Carriers Say Tougher E-911 Standard Impossible with Current Technology

“The whole history of 911, going back to 1994 when the docket was opened, is that the Commission has gotten out ahead of technology because they want to do the right thing and then it leaves not just carriers but PSAPs struggling to live up to the expectations,” said an industry attorney. “At the end of the day there’s going to be testing. Why shouldn’t there be testing at the beginning of the process, to demonstrate the commercial availability of these technologies?”

GSM and CDMA carriers face different issues, industry sources said. GSM-based E-911, dependent on triangulation of cell towers to locate a caller, works well in urban environments but not in rural areas, especially when towers are in a straight line along a highway. A CDMA solution, based on GPS technology in handsets, functions well outdoors when a device can be tracked using three or more satellites. But CDMA falters inside buildings or urban canyons without clear exposure to the sky.

CTIA said wireless carriers have made significant progress in their ability to locate emergency calls. “The Commission must recognize that, as before, any possible changes to E-911 location requirements will necessitate changes to wireless networks and handsets,” the CTIA said. “These changes require time to identify, develop and implement.” Requirements have not been set for the number of testing points, testing criteria and determination of ground truth.

CTIA also warned the FCC that it could be opening carriers to significant liability. “The civil tort standard for a carrier’s duty of care in processing 911 calls, which, by their very definition, involve threats to life and property, may be based on the commission’s rules,” the association said. FCC action may even cut off capital, since financing depends on carrier compliance with agency rules. “To avoid such risks and, more importantly, to allow wireless carriers and their suppliers sufficient time to develop, test, and deploy advanced technologies to comply with a new standard, the commission should not require compliance with any new accuracy standard until the commission has a full record before it and is confident that the implementation of any standard it sets forth is readily achievable,” the CTIA said.

The CTIA and AT&T called for a special industry forum -- made up of engineers and other technical experts from the FCC, public safety, handset vendors, carriers and elsewhere - - to examine the best method for making wireless E-911 more reliable. They suggested modeling the group on the Commercial Mobile Service Alert Advisory Committee established by the Warning, Alert and Response Network Act to examine emergency alert service warnings on cell phones. AT&T said no evidence has even presented to show that a PSAP-level measure is possible across more than 6,600 PSAPs. “Nor, of course, is there any record evidence as to how much that would even cost if it were feasible,” AT&T said. “AT&T’s own analysis indicates that the costs would be staggering.”

Other carriers, large and small, also objected to PSAP-level testing. Sprint Nextel noted that no standard for PSAPs exists and no one can even say with certainty how many exist. “A ‘PSAP’ can be as small as a one or two cell sectors or as large as an entire state, with radically different topologies and population densities,” Sprint said: “Moreover, ‘PSAPs’ can change geographic coverage areas, vary in shape, or cease to exist all together. Adding such an ambiguous and amorphous concept to a technical standard would result in no standard at all.”

SunCom Wireless said the new standard could prove “financially disastrous” and drain resources that could be better spent elsewhere to make E-911 calling more reliable. “SunCom serves several sparsely populated rural areas that contain very few cellsites at the PSAP level, including some PSAPs that may contain no more than a single tower site,” it said. “SunCom would be required to deploy new facilities, including tower sites and base stations utilizing new sensors, repeaters, and other equipment arrays.”

Motorola and Nokia agreed with carriers, contending in joint comments that PSAP-level testing would be extremely difficult and expensive. “There are two major problems with the commission’s proposal to require PSAP-level location accuracy,” they said. “First, testing accuracy at a PSAP level would result in significant operational and financial challenges for the industry as well as for PSAPs. Second, implementing a solution that would universally generate PSAP-level accuracy would be extremely difficult to achieve.”

But APCO told the FCC that since most 911 calls to many PSAPs are from wireless phones, accurate location information is more important than when APCO asked for PSAP-based testing in 2004. “Unlike wireline calls, wireless calls are not transmitted with exact street addresses, so PSAP call-takers must ascertain precise location information from the caller,” APCO said. “At best, that causes delay. At worse, it leaves the call-taker in the dark if the caller is unable to describe their location. Examples are numerous, and include callers in emotional or medical distress, hostage situations, poor wireless connections, language barriers, or simply because the caller does not know their exact location (a common issue with vehicle accidents, travelers, lost hikers, etc.).”

The National Emergency Number Association (NENA) said it supports PSAP-level testing in general, but the FCC should hold off enforcement to give carriers time to come into compliance: “This position is taken with an understanding that all 911 callers deserve to have their call located as accurately as possible and expect a comparable level of service regardless of where they are calling from or the device or service they are using. NENA believes that elemental fairness demands suspension of enforcement of this requirement for a reasonable period because it is new and the timing for its attainment uncertain.”

VoIP operators are in a worse position than wireless carriers if they have to meet a tougher location standard, said the Voice on the Net Coalition. It was responding to a request in the FCC’s May rulemaking for comments on whether PSAP testing should apply to interconnected VoIP operators. “By seeking comment on the applicability of a PSAP-level testing standard to interconnected VoIP providers, the commission is putting the cart before the horse,” the group said. “Despite the success of the interconnected VoIP industry in providing E-911 services, VoIP providers do not have the same several-year experience with location accuracy testing and reporting as the CMRS industry.” Howard Buskirk