TR Daily Draft 911 Item Would Set Nationwide Z-Axis Deployment Deadlines
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Thursday, June 25, 2020

Draft 911 Item Would Set Nationwide Z-Axis Deployment Deadlines

A draft item circulated for consideration at the FCC’s July 16 meeting and released today would require national wireless carriers to deploy z-axis, or vertical, 911 location accuracy technology nationwide by April 3, 2025, with non-nationwide providers getting an additional year to comply with the mandate.

The item also would require carriers to provide dispatchable location with wireless 911 calls “when it is technically feasible and cost-effective to do so beginning January 6, 2022.”

It also would permit providers to deploy technologies with the focus of concentrating on multi-story buildings.

The item also would affirm the April 3, 2021, and April 3, 2023, z-axis location accuracy deadlines for national carriers to deploy z-axis technology to within plus or minus of 3 meters for 80% of indoor 911 calls to the top 25 markets by April 3, 2021, and the top 50 markets by April 3, 2023.

The sixth report and order on reconsideration in PS docket 07-114 would follow up on a fifth report and order and fifth further notice of proposed rulemaking adopted last November (TR Daily, Nov. 22, 2019).

“With this Sixth Report and Order, we adopt our proposals in the Fifth Further Notice to expand the options for CMRS providers choosing to deploy z-axis technology to meet the April 2021 and April 2023 compliance benchmarks, with some revisions and clarifications,” the draft item said. “We adopt our proposal to allow CMRS providers flexibility to develop dispatchable location solutions that do not depend on the National Emergency Address Database, which has been discontinued. In addition, to make our wireless dispatchable location rules consistent with our dispatchable location rules for other services adopted pursuant to Section 506 of RAY BAUM’S Act, as of January 6, 2022, we require CMRS providers to provide dispatchable location for wireless 911 calls when it is technically feasible and cost-effective for them to do so. We also address implementation issues for dispatchable location solutions that are not based on the National Emergency Address Database, including (1) privacy and security and (2) confidence and uncertainty data requirements.”

The item continued, “For the time being, we defer the issues raised in the Fifth Further Notice of whether to migrate from 3 meters to a stricter z-axis metric or to require CMRS providers to deliver floor level information. Based on the comments received on these issues, we believe that further work is needed to develop improved location technology that can achieve these capabilities and that adopting a timetable for such requirements at this stage would be premature. We direct the Public Safety and Homeland Security Bureau to consider whether to refer certain technical issues to a federal advisory committee, such as the Communications Security, Reliability and Interoperability Council (CSRIC). In response to APCO’s Petition for Clarification, we address other implementation matters and clarify certain aspects of the Fifth Report and Order. We deny BRETSA’s Petition for Reconsideration of the Fifth Report and Order. We defer consideration of a number of other issues raised in comments that fall outside the scope of the Fifth Further Notice. Finally, we grant Polaris’ Petition for Emergency Declaratory Ruling to the extent stated herein. Taken together, we conclude that the benefits of today’s decision outweigh the costs and that our actions will assist PSAPs and first responders in locating wireless 911 callers in the most populous areas in the near term and nationwide over the long term.”

The item added that the FCC would “reject calls by some quarters to weaken our existing benchmarks and replace them with exclusive nationwide benchmarks that do not meet our current accuracy target. In their comments, CMRS providers propose an alternative timeline for deployment of z-axis technology meeting the accuracy standard adopted by the Commission in the Fifth Report and Order. T-Mobile, Verizon, and AT&T support an option for nationwide deployment that would require meeting the ± 3-meter vertical location accuracy metric for 50% of calls by April 2021, 70% of calls by April 2023, and 80% of calls by April 2025. T-Mobile asserts that under this alternative, z-axis technology would be available ‘across the country on nearly all devices’ by April 2021. T-Mobile also supports either relaxing the z-axis metrics to ‘±5 meters for 80% of calls or ±3 meters for 60% of calls.’ Verizon and AT&T also support a schedule for introducing z-axis capable devices nationwide.”

“NENA commends FCC Chairman [Ajit] Pai and welcomes the items on the July open meeting agenda,” said Dan Henry, NENA’s government affairs director. “If adopted, the draft rules will further improve vertical (‘z-axis’) location accuracy for wireless 9-1-1 calls, not just in the Top 25 or 50 largest U.S. cities, but across the country and where 9-1-1 callers need it most. Based on our initial review, the Sixth Report and Order follows in the Fifth R&O’s footsteps by striking a good balance between public safety’s needs and what is technically feasible. We look forward to working with the Commission and stakeholders in support of these items and their smooth implementation.”

“I believe that public safety will support the draft order, and would want the other commissioners to hold the line on the 3 meter 80% of 911 calls for the nationwide requirement in 2025. The FCC should not allow the carriers either 5 meters or 50% of calls they have proposed and have been pushing in their ex parte filings,” a public safety veteran told TR Daily. “Public safety would also endorse that the FCC is clarifying that dispatchable location can be achieved by methods other than the NEAD, which CTIA shut down earlier this year.”

Also on tap for the July 16 meeting is a draft declaratory ruling in WC docket 18-89 that would find that the FCC’s November 2019 universal service supply chain order (TR Daily, Nov. 22, 2019) satisfies section 3 of the Secure and Trusted Communications Networks Act of 2019, which became law in March (TR Daily, March 12).

A companion second further notice would seek comment on implementing other provisions of the act.

The item would propose to (1) “create and maintain a list of covered communications equipment and services (Covered List), as required by section 2”; (2) “prohibit the use of federal subsidies administered by the Commission, including all USF funding, to purchase, rent, lease, otherwise obtain, or maintain any covered communications equipment and services on the Covered List, as required by section 3”; (3) “require all providers of advanced communications services to submit annual reports to the Commission indicating whether they have purchased, rented, leased, or otherwise obtained any covered communications equipment and services, as required by section 5”; and (4) “implement enforcement penalties and recovery of improperly spent funds, as required by section 7,” a fact sheet noted.

The FCC also is set to consider a draft NPRM in PS docket 20-187 that would consider updates to its rules and requirements for priority services.

The item would address the Telecommunications Service Priority (TSP) System and the Wireless Priority Service (WPS).

“The Commission’s rules for the current priority services programs date back to the establishment of the Telecommunications Service Priority (TSP) System in 1988 and the creation of the Priority Access Service (PAS), more commonly referred to as Wireless Priority Service (WPS), in 2000,” the item noted. “These rules, which were developed when communication networks were primarily based on circuit switched technologies, have not been updated to address the advanced capabilities of Internet Protocol (IP)-based communications supporting data as well as voice services, or to enhance the ability of users at different priority levels to share network capacity and resources.”

In 2018, the National Telecommunications and Information Administration filed a petition for rulemaking asking the FCC to modify its WPS rules, including by permitting some WPS users to preempt non-911 calls and by expanding WPS availability to non-voice services (TR Daily, July 10, 2018). In 2019, NTIA filed a petition for rulemaking asking the Commission to update its TSP rules so they better reflect technological changes and industry practices (TR Daily, July 17, 2019).

A public notice observed that the draft NPRM would (1) “[m]odernize the Commission’s rules to authorize priority treatment of voice, data, and video services for public safety personnel and first responders”; (2) “[s]treamline the Commission’s rules by removing outdated requirements that may impede the use of IP-based technologies”; and (3) “[a]mend the Commission’s rules to clarify and reflect the current administrative responsibilities for the priority services programs, while eliminating burdensome administrative requirements.” —Paul Kirby, [email protected]

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