APCO, CTIA Petitions Ask FCC to Reconsider 9-1-1 Location Accuracy Rules
Tuesday, October 20, 2020 | Comments

The FCC announced the deadlines for oppositions and replies to petitions for reconsideration of the commission’s sixth report and order on wireless E9-1-1 location accuracy requirements filed by the Association of Public-Safety Communications Officials (APCO) and CTIA.

Oppositions to the petitions are due Nov. 3 and replies to those oppositions are due Nov. 13.

In its petition for reconsideration of the order, APCO requested that the FCC reconsider the way in which the dispatchable location requirements were revised to take into account the end of the National Emergency Address Database (NEAD).

“The new rules lacks basis in the record, fails to chart a course for achieving real progress with the delivery of dispatchable location and risks creating a way for carriers to comply with the location accuracy requirements without actually providing improved location information with 9-1-1 calls,” the petition said.

APCO argued that prior to the sixth report and order, carriers that chose to comply with the vertical accuracy requirements by deploying dispatchable location solutions would have had to ensure the NEAD was populated with a number of reference points equal to at least 25% of the census metropolitan area (CMA) population.

“Because the carriers abandoned the NEAD, this benchmark is no longer appropriate,” the filing said. “The commission amended the rules to delete the reference to the NEAD but retained the metric for measuring a carrier’s deployment of dispatchable location reference points.”

APCO argued against the FCC’s decision to convert the NEAD benchmark to “any database.”

“The commission should not allow carriers to comply with the dispatchable location option by counting reference points in ‘any database,’ “ said APCO’s filing. “This approach presumes that carriers would provide dispatchable location only by using the NEAD-based approach, and it creates confusion over whether reference points in crowdsourced databases such as those maintained by Apple and Google, which have not been demonstrated as capable of providing dispatchable locations, could be used to satisfy the requirements.”

Meanwhile, CTIA’s petition asked the FCC to reconsider the rules and timelines created in the sixth report and order due to conditions caused by the COVID-19 pandemic.

“The sixth R&O acknowledged that the COVID-19 pandemic could impact the testing and deployment of 9-1-1 location accuracy solutions, but no one anticipated today’s challenges,” CTIA’s petition said. “These changed circumstances have derailed the prospects for achieving the sixth R&O’s timelines. Recently adopted and evolving government restrictions and building access limitations have delayed testing necessary to determine whether any technology can be validated for compliance with the sixth R&O’s requirements.”

The CTIA petition also took issue with the Z-axis benchmarks that the sixth report and order put into effect.

“Further, the sixth R&O’s Z-axis benchmarks are in effect a technology mandate for network-dependent, barometric-sensor-based solutions premised on claims made by two vendors,” the filing said. “With only seven months to go, these vendors have not integrated their solutions directly into the handsets used by most wireless 9-1-1 callers, as the commission encouraged. In the absence of integration with a handset, the sixth R&O shifted responsibility onto consumers to opt into 9-1-1 vertical location solutions through over-the-top (OTT) applications, an unprecedented change of 9-1-1 policy that forces consumers to take action to receive the benefits of 9-1-1.”

Find APCO’s petition for reconsideration here and CTIA’s petition for reconsideration here.

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