The Safer Buildings Coalition emphasizes indoor wireless coverage for emergency communication, warns that…

COMMENTS OF THE SAFER BUILDINGS COALITION

EXECUTIVE SUMMARY

The Safer Buildings Coalition (“SBC”) is a cross-sector membership organization of public safety agencies, industry organizations, and the owners and operators of buildings where in-building coverage is required. SBC does not offer scientific conclusions on the biological effects of radiofrequency (“RF”) energy and defers on those questions to the expert agencies and standards bodies responsible for them. SBC’s comments address the public safety benefits and costs that any complete assessment of RF exposure policy must weigh.

In-building wireless coverage is a cornerstone of emergency communications. Americans spend about 90 percent of their time indoors, and about 80 percent of 911 calls are placed from wireless devices. Cellular coverage allows building occupants to reach 911, and public safety radio coverage allows first responders to communicate once they are inside. The International Fire Code (“IFC”) and the National Fire Protection Association’s (“NFPA”) NFPA 1225 require building owners to provide and maintain minimum levels of public safety radio coverage.

That coverage depends on wireless infrastructure engineered to existing federal standards. Distributed antenna systems (“DAS”), Emergency Responder Communications Enhancement Systems (“ERCES”), indoor small cells, signal boosters, and Wi-Fi are required to comply with Federal Communications Commission (“FCC”) rules, including the FCC’s RF exposure requirements. More than 830,000 indoor small cell and DAS nodes are in service nationwide, and in-building systems typically cost $1 to $5 or more per square foot.

Changes to RF exposure limits could force costly redesign and reduce coverage. Lower permissible antenna power, minimum distances between antennas and occupants, or setbacks from homes, schools, and healthcare facilities would require disproportionately more antennas, could render existing systems incompatible with new limits, and could place building owners in conflict with fire-code signal requirements. Redesign or replacement of only 10 percent of existing indoor nodes would cost an estimated $820 million, before counting Wi-Fi networks, public safety ERCES, equipment removal, and recertification.

Policy focus should be directed at eliminating in-building dead zones. Federal law already requires the FCC to measure and map broadband availability, but no comparable data exists for coverage inside buildings. Publishing in-building coverage data would inform policymakers, allow building owners to make informed investment decisions, and let market forces drive private investment to close the in-building coverage gap.

SBC recommends that the Department of Health and Human Services (“Department” or “HHS”) base any conclusions on robust, peer-reviewed scientific evidence; evaluate the consequences for public safety communications before recommending any change to exposure limits, siting restrictions, or setbacks; preserve regulatory certainty and coordinate with the FCC in its parallel proceeding; and support the collection and publication of in-building wireless coverage data.