Carriers Propose Handset-Based 9-1-1 Indoor Location Requirements
Tuesday, June 23, 2020 | Comments

Earlier this month, CTIA and representatives from the nationwide wireless providers met with FCC officials to discuss adopting an alternative nationwide Z-axis benchmark that will deliver ±3 meter vertical location information for what the carriers said would be far more wireless 9-1-1 calls than can be achieved under the FCC’s existing benchmark.

The FCC’s current Z-axis rules were structured around the technology solutions — network-dependent solutions — deemed promising more than five years ago, the filing said.

In its order last year, the FCC established compliance benchmarks for April 2021 of ±3 meters relative to the handset for 80% of indoor wireless 9-1-1 calls in the top 25 cellular market areas (CMAs). The FCC also sought comment on alternative options for Z-axis deployment, including modifying the geographic coverage requirements.

CTIA and the nationwide providers encouraged the commission to adopt an alternative Z-axis framework that expands the geographic coverage requirements to wireless 9-1-1 calls nationwide and recognizes the current state of mobile OS-based solutions to deliver ± 3 meter vertical location information.

Specifically, the FCC should allow the providers to meet the April 2021 benchmark with Z-axis solutions that deliver ±3 meters nationwide, rather than in just the top 25 CMAs. The change would ensure that providers can deliver ±3 meter vertical location information for 20 times more 9-1-1 calls than the existing benchmark focused on the top 25 CMAs, the filing said.

An attachment to the filing says a nationwide approach that recognizes the current capabilities of mobile OS-based solutions can yield 40% of 9-1-1 calls producing ±3 meter Z-axis location information by April 2021, while network-dependent solutions in contrast will likely yield only 2% of 9-1-1 calls producing ±3 meter z-axis location information. By adopting a requirement that increases the target accuracy metric in the test bed over time — 50% in 2021, 70% in 2023 and 80% in 2025 — mobile OS-based solutions can yield up to 75% of 9-1-1 calls with ±3 meter Z-axis information nationwide by April 2025, while network-dependent solutions will likely yield only 16% of 9-1-1 calls with ±3 meter z-axis information, the filing said.

Stage Za testing, which reviewed only Google’s Android-based Emergency Location Service (ELS), showed that an existing mobile OS-based solution can meet this approach. The report of the testing was marked confidential and is not publicly available.

CTIA said no commercial Z-axis solutions have yet been validated to achieve the commission’s current benchmark of ± 3 meters for 80% of calls, and the executives expressed significant concern that no Z-axis solutions that achieve the FCC’s current April 2021 benchmarks are available. “Network-dependent solutions will rely on handset manufacturers for commercial availability, and there is no evidence to suggest that these network-dependent solutions will be integrated by April 2021 given handset manufacturers’ privacy-related concerns.”

However, in a May filing, AT&T Services and NextNav provided a list of the 105 CMAs where the NextNav Z-axis network will be available for use to support the First Responder Network Authority (FirstNet) and potentially E9-1-1 services.

AT&T said the network is designed to provide vertical location accuracy of within 3 meters to at least 80% of all commercial buildings that are three or more floors in height within the 105 CMAs. The network is scheduled to be completed within these 105 CMAs in advance of the commission’s April 2021 deadline for the initial provision of vertical location services to support public safety.

An AT&T spokesperson didn’t respond to a request for comment by press time.

“CTIA and the nationwide providers are eager to work with the commission and public-safety stakeholders to deliver ± 3-meter vertical location information for as many wireless 9-1-1 calls as possible, nationwide,” the filing said.

“The National Emergency Number Association (NENA) has been consistent in advising the commission that the current benchmarks are technically feasible and support first responders' needs to locate 9-1-1 callers inside of buildings, and looks forward to the next phase of testing under the CTIA test bed (where NENA participates),” said Dan Henry, NENA government affairs director. “We are experts on public safety and technology, and can only speak generally to the economic feasibility of the options proposed to the commission. Thus, the past few weeks' numerous filings fall largely out of our scope as an organization, and NENA does not want to unduly bias the commercial marketplace.”

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