Public-Safety Groups Split on Wireless 9-1-1 Indoor Location Agreement (11/18/14)
Tuesday, November 18, 2014 | Comments

By Kristen Beckman
A new agreement among the Association of Public-Safety Communications Officials (APCO) International, the National Emergency Number Association (NENA) and wireless carriers for 9-1-1 indoor location accuracy has public-safety groups divided on whether the requirements go far enough to locate 9-1-1 callers inside buildings.

The agreement was announced late Friday, and by Monday several groups had filed comments with the FCC opposing the agreement.

The agreement was expected to be forwarded to the FCC Nov. 18 via an ex parte notice and the commission will then have the option to accept or reject the agreement in whole or accept it in part.

“In our experience, once things like this are submitted, there are invariably some details that the commission will fill in differently than the parties might have, but we think in general by putting together a framework that puts us on a long-term path to parity with commercial location services, that we are doing the right thing for public safety,” said Trey Forgety, government affairs director at NENA.

The Agreement
The agreement negotiations stemmed from established relationships among APCO, NENA and wireless carriers that were built during the process of planning and deploying text-to-9-1-1 service during the past two years.

“The commission encouraged public safety to engage with the wireless carriers in the same way we did with text messaging almost two years ago now to try to find a consensus approach that would get us to real measurable improvements on location accuracy without requiring the years of litigation that have often characterized this debate in the past,” said Forgety. “For us the most important thing was making sure we had specific measurable commitments from the carriers that ultimately could be enforced mostly through the framework of the agreement, and also to make sure nobody was left behind.”

The agreement relies heavily on the idea of delivering a “dispatchable location” to public-safety answering points. A dispatchable location is the civic address of the calling party plus additional information such as floor, suite, apartment or similar information. That location information will rely on development of a new national emergency address database (NEAD) as well as the use of a variety of technologies referred to in the agreement as “heightened location accuracy technologies.”

“It’s a term that basically means a high accuracy location technology, and it includes advanced satellite positioning, dispatchable location technologies such as Wi-Fi, Bluetooth, hybrid technologies and any other technologies that have been shown to meet or exceed accuracy requirements,” said Derek Poarch, executive director of APCO. “It is a hybrid of all the available solutions that are verifiable that means that calls will be delivered with either a dispatchable location or within a fix of 50 meters or better.”

The agreement envisions testing current and future location-finding technologies using a new test bed created and funded by the carriers. Poarch said the test bed will build on key elements of the Communications Security, Reliability and Interoperability Council (CSRIC) test bed previously used to test location technologies, and it will be an open, transparent and technology-neutral test bed under real-world conditions that any location technology vendor can use to enable public safety to assess actual performance, utility and value of a location solution.

Another key element of the agreement is the requirement for quarterly reports from carriers on live 9-1-1 call data illustrating the performance over time of various location technologies.

The proposed timeline included in the agreement calls for a pre-standards dispatchable location solution demonstration in nine months, followed by creation of a technology test bed and development work on NEAD within one year. Quarterly progress reports of wireless 9-1-1 call data would commence in 18 months, according to the agreement.

Longer-range benchmarks include the incorporation of assisted Global Navigation Satellite System (A-GNSS) technology in all new voice over Long Term Evolution (VoLTE) handsets incrementally to 100 percent within four years, incorporation of location fixes obtained using heightened location accuracy technologies deployed incrementally over six years, and the evaluation of various z-axis technology solutions as well as the use of crowd-sourced latitude/longitude information from Wi-Fi beacons.

The wireless industry expressed satisfaction with the agreement.

“For the first time, 9-1-1 is on a path that tracks closely with technology evolutions and improvements on the commercial side,” said Scott Bergmann, vice president, regulatory affairs at CTIA. “Prior to this agreement, 9-1-1 services were separate and distinct from commercial technologies. Over the last decade, 9-1-1 technologies haven't been able to keep pace with the rapid evolution of communications technologies, particularly in wireless. This plan sets 9-1-1 on a parallel path by getting in on the ground floor of Wi-Fi and Bluetooth beacon technologies that are expanding significantly throughout the country.”

In particular, the wireless stakeholders were happy about the de-emphasis of z-axis location technologies as the primary solution to the vertical location problem.

“CTIA and wireless carriers have made clear our concerns with pursuing propriety z-axis solutions using outdoor technologies to solve an indoor problem,” said Bergmann. “While not foreclosing z-axis solutions from the suite of possible solutions, this plan focuses on harnessing indoor technologies to solve an indoor problem.”

While the negotiations included a lot of give and take, the parties to the agreement all were satisfied that the important goals they went into the meetings with were achieved.

“I believe that we ultimately got what we wanted,” said Poarch. “If there had been a way that 12 months from now that dispatchable location would have been available, clearly tested and available around the country, that would have been perfect. But we recognize that wasn’t out there.

“I suspect the carrier representatives would say that we pushed them pretty hard in some areas they didn’t want to be pushed in, and certainly from a public-safety standpoint, if there had been a perfect slam dunk, we would have taken that, but that wasn’t available,” said Poarch. “I think anytime you’re involved in one of these processes, if all the parties come out wishing they hadn’t given as much as they did or could have gotten more you’ve probably gotten a pretty good agreement, and that’s where we believe we are.”

The International Association of Chiefs of Police (IACP), the International Association of Fire Chiefs (IAFC), the National Association of State Emergency Medical Services Officials (NASEMSO) and the National Sheriff’s Association (NSA) joined to file a letter with the FCC criticizing the consent agreement.

“We are aware that there have been ongoing negotiations among the wireless carriers, the Association of Public-Safety Communications Officials International (APCO), the National Emergency Number Association (NENA), and the CTIA-The Wireless Association to develop an alternative to the proposed FCC regulations for 9-1-1 location information,” said the letter. “We were not consulted on these negotiations and were not provided any details of the discussions until October 29, 2014. Our organizations are disappointed that we were not consulted earlier, because we represent the leadership of the frontline first responders who are called upon to respond to 9-1-1 emergencies every day.”

The letter cited concerns with the details of the roadmap outlined in the agreement, including that the roadmap relies on technology solutions that are untested in a real-world environment such as Wi-Fi and Bluetooth information and crowdsourcing. The letter asked the FCC to ensure carriers use technologies that have been tested by the CSRIC test bed.

The letter also pointed out concerns with the NEAD proposed in the agreement, saying details of the proposed database remain undetermined.

“We believe a better approach is for the FCC to focus on using performance-based metrics for providing dispatchable location to PSAPs,” the opposition group said. “This approach would be technology-neutral and the specific metrics would be enforced by the FCC.”

These opposing public-safety groups submitted their own proposal to the FCC, which spells out specific accuracy requirements and deadlines. The proposal is available here.

In a separate letter to the FCC, a variety of public safety and other interested parties criticized the agreement as being carried out in closed-door negotiations and producing an unacceptable solution that would “remove all mandatory accuracy requirements and their associated deadlines, sabotage the commission’s stated goal of finding all indoor callers, and delay any carrier action for years longer than the FCC’s proposed timeline.”

Notably, the letter was signed by Danita Crombach, president of the California chapter of NENA (CALNENA) as well as R. Craig Whittington, past president of NENA. Other signatories include representatives of the Alliance for Retired Americans, the Emergency Medical Services (EMS) Medical Directors Association of California (EMDAC) and eight organizations representing deaf and hard-of-hearing individuals.

NENA’s Forgety acknowledged the dissent by the association’s California chapter president but attributed much of the opposition to the work of an organization he said is serving as a front for a single location vendor that is pushing short-term location deadlines as a way to get its technology adopted.

“I think it’s questionable that they really have the best interests of public safety at heart,” said Forgety.

The Find Me 911 Coalition aggregated many of the opposition responses and reacted angrily to the agreement, calling it a “secret deal that lacks consensus.”

“This is absolutely not a consensus agreement, as it only appears to be supported by a handful of APCO and NENA execs, not their peers in the 9-1-1 and public-safety community,” said Jamie Barnett, director of the Find Me 911 Coalition and former chief of the FCC’s Public Safety and Homeland Security Bureau. “The terms of this so-called deal are a travesty for public safety and a tragedy for consumers. The carrier proposal delays implementation of robust accuracy requirements for years longer than the FCC’s proposed rule, offers no vertical accuracy standard or timeline, and abandons millions of users of existing 3G or 4G phones by focusing only on future handset design.”

The coalition was founded in 2013 with initial funding from TruePosition and has advocated for the FCC to enforce location requirements on indoor wireless 9-1-1 calls.

APCO’s Poarch declined to comment on the opposition to the agreement.

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