NYPD Says FCC Should Keep 2007 E-911 Location Accuracy Rules
The New York Police Department urged the FCC to reject E-911 location accuracy plans from AT&T and Verizon Wireless and keep rules the FCC approved in September 2007, triggering a court challenge by wireless carriers. “The accuracy of location information is critical to emergency response,” the NYPD said. “Absent a compelling reason to change the existing standards, they should be maintained.” The Court of Appeals for the District of Columbia Circuit issued a stay of the original rules in March, and in August the FCC told the court it would propose revised standards.
Sign up for a free preview to unlock the rest of this article
If your job depends on informed compliance, you need International Trade Today. Delivered every business day and available any time online, only International Trade Today helps you stay current on the increasingly complex international trade regulatory environment.
APCO and NENA should clarify their shifts from positions endorsing the earlier standards, the NYPD said in comments. “The NYPD opposes any change to either the accuracy or compliance requirements or the implementation timetable,” it said. “The NYPD is deeply concerned by the position taken by APCO International and NENA, who both previously supported the existing accuracy requirements.”
The proposals drew continuing criticism from T-Mobile and the Rural Cellular Association. They also were panned by the Rural Telecommunications Group, which questioned whether small carriers can could meet even the revised standards.
T-Mobile and RCA said AT&T, Verizon Wireless and the public safety groups have crafted plans that “helped move the process forward toward a lawful resolution” of many tough issues. But, they noted, just because the plan works for AT&T doesn’t mean it addresses smaller carriers’ concerns. It’s “not surprising” that the AT&T plan “reflects its unique starting point as the only GSM carrier to have launched a 3G network and A-GPS handsets prior to this year, as well as its cell site density, local topography in its service areas, network designs, anticipated customer mix, and resources as the nation’s largest wireless carrier,” they said.
“The proponents provide no evidence that such standards are achievable using current technology,” RTG said of both carrier proposals. “The Commission has repeatedly found in this proceeding that imposing location accuracy standards based on a hope that evolving technology will make compliance possible results only in the need for waivers, extensions or rule modifications. It should not make the same mistake again.”
Sprint Nextel can accept the rules for CDMA networks worked out between Verizon Wireless and public safety, it said. Sprint noted that under the plan carriers would have to conduct “far more compliance tests, at significant additional costs” because accuracy measurements would have to be made in much smaller geographic areas -- each of the 2,100 counties it serves. Sprint in general would have to meet a more rigorous location accuracy benchmark. But the carrier said it supports the proposal “notwithstanding these new burdens” it faces.
“Sprint recognizes public safety’s need to have a better granular understanding of network operations and the desire to impose an accuracy standard that presses carriers to achieve the maximum accuracy capable, while recognizing the limits of technology,” the company said. “The proposed standard strikes a careful balance on these issues.”
At this point the standards should not apply to emerging wireless providers of mobile or portable interconnected VoIP service, the Wireless Communications Association said: “At bottom, any change in the Commission’s current location accuracy requirements for emerging facilities-based interconnected VoIP providers would be a leap of faith with no foundation in the record.”