Adhering to Best Practices Is Better than New Policy
Wednesday, January 15, 2014 | Comments

In recent months, there has been considerable sound and fury regarding the ability of public-safety answering points (PSAPs) to locate emergency calls generated from wireless telephones. With the rapid migration of the public from wireline to wireless devices, there is no question that the ability to locate callers, when the caller is unable to provide a good location, is an essential tool in the public-safety telecommunicator’s toolkit. We all want, and need, instantaneous, pinpoint accurate location information from indoor, outdoor, urban, suburban and rural areas. The landscape for wireless-generated calls for emergency assistance has shifted since the development of current FCC rules governing location determination, and improvements in location technology are needed.

There is less agreement, however, about whether we are facing a full-blown crisis, requiring radical changes in previously agreed-upon priorities, or whether adherence to best practices presents the best path forward. The Association of Public-Safety Communications Officials (APCO) International and the National Emergency Number Association (NENA), the two primary public-safety telecommunications associations, have defined PSAP best practices. Leading the charge for a crisis is a vendor-driven, vocal band of supporters using questionable and misleading data to seek an improved share of the market. Filings posted to the FCC docket 07-114 Dec. 20 draw a clear line between a single location technology provider and the Find Me 911 Coalition.

When evaluating the current landscape of location technology, most knowledgeable parties agree that no one technology has demonstrated the ability to locate all wireless callers in all areas and settings with a high degree of accuracy and low latency. Equally, contrary to public statements made by the Find Me 911 Coalition, there is no consensus within the public-safety community as to whether the best available accuracy or low latency — defined as the difference between perhaps 5 seconds and 20 to 30 seconds — is more valuable.

Using a fast food analogy, one can get relatively poor quality food at a drive-in restaurant quickly, but it is considerably more challenging to get high-quality, gourmet food within that same time period. Assisted-GPS (A-GPS) location technologies have proven to be highly accurate, but take a few seconds longer to process. Network-based systems can provide a quicker fix, but are highly challenged in rural areas and at the cell edges where fewer towers can be used to generate an accurate fix. All location technologies work well in some indoor settings, and not in others, with variation among the technologies — but none can definitively pinpoint a caller’s location to a specific building.

For example, a “Z” (altitude, floor) fix for high-rise structures likely will be limited to markets where there are enough high-rise structures to justify the expense of implementation. And the reality is that not every PSAP can afford to implement new capabilities or modify existing systems to receive such data even if they become available.

Up until mid-2013, the public-safety community worked within the structure of organizations such as APCO, NENA, Alliance for Telecommunications Industry Solutions (ATIS) and the FCC’s Communications Security, Reliability and Interoperability Council (CSRIC) to define issues, recommend best practices and seek industry solutions. With the release of the California chapter of the National Emergency Number Association (CalNENA) report in August following the birth of the Find Me 911 Coalition, however, a vocal minority emerged that has attempted to force the formulation of regulatory policies through a process of “policy that sounds good” rather than through an analysis of the realistic options that can provide “good, sound policy.”

Blinking campaign buttons, flashy posters and wishful thinking neither change the laws of physics and the current state of engineering technology nor provide a realistic path forward for improved location technology. In November, the FCC hosted a workshop focused on the current state of affairs related to location technology. In presentations made by all leading providers of wireless location technology, there were reports of new technologies that will be introduced into the wireless networks within the next two years that will generate significant improvements over current technologies.

As carriers continue the rapid buildout of 4G Long Term Evolution (LTE) networks, they will, for the first time, be able to run multiple location technologies simultaneously, improving both the likelihood of a more accurate fix, especially from indoor locations, and the ability to pick the best of multiple location estimates. Several of these technologies were vetted in the last FCC CSRIC session and additional testing and evaluating of these technologies is underway in the CSRIC process. Wireless carriers are equally motivated to incorporate the improvements, as improved location capabilities contribute greatly to their business plans.

One element missing from the discussions, however, is the ability of many PSAPs to incorporate additional accuracy elements, once introduced. As an example, the public-safety representatives on the FCC’s November panel stated a desire to incorporate a “Z” dimension to their location fixes, but failed to address the changes required in CAD and records management systems (RMS) to accept this feature. Anyone who has modified CAD and RMS software knows this is no small task.

Learning from the history of the current wireless location landscape, it took more than 10 years for the majority of the country to request and implement Phase II services after the original delivery capabilities of the wireless carrier community. With the discussion of migration to next-generation 9-1-1 (NG 9-1-1) systems, it would be enticing for a PSAP to wait and incorporate new location technology capture features in its NG 9-1-1 upgrade, but what is the timeframe for these upgrades?

The Find Me 911 Coalition has been vocal about the expectation of the public regarding this topic. Is the coalition now willing to press for the same mandates for public safety to be able to accept the sought after improved location information as they are for regulatory requirements for wireless service providers to provide the requested location information?

If we are to reach the goal of improved location information in a timely manner, it is imperative that both the public-safety and wireless communities work within the structures, including, but not limited to, APCO, NENA, ATIS, CSRIC and CTIA, that have served them well for many years. Through these venues, public safety and the people they serve can benefit through the development of good, sound policy as opposed to policy that sounds good.

For an article on why FCC policy should be implemented to help alleviate 9-1-1 location accuracy problems, click here.

After a 30-year career in public safety, Joe Hanna now serves as a consultant to the wireless industry in matters related to public policy and regulatory affairs. He is a fellow in the Radio Club of America (RCA), a senior fellow for the Center for Digital Government, and a life member and past president of the Association of Public-Safety Communications Officials (APCO) International.

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