March 7, 2017–The Competitive Carriers Association has asked the FCC’s Public Safety and Homeland Security Bureau to issue further guidance related to implementation of reporting obligations included in a 911 indoor location accuracy order adopted in 2015 (TRDaily, Jan. 29, 2015), including guidance related to preserving the confidentiality of data submitted to the agency. An ex parte filing yesterday in PS docket 07-114 said that CCA representatives in a meeting with bureau officials highlighted efforts by the group’s members “to catalog and report live 911 call data and location accuracy certifications in line with requirements set forth in the Fourth Report and Order, and asked for clarity regarding certain aspects of the FCC’s reporting regime. To facilitate the reporting process moving forward, CCA also encouraged the Commission to release another guidance Public Notice prior to the April 3, 2017 compliance deadline, to clarify certain issues left unaddressed since reports were submitted on February 3, 2017.”
“Specifically, since the first round of live 911 call data reports were submitted on February 3, 2017, carriers have faced technical challenges providing supplemental call data details as anticipated by the FCC’s revised template, including collecting information based on monitoring regions and synthesizing call delivery data by number and type,” according to the filing. “In particular, CCA explained the difficulty in applying the ATIS definitions for each of the morphologies – dense urban, urban, suburban, and rural – to carriers’ network footprints. Confusion regarding the application of the definitions may have [led] to inconsistent data and reporting, and could contribute to anomalies in the June reports. To that end, CCA proposed that the Bureau issue guidance to clarify how carriers may proceed in determining the morphology of a particular area.
“Additionally, CCA asked for clarity regarding the FCC’s required definition of ‘yield.’ While the Fourth Report & Order defines yield in the test bed context, the Bureau’s live 911 call data report template purports to require carriers to ‘us[e] the methodology described in ATIS Standard 0500031, [and] enter the percentage of total 911 calls that result in sending dispatchable location or x/y location with an accuracy that is within 50 meters.’ CCA appreciates the Commission’s goal to effectively evaluate the evolution of location accuracy technologies across different morphologies. To that end, and to aid carriers’ ability to file relevant data, CCA supports recommendations in the record to revise the definition of yield to instead require ‘the percentage of total 911 calls that result in dispatchable location or x/y location information by morphology and position technology,’” the filing said. “If the Bureau were to release another guidance Public Notice, CCA encourages the FCC to clarify its definition of yield, and collectively highlight all standards and computations needed to ensure compliance for future reports.”
The filing also said that “CCA and the Bureau discussed the importance of maintaining confidentiality of reports. CCA recognizes that the Fourth Report & Order does not require data to be published in an open docket, and thanks the Bureau for its recent explanation of requests for confidential treatment of providers’ live 911 call data reports. At the same time, however, the Commission reserves the right to release aggregate or anonymized data to measure compliance with its rules and could ‘publish on its website aggregate information on  providers’ performance in a given geographic area, a comparison of positioning technologies across the six Test Cities, or the percentage of calls using a particular positioning source method across all  providers.’ CCA explained that this information could be considered proprietary, and must be protected against unauthorized third party review. The FCC should clarify how carriers protect the confidentiality of their proprietary data, to prevent disparities in approaches used, and provide carriers clear assurance that proprietary data will be kept confidential. To assuage concerns, CCA recommends that the FCC issue a blanket decree of confidentiality for all reports submitted to the Commission and public safety entities. In the alternative, the FCC should clarify in a second Public Notice how, and to what extent, carriers are required to request and ensure confidentiality of their reports.” —Paul Kirby, firstname.lastname@example.org