Preface:
Public safety wireless communications has evolved to wireless systems which are highly dependent upon handheld or 'handset' communications. The use of handsets provide user mobility into any location an individual may go, such as in-buildings, basements tunnels and other places older mobile radio usage was not practical or possible.

Operation of wireless equipment requires a radio path between the handset and the rest of the communications system. Radio signals are greatly reduced when passing through earthen barriers and dense construction materials making in-building and underground wireless communications unreliable or impossible without taking additional actions.

Radio signals may be re-distributed within obstructed areas by the use of special coaxial cables, fiber optics and indoor antennas. However these signals usually require amplification to overcome the losses of the distribution system to be effective.

The most common solution involves the use of special amplifier devices called 'signal boosters' by the Federal Communications Commission, who has federal jurisdiction of the use of such devices. Other terms such as 'Bi-Directional Amplifier' or 'BDA' are industry jargon for signal boosters, all meaning the same device.

The Implementation of signal boosters within larger properties, both public and privately owned, is becoming a commonplace solution. The use of signal boosters is critical to the welfare of public safety personnel in the performance of their duties.

There are costs associated with the implementation of signal booster systems which most private building owners naturally resist, so local codes and ordinances have become the vehicle to provide a balance between public necessity and private interests.

This paper examines codes successfully implemented by many local governments and discusses the various components of these codes for the benefit of those authorities interested in developing their own codes.

Necessity of an In-Building Coverage code or ordinance:
Modern fire and police systems use portable radios as their primary communications device. That means ubiquitous coverage is expected wherever handheld radio may be carried; basements, high rise buildings, etc. Places older mobile mounted radios never went.

Reliable wireless communications is an absolute necessity today. Radios are lifelines to first-responders.

The public expects first responders to provide their services no matter where the citizen may be; on public and private property alike.

Implementing in-building coverage codes is like requiring fire sprinkler systems. And like sprinkler systems many years ago, the adoption of in-building codes is rapidly evolving from a unique requirement to a standard practice.

Impact Upon Private Owners:
There is often considerable discussion of the negative impact such codes may have on the owners of existing and new structures. The most extreme apprehension is such a code will drive building owners out of the area or put them out of business. However, there is no evidence of such a result occurring in any of the many jurisdictions that have these codes.

The relative costs of most signal booster implementations by private owners is usually negligible when calculated as a cost of doing business.

Government officials and administrators should view these costs not as lump sums but as long term property improvements.

Cost Example: Los Angeles area

The typical cost of implementing a signal boosters system for a 150,000 square foot are of coverage is about $30,000. This is NOT an absolute rule!

Costs will vary dependent mainly on specific variation of structure composition, floor plans, and radio channels required, but most typically within a range of $0.15 to $0.30 per square foot. $0.30 per square foot , or $45,000, in this example .

According to the Daum Office Market Report for Los Angeles, 3rd Quarter 2005; (http://www.gvadaum.com/research/mktreports/01-marketreview/01-LACOFF.pdf)

The average LA county monthly office space lease rates are: $ 1.92 to 2.30 sq. ft.: $ 2.09 average.
The vacancy rate is 10.0 to 15.4 %: 11.8 % average.

Using the worse case values of $ 1.92, less 15.4% vacancy, we derive a worse case monthly lease income of $1.62 per square foot, or $ 243,000 for a 150,000 square foot (usable office space) building.

The cost of a $45,000 signal booster is only 18.5% of ONE months gross rental income.

Assuming at least a 5 year lifetime of the signal booster system, the cost per month is $750 or .3% of gross monthly income or less cost than most trash pickup fees.

Such low costs shouldn't be a major financial concern to a building owner, and it is to be expected they will object to any new expenses.

On the positive side, the installation of a such as system increases the value of the property, improves the properties attractiveness to potential tenants and may even lead to future insurance savings to the owner.

Retroactivity:
It is notable that the very first code, City of Burbank, is retroactive and will be discussed more later. Most codes include major structure revisions as the same as new construction.

Retroactivity in new codes is highly recommended because;
a. They frequently present greater fire risk than newer structures. Not including these structures will leave first responders in jeopardy for many years.
b. Codes often include exemptions for smaller structures which inherently exempts many older structures. Local Agency Structure funding.

Most codes also apply to public owned structures, especially fire codes, unless specifically exempted. Funding to implement public safety communications within structures owned by the authority may include new COPS and DHS grants as well as traditional tax based sources.

Existing Codes:
Examples of many codes that have been successfully enacted and enforced are available at www.RFSolutions.com/fcc.htm , includng those referrd to the following discussion.

The oldest known ordinance was adopted by the City of Burbank in 1991, over 14 years ago. It was the only such code for many years but now there are many and hundreds more are under development.

Almost all in-building codes are derivatives of the Burbank code, so it is appropriate to examine it's construction to understand the newer versions.

Construction of Codes
The Burbank code is the core essence of what codes need to include;
1. The purpose of the code.
2. What constitutes compliance to the code.
3. What remedies to achieve compliance are acceptable.
4 Applicable Federal Communications Commission rule compliance.
5. Methodology used to verify and maintain compliance.
6. Penalty for non-compliance
7. Exemptions

Additionally, some codes include;
8. Authority citations.
9. Additional equipment specification requirements.
1-. Additonal Personnel qulaification requirements.

Expanding upon these topics:
1. Purpose of the code is self-evident in most of the various codes. Typically it simply says the code is to insure adequate communications to local pubic safety agencies (fire and police) from within applicable structures.

2. What constitutes compliance to the code varies from minimal to onerous and lengthy technical details;

a. Frequency Bands:
The Burbank ordinance is somewhat technically ambiguous about the frequencies of interest but it has served their purposes well.

Note they operate in the UHF frequency band. In-building systems operating in the UHF and VHF frequency bands are generally harder to define due to lesser standardization of the individual channels approved by the Federal Communications Commission.

Most codes state two bands of frequencies, such as "806 to 824 and 851 to 869 MHz", one set being those frequencies to be received inside the structure (or the "downlink) and the other set those frequencies to be transmitted from inside the structure (or the 'uplink') .

In a very recent codes an element of compatibility to future frequency requirements has been added, such as; (example form VA Statewide Uniform Standard Building Code draft) "The frequency that must be supported shall be 850 to 824 MHz and 851 to 869 MHz and adaptable to other appropriate emergency frequencies (700 MHz or greater). "

In this example, citing and enforcing 746 to 869 MHz frequency adaptability for future public safety frequency usage protects the in-building equipment owners investment from obsolescence and such specifications are not exclusionary except to lower, consumer, grade signal booster products. Naturally the frequencies will vary from jurisdiction to jurisdiction.

The City of Irvine CA code states; All system components must be 100 percent compatible with analog and digital modulations after installation without additional adjustments or modifications. The systems must be capable of encompassing the frequencies stated herein and capable of future modifications to a frequency range subsequently established by the City of Irvine. If the system is not capable of modification to future frequencies, then a new system will need to be installed to accommodate the new frequency band.

Some equipment providers may find compliance to frequency "adaptability" burdensome and take exception, however the inability of a manufacturer to comply with the intent of this in a definite, definable manner, is a choice made by that manufacturer and characteristic of minimal, lowest cost product designs. There is no technological constraint on compliance to this hardware requirement and this capability has been provided in many products for several years.

It is important to understand for technical reasons the optimum specified frequency band is the smallest band that is actually needed;, an excessively wide band of frequencies will increase the probability of interference and poor performance..

b. Interference Rejection:
In recent years many public safety systems have experienced interference from commercial users, such as Nextel, operating on nearby channels in the 800 MHz band. In addition to specifying the optimum frequency band, 'rejection' of adjacent frequencies may also be specified.

This is most notable in those codes addressing the use the 866 to 869 MHz band. This is a public safety only band (named "NPSPAC") lying between Nextel and cellular channels. The latest NPSPAC signal booster specifications cite; "The signal booster shall include filters to reject frequencies below 865 and frequencies above 870 MHz by a minimum of 35 dB."

A similar specification is in the City of Irvine CA ordinance. Similar protection criteria may arise in future UHF and VHF band systems.

c. Signal levels, percentage of coverage and reliability percentage.
These specifications are interrelated and impact upon the complexity and cost of a signal booster system. The ideal of 100% coverage and 100% reliability is not practical economically and almost impossible to achieve. The objective is to specify adequate signal levels and areas of coverage while not being excessively demanding. It is appropriate to use minimum signal level values that are similar to what is acceptable for the outside coverage.

Most ordinances set RF signal levels near -95 dBm, which is sufficient to inherently approach 95% reliability, the two factors being related. Signal levels used for other wireless devices such as WLAN, cellular and paging are different because their operation, frequencies and technologies are different and not directly associative to public safety radio systems.

In a draft proposal for a State-wide Arizona ordinance, different signal levels are cited between analog and digital modulations. The intent appears to be an allowance for legacy VHF/UHF analog systems used smaller communities versus APCO P-25 800 MHz systems used in urban areas. We respectfully submit that the signal levels in urban areas should always anticipate the evolution to digital modulation.

Bayside Wisconsin code stipulates an RF level of -101 dBm for 95% of the area with a Delivered Audio Quality (DAQ) of 3. Likewise, in the Village of Schaumburg Illinois code, a " DAQ of 3 " standard is employed.

This is a universal standard often cited in Motorola system designs and to a lesser degree by other radio system providers. In this case, the DAQ is used instead of measured signal strengths, making the standard somewhat subjective.

Delivered Audio Quality Definitions:

DAQ Delivered Audio Quality Value / Subjective Performance Description

DAQ 1 / Unusable, speech present but unreadable.

DAQ 2 / Understandable with considerable effort. Frequent repetition due to noise & distortion.

DAQ 3 / 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 based standards are subjective and subject to interpretation.

Altrenately, many system engineers recommend -95 or -100 dBm signal levels, 95% of the area and 95% reliability for as an proven, achievable and measurable balance of function versus cost.
(Note. -95 dBm is a stronger signal than -100 dBm)

The code should also state the signal booster must be 100% compatible with analog or digital modulations after installation without additional adjustment or modification. This accommodates future equipment upgrades.

d) What remedies to achieve compliance are acceptable.
Typically a statement similar to this is used; Buildings and structures which cannot support the required level of radio coverage shall be equipped with any of the following in order to achieve the required adequate radio coverage: a radiating cable system or an internal distributed antenna system (DAS) with or without signal boosters as needed.

e) Applicable Federal Communications Commission rule compliance.
(reference FCC Rules CFR Part 47, 90.219)
A very important statement used in most codes is; "AMPLIFICATION SYSTEMS ALLOWED" The FCC rules restrict the right to operate signal boosters to duly authorized (FCC licensed) system owners, or others the licensee may give explicit permission to do so.

This statement serves the legal purpose of authorizing others the use of signal boosters to meet the code requirements.

Equally important is the mandatory use of "FCC certified" equipment. (In the past this was called 'FCC approved' or 'type accepted' and the terms were somewhat interchangeable. "FCC certificated" should be used in new codes.)

As the licensee, you are responsible for compliance to the FCC rules and those rules require you to use FCC certificated equipment. As the FCC licensee you will still be liable for compliance even though you did not purchase or install the equipment required by your code.

There are some products illegally being advertised and sold without FCC certification. It does not matter if the source promises to get certification later, legally certification must exist when the equipment is placed into operation. It is important that to use legal and well designed equipment to avoid fines or orders to cease operations due to interference caused by unstable designs.

f). Methodology used to verify and maintain compliance.
This is an area of great differences between many ordinances. Several methodologies are included in the attached examples. This is also the area where some codes become onerous and difficult to comply with due to excessive quantities of measurements, overly restrictive measurement technique details and documentation.

The most universally accepted method is generally the ' 50 ft by 50 ft grid' measurement approach because most agencies have the capability to perform the measurements and the tests can be accurately repeated to confirm corrective actions and archived for future reference.

In any case, the performance tests should be performed in a manner the agency is comfortable with, even if that is simply a go-no go portable radio talk test.

g). Penalty for non-compliance.
In most cases the penalty is suspension of the Occupancy Permit to the structure until the code is met following a reasonable period after a citation of non-compliance. A typical scenario for an existing structure is; the discrepancy is discovered during a routine fire inspection and a citation is issued.

Then compliance is required by the next routine fire inspection. The interval may be a year so there is not normally any undue pressure on the building owner to take immediate action. However the building owner should be made aware that the in-building installation process may take 3 to 6 months from start to end.

Some codes, such as Grapevine Texas, include fines and or jail for continued non-compliance. We do not know if any such penalty has actually been imposed.

h). Exemptions
Most residential, (R1, etc) structures are exempted. Buildings less than three stories with less than 50,000 sq. ft. per floor are exempt UNLESS they include below grade basements, metal wall construction or contain hazardous materials.

IMPORTANT: Elevator coverage is usually exempt since elevators are not in service during emergencies, fires and earthquakes. For the same reason, it is important to include radio coverage within stairwells, which are often inherently shielded from outside radio signals, within the scope of the code within the scope of the code.

i). Authority citations.
Most codes have been advanced through routine authority channels, with recommendations, studies, hearings, etc. The most cited umbrella codes are Uniform Fire Codes; NPFA, UFC, IFC, etc.

Three interesting application of uniform codes are;

- Boston linked their in-building codes to NFPA central alarm codes, even requiring an audible failure alarm as part of the signal booster. Now they find recent changes in the NFPA section they used requires the coaxial cables and equipment to meet a 4 hour survivability condition. This is not a problem except for existing equipment and cables that were not always installed in protected areas. In fact, a recent fire inside a high rise trash chute melted a nearby coaxial cable feeding their in-building system. This will not happen following the new standards.

- Almost every jursidictions rotinely adopt standard codes approved by the National Fire Protection Association (NFPA), including the International Building Code (IBC), Uniform Building Codes (UBC) and the National Electrical Code (NEC). In doing so, the authority amends or expands upon these codes to better fit local requirements using their normal ordinance processes. Some jurisdictions have recently started using the following IBC code to implement in-building communications immedilately without going through lengthy routine code adoption processes. Notice it is the 'exception' that enables in-building radio systems to be substituted for mandatory wired communications systems;

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IBC (2003) : Section 907.2.12.3 Fire department communications system. An approved two-way, fire department communications system designed and installed in accordance with NFPA 72 shall be provided for fire department use. It shall operate between a fire command center complying with section 911and elevators, elevator lobbies, emergency and standby power rooms, fire pump rooms, areas of refuge and inside closed exit stairways. The fire department communications device shall be provided at each floor level within the enclosed stairway. EXCEPTION: Fire department radios systems where approved by the fire department.
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Also note the IBC Section (907.2.12) only applies to "high rise" buildings, defined as buildings having human occupancy located more than 75 feet (approximately 7 stories) above the lowest level of fire vehicle access. There are some exceptions so this code should be considered in its entirety. The local fire department should have the complete IBC codes on file. In some new structures, in-building radio systems can be cheaper to implement than wired systems.

- Prior to the availalability of IBC Section 907.1.12.3, South Metro Fire (Denver) used Section 101.3 of the Uniform Fire Code and Section 104.l of the 2000 International Fire Code which authorizes the chief to make and enforce rules and supplemental regulations in order to carry out the application and intent of its provisions. Section 1001.9 of the Uniform Fire Code and Section 102.8 of the 2000 International Fire Code authorizes the chief to require additional safeguards consisting of special systems suitable for the protection of the hazard involved. Therefore, South Metro Fire Rescue requires that a public safety radio amplification system shall be installed within certain buildings and structures within the South Metro Fire Rescue district to provide for emergency communications to and from the emergency communication center.

Additional equipment minimum specifications.
There are some additional hardware requirements that are frequently included in the 'acceptable equipment' specifications.

Most ordinances require 12 hours battery back-up power. Typical statement; "If any part of the installed system or systems contains an electrically powered component, the system shall be capable of operating on an independent battery and/or generator system for a period of at least twelve (12) hours without external power input. The battery system shall automatically charge in the presence of an external power input. "

Some require the use of a water-tight case, typically NEMA-4, which is an industry standard specification for a sealed wall mounted cabinet. The reason for this requirement is the signal booster may be located in an equipment room that may become water soaked or sprayed with fire retardants during a fire. The closed cabinet also reduces tampering.

Those agencies using 800 MHz NPSPAC channels or other closely grouped channels often specify additional adjacent channel rejection ('notch') filters to reduce the negative impact from nearby Nextel and cellular signals. This is highly recommended.

Additional Personnel Qualifications.
Newer ordinances are requiring the parties who design, install to maintain the in-building systems to have minimum qualifications and /or experience with such systems. In-building systems are not common practice for most electricians or many communications service companies and may not be capable of compliance to your code.

More and more ordinances are requiring the technical work to be performed by people who have;
- Factory Certified training on the signal boosters they use.
- FCC or national association certified skills.
- Contractors licenses (may already be required by existing building codes)

Example: FCC-Certified Technician: An individual who is qualified with a General Radiotelephone Operator License (GROL/PG), or equivalent, to review design plans and perform tests. Conclusion: The use of codes or ordinances to assure radio communications for public safety agencies is a proven and acceptable solution.

As evidenced by the many examples of successful existing codes, the construct of these codes follows common terminology and technology, reducing the necessity of expensive development of a totally new code and the attendant delays of such an effort.

In most cases the agency's own communications department can provide the few technical specifics required.

Additional resources and copies of existing codes may be found at www.RFSolutions.com/fcc.htm.
To arrange for copies of this discussion in power point format or a live presentation, contact the author.
Jack Daniel
Jack Daniel Company
800-NON-TOLL
email: JackDaniel@RFWise.com
web site: www.RFSolutions.com

NOTICE: This document is © 2005 Jack Daniel Company All rights reserved. This document may be re-distributed only in it's entirety including copyright notices by non-profit state and local government agencies and TX RX Systems Inc. All other use or sale of all or any portion of the original content of this document in any form for commercial purposes is specifically forbidden.