APCO Highlights 9-1-1 Indoor Location Accuracy Concerns Ahead of FCC Vote
Thursday, November 21, 2019 | Comments

The Association of Public-Safety Communications Officials (APCO) laid out more detail about its concerns with the FCC’s proposed rules for indoor location accuracy for 9-1-1 calls. The FCC is expected to vote on the draft order Nov. 22.

The main point of contention for APCO is that the draft rules require height above ellipsoid (HAE), a raw technical format for altitude. A 9-1-1 dispatcher would receive something similar to “101 Main Street; 76 meters, +/- 3 meters HAE” instead of “101 Main Street, 7th floor” or “101 Main Street, Apt. 702.” APCO said the latter would be more effective for 9-1-1 centers.

“The largest 9-1-1 centers in the country have said that even they don’t have the resources to turn HAE data into actionable information because it would require significant time and money to create and maintain 3D maps for the millions of buildings across the country, and then specialized software to translate the HAE readings onto the maps,” said a blog written by Jeff Cohen, APCO chief counsel and director of government relations.

The National Emergency Number Association (NENA) said in its comments that floor level location can’t be done reliably.

“The problem for 9-1-1 is that nobody has a dataset of all the various layouts in existing office buildings,” NENA said on its website. “We don’t have a database of all the multistory lobbies or split-level office units nor a database that accounts for buildings that are built into an incline and have two distinct ‘ground floors’ (FCC staff know all about this). To require wireless carriers to provide this information would either be viewed as impossible or would result in a hasty mathematical solution — just divide the height above ground level of the call by 4.3 meters (the average height of a floor).”

APCO noted that Google urged the FCC to modify the proposed rules to allow the provision of a floor label rather than mandate sole reliance on measurements of HAE.

“There are several ways carriers could deliver a floor level to 9-1-1,” Cohen said. “They could partner with a company like Google, or they could leverage their own in-home products (like Internet access, 5G products) and a host of other viable methods.”

In its comments to the FCC, NENA requested 3D location, delivered in a standards-compliant, X/Y/Z format. The 3D maps could come from players in the geographic information system (GIS) world or from commercial mapping giants such as Google or Microsoft.

“The X/Y/Z format is critically important for us because we envision a future in which 9-1-1 has 3D maps of every multistory building in its jurisdiction,” said NENA.

APCO disagreed, saying even the largest 9-1-1 centers in the country have said they don’t have the resources to create 3D maps of every building and specialized software to visualize the caller’s location.

“9-1-1 centers shouldn’t have to shoulder this responsibility when the FCC’s rules are all about imposing requirements on the carriers, and there are more efficient options,” APCO said.

The APCO blog also noted that many handsets will not provide vertical location information, and major handset manufacturers might refuse to support the specialized location technologies that are necessary to meet the FCC’s accuracy requirements.

APCO said the FCC is being lobbied by vendors of the HAE solutions, which will benefit financially. APCO also said the rules focus too little on 9-1-1 call location and too much on providing a responder tracking solution, which is better handled by the First Responder Network Authority (FirstNet).

“The wireless carriers have been suspiciously quiet (except for a subtle refrain that complying with the FCC’s rules might not be possible),” said Cohen in the blog. “Why? Because they are being let off the hook. Maybe they will hire the specialized vendors and pursue other options for improving 9-1-1 location accuracy, but I bet they won’t. My guess is they’re biding their time and hoping that Google and Apple will solve the problem for them.”

Earlier this week, the FCC released a statement outlining the various groups that support FCC Chairman Ajit Pai’s draft order for indoor 9-1-1 call location rules. APCO was missing from the list, but NENA and other public-safety groups were highlighted.

APCO also filed an ex parte filing outlining its concerns.

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