Public safety and industry entities have weighed in at the FCC with suggestions on ways to ensure that 911 calls place from cellphones reach the correct public safety answering points (PSAPs), even though some say hard data on the scope of the problem is elusive. Parties offered diverse opinions on whether technologies currently exist to address the problem and if they should be deployed, or whether it would make more sense to focus resources on the deployment of next-generation 911 technology.

The comments were filed in PS docket 18-64 in response to a notice of inquiry adopted in March seeking input into ways to address situations where 911 calls from cellphones are misrouted to the wrong PSAP because the location of the cell tower being used by phone is not in the same PSAP jurisdiction as the caller (TR Daily, March 22).

The NOI seeks input on ways call-routing could be improved, and on ways the FCC could facilitate and encourage such improvements. It notes that recent technological improvements could enable routing based on the caller’s actual location.

The item also seeks comments on recommendations regarding location-based routing made by the FCC’s Communications Security, Reliability, and Interoperability Council (CSRIC) in 2016 and asks about the costs and benefits of adopting location-based routing.

In its comments, the Association of Public-Safety Communications Officials-International said that the lack of interoperability among PSAPs can exacerbate the impact of misrouted 911 calls.

“There are still instances where PSAPs have to manually call each other to convey the information about an emergency. This holds true both for misroutes and for other incidents that would benefit from seamless voice and data sharing between PSAPs, such as calls for mutual aid,” APCO said.

“Unfortunately, early-adopter deployments of NG9-1-1 components such as ESInets have shown that the introduction of IP-based technology alone is not solving the interoperability problem,” the filing said.  “Policymakers, industry partners, and 9-1-1 authorities must recognize and work to resolve this problem.”

APCO also said that it “would welcome additional data but anticipates that precisely quantifying the scope of the problem will be difficult. PSAPs may have different policies and capabilities for transferring as well as tracking misrouted calls. Additionally, the dynamic nature of wireless networks can mean that even two 9-1-1 calls made from the same location could route to different PSAPs because one call might route based off of the nearest tower while the other call might connect through a different tower or cell sector that has been set up to route to a different PSAP based on pre-established boundaries. The frequency of misroutes likely varies greatly across PSAPs.”

“The Commission seeks comment on the CSRIC Report’s recommendations about several location-based routing solutions. APCO generally supports the Report’s recommendations. In particular, APCO agrees with the recommendations that the Commission should take steps to ensure that any location estimates considered for routing 9-1-1 calls are accurate, and support the independent testing and analysis of new location technologies that promise significantly increased accuracy and speed. PSAPs are all too often approached by companies promising solutions, without feasible methods to verify the claims or hold the providers accountable,” APCO said.

APCO noted that “the Commission asks whether the NEAD [National Emergency Address Database] will be capable of being leveraged to obtain a caller’s location for the purpose of routing a 9-1-1 call. APCO would urge caution on prematurely considering the use of the NEAD for routing purposes. While the NEAD holds great promise for achieving a dispatchable location solution for wireless 9-1-1 calls, particularly inside buildings, it remains in development. At this point, efforts concerning the NEAD should therefore remain focused on its intended purpose.”

“Finally, the Commission asks what role, if any, it should play in the creation or implementation of standards or practices for location-based routing. Standards are best handled by industry standards bodies. As a general matter, the introduction of new technology and architectural approaches will make it increasingly difficult for 9-1-1 authorities and service providers to be clear on their respective responsibilities for allocating costs,” APCO said. “Accordingly, the Commission can provide much-needed support by continuing to offer clarification and ensuring that PSAPs do not bear costs that the Commission’s rules would otherwise allocate to service providers.”

“Until the IP-native routing features of NG9-1-1 arrive, NENA supports the development and implementation of proven interim processes and technologies for location-based routing. However, NENA respectfully requests caution by the Commission that interim solutions neither cause harm to existing routing mechanisms or delay the implementation of NG9-1-1 native location-based routing,” said the National Emergency Number Association.

“The Notice requests comment on the viability and effectiveness of provisioned or registered civic addresses. Location based routing using civic address can be successful, assuming addresses are accurate. Registered or provisioned addresses have proven to be problematic if provided by customers, because the large percentage of these that are nomadic VoIP are not kept updated by their users,” NENA said. “Automatic location definition without customer action would be highly preferable to support effective 9-1-1 service. Further, wireless carriers do not currently support processes that can help 9-1-1 validate user addresses, or provide them for use by the NG9-1-1 systems for routing control.”

“The Notice also seeks information on ‘how quickly 911 calls can potentially be routed when using device-based hybrid location solutions.’ NENA notes that current trends — especially in the marketplace for third-party solutions — gravitate toward warm-start GPS processes. Assuming the data provided by these processes is properly handled and utilized, initial routing control could be accomplished within 2–3 seconds of call start for calls where the supplemental location data is determined to be dependable and adequate. However, the proprietary nature of these location services, the unknown nature of the databases that underpin them, and their management and maintenance causes questions about how well those services can be safely applied. The concepts noted in the NOI — including the NEAD — are all capable of improving call routing and timing, but not if they are applied only within the traditional routing processing timeframe of CMRS wireless 9-1-1 within the carrier networks. Many of the newer methods for location can provide data well within 5 seconds, but if it is not utilized in a timely way, little progress will be enabled.”

The Texas 911 entities, which include the Texas 9-1-1 Alliance, the Texas Commission on State Emergency Communications, and the Municipal Emergency Communication Districts Association, provided some data on the frequency of 911 calls that are misrouted, saying that “recent data for a reasonably large sample of approximately 13,000 cell sectors in Texas shows that the percentage and number of misroutes varies considerably between sectors and between Public Safety Answering Point (‘PSAP’) serving areas. For example, that data appears to show approximately 70% of the cell sectors indicated no misroutes, while approximately 10% of the sectors have greater than 50% misroutes, with certain enclave areas or cities surrounded by another city often being materially impacted by misroutes. Because the data varies considerably between sectors and between PSAP serving areas, utilizing only a general aggregate average for many sectors can completely obscure a considerable number of misroutes, and obscure the potential benefits of improvements in individual sectors.

“In the absence of sufficient public disclosure of information and informed discussions between various 9-1-1 stakeholders (e.g., wireless service providers, handset manufacturers, third-party vendors, 9-1-1 authorities, etc.), the nature of the competitive market and the sheer number of stakeholders can present some challenges to making informed decisions and strategic transition planning regarding device-based handset initiated location technology solutions,” the entities added. “Given the current frequency of misroutes, in the absence of documentation of material costs to wireless service providers being submitted into the record in this proceeding, at the present time it appears that Commission action would withstand ‘the test of feasibility and functionality relative to costs.’ The manner in which device-based handset initiated location technology solutions and NG9-1-1 transition may sync up together, including interoperability and timing considerations, and how much cost responsibility is placed on wireless service providers as compared to the NG9-1-1 systems, are appropriate issues to clarify in this proceeding.”

The filing continued, “Delaying the delivery of 9-1-1 calls more than fractionally beyond 6 seconds to achieve LBR [location-based routing] should generally be avoided. This is especially the case when other alternatives appear to be available to achieve improvements towards LBR. Finally, with regard to mobile VoIP, continuing to provide only a registered and provisioned civic address from a smartphone or tablet for mobile VoIP 9-1-1 calls is quite concerning. Accordingly, the Texas 9-1-1 Entities urge the Commission, at a minimum and as recommended in the NENA Non-Mobile Technical Information Document, to consider the issue of a location sanity check when a customer with mobile VoIP changes locations and has not reregistered a caller civic location.”

“There are a number of measures which can and should be taken to remedy Phase I Misroutes of wireless calls,” said the Boulder (Colo.) Regional Emergency Telephone Service Authority. “The first two are for wireless providers to consider jurisdictional boundaries in siting and cell sectorization decisions, and for providers to evaluate available data to determine which existing cell sites produce a high percentage of Phase I Misroutes. For sites identified to have a high percentage of misroutes, remedies are available and should be considered in consultation with PSAPs from (i) flagging for dispatchers calls from cell sites or sectors with high percentages of Phase I Misroutes, and low percentages of misroutes, (ii) modifying orientation of cell sectors, to implementing Phase II Routing or ‘Phase III Routing:’ routing calls based on a location technology which is more granular than Phase I Routing and can provide a TTFF [time-to-first-fix] of five-seconds or less.”

The filing continued, “The 9-1-1 system and services must accommodate a variety of location technologies which are suitable to different environments, or may be developed in the future. A 9-1-1 location technology should be secure, reliable and provide data in a format consistent with other location technologies. BRETSA raises the prospect of terrestrial GPS signals embedded in high power broadcast signals capable of penetrating buildings, or special purpose beacons. These terrestrial GPS signals would allow WiFi, Bluetooth or BLE access points or beacons to determine their coordinates and signal timing requirements, and in turn provide GPS signals to devices located in indoor locations. This would require Commission requirements or authorizations of the terrestrial GPS transmitters, as well as of devices which would utilize these signals to become GPS transmitters themselves.”

“Given the potential synergy between the various efforts the FCC has already enabled and the vast technologies at hand the FCC should simply replace the cell site based requirement with a device based routing requirement on a short time-line for implementation,” said Robert Oenning, former enhanced 911 administrator for Washington state. “The question is not if device location based routing can be done but rather how those in the industry who have already demonstrated an ability to collaborate on improving 911 services can be enabled to make it happen.   The action the FCC takes to move forward location based routing should be tempered to assure that the industry does not again get trapped again into retaining 911 methodologies well past the point where it is practicable to move toward improved systems.”

“As the wireless industry continues to deploy technologies that enhance location information about wireless 9-1-1 calls, the Commission is right to ask whether new technologies can also reduce the number of 9-1-1 calls delivered to PSAPs in neighboring jurisdictions,” CTIA said. “The Commission should use the record developed here to carefully weigh the costs and benefits of different policy approaches to improvements in wireless 9-1-1 call routing. For example, the Commission should assess the tradeoffs associated with different 9-1-1 call routing mechanisms, such as the potential for a general delay to routing all 9-1-1 calls. The Commission also should consider whether location-based routing solutions would be better suited for, and more easily implemented in, the next generation 9-1-1 (NG911) environment. Finally, the Commission should consider alternative methods that can prevent misroutes and/or help to mitigate the impact of misrouted 9-1-1 calls, such as encouraging additional coordination among PSAPs and by PSAPs with wireless providers.”

“Such alternative techniques can be implemented far more efficiently and effectively than wholesale, standalone changes to current routing mechanisms,” CTIA added. “Therefore, as part of this proceeding, the Commission should examine and draw attention to successful techniques that can reduce misrouted 9-1-1 calls, as well as those that can mitigate the impact of calls that are misrouted.”

T-Mobile US, Inc., said it “supports improving 911 call routing, utilizing emerging location technologies, and the transition to NG911 systems. The technological improvements capable of producing high-accuracy/low-latency locations that are becoming available for use in 911 solutions have been aggressively sought-after and are welcomed by all stakeholders. But today, the single most important contribution that public safety and the Commission can make in this regard is to encourage PSAPs to expeditiously make the transition to NG911, so that public safety and consumers can benefit from these technological advancements.”

T-Mobile added “that focusing limited resources in an attempt to add location-based 911 call routing to legacy 911 systems would offer a poor return for a very significant level of effort. T-Mobile instead proposes that the concerted effort to improve 911 call routing be directly associated with the transition to NG911 systems. T-Mobile is already taking steps to help encourage this transition and subsequent testing and refinement of such improved call routing methods. In this effort, T-Mobile believes all parties would benefit from a better understanding of the real-world trade-offs between minimizing the delay of 911 call placement, and the ability to more precisely route the call to the desired PSAP. Which of these parameters is the highest priority? How long is too long to delay a 911 call to improve the precision of call routing? With better insight into these types of system design trade-offs, and a concerted effort from all relevant stakeholders, there is a strong potential for improvement.”

“Based on trial experience, Verizon agrees that location-based routing is technically feasible and can mitigate (although not eliminate) the number of instances in which 911 calls are routed to PSAPs outside the caller’s jurisdiction,” Verizon Communications, Inc., said. “The Commission is thus right to seek input on the measures that wireless, Next Generation 911 (‘NG911’) providers, and PSAPs will need to undertake to ensure that consumers benefit from location-based routing of 911 calls.”

“Stakeholders will need to carefully allocate the roles and responsibilities of wireless service providers and state/local governments in deploying and maintaining LBR capabilities to ensure that LBR is deployed efficiently and effectively,” Verizon added. “Most important for consumers’ public safety needs, LBR should be implemented in manner that does not undermine the reliability of wireless 911 call routing. That, as a practical matter, will require the continued availability of cell sector-based routing for the foreseeable future. Finally, in the interim period, the Commission should support the use of existing best practices to improve and maintain the reliability of cell sector-based routing.”

The Voice on the Net Coalition said the CSRIC report “does not address the specific challenges faced by interconnected VoIP providers (and their third party 911 vendors) who may not have the same access to location information as CMRS providers. Notwithstanding the challenges, it’s likely that location-based technologies will provide more accurate and timely routing information for mobile VoIP 911 calls than the required registered location. By moving to a routing paradigm based on acquisition of a real-time location calculation, the FCC and industry standards bodies have the opportunity to significantly improve emergency calling services by routing mobile VoIP calls to a more appropriate PSAP. To the extent that location information can be used in a manner that rapidly and efficiently routes a 911 call to the most appropriate PSAP, VON believes there is great promise in leveraging these available technologies. There is much work to be done to effectuate a new emergency call routing paradigm, but the foundation is evident in the location capabilities available in the marketplace today.”

VON also asked “that the FCC take a broader view than simply the US market. While we recognize that the FCC’s authority does not extend beyond the US, the FCC can be a leader by encouraging the use of available technologies through consistent technical standards developed across the globe.”

“The location accuracy problems inherent with the routing of wireless 9-1-1 calls can be addressed by migrating to device-based hybrid location solutions, which combine data from various sensors on the user’s mobile device and provide the best information about the user’s actual location based on context and environment. Numerous test results confirm the viability of these device-based hybrid location solutions, which can provide more accurate location information on a more timely basis as compared to the legacy 9-1-1 routing architecture,” Motorola Solutions, Inc., said.

“The Commission should use this proceeding to explore the creation of incentives for deploying location based routing technologies. Such incentives should include sufficient and sustained levels of funding for Next Generation 9-1-1 (‘NG9-1-1’) deployments, of which device-based hybrid location solutions should be an integral part,” Motorola added. “Specifically, the Commission should explore the creation of incentives for: (1) ongoing testing and pilot activity validating improvement/benefits derived from location based routing technology; (2) PSAPs to use location based routing technology; and (3) the migration to NG9-1-1 and the use of location based routing technology at the state and local levels.”

“As the Commission recognizes, the path forward to achieve successful 9LBR [911 LBR] requires striking a balance between the industry’s concerns over disruption to existing processes and that of providing more accurate information more quickly to aid in essential lifesaving services,” Comtech Telecommunications Corp. said. “Indispensable elements along this path include, identifying and measuring the problem, consistent use of technical terms and operational processes, application of appropriate (existing or new) industry standards, specifically addressing the ‘delay of call’ issue, safeguarding the sources and destinations of location data, and promoting consistent and systematic testing of call and location data. Also, new entrants need to understand and accept that public safety operates differently than other business arenas. Public safety isn’t a game or a greenfield for the latest consumer product fad, it’s a highly regulated industry devoted to the public good. Serious vendors are encouraged, respected, and protected; less dedicated vendors may not be.”

Comtech continued, “While technological advancement brings new ways of solving difficult problems, much of today’s well-meaning progress is being promoted in a vendor-specific, proof-of-concept approach that competes with the time-tested and more inclusive public safety coordinated, and standardized approach. While Comtech shares in the desire for innovation, some of the current side effects experienced in the fray to overturn the ‘status quo’ of what is today’s emergency location processes include[:] lack of common goals, the inability to verify results, unanswered questions around whether there is statistical significance, and unknowns as to whether these experiments are replicable.

“Wireless 9-1-1 location based routing is not a panacea for all of 9-1-1’s ills, and the quest for 9LBR cannot impede the goal of maintaining reliable wireless 9-1-1 calling. It is imperative that for 9-1-1, we achieve consistent, reliable methods and solutions, avoiding at all costs, experiments that potentially jeopardize ‘live’ 9-1-1 calls without carrier and FCC notification,” Comtech concluded.

West Safety Services, Inc., said it “has experienced encouraging test results for handset-initiated location technologies that utilize device-based hybrid location information. Unlike network-initiated technologies, calls to 9-1-1 over these handset-initiated technologies do not have to traverse complex carrier networks or wait to reach the carrier’s routing element before initiating the process for location determination. West Safety believes these handset-initiated location technologies offer promise for significantly reducing the PSAP transfer rate. West Safety cautions the Commission, however, that carriers should maintain control over any implementations of device-based hybrid location solutions. Permitting third-party applications to deliver locations directly to PSAPs without interconnecting to the carrier’s routing element should be avoided. Carriers are in the exclusive position to ensure location uniformity, security, reliability and validation under centralized Commission oversight and clear jurisdiction.”

NextNav LLC said that the FCC “should ensure that any location-based routing solution that is employed for E911 calls incorporates adequate backup protection in scenarios where a technology might be used by a wireless carrier for location compliance, but fails to timely achieve an accurate fix in all instances. For example, in those cases in which a carrier employs A-GPS, other location technologies should be available to support the routing of calls originating from indoor locations where A-GPS may not produce a location fix. In addition, if a DBH [device-based hybrid] approach is used, consideration must be given to whether the resulting location information is sufficiently reliable to support call routing, particularly in communities and neighborhoods where broadband penetration is low (such as in low income areas), where Wi-Fi devices may be subject to frequent relocation (such as college dorms or apartment complexes), or in cases in which individuals may have turned off the location functions on their wireless handsets due to privacy concerns.”

NextNav also said that its location technology could be deployed to quickly ensure that 911 calls are accurately routed to the correct PSAP.

LaaSer Critical Communications said it “has created patented technology that pinpoints a 911 caller’s location using any mobile device, efficiently routes them to the appropriate Public Safety Answering Point (PSAP), and provides the emergency operator and responders with precise location information.” It said “that the answer to the question ‘what is the best way to avoid delays’ caused by ‘misroutes’ is inclusion of DBH location within the existing wireless carrier routing systems. Such a deployment leverages the best of what DBH has to offer, ensures that routing improvements are only ever additive with existing systems providing a consistent and reliable base level of performance, allows for ubiquitous PSAP availability, and is available in current-state environments, NG911 environments, and transitional environments.”

Precision Broadband LLC described its prototype fixed broadband 911 location and routing system and said that “[b]y utilizing fixed broadband for 911, state governments would be justified, and legally empowered, to assess 911 fees on home broadband service (as is done today on landline and mobile phone service). When applied to the 106 million US broadband households, an additional $1 billion annually could be collected for 911 services. These fees, along with revenues from new entrants in the 911 market, could be used to implement the solutions being developed by Precision Broadband and other market participants as well as expediting the deployment of NG911 technologies.”

Onvoy LLC (d/b/a Inteliquent) said it “appreciates and supports the Commission’s efforts to solve the very real problem of wireless 9-1-1 call misroutes due to the outdated cell-tower-based call routing system. Inteliquent’s experience counsels that device-based solutions are the way forward to delivering fast and accurate location information to the correct PSAP at the outset. Inteliquent is already working with its partners on developing such a solution, and looks forward to real-world testing of the solution later this year. Any steps taken by the Commission should facilitate and encourage device-based location routing for 9-1-1 calls, and avoid solutions that rely on centralized databases that are costly to update and maintain at the level necessary for use in emergency services.”

Mission Critical Partners LLC encouraged the FCC “to promote the uniform adoption of location-based routing technologies, especially with universal transition to Next Generation 911 (NG911). Particularly, the Commission should encourage the implementation of Advanced Mobile Location (AML) or the vendor-specific variations, e.g., Emergency Location Service (ELS), a proven life-saving technology. MCP believes the Commission can support the implementation of location-based routing by removing liability barriers that could be raised by the Commercial Mobile Radio Service (CMRS) providers and NG911 solution providers for using third-party location.”

Charity Feb of Camas, Wash., whose 911 call about her husband, who had a fatal heart attack in 2012, was routed in Portland, Ore., thanked the FCC for launching its proceeding. – Paul Kirby, paul.kirby@wolterskluwer.com