Carriers Question Need for Revised Wireless Location Accuracy Rules
Wireless carriers urged the FCC to move with caution in response to a Further NPRM on wireless location accuracy, which commissioners approved 4-0 in March (see 2503270042). The FNPRM probes ways to improve accuracy and whether providers should be required to deliver vertical location information to 911 call centers measured in height above ground level (AGL), instead of height above ellipsoid (HAE). The notice also asks about ways to ensure that more public safety answering points receive dispatchable location (DL) as part of calls to 911. Reply comments were due Monday and mostly posted Tuesday in docket 07-114.
Sign up for a free preview to unlock the rest of this article
Communications Daily is required reading for senior executives at top telecom corporations, law firms, lobbying organizations, associations and government agencies (including the FCC). Join them today!
CTIA said initial comments show little consensus on what a revised horizontal location accuracy metric should be. “To that end, the path to tighter horizontal benchmarks should be data-driven and aligned with technological advances,” it said. “Further testing and evaluation is necessary before the Commission considers adopting new” rules.
In addition, the usefulness of z-axis data in the AGL format “remains an open question,” CTIA said, again calling for further investigation. DL is being made available when possible, but there isn’t “presently the widespread available solution stakeholders once hoped for,” it said. “No achievable, scalable, or technically ready DL-compliant solutions have come forward to participate in the [industry] Test Bed that would increase the volume of wireless 911 calls with DL information.”
The Competitive Carriers Association warned that requiring carriers to convert HAE data to AGL “would impose substantial burdens on wireless providers without commensurate public safety benefits and could ultimately impede innovation of critical technologies.” Public safety answering points (PSAPs) and their vendors, rather than carriers, remain “best positioned to perform such conversions accurately and efficiently.” The group noted that the FNPRM also proposes a per-morphology compliance regime requiring carriers to meet vertical location benchmarks separately across four morphologies -- dense urban, urban, suburban and rural. “The record reflects near-universal opposition to this approach.”
T-Mobile questioned whether the FCC needs new wireless location accuracy rules. “Many of the proposed rules, as commenters observe, run counter to the goal of this Administration and Commission to reduce regulatory burdens.” HAE-to-AGL conversion would be better done at the PSAP, the carrier argued. “The record also reflects that a lengthy and expensive standards-developing process would be necessary before wireless carriers can provide both HAE and AGL (with the latter being almost certainly suboptimal vertical location information).”
The National Association of State 911 Administrators said it’s neutral on where the conversion of vertical location data should take place. But the FCC should recognize that many PSAPs across the U.S. “are not technologically able to convert HAE to AGL.” Requiring an 80% accuracy threshold within each of the four morphologies “would be helpful in improving location accuracy” for PSAPs, the group said. “It can be argued that having a blanket 80% accuracy requirement allows … providers to achieve success in certain morphologies and not others.”
“As noted in our initial filing,” the provision of AGL data from the carrier network is “counter-intuitively less useful for first responders than doing the same conversion using local data,” the National Emergency Number Association said. “NENA finds broad consensus on this matter.” The standards work needed to support the commission’s proposal of delivering both HAE and AGL “would take years,” it warned.