Carriers Urge Task Force on Tougher E-911 Requirements

Because technical and timing considerations complicate E-911 location accuracy, CTIA said, it “strongly recommends” that the commission hold off on reaching conclusions regarding the timing for imposing new rules until it “convenes an E911 working group to vet concerns and issues and present solutions.”

The forum should include engineers and technical experts from the commission, public safety groups, wireless carriers, local exchange carriers, handset vendors, and infrastructure and location vendors, CTIA said. “The benefits of a consensus-based working group process are significant: public safety entities will be allowed a venue for expressing the requirements they have to provide 911 service to the public; CMRS providers and manufacturers will be able to describe their network operations and present workable technical solutions that address the needs of public safety in an achievable fashion; and, other interested stakeholders and technology developers will be permitted to introduce new technologies or ideas to this group,” it said.

CTIA warned the FCC that it will take time to comply with rule changes as industry must create standards, test gear and deploy against a backdrop of “the extensive base of existing CMRS customers and location solutions already deployed in the marketplace.”

Carrier T-Mobile recommended a three-stage approach to improved location accuracy. First, carriers and public safety answering points should have to optimize existing technologies to assure they achieve PSAP-level accuracy to “the extent technically feasible and economically reasonable.” Second, the FCC should set up an advisory committee such as CTIA urges. Third, carriers and PSAPs should put in place new standards recommended by the committee following a “reasonable” transition schedule.

“There has been no systematic evaluation of the actual utility of increased accuracy, and what information does exist is anecdotal,” T-Mobile warned. “If E911 requirements become so onerous that carriers withdraw from, or decide not to initiate, service in areas where compliance is overly difficult, public safety will be harmed, particularly in rural areas, because the public will no longer be able to place wireless 911 calls (or any other wireless calls) in those areas.”

AT&T called an E-911 Technical Advisory Group critical to the process. “Until the capabilities of location technologies are fully understood, it would be premature to adopt new accuracy or other E911 requirements,” it said. “Thus, it is premature to address the variety of questions posed by the Commission in this proceeding.”

Qualcomm endorsed creation of a working group to examine tougher mandates before the FCC sets a deadline for meeting more exacting requirements. “Qualcomm urges the Commission not to set an arbitrary date on which it will begin enforcing a requirement that cannot be met, and instead, as quickly as possible, to convene all affected stakeholders-carriers, public safety organizations, vendors, and others -- in a consensual process, under tight time frames, to develop measurable, achievable metrics, with deadlines that can be reached, to improve E911 accuracy as much as possible, as broadly as possible, and as quickly as possible,” the company said.

Motorola said an industry working group must be “the first step” the FCC takes. “The establishment of a working group would ensure that all technologies and limitations are considered, thus ensuring that (i) the established standard will be achievable and (ii) a universal testing method for confirming compliance is created,” Motorola said.

The Rural Cellular Association, representing smaller carriers, voted for FCC caution. “RCA urges the Commission to temper expectations and to consider the very real and practical limitations faced by rural carriers in their efforts to deliver accurate location information to PSAPs,” the group said. “The single most important public safety tool offered by wireless carriers in rural America is voice service availability. It would be highly counterproductive to adopt aggressive location accuracy requirements that in turn cause small carriers to pull back on service availability in their attempts to comply.”

MetroPCS said the FCC should impose tougher location requirements if the changes are found technically feasible. “This approach improves the chances that new rules will be upheld by a court under the Administrative Procedures Act, and also avoids subjecting carriers to potential civil liability,” the carrier said. “Moreover, imposing new requirements without giving carriers an adequate opportunity to bring their systems into compliance could harm competition and end user subscribers by frustrating efforts of carriers to secure the financing necessary to fund existing operations and growth because they may not be able to certify compliance with the new rules to their lenders or other investors.”

But a few commenters urged the FCC to be more assertive. The Rural Telecommunications Group urged the FCC to require all carriers to adopt handset-based technologies for locating callers, while phasing out network-based technologies. Verizon Wireless, Sprint Nextel and other CDMA carriers use a handset-based solution. AT&T and T-Mobile, the major GSM carriers, use the network-based method.

“If the Commission were to require the use of GPS-enabled handsets, it would be creating a market demand sufficient to justify the efforts necessary by equipment manufacturers to develop handset-based solutions for GSM carriers,” the rural group said. “Experience has demonstrated that without such mass market demand, manufacturers will not expend the resources necessary to develop such solutions.”

Among the toughest questions the FCC raised is how to ensure that subscribers can make E-911 calls when roaming on another carrier’s network. Many commenters noted that this issue is especially tricky because carriers use different technologies to locate callers. The Association of Public Safety Communications Officials said the FCC should require carriers to develop a “technical solution to this problem by a specific deadline.”

But industry groups said roaming will be difficult to handle. The FCC allowed carriers and manufacturers to develop location systems on a “technology neutral, competitive basis,” bringing faster rollout of E-911 but also incompatible systems, CTIA said. The group recommended that roaming be “a key discussion point” for the forum it recommends. MetroPCS said the FCC should make clear that E-911 incompatibility can’t be cited to deny a carrier a roaming agreement.

Industry: Too Early to Impose E-911 Rules on VoIP Providers

The FCC shouldn’t impose new E-911 location requirements on VoIP providers “until it knows what capabilities are technically and commercially feasible,” Verizon said. Its comments came in a filing in the same proceeding, which deals with both VoIP and wireless E-911 location requirements. The VoIP industry has been working on automatic location standards for nomadic services but its efforts could be delayed if the FCC were to take a different approach “and adopt the wireless requirements for providing location by latitude and longitude,” Verizon warned. Instead, the FCC should keep monitoring industry efforts, it said. “By doing so, the Commission will encourage prompt deployment of useful and feasible industry solutions” and “avoid imposing requirements that do not bring additional benefits to consumers, or that bring costs that outweigh the benefits.”

Mandatory location accuracy requirements for VoIP providers “would be premature,” said the Wireless Communications Association, representing wireless carriers deploying VoIP over broadband networks. The FCC instead should form a “joint advisory committee” of FCC staff, industry representatives, equipment vendors, public safety officials, consumer groups and others to make recommendations on VoIP location accuracy requirements. WCA members are “well along in designing network architectures, acquiring equipment and launching new wireless broadband networks that allow them to offer interconnected VoIP service to consumers equipped with fixed, portable and mobile devices,” WCA told the FCC. These providers have an incentive to offer E-911 capabilities, “since widespread market acceptance of their interconnected VoIP service depends in part on whether consumers perceive it to be as reliable in emergency situations as competitive offerings,” WCA said. Rather than prematurely adopting “onerous” requirements, the FCC could devise a better solution by forming a committee to solve the “technical, operational and economic issues,” the association said.

The FCC wants to impose standards for “automatic location technology that meets the same accuracy standards” applied to wireless carriers, but it won’t work, said Telecommunications Systems, which runs data centers that process nomadic VoIP and wireless E-911 calls. Nomadic VoIP is “significantly different” from wireless technology, TCS said. “Applying even the more stringent of the two current wireless standards would reduce the current accuracy provided for the vast majority of VoIP calls,” TCS warned. VoIP users who register their addresses provide a higher level of local accuracy, TCS said.