During an Interoperability Forum held on Friday, March 4, 2011, Erika Olsen, Special Counsel to the Federal Communications Commission (FCC)'s Public Safety and Homeland Security Bureau pleaded for parties to submit legal arguments to support the secondary use of the 700 MHz public safety spectrum including utilities and other critical infrastructure industries. Olsen explained that the FCC is revisiting this issue in light of statements of support by certain public safety entities who want to promote coordination of emergency response, spread costs and share infrastructure. She stressed that while policy arguments are very important, even the most compelling arguments do not trump the law. She went on to explain how section 337(f) of the communications act requires that the "sole or primary purpose" of public safety services must be to protect life, health or property, and that parties should explain how the FCC could allow secondary use consistent with this limiting language in the statute. She clarified that section 337(f)(1)(B) also requires the licensees must be governmental entities or nongovernmental entities that are authorized by a public safety entity and that parties should explain how to ensure that such authorizations that are obtained are legitimate. She informed the audience that section 337(f) requires the public safety services be made commercially available to the public and that parties should explain how commercial arrangements comport with this language. Finally, she described that section 337(a) allocates 36 MHz for commercial services and 24 MHz for public safety services and that parties should explain how allowing access to the 24 MHz of public safety spectrum by commercial entities can be accomplished consistent with the limiting language in the statute. Olsen closed by reiterating her plea to refresh the record for the legal and factual support to support secondary access to the 700 MHz spectrum.