FCC Petition Published for Public Comment: Signal Booster Authorization Framework - What You Need to Know
UPDATE: September 16, 2025
Executive Summary
The Safer Buildings Coalition has filed a formal petition with the Federal Communications Commission (FCC) requesting amendments to 47 CFR § 90.219 to establish a comprehensive authorization framework for Part 90 industrial signal boosters.
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Interested parties may file comments on or before October 16, 2025. Interested parties may file replies on or before October 31, 2025.
Signal boosters are an important tool for addressing in-building wireless coverage gaps that ensure reliable public safety communications. However, while FCC rules require "express consent" from frequency licensees before installation, no standardized framework exists for requesting, evaluating, granting, or tracking this consent. The absence of rule-based coordination procedures has led to improper deployments that can cause harmful noise and interference with the very systems they are designed to support, while creating resource drain and inefficient use of staff and budget across federal, state, and local agencies.
What does the Petition Say?
The petition asks the FCC to establish clear, standardized procedures that reinforce licensee authority while reducing administrative burden through published technical criteria, streamlined compliance processes, and systematic tracking. By addressing coordination failures proactively, the framework reduces the need for reactive government enforcement while leveraging market-based solutions. The petition creates these standardized procedures for the "express consent" requirement established in the 2013 Report and Order (WT Docket No. 10-4).
What is the current FCC "Authorization Framework" for deploying Signal Boosters?
Here are the current FCC rules about licensees authorizing signal boosters. Do you think this is adequate?:
47 CFR § 90.219 - Use of signal boosters - (b) Authority to operate. (1) PLMRS licensees may also consent to operation of signal boosters by non-licensees (such as a building owner or a signal booster installation contractor) within their service contour and across their applicable frequencies, but must maintain a reasonable level of control over these operations in order to resolve interference problems.
(i)Non-licensees seeking to operate signal boosters must obtain the express consent of the licensee(s) of the frequencies for which the device or system is intended to amplify. The consent must be maintained in a recordable format that can be presented to an FCC representative or other relevant licensee investigating interference.
Let's sum that up:
Licensees can authorize third-parties to install signal boosters to amplify their applicable frequencies.
Non-licensees seeking must obtain the express consent of the licensee(s) and the consent must be maintained in a recordable format.
What's missing?
What is the criteria for granting (or denying) permission to rebroadcast?
What is the process?
What does recordable format mean? Where is it written down? Is it in a database where responsible stakeholders can look it up?
Is permission for one year? Three years? Forever?
If a signal booster is creating noise and interference, is there a good repository of where they were installed so I can quickly research and identify where any problems may be?
THIS is why SBC is asking the FCC to update part 90 rules to establish a Formal Authorization Framework for Signal Boosters!
FCC Signal Booster Petition - Public Comment FAQ
What is the FCC Seeking Comments On?
The Federal Communications Commission has issued Public Notice DA 25-853 (, seeking public comment on the Safer Buildings Coalition's petition to revise the rules governing Part 90 signal boosters (also known as BDAs, ERCES, or ERRCS systems). The FCC is specifically asking for input on three critical areas:
1. Problem Validation: Do you believe that improper deployment of signal boosters creates problems? Does it strain resources?
Do improperly deployed signal boosters actually cause interference to public safety radio communications?
Is the problem as widespread as SBC claims based on documented evidence from DHS/CISA and APCO surveys?
2. Solution Effectiveness: Will SBC's proposed solutions help? Do you disagree? Have Concerns?
Will SBC's proposed authorization framework actually solve these interference problems?
Are the proposed rule changes comprehensive enough to address root causes?
3. Alternative Solutions: What else will help matters? Be as creative as you like.
Are there better approaches than what SBC has proposed?
Should the FCC require automatic shutdown features for improperly installed signal boosters?
What other technical or regulatory solutions might work?
Why Should You File Comments Now?
This rulemaking proceeding will shape the regulatory framework that governs signal booster deployment nationwide. As noted in the SBC petition, the current regulatory framework was established in 2013 and left significant implementation gaps for industrial signal booster deployment.
Your comments will directly influence:
How signal boosters are authorized and deployed nationwide
The technical standards and safety requirements for these systems
The administrative processes that affect project timelines and costs
The interference protection mechanisms for public safety communications
Rare Opportunity to influence the next decade of Signal Booster Rules
The last comprehensive look at Part 90 signal booster rules was in 2013 - over a decade ago. Given the FCC's typical rulemaking cycles and the complexity of these technical issues, we could easily be looking at another decade or more before there's another opportunity for comprehensive reform. Whatever framework emerges from this proceeding, we'll likely be living with it for many years to come. That's why getting it right now is so critical. People have to formally comment to the FCC, or the Commission could rightfully conclude "Nothing to see here…."
This isn't just a regulatory issue affecting one group - it's a complex ecosystem involving first responders whose lives depend on reliable communications, public safety radio operators managing interference complaints, fire code officials trying to enforce building safety, property owners facing unpredictable costs and delays, manufacturers designing equipment, and contractors installing systems. Each stakeholder group has skin in the game, and each brings essential expertise to solving these coordination challenges."
The Commission is directly asking whether signal boosters should be required to have automatic shutdown capabilities when improperly installed - similar to existing rules for consumer cellular boosters. That's not a theoretical policy question for manufacturers; that's a potential mandate that could fundamentally alter product design, development timelines, and manufacturing costs. Any manufacturer who doesn't weigh in on this specific question may find themselves scrambling to redesign products to meet new requirements they had no voice in shaping."
What's at Stake for Each Stakeholder Group?
Public Safety Agencies (Fire, Police, EMS)
Critical Stakes:
Life Safety: Ensure continued support for quality in-building public safety communications coverage while maintaining existing outdoor public safety communications coverage
Operational Reliability: Poorly deployed systems create dead zones where reliable coverage previously existed
Resource Protection: Stop diverting personnel from emergency response to resolve preventable interference issues
System Integrity: Establish clear standards to prevent radio system failures during emergencies
Key Comment Topics:
Share specific interference incidents and their operational impact
Document resource costs of troubleshooting signal booster problems
Describe coordination challenges with building owners and contractors
Support or propose modifications to authorization procedures
Public Safety Radio System Operators (Frequency License Holders; Licensees)
Critical Stakes:
Life Safety: Ensure continued support for quality in-building public safety communications coverage while maintaining existing outdoor public safety communications coverage
Regulatory Clarity: Establish standardized procedures for signal booster authorization and testing
Resource Management: Obtain framework for handling the growing volume of signal booster requests
Technical Authority: Ensure frequency licensees maintain appropriate control over their spectrum
Interference Mitigation: Create systematic approaches to prevent and resolve interference
Key Comment Topics:
Current workload and resource constraints for reviewing signal booster requests
Technical review capabilities and staffing needs
Coordination challenges with multiple stakeholders
Effectiveness of proposed timeline and evaluation criteria
Authorities Having Jurisdiction (AHJs) - Fire and Building Code Officials
Critical Stakes:
Life Safety: Ensure continued support for quality in-building public safety communications coverage while maintaining existing outdoor public safety communications coverage
Regulatory Clarity: Clear delineation between fire code enforcement authority and FCC rules enforcement
Resource Allocation: Make sure Code Officials can focus on ERCES Code Enforcement and better define tasks and responsibilities that are more appropriately assigned to Frequency License Holders
Responsibility Definition: Establish clear lines of responsibility for testing, design review, periodic inspection and enforcement
Technical Support: Obtain adequate advance guidance from frequency licensees that can be shared with building owners and contractors
Key Comment Topics:
Current confusion between local code authority and frequency license holders
Resource diversion to technical plan review and testing duties without adequate frequency licensee guidance
Unclear responsibility lines for ongoing testing, inspection, and enforcement activities
Lack of standardized technical criteria and guidance from frequency licensees for building owners and contractors
Need for standardized procedures that respect both fire safety and licensed frequency management authority
Signal Booster Manufacturers
Critical Stakes:
Life Safety: Ensure continued support for quality in-building public safety communications coverage while maintaining existing outdoor public safety communications coverage
Equipment Standards: Influence new technical requirements and certification processes
Market Clarity: Establish consistent nationwide requirements rather than varying local interpretations
Innovation Guidance: Shape requirements for automatic shutdown and monitoring capabilities
Competitive Positioning: Ensure standards that reward quality engineering and proper design
Key Comment Topics:
Technical feasibility of proposed equipment standards and labeling requirements
Manufacturing timeline impacts of new requirements
Cost implications of enhanced monitoring and shutdown capabilities
Support for consistent nationwide standards vs. local variations
ERCES System Integrators
Critical Stakes:
Life Safety: Ensure continued support for quality in-building public safety communications coverage while maintaining existing outdoor public safety communications coverage
Process Standardization: Create defined nationwide practices replacing inconsistent local requirements
Professional Recognition: Establish clear qualification standards and certification requirements
Liability Protection: Reduce legal exposure through standardized authorization procedures
Business Efficiency: Streamline project approval processes and reduce delays
Key Comment Topics:
Current challenges with varying local requirements and processes
Qualification and certification standards for installers
Timeline and cost impacts of proposed authorization procedures
Third-party service provider opportunities and responsibilities
Building Owners and Property Managers
Critical Stakes:
Life Safety: Ensure continued support for quality in-building public safety communications coverage while maintaining existing outdoor public safety communications coverage
Cost Predictability: Establish clear, consistent requirements to avoid costly redesigns and delays
Timeline Certainty: Create standardized processes to support project scheduling and occupancy permits
Compliance Clarity: Remove confusion about conflicting requirements from different authorities
Risk Management: Reduce liability exposure through proper coordination and authorization
Key Comment Topics:
Current cost impacts of unclear requirements and project delays
Timeline challenges with fire code compliance and building permits
Coordination difficulties between different regulatory authorities
Support for expedited review processes for time-sensitive situations
How to Make Your Comments Most Effective
Be Specific and Data-Driven
Include concrete examples, case studies, and quantifiable impacts
Reference specific incidents, costs, or operational challenges
Provide technical data supporting your positions
Address the FCC's Specific Questions
Directly respond to the questions posed in the Public Notice
Clearly state whether you support, oppose, or suggest modifications to specific proposals
Explain your reasoning with supporting evidence
Consider Multiple Perspectives
Emphasize the shared goal of ensuring quality in-building public safety communications coverage while maintaining existing outdoor coverage
Acknowledge legitimate concerns from other stakeholder groups
Propose solutions that balance competing interests
Show how your recommendations serve the broader public interest
Propose Constructive Alternatives
If you disagree with SBC's proposals, offer specific alternative solutions
Explain why your alternatives would be more effective
Address potential implementation challenges
Specific Questions the FCC is Asking
(The FCC seeks) comment on the SBC’s Petition and its proposed rule changes.
In particular, (the FCC seeks) comment on whether parties agree with the SBC that improperly deployed signal boosters cause interference to public safety radio communications and whether the problem is as pervasive as SBC claims.
If so, (the FCC seeks) comment on the extent parties believe SBC’s proposed revisions to section 90.219 of the Commission’s rules will address the problem.
(the FCC seeks) comment on whether alternative solutions, beyond what SBC proposes, exist to address interference from improperly deployed signal boosters. For instance, we seek comment on whether the Commission’s rules should require part 90 signal boosters to have a self-monitoring capability and automatically shut down if the device detects that its improperly installed. We note that the Commission has similar rules for consumer signal boosters designed to operate on commercial wireless spectrum.
Why This Matters Now
Timing is Critical: Signal booster deployment is accelerating rapidly, and interference problems are escalating. This rulemaking proceeding offers the first comprehensive opportunity since 2013 to address the regulatory gaps that have created current problems.
Precedent Setting: The framework established through this proceeding will likely remain in place for many years and will influence how thousands of future signal booster installations are handled.
Federal Recognition: DHS/CISA has already established a Bi-Directional Amplifier Focus Group specifically to address these coordination and interference issues, demonstrating federal-level recognition of the problem's severity.
Resource Impact: Without systematic reform, public safety agencies will continue diverting critical resources from emergency operations to resolve preventable interference issues, and building owners will continue facing unpredictable costs and delays.
Filing Deadlines and Process
Comments Due: October 16, 2025Reply Comments Due: October 31, 2025
1. For technical questions about the petition or filing process, contact the SBC at the information provided in the original petition filing.
2. For FCC procedural questions, contact:
Brian Marenco, Public Safety and Homeland Security Bureau: 202-418-0838
Morgan Mendenhall, Wireless Telecommunications Bureau: 202-418-0154
Remember: Your participation in this comment process is essential to ensuring the final rules effectively address real-world challenges while supporting the critical goal of reliable public safety communications.
Filing Background: Essential Technology Without Coordination Framework
Signal Boosters: Essential Technology Lacking Coordination Procedures
Signal boosters (also called Bi-Directional Amplifiers or BDAs) address in-building coverage problems in weak signal areas. Fire and building codes and standards have required solutions to ensure adequate first responder communication coverage inside buildings since 2009, with signal boosters being the most common technology deployed to meet these performance requirements.
These signal boosters are the core component of Emergency Responder Communication Enhancement Systems (ERCES) - the current standard terminology in fire and building codes and standards. ERCES are complete solutions that include signal boosters, cabling, antennas, couplers, power supplies, and other components needed to provide reliable in-building coverage. While the entire ERCES system is needed for a complete solution, signal boosters and their performance are specifically referenced in FCC Part 90 rules, which is the focus of this petition.
The technology itself is valuable and necessary - but the lack of a standardized coordination framework is the root cause of current problems.
The Missing Framework: Multiple Coordination Problems
No Clear Process: Current rules require "express consent" but provide no standardized procedures for requesting, evaluating, or granting permission
Unpublished Requirements: Without clear, published technical criteria, building owners cannot plan effectively, system integration contractors cannot design to meet licensee needs and expectations, and competitive bidding becomes difficult
Role Confusion: Without clear framework, misunderstanding develops between code enforcement and public safety network operations
Authority Gaps: Unclear duties and responsibilities decrease effectiveness of essential deployments
Project Uncertainty: Building owners face unpredictable approval processes causing occupancy permit delays
Resource Strain: Public safety agencies handle ad-hoc requests without standardized procedures or professional support, creating inefficient use of staff time and budget
Lack of Tracking: Without systematic tracking, harmful noise and interference hunting and mitigation become more difficult, and system updates and continuing maintenance are harder to coordinate
Broad Recognition of Coordination Challenges
Multiple organizations have documented these coordination process gaps. The Department of Homeland Security's Cybersecurity and Infrastructure Security Agency (CISA) established the Bi-Directional Amplifier Focus Group specifically to address these issues, documenting that "unknown implementations and operations of uncoordinated Bi-Directional Amplifiers is causing harmful noise and interference to public safety radio systems." An APCO survey of public safety agencies confirmed widespread deployment challenges, while SBC's No Noise Task Force brought together industry veterans to develop solutions for these coordination problems. Supporting documentation and references are included in the filed petition.
Benefits of the Authorization Framework
Life Safety Protection:
First Responder Safety: Framework directly addresses DHS/CISA documented concerns that uncoordinated signal boosters are "potentially placing first responders in jeopardy"
Emergency Communication Reliability: Addresses cases of signal booster harmful noise and interference blocking critical communications during incidents
Resource Protection: Reduces diversion of essential public safety personnel from emergency response duties and eliminates inefficient use of agency staff and budget
For Public Safety Operations:
Communication Reliability: Reduces harmful noise and interference with critical emergency communications during incidents
Professional Standards: Ensures signal booster systems are properly deployed and integrated to support public safety operations
System Tracking: Comprehensive database with current contact information enables rapid identification of systems during troubleshooting
Coordination Support: Leverages FCC and legislative precedents for optional third-party support services to assist agencies
For Building Owners and Contractors:
Clear Procedures: Standardized process eliminates confusion and project delays
Published Criteria: Requirement for licensees to publish technical criteria enables better planning and reduces costs
Streamlined Process: Framework reduces expensive troubleshooting and rework through standardized coordination
Compliance Certainty: Clear guidelines ensure federal regulatory compliance while meeting fire code requirements
For Regulatory Efficiency:
Addresses Problems Proactively: Coordination reduces enforcement actions and harmful noise and interference complaints
Market-Based Options: Petition suggests leveraging third-party coordination options, following established FCC precedents, rather than expanding government bureaucracy
Streamlined Compliance: Standardized procedures reduce regulatory uncertainty and administrative burden
Structured Approach: Provides clear, standardized procedures that reduce uncertainty and streamline compliance
Frequently Asked Questions
Q: What are signal boosters and when do buildings need them?
A: Signal boosters (also called Bi-Directional Amplifiers or BDAs) address the well-established problem of "wireless dead zones" inside buildings that block critical public safety communications. The FCC has recognized that "signal booster systems play a crucial role in allowing public safety first-responders to communicate in buildings, tunnels and other areas where signals would normally be blocked." Under FCC rules, frequency licensees are permitted to grant express permission to building owners and their contractors to use signal boosters to address poor in-building public safety communications coverage.
Q: How do ERCES and signal boosters relate to building codes?
A: Fire and building codes and standards have required solutions to ensure adequate first responder communication coverage inside buildings since 2009, though these requirements have been continuously refined over time. Authority Having Jurisdiction (AHJ) and code official awareness of these requirements has grown significantly, leading to increased enforcement and more ERCES deployments.
A: Rapid growth in coverage solution deployments driven by fire code requirements has exposed the absence of rule-based coordination procedures, creating a regulatory gap during significant deployment growth.
Q: Will this delay building projects?
A: No. The framework provides clear procedures with published criteria that reduce uncertainty and streamline coordination, actually reducing delays caused by current confusion.
Q: Does this create more red tape?
A: No. This streamlines existing requirements by providing clear procedures and leveraging market-based options rather than expanding government bureaucracy. It reduces regulatory burden by addressing problems before they require government enforcement action.
About the Safer Buildings Coalition
SBC is an independent 501(c)(4) non-profit organization and the recognized thought leader on policies and technologies that ensure effective in-building communications for public safety personnel and the communities they serve. SBC authored the Complete ERCES Handbook, a foundational reference for the NICET Public Safety In-Building Communications (IB-PSC) Certification Program. SBC's mission focuses on eliminating wireless "dead zones" while combating harmful RF interference.
