NRIC Subcommittee Agrees On E911 Location Accuracy Requirements

The issue proved controversial, as the Focus Group on E911 Near Term Issues told the Council last Dec. it couldn’t reach agreement (CD Dec 7 p1). NRIC then asked the FCC for 60 days to do so; the FCC agreed. The Council has 2 weeks to vote on the recommendations, which, once adopted, will be presented to the FCC.

“Accuracy testing will be conducted on a statewide basis,” said focus group Chmn. Mary Boyd. “Given the current state of location technology, it is understood that the FCC accuracy rules will not be met at every PSAP,” the report said: “Thus, we have reached a consensus that FCC compliance will be measured at the state level.” The report noted that PSAPs, states and others “may seek FCC relief in the event they reasonably demonstrate non-compliance with the FCC accuracy rules.”

APCO strongly opposed the report, calling it “a threat to the public’s safety.” “APCO International remains puzzled by an assertion that there should be no expectation for the accountability of accuracy at the local level,” APCO Acting Pres.-Elect Wanda McCarley told NRIC members Tues.: “For better or worse, Phase II services are requested at the local level… contracts between wireless carriers and PSAPs are initiated at the local level. Phase II services are deployed at the local level. Phase II services are utilized at the local level and responses to calls are initiated at the local level.”

APCO voted no last month when the report was presented within the focus group. In Oct., it filed a petition for declaratory ruling with the FCC asking that wireless 911 accuracy testing be required at the local community level (CD Oct 6 p7). FCC officials have indicated they would wait for NRIC recommendations before determining when and how to address the APCO petition.

The focus group recommended rural carriers meet accuracy levels attained by Tier I and Tier II carriers operating in the same coverage area. Carriers agreed to certify compliance to the FCC at the state level using ESIF/OET based testing methods when Phase II deployment meets defined thresholds. The report said: (1) All parties agreed to maintenance testing concepts with specific methods and procedures, including accuracy verification, to be further defined by ESIF. (2) Carriers agreed to provide representative performance characteristics for various topographical areas. (3) Carriers agreed to make test data available to the FCC and Public Safety on request if confidentiality can be kept. (4) All parties agreed to specified percentages of test calls to be conducted from indoor locations for compliance and maintenance testing. (5) It was agreed that test equipment should be typical of equipment used by ordinary customers. (6) All parties agreed that wireless carriers will provide, and E911 SSPs shall pass, confidence and uncertainty estimates in accordance with standards being developed by ESIF. The group urged that accuracy testing results be reported at the state level to the FCC, and that testing begin within 12 months of the FCC adoption.

APCO’s McCarley said group’s final discussions didn’t address fundamental issues in a way acceptable to the public safety community. Specifically, she said, APCO worried about the report’s definition of the compliance testing and reporting footprint, the method and guideline under which test data would be made available to public safety agencies, the definition of the nature and frequency of testing, reporting and certification after initial compliance, and the delivery, accuracy and consistency of confidence and uncertainty.

NENA Pres. Bill McMurray strongly supported the report’s recommendations, which he said would “serve to improve the delivery of Enhanced 911 services.” “The majority consensus was achieved through considerable dialogue as the stakeholders wrestled with the very serious issues of accuracy and reporting processes and requirements,” he said: “NENA believes that the resulting report before you today is more than just acceptable; it represents a comprehensive and interconnecting set of requirements that will guide industry and government. The unique approach to improve the value of information to the 911 call taker cannot be underestimated.”