FCC Policy Necessary to Fix 9-1-1 Location Accuracy Problems
Wednesday, January 15, 2014 | Comments

When measuring technological innovation, time usually equals progress. As years pass, connections get faster, chips get smaller and computers get more powerful.

In the wireless 9-1-1 world, however, progress seems to be moving in the wrong direction. Just about any 9-1-1 professional will tell you that the wireless 9-1-1 location system doesn’t work as well today as it did even a few years ago. Calls that used to have accurate Phase II (latitude and longitude) locations now lack them, and wireless 9-1-1 callers often can’t be located if the caller can’t vocally convey his or her location.

During recent months, the nation’s 9-1-1 professionals have started speaking out on this worsening problem. More than 165,000 9-1-1 professionals, law enforcement officers, firefighters, emergency medical technicians (EMTs) and other first responders signed up to support the Find Me 911 Coalition in its efforts to convince the FCC to immediately adopt indoor location accuracy requirements for carriers. More than 30,000 people have signed a separate petition to the FCC asking for quick action on the issue, and thousands of letters have been sent to members of Congress.

Current Phase II wireless 9-1-1 rules require wireless service providers to provide the latitude and longitude of a caller within 50 to 300 meters depending on the type of location technology used. The FCC recently required wireless carriers to comply with the FCC’s location accuracy rules at either a county-based or PSAP-based geographic level. The new standards apply to outdoor measurements only, because indoor use poses unique obstacles.

Recent data shows why the 9-1-1 community is frustrated. In August, the California chapter of the National Emergency Number Association (CalNENA) filed information with the FCC from five major California public-safety answering points (PSAPs) that showed a significant decline in the number of Phase II locations delivered to the PSAPs during the past four years for some carriers. For one carrier, only 19 percent of its wireless 9-1-1 calls included Phase II information by call termination. Even for the best-performing carrier, less than 60 percent of its wireless 9-1-1 calls delivered that vital information to the PSAP.

Additional data from other states confirmed that this problem is nationwide, and it is increasing. Since the CalNENA filing, six others states or counties within those states have filed data with the FCC showing poor performance in the delivery of Phase II locations with wireless 9-1-1 calls, including North Carolina, Oregon, Pennsylvania, Texas, Utah and Washington. Across all of those states, the data showed unacceptably high percentages of incoming 9-1-1 calls that lacked critical Phase II data, ranging from one-third of calls in Utah to up to two-thirds of all calls in Texas.

Why has this problem rapidly worsened? Other filings with the FCC reveal the answer: The carriers have increasingly adopted Assisted-GPS (A-GPS)-based location systems during that timeframe.

GPS systems can provide excellent accuracy as long as the line of sight to satellites is unobstructed. Unfortunately, at least 50 percent of 9-1-1 calls originate indoors or in other areas where the satellites’ view is blocked. Wireless carriers reported to the FCC that GPS fails 20 – 30 percent of the time, presumably when calls are made indoors, or when satellites can’t see the caller because of an urban canyon, a thick forest canopy or other obstruction.

When GPS fails, carrier filings show that the location systems fall back on technologies that can be much less accurate and can even be misleading as to the location of the caller. No wonder 9-1-1 professionals are upset.

The carriers assert that GPS is better than other technologies and that 9-1-1 professionals need to update their practices by “rebidding” — or manually requesting updated location information — after GPS has the 30 seconds or so required to obtain and generate a location, which can be a long time in the 9-1-1 world.

While everyone agrees that rebidding may help deal with the GPS time delay, it is not a solution to the deeper problems inherent to a GPS-based solution. In its FCC filings, one carrier admits that rebidding often fails to provide a GPS-based location, with about 20 percent of wireless 9-1-1 calls then providing a false Phase II location that can send emergency responders to the wrong location. Thus, regardless of the number of rebids submitted by PSAPs, tens of millions of wireless calls each year can’t be located if the caller can’t share — or doesn’t know — their location.

Steve Souder, director of public-safety communications for Fairfax County, Va., demonstrated how feeble the rebidding argument is when he spoke at the FCC’s E9-1-1 Location Accuracy Workshop Nov. 18. He described hosting the then chairman of the FCC, Julius Genachowski, at his PSAP. Genachowski dialed 9-1-1 from inside the large, metal-roofed building, but his location came up more than one-quarter mile away in a local Costco store, near the meat section. Upon rebidding, his location moved, but rather than showing his accurate location at the PSAP, it shifted within the Costco to where they sell the pizzas.

It is clear that the real problem is the carriers’ choice of technology, perhaps accurate in certain settings, but with disastrous results overall. The use of GPS technology may be cheaper for the carriers because the consumer pays for the chip in the handset and the federal government pays for the GPS satellites, but the cost to the 9-1-1 caller — and our public safety overall — is unacceptable. Moreover, GPS will not enable next-generation 9-1-1 (NG 9-1-1) capabilities, because it is too slow to support X, Y routing that determines which PSAP should receive a call based on the actual location of the caller.

Americans are communicating wirelessly more and more, and that trend will continue. If the safety of the public is our first priority, we must use fast and accurate technologies to find callers in crisis. Those technologies are available, but the FCC must take immediate action to require the carriers to meet reasonable indoor location standards to assure their use. By doing so, we can ensure that our 9-1-1 professionals can quickly and reliably find victims wherever they are — indoors or outside, in rural or urban areas — and get them the help they need.

For an article on why best practices are better than new 9-1-1 location accuracy policy, click here.


James Barnett Jr. is a partner at Venable and co-chair of firm’s telecommunications group in the government division in the Washington, D.C. office. Barnett is also director of the Find Me 911 Coalition. Barnett served as chief of the FCC’s Public Safety and Homeland Security Bureau (PSHSB) from 2009 – 2012. Prior to joining Venable, he served as senior vice president for national security policy at the Potomac Institute for Public Policy. He remains a senior fellow of the Potomac Institute.

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