Disagreements Surface on Revisions to 911 Caller Location Rules
Wireless carriers are asking the FCC to trim old regulations and focus on flexible approaches in response to a March Further NPRM on wireless location accuracy. Public safety groups, including the Association of Public-Safety Communications Officials, want the FCC to put more emphasis on providing dispatchable location information (see 2506060031). Comments were due Friday in docket 07-114, and most were posted Monday.
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CTIA said the FCC’s “1990s-era” Phase II enhanced-911 location-accuracy requirements “have been fully surpassed by the FCC’s indoor location accuracy obligations, which are now the standard for both outdoor and indoor wireless 911 location accuracy.” Cutting those rules “will reduce burdens on wireless providers and foster investment and innovation that will benefit wireless 911 callers and public safety nationwide.”
Location-accuracy rules should be “premised on collaboration among industry and public safety and grounded in data-driven understanding of technological feasibility,” CTIA continued. Technologies already in use “deliver to public safety the most accurate horizontal (x,y) and vertical (z-axis) location information ever available for wireless 911 calls -- on a nationwide basis and for 911 calls made outdoors and indoors.” Requiring compliance on a per-morphology basis “would reverse years-old FCC engineering guidance, create years-long delay in the Test Bed processes, and call into question the existing benchmarks.” At issue is whether carriers would have to provide data in four “morphologies”: dense urban, urban, suburban and rural.
Blooston Rural Carriers said companies in rural areas shouldn’t have to convert z-axis information from the currently required height-above-ellipsoid (HAE) methodology to height-above-ground-level (AGL) methodology until public safety answering points can show “the capability to utilize z-axis information effectively.” PSAPs should also have to submit a written request for AGL data, “with a compliance lead time of no less than six months,” Blooston said. “This approach is reasonable and it is consistent with the way the Commission has handled initial E911 deployments” and “recognizes the limited resources available to many rural carriers (as well as rural PSAPs).”
The Competitive Carriers Association called on the FCC to exercise caution in mandating new requirements for how a call's vertical location is measured. The agency shouldn’t require providers to deliver height AGL data, floor-level information and other data until “underlying technologies and standards are sufficiently mature,” the group said. The commission “must balance aspirational goals with the on-the-ground realities of deployment and support policies that are scalable, flexible, and responsive to implementation challenges.”
Verizon said a proposed requirement to convert data to height AGL and a per-morphology compliance metric and testing regime “raise significant questions over technical feasibility and necessity, standards development needs, and costs.” It also questioned a finding in the FNPRM that less than 1% of calls are now delivered with dispatchable location information. That number doesn’t seem to take account Verizon’s “substantially higher performance,” the filing said, noting that the company started delivering the data years ago on some devices.
Verizon uses Wi-Fi calling, indoor distributed antenna system and femtocell products to determine dispatchable location, the company said. It's also using third-party “Neutral Host Network” vendors “to leverage their fixed wireless radio access network equipment portfolios to deliver dispatchable location when they originate 911 calls from Verizon customer devices.”
T-Mobile said that since requirements started to deliver vertical location data in 2021, it “has received no formal complaints from PSAPs regarding the accuracy of the horizontal and vertical location information it provides in each of the defined morphologies.” Wireless carriers “are already delivering the best location information available by leveraging today’s state-of-the-art location technologies, while avoiding one-off, purpose-built location solutions that quickly become technologically outdated and stagnant.”
The National Emergency Number Association cautioned that using AGL data doesn't guarantee that first responders can more easily locate callers. “The only information that AGL provides is that the caller is either on the ground or somewhere above it,” the group said. “Public safety telecommunicators and, as an extension, field responders, need actionable data.”
The Major County Sheriffs of America stressed the importance of dispatchable location data to its members. “When a call is placed from a multi-story building and we lack vertical location data, sheriff’s deputies are forced to search multiple floors, delaying emergency assistance,” the association said. “In the field of emergency response, time is the most critical resource we have.”
The Texas 9-1-1 Alliance called on the FCC to mandate more testing and require carriers to provide data on a call's location by floor in a building. “Providers could initially use a uniform standard of 3 meters per floor, then fill in the map with specific building data as it becomes available,” it said. The alliance also said AGL data is more usable for first responders than HAE data, especially “in areas with varying terrain heights.”