Federal Communications Commission
Washington, D.C. 20554
December 6, 2016
Standard Occupational Classification Policy Committee
United States Bureau of Labor Statistics
2 Massachusetts Avenue NE, Suite 2135
Washington, DC 20212
RE: 2018 SOC Classification of Public Safety Telecommunicators
Dear Members of the Committee:
I am writing today to provide the perspective of the Public Safety & Homeland Security
Bureau (Bureau) of the Federal Communications Commission regarding the ongoing issue of
classification of public safety telecommunicators. The Bureau is responsible for the
implementation of the Commission's regulations and policies with respect to public safety
communications, which includes the nation's 911 system. In that capacity, we work closely with
state and local agencies that operate the nation's Public Safety Answering Points (PSAPs)
responsible for 911 call-handling and dispatch. In addition, as the federal agency with primary
regulatory responsibility for the nation's communications sector, we are very familiar with -- and
have observed first-hand -- the impact of "next-generation" communications technology in
changing and expanding the typical scope of work performed by many public safety
telecommunicators. Because the new occupational classifications that you are developing will
be in effect for a 10-year period, we believe it is important that the classifications accurately
reflect these ongoing trends.
Currently, the nearly 100,000 men and women working as 911 call-takers and dispatchers
are classified under the "Police, Fire, and Ambulance Dispatcher" category (43-503 1), which is
grouped within Standard Occupational Classification (SOC) Major Group 43-0000, "Office and
Administrative Support Occupations," a category that also includes commercial and other non-
public safety call-takers and dispatchers, as well as many other categories of administrative
workers. In response to the May 22, 2014, Federal Register Notice seeking comment whether
this classification should be modified,' the Standard Occupational Classification Policy
Committee (SOCPC) received comments advocating (1) that employees working in this field
receive a new occupational classification as "public safety telecommunicators," "emergency
service telecommunications specialists," or "911 communications operators," and (2) that this
See 79 Fed. Reg. 29620, May 22, 204.
classification be moved from Major Group 43-000 to Major Group 33-000, "Protective Services
Occupations."2
The SOCPC has initially declined to accept these recommended changes, stating that in
its view the work performed by public safety telecommunicators "is that of a dispatcher, not a
first responder," and that separating public safety telecommunicators from other dispatcher
categories "would be confusing."3 The SOCPC also recommended against reclassification on
the grounds that '{m]ost [public safety] dispatchers are precluded from administering actual care,
'talking' someone through procedures, or providing advice,"4 and that they are "often located in
a separate area from first responders and have a different supervisory chain."5
Based on our experience working with the 911 community, the SOCPC's initial findings
appear to reflect an incomplete and inaccurate understanding of the work performed by today's
public safety telecommunicators. As you enter the next phase of the decision-making process,
we urge you to carefully consider the comments that have been submitted in response to the
SOCPC's initial findings by public safety organizations and individual telecommunicators,6
Among other things, these comments document that in the current 911 system, public safety
telecommunicators: (1) under established protocols and procedures, provide assistance, guidance,
and life-saving advice to 911 callers in many emergency situations;7 (2) are involved in the
planning, coordination, and direction of response activities both before and after emergency
personnel are dispatched to the scene;8 (3) receive specialized and rigorous training in
emergency response and crisis management skills;9 and (4) operate within organizations and
under chain-of-command structures that group them with other public safety professionals,
including police, fire, and emergency medical personnel.10
We also believe that your classification analysis should be informed by the impact that
the transition to Next Generation 911 (NG9 11) is already having and will continue to have on the
work performed by public safety telecommunicators. Throughout the next decade, the Nation's
PSAPs will be at the center of this transition as they migrate from legacy circuit-switched
telephone technology to Internet Protocol (IP) based networks that will support not only 911
2 See, e.g., Comments of APCO International (2014).
See United States Bureau of Labor Statistics (BLS), at http://www.bls.gov/soc/20 18/soc responses.htm.
Id.
Id. The Office of Management and Budget has sought comment on SOCPC's initial recommendations, See 81
FED.REG. 48303 (July 22, 2016).
6 See, e.g., Comments of APCO International (filed Sep. 20, 2016) (APCO 2016 Comments); Comments of the
National Emergency Number Association (NENA) (filed Sep. 20, 2016) (NENA 2016 Comments); Comments of
Texas 9-1-1 Alliance (filed Sep. 13, 23016, via regulations.gov) (Texas Alliance 2016 Comments).
See NENA 2016 Comments at 2; Texas Alliance 2016 Comments at 1; APCO 2016 Comments at 8-10.
8 See Texas Alliance 2016 Comments at 1; NENA 2016 Comments at 2-3.
° See Texas Alliance 2016 Comments at 1-2; APCO 2016 Comments at 7, 13-14; NENA 2016 Comments at 5-6.
10 See NENA 2016 Comments at 4-5; APCO 2016 Comments at 20-21.
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voice communications but also text, data, and video, data analytics, GIS mapping, and targeted
alerting. Even in the early stages of this transition, the shift in technology is leading to an
evolution in the role of public safety telecommunicator, which increasingly encompasses not
only call-taking and dispatch, but also the integration and analysis of multiple sources of
information to determine the appropriate response to any given emergency.
Today, many PSAPs are also taking on a new role in which they not only receive 911
calls and dispatch first responders, but also analyze external information sources, such as photos;
video from police body cameras, traffic cameras, or other publicly accessible cameras; machine-
to-machine sensor inputs, such as Shot-Spotter; and alarms indicating traffic flow. Synthesizing
	
this information as a team, telecommunicators in the PSAP disseminate alerts or "reverse 911"
calls to the public as part of the emergency response. They coordinate activities with other
agencies and, at times, are brought directly into the response when an on-scene participant
engages the telecommunicator for mediation or other dc-escalating effort. These trends provide
clear indication of the expanded scope of responsibility for public safety telecommunicators that
exists in the NG9 11 environment.
The sweeping changes in the role of public safety telecommunicators have been
documented in detail in a report issued on December 2, 2016, by the Task Force on Optimal
PSAP Architecture (Task Force), an expert advisory group convened by the Commission to
provide guidance to PSAPs on how to optimize technology, operations, and funding to support
the migration to NG9 11.11 The report, issued by Working Group 2 of the Task Force to assist
PSAPs in assessing their NG91 1 readiness, describes the changing role of the public safety
telecommunicator in the current 911 environment and the additional evolution that will occur as
PSAPs transition to NG91 1:
The public safety telecommunicator's position has transformed from a clerical staff
handling telephone calls and incidents with manual methods, to technically savvy
protective service professionals managing multiple integrated technology systems to
track and manage public safety field resources and responses. The public safety
telecommunicator position will continue its evolution with the integration of Next
Generation 911 technologies.12
The Task Force Report confirms that in the current 911 environment, public safety
telecommunicators already have multi-faceted responsibilities and must meet highly specialized
training and certification requirements related to emergency response:
'See generally, Federal Communications Commission, Task Force on Optimal Public Safety Answering Point
Architecture (TFOPA), at https://www.fcc.gov/about-fcc/advisory-comm ittees/general/task-force-optimal-public-
safety-answering-point.
2 See TFOPA Working Group 2, Phase II Supplemental Report: NG9-1-1 Readiness Scorecard at 55, Sec. 4.11.1,
https://transition.fcc.gov/pshs/9 11 !TFOPA/TFOPA WG2 Supplemental Report- 12021 6.pdf (TFOPA Supp.
Report) (issued Dec. 2016).
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[P]ublic safety telecommunicators are required to operate a sophisticated work station
comprised of multiple networked computer and technology systems. . . [as well as] be
able to quickly answer, elicit pertinent information from a distraught caller, analyze given
information, and expediently make appropriate entries into various technology systems.
Additionally, in many jurisdictions public safety telecommunicators are required to be
licensed or certified as public safety telecommunicators, hold State Criminal Justice
Information System and Federal Bureau of Investigation National Crime Information
Center access permissions and also be certified emergency medical dispatchers. In many
jurisdictions, oftentimes public safety telecommunicators need certifications in
cardiopulmonary resuscitation (CPR) and in automated external defibrillation (AED).'3
The Task Force Report also highlights the ways in which the transition to NG9 11 will further
expand the responsibilities of public safety telecommunicators:
New skill sets will be needed for 9-1 -1 Telecommunicators [including] how broadband
implications and implementations will affect the PSAP. . . . NG9-1-l technology will
enable PSAPs to utilize broadband data in ways that will transform how the public
reaches 9-1-1 and how telecommunicators communicate with first responders. Other IP-
based technologies, including those supported by smartphones, tablets, and mobile apps,
are available throughout the general public and are capable of sending an array of
information to the PSAP. As a result, PSAPs of the future will be the nerve center,
managing data-rich communications via broadband technology with 9-1 -1 callers and
first responders. 9-1-1 Authorities need to be mindful that NG9- 1-1 and Public Safety
broadband operations and policies should be built into PSAP training and education,'4
The Task Force also found that the convergence of communications in the PSAP around
Internet Protocol-based networks, databases, and terminals, creates an additional need for
telecommunicators to be aware of cybersecurity threats and trained to recognize, avoid, respond,
and recover from cyberattacks. This year alone, a spate of ransomware and telephone denial-of-
service (TDoS) attacks have hit the PSAP community, placing additional professional demands
on telecommunicators.
The occupational classifications you are developing will be in effect for the next decade.
Therefore, it is vitally important that, in addition to recognizing the "first responder" role
performed by telecommunicators in most of our nation's PSAPs, the classification also take into
account the major changes that are occurring in the 911 technology landscape and the profound
impact these changes are having on the work performed by 911 professionals. Although not all
PSAPs will experience this change uniformly, the focus of public safety telecommunicator
recruiting, hiring, and training throughout the next ten years will be on developing a workforce
that can take full advantage of the technological capabilities ofNG9ll to protect and serve the
public.
TFOPA Supp. Report at 55, Sec. 4.11.1.
" TFOPA Supp. Report at 58, Sec. 4.11.3.
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Thank you for your consideration of our views. If you have questions or would like
additional data to assist in your analysis, we would be happy to meet with you to address these
issues in greater detail.
Sincerely yours,
David Grey Simpson
Rear Admiral, USN (Ret.)
Chief, Public Safety and Homeland Security Bureau
cc:
	
Joe Heaps, National Institute of Justice, US Department of Justice
Laurie Flaherty, National 911 Program Office, US Department of Transportation
Ron Hewitt, Office of Emergency Communications, US Department of Homeland Security
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