Organizations Ask FCC to Deny CTIA Petition for Reconsideration of 9-1-1 Location Rules
Wednesday, November 11, 2020 | Comments

A group of seven public-safety organizations filed a joint response in opposition to CTIA’s request for reconsideration of the FCC’s sixth report and order (R&O) on E9-1-1 location accuracy requirements.

CTIA’s petition asked the FCC to reconsider rules and timelines created by the 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.”

That petition took issue with the R&O’s Z-axis benchmark saying that it was based on barometric sensor pressure solutions that had not been directly integrated into handsets.

“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,” the petition said.

At the same time as CTIA’s petition, APCO also filed a petition for reconsideration with the FCC that asked the commission to reconsider the way that dispatchable location requirements were revised to account for the end of the National Emergency Address Database (NEAD).

The filing from the public-safety organizations opposed CTIA’s request for reconsideration and offered support for APCO’s petition for reconsideration.

“CTIA claims that the carriers will not be able to meet the upcoming deadline because the vendors have not integrated their solutions into devices,” the filing said. “This wrongly attempts to absolve the carriers of their ability and responsibility to influence the capabilities of devices operating on the carriers’ own networks. The commission has already decided that carriers are ‘capable of negotiating requirements with handset manufacturers and operating system providers and establishing contractual timelines that will enable timely deployment of Z-axis solutions in time to meet the deadline in the rules.

“If the carriers were acting in good faith to achieve the benchmark but encountering difficulty in their negotiations with handset and OS providers, perhaps they’d be seeking assistance from the commission to resolve the impasse,” the filing said. “Instead, the carriers ask the commission to move the goal posts on public safety.”

The public-safety organizations also argued that CTIA’s petition asked the FCC to contradict its own rules.

“In suggesting that only devices with barometric pressure sensors could be considered Z-axis capable, CTIA is impermissibly seeking reconsideration of the commission’s decision that Z-axis capable devices include all handsets that have the capability to measure and report vertical location information without a hardware upgrade, regardless of technology, handset age, or having a barometric sensor,” the filing said. “If carriers are not achieving the Z-axis metric for all types of Z-axis capable devices in use on their networks, they would not be compliant with the commission’s rules.”

The organizations argued that public-safety personnel should not have to wait longer to receive improve location information.

“When the April 2021 benchmark arrives, public-safety professionals should immediately see benefits and be able to verify carriers’ compliance by placing test 9-1-1 calls from devices that are capable of reporting vertical location without a hardware upgrade (Z-axis capable handsets) and seeing that at least 80% of the calls are delivered with 3-meter vertical accuracy or better.”

In support of APCO’s petition for reconsideration, the organizations argued that the R&O’s revision of the NEAD-based benchmark would create confusion.

“It arguably permits carriers to demonstrate compliance with a raw number of reference points leveraged by a solution regardless of whether the solution can accurately estimate a dispatchable location, or more importantly, whether a carrier delivers dispatchable location information with 9-1-1 calls,” the filing said.

The organizations argued that the revised benchmark could potentially give carriers a way to comply with the requirements without providing improved location information with 9-1-1 calls.

“The commission can solve this problem by establishing a minimum percentage of 9-1-1 calls that must be delivered with dispatchable location information rather than basing compliance on the number of reference points in a database,” the filing said. “As the commission recognized, dispatchable location is being provided for some calls already and solutions are likely to become increasingly available. The benchmarks could start with conservative percentages based on reasonable estimates in the record of what’s feasible.”

The organizations who jointly filed the response were APCO, the International Association of Chiefs of Police (IACP), the Major Cities Chiefs Association (MCCA), the Major County Sheriffs of America (MCSA), National Association of State EMS Officials (NASEMSO), the National Public-Safety Telecommunications Council (NPSTC) and the National Sheriffs’ Association (NSA). Find the full filing here.

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