February 22, 2017–Four public safety groups told the FCC today that they are concerned with an industry standard for dispatchable location (DL). In an ex parte filing in PS docket 07-114, the International Association of Chiefs of Police, the International Association of Fire Chiefs, the National Association of State Emergency Medical Services Officials, and the National Sheriff’s Association noted that the fourth report and order adopted by the FCC in 2015 in its 911 indoor location accuracy proceeding (TRDaily, Jan. 29, 2015) “defines DL as being ‘the verified or corroborated street address of the calling party plus additional information such as floor, suite, apartment, or similar information that may be needed to adequately identify the location of the calling party.’ We agree.”
The groups said that at a September 2016 quarterly meeting of the CTIA 911 Location Accuracy Advisory Group, attendees discussed DL standards development being overseen by the Alliance for Telecommunications Industry Solutions (ATIS).
“The ATIS standard planned on having two levels of DL. DL Level 1 is information provided to the PSAP which will provide location information if the location is nearby and/or is either one floor above or below from where the individual is in a multi-level structure. Also, it appears from the ATIS standard that an adjacent building or one across the street could qualify as DL Level 1,” today’s filing said. “The ATIS standard describes a use case where the building from where the individual calling has no Wi-Fi access points. If an adjacent building has registered Wi-Fi points, the NEAD [National Emergency Address Database] sends the emergency responders to that building and describes this as the DL. We strenuously disagree with this situation being deemed DL.
“The standard also describes a DL Level 2, which is closer to the definition in the Fourth Report and Order. DL Level 2 is the information provided which finds the individual on the same floor and the suite (in other words, ‘the right door to kick in.’) DL Level 2 follows the definition of DL in the Roadmap and the FCC’s Fourth Report and Order. The ATIS standards were developed without the input or agreement of the Advisory Group. We raised our concerns with the standard at the September meeting and in subsequent discussions with CTIA, the wireless carriers, and APCO/NENA.
“The use of DL Level 1 creates confusion with the FCC definition of DL,” the public safety groups said in their letter. “We believe that DL is information which tells the emergency responders where the caller is in a building. To use the term DL to describe a situation where an access point is located, and not necessarily where the person is located, waters down what the wireless carriers and APCO/NENA agreed to in the Roadmap and the Fourth Rule and Order. We cannot agree or support the description of level 1 information as DL. Fire chiefs, police chiefs and EMS officials will not accept a DL Level 1 as being the ‘gold standard.’ We suggested that level 1 information be called ‘vicinity location’ or a similar term to describe a location other than where the caller is located. Our suggestions have fallen on deaf ears.
“In our view, the wireless carriers and APCO/NENA persuaded the FCC to relax a much tighter 911 framework outlined in the Third Further Notice by promising the ‘gold standard’ and it now appears the Roadmap signatories are walking back from that promise. The undersigned find this unacceptable,” the groups added. They also said that the indoor 911 call technology testing process should be more transparent.
“The wireless carriers cite the FCC Fourth Report and Order (paragraphs 131 & 132) as justification that during Stage 1 testing they are not required to make public the details of test results for technologies that have been certified by the Test Bed LLC, but such results may be provided to non-nationwide wireless providers that cannot participate directly in Stage 1 testing,” today’s filing said.
“The Fourth Report and Order itself doesn’t prohibit disclosing ‘summary’ results of any, including ‘existing’ technologies; it merely states it won’t require the ‘details’ to be disclosed to protect vendor’s proprietary information. As the FCC noted, summary test data was publicly disclosed during the Communications Security, Reliability, and Interoperability Council (CSRIC) III test program in 2012, which our organizations found informative and very useful. We are heartened by the FCC’s recent public notice on the wireless carriers’ reporting obligations whereby the FCC reserved the right to disclose summary data of this nature,” the groups said. “We believe our organizations have an ongoing public interest, both for our membership and for the public at large, to understand as fully as possible the performance of these life-saving technologies. To do so effectively requires visibility into both the test results from existing and emerging technologies (at a summary level) as well as the live E911 call reporting results from the various carriers. To expect less or accept less would be a disservice to our memberships, our missions, and the public at large.” —Paul Kirby, firstname.lastname@example.org