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The Joint National EMS Leadership Conference
April 11, 2011
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of:
Service Rules for the 698-746, 747-762 and 777792 MHz Bands
Implementing a Nationwide, Broadband,
Interoperable Public Safety Network in the 700
MHz Band
Amendment of Part 90 of the Commission’s Rules
WT Docket No. 06-150
PS Docket No. 06-229
WP Docket No. 07-100
The Joint National Emergency Medical Services Leadership Conference (JNEMSLC) submits
these comments in response to the Federal Communication Commission’s (Commission or FCC)
Fourth Further Notice of Proposed Rulemaking (Fourth FNPRM) released January 26, 2011 in
the above-captioned proceeding.
The JNEMSLC includes five national emergency medical services (EMS) associations:
• The National Association of EMS Educators
• The National Association of EMS Physicians
• The National Association of Emergency Medical Technicians
• The National Association of State EMS Officials
• The National EMS Management Association
The members of the these associations practice in, and in many cases lead, emergency medical
care and transportation systems at the local, regional, state, and national levels in the United
States. We are EMTs and paramedics, service chiefs and managers, emergency physicians and
Page 1 other clinicians, EMS educators, and system chiefs and regulators.
One of our members, the National Association of State EMS Officials (NASEMSO), is an active
member of the National Public Safety Telecommunications Council (NPSTC) and the Public
Safety Spectrum Trust (PSST). The JNEMSLC joins our sister association in endorsing the
comments of NPSTC and the PSST in this proceeding.
We wish to express further emphasis and detail in two areas, however. The first is the general
approach of the FCC in this proceeding, and the second pertains to "Section 337 Eligible Users"
and its potential impact on EMS in this country.
On the first point, we commend the Commission on its interest in assuring the success of a
nationwide public safety broadband system, and the thought evident in the queries in this
FNPRM. However, we also believe that the FCC is asking for detail that is not yet available, in
many cases, and signals an interest in operational matters that would be appropriate for the
governing and operating body of a national public safety broadband system. We join the NPSTC
and PSST in suggesting that the FCC does not, as the nation's communications system regulatory
arbiter, have such a role without creating significant conflict in its missions.
We believe that when the D Block of the 700 MHz bandwidth is allocated to public safety by
Congress, it will be added to the existing bandwidth licensed by the PSST and will be licensed as
a whole by a nationwide network governance entity (NNGE) which will function to govern and
coordinate the operations of the nationwide system. This NNGE cannot be the FCC, as the FCC
must be reserved to exert its regulatory authority in issues that may arise from operation of that
system. We support the notion of a nationwide, public safety controlled, quasi-governmental
NNGE that has the ability to remain bureaucratically nimble in its development, governance, and
operation of the nationwide network.
The second point involves the proceeding's Section IV.F. on "Section 337 Eligible Users".
Specifically, we wish to comment on the application of this section, and subparagraphs 134 to
138, to primary users in the EMS community.
The EMS response community consists of a variety of agencies that respond to a medical
emergency. Some respond to provide patient care before the ambulance arrives. Others provide
emergency medical care en route by air, ground, or water to the hospital or other facility, and yet
others provide specialty emergency care, such as advanced life support back-up to basic life
support transport services. The other major EMS system participant is the hospital or other health
care facility that provides medical direction to EMS providers in the field. These may be public
or private agencies, operated under a variety of business/governmental models.
For these purposes, there is less problem with the following parts of Section 337 of USC 47 as
they apply to all of these providers of EMS (if "governmental entity whose primary mission is
the provision of such services" includes municipalities and other governmental bodies who
contract with EMS providers for service in their governmental boundaries):
The term "public safety services" means services Page 2 (A) the sole or principal purpose of which is to protect the
safety of life, health, or property;
(B) that are provided (i) by State or local government entities; or
(ii) by nongovernmental organizations that are authorized
by a governmental entity whose primary mission is the provision of such services...
Where Section 337 begs clarification is with the next phrase:
"(C) that are not made commercially available to the public by the provider".
It is common to most of the EMS system providers described above, that they charge patients
for the medical care and transport received. If this type of system support necessity is interpreted
as precluding EMS from the definition of eligible public safety services because it violates the
"commercially available" restriction, it will stop EMS in its tracks nationwide. Historically and
anecdotally, this has been at least an unevenly applied, veiled threat that has kept some types of
EMS from licensure in traditional EMS channels. It begs clarification and correction so that
EMS can continue as a full public safety partner in the new broadband system. The future of
EMS, and its ability to save lives, depends on broadband.
Thank you for your consideration of these comments.
Kevin McGinnis
Chair and Communications Technology Advisor
Joint National EMS Leadership Conference
Page 3