After a year of non-stop lobbying, political rhetoric and committee work by public safety organization, today the Federal Communications Commission (FCC) approved regulations that will increase the reported accuracy of 911 calls, particularly for calls made from indoors and above the ground. FCC said they gave “considerable weight” to the consensus agreement reached between the wireless carriers and APCO/NENA to “establish clear and measureable timelines for wireless providers to meet indoor location accuracy benchmarks, both for horizontal and vertical location information.” Acknowledging the technical hurdles of improved locations, the FCC said their requirements allow enable wireless providers to choose “the most effective solutions and allow sufficient time for development of applicable standards, establishment of testing mechanisms, and deployment of new location technology.” The Order takes into account an agreement reached last year between the four largest wireless carriers and two biggest public safety groups, and a later amendment, But it doesn’t meet the standards of the Find Me 911 coalition that was lobbying for even tighter accuracy rules. In a statement, FCC chair Tom Wheeler says the coalitions accuracy concerns were addressed and reassured, “We will have better data than ever before about carriers’ location accuracy performance, and we will hold them to account if they do not live up to their commitments.” Wheeler added, “Let there be no mistake—we are establishing a floor, not a ceiling. It is a beginning, not an end.” Update: On Feb. 4th the FCC posted the official Report & Order (pdf) outlining all of the new location regulations, which includes a timeline of how the new requirements were developed.
The Location Specifics
Under the new horizontal location rules, all carriers must provide a “dispatchable” location within 50 meters for the following percentages of wireless 911 calls, and within the following timeframes:
- within 2 years: 40 percent of all wireless 911 calls
- within 3 years: 50 percent of all wireless 911 calls
- within 5 years: 70 percent of all wireless 911 calls
- within 6 years: 80 percent of all wireless 911 calls
Under the new vertical location rules, all CMRS providers must also meet the following requirements
- within 3 years: all carriers must make uncompensated barometric data available to PSAPs from any handset that has the capability to deliver barometric sensor data
- within 3 years: nationwide carriers must use an independently administered and transparent test bed process to develop a proposed z-axis accuracy metric, and must submit the proposed metric to the Commission for approval
- within 6 years: nationwide CMRS provides must deploy either (1) dispatchable location, or (2) z-axis technology that achieves the Commission-approved z-axis metric, in each of the top 25 Cellular Market Areas (CMAs)6:
- where dispatchable location is used: the National Emergency Address Database (NEAD) must be populated with a total number of dispatchable location reference points in the CMA equal to 25 percent of the CMA population.
- where z-axis technology is used: CMRS providers must deploy z-axis technology to cover 80 percent of the CMA population.
- within 8 years: nationwide CMRS providers must deploy dispatchable location or z-axis technology in accordance with the above benchmarks in each of the top 50 CMAs.
The FCC also set a 30-second time limit on generating a location fix for Phase II calls, but not for indoor call requirements, and a 90 percent “confidence” level for indoor-outdoor calls.
Commissioner Statements
In a statement on the Order, FCC commissioner Mignon Clyburn said he would have preferred to adopt the rules the FCC proposed in 2013 that had stronger accuracy requirements at the two and three-year benchmarks. Yet, he concurred with the rules that will eventually lead to a vertical location proposal from the carriers. Download (pdf) all of the FCC commissioner statements on the new rules.
The Find Me 911 Coalition, which has consistently opposed the carrier agreement, angrily called the FCC’s new accuracy rules “weak,” and dependent upon “hollow promises” by carriers. Here’s the coalition’s full statement:
“Unfortunately for millions of indoor 911 callers in need, the FCC has adopted the weak carrier roadmap over its own strong proposal. The Find Me 911 Coalition has been the strongest supporter of the Commission’s efforts to find wireless 911 callers indoors, but we have deep concerns that the final rule contains a catastrophic flaw, as it does not require the cell phone companies to measure or report indoor call accuracy.””While the rule claims to improve indoor accuracy, there appear to be no indoor-specific requirements in it, only a ‘blended’ indoor-outdoor standard that allows the carriers to take credit for their outdoor location performance. Thus, the phone companies can meet all of their obligations for years or longer without implementing any new technologies or finding any more indoor callers.””We know this entire issue is a problem of the carriers’ own making, yet this rule – drafted by the carriers themselves – depends on more hollow promises to solve it. Given the two-year requirements to find 40% of all callers, cell phone carriers are now admitting they cannot find at least 60% of all wireless 911 callers today, yet this rule rests on even more promises around a complicated new and untested system.””While we have not yet seen the text of the rule, we believe the rule as described is a triumph of carrier rhetoric over substantive accuracy requirements.”
The Association of Public Safety Communications Officials (APCO) issued a statement that outlined the work that has led to the new regulations:
Over the course of the past several months, APCO has kept our members well informed on our progress. We outlined our goal of working on a consensus approach to secure meaningful, universal, verifiable, and enforceable improvements. We announced the details of the Roadmap negotiated with the four largest carriers and the National Emergency Number Association (NENA) in response to the FCC’s invitation for alternative approaches. And in the face of relentless disinformation campaigns, we set the record straight and remained steadfast in pushing for the best solution for PSAPs and the citizens of our country.In our most recent membership communication, we highlighted the message of our public comments to the FCC that the Roadmap represents a qualitative improvement in indoor location by targeting the gold standard, a “dispatchable location” – meaning the civic address plus the floor, suite, apartment number, or other information needed to find the caller. In addition to championing a dispatchable location, APCO was adamant that any solution be technology-neutral and break public safety out of the cycle of reliance on imperfect, single-source or proprietary solutions to solve 9-1-1 problems.Leading up to today’s FCC action, APCO reached out extensively to numerous stakeholders in the public safety community, who indicated substantial support for a dispatchable location solution. At the same time, some understandably sought further assurances that a dispatchable location solution will be achieved. Thus, we asked the carriers to commit to additional measures that would strengthen the Roadmap, and the carriers agreed to build in even greater assurances related to both dispatchable location and z-axis solutions. Specifically, the carriers pledged to deploy, in the 50 most populous Cellular Market Areas (CMAs) representing the most indoor use cases, a significant number of dispatchable location reference points (i.e. Wi-Fi access points or Bluetooth LE beacons), or a z-axis solution that provides coverage to at least 80% of the population of the CMA.
Recognizing APCO’s expertise and leadership in public safety, numerous voices joined ours in support of the Roadmap’s approach to achieving a dispatchable location and moving public safety away from single-source proprietary solutions. The Order adopted today largely incorporates the Roadmap’s provisions. This success is a product of our advocacy with other stakeholders and FCC decision-makers.
“APCO is proud to have worked with the FCC, wireless carriers, and other stakeholders to set a path that embraces new technologies and – most importantly – provides meaningful location information to our nation’s public safety communications professionals and first responders as they protect the life and property of our citizens,” said APCO President John Wright. “Throughout our efforts, including in the face of pressure from vendors with a significant financial interest in proprietary proposals, APCO held true to its principles.”
President Wright continued, “I want to thank the FCC Commissioners, their staff, and the Public Safety and Homeland Security Bureau for taking a collaborative approach to solving this important public safety problem. I also want to thank APCO’s members for your support. The success of this effort is in no small part a credit to our professionalism, expertise, and reputation as public safety communications experts. Hard work lies ahead. APCO remains committed to ensuring that when someone calls 9-1-1 we can get them help immediately.”
While the text of the FCC’s order will be forthcoming, it will include the following critical features:
- Performance benchmarks and deployment commitments for implementing dispatchable location solutions, z-axis solutions, and other location accuracy improvements.
- Standards development for dispatchable location and z-axis solutions.
- Creation of an open, transparent test bed for testing location technologies.
- Development of the National Emergency Address Database, which will support dispatchable location solutions.
- Availability of live 9-1-1 call data to enable tracking of the performance of indoor location technologies.
The Electronic Frontier Foundation issued a statement ahead of the FCC’s action, expressing concern about how the rules might affect citizen privacy, especially in light of a carrier proposal to create a national emergency address database.
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