January 20, 2015

FCC Staff Entry in PS Docket No. 07-114  (In the Matter of Wireless E911 Location Accuracy Requirements)

Since the release of the Third Further Notice of Proposed Rulemaking in this docket on February 21, 2014, the Commission has received a large number of e-mail communications from individual members of the public. We hereby document these communications for the record.

1. In July – October 2014, the Commission received approximately 9,297 e-mails identical or substantially identical to the following:

“Dear Federal Communications Commission,

Emergency responders and 9-1-1 professionals face the tragic daily challenge of trying to find callers who do not know, or cannot share, their locations. To address this crisis, the FCC proposed a rule that offers a reasonable and achievable two-year path to indoor location accuracy for wireless 9-1-1 calls. Nearly every major public safety organization has since endorsed the FCC’s proposed approach. The nation’s 9-1-1 professionals have made clear that they are strongly opposed to any wireless carrier deal, with 99% of 9-1-1 managers and staff calling the rule “critically” or “very” important for public safety in their communities, and 97% opposing any delay in its implementation, according to a recent survey. The FCC estimates 10,000 lives per year could be saved with the rule. Any effort to delay the implementation of this lifesaving rule will cost thousands of additional lives. No more talking, no more testing, we need action. Please reject any deal delaying 9-1-1 location accuracy requirements.”

2. In October 2014, the Commission received approximately 35 e-mails identical or substantially identical to the following:

“Dear David Simpson,

“I want location accuracy to work on all wireless calls to 9-1-1. Lives are lost with each passing day. Your efforts to move quickly on this are very much appreciated by those of us on the front lines of public safety. Please keep moving forward and adopt the rule as proposed to require accurate 9-1-1 location from all wireless phones within two years.”

3. In November-December 2014, the Commission received approximately 379 e-mails identical or substantially identical to the following:

“I am writing to urge you to oppose the carrier-backed proposal on wireless 9-1-1 location. It is not a consensus agreement and is not supported by those on the front lines of 9-1-1 and public safety, who want to see real improvement now. “The terms of this so-called deal are a travesty for public safety and a tragedy for anyone who depends on a wireless phone in case of emergency. The carrier-backed proposal delays implementation of robust accuracy requirements for years longer than the FCC’s proposed rule, offers no vertical accuracy standard or timeline, and abandons millions of users of existing 3G or 4G phones by focusing only on future handset design. “Please do not accept the deal as proposed by the wireless carriers. Don’t make the job of saving lives harder than it already is.”

4. On November 27, 2014, the Commission received two e-mails with the following message, under the subject heading, “Accept the deal”:

“I am writing to urge you to accept the carrier-backed proposal on wireless 9-1-1 location. Don’t make the job of saving lives harder than it already is. Instead of making it the responsibility of the 911 center to determine where the caller, The (sic) phone companies need to display to the caller where they are so they can tell 911. I’ve been in this job a long long time and it’s just crazy how lazy people have become because of cell phones. they (sic) don’t even know their home addresses!! Do not force more technology onto the 911 center. or (sic) if you do, make damn sure it works because what is out there now is not reliable.”

5. In January 2015, the Commission received over 1,000 e-mails identical or substantially identical with the following message, under the subject heading, “Don’t Compromise on Public Safety”:

“I am writing to urge you to oppose the phone companies’ attempt to delay real and enforceable requirements for accurate 9-1-1 locations. The technology exists today to find all wireless 911 callers, so we should require phone companies to find the location of indoor and outdoor callers within the next two years, as your original rule proposed. To make sure any new rules are enforced, please also require the phone companies to share all of their location metrics and data about 911 calls with the FCC and the public, so we can measure their success and enforce the rules that you put in place. Please do not accept the delay proposed by the wireless carriers or their promises that an untested future system will solve all of our problems. Lives depend on your continued commitment to adopting the specific and enforceable requirements in your proposed rule.”