APCO, NENA Offer Olive Branch on E-911 Location Accuracy Rules
APCO and the National Emergency Number Association are backing down from demands for what carriers have insisted were unrealistically tough requirements in E-911 location- accuracy rules approved by the FCC in 2007. APCO and NENA said in a letter to the FCC they would be comfortable changing a central requirement approved by the commission at a special Sept. 11 meeting.
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The FCC required that within five years carriers be able to determine the location of wireless emergency callers with 95 percent accuracy -- within 150 meters for carriers with handset-based solutions and within 300 meters for those with a network-based solution (CD Sept 11 Special Bulletin p2). Carriers would have to satisfy this requirement for each public-safety answering point rather than by averaging results across a state.
The Rural Cellular Association, T-Mobile, Sprint-Nextel, Verizon Wireless and AT&T went to court to fight the order. In March, the U.S. Court of Appeals for the District of Columbia Circuit stayed the order.
“We recognize that satisfying this requirement at a PSAP or county level is especially difficult for many carriers due to variations in geography and system deployments,” APCO and NENA said. “Thus, the Commission may want to consider either reducing the percentage of 911 calls from 95 percent or increasing the 150/300 meter metrics.”
APCO and NENA said they would be willing to measure wireless E-911 accuracy by the county instead of the PSAP. “In part, this reflects the changes that are occurring in the PSAP community, as some communities are consolidating 911 centers, and others are changing PSAP geographic boundaries to match county boundaries,” the letter said. “Counties, unlike PSAP service areas, also reflect a stable geographic area and would be a more appropriate regulatory criteria.” The groups also suggested that the FCC allow waivers on counties where carriers can’t meet the requirement. “For such waivers, the Commission should identify factors for consideration such as technical limitations, whether the carrier is meeting network optimization criteria and whether it is maintaining state of the art capabilities for its chosen location technology,” the letter said.
David Nace, counsel to RCA, told us the group is pleased in general that APCO and NENA recognize the “feasibility problems” faced by wireless carriers in providing location information to PSAPs, especially rural ones. “It appears that progress is being made, although RCA has concerns with the suggestion that a rule waiver would be needed in every instance where it is not technically feasible to meet accuracy standards for a county,” Nace said. “Carriers cannot be put in a position of non-compliance with FCC rules unless and until a rule waiver is granted. RCA is hopeful that further progress can be made in talks with APCO and NENA on this issue and that the FCC’s rules will be modified to reflect the practical limitations of meeting any accuracy standard.”
“I wouldn’t view it as their backing down,” said a wireless carrier official. “They're some efforts to see if there’s some middle ground. This sort of reflects part of that… Right now the fact that the stay is in place provides some breathing room to see if something can be worked out.” - Howard Buskirk