APCO Voices 9-1-1 Location, 6 GHz Concerns; FWCC Disputes 6 GHz Unlicensed Technical Analyses
Monday, August 05, 2019 | Comments

In an ex parte filing with the FCC, the Association of Public-Safety Communications Officials (APCO) International voiced concerns with proposed rules around wireless 9-1-1 location accuracy, the 6 GHz band and the wireless resiliency cooperative framework.

APCO said it is concerned that 9-1-1 location information will not be useful for 9-1-1 professionals or the public, and carriers will not produce meaningful improvements. The association said dispatchable location is the gold standard for 9-1-1, and to provide a dispatchable location, the carriers leverage several tools including the National Emergency Address Database (NEAD), location information from commercial location-based service and technology providers, carriers’ in-home services, GPS, handset sensors, enterprise Wi-Fi-based location systems, location-purposed Bluetooth devices and known subscriber information such as home address.

“APCO is especially concerned that the carriers have remained mainly silent about implementing dispatchable location solutions that could be achieved without the NEAD at all, through their own Wi-Fi and other home and business products, or with emerging 5G offerings,” the filing said.

While the commission’s rules set requirements for the NEAD, a dispatchable location can be provided without using the NEAD at all, APCO said. “Yet, the carriers appear overly focused on the NEAD for deriving a dispatchable location, have described implementation challenges such as reference point provisioning and handset support, and have not provided information about other methods they should be exploring,” APCO said.

APCO is concerned that carriers might abandon dispatchable location solutions altogether in lieu of a Z-axis approach “that would leave public safety worse off than the original 2014 proposal.” APCO said the commission should forego adoption of a Z-axis metric and require carriers to rely on dispatchable location solutions.

At a minimum, the Z-axis metric should include a requirement for delivering a floor-level estimate with the Z-axis information. “Ultimately, wireless carriers should not be able to comply with the fourth report and order by abandoning dispatchable location altogether and providing, for example, location information that is only an estimate in meters above sea level, or information that emergency communications centers (ECCs) have no means to make actionable,” the filing said.

The National Emergency Number Association (NENA) disagrees and said in recent comments that dispatchable location is not the most accurate, useful or efficient means to locate an individual. “Geodetic location information provides the best information for 9-1-1 to locate a caller,” NENA said in May. “The location of a caller must be delivered to the 9-1-1 system as a standards-based, interoperable LO, carried over IP and expressed as a geodetic LO, which includes the FCC’s proposed z-axis measurement.”

APCO also voiced concerns with the FCC’s proposal to introduce significant unlicensed operations into the 6 GHz band, which is heavily used by public-safety agencies for mission-critical communications. “Identifying sources of interference could require substantial effort, and a single instance of interference could result in fifteen minutes or more for restoration,” APCO said. “This would be unacceptable for mission-critical uses such as public-safety dispatch or first responder voice communications.”

APCO said it is unconvinced that the technical showings put forth by advocates of unlicensed sharing of the band are taking into account the real-world implications of the deployment of hundreds of millions of devices or the specific nature of public-safety microwave systems that are designed for very high reliability.

To that end, the Fixed Wireless Communications Coalition (FWCC) said analysis detailed in July 2 and July 5 filings claim to show that outdoor radio LAN (RLAN) devices at 14 dBm, and indoor devices at 30 dBm, can operate free of automatic frequency control (AFC) without causing interference to fixed service (FS) receivers. “In fact, as we have shown in prior filings and reiterate here, uncontrolled RLANs at any useful power will cause harmful interference to the FS,” the FWCC said in an ex parte filing.

“Both the July 2 and July 5 RLAN filings contain disturbing factual errors and contrary-to-fact assumptions that, in combination, greatly understate the risk of interference from uncontrolled RLANs — and yet, even then, still predict wholly unacceptable levels of interference.”

The FWCC filing outlines the mathematical and technical flaws here.

“Even if the commission is able to develop strong protections and an automated frequency coordination (AFC) system is proven effective for protecting incumbent users, APCO is further concerned that consumers or manufacturers could defeat the technical limitations or AFC controls,” APCO said. “With hundreds of millions of unlicensed devices in the stream of commerce, when interference occurs, it will be impossible to identify and eliminate the source. … At a minimum, the commission should delay action on the 6 GHz band, pending further research into the risk of interference and the effectiveness and enforceability of its technical rules and AFC requirements.”

Finally, in regard to the wireless resiliency cooperative framework, APCO said carriers have not established a contact database for carriers and ECCs for use during outages. “The commission should set a deadline for the carriers and make clear that it is their responsibility to promptly establish, maintain and make available to ECCs a secure database to ensure that ECCs know who to contact in the event of an outage and for carriers to promptly notify ECCs of known and suspected outages,” the APCO filing said.

The APCO filing is here.

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