Although a draft order circulated this week for tentative consideration at the FCC’s Jan. 30 meeting would not mandate improved geo-targeting by May 2019 (TR Daily, Jan. 9), as public safety entities had sought, the Association of Public-Safety Communications Officials-International expressed support for the draft second report and order in an ex parte filing today in PS docket 15-91. However, APCO asked the FCC to clarify portions of the item.
The draft order would mandate enhanced geo-targeting by Nov. 30, 2019. Carriers would have “to deliver alerts to an area that matches the target area specified by the alert originator, specifically by delivering the alert to 100 percent of the target area that overlaps with the wireless provider’s network coverage area, with no more than 0.1 mile overshoot.” CTIA has asked the FCC to give the industry 36 months to implement the enhancement.
In its filing today, APCO said, “The proposed enhancements to geo-targeting and alert message preservation will make our communities safer and improve public safety operations around the country. Based on the record that has developed in this proceeding, requiring the proposed enhancements by November 30, 2019, is reasonable and technically feasible.”
“In addition to expressing support for requiring geo-targeting enhancements by 2019, APCO recommends the incorporation of rule language to add clarity to the obligations of participating WEA service providers,” it added. “For example, the language of Final Rule Section 10.450 could specify that, ‘No later than November 30, 2019,’ participating CMS providers must match the target area. Section 10.450 could also reflect the language of the draft Order specifying that this deadline is to apply to ‘new mobile devices offered for sale after the rule’s effective date and to existing devices capable of being upgraded.’
“The rules could also clarify the narrow intent of what it means to be ‘technically incapable of matching the specified target area.’ Based on the record, it is technically feasible to achieve the geo-targeting goal by November 30, 2019, through software upgrades to many existing devices and with the introduction of new devices,” APCO added. “Thus, the rules should be clear that ‘technically incapable’ should not apply where providers have failed to develop standards, implement network and device changes, or pursue other technological solutions. After November 2019, CMS providers may only fall back to the ‘best approximates’ standard in a narrow set of circumstances. While APCO expects participating CMS providers to continue serving as good partners in this trusted and official public safety alerting system, the FCC’s rules should minimize the potential for any confusion with respect to the carriers’ obligations to achieve geo-targeting improvements.”- Paul Kirby, firstname.lastname@example.org