TR Daily Draft 911 Item Says 3-Meter Metric ‘Technically Feasible’
Friday, February 22, 2019

Draft 911 Item Says 3-Meter Metric ‘Technically Feasible’

A draft fourth further notice of proposed rulemaking that the FCC tentatively plans to vote on at its March 15 meeting would tentatively conclude that a z-axis, or vertical, metric of plus or minus 3 meters for 80% of indoor wireless 911 calls is accurate enough to identify the floor level of callers, in most cases, and is technically feasible by the deadlines outlined in the agency’s rules.

The item would also tentatively conclude that the 5-meter metric proposed by national wireless carriers wouldn’t be precise enough to meet the needs of first responders.

“Given the current state of the record, we believe it is appropriate to propose a z-axis metric based on a 3-meter standard,” said the draft item in PS docket 07-114, which was released today along with a tentative agenda for the March 15 meeting and other draft items. “The adoption of such a standard would provide certainty to all parties; establish a focal point for any further testing, development, and implementation of vertical location technologies; and maintain the existing timetable for wireless providers to meet their vertical location accuracy obligations. To ensure a complete and comprehensive record on this issue, we seek comment on our proposal as discussed below.”

The item proposes “to require that by April 3, 2021, nationwide CMRS providers must deploy in each of the top 25 Cellular Market Areas either dispatchable location or z-axis technology in compliance with the 3-meter metric. By April 3, 2023, these requirements would be expanded to cover each of the top 50 Cellular Market Areas. Non-nationwide CMRS providers that serve any of the top 25 or 50 Cellular Market Areas would continue to have an additional year to meet each of these benchmarks in the relevant Cellular Market Area.”

“We also seek comment on other elements of the proposed metric. Should the metric apply to 80% of wireless calls?” the draft item asks. “If not, what percentage of calls is appropriate? CTIA’s proposed metric would apply only to ‘mobile devices capable of delivering barometric pressure sensor-based altitude estimates.’ Should the z-axis metric apply only to calls from such devices, only devices manufactured after a date certain, or should it apply to wireless calls from all mobile devices, as we propose? Additionally, NPSTC [the National Public Safety Telecommunications Council] asserts that reporting vertical location information as height above ground level (AGL) would be preferable to height above mean sea level (MSL). Should the Commission specify that CMRS providers must report z-axis information as AGL, as NPSTC suggests, or are there advantages to keying height estimates to MSL? Alternatively, should we decline to specify this level of detail so that entities developing z-axis solutions have more flexibility?”

The draft item also would “tentatively conclude that, at this time, the value of a 3-meter metric exceeds that of a 2-meter metric. We acknowledge that a 2-meter metric would further improve the accuracy of 911 calls by increasing the likelihood that the caller’s floor level could be identified with certainty, which would further improve emergency response times and patient outcomes. … However, because we tentatively conclude that existing solutions are unlikely to achieve 2-meter accuracy for 80% of E911 calls prior to the deadlines established by our rules, we expect that adopting a 2-meter metric would likely cause developers of z-axis solutions to incur substantial development, testing, and implementation costs, without any guarantee of achieving the 2-meter metric before the deadline.”

Last year, national wireless carriers recommended a z-axis metric “of +/- 5 meters” (TR Daily, Aug. 7, 2018). The carriers were required to submit a recommendation pursuant to a 911 location accuracy order adopted in 2015 (TR Daily, Jan. 29, 2015).

But CTIA then said the Commission should not adopt the standard and should instead allow the industry to conduct further testing (TR Daily, Oct. 1, 2018). Verizon Communications, Inc., also told the FCC that it would be “premature” for the agency to adopt the standard proposed by the carriers, saying that additional time would allow “further testing on alternative Z-axis solutions that would improve on Z-axis accuracy” (TR Daily, Sept. 28, 2018).

However, more recently, CTIA and national wireless carriers said they want the FCC to adopt a z-axis standard in the near term rather than waiting for additional testing (TR Daily, Jan. 10).

But public safety entities have said the industry proposal falls short and that a more precise z-axis metric should be adopted by the FCC. They have called for floor-level accuracy, and no more than +/- 3 meters.

Meanwhile, a fact sheet on the draft spectrum horizons first report and order in ET docket 18-21 notes that it would “[c]reate a new category of experimental licenses for the 95 GHz to 3 THz range (a Spectrum Horizons License). … These licenses would offer increased flexibility compared to conventional experimental licenses by providing for longer license terms, license transferability, and the ability to sell equipment during the experimental term.”

The item also would free up “21.2 gigahertz of spectrum available for unlicensed use,” the fact sheet adds. The “spectrum would span several band segments (116-123 GHz, 174.8-182 GHz, 185-190 GHz, and 244-246 GHz),” it adds. “Rules for unlicensed use would be based on those currently in place for unlicensed use of the 57-71 GHz band.”

A fact sheet on a draft NPRM in WT docket 17-200 concerning the 900 megahertz band notes that it proposes “a reconfiguration of the 900 MHz band to facilitate the use of wireless broadband by a variety of businesses, including those providing critical infrastructure, by creating a paired 3/3 megahertz broadband segment in the band, while reserving two separate segments for continued narrowband operations.”

The item also (1) seeks “comment on alternate approaches to realigning the band”; (2) proposes “to license the broadband segment on a geographic basis”; (3) proposes “to authorize a market-driven, voluntary exchange process that would allow existing licensees to agree voluntarily on a plan for relocating incumbents and transitioning the band for broadband use”; (4) seeks “comment on two other methods of transitioning the band to broadband use — an auction of overlay licenses and an incentive auction — as potential additional tools for repurposing this spectrum”; and (5) proposes “to designate the 900 MHz broadband service as a Miscellaneous Wireless Communications service governed by the licensing and operating rules applicable to all Part 27 services,” the fact sheet adds.

In 2014, pdvWireless, Inc., and the Enterprise Wireless Alliance filed a petition for rulemaking asking the FCC to realign the 900 MHz band to enable the private enterprise broadband (PEBB) network in a 3x3 MHz segment, with narrowband communications in a 2x2 MHz segment (TR Daily, Nov. 18, 2014). The action would allow pdvWireless, which acquired Sprint Corp.’s 900 MHz band licenses, to deploy a broadband network, giving priority access to utilities and other critical infrastructure industry entities.

In 2017, the FCC adopted a notice of inquiry in WT docket 17-200 seeking comments on the pdvWireless/EWA proposal and another petition submitted by M2M Spectrum Networks LLC (TR Daily, Aug. 4, 2017).

The FCC also tentatively plans to consider an NPRM in WT docket 19-38 “that would explore how potential changes to our partitioning, disaggregation, and leasing rules might better close the digital divide and increase spectrum access by small and rural carriers, fulfilling the Commission’s requirement under the MOBILE NOW Act,” the tentative agenda notes.

A fact sheet says the FCC would “[a]sk commenters to address the three considerations delineated in the MOBILE NOW Act, including the administrative feasibility of” (1) “[w]hether reduced performance requirements applicable to partitioned or disaggregated licenses would promote the availability of advanced telecommunications services in rural areas or spectrum availability for small covered carriers;” (2) “[w]hat conditions may be needed to eliminate impediments to transfers of spectrum to small carriers to allow them to build out in a reasonable time;” and (3) “[w]hat incentives may encourage licensees to lease or sell spectrum to small carriers or unaffiliated carriers that will serve rural areas.”

Also on the tentative agenda is a draft fourth report and order on rural call completion in WC docket 13-39 that would establish service quality standards for intermediate providers — that is, providers that handle calls between the originating and terminating providers — completing the agency’s implementation of the Improving Rural Call Quality and Reliability Act signed into law by President Trump early last year (TR Daily, Feb. 27, 2018).

According to a fact sheet released by the FCC, the draft fourth report and order would establish “flexible” service quality standards for intermediate providers, including requirements that they “[t]ake steps reasonably calculated to ensure that any calls they handle are in fact completed. In short, where intermediate providers know, or should know, of a call completion issue, they must act to address it.”

The draft fourth report and order would also require intermediate providers, “[w]hen routing calls to rural areas, [to] actively monitor the performance of any directly contracted intermediate provider, and based on the results of that monitoring, take steps to address any identified performance issues with that provider.”

It would also require intermediate providers to “[e]nsure that any additional intermediate providers to which they hand off calls are registered with the Commission.”

Last year, the FCC established a registry for intermediate providers and mandated intermediate providers to register “before offering to transmit covered voice communications,” which was another requirement of the Improving Rural Call Quality Act (TR Daily, Aug. 15, 2018).

The draft fourth report and order would also create an exception to the intermediate provider service standards by adopting a safe harbor for covered providers — “entities that select the initial long-distance route for a large number of lines” — when serving as intermediate providers, which mirrors the existing safe harbor for covered providers in the agency’s rules. The existing safe harbor, adopted in the FCC’s first rural call completion order, “reduces recording, retention, and reporting requirements for covered providers that limit the number of intermediate providers in a call path to terminating provider or terminating tandem,” the draft fourth report and order released today notes.

The Rural Call Quality Act, or RCC Act as the FCC refers to it, “provides that the service quality standards established by the Commission pursuant to the RCC Act ‘shall not apply to a covered provider’ that has certified as a safe harbor provider under Section 64.2107(a) on or before February 26, 2019 (which is one year after the enactment of the RCC Act) and that continues to maintain eligibility for the safe harbor. To implement this provision of the RCC Act, we adopt an exception to the service quality standards described above for intermediate providers that qualify for our covered provider safe harbor established in new section 64.2109 of the Commission’s rules, similar to the Commission’s existing section 64.2107 safe harbor from the rural call completion recording and retention requirements,” the draft item says.

“[T]o qualify for the exemption from the intermediate provider service quality standards established by the RCC Act, covered providers must satisfy three requirements: (1) the covered provider must restrict by contract any intermediate provider to which a call is directed from permitting more than one additional intermediate provider in the call path before the call reaches the terminating provider or terminating tandem; (2) any nondisclosure agreement with an intermediate provider must permit the covered provider to reveal the identity of the intermediate provider and any additional intermediate provider to the Commission and to the rural incumbent LEC(s) [local exchange carriers] whose incoming long-distance calls are affected by the intermediate provider’s performance; and (3) the covered provider must have a process in place to monitor the performance of its intermediate providers,” the draft item adds.

“We also set forth procedures to enforce our intermediate provider requirements. Moreover, we sunset the rural call completion data recording and retention requirements adopted in the First RCC Order one year after the effective date of the service quality standards we adopt today. Finally, we deny petitions for reconsideration of the Second RCC Order,” the draft item says.

The FCC also plans to consider a report and order in MB docket 19-214 and GN docket 12-268 “that implements Congress’s directive in the Reimbursement Expansion Act that the Commission reimburse certain low power television, television translator, and FM broadcast stations for costs incurred as a result of the Commission’s broadcast television spectrum incentive auction,” the tentative agenda says.

A fact sheet notes that the order would “[c]onclude that the REA permits the Commission to use the funds appropriated to the Reimbursement Fund for fiscal year 2019 to reimburse eligible LPTV/translator and FM stations as well as full power and Class A stations and MVPDs [multichannel video programming distributors], and that the Commission will prioritize the payment of those funds to full power, Class A, and MVPD entities over payments to LPTV/translator and FM entities.”

It also would “[c]onclude that LPTV/translator stations are eligible for reimbursement if: (1) they filed an application during the Commission’s Special Displacement Window and obtained a construction permit, and (2) they were licensed and transmitting for at least 9 of the 12 months prior to April 13, 2017, as required by the REA.” And it would “[c]onclude that the Commission will reimburse LPTV/translator stations for their reasonable costs to construct the facilities authorized by the grant of the station’s Special Displacement Window application.”

It also would “[c]onclude that full power and low power FM stations and FM translators that were licensed and transmitting on April 13, 2017, using the facilities impacted by the repacked television station are eligible for reimbursement under the REA. This includes FM stations that incur costs because they must permanently relocate, temporarily or permanently modify their facilities, or purchase or modify auxiliary facilities to provide service during a period of time when construction work is occurring on a collocated, adjacent, or nearby repacked television station’s facilities.”

The item would “[c]onclude that the Commission will not reimburse LPTV/translator or FM stations for costs for which they have already received reimbursement funding from other sources.” And it would “[d]iscuss the measures the Commission will take to protect the Reimbursement Fund against waste, fraud, and abuse.”

The FCC adopted an NPRM and order last year in MB docket 18-214 and GN docket 12-268 (TR Daily, Aug. 2, 2018).

Finally, the tentative agenda includes a draft report and order in MB dockets 18-63 and 17-105 to streamline the reauthorization process for “satellite” terrestrial broadcast television stations when they are assigned or transferred. It would “[e]liminate the requirement that a full reauthorization showing be made if the applicants to a transaction: (1) certify that there has been no material change in the underlying circumstances upon which the Commission relied in granting the current satellite authorization, and (2) provide a copy of the most recent written decision granting that authorization,” according to a fact sheet.

It would also “[a]llow interested parties that disagree with the applicant’s certification “an opportunity to present their objections in accordance with the existing petition to deny/informal comment process applicable to the assignment or transfer of licenses.” —Paul Kirby, [email protected], and Lynn Stanton, [email protected]


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