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Public Interest Groups Raise Location-Accuracy Privacy Concerns at FCC

Public Knowledge and the Electronic Privacy Information Center urged the FCC to take privacy into consideration as the agency looks at wireless location accuracy for 911 calls (see 2506090022). Comments were posted this week in docket 07-114. “The Commission has presented acceptable proposals to make [enhanced 911] better, but has failed to properly consider in its proposals the importance of consumer privacy,” the groups said. Before adopting new E911 rules, the FCC should “seek further comment on how to protect subscriber information, including Customer Proprietary Network Information, as demands for sensitive location data increase.”

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The Alliance for Telecommunications Industry Solutions joined carriers in raising concerns about a proposal to require caller locations to be conveyed to public safety answering points using height-above-ground-level (AGL) instead of the currently required height-above-ellipsoid (HAE) methodology. “There are no standardized methods to convey AGL,” the alliance said. “Significant time therefore would be required to allow the industry to update the necessary standards,” and implementing changes “would take years and result in significant development costs for all parties, especially the PSAPs.” The group also noted that “the accuracy of generally available terrain data may not be sufficient, particularly in hilly areas.”

The FCC also heard from technology vendors.

Intrado, which offers 911 technology, agreed that “HAE-to-AGL conversions will not meaningfully improve accuracy and response times for indoor calls without PSAP access to better map data.” While dispatchable location “is an important long-term goal, as defined today, it is technically infeasible and will likely remain impractical for the foreseeable future,” it said. Data sources “available in the nearer term include associated addresses from Voice over Wi-Fi (VoWiFi) and other inputs that can help inform a potential location with a relatively high degree of confidence.”

Since 2020, “NextNav has offered its Pinnacle z-axis service to provide PSAPs and first responders with accurate vertical location information,” the company said. “This provision of vertical location information to emergency first responders is enabled by small barometric pressure sensors, with which nearly all smartphones on the market are equipped.” OneNav said L5 signals from global navigation satellite system can help improve horizontal accuracy of caller information.