April 28, 2017–The International Association of Chiefs of Police, International Association of Fire Chiefs, National Association of State Emergency Medical Services Officials, and National Sheriffs’ Association today renewed their concerns about the transparency of indoor 911 location accuracy test results and the definition of “dispatchable location.” Today’s ex parte filing in PS docket 07-114 reiterated and elaborated on a filing the groups submitted in February (TR Daily, Feb. 22).
The earlier filing observed that the FCC’s fourth report and order in the proceeding (TR Daily, Jan. 29, 2015) said the Commission would not require “details” of testing on existing 911 location technologies to be disclosed, but the groups urged carriers to release “summary” results. The groups said they are pleased that the FCC has left open the option of disclosing summary information.
In today’s filing, the groups noted “that the carriers held a meeting on April 11 with the FCC on the issue of live call data requesting the FCC to modify its reporting requirements to eliminate the need to report yield (or accuracy) as part of their live call reports. We strongly agree with the FCC’s position on the need to provide this data and note that the FCC itself references this yield/accuracy metric is consistent with Alliance for Telecommunications Industry Solutions (ATIS) 0500031 calculations which the carriers must complete in any case to certify compliance. As the carriers note, the Order notes that the test bed results are used to determine ‘the degree to which that method can be counted towards the required location accuracy thresholds.’ The FCC’s reporting template simply requires that the resultant calculations of the ATIS 0500031 standard for the relevant market be included in the report. In our view, this all goes to the heart of the issue of transparency in the process.
“The carriers indicate that they are providing data on a voluntary and confidential basis to assist the FCC in its evaluation of the 911 location accuracy solutions,” the public safety groups added in the filing. “We take exception to this statement and believe that the carriers have an obligation to provide data for the six monitored markets validating their compliance with the order. Whether the FCC agrees to restrict public access to some portion of this data for confidentiality reasons, the summary levels of performance by the carrier, by market, and by technology are very valid elements of public interest, most particularly to our organizations and membership who are highly dependent on the underlying accuracy that is being provided in emergency situations. As we stated in our February 21 filing, the carriers appear to be using confidentiality as a shield from providing an open and transparent process. The public at large, and our collective organizations most specifically, need to have visibility into the technology testing processes (including independent indoor location testing through the test beds and carrier-conducted outdoor testing), as well as ongoing live call accuracy performance in the six monitored markets. To cloak all test data from the public through a veil of confidentiality provisions, and to disclose only the carriers’ certifications that they are ‘in compliance’ is antithetical to the very concept of a transparent and open process.”
In today’s filing, the public safety groups also continued to complain about having two levels of dispatchable location, DL Level 1 and DL Level 2, in an Alliance for Telecommunications Industry Solutions standard. DL Level 1 should be called a term such as “vicinity location” because it will not provide a location allows first responders to precisely find callers, the groups have said. “To date, our suggestions to call DL Level 1 another term such as vicinity location have fallen on deaf ears,” they said in today’s filing. “The carriers have ignored our position and are proceeding along using a DL Level 1 and DL Level 2. The undersigned organizations do not agree and take exception. In the Order, the carriers must meet certain percentages of wireless emergency calls that contain location information within 50M or provide DL (consistent with the definition of DL contained in the Order).
The carriers must demonstrate within 2 years, 40 percent of all wireless calls; within 3 years, 50 percent of all calls; within 5 years, 70 percent of all calls; and within 6 years, 80 percent of all calls. Only calls with location information identified as DL Level 2 should count toward compliance with the carriers’ obligations, since DL Level 2 is the only level of accuracy consistent with the definition of DL in the Order. To allow DL Level 1 to count toward compliance percentages is inconsistent with the definition of DL in the Order and would remove every incentive for the carriers to improve performance and identify the location of the caller (DL-2) versus the location of the access point (DL-1). Test bed processes for DL accuracy testing should reflect this reality and match requirements of DL in the Order.”- Paul Kirby, firstname.lastname@example.org