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4-0 Approvals

Public Safety FNPRMs Saw Changes of Note Before Commissioner Approval

The FCC made few but potentially significant changes to a Further NPRM on 911 wireless location accuracy that commissioners approved 4-0 on Thursday (see 2503270042). An FNPRM on next-generation 911 was also tweaked, based on a side-by-side comparison of the FNPRMs. Both were posted in Monday’s Daily Digest.

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CTIA had suggested numerous additions to the draft wireless location FNPRM, and while the FCC didn’t adopt most of them, it nonetheless made changes that appeared industry-friendly. The FCC has long wanted providers to supply dispatchable location information as part of emergency calls when possible (see 1501290066).

In a paragraph about improving the usefulness of vertical location information, the final FNPRM asks how public safety answering points (PSAPs) are using the information available today. “Have PSAPs found the information to be useful, and have they observed any limitations in the accuracy of such information?”

It poses similar questions about the usefulness of dispatchable information: “When dispatchable location information is available, how often do PSAPs use this information to support emergency response, and how do they use it?” The FNPRM now asks how height above ground level (AGL) data is used and proposes that carriers be required to convert required height above ellipsoid (HAE) data to AGL data for emergency responders to use.

Questions added to the final version probe the role of cable companies, device manufacturers and others in improving the location accuracy of 911 calls.

It now asks what other companies “own or control … capabilities or systems” that are important to the process. “To what extent do wireless providers have access or visibility to information sources owned, controlled, or managed by these entities? How would access to such information sources enable … providers to obtain or generate dispatchable location?”

The FNPRM seeks comment “on the extent to which applying standards or requirements to parties other than … providers would increase the availability and use of dispatchable location solutions.”

The notice proposes that location accuracy be tested across four morphologies -- dense urban, urban, suburban and rural areas. The draft proposed asking about whether the FCC should require a certain percentage of tests in each environment. Instead, the final version asks about “the number” or percentage of total 911 test calls.

The final FNRPM also asks about the effect on the industry of required changes. “Is additional testing and standardization necessary to determine whether any revisions to our accuracy benchmarks are required due to these new requirements? If so, how much time is needed to complete such additional testing or modifications to standards?”

The FCC also added language to a section on protecting the privacy of information submitted to a location accuracy test bed. “Given the critical public importance of providing accurate location with 911 calls, should we create a presumption that test bed reports are to be made public? How can the Commission’s rules help the test bed strike a balance between protecting and safeguarding non-public information (e.g., proprietary business information) in ways that promote vendor participation in the test bed, while also promoting greater transparency and accountability for non-nationwide … providers and public safety stakeholders in the test process?”

NG911

The approved NG911 FNPRM contains new language about covered 911 service providers (CSP) not fitting cleanly into the description of telecommunications carriers and asks whether there should be clarification that CSPs are required to transmit all 911 calls they receive to PSAPs. It also inquires about treating CSPs differently from telecommunications carriers.

The draft order asked if user-minutes of lost communications to PSAPs is the best metric for outages specific to NG911 facilities. The approved order goes beyond that, asking what metric should be considered, if not user-minutes.

The approved order also dives deeper into three-way video issues and direct video calling, asking about amending rules to require that NG911 core service systems support three-way video for relay services, as well as direct video calling. In addition, it asks about timeframes for requiring support of either service. And it inquires about the potential efficiencies of using three-way video and direct video calling and what they could mean for PSAPs in NG911 systems.

Language about creating a dedicated consumer portal for reporting 911-related outages -- something Commissioner Anna Gomez said she got added to the FNPRM (see 2503270042) -- asks about potential benefits of the idea, including how it could add to reporting mechanisms.