Stakeholders Work To Discern Details of 911 Accuracy Order

Stakeholders are working to learn the details of the draft 911 location accuracy order that was circulated to FCC Commissioners yesterday for tentative consideration at their Jan. 29 meeting (TRDaily, Jan. 8).  The draft item would incorporate provisions from a third further notice of proposed rulemaking released early last year (TRDaily, Feb. 20, 2014), as well as from a road map endorsed by the four national wireless carriers, the National Emergency Number Association, and the Association of Public-Safety Communications Officials-International, sources said.

For example, the item would mandate both horizontal and vertical milestones, sources said. While the draft order would extend the FCC’s proposed deployment milestones a bit, it proposes accuracy thresholds of 50 meters for horizontal calls and 3 meters for vertical calls.  Carriers would be permitted to use dispatchable location to meet the requirements, but if that does not work, the mandates would still have to be met using other technologies. The order also would incorporate the use of some live call data to measure benchmarks, as proposed by the road map. And it supports the road map’s test bed component.

Specifically as to the deployment milestones in the draft order, after three years 50% of all non-satellite-generated horizontal location fixes would have to be by dispatchable location or within 50 meters. After six years, 80% of non-satellite-generated horizontal location fixes would have to be by dispatchable location or within 50 meters, and 80% of such vertical fixes would have to be by dispatchable location or within three meters, according to a source.

Sources said that by removing satellite-assisted calls from measurements, the FCC is hoping to isolate performance for indoor calls. However, one source said that approach will make it much more difficult for carriers to provide accurate location fixes.

In its third further notice, the FCC proposed to require wireless carriers to locate 911 callers horizontally indoors within 50 meters for 67% of calls within two years and for 80% of calls within five years. For vertical location, carriers would have to locate callers within three meters for 67% of calls within three years and for 80% of calls within five years.

In the road map, carriers committed “to obtain a location fix using ‘heightened location accuracy technologies’ for the following percentage of wireless 9-1-1 calls from the date of the Agreement consistent with Section 4(a),” which is based on live call data: “i) 40% of all wireless 9-1-1 calls within two years; ii) 50% of all wireless 9-1-1 calls within three years; iii) 75% of all VoLTE wireless 9-1-1 calls within five years; and iv) 80% of all VoLTE wireless 9-1-1 calls within six years.

“Wireless 9-1-1 calls that originate from ‘heightened location accuracy technologies’ are calls with fixes for A-GNSS (GPS and/or GLONASS), dispatchable location, and the proportion of calls from any other technology or hybrid of technologies capable of location accuracy performance of 50m using a blended composite of indoor and outdoor based on available data from a test bed and/or drive test performance,” according to the plan.

The road map does not commit carriers to a specific vertical accuracy metric and says signatories of the agreement will work on such a metric.

The draft order circulated yesterday also is believed to propose requiring carriers to address privacy and security concerns, while not imposing prescriptive rules, a source said.

Harlin McEwen, chairman of the Communications & Technology Committee of the International Association of Chiefs of Police, which is one of several major public safety groups to voice concerns with the road map, told TRDaily today that he is pleased that FCC Chairman Tom Wheeler is taking into account issues raised by his group and others. “I think what he’s trying to do is balance the road map proposals with our concerns,” Mr. McEwen said of Mr. Wheeler.

Critics of the road map have complained that there are too many unknowns, holes, and loopholes in the plan. For example, they have accurately noted that it would not commit carriers to actually deploy dispatchable location, includes weaker milestones than the FCC’s proposals, does not require robust indoor accuracy because of a blended outdoor/indoor framework, does not require a vertical solution, and would rely on Wi-Fi and Bluetooth technologies that haven’t been used to enable the deployment of public safety services.

In a blog posting today, Jeff Cohen, APCO’s chief counsel-law and policy and director-government relations, touted what he said are key benefits of the road map.  “The time for all stakeholders to join APCO and its Roadmap partners to aggressively pursue and implement nothing short of a dispatchable location solution is right now.  It is time to break public safety out of the cycle of substandard proprietary solutions trailing technological advancements enjoyed in the consumer marketplace. It is time to depart from position estimates that are increasingly successful outdoors but inside buildings can leave responders searching for those who need help,” Mr. Cohen said. “Chairman Wheeler is helping to set us on this path. We will look forward to reviewing his proposals.  Any ideas that would make the Roadmap even more effective, including reaching our gold standard of dispatchable location, will be most welcome.”

In a related development, ATIS today announced the establishment of a new Emergency Location Task Force (ELOC) to support standards development needed for the road map. “ATIS’ previously completed work identifying six geographic test regions will be used as the basis for the collection and reporting of data for live wireless 9-1-1 calls,” the group said in a news release. “In support of the ELOC, ATIS will continue to identify recommendations for establishing wide-scale indoor location performance, similar to work it had previously undertaken in support of the FCC’s Communications Security, Reliability, and Interoperability Council (CSRIC).” – Paul Kirby, paul.kirby@wolterskluwer.com