CTIA Suggests Numerous Changes to Location Accuracy FNPRM
CTIA sought extensive tweaks to a draft Further NPRM on 911 wireless location accuracy, set for a vote by the FCC on March 27 (see 2503060061). Representatives spoke with an aide to Chairman Brendan Carr. CTIA is the only party to file an ex parte in docket 07-114 since the FNPRM was circulated.
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“CTIA highlighted that the FCC’s decade-long effort to enhance wireless 911 location accuracy has been a resounding success for wireless 911 callers, the public safety community, and the wireless industry,” said a filing posted Wednesday. “Driven by stakeholder collaboration, advanced wireless location technology solutions provide public safety with the most accurate horizontal (x,y) and vertical (z-axis) location information ever available for wireless 911 calls.”
But CTIA offered advice on how the draft could be improved. In a paragraph seeking comment on how data sources can be leveraged to generate floor-level information and whether to require providers to provide a floor-level estimate with all calls, CTIA suggested the FCC also ask about public safety answering points' use of the information. The group said the FCC should ask: “What are PSAPs experiences involving the utility of the vertical location information being provided today? Are there any limitations observed with the accuracy of such information?”
In a paragraph on possible inaccuracies in translating the currently required height above ellipsoid (HAE) to a height above ground level (AGL), “which is likely to be more actionable for first responders,” CTIA suggested additional questions: “To what degree would conversion from HAE to AGL introduce errors in the accuracy of the z-axis information that could impact emergency response?” “What technical standards are available or would need to be developed for providers to determine the level of errors in HAE to AGL conversion that would be acceptable for public safety use?”
CTIA also proposed the addition of text to a section in the FNPRM on the use of an industry test bed to validate the accuracy of location technology.