Previous blogs have highlighted the difference between ERRCS and ERCES. We’ll use the term “ERRCS,” the preferred acronym in San Francisco. We thought it would be helpful to revisit some basics, as many building owners remain uninformed about the requirement (our apologies to the ERRCS vendors and experts). Therefore, here are the basics:
1. Most building materials block emergency radio signals
- Even low-E glass, concrete, and metal frames can significantly diminish radio signal strength.
- That stunning new LEED-certified building? Likely a dead zone for first responder radios without ERRCS.
2. ERRCS are not Wi-Fi or cell boosters
- People often confuse them with consumer signal boosters. ERRCS are specifically tuned to public safety radio bands, such as:
- 700 MHz / 800 MHz (common for police/fire)
- VHF (used in rural areas)
- Amplifying other signals can disrupt emergency systems — and that’s against the law.
3. They’re often mandated retroactively after fire code changes
- Recent code updates, such as NFPA 1225 from the 2022 edition, are abruptly making existing buildings non-compliant.
- This means owners are rushing to test and possibly install expensive systems in older buildings they believed were adequate.
4. They require annual testing, which can be expensive.
- Local fire jurisdictions often mandate annual signal strength verification.
- Testing requires walking through the entire building with specialized equipment. If any parts fail, you must repair them.
5. They can actually be shut down if they interfere with public systems
- If an ERRCS is improperly installed or unlicensed, it may “scream” across radio bands and interfere with public safety communications.
- In that case, the FCC or the local authority can demand its immediate shutdown — a potentially significant liability.
6. The ERRCS design must be customized for each building
- No two systems are alike — even identical buildings in different cities will require different setups based on:
- Nearby cell towers
- Geography
- Radio frequency use by local emergency services
7. Some jurisdictions won’t issue occupancy permits without ERRCS
- A working ERRCS is essential for final inspections and occupancy, particularly in high-rise or underground structures.
- Sometimes, developers fail to plan for this, leading to delays in move-in or leasing.
So which states are most aggressive in enforcing ERRCS/ERCES?
Some states and local jurisdictions are significantly more aggressive in enforcing ERRCS/ ERCES requirements, often exceeding national fire codes. Here are the most stringent states (and a few standout cities) based on enforcement, permitting, and inspection rigor:
1. California
- Why? Earthquakes, wildfires, and high-density cities.
- Notable jurisdictions:
- Los Angeles: mandates extensive ERRCS in almost all new commercial buildings, high-rises, and underground structures.
- San Francisco: Strict plan review and testing requirements — zero tolerance for dead zones in stairwells and basements.
- Extras: Some counties, such as Santa Clara, even mandate redundant power and backhaul systems for ERRCS.
2. New York
- Why? A high-rise city, the legacy of 9/11, and very active fire code enforcement.
- Notable jurisdictions:
- NYC mandates Public Safety Distributed Antenna Systems (DAS) in accordance with FDNY code.
- You must conduct radio signal surveys for every floor and enclosed area.
- Enforcement is strict — noncompliance stops occupancy.
3. Arizona
- Why? Rapid urban development and challenging radio frequencies caused by mountains and desert terrain.
- Standout: The Phoenix Fire Department is among the strictest in the country.
- Requires third-party testing; all designs must meet specific performance levels before permit approval.
4. Florida
- Why? Hurricanes, high humidity (which affects signal), and densely packed high-rises.
- Notable jurisdictions:
- Miami-Dade & Broward Counties require testing and installation in nearly all commercial buildings.
- Many cities require NFPA 1225 and FCC license coordination.
5. Colorado
- Why? Mountains and challenges in emergency response in remote areas.
- Denver, Boulder, and other cities are very proactive — ERRCS is mandatory in all buildings where 95% coverage is not demonstrated.
6. Texas
- Austin, Houston, and Dallas, in particular, adhere to strict interpretations of IFC and maintain aggressive inspection requirements.
- Dallas Fire-Rescue has established specific standards for “two-way radio signal strength” that exceed basic code requirements.
Summary
Most enforcement occurs locally, so some counties or cities may be strict, even in lenient states. It all depends on:
- How many radio dead zones have they had to deal with?
- The proactivity of the Fire Marshal’s office.
- Recent local incidents (such as fires, mass shootings, etc.)
IBWS specializes in ERRCS. If you need assistance, please reach out to us.