is usually the determinant of performance.

Since there is usually asymmetry in the effec ve radiated power, it is not uncommon for the uplink performance to

be worse, typically by 10‐15 dB. Therefore, in order to ensure that the uplink signals are adequate, the downlink

signals should have a margin of 10‐15 dB above the minimum downlink requirement for buildings with radio

enhancement systems. The precise value will primarily depend upon the rela ve ERPs of the donor sites and

portables, the gain of the donor uplink antenna, and the noise floor of the uplink donor.

Even in a building that has a radio enhancement system, the uplink and downlink performance are based upon the

performance of both the donor link and the in‐building coverage system, not just the downlink signal level provided

by the radio enhancement system. The overall link budget is based upon the combina on of the performance of the

donor and in‐building link. If the link budget for both is nearly the same, the combina on link has a performance

that is actually 3 dB worse. Therefore, the downlink signal measured in the building is not the only determinant of

performance. The effects of both donor links and in‐building links needs to be considered, especially when the

system is fully loaded, and the BDA power is shared between all ac ve carriers. The use of AGC on both the

downlink and the uplink change the performance of the links as compared to macro signals.


While DAQ is ultimate performance measure, it is not easily measured by installation contractors, and is best used as a checking metric rather than a primary metric. It has been hinted that -95 dBm may find its way back into the code. This is an old objective derived when analog systems were the norm. Since there can be significant variance in the performance requirements of each jurisdiction, it should be left up to the jurisdiction to decide what values are appropriate for their locale. Also, there should consideration made for determining adequate coverage of a radio enhancement system as opposed to adequate coverage by the macro system. They are quite different, and AHJs should not be misled to think that they are the same.


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Public Input No. 101-NFPA 1225-2019 [ Sections A.19.3.9, A.20.5.1 ]

Sections A.19.3.9, A.20.5.1


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A.19.3.9


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Test Procedures. The test plan should ensure testing throughout the building. Test procedures should beas directed by the AHJ.Note: Testing procedures typically are done on a grid system. A grid is overlaid ontoa floor area to provide 20 grid cells. Grid cells are provided with definite minimum and maximumdimensions. For most buildings, using a minimum grid dimension of 20 ft (6

.1 m) and a maximum grid dimension of 80 ft (24.4 m) will suffice to encompass the entire floor area.

Where a floor exceeds 128,000 ft 2 (11,900 m 2 ), which is the floor area that can be covered by themaximum grid dimension of 80 ft (24.4 m), it is recommended that the floor be subdivided into sectors each

having an area less than or equal to 128,000 ft 2 (11,900 m 2 ), and each sector be tested individually with20 grid cells in each sector. Signal strength measurements should be taken at the center of each grid andshould be performed using standardized parameters as specified in the notes of “MeasurementParameters” of this section. The delivered audio quality (DAQ) scale is a universal standard often cited insystem designs and specifications, using the following measures:

DAQ 1: Unusable, speech present but unreadable.

DAQ 2: Understandable with considerable effort. Frequent repetition due to noise/distortion.DAQ 3:Prior to the activation of any Bi-Directional Amplifier equipment, the isolation of the antenna system shallbe tested and verified that the minimum required antenna isolation is achieved. Any deficiencies shall becorrected prior to any further testing.

Downlink RF signal level testing should generally be accomplished by a walk test of all locations in thebuilding requiring radio coverage. The walk testing is accomplished by a qualified tester, with calibratedtest equipment and calibrated test antennas, to document the mean signal level throughout the building. For downlink RF signal level testing, an AGC mode shall be used that evenly distributes the channel powerto all required channels, so as to not bias the measurement.

Uplink RF signal level testing should be accomplished to verify that the uplink RF signal level is adequatebut not excessive, and that the uplink does not increase the noise floor at donor repeater site. For uplinktesting, the uplink AGC mode shall evenly distribute the channel power to all required channels, so as tonot bias the measurement. The minimum signal level received at the donor site shall be measured from theworst case coverage location in the building. For uplink noise verification, the measuremet shall be madefrom the best case coverage location in the building.

When it is determined through walk testing that the RF signal level coverage exceeds the minimumrequirements established by the AHJ, documentation of that coverage shall be provided to the AHJ forreview and approval. The AHJ may then choose to verify the coverage throughout the building, or to spotcheck the coverage at its discretion, typically by accomplishing a series of voice checks to verify DeliveredAudio Quality (DAQ) that meets the requirements of the AHJ. The DAQ objective is DAQ 3, where" Speech understandable with slight effort. Occasional repetition required due to noise/distortion

.

DAQ 3.5: Speech understandable with repetition only rarely required. Some noise/distortion.

DAQ 4: Speech easily understood. Occasional noise/distortion.

DAQ 4.5: Speech easily understood. Infrequent noise/distortion.

DAQ 5: Speech easily understood."

The DAQ scale comes from TIA TSB-88, Wireless Communications Systems Performance in Noise andInterference-Limited Situations. A DAQ test is preferred to absolute RF signal levels for two reasons: theDAQ test is easier to administer than because RF signal levels alone do not determine performance , andDAQ is useful regardless of the type of modulation or system technology used (analog or digital). Itmeasures what really matters — how the signal sounds to the user — regardless of manufacturerspecifications.

The minimum allowable DAQ for each grid cell typically is three. Not more than two nonadjacent grid cellsshould be allowed to fail the test. In the event that three of the areas fail the test, or if two adjacent areasfail the test, in order to be more statistically accurate the testing grid resolution should be doubled. Thiswould require decreasing the size of the grids to one-half the dimension used in the failed test to aminimum of 10 ft (3 m) and a maximum of 40 ft (12.2 m). Further, to cover the same floor area, the numberof grids is quadrupled to 80 grids. No more than eight nonadjacent and/or five adjacent grid cells shouldthen be allowed to fail the test.

In the event that nine or more nonadjacent and/or six or more adjacent grid cells fail the test, considerationshould be given to redesigning and reinstalling the public safety radio enhancement system to meet theminimum system design requirements. Failures should not be allowed in critical areas. Measurementsshould be made with the antenna held vertically at 3 ft to 4 ft (0.9 m to 1.2 m) above the floor. The DAQreadings should be recorded on small-scale drawings that are used for testing with the AHJ. In addition,


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the gain values of all RF-emitting devices and system components should be measured and the testmeasurement results should be kept on file with the building owner so that the measurements can beverified each year during annual tests.

Two Portable Testing. To test the in-building radio enhancement system with two portable radios noiseand interference levels, and Time Domain Interference also impact performance, and in the end, adequatevoice quality is what is required for adquate coverage.

Near-FarTesting. To test a Class B in-building radio enhancement system for adequate near-farperformance , the following procedure can be used: One portable radio should be positioned no greaterthan 10 ft (3 m) from an indoor distribution antenna or leaky coaxial cable. located at a location has thestrongest downlink signal in the radio enhancement system, usually near an antenna closest to the Bi-Directional Amplifier. The second portable radio should be positioned at a distance that represents thefarthest distance possible in that location of the building from an indoor distribution antenna or radiatingcable. located in the area of the radio enhancement system that has the weakest coverage in the radioenhancement system, frequently in a stairwell. Both portables should be simultaneously keyed up ondifferent frequencies or talkgroups within the same radio band, and listeners on those different frequenciesor talkgroups should verify that the voice messages received were intelligible to DAQ 3.0. message fromthe radio in the weakest coverage location can still be received with the specified DAQ. It is useful whenperforming these tests to use unfamiliar words, such as from the Harvard Sentences list, when determiningreception intelligibility. This test is not required with Class A signal booster systems.

Measurement Parameters. DAQ levels should be measured to ensure the system meets the criteria of17.6.7 according to parameters as directed by the AHJ.

Note: Downlink measurements Measurements should be made with the following standardizedparameters:

(1) Receive antennas of equal gain to the agency’s standard portable radio antenna, oriented vertically,with a centerline between 3 ft to 4 ft (0.9 m to 1.2 m) above floor

(2) Levels recorded while walking an “X” pattern, with the center of the pattern located approximately inthe center of each grid area

(3) The linear distance of each side of the “X” equal to at least 10 percent of the length of the grid’s sideand a minimum length of 10 ft (3 m)

Measurements sampled in averaging mode to include a minimum of one sample

(4) Standard half-wave test antennas mounted at a height that will not incur body blockage from testpersonnel

(5) RF signal test equipment (spectrum analyzer, RF scanner) calibrated to NIST standards with currentcalibration certificate.

(6) Levels recorded walking in a straight line that permits the interpolation of the location of test datapoints or the use of indoor navigation system to identify measurement locations.

(7) Measurements at a minimum of one median signal level sample reported per each 5 ft (1.5 m) traveledrecorded with not less than five samples per measurement recorded per side of the “X.” 150subsamples per measurement location to determine the mean signal level. Where the pathways forthe walk test exceed 5 feet in width, multiple parallel passes, offset by 10 feet, shall be made until allbuilding locations are tested.

(8) Portable radios of the same manufacturer and model used by the juristiction public safety radiopersonnel for DAQ tests. The AJH may wish to insert an attenuator between the portable antennaand portable radio to ensure that there is some minimum level of RF signal margin during the DAQtesting.

Acceptance Test. An acceptance test of the two-way in-building wireless communication systems shouldbe scheduled with the AHJ. Acceptance test procedures and requirements should be as directed by theAHJ.

Note: Typically, acceptance tests are required by the AHJ prior to building occupancy. As-built drawingsshould be provided including all system design parameters, other information required from the DAQ leveland commissioning tests, including a full report with grid locations, DAQ measurements, and RF-emittingdevice all measured signal level data, and Bi-Directional Amplifier or system component gain values. Theacceptance test typically entails a random test by the AHJ of radio communication in various portions of thebuilding, especially including the critical areas. The AHJ can review any test documentation and ensure thatthe findings of the commissioning test with respect to DAQ levels and gain values are supported by theacceptance test.

If RF Bi -emitting devices Directional Amplifiers are used in the two-way radio communicationsenhancement systems, a spectrum analyzer shall be used to ensure spurious oscillations are not generated


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nor are unauthorized carriers repeatedly in violation of radio licensing authority regulations. This testingshould be conducted at time of installation and during subsequent inspections. Downlink and uplinkspectrum should be recorded with a maximum-hold screen capture at the active system air interfaces withthe system under normal load and at least one uplink carrier active on the indoor portion of the system.Measurements should be analyzed for correct gains on both uplink and downlink paths, noise floorelevation from active components, intermodulation, and other parameters determined necessary by theAHJ. Gain values of all RF-emitting devices and system components should be measured and the resultskept on file with the building owner and the AHJ. In the event that the measurement results are lost, thebuilding owner will need to repeat the acceptance test to re-establish the gain values.

Where the two-way radio communications enhancement system is shared with other non-public safetyservices, the testing of the public safety system should be made under simulated heavy traffic loadconditions of the non-public safety services to ensure that the DAQ values, noise floors, intermodulation,and other parameters, as described by the AHJ for both in-bound and out-bound, are met for the publicsafety portion of the system.

Annual Tests. The AHJ should be notified in advance and should direct annual test procedures andrequirements. Note: Typically, annual tests require several items to be checked. RF-emitting devices andsystem components should be tested to ensure that the gain is the same as it was at initial installation andacceptance. Backup batteries and power supplies should be tested under load for 1 hour to verify that theywill operate properly during a power outage.

License or Certification of Personnel. All system designs, installation, testing, and maintenance shouldbe conducted, documented, and signed by an acceptable manufacturer or person in possession of acurrent radio licensing authority license, industry certification, professional electrical engineering license, oras required by the AHJ.

Note: Many manufacturers of two-way in-building wireless communications systems provide certificationprograms for installing contractors. Local adopting jurisdictions could require certification of two-way in-building wireless communications system training for the installing contractors issued by a nationallyrecognized organization or school, or a certificate issued by the manufacturer of the equipment beinginstalled.

A.20.5.1

The CAD system should record a history (audit trail) of the following actions taken with the items:

(1) Creation

(2) Change, including modification, deletion, or supplementation

(3) Disposition, including close-out, archiving, and transfer

(4) Inquiry to external data sources

Each entry in the history should include the following:

(1) Coordinated universal time (UTC) of action

(2) Identification of the individual performing the action

(3) Identification of the device on which the action was performed

(4) Effects of action on the characteristics of the items


The result of a grid test is a value that is expected to represent the approximate coverage over any location within the grid. As currently recommended, the sides of a grid can be as large as 80x80 and can encompass spaces where the coverage is significantly different over grid locations due the general construction of the building, the build-out of the building including walls and doors, the furniture and equipment installed within the building, and the inward macro leakage based upon location within the grid. This is especially true for areas around elevator shafts, interior fire rated stairwells, mechanical rooms in buildings, and buildings where the interior walls have high attenuation based upon the building construction. Even with a 20x20 grid, there can be significant variation in the median signal levels in the grid.

The only accurate method of RF coverage testing is a walk test where the mean signal level of the building is recorded in small increments, nominally every 5-6 feet, and poor coverage in certain areas of the building is not masked by averaging the coverage predictions over a larger grid. The current availability of automated test equipment facilitates the performance of walk testing and evaluation of test results. Ideally, the test equipment will record the mean signal level automatically, and simultaneously automatically record the location using an inertial navigation system.


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When performing these coverage tests, it is important that the worst case test conditions are accounted for, either by testing the worst case environment or increasing the required signal level to accommodate the worst case, such as a full versus empty parking garage.

Walk testing is the current approach used for cellular testing, and with the implementation of FirstNet, a common approach for testing may eventually be required. Also, propagation models used for coverage design can utilize walk test results to tune model propagation algorithms, not possible with grid testing.

Since the radio signals being measured are constantly changing due to multipath fading, the coverage testing should be accomplished with a test receiver that provides a minimum of 150 sub-samples per measurement result to determine the “mean” signal level, as recommended by TSB-88-3. The mean signal level is what is important for determining RF coverage, which is the basis for TSB-88-1 “faded sensitivity", and the most important specifications from portable radio manufacturers, since in normal operation, the portable radio will always be seeing a fading signal.

Standard half-wave antennas should be used for RF coverage testing, since the median signal level are normally referenced to the signal received using a half-wave dipole. The actual receive level into the portable radio can be determined by adjusting the value measured with a half-wave dipole by the antenna loss factors shown in TSB-88-1 Table D5 for radios used at head level or radios worn at the hip, for all the different public safety bands. These factors accommodate both the antenna gain and the body loss, whether the radio is used at head level or worn at the hip. The half-wave test antenna should be installed at a height where there will not be any body loss, since it is accounted for in the portable antenna factors. An antenna used for testing at lower levels will incur uneven body loss depending upon the orientation of the test antenna, test personnel, and the donor or DAS antenna.

The current near-far test is poorly designed and will not identify all near-far problems. Near-far is a dynamic range problem, that is best observed when a strong signal drives the BDA into maximum AGC, thereby minimizing the gain available from the weakest location in the coverage area.




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Public Input No. 191-NFPA 1225-2019 [ Chapter F ]

Annex F Cyber Security (formerly Annex B of 1221)

This annex is not a part of the requirements of this NFPA document but is included for informationalpurposes only.

THESE RESOURCES NEED TO BE REVIEWED AND UPDATED.

F.1 Where to Start.

It is often difficult for agencies to decide where to start in cyber security. Here are three resources:

(1) Council on Cyber Security’s Critical Security Controls. www.counciloncyber-security.org/critical-controls. All agencies should strive to implement the top four controls as soon as possible becausethey represent the most common security threats and to implement the others as determinednecessary by the AHJ.

(2) Stop.Think.Connect. (www.dhs.gov/stopthinkconnect) is a Department of Homeland Security campaignaimed at educating end users about phishing attacks.

(3) SANS Securing the Human (www.securingthehuman.org/resources) is another program aimed ateducating end users. Many successful attacks are the result of phishing or similar techniques that lureusers onto sites that infect their computers with malware and allow adversaries to steal legitimate usercredentials.

F.2 Additional Information.

F.2.1

The International Association of Chiefs of Police (IACP) (www.theiacp.org/Technology/tabid/72/Default.aspx) has begun a major effort to disseminate information on cyber security and to combatcyberthreats. Emergency services agencies with a law enforcement presence should be able to gainaccess to these resources:

(1) The Law Enforcement Tech Minute video: “The Current Climate in Cyber Security”

(2) The Law Enforcement Cyber Security Center

F.2.2

The National Institute of Science and Technology (NIST) has been researching and issuing securitystandards for some time. Here is a partial list, with the most current first:

(1) Preliminary Cyber Security Framework (www.nist.gov/itl/upload/preliminary-cyber-security-framework.pdf): useful mapping to previous security frameworks such as ISO 270001

(2) Security and Privacy Controls for Federal Information Systems and Organizations(http://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-53r4.pdf)

(3) Minimum Security Requirements for Federal Information and Information Systems (http://csrc.nist.gov/publications/fips/fips200/FIPS-200-final-march.pdf)

(4) Federal Information Security Management Act of 2002 (FISMA), Title III—Information Security(http://csrc.nist.gov/drivers/documents/FISMA-final.pdf)

F.2.3

The National Emergency Number Association (NENA) has issued guidelines on cyber security that areuseful for 9-1-1 centers:

(1) Next Generation 9-1-1 Security (NG-SEC) Audit Checklist (https://c.ymcdn.com/sites/www.nena.org/resource/resmgr/Standards/NENA_75-502.1_NG-SEC_Audit_C.pdf)

(2) NENA Security for Next Generation 9-1-1 Standard (NG-SEC) (http://c.ymcdn.com/sites/www.nena.org/resource/collection/2851C951-69FF-40F0-A6B8-36A714CB085D/NENA_75-001-v1_NG-Security.pdf)


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F.2.4

The Association of Public Safety Communications Officials (APCO) has issued several guidelines, amongthem the following:

(1) Telephony Denial of Services (TDOS) to Public Safety Communications Phone Service RecommendedBest Practices Checklist (http://psc.apcointl.org/2013/03/28/telephony-denial-of-services-tdos-to-public-safety-communications-phone-service)

(2) APCO International and the IJIS Institute Outline Information Sharing Priorities (http://psc.apcointl.org/2013/08/20/apco-international-and-the-ijis-institute-outline-information-sharing-priorities)

F.2.5

A cyberhealth pyramid can be found at www.state.nj.us/njinfosecure/home/Posters/2012_Pyramid_Poster.pdf

F.2.6

The FBI’s Next Generation Cyber Initiative offers information here: www.fbi.gov/news/testimony/cyber-security-terrorism-and-beyond-addressing-evolving-threats-to-the-homeland, and a Cyber Shield Allianceoffers information here: www.ise.gov/blog/ise-bloggers/fbis-guardian-portal-expands-cyber-threat-information


Some of the information is outdated and needs review or adding to.




Affiliation: NFPA 1221/1225 TC

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Public Input No. 22-NFPA 1225-2019 [ Section No. G.1.2.5 ]

G.1.2.5 TIA Publications.

Telecommunications Industry Association, 1320 North Courthouse Road, Suite 200, Arlington, VA 22201.

ANSI/TIA 102.AABF-A D , Link Control Word Formats and Messages New Technology Standards Project— Digital Radio Technical Standards, 2004 , 2015 .

ANSI/TIA-102.BAAA, FDMA Common Air Interface, 2003 2017 .

ANSI/TIA-102.BBAC, Two-Slot TDMA MAC Layer, 2010, addendum 1, 2013 .

TIA-603-D E , Land Mobile FM or PM — Communications Equipment — Measurement and PerformanceStandards, 2010 2016 .

TIA-TSB-88.1-D , Wireless Communications Systems Performance in Noise and Interference-LimitedSituations, 2013. - Part 1: Recommened Methods for Technology Independant PerformanceModeling, 2016 . (Supersedes TIA-TSB-88)



Public_Input_No._6-NFPA_1221-2018_Section_No._C.1.2.5_.pdf


Referenced current national consensus standard editions.



Public Input No. 15-NFPA 1225-2019 [Section No.2.3]

Referenced current national consensus standardeditions.


Submitter Full Name: Aaron Adamczyk

Organization: [ Not Specified ]

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