Who does what in an Emergency Responder Communication Enhancement System (ERCES)?
The answer: Several organizations are typically involved in designing, installing, and maintaining an ERCES. Each has a distinct role. This matrix, courtesy of the Puget Sound Emergency Radio Network (PSERN), outlines the various organizations and their roles. These roles are categorized as the responsible party (R), accountable party (A), consulted party (C), or informed party (I).
The building owner and DAS vendor are typically on the commercial side of the fence. On the government side, you have the Authority Having Jurisdiction (the Fire Code Official in the matrix above) and the FCC license holder (Frequency Licensee above).
The Authority Having Jurisdiction (AHJ) and the FCC license holder each play distinct yet critical roles in ensuring the system is safe, compliant, and legal.
Authority Having Jurisdiction (AHJ)
The AHJ is typically the local fire marshal or building department official responsible for code enforcement. Their roles include:
| Responsibility | Description |
|---|---|
| Code Compliance | Ensures ERCES is installed in accordance with NFPA 1225, IFC, and local fire code requirements. |
| Coverage Verification | Requires and reviews radio signal coverage testing (20-grid test) before and after installation. |
| System Approval | Approves system design, components, and installation methods—often requiring engineered plan submission. |
| Annual Inspections | May mandate annual recertification/testing of the system. |
| Survivability Enforcement | Enforces survivability standards (e.g., 2-hour fire-rated cable pathways in critical areas). |
| Right to Disable | Can order shutdown or correction of a system that causes harmful interference or doesn’t meet public safety requirements. |
FCC License Holder (Typically the owner of the Public Safety Radio System)
This entity (usually the local government or public safety agency) is licensed by the FCC to operate the public safety radio frequencies used inside the building via the ERCES. Their roles include:
| Responsibility | Description |
|---|---|
| Frequency Authorization | Grants permission to rebroadcast their licensed frequencies inside the building. This is required under FCC Part 90 rules. |
| Signal Integrity | Ensures that the ERCES does not interfere with the public safety radio system (no noise, oscillation, or feedback). |
| Final Sign-Off | May require testing to validate that their network is not degraded and may need to approve or witness acceptance testing. |
| Revocation Rights | Has the right to request shutdown of a system causing interference to their network. |
| No Re-Radiation Without Approval | FCC regulations (Part 90.219) make it illegal to amplify or retransmit a public safety frequency without express approval from the license holder. |
So, to summarize: they play distinct roles and building owners and system integrators need to work with both organizations during an ERCES project.
| Role | AHJ | FCC License Holder |
|---|---|---|
| Enforces code? | ✅ Yes (NFPA/IFC) | ❌ No |
| Grants frequency use? | ❌ No | ✅ Yes |
| Approves system design? | ✅ Yes | Often involved or consulted |
| Performs inspections? | ✅ Yes (initial + periodic) | Occasionally (for system impact) |
| Can shut system down? | ✅ Yes (non-compliance) | ✅ Yes (interference) |
| Legal authority source | Local jurisdiction/fire/building code | Federal license (FCC Part 90) |
If you are designing, installing, or maintaining an ERCES, you must coordinate with both:
- The AHJ for code compliance and installation approval, and
- The FCC license holder (usually via the radio system manager) for signal permission and interference prevention.
IBWS tests, designs, and consults on ERCES and Cellular DAS projects. Call us if you need help.
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