Notice on Petition for Reconsideration of E9-1-1 Location Accuracy Rules
Tuesday, March 03, 2020 | Comments

Opposition to a petition for reconsideration on the FCC’s fifth report and order regarding wireless E9-1-1 location accuracy requirements filed by the Boulder Emergency Telephone Service Authority (BRETSA) are due 15 days after publication in the Federal Register. Replies to oppositions are due 25 days after publication.

In December, BRETSA filed a petition for reconsideration to the rules on several points. BRETSA said that it was arbitrary and capricious, and an abuse of discretion, for the FCC to have declined to adopt proof-of-performance testing at limited locations in the 50 markets in which carriers will be required to provide Z-axis location data, on the grounds that it would be impractical and burdensome.

“The carriers themselves have stated that additional testing is required, including in additional morphologies and in a production environment, and cited difficulties in securing test buildings in the test-bed cities,” the petition said. “It is inappropriate for the commission to reject a new proposal as inconsistent with a prior commission decision, when the accuracy of the assumptions underlying the prior decision have been drawn into question by the very parties implementing that decision.”

BRETSA stated that the FCC should require wireless providers to conduct proof-of-performance testing to benchmark the accuracy that can be expected in each market.

BRETSA also said the FCC failed to address its proposed requirement that wireless carriers cooperate with public-safety stakeholder accuracy testing and correlation of test results to floor numbers. “Correlation of elevation information to building floor levels is necessary for Z-axis information to be actionable,” the petition said.

The December petition is here.

The public notice on oppositions and replies to oppositions is here.

In February, the Association of Public-Safety Communications Officials (APCO) International submitted a petition for clarification in response to the FCC’s fifth report and order on wireless E9-1-1 location accuracy requirements.

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