February 1, 2017–The four nationwide wireless carriers don’t plan to use an FCC form for the reports they plan to file Feb. 3 on initial 911 location accuracy live call data, but they plan to modify a carrier consensus format for subsequent quarterly reports, CTIA told the FCC in an ex parte filing yesterday in PS docket 07-114. “The nationwide carriers are refining their initial quarterly Live Call Data reports, consistent with the report format submitted by CTIA on December 15, 2016 (carrier format). On January 18, 2017, the [Public Safety and Homeland Security] Bureau released a public notice and new report form (FCC Form) directing wireless carriers to ‘break out live call data for each Test City or relevant service area’ and include additional data not included in the carrier format. The nationwide carriers will work diligently and in good faith to modify the IT and analytic systems designed around the carrier format to align with the new FCC Form for future reports.
“Carriers will determine when those system changes can be completed and may follow up with Bureau staff as needed. Carriers will also provide the reports to APCO, NENA and NASNA, once appropriate confidentiality protections are in place. As noted in CTIA’s January 9, 2016 ex parte filing, during a meeting between the nationwide carriers, CTIA, and FCC staff, ‘all agreed upcoming compliance certifications will be based solely on data aggregated across all six monitoring regions….’
“The new FCC Form also has data fields to capture information for 9-1-1 calls that the carriers will exclude from the quarterly Live Call Data reports and also from the carriers’ compliance analysis (excluded call data),” CTIA noted. “The nationwide carriers intend to provide this excluded call data, for informational purposes only, when they file subsequent reports in the new FCC Form, consistent with the definitions provided below for the specific and limited list of call types covered under those exclusions. The indoor wireless 9-1-1 location accuracy rules focus on a service provider’s own technology solutions. This aligns with long-standing 9-1-1 policy, under which the Commission has excluded various categories of 9-1-1 calls and devices for which carriers lack direct control of location accuracy capabilities.”
The excluded 911 call categories are calls less than 30 seconds, calls that appear to originate from non-service-initialized (NSI) phones, calls from roamers, calls from “gray market” devices, calls from non-affiliated mobile virtual network operators (MVNOs), test calls, and calls to public safety answering points (PSAPs) that aren’t Phase II-capable.
Public safety groups have expressed concern by carrier plans to exclude certain calls from the quarterly reports, particularly those from roaming handsets and NSI devices (TRDaily, Dec. 21, 2016). But the carriers argue that the exclusions are consistent with the indoor 911 location accuracy order adopted by the Commission in 2015 (TRDaily, Jan. 29, 2015).- Paul Kirby, firstname.lastname@example.org