Carriers Submit Modified 9-1-1 Location Plan (1/22/15)
Thursday, January 22, 2015 | Comments

By Kristen Beckman
The nation’s four largest wireless carriers submitted a revised 9-1-1 location accuracy roadmap to the FCC this week, following two months of heated debate among carriers and public-safety stakeholders about the best way to proceed with rules designed to help public-safety answering points (PSAPs) locate 9-1-1 callers.

The FCC is expected to make a decision about 9-1-1 location rules at a meeting Jan. 29.

The four carriers, along with the National Emergency Number Association (NENA) and the Association of Public-Safety Communications Officials (APCO) International, submitted a consensus plan addressing 9-1-1 location Nov. 14. The agreement drew strong criticism from many public-safety groups that claimed not only that the roadmap plan was weak and unenforceable, but also that the agreement meetings were held in secret and excluded important stakeholders.

Among the many issues public-safety groups pointed to in the consensus agreement were a lack of hard deadlines, a weakening of specific location accuracy benchmarks, lack of neutral oversight of a proposed location testbed, the exclusion of tools to locate non-voice over Long Term Evolution (VoLTE) devices, and the de-emphasis of z-axis location-finding technology. In addition, Public Knowledge and 16 other organizations sent a letter to the FCC commissioners urging them to consider and resolve privacy concerns.

Earlier this month, FCC Chairman Tom Wheeler wrote a blog post suggesting that the commission would not accept the agreement as submitted but would add its own changes and deadlines.

With the likelihood that the agreement would not be adopted as submitted, the carriers submitted a modified roadmap that they say includes quantifiable indoor-specific metrics to include indoor and vertical location fixes; expands the roadmap’s performance metrics to apply to all 9-1-1 calls, not just VoLTE calls; and commits to developing a national emergency address database privacy and security plan that will be transmitted to the FCC.

“Importantly, the new metrics will achieve meaningful and quantifiable improvements for indoor wireless 9-1-1 location fixes that build on the roadmap with achievable and verifiable performance metrics superior to those in the draft order on circulation,” the carriers said in their comments to the FCC. “For this reason, we offer the amended roadmap metrics to replace, not supplement, those in the draft order.”

The original roadmap contained five sections. Section 1 outlined the creation and operation of a neutral test bed to evaluate 9-1-1 location technologies under real-world conditions. Section 2 proposed the development of dispatchable locations defined as the civic address of the calling party plus other specific location information, and called for development of a national emergency address database. It also provided benchmarks and timeframes for deploying dispatchable addresses. Section 3 addressed testing and deployment of latitude/longitude technologies such as observed time difference of arrival (OTDOA) and assisted GPS and GLONASS (A-GNSS) for outdoor and indoor accuracy on VoLTE platforms. Section 4 called for carriers to collect and provide live 9-1-1 caller data to public safety. Section 5 addressed z-axis location-finding techniques.

The revised roadmap adds a sixth section with the following provisions:

• Carriers agree to determine within 36 months if dispatchable solutions are on track and consistent with timeframes outlined in the original agreement.

• If dispatchable location solutions are on track, carriers agree to implement a dispatchable location or z-axis location solution that has been tested in the proposed test bed in the 50 most populous cellular market areas (CMAs) and includes benchmarks for determining when a CMA can be deemed to be deployed.

• If dispatchable location solutions are not on track, the dispatchable location provisions will be supplanted with an alternative solution, although carriers would still be allowed to continue to implement dispatchable location solutions and use them to demonstrate compliance with location commitments. The carriers also commit to further z-axis benchmarks if dispatchable location solutions are not on track.

• Any z-axis solution implemented must be technically feasible; fit within network plans and architectures; be standardized, scalable and commercially available from multiple sources; and may require consumers to purchase equipment, possibly including new handsets, or modify service plans.

The modified plan is available here.

While APCO and NENA did not join the four carriers in submitting the revised roadmap, both groups filed comments in support of it. APCO said following the release of the roadmap it reached out to a variety of stakeholders and found support for some of the roadmap provisions but also noted concerns.

“Thus, in recent weeks we asked the carriers to commit to additional measures that would strengthen the roadmap’s objective of a dispatchable location,” APCO said in its ex parte filing. “As a result, we are pleased to report that the carriers have agreed to build in even greater assurances related to both dispatchable location and a z-axis solution. Recently, the carriers presented these assurances to the Public Safety (and Homeland Security) Bureau. Specifically, the carriers are pledging to deploy, in the 50 most populous CMAs, a significant number of dispatchable location reference points (i.e. Wi-Fi access points or Bluetooth LE beacons), or a z-axis solution that provides coverage to at least 80 percent of the population of the CMA.”

NENA’s letter in support of the revised roadmap was largely the same as APCO’s.

“NENA is pleased that the carriers have agreed to these additional commitments, and believes that the commitments represent a material improvement over the initial terms of the roadmap,” NENA said in its ex parte filing. “At the same time, we recognize that the commission is bound to consider the entirety of the record as it formulates its final rules. Likewise, NENA is cognizant of the concerns expressed by our colleagues from other public-safety associations who call on the commission to include additional assurances and metrics for evaluating carrier compliance with the terms of the roadmap and with the ultimate goal of locating callers in need.”

In an ex parte response, Jamie Barnett, representing location vendor TruePosition, highlighted the fact that APCO and NENA did not sign the modified roadmap as a sign of division among the carriers and public safety. Barnett also said the modified agreement has not been vetted and endorsed by critical stakeholders including first responders and public-safety officials.

Barnett criticized the modified agreement for further diluting measurable standards for indoor location accuracy rather than addressing criticisms about the vagueness and unenforceability of the original agreement. In addition, Barnett said that in backing away from the emphasis on VoLTE technology and blending indoor and outdoor metrics, the modified agreement still leaves a larger percentage of callers uncovered compared with the FCC’s original proposal.

The 9-1-1 location accuracy discussion has prompted thousands of comments to the FCC, many coordinated by groups on either side of the debate. The FCC released a staff entry detailing some of the coordinated comments since the release of the location accuracy proposed rulemaking on Feb. 21, 2014.

The commission said it received about 9,297 e-mails from July to October 2014 identical or substantially identical to a comment generally urging the commission not to delay implementation of 9-1-1 location accuracy requirements.

Since the announcement of the roadmap plan in November, the FCC reports it received 35 e-mails identical or substantially identical to a comment urging the FCC to adopt rules as proposed to require accurate 9-1-1 location from all wireless phones within two years. The commission received 379 e-mails identical to a comment urging the FCC to oppose the carrier-backed proposal on wireless 9-1-1 location. Two identical emails came in Nov. 27 urging the commission to accept the carrier-backed proposal.

Finally, the commission said this month it has received more than 1,000 identical or substantially identical e-mails with a comment urging it to oppose carriers’ attempts to “delay real and enforceable requirements for accurate 9-1-1 locations” under the subject line “Don’t Compromise on Public Safety.”

The Find Me 911 Coalition, which has vocally opposed the carrier roadmap plan, is organizing a coordinated social media campaign for Jan. 29 that urges people to tweet or share on Facebook and Tumblr a message urging the FCC to adopt “specific and enforceable” 9-1-1 location requirements. The group created a Web page to coordinate the effort.

Comments on 9-1-1 location accuracy are filed at the FCC under proceeding number 07-114.

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