Parties Continue To Press FCC on 911 Location Accuracy Item

Stakeholders continued to lobby the FCC today ahead of its vote at the Jan. 29 meeting on a 911 location accuracy order. In announcing the meeting today (see separate story), the Commission gave parties until tomorrow night to make their case on the item.  As circulated, the draft order would incorporate provisions from rules the FCC proposed early last year as a well as from an alternative road map unveiled more recently by the four national wireless carriers, the National Emergency Number Association, and the Association of Public-Safety Communications Officials-International.

Parties continued to weigh in on a modified version of the road map unveiled yesterday (TRDaily, Jan. 21). The carriers say the changes would provide additional assurances of improved indoor location accuracy, including vertical accuracy, but some vendors and public safety officials are critical of the proposal.  Meanwhile, CTIA and NENA late today responded to criticism from a lawmaker that use of the Russian GLONASS system in the road map framework could compromise national security.

In February 2014, 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, 2014). 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.

Under the draft order as circulated, after three years, 50% of all non-satellite-generated horizontal location fixes would have to be by dispatchable location or within 50 meters. After six years, 80% of non-satellite-generated horizontal location fixes would have to be by dispatchable location or within 50 meters, and 80% of vertical fixes would have to be by dispatchable location or within three meters, according to sources.

One public safety source complained to TRDaily today that the revised road map would push vertical, or Z-axis, implementation back to eight years, although there is no specific accuracy standard for that deployment. “And it does not seem to address compensated barometric pressure,” the source said.

Meanwhile, TruePosition, Inc., and NextNav LLC, which are location accuracy technology vendors, criticized the revised road map in ex parte filings filed today in PS docket 07-114 and asked the Commission to adopt the draft order.

“If anything, the Modified Roadmap moves further away from accountable indoor accuracy standards in that it would deem the carriers to be in compliance so long as they have successfully ‘mapped’ one WiFi or Bluetooth access point for every four persons living in a particular Cellular Market Area,” TruePosition said. “In other words, the carriers will deem their proposal successful so long as they can create a database of WiFi hotspots in a city or town; it will not matter whether any local PSAPs can effectively use that data to send First Responders to find people in an emergency, and it will not matter if this mapping plan can successfully locate anyone who places an emergency 911 call from a cellphone at an indoor location.”

NextNav said the revised road map “continues to focus on activities the carriers offer to undertake, rather than actual performance results that will be achieved. In many cases, the Supplement misunderstands or misstates the Commission’s proposals and further extends compliance deadlines previously offered in the Roadmap.” For example, NextNav said “that the Commission’s non-satellite metric will closely correlate to indoor location accuracy in urban and suburban environments” and it said it is working to get its beacon system standardized so it won’t be seen as a proprietary solution. NextNav also said that the amended plan does not guarantee any particular vertical location accuracy.

As for providing dispatchable location, NextNav said, “The new compliance benchmark offered by the carriers involves nothing more than a year six declaration that a certain number of Wi-Fi or Bluetooth reference beacons exist in a particular market. The reference point density specified, one for every four people, has no technical underpinnings, no test results, and in fact nothing in the record to support the sufficiency of such an arbitrary metric. This approach again pushes any measurable benchmark out for many years, and relies upon activities undertaken rather than performance results demonstrated to declare compliance. In contrast, the Commission’s draft order relies upon the proven. The solutions either work or they do not. They either meet the required accuracy and serve a measurable number of calls or they do not. Every opportunity is provided in the draft order to allow the carriers to demonstrate that their chosen solutions (be they address-based or coordinate-based) can deliver results, and additional years and lowered performance thresholds have already been provided in the draft order to accommodate carrier concerns.”

“Considered together, the additional provisions included in the Supplement do not provide any substantive improvement over the Roadmap in terms of ensuring that accurate and reliable location information for wireless calls to E911 is provided to emergency first responders,” NextNav added. “Instead, the Supplement appears to muddle the Roadmap commitments even further by significantly extending the timelines that the carriers had originally proposed for themselves for taking action, and by further obscuring the fact that their touted ‘dispatchable location solution’ is unlikely to provide a dispatchable location to emergency first responders for the vast majority of wireless calls to E911.”

Meanwhile, CTIA and NENA issued a joint statement late today responding to a “Washington Times” story that reported on a letter yesterday from Rep. Mike Rogers (R., Ala.), chairman of the House Armed Services Committee’s strategic forces subcommittee, to Defense Secretary Chuck Hagel and Director of National Intelligence James Clapper expressing concerns about use of the Russian GLONASS system as part of the enhanced reliability envisioned by the road map. Those concerns have been expressed since the road map was unveiled by the Find Me 911 Coalition, which has received funding from TruePosition.

“In view of the threat posed to the world by Russia’s Vladimir Putin, it cannot be seriously considered that the U.S. would rely on a system in that dictator’s control for its wireless 911 location capability, which is planned to allow public safety and other first responders to find 911 callers,” Rep. Rogers wrote in the letter, which TRDaily obtained this evening from his office.

Rep. Rogers noted that he authored a provision in the Fiscal Year 2014 National Defense Authorization Act (NDAA) “that prohibited locating GLONASS ground stations in the United States.” He sought information on to what extent DoD would rely on the E911 system, the “national security implications … of GLONASS integration into the E-911 system,” and “the impacts on national security users and public safety first responders if Vladimir Putin decided to use U.S. reliance on GLONASS as a weapon against the U.S.”

“What is your understanding of the current status of this GLONASS E-911 proposal and can you assure me that you will act to ensure it is not allowed to move forward?” Rep. Rogers added.

In their statement, CTIA and NENA noted that the road map envisions GLONASS as well as GPS being available to help improve location accuracy, and that more options are expected to be online in the future. Any GLONASS shutdown would not impact 911 reliability because handsets could still use GPS signals, they said. Russia would not get power over U.S. wireless communications because GNSS chipsets are receive-only and can’t transmit signals back to the satellite constellation, they noted. CTIA’s portion of the statement blasted the Find Me 911 Coalition by name.

“The NDAA amendment limiting construction of Russian monitoring facilities on U.S. soil does not impact the availability of GLONASS ranging signals,” CTIA also said. “Other monitoring stations around the globe can still ensure the accuracy of GLONASS clock and orbit data.”

“Nothing the FCC is proposing would mandate or require the use of any foreign satellites,” added Scott Bergmann, vice president-regulatory affairs for the trade group. “U.S. wireless providers will continue to carry 911 calls from U.S. consumers on U.S. networks. Contrary to rumors spread by disgruntled 911 vendors who are seeking a government mandate of their own proprietary technologies, the Roadmap for improving 911 service developed by public safety and wireless providers will make consumers safer and protect their security and privacy.”

Also today, Harold Feld, senior vice president of Public Knowledge, expressed optimism that privacy and security concerns will be addressed in the deployment of a National Emergency Address Database (NEAD). In amending the road map, carriers said they would commit “to engage with various industry experts on privacy and security to ensure that best practices are followed in the development and operation of the database. An additional commitment is made here to require the vendor(s) selected for the NEAD administration to develop a Privacy and Security Plan in advance of going live and transmit it to the FCC.”

“The FCC very properly solicited comment on the privacy concerns when it issued the notice of proposed rulemaking,” Mr. Feld told TRDaily. “As far as we can tell, both the carrier community and the public safety community are in total agreement with us that E911 is not a profit center but a public service, and recognize the need to address these privacy concerns. There is also a growing recognition both within the FCC and within the stakeholder communities that good privacy means good security and good security requires good privacy.

“So we are hopeful that these concerns will be addressed in the Order. Because the technology is still at the development stage, we expect that the FCC may need a Further Notice or some other mechanism to fully flesh out the appropriate privacy protections,” Mr. Feld added. “But that is also the good news, since it allows carriers and public safety to work with privacy advocates to ensure that the enhanced geolocation features are architected for privacy rather than attempting to layer privacy on at a later stage.”

For its part, T-Mobile US, Inc., submitted a report to the FCC that touted the potential of beaconing and local area network technologies in helping locate 911 callers indoors.  “The research and analyses in this report reveal that alternative, standards-based beaconing, and local area network/personal network-based location methods can provide a reliable, robust, accurate, and usable dispatchable location to public safety agencies for indoor mobile 911 callers,” said the report, which was prepared by Roberson and Associates LLC. “These methods, based on Wi-Fi or Bluetooth, have been proven in commercial applications and should be readily extended to serve both near- and long-term public safety requirements. In these alternative approaches, when a mobile user initiates a 911 call, the user device receives identification information from nearby wireless access points or beacons, and relays that information to a database location server that translates the identification information to a dispatchable location. The dispatchable location is in turn delivered to the public safety answering point or PSAP. The beacon methods are based on the precise address and indoor location (street / floor / suite / apartment number / elevator / foyer etc.) of the Wi-Fi access points and/or Bluetooth beacons and enable indoor location accuracy that is often times within a few meters of the 911 caller, and does not rely on reverse geocoding a geospatial coordinate.” – Paul Kirby,