TR Daily FCC Rejects CTIA, APCO 911 Location-Accuracy Petitions
Monday, January 11, 2021

FCC Rejects CTIA, APCO 911 Location-Accuracy Petitions

The FCC released an order on reconsideration today that rejects petitions for reconsideration filed by CTIA and the Association of Public-Safety Communications Officials-International of a 911 location-accuracy sixth report and order adopted last summer (TR Daily, July 16, 2020). Commissioner Jessica Rosenworcel concurred in the item but did not release a statement.

The order required nationwide wireless carriers to deploy z-axis location-accuracy technology nationwide by April 2025, and it gives non-nationwide carriers an additional year to meet the mandate. It also affirmed a fifth report and order adopted in 2019 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 2020 item also affirmed that nationwide carriers must meet April 3, 2021, and April 3, 2023, milestones for complying with the metric in the top 25 and top 50 markets, respectively.

Citing testing delays caused by the COVID-19 pandemic and the inability of technologies to be ready to meet the FCC-mandated location-accuracy metric, CTIA asked the Commission in its petition to reconsider its z-axis rules and deployment timelines (TR Daily, Sept. 29, 2020). The request drew criticism from the public safety community.

In its petition, APCO urged the FCC to reconsider "the way in which the dispatchable location requirements were revised to take into account termination of the National Emergency Address Database (NEAD) [TR Daily, Sept. 24, 2020]. The new rule lacks a basis in the record, fails to chart a course for achieving real progress with the delivery of dispatchable location, and risks creating a way for carriers to comply with the location accuracy requirements without actually providing improved location information with 9-1-1 calls."

"For the reasons discussed below, we dismiss the petitions as procedurally defective and, as an alternative and independent ground for resolving the issues raised, we deny the petitions on the merits," the FCC said in today’s order in PS docket 07-114.

"We find CTIA’s petition procedurally improper because it repeats arguments raised by other commenters in this proceeding and fully addressed in the Sixth Report and Order. After making clear that we intended to keep the longstanding April 2021 and 2023 z-axis deadlines, the Commission noted in the Sixth Report and Order that some CMRS providers had asserted that the ongoing COVID-19 pandemic could delay or otherwise adversely affect the testing of vertical location technologies. The Commission further noted that while the pandemic created recent challenges, the Commission agreed with public safety commenters who pointed out that ‘vertical location requirements were adopted six years ago and [ ] the public urgently needs accurate 911 location.’ The Commission therefore declined to change the long-established April 2021 deadline for z-axis implementation … ."

"CTIA’s attempt to reargue this point is repetitive and untimely, and CTIA has failed to offer sufficient factual details about any of its individual member service providers that would support grant of a waiver to a particular provider," the order said.

"Similarly, we find that APCO’s arguments are repetitive and misconstrue the record. In its reconsideration petition, APCO does not allege any change in circumstances or offer any newly discovered facts, but rather, reargues points that it previously advanced and that the Commission rejected in the Sixth Report and Order," the FCC said. "Specifically, in the Sixth Report and Order, the Commission considered and rejected APCO’s suggestion that the Commission revise its rules to require CMRS providers to provide dispatchable location for a minimum percentage of 911 calls. The Commission also considered and rejected APCO’s argument that requiring dispatchable location only when ‘technically feasible’ was ineffective. We therefore dismiss the Petition as repetitive."

The FCC also called the petitions untimely because they seek reconsideration of requirements established in a fourth report and order five years ago.

"As an alternative and independent basis for rejecting the CTIA and APCO Petitions, we deny them on the merits and once again affirm our vertical location timelines and rules," the order said.

For example, it said that the FCC disagrees "with CTIA’s claim that postponement of Stage Zb testing due to the pandemic has ‘derailed the prospects for achieving the Sixth R&O’s timelines.’ CTIA asserts that Stage Zb was preparing to test both ‘network-based and mobile OS-based Z-axis solutions.’ To the extent Stage Zb would have tested mobile OS-based technologies, the Commission found in the Sixth Report and Order that deployment of these solutions has no bearing on whether the 3-meter metric and z-axis timelines are feasible." —Paul Kirby, [email protected]

MainStory: FCC FederalNews PublicSafety

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