A variety of industry associations, service providers and user agencies responded to an FCC request for comments on the use of location-based routing for public-safety answering points (PSAPs). Many commenters focused on whether or not the FCC should require providers to provide location-based routing.

The Association of Public-Safety Communications Officials (APCO) International said that the technology to improve routing is available.

“As the commission notes, modern devices are capable of deriving location estimates quickly enough to substantially improve routing and some nationwide wireless carriers have begun implementing location-based routing voluntarily,” APCO’s filing said. “Routing 9-1-1 calls based on the device’s location rather than relying solely on upon cell-sector based routing will save lives. The technology is available today and the commission should act quickly to require service providers to implement it.”

APCO noted that the implementation of location-based routing is not dependent on the implementation of next-generation 9-1-1 (NG 9-1-1) such as the implementation of emergency services IP networks (ESInets).

“AT&T’s recent announcement that it is implementing location-based routing nationwide illustrates that wireless carriers can implement location-based routing regardless of whether ECCs have an ESInet in place,” APCO’s filing said. “Further, it is important to clarify that NG 9-1-1, as defined by the public-safety community and recent legislative proposals, has not yet been fully deployed anywhere in the United States, and ‘transitional NG 9-1-1’ environments entail the deployment of ESInets that are intended to implement some call-delivery elements of an end-state NG 9-1-1 environment. NG 9-1-1 needs to mean the ability of ECCs to receive new forms of data from the public, process, triage and analyze this information, and share incident data in a fully interoperable manner with other ECCs and responders in the field. ECCs face significant obstacles to achieving these capabilities, and to succeed, the 9-1-1 community must work toward a common vision of NG 9-1-1.”

APCO also argued that location-based routing should be implemented without additional costs to emergency communications centers (ECCs) and said it is possible to do so.

In its own filing, AT&T discussed its nationwide implementation of location-based routing. The carrier’s implementation uses Apple’s Hybrid Emergency Location (HELO) or Google’s Emergency Location Service (ELS) for providing a location estimate for routing. AT&T then uses a tool developed by Intrado to use the handset provided location estimate from those technologies to determine which PSAP or ECC the call should be routed to.

Prior to rolling out the technology, AT&T ran two trials of it.

“Throughout both trials, the latency of the 9-1-1 call setup showed that over 95% of calls were receiving ringing within 6 seconds of dialing, consistent with latency seen prior to enabling location-based routing,” AT&T’s filing said. “This was well within the expected delay, and we saw no corresponding increase in 9-1-1 callers abandoning the initial call to re-originate a subsequent call to 9-1-1. In addition, the location estimate was available for routing purposes for approximately 80% of all 9-1-1 calls. When location was not available, the process defaults to using sector-based routing so that calls may be completed without excessive delay.” AT&T said that in both the trials and since its implementation, it is seeing that location-based routing selects the optimal route about 10% more than sector-based routing.

Intrado noted in its filing that location-based routing has the potential to solve some of the problems of sector-based routing.

“Misroutes of 9-1-1 calls have not gone away,” Intrado’s filing said. “Although most 9-1-1 calls routed by cell sector timely reach the appropriate public-safety answering point (PSAP) without the need for a burdensome transfer, misroutes are frequent in certain parts of the country with dense populations set within complicated PSAP boundaries over a single cell sector due the inherent technology limitation of tower-based routing. LBR, fortunately, provides an appropriate technological shift that is now ready for nationwide deployment.”

Intrado discussed its work with AT&T in implementing nationwide location-based routing.

“Working with Intrado, AT&T has achieved astounding results with LBR successfully utilized for over 80% of all AT&T wireless calls resulting in proven routing correction for thousands of 9-1-1 calls since early implementation in February 2022,” Intrado said. “Known problem areas for misroutes like the county of Los Angeles (California), Snohomish County (Washington) and Palm Beach County (Florida) (the latter two being early adopters of AT&T’s LBR service) provide strong stand-alone use cases for LBR evaluation. Additionally, AT&T’s nationwide LBR deployment ultimately can serve as a valuable proving ground for commission action to extend LBR implementation to all wireless carriers.”

T-Mobile said that it was the first carrier to make 9-1-1 location-based routing available nationwide and said that the FCC should continue to encourage carriers to voluntarily adopt it. However, it said that the FCC should not mandate that location-based routing be activated in areas where “doing so would not improve emergency response.”

“Where NG 9-1-1 systems have been deployed with subtending PSAPs (a prerequisite for full NG 9-1-1 implementation), the NG 9-1-1 system operator routes 9-1-1 calls based on location information provided by the carrier with the call,” T-Mobile’s filing said. “Thus, when a carrier can provide an accurate, low-latency location estimate, location-based routing can reduce the number of 911 calls that must be transferred. However, if a carrier only has Phase I location information available, routing on that rather than cell sector location could have the opposite effect. Routing based on Phase I location information could lead to more call transfers compared to cell sector routing. It is T-Mobile’s understanding that in some early NG 9-1-1 system deployments, those systems would route calls based on the location of the caller provided with the call; where that location information was Phase I location, calls were more likely to connect to the incorrect PSAP. In short, mandating a specific way of routing may not always lead to the best results; therefore, it is critical that the FCC ensures all involved parties have the flexibility to route 9-1-1 calls based on the best available information at the time a routing decision is made.”

Verizon also expressed some concern about location-based routing being required.

“As Verizon continues to assess the merits of LBR, we are cognizant that relying more on per-call device-level capabilities in 9-1-1 routing decisions would at least partially depart from the certainty of the PSAP-driven method of cell sector-based routing,” Verizon said in its filing. “(Indeed, Verizon is aware that some PSAPs do not want LBR at this time.) Still, service providers should remain free to employ these solutions consistent with Commission rules and policies.”

Verizon noted that like sector-based routing, location-based routing also requires that PSAPs up to date information on PSAP boundary changes to providers to ensure that the “location fix is plotted accurately.”

CTIA also argued that the commission should ensure that carriers should have flexibility in how calls are routed.

“The record also demonstrates that innovative 9-1-1 call routing solutions based on device-level location information require time for development and testing to ensure that the deployed solutions deliver mission-critical performance for public safety,” CTIA’s filing said. “Any modifications to 9-1-1 call routing requires consideration of factors unique to each wireless provider and PSAP and careful coordination between each wireless provider and each PSAP.” CTIA said that adoption of location-based routing should be entirely voluntary.

“For these reasons, the commission should ensure that wireless providers and PSAPs have sufficient flexibility to utilize device-based location for call routing purposes in a collaborative, voluntary manner that accounts for each wireless provider and PSAP’s capabilities,” CTIA said. “Further, the commission should recognize that PSAPs must continue pursuing solutions to enable seamless collaboration with adjacent and surrounding PSAPs, including shared mapping technologies and call-transfer capabilities.”

Meanwhile, Comtech, a 9-1-1 services provider, said that the calls can be best routed using an emergency services IP network (ESInet), a key component of NG 9-1-1 systems.

“… Consistent and appropriate routing of wireless 9-1-1 calls to PSAPs can best be achieved through wireless carriers’ delivery of 9-1-1 calls to an emergency services IP network (ESInet), which utilizes the most accurate location information available at the time a call is placed,” Comtech’s filing said. “Since NG 9-1-1 systems are inherently superior to legacy 9-1-1 systems at routing calls to PSAPs, Comtech urges the commission to facilitate the timely deployment of NG 9-1-1 systems throughout the country.”

In reply comments, the National Emergency Number Association (NENA) noted that it appeared there was strong support for location-based routing, as well as standards-based NG 9-1-1. In both its reply and initial comments, NENA urged the FCC to adopt a framework that would support standards-based NG 9-1-1.

“NENA also pointed out that such a framework would reduce taxpayer burden to fund 9-1-1 systems, as current transitional networks require 9-1-1 authorities to operate both NG 9-1-1 and legacy E9-1-1 system simultaneously,” NENA said in its reply comments. “Statements from all three major wireless carriers indicate support for such a framework.”

NENA urged the commission to start a proceeding that would establish rules to implement LBR nationwide.

“It is clear from the record that universal standards-based LBR is technically feasible and that early transitional LBR systems have had tangible positive results,” NENA’s reply comments said. “Universal LBR will reduce response times for millions of calls in the United States by reducing the number of call transfers required. This will save lives. There are standards-based mechanisms built into NG 9-1-1 that address some of the technical concerns introduced by commenters in implementing universal LBR. Some of these standards-based mechanisms have already been implemented, have been published and additional standards are already underway.”

The state of Massachusetts State 911 Department said it has completed the transition to next-generation 9-1-1 in December 2017. The department said that its system currently supports 215 Public-safety answering points.

“Prior to the NG 9-1-1 deployment, most wireless calls required a transfer,” the state’s filing said. “NG 9-1-1 has allowed all Massachusetts PSAPs to receive wireless calls directly, and also has provided the PSAPs the option of receiving only WPH2 (wireless phase II) calls,” the filing said. “As of 2022, most PSAPs have decided to receive both WPH1 and WPH2 calls, resulting in a savings of over a half a million minutes per years in terms of public-safety response times by reducing unwanted transfers.”

The 9-1-1 department said that the location provided by wireless carriers has improved over time.

“We consider a circle of 200 meters small enough to route,” the filing said. “In 2019, 27% of wireless calls had an initial location of 200 meters or less. In 2022, that has increased to 52%.”

The 9-1-1 department also said that the implementation of NG 9-1-1 has led to some new routing issues. The department said that the type of location information provided by a carrier can impact its ability to route 9-1-1 calls to the correct PSAP.

“In general terms, we define location types as civic, latitude/longitude only and probable circle,” the filing said. “Civic is conceptually similar to the ALI … Probable circle is defined as latitude, longitude and uncertainty. The uncertainty is used as the radius, and together with the latitude/longitude center point, we create the probable circle. Wireless calls are typically routed using a probable circle. Historically, the larger the circle, the more likely the call was misrouted. In 2017, when we began location-based routing, getting a radius of more than 50,000 meters was common. We received uncertainties (radius) of over one million meters regularly. One wireless carrier provides a location type of latitude/longitude only for the vast majority of wireless calls, and these route to the PSPA where the tower is located, a step backward from E9-1-1’s ESN (ESRK) based routing.”

The Massachusetts 9-1-1 Department also said that so far, only one carrier has connected to the state’s NG 9-1-1 via IP for voice call.

America’s Public Television Stations (APTS) advocated the use of datacasting, noting that many emergency services across the U.S. still use analog voice paging technology to communicate information to first responders. It noted that PBS North Carolina has been working on datacasting technology that can provide a redundant option for public-safety paging.

“Datacasting is the transmission of data utilizing the available capacity of the broadcast transmission signal,” APTS’ filing said. “Use of datacasting in the ATSC 3.0 signal for public-safety communications could lead to cost-sharing, higher reliability, greater collaboration across jurisdictions, and reduced response times. The ability to alert multiple responders will take only milliseconds using a datacast digital format, which is literally a thousand times faster than today’s analog paging format.”

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