New P25 CAP Compliance Assessment Bulletins Released
Tuesday, September 06, 2016 | Comments

Seven new documents critical to the Project 25 (P25) Compliance Assessment Program (CAP) pushing forward with new product performance and interoperability testing were released. Following a transfusion of Department of Homeland Security (DHS) Science and Technology Directorate (S&T) leadership and funding, new energy, additional staff, appointment of a well-qualified advisory panel (AP) and continued support from industry, the P25 CAP is showing signs of life, but much work remains.

The P25 CAP AP held its second in-person meeting Aug. 17, in Orlando, Florida, during the Association of Public-Safety Communications Officials (APCO) International Conference. The goals were to implement P25 policies, identify priorities, establish the path forward, and increase awareness of the P25 CAP AP and how it can positively impact P25.

Attendees included 57 users, manufacturers, associations, public-safety professionals, other interested parties, along with DHS officials and staff who convened the meeting. The morning session included presentations by DHS S&T Program Manager Sridhar Kowdley and P25 CAP AP Chair Gerald Reardon, who is also fire chief for the city of Cambridge, Massachusetts. In the afternoon, a lively and substantive Q&A session involved P25 CAP panel members and attendees.

Existing P25 CAP Documents
Summary test reports (STRs) and suppliers’ declarations of compliance (SDoCs), previously available at, are being migrated to the DHS S&T P25 site. However, no documents are currently available on the new site. “We are working to post all previously published P25 CAP materials as soon as possible,” the DHS S&T website said.

The delay is because of pending compliance with Section 508 of the Rehabilitation Act of 1973, which has strict guidelines for formatting. In the interim, a spreadsheet listing all previously published STRs and SDoCs is available here.

New Compliance Assessment Bulletins (CABs)
Seven new CABs replaced those published in March 2010 and are on the S&T website. Vendors use the CABs when they test P25 equipment within the P25 CAP process. With the release of the new CABS, the laboratories have one year — until Aug. 17, 2017, to reaccredit, and vendors may need to retest current products by that deadline.

The new CABs specifically cover baseline requirements for attaining recognition as a P25 CAP laboratory, laboratory equipment requirements for attaining recognition as a P25 CAP laboratory, P25 interfaces covered by CAP and when SDOCs and STRs are required. Additional CABs cover Common Air Interface (CAI) baseline testing requirements, Inter RF Sub-System (ISSI) baseline testing requirements, SDoC requirements and STR requirements.

Existing STRs and SDoCs will stay on the DHS website until Aug. 17, 2017. Labs may continue testing on the March 2010 CABs until Aug. 16, 2017, and vendors may post documents. However, new STRs and SDoCs must be resubmitted by Aug. 16, 2017. No retesting is needed if a test and the product have not changed; however, a retest is required if the test has changed or has an addition or if the product has changed. It is the vendors’ responsibility to analyze the change and determine if a retest is needed. DHS S&T Office of Interoperability and Compatibility (OIC) staff will review each new submission and decline approval if a full test should have been run.

Labs must test all the P25 features and services within the radio. “If the radio is capable of the thing, you must test the thing,” a DHS official said.

All test results submitted must be Section 508 compliant or they will be delayed or returned. DHS will conduct webinars to train SDoC and STR submitters to follow the correct style and format. Please email if interested in attending. Previously posted STRs and SDoCs on the DHS website will be taken down if not resubmitted by Aug. 16, 2017.

The P25 CAP AP discovered some problems with dates and specific language in the new CABs. DHS plans to revise them prior to re-accreditation of the labs. Although these are governing CABs, they are expected to change.

The CABs were published without industry collaboration because of time pressures on DHS. “We have been trying to get these out for several years. …we are going back to pull back the 2008 version … this is not an end run on the manufacturers,” Kowdley said. Many attendees expressed the desire for more transparent collaboration in the future to produce a better result for all stakeholders.

A vendor offered a draft CAB for the Console Subsystem Interface (CSSI), and the CAP AP will offer it to all for review. It will be posted on the website followed by review and comment. Telecommunications Industry Association (TIA) TR-8.25 is working on updating the trunking Inter RF Subsystem Interface (ISSI) recommended compliance assessment tests (RCATs) to include trunking CSSI testing, and TIA TR-8.19 is working on a trunking ISSI/CSSI messaging document revision. Developing these new CABs offers another opportunity for collaboration between TIA and the P25 CAP AP, which could benefit all stakeholders.

The DHS Office for Interoperability and Compatibility (OIC) said they would make the final decision on new CABs, “with the advice and counsel of the CAP AP.” “If the TIA and CAP AP recommends something, and DHS goes the other way, it will be a disaster,” said a public-safety communications official who attended the meeting.

Other Issues
ISSI/CSSI lab assessments were a hot topic because there are no recognized labs for ISSI CAP testing. A priority for the panel, members asked for suggestions on how to conduct ISSI CAP testing in lieu of a permanent test lab. Several technical, compliance, accreditation and regulatory issues when considering ISSI CAP testing at remote locations were discussed. Both DHS officials and P25 CAP AP members said they are open to ideas.

In addition, if a manufacturer offers several versions of a P25 radio with a hierarchy of features, how many versions should they test? Increased cost would result from testing every version, and all the tests can’t be done if the hardware doesn’t support a feature, such as a display.

Manufacturers don’t need to test multiple devices if test results were the same across all platforms. For a feature-limited model, the manufacturer should submit a separate SDoC and STR for that limited model. “The model class definition in the published CABs does not address the current issue about model class test result reporting,” Kowdley said. “DHS intends to work with stakeholders to improve this.”

Ideally, this would be completed before manufacturers are ready to post new SDoCs and STRs.

“One document should not show different test results — one document for each model class,” said Roger Strope, P25 CAP AP vice chair.

Model class definitions were being worked by TIA, but this input may have not been considered when the new CABs were released. Resolving the model class issue could be another great opportunity for TIA and P25 CAP AP collaboration.

New P25 CAP Advisory Panel
• Gerald Reardon, chair, fire chief, city of Cambridge (Massachusetts) Fire Department
• Roger Strope, vice chair, state of Missouri
• Jason Ervin, Lower Colorado River Authority, Texas
• John Evanoff, FCC
• Joseph Heaps, National Institute of Justice (NIJ)
• Arnold Hooper, state of Tennessee
• Chris Kindelspire, Grundy County, Illinois
• Mike Kionka, state of Colorado
• Morton Leifer, town of Clarkstown, New York
• Dan Robinson, state of Michigan

P25 CAP AP Priorities
1. Outreach and education
2. Resolve confusion on P25 CAP, Statement of Requirements and P25 Standards
3. Enhance the P25 CAP dialogue among all stakeholders
4. Publish a minimum required P25 CAP feature set as a CAB
5. Engage end users in development of requirements
6. Determine receive-only P25 CAP testing approach
7. CABs to support Phase 2 TDMA
8. Encourage ISSI and CSSI lab assessments
9. Update ISSI/CSSI CABs
10. CABs for conventional conformance testing
11. P25 CAP testing under FCC 700 MHz rules
12. Strengthen SAFECOM grant guidance

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Chris Lougee is the principal of 5X9 Communications, providing professional services to the LMR industry. Lougee recently retired after 25 years as vice president of Icom America. He may be reached at

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