December 17, 2014.  A 911 location accuracy plan hammed out by the four national wireless carriers, the National Emergency Number Association, and the Association of Public-Safety Communications Officials-International has drawn criticism from a wide range of entities, including public safety, public interest, deaf and hard of hearing, senior citizen, and state regulator groups, as well as technology vendors and other current and retired public safety officials.

However, the plan, unveiled last month (TRDaily, Nov. 14), has attracted support – or at least generally positive comments – from groups representing smaller wireless carriers; wireless equipment, technology, and integrator entities; groups representing state legislators and local telecommunications officials; some public safety professionals; and advocates for the disabled.

The comments were filed by yesterday’s deadline in PS docket 07-114 in response to a public notice seeking comment on the location accuracy plan (TRDaily, Nov. 20).

Under the plan, the focus would be on providing a dispatchable location, although that would take years at best to accomplish – and would not have to be accomplished at all. The plan also lacks specific metrics for vertical deployment and overall vague indoor milestones

In February, the FCC proposed to require wireless carriers to locate 911 callers horizontally indoors within 50 meters for 67% of calls within two years of the rules being adopted and for 80% of calls within five years (TRDaily, Feb. 20). For vertical location, carriers would have to locate callers within three meters, or approximately floor-level location, for 67% of calls within three years and for 80% of calls within five years. The wireless industry has argued that those proposed deployment milestones were too aggressive and not feasible given the state of technology.

In the plan offered by the national wireless carriers, APCO, and NENA, the parties said that carriers “commit to obtain a location fix using ‘heightened location accuracy technologies’ for the following percentage of [all] wireless 9-1-1 calls from the date of the Agreement consistent with Section 4(a),” which is based on live call data: “i) 40% of all wireless 9-1-1 calls within two years; ii) 50% of all wireless 9-1-1 calls within three years; iii) 75% of all VoLTE wireless 9-1-1 calls within five years; and iv) 80% of all VoLTE wireless 9-1-1 calls within six years.

“Wireless 9-1-1 calls that originate from ‘heightened location accuracy technologies’ are calls with fixes for A-GNSS (GPS and/or GLONASS), dispatchable location, and the proportion of calls from any other technology or hybrid of technologies capable of location accuracy performance of 50m using a blended composite of indoor and outdoor based on available data from a test bed and/or drive test performance,” according to the plan.

The parties signing the plan agreed to work on a z-axis, or vertical, solution and they said they would work on a specific metric later.

In their comments, critics of the plan complained that there are too many unknowns, holes, and loopholes in it. For example, they correctly noted that it would not commit carriers to actually deploy  dispatchable location, includes weaker milestones than the FCC’s proposals, does not require robust indoor accuracy because of a blended outdoor/indoor framework, does not require a vertical solution, and would rely on Wi-Fi and Bluetooth technologies that haven’t been used to enable the deployment of public safety services.

Critics also said that the plan is not technology neutral, could leave millions of Americans with 2G and 3G phones out of any solution, and raises numerous privacy concerns. Many of the critics also complained that the national wireless carriers, APCO, and NENA left other parties out of the negotiations entirely – or, at least until near the end of the discussions.

However, even some entities that voiced concerns with the APCO-NENA-carrier plan emphasized the value of working toward providing first responders with dispatchable locations, and thus suggested that the FCC pursue such a solution in a further notice as it adopts its proposed rules. Some suggested the FCC should consider adopting provisions from the plan as long as they can be enforced. A few of those that expressed support for the FCC’s plan did not discuss the APCO-NENA-carrier plan.

Supporters of the plan contended that it would ensure progress is made toward providing first responders with a dispatchable location and lays out more realistic deployment milestones than the FCC proposed. The backers also noted the proposed use of live calls to measure progress, the use of a test bed to gauge the effectiveness of new technologies, and the plan to establish a national database. They also contended that the plan is technology neutral and blasted vendors that have opposed it, even though some public safety groups have raised similar concerns. The supporters also noted that APCO, NENA, and the national wireless carriers have asked the FCC to codify provisions of the agreement.

In joint comments, the National Association of Chiefs of Police, the International Association of Fire Chiefs, the National Association of State Emergency Medical Services Officials, the National Sheriffs’ Association, and the National Volunteer Fire Council, the first four of which were not invited to negotiations over the location accuracy plan until late in the process, suggested that public safety is not “split on the issue of supporting the agreement,” as it noted news stories have indicated.

“We do not agree. APCO and NENA are an integral part of the broader public safety community. However, under the issues addressed in the docket, the associations signing this letter represent the leadership of the frontline first responders as well as the volunteer fire, EMS, and rescue services who are called upon to respond to 9-1-1 emergencies every day,” the groups said.

The groups added that while they support the plan’s definition of dispatchable location, they added that they “have serious concerns about the details of the actual roadmap. For example, we believe that the carriers should utilize all potential technology options in determining the dispatchable location of a 9-1-1 caller using a wireless device, including technology using both compensated and uncompensated barometric pressure. The proposed roadmap relies on technology solutions for 9-1-1 emergencies that have never been tested in a real-world environment, including the use of in-building Wi-Fi, Bluetooth information and crowdsourcing. . Even if proved to be usable, it is hard to believe that these technologies will be deployed in all buildings and homes.

“As to advanced vertical (z-axis) technology, the only commitment is to address the issue of using uncompensated and compensated barometric pressure within 36 months, if the PSAPs and carriers determine such data to be beneficial to public safety. Also, the Roadmap limits any use of the technology unless there are two proven candidate technologies. This is totally unacceptable and virtually eliminates any substantive effort on vertical technology use,” the groups added. “We still have concerns that many of the provisions in the Roadmap must be worked out after the agreement has been finalized. . Governance and funding of the test bed and the National Emergency Address Database is unresolved. Any funding shortfalls must be borne by the Carriers. We believe a better approach is for the FCC to focus on using performance-based metrics for providing dispatchable location to PSAPs. This approach would be technology-neutral and the specific metrics would be enforceable by the FCC.”

However, the groups added that they “are not opposed to the FCC incorporating portions of the Roadmap into its final rules so long as they are measureable and achievable benchmarks which are enforceable by the FCC to ensure that the carriers provide improved indoor location results in a reasonable timeframe.”

In joint comments, the National Association of Emergency Medical Services Physicians, the National Association of Emergency Medical Technicians, the National Association of State Emergency Medical Services Officials, and the National Emergency Medical Services Management Association submitted comment similar to the previous joint public safety filing.

“Of greatest concern, the roadmap fails to include any measurable or enforceable results for either improving indoor location accuracy or for the delivery of ‘dispatchable address,” the Congressional Fire Services Institute and the International Association of Fire Fighters said in a joint filing. “The Commission’s proposal contains technology-neutral accuracy measurements for indoor location within reasonable timeframes and validated through independent testbeds.”

The groups added that “the majority of the technologies proposed in the roadmap lack measurable, real-world testing results and require adoption by third-parties. Even if affirmative testing results were forthcoming, neither the Commission nor the carriers have the authority to compel the private sector or individual consumers to adopt such technologies, resulting in highly variable coverage.” They also complained that “the roadmap also lacks any meaningful implementation of vertical location capability.”

“The proposed fifty meter horizontal accuracy and three meter vertical accuracy will not only reduce response times, it will increase the safety of law enforcement and other public safety officers executing searches in hazardous environments,” the National Fraternal Order of Police said. “We agree with the Commission and industry experts that these measures are realistic and achievable with current technology.”

The International Municipal Signal Association said the road map is not a consensus document, noting that APCO and NENA account for only a fraction of the 16 voting members of the representative National Public Safety Telecommunications Council.

“More fundamentally, the Commission should not adopt the Roadmap because it does not address several critical issues that should be resolved through the rulemaking process,” IMSA said. “For instance, there are unresolved issues relating to the test bed, including the non-governmental entity that will manage it and how it will be funded.  The Roadmap also relies on technologies like in-building Wi-Fi and Bluetooth that have not been tested in real-world conditions.  Even if these technologies do prove useful, the Roadmap’s reliance on them unrealistically presumes their ubiquity in all American homes and businesses. Further, many of the details of the proposed National Emergency Address Database (‘NEAD’) – essential to the proposal to use Wi-Fi and Bluetooth to provide dispatchable location information – have not yet been resolved.  Among other things, the Roadmap sponsors have yet to develop the design, operations, and maintenance requirements for the NEAD; establish a database owner; establish funding mechanisms; or develop privacy, performance, and management provisions.”

“The Commission must reject the ‘Roadmap Agreement’ and not adopt its provisions into its rules for indoor wireless location accuracy,” the Boulder, Colo., Regional Emergency Telephone Service Authority said. “The terms of the Agreement itself have not been filed with the Commission, and the terms that have been disclosed water-down and delay the accuracy standards and deadlines to the point that they are meaningless. The Roadmap Agreement also makes the requirements that are proposed too discretionary to be enforceable as rules.”

The State of Hawaii Enhanced 9-1-1 Board argued that the Commission’s “proposal has been the subject of an open, fair, and vigorous administrative proceeding, and the proposed rules are supported by a strong and well-documented record..” It added that the APCO-NENA-carrier plan “does not provide the same near-term improvements as the FCC’s proposed rule. In place of such improvements, the Roadmap alludes to services and technologies that may be developed.”

In particular, the 911 board noted that the proposed milestones in the plan include both indoor and outdoor deployment and VoLTE phones, adding that they “do not provide anywhere near the same coverage or effectiveness as the FCC’s proposed rules.” The board added that the plan “does not include firm benchmarks for vertical axis location accuracy,” and does not specifically detail how a dispatchable location would be realized. It also said that the plan’s references to OTDOA, GLONASS, and GPS show that it is not technology neutral. But it said the FCC should “explore dispatchable address with an immediate further notice of proposed rulemaking,” adding that the agency “should not delay or weaken its proposed rules in any way.”

A number of other current and former public officials, state public safety groups, and other individuals also filed generally brief comments opposing the 911 location accuracy plan and supporting the FCC’s proposals. Some of the filings were similar to each other, and several took aim at wireless carriers.

For example, Patrick Devaney, president of the Associated Fire Fighters of Illinois said, “It is disturbing that these companies would put their misguided priorities above American lives.”

Some entities filing comments were mixed in their reviews.

For example, the National Association of State 911 Administrators said it was disappointed that it was not asked to participate in the discussions that led to the agreement, noting that it was a signatory to a 1996 enhanced 911 consensus agreement.

But the group suggested there are some positive aspects to the agreement, but it said it is necessary to address issues such as (1) “carriers’ remedies if the test bed should yield unfavorable results,” (2) how non-NEAD dispatchable location information would be made available to public safety answering points, (3) who will own and maintain the NEAD, and (4) the “unreasonably nebulous” language concerning the delivery of vertical location accuracy information.

“Even though NASNA believes that a dispatchable location/address will be more useful to PSAPs and first responders, we do not agree to delay progress on achieving and delivering meaningful z-axis data,” it said. “If the Commission should choose to delay its proposed z-axis requirements on the basis of what is presented in the Roadmap, then we strongly urge the Commission (1) to require carriers to develop dispatchable location/address technologies and deliver dispatchable location/address information to PSAPs, and (2) to do so on the same timeframe and with the same benchmarks as it proposed for improved x-y coordinate data. Dispatchable location/address is the gold standard for indoor location, and z-axis is not a suitable substitute for it.”

NASNA also said the FCC should “adopt rules that hold the carriers accountable for doing whatever it takes to succeed and that do not allow for the possibility that progress might not have been made in 36 months.”

The Texas 9-1-1 Alliance, the Texas Commission on State Emergency Communications, and the Municipal Emergency Communications Districts Association said, “The Roadmap submitted by APCO, NENA and the four major wireless carriers is commendable in that it advances the issues of 9-1-1 ‘dispatchable address’ and new consumer home phone products and services, including, but not limited to, Wireless Home Phones (‘WHP’) and femtocells, beyond what was addressed by the Commission’s proposed rules. However, the Texas 9-1-1 Entities have one major, threshold problem with the Roadmap, which the Commission must rectify in order to protect the safety of the public. The requirements under section 2(b)(i)6 of the Roadmap mandating the provision of a 9-1-1 ‘dispatchable address’ from consumer home phone products must be incorporated into Commission rules applicable to all wireless carriers, and not apply on a strictly voluntary basis only to the customers of the four major wireless carriers for ‘new’ consumer home phone ‘products’ within 18 to 24 months.” The entities added that the FCC should mandate “that all existing and new consumer home phone products provide a ‘dispatchable address’ within 6 to 12 months.”

“The carriers’ agreement does not provide accountability or assurance that its plan would be effective,” AARP contended in its filing. “The FCC’s proposed rules provide specific, fair and measurable requirements for indoor location accuracy, requiring horizontal accuracy within 50 meters for 67% of indoor wireless 9-1-1 calls by the two year mark and vertical accuracy within 3 meters for 67% of indoor wireless 9-1-1 calls by the three year mark. By comparison, the carriers’ agreement discusses ‘dispatchable address’ as the goal, but the benchmarks do not deliver dispatchable address. Rather, the carriers’ agreement calls for its handsets to have ‘heightened location accuracy technology’ that would provide a location within 50 meters for 40% of all wireless 9-1-1 calls (indoor and outdoor) within two years. The introduction of outdoor calls as a variable in the equation is concerning. By boosting outdoor performance, indoor location accuracy may not be appreciably improved or even realized to any practical extent. Most importantly, it removes real accountability for indoor location accuracy.”

AARP also said that the “carriers’ agreement is hampered by its closed, opaque process.” But it added that the plan “raises points worthy of further consideration. First, the FCC should set ‘dispatchable address’ as an ultimate goal, and since the record is scant on this topic, the Commission should immediately issue a Notice of Inquiry or Further Notice of Rulemaking to explore dispatchable address. Second, the proposals for a test bed should be considered as well as the National Emergency Address Database, since the carriers have indicated their willingness to provide these aspects.”

Ten entities that represent the deaf and hearing impaired community reiterated their support for the FCC’s rules, while also saying that provisions in the road map are worth exploring. The entities had been critical of the stakeholders that negotiated the agreement for leaving them out of the process.

“The Commission should encourage further effort in that direction by having appropriate open and transparent bodies (e.g., CSRIC) study elements of the Roadmap such as the test bed setup, NEAD and its’ privacy, reliability, and funding aspects,” the entities said. “Consistent with that approach, our organizations view the Roadmap and its proposed use of commercial Wi-Fi databases for E911 location as an important and promising supplement to the Commission’s proposed rules rather than as a replacement (that is, they would serve as a means to achieve the proposed performance benchmarks).”

The filing added, “The measures as proposed by the Roadmap are not sufficient to give deaf and hard of hearing consumers assurances that they will be found in the majority of times when they place wireless 9-1-1 calls. There is a need for developing enforceable, reasonable, and representative metrics. And it must be done in a way that the FCC can enforce them. With respect to outdoor versus indoor metrics versus total metrics, we acknowledge that this is a difficult issue. However, we see a need for assessing both separately, to ensure that improvements in outdoor location accuracy do not artificially inflate progress toward our targets, even if indoor location accuracy were to remain poor.”

Signing the filing were Telecommunications for the Deaf and Hard of Hearing, the Gallaudet University Technology Access Program, the National Association of the Deaf, the Hearing Loss Association of America, the Association of Late-Deafened Adults, the Deaf Seniors of America, the American Association of the Deaf-Blind, the Cerebral Palsy and Deaf Organization, the California Coalition of Agencies Serving the Deaf and Hard of Hearing, and the Deaf and Hard of Hearing Consumer Advocacy Network.

“At a minimum, it is clear the Roadmap simply does not provide the same near-term improvements as the FCC’s original proposal,” stated the National Association of Regulatory Utility Commissioners. “Instead of those improvements, the Roadmap references services and technologies that may be developed. Accordingly, NARUC continues to endorse elements of the FCC’s original proposal.” NARUC added that the road map’s proposal to combine both indoor and outdoor figures would result in slower improvement in indoor location accuracy.

The Nebraska Public Service Commission expressed similar concerns, saying that it is worried “by the Roadmap’s delayed timetable, technology specific approach, and lack of indoor location accuracy requirements. The NPSC is particularly troubled by the ‘blended composite of indoor and outdoor’ location accuracy that camouflages poor location accuracy, which in turn puts the safety of the public at risk by failing to provide location information in emergency situations. Under the Roadmap’s standard, if outdoor performance was at or above 80%, indoor location accuracy could potentially be zero. This means a carrier could never locate a single indoor call within 50 meters, but would still meet the national standard. A location accuracy standard of zero should never be acceptable.”

Several location technology vendors also lobbed complaints at the APCO-NENA-carrier plan, including TruePosition, Inc., and the Find Me 911 Coalition, which TruePosition has funded. Both TruePosition and the coalition have been prominent critics of the plan.

“While providing a ‘dispatchable address’ is a worthy long-term goal (assuming public safety authorities can agree on its definition and effectively use that data), the carriers’ Plan abandons the critical near-term improvements to the E911 system proposed by the FCC to pursue a vague, aspirational goal,” TruePosition declared. “As the carriers’ previous statements (as well as their Plan) attest, the technologies and resources do not exist today to provide a ‘dispatchable address’ in the way described by the carriers. However, the technology does exist today to meet the standards proposed by the FCC.

“The substitutions proposed by the carriers will replace feasible standards and firm deadlines with vague promises, additional study, and reduced accountability,” TruePosition added. “Moreover, the Plan seeks to shift the responsibility of providing life-saving E911 services to private citizens, building owners, Internet service providers, and Russian satellite systems. Here again, in addition to creating national security issues, the Plan undermines the FCC’s E911 public safety framework since participation by these parties would be completely voluntary. The FCC would have essentially no legal power to enforce most aspects of the Plan.”

The coalition urged “the FCC to reject the phone companies’ efforts to replace the realistic and achievable targets in its proposed rule with the weak, vague and unenforceable concepts outlined in the ‘Roadmap.'”

Polaris Wireless, Inc., said that “the proposed Roadmap is not a step in the right direction – it is unproven, has not been publically vetted (the standard to which all parties agree), and is neither available on the market today nor will it be fielded for many years. In addition, the protocols required to achieve even a baseline version of the ultimate proposed system have been neither articulated nor introduced for consideration before the relevant standards-setting bodies. Furthermore, the sheer complexity and torturous number of entities which flawlessly must work together should give the Commission pause: ‘Cellular Service Providers, System Service Providers, Enterprises, Wi-Fi Equipment Providers, Smartphone Vendors, Public Safety, [and] Government.'”

Polaris added that under the plan, carriers do not have to deliver a dispatchable location, the NEAD “is woefully vague,” and the road map’s language “is carefully worded to exempt the wireless network operators from virtually any firm timetable or standard of accuracy performance – it is a self-serving statement that, through hairsplitting legalese, avoids any commitments to improve emergency location services.”

“The Commission has a carefully-considered proposal for indoor location accuracy, which aligns well with its current outdoor location accuracy mandate,” Polaris added. “An eleventh-hour proposal, which was developed behind closed doors, with no involvement from the Commission or important stakeholders, should not derail the Commission’s process or imperil public safety.”

NextNav LLC said that the APCO-NENA-carrier plan “eschews specific performance requirements in return for studies, tests, exploration, and avoidance of regulatory oversight. The Roadmap does not commit to achieve any concrete, quantifiable improvements in indoor accuracy, and proposes instead a carefully-worded set of promises to evaluate, standardize, and promote various approaches to address-based location capability without undertaking any actual commitment to verifiable and tested performance results. As a result, the Roadmap is not an acceptable alternative to the proposed rules and the Commission should proceed with adopting its rules as proposed.”

NextNav added, “The Roadmap’s trumpeting of ‘dispatchable location’ is understandable, but ultimately disappointing. It is understandable because every party on the record agrees that a reliably provided dispatchable address would be extremely useful (often termed by public safety as the ‘gold’ standard). It is ultimately disappointing, however, because the Roadmap never actually commits to providing even a minimal number, or any dispatchable address at any future time, and the technical approaches described within it would provide instead some address in the general vicinity of the caller (perhaps best characterized as a ‘pyrite’ standard). Due to the voluntary nature of the effort envisioned by the Roadmap, even the provision of a ‘vicinity address’ is likely to be applicable to only a small fraction of E911 calls in the foreseeable future.”

For their part, 16 groups and an individual privacy advocate submitted joint comments expressing concern that the 911 location accuracy plan would compromise consumer privacy.

“The roadmap raises significant privacy-related concerns that are not adequately addressed in the roadmap itself,” the parties argued. “In light of these newly raised concerns, privacy advocates urge the Commission to pass regulations that require commercial mobile radio service (‘CMRS’) carriers and others to treat mobile 911 location information and National Emergency Address Database (‘NEAD’) as protected information, to require that representatives of consumer privacy organizations be allowed to participate fully in the further development of improved E911 location accuracy, and to ensure that any final agreement(s) will be subject to further notice and comment. In the event the Commission moves forward with an Order in this docket and determines that the record is currently insufficient to support the regulations that privacy advocates recommend, the Commission should issue a Further Notice of Proposed Rulemaking proposing privacy regulations for wireless E911 location data.”

Submitting the comments were Public Knowledge, the American Civil Liberties Union, Alvaro Bedoya, the Benton Foundation, the Center for Democracy & Technology, the Center for Digital Democracy, Common Sense Media, Consumer Action, the Consumer Federation of America, the Consumer Federation of California, Consumer Watchdog, the Electronic Frontier Foundation, the Electronic Privacy Information Center, the New America Foundation’s Open Technology Institute, the Privacy Rights Clearinghouse, U.S. PIRG, and the World Privacy Forum.

Supporters of the plan touted what they said were its benefits, although representatives of smaller carriers cited difficulties in implementation.

The Competitive Carriers Association endorsed “the approach and the concepts in the Roadmap, but encourages the FCC to take into account technical and economic realities that improved location accuracy requirements present for smaller carriers and the consumers they serve.”

CCA added that it “is actively exploring with its members and with representatives of the public safety community endorsing a framework similar in structure to the Roadmap, but which takes into account the unique needs of and challenges faced by competitive carriers, especially in rural America. Since smaller carriers were not a part of the discussions that led to the present Roadmap, these carriers did not have the opportunity to address how certain aspects of the Roadmap will disproportionately affect them. The Commission must ensure that any improved location accuracy requirements are readily achievable for all industry stakeholders, not merely the largest.” The two most important issues for smaller providers are being able to rapidly deploy VoLTE and obtain handsets, CCA said.

Similarly, NTCA said that while it “is generally supportive of the process” that led to the agreement, “the Roadmap does not resolve any of the limitations that constrain small and rural wireless providers from meeting the new proposed mandates specified by the Commission or the Roadmap itself. The Commission should therefore refrain from imposing any new E-911 indoor location accuracy requirements on small and rural wireless providers until such as time as global standards have been created; technology has been developed, proven, and certified; equipment is widely available, accessible, and affordable to small carriers; and, therefore, compliance can be reasonably achieved.”

The Telecommunications Industry Association endorsed the plan, saying it “makes significant progress toward achieving the previously established policy goals set by the Commission.” It also cited what it said were the benefits of “a voluntary, consensus based process for standard development.”

“The public safety and wireless carrier Roadmap is a model of public-private collaboration that advances the public interest,” Qualcomm, Inc., said. “It provides a very aggressive yet technically achievable plan to improve wireless 911 call location accuracy for emergency calls placed indoors and outdoors. Qualcomm encourages the Commission to adopt the approach and associated performance goals set out in the Roadmap in toto, as soon as possible. The FCC should disregard the groundless complaints already made by certain vendors seeking to manipulate the Commission’s processes for their own private gain.”

Mobile Future also endorsed the plan, saying it “leverages wireless innovation and billions of dollars in existing and planned investments in location based service solutions.”

“In Cisco’s view, the Roadmap is much more than a list of commitments between a limited number of parties. It is a fundamental and important change in approach to technology, governance, and outcomes for 911 location services,” said Cisco Systems, Inc. “Moreover, Cisco sees no foreseeable technological barriers to its implementation. The milestones and metrics, while ambitious, are achievable.”

Motorola Mobility LLC expressed support for the plan and added, “To realize the benefits of the Roadmap, however, all stakeholders-including carriers, public safety, and manufacturers-must be fully involved in the development, testing, and implementation of new location technologies.”

Intrado, Inc., said it “believes that the Roadmap is what it professes to be: a realistic, effective, sustainable, initial framework that lays the foundation for continuous improvement of 911 location accuracy.”

TeleCommunication Systems, Inc., said that many elements in the road map were ones that it had proposed previously, including the use of a test bed and the providing of dispatchable location. It also suggested that it has shown that existing handsets and Wi-Fi technologies can currently provide a dispatchable location. TCS said that the milestones can be reached sooner with software upgrades in handsets, rather than hardware upgrades.

The Industry Council for Emergency Response Technologies said it “believes that the Roadmap is an excellent plan for guiding further efforts, but recognizes that there is much work to do to enable fully functional dispatchable location solutions. In particular, the creation of the proposed National Emergency Address Database is a critical component of achieving the Roadmap’s vision. iCERT recommends focusing increased attention on making that database a reality as quickly as possible.”

The InLocation Alliance said it “strongly supports the Roadmap for it presents a reasonable and realizable alternative, in contrast to the proposals set forth in the Third Further Notice.”

The National Conference of State Legislatures said the FCC “should consider the Roadmap as it drafts final location accuracy rules.”

The National Association of Telecommunications Officers and Advisors said it agreed with APCO that the road map provides needed flexibility to adjust in the future and anticipate technological developments.

In a joint filing, the American Association of People with Disabilities, the American Foundation for the Blind, the National Council on Independent Living, and the World Institute on Disability said, “The Roadmap represents a promising milestone reached by wireless industry and public safety organizations to come together in agreement on an issue of critical importance for people with disabilities. The parties’ initiative in developing a plan that increases the ability to use a dispatchable location could have significant benefits for consumers with disabilities by enabling First Responders to locate 911 callers more accurately and quickly. Although harnessing commercial Wi-Fi databases and Bluetooth beacons for these purposes as proposed by the Roadmap is new, we look forward to the unique potential that its application might have beyond E911 calls. We do, however, urge the carriers and public safety organizations to monitor any new and innovative technologies that emerge during the implementation of this plan which could more accurately and expeditiously aid in the identification of wireless users and adjust the plan accordingly.”

Meanwhile, signatories to the APCO-NENA-carrier plan touted what they said were its benefits compared with the FCC’s proposed rules.

“The roadmap establishes the commitments and benchmarks necessary for real improvements, is flexible enough to make adjustments along the way, and anticipates future advancements both in the private and public safety sectors, including roll out of Next Generation 9-1-1 services,” APCO said.  “The roadmap provides a comprehensive strategy that reflects the reality that short-term gains will be hard to achieve under any proposal. In the not-too-distant future, however, (within five years) the roadmap will yield far greater benefits than what could be achieved under the FCC’s proposal alone. At the same time, the roadmap preserves the core aspects of the FCC’s proposal, including performance benchmarks and enforceable rules.”

APCO also noted the use of a test bed, live call data, and benchmarks, adding, “A simple side-by-side comparison of the FCC benchmarks vs. the roadmap benchmarks overlooks an additional qualitative difference. As compared to the existing (and proposed extension) of the FCC’s location accuracy requirements, the roadmap benchmarks will improve our ability to assess real-world performance. This in turn empowers the public safety community and the FCC to hold the carriers accountable while at the same time incentivizing all stakeholders to pursue solutions that actually work.”

“The landmark location accuracy roadmap concluded between AT&T, Sprint, T-Mobile, Verizon, NENA, and APCO sets the stage for a quantum leap in 9-1-1 location accuracy,” NENA said. “No longer must 9-1-1 be an afterthought, consigned by economic realities and regulatory timelines to slow and halting advances. With this agreement, the public, the public safety community, the carriers and the Commission alike can finally benefit from the rapid rate of advance that comes with the force of a vibrant market and intense competition. At the same time, though, each stakeholder can rest assured that meaningful regulatory requirements undergird these advances. The roadmap provides the sort of meaningful voluntary commitments that NENA has previously insisted to be conditions precedent to a lighter regulatory touch. Consequently, NENA encourages the Commission, consistent with the roadmap, to codify certain of its provisions that align with such an approach.”

NENA also stressed the benefits of dispatchable location and said the road map “will meet the need for actionable z-axis data.” It also suggested that a unified indoor and outdoor location accuracy requirement of at least 50 meters was a step forward given the current outdoor rules that allow accuracy of up to 300 meters.

The Pennsylvania and Colorado NENA chapters filed separate, nearly-identical comments supporting the APCO-NENA-carrier plan.

“Some parties have filed ex parte comments in the docket in response to the Roadmap and have raised concerns about it. Several of these parties are technology vendors who have been pushing for proposed regulations that would ultimately entail carriers purchasing a proprietary vendor solution,” Sprint Corp. said. “These commenters argue the Roadmap does not contain sufficiently measurable commitments or adequate benchmarks to ensure the delivery of a dispatchable address. In fact, the Roadmap contains detailed commitments pursuant to which carriers agree to promote the development and approval of dispatchable location standards within 18 months, design and develop the National Emergency Address Database (‘NEAD’) database to correlate known MAC addresses with a dispatchable location within 36 months, and meet metrics for network design/development and handset design/development that will enable the provision of dispatchable location information.”

“This Roadmap – developed and embraced by the nation’s most respected public safety organizations – is a meaningful and substantive alternative to the unworkable rules proposed earlier this year,” Verizon Communications, Inc., said.  It said the plan will allow carriers “to draw upon the same Wi-Fi, Bluetooth, and other indoor technologies that are already widespread throughout the marketplace” and argued that it requires carriers “to improve outdoor technologies.” Verizon added that “many of the Roadmap’s critics erroneously presume that compliance with the proposed rules would be technically feasible. As Verizon and others have exhaustively demonstrated, the proposed rules are technically infeasible and as a result will not benefit consumers or public safety.”

AT&T, Inc., said that the plan “is faithful to the Commission’s overarching aims in this docket. First, the Roadmap is the end product of collaboration between public safety and wireless providers. Second, the Roadmap adheres to the Commission’s goal of improved indoor wireless location accuracy-50 meters horizontal and a vertical component. Third, the Roadmap endeavors to fulfill the Commission’s ultimate goal for wireless location accuracy: a dispatchable address (referred to as ‘dispatchable location’ in the Roadmap). And, fourth, the Roadmap meets the Commission’s three stated key objectives for new wireless indoor location accuracy rules; that is, to: (1) make indoor location as widely available as technically and economically feasible, tracking recent improvements in location technology; (2) help CMRS providers, public safety entities, and the Commission to monitor performance and compliance; and (3) adopt rules that are technology-neutral, cost-efficient, and easy to understand and administer.”

AT&T added that the plan “does not prohibit the use of any technology to assist carriers to meet their agreed-upon location-accuracy obligations.”

“All providers of emergency service location solutions are welcome to participate in the test bed proposed in the Roadmap; none are excluded,” echoed T-Mobile US, Inc. “This permits rational, evidence-based evaluation in a common test bed of all candidate technologies in parallel with the development of a dispatchable location solution. Indeed, while some location technologies are specifically included in the Roadmap (namely, those with the highest probability of providing the most improvement in the shortest time, those that will align emergency and commercial location services, and those capable of providing a dispatchable location), the goal of the Roadmap is not to exclude any particular technology but rather to provide a technology-neutral, empirically verifiable path for improving E911 location accuracy.”

The plan “sets forth a path to rapidly improve both indoor and outdoor location accuracy for wireless 9-1-1 calls,” said CTIA, which helped negotiate the agreement. “Through tangible and near-term carrier commitments, it attains the Commission’s longer term goal of dispatchable location and its proposed 50-meter location accuracy nearly as quickly as the Third Further Notice’s more limited geographic coordinate proposals. CTIA respectfully asks the Commission to act quickly to codify specific elements of the Roadmap, with enforceable rules that align all interests in meeting the Roadmap’s aggressive benchmarks and delivering more actionable location information to First Responders.”- Paul Kirby, paul.kirby@wolterskluwer.com