TR Daily FCC Adopts 911 Location Accuracy Item
Thursday, July 16, 2020

FCC Adopts 911 Location Accuracy Item

The FCC today adopted a wireless 911 location-accuracy item that has drawn concerns from both public safety entities and wireless carriers. Carriers prefer an alternative location accuracy framework and suggest that they won’t likely be able to comply with a 2021 milestone, while public safety groups say the item should have included stricter provisions.

Among other things, the sixth report and order and order on reconsideration in PS docket 07-114 requires nationwide wireless carriers to deploy z-axis, or vertical, location accuracy technology nationwide by April 2025, giving non-nationwide carriers an additional year to meet the mandate.

It follows up on an item adopted last year that set a z-axis metric of plus or minus three meters relative to the handset for 80% of indoor calls (TR Daily, Nov. 22, 2019). The item required nationwide carriers to meet April 3, 2021, and April 3, 2023, milestones for complying with the metric in the top 25 and top 50 markets, respectively.

“In the Order adopted today, the Commission affirmed the 2021 and 2023 z-axis requirements, rejecting a proposal to weaken them,” a news release noted on the item adopted today. “The Commission added a new requirement that nationwide wireless providers deploy z-axis technology nationwide by April 2025, while affording non-nationwide wireless providers an additional year (i.e., until April 2026) to do so within their service areas. To give wireless providers additional flexibility in meeting these requirements while still advancing critical public safety objectives, the Commission allowed providers to deploy technologies that focus on multi-story buildings, where vertical location information is most vital to first responders. The Commission also required wireless providers, beginning in January 2022, to provide dispatchable location with wireless 911 calls when it is technically feasible and cost-effective to do so, which will promote consistency in the Commission’s 911 rules across technology platforms.” In the days leading up to today’s vote at the FCC’s monthly meeting, wireless carriers and CTIA told the FCC that they would have preferred the FCC adopt an alternative z-axis framework that relies on mobile operating system-based technology (TR Daily, June 16).

Commissioner Jessica Rosenworcel approved in part and dissented in part on the item, saying she is pleased that the FCC adopted “a uniform, national policy” on 911 location accuracy.

“While we get this right, in other ways I fear today’s decision misses the mark. It makes complex what should be simple when we call 911. It makes location information available but not in any format that is actionable for 911 operators. And it makes it too hard for public safety officials to use the information that is provided,” Ms. Rosenworcel complained.

She bemoaned that “we adopt an approach that requires 911 opt-in. Every wireless consumer will only get full location information sent with their emergency calls if they perform a specific software update on their device or respond to a notice from their carrier regarding an application that may be available. Let’s be honest, in the best case a whole lot of people are going to miss this one, never download it or respond to the fine print in a service notice.”

She also said that “we need to provide 911 operators actionable location information. Nine months ago, the FCC adopted a standard for wireless carriers providing vertical location information using a z-axis solution. Specifically, the agency required that wireless carriers offer public safety an indoor caller’s vertical location measured plus or minus three meters height above ellipsoid. At the time, I observed that this measurement system does not produce actionable data that a 911 operator can easily use.”

Ms. Rosenworcel added that “we need to listen to public safety officials calling for useful information. Nine months ago, we acknowledged a hard truth. We recognized that a vertical location measurement of plus or minus three meters may not be good enough for police, firefighters, and emergency medical personnel trying to locate a 911 caller in crisis. … So nine months ago we sought comment on how to improve the plus or minus three meter margin of error. But instead of acting on this today, we kick the can down the road and put off review of this standard until 2022. Why not do it right here, right now? After all, the International Association of Fire Chiefs, International Association of Firefighters, International Association of Chiefs of Police, National Sheriffs’ Association, and National Association of State EMS Officials have all asked the agency to narrow this standard or at a minimum reassess it twice a year. I think we should have taken on this task today.”

Commissioner Mike O’Rielly said that “[w]hile equipment and wireless providers are making great strides with z-axis technologies, the technology still is not commercially deployed and proven. Promising results have been achieved in a test bed environment, but there are no real-world operations yet. And while meeting deadlines and benchmarks is still a work in progress, nonetheless, today we double down and require z-axis nationwide availability by 2025, as if the ultimate remedy requires just one more mandate.

“We now have wireless providers and manufacturers expressing concerns about the direction in which we are headed. We cannot just dismiss the merits of their arguments by attacking their motives or hiding behind Commission procedure. These are the very companies that we are going to rely on to make this technology work, and they seem to have serious doubts,” Mr. O’Rielly added. “The handset-based solutions that will facilitate nationwide deployment are currently less accurate than the network-based systems this Commission has been considering for years. I am concerned that the Phase II history is repeating itself, heading us towards a deluge of waivers. And, the handset-based technology may not be ready in time to meet the earliest deadlines, forcing providers to switch z-axis solutions midstream. That seems neither effective nor cost-efficient, and we know who will end up paying for this: the American consumer. One way or another, these costs will be passed on in the form of higher bills or reduced functionality.”

“Thankfully, today’s item does provide more flexibility, such as allowing providers to comply by deploying z-axis technology on handsets, covering 80 percent of a Cellular Market Area’s multi-story buildings, and providing dispatchable location – which is still the ultimate goal – without the National Emergency Address Database, or NEAD,” Mr. O’Rielly added. “Further, I am pleased that we have withheld from making other premature rule changes. The goal should be to get what is already required actually working and helping people before shifting the goalposts any further.”

“Though I support today’s action, I also recognize that there is much more to do,” Commissioner Geoffrey Starks said. “Based on the record in this proceeding, I am confident that technological developments will soon enable us to tighten the requirement beyond plus or minus three meters. I will continue to encourage industry to step on the gas in working towards even more accurate solutions —and encourage the Commission to soon require even more precise z-axis location information. We must remain focused on the ultimate goal: getting first responders to the precise location where they are needed.”

Mr. Starks added that he “will also continue to highlight the importance of technology-neutral solutions. The progress many innovators have made using barometric pressure sensors is impressive, and those sensors will become more ubiquitous as costs continue to decrease. But we must recognize that not all devices, particularly the less expensive devices often offered by Lifeline providers, contain barometric pressure sensors. As the item explains, there are technologies on the horizon that can provide z-axis information even for these less expensive devices. The Commission should encourage the development of those solutions, because a speedy response in an emergency should not be luxury. If, after the initial April 2021 deadline, it appears that Lifeline subscribers are not benefitting from our z-axis rules, the Commission must consider additional rules to close that gap. As I have long said, lifesaving technology needs to be available to everyone.”

Commissioner Brendan Carr said he thinks he “can speak for all of us—public safety advocates, the wireless industry, and each of my fellow commissioners—when I say we need tech’s help to improve 9-1-1 response. Since at least 2015, the Commission has mandated that wireless phones transmit to 9-1-1 operators certain location information that can be tied to an address or place on a map. It has taken longer to arrive at a height information requirement, with our first deadline coming next April. But we’re getting there with barometers and software that leverages device signals.

“This is not an achievement of government mandates but of technologists and entrepreneurs focused on solving the problem,” Mr. Carr added. “Already two companies have demonstrated how using air pressure can accurately project the height of a call’s origin. Google is making progress with a different approach, and Apple will demonstrate its solution in the test bed this fall. We are grateful for these companies’ efforts and confident that their solutions will save lives.”

FCC Chairman Ajit Pai detailed provisions in the item and then added that “much work will remain after today. So wireless carriers, the public safety community, z-axis solution providers, device manufacturers, and others will have to work together in good faith to get the job done—and done on time. We owe it to the Americans who rely on their mobile phones to call 911 in an emergency. And we owe it to the first responders who often risk their own lives to answer those calls.”

During a call with reporters after today’s meeting, he was asked if he was concerned that wireless entities have indicated that they don’t expect to be able to meet the April 2021 milestone.

He said the record showed that the “timeframe was feasible,” adding, “I do believe we made the right decision.”

“NENA commends Chairman Pai and supports the vertical location accuracy item on the July meeting agenda,” said Dan Henry, regulatory counsel and director-government affairs for NENA. “The new rules will further improve ‘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. The Sixth Report and Order – like the Fifth R&O before it – strikes a good balance between public safety’s needs and what is technically feasible. We look forward to working with the public safety community, including public safety operations, standards development partners, and vendors, to implement these orders in a practical, interoperable way.”

The National Public Safety Telecommunications Council “commends the FCC for the Sixth Report & Order which will finally, after 6 years, bring vertical indoor location to 9-1-1 calls which originate inside of buildings. This action will narrow the search circle, and make it easier to find those who are in need of help. This is a step in the right direction. Today is a very positive day for public safety and the general public. We thank the Commission,” said NPSTC Chairman Ralph Haller.

“The FCC’s Sixth Report and Order delivers real results for the nation’s first responders,” said Gary Ludwig, president and chairman of the board of the IAFC. “It affirms the existing 911 benchmarks while establishing a new benchmark for nationwide deployment that will ensure those living outside major cellular markets will benefit from vertical 911 location accuracy. We look forward to working with stakeholders to reach these deadlines, which are vitally important to life safety.”

But Matt Gerst, vice president-regulatory affairs for CTIA, said, “The FCC is missing an opportunity to use smartphone solutions to provide vertical location data for millions of 9-1-1 callers nationwide by April 2021. The wireless industry has been working tirelessly for years on this important issue, and we will continue to work with the FCC and public safety stakeholders on enhancing location information for wireless 9-1-1 callers.”

In recent filings, AT&T, Inc., and Verizon Communications, Inc., said it could be difficult to meet the 2021 milestone, with AT&T citing the COVID-19 pandemic and Verizon mentioning possible difficulties with handset vendors (TR Daily, July 9 and 8).

Public safety entities, which opposed the industry’s alternative proposal, had asked the FCC to adopt stricter milestones.

For example, NPSTC had urged the FCC to require wireless carriers to provide more precise indoor 911 location accuracy “in the relatively near future” and the federation also asked the Commission to impose other stricter regulations in the item (TR Daily, July 8).

The Association of Public-Safety Communications Officials-International had asked the FCC to modify the draft order “to eliminate loopholes regarding the provision of dispatchable location and z-axis information” (TR Daily, July 7). —Paul Kirby, [email protected]

MainStory: FCC FederalNews PublicSafety

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