FCC Adopts Indoor 9-1-1 Location Accuracy Rules (1/29/15)
Thursday, January 29, 2015 | Comments

By Kristen Beckman
The FCC voted unanimously to adopt new location accuracy rules aimed at improving wireless 9-1-1 location accuracy for indoor environments.

“We have a 5 – 0 vote today to make sure that as technology changes, that the expectations that technology is going to be available for public safety continues to keep pace,” said FCC Chairman Tom Wheeler, who initiated a notice of proposed rulemaking (NPRM) in February 2014 that kicked off the indoor location-accuracy debate. “This road map is a plan for carriers, for vendors, for public-safety officials to follow to deliver on that kind of an expectation. The other thing that it does is that it establishes measurement tests. It’s not enough to say we’re going down the road. Let’s know what the mile marker is, and let’s make sure that we’re hitting the mile markers.”

The order incorporates many of the proposals outlined in the roadmap plan submitted to the FCC in November by the four nationwide wireless carriers along with the Association of Public-Safety Communications Officials (APCO) International and the National Emergency Number Association (NENA). A revised plan was submitted last week.

The order focuses on two approaches for locating wireless callers indoors. The first approach relies on using X and Y coordinates at a specific confidence level to find wireless 9-1-1 callers. A vertical, or Z-axis component, is also included. The second approach uses a dispatchable location to pinpoint caller locations using the street address of the building as well as the caller’s floor level, apartment, office number and any other information that can help identify the caller’s location in the building.

The order requires all wireless carriers to provide either a dispatchable location or X and Y coordinates within 50 meters of the caller. Carriers must meet these standards for 40 percent of all wireless 9-1-1 calls within two years, 50 percent within three years and 70 percent within five years. Within six years, carriers must deliver dispatchable location or X and Y coordinates within 50 meters of the caller for 80 percent of all wireless 9-1-1 calls.

The benchmarks apply to all wireless carriers, but non-nationwide carriers will be allowed an extension of the five- and six-year deadlines based on the level of deployment of voice over Long Term Evolution (VoLTE) within their networks.

The order further requires carriers to validate dispatchable and coordinates-based location technologies in an independently administered test bed. Beginning at the 18-month mark, nationwide carriers must collect and report live 9-1-1 call data on a quarterly basis from six representative test cities.

For vertical location, the order provides that within three years, all carriers must make uncompensated barometric pressure data available to 9-1-1 call centers from any handset that has the capability to deliver such data. Carriers must also use an independently administered test bed process to develop a reasonable accuracy threshold that will be submitted for commission approval. Within six years, nationwide carriers must deploy either dispatchable location or a vertical location solution that complies with the metric ultimately adopted by the commission in the 25 most populous cellular market areas. Within eight years, nationwide carriers must have deployed their chosen vertical location technology in the 50 most populous cellular market areas. Non-nationwide carriers will have an additional year to comply with the benchmark.

Dispatchable location will require that a national emergency address database be constructed and maintained, which the nationwide carriers committed to doing in their roadmap plan submitted to the commission in November. Carriers must submit a comprehensive privacy and security plan for the database to the commission for review and approval within 18 months.

Carriers also will be required within 18 months to report their plans for implementing improved indoor location accuracy, including how they plan to comply with the three- and six-year benchmarks. Non-nationwide carriers will have an additional six months to submit their plans.

At three years, all carriers must report their progress toward implementation with an emphasis on the status of any planned dispatchable location solutions.

The order also requires carriers to record and provide aggregate 9-1-1 call data to requesting public safety answering points (PSAPs) to allow them to determine if carrier performance in their jurisdiction is consistent with performance reported in the six test cities. If call data indicates performance is below the required threshold, the PSAP may seek enforcement of the rules. However, PSAPs and carriers must first attempt to resolve the issue themselves before an action will be taken.

Commissioner Ajit Pai said it became clear to him that the original rules proposed a year ago in a notice of proposed rulemaking (NPRM) would not be achievable.

“My goal, as I said back then, was to adopt rules that are both aggressive and achievable,” Pai said. “At the time, I expressed concern that the NPRM’s proposals would fail to meet that test, and that concern was borne out by the record in this proceeding, which shows that our original proposals were impractical and unrealistic.

“I'm pleased that we have adjusted course and are now adopting requirements that are aggressive and achievable. I’m also glad that the framework we’re putting in place puts us on a path to providing emergency responders with what is known as a dispatchable location. Public-safety organizations have described this as the gold standard for indoor location accuracy because it tells first responders exactly which door they need to knock on, or in some cases, kick in during an emergency.”

Commissioner Mignon Clyburn also acknowledged that the original proposed rules contained stronger requirements but applauded wireless carrier and public-safety efforts to develop a plan for improving 9-1-1 caller location accuracy.

Commissioner Michael O’Rielly also supported the order but expressed privacy concerns. “I renew my concern that the implementation of this item could be used by government agencies to pinpoint the location of law-abiding Americans,” said O’Rielly. “This is not a direct responsibility of the commission, and I trust that appropriate oversight including congressional involvement will seek to ensure that this information is not used or abused to the detriment of the American people. Improving location accuracy for wireless 9-1-1 callers should not happen at the expense of greater exposure to surveillance and monitoring by government officials.”

NENA issued a statement applauding the FCC for adopting the rules. “Under the new rules, wireless carriers will be required, for the first time, to use the latest technology to identify the location of consumers who call 9-1-1, even when calls are placed indoors,” said the statement. “With its emphasis on identifying a caller’s physical address, the new FCC policy will enable public-safety professionals to serve the public with greater speed, accuracy and efficiency than ever before.”

Joe Hanna, an industry consultant and former APCO president, supported the FCC’s order.

“Last year, I noted in an editorial “point/counterpoint” discussion that the FCC needed to focus on good sound policy rather than policy that sounds good. The commission has done an excellent job of meeting that challenge and has separated substance from rhetoric,” said Hanna. “The American public and the dedicated professionals who staff our 9-1-1 centers are the clear winners in today’s rulemaking.”

The Find Me 911 Coalition, which has led a strong opposition to the carrier roadmap plan, released a statement criticizing the new rules following adoption of the order.

“Unfortunately for millions of indoor 9-1-1 callers in need, the FCC has adopted the weak carrier roadmap over its own strong proposal. The Find Me 911 Coalition has been the strongest supporter of the commission's efforts to find wireless 9-1-1 callers indoors, but we have deep concerns that the final rule contains a catastrophic flaw, as it does not require the cell phone companies to measure or report indoor call accuracy,” said the Find Me 911 statement. “While the rule claims to improve indoor accuracy, there appear to be no indoor-specific requirements in it, only a ‘blended’ indoor-outdoor standard that allows the carriers to take credit for their outdoor location performance. Thus, the phone companies can meet all of their obligations for years or longer without implementing any new technologies or finding any more indoor callers.

“We know this entire issue is a problem of the carriers’ own making, yet this rule — drafted by the carriers themselves — depends on more hollow promises to solve it. Given the two-year requirements to find 40 percent of all callers, cell phone carriers are now admitting they cannot find at least 60 percent of all wireless 9-1-1 callers today, yet this rule rests on even more promises around a complicated new and untested system,” the statement said. “While we have not yet seen the text of the rule, we believe the rule as described is a triumph of carrier rhetoric over substantive accuracy requirements.”

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