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‘Premature’

CTIA Asks FCC to Hold Off on Further Changes to Location Accuracy Rules

"Any additional action” by the FCC imposing even tougher E-911 location accuracy rules for wireless is “inappropriate at this time,” CTIA said in comments filed at the commission. The FCC sought comment on enhancements to its rules when it approved tougher location-accuracy standards Sept. 23 (CD Sept 24 p6). Other wireless carriers agreed the FCC should allow for more time before imposing additional rules.

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"The Commission only recently required wireless providers and manufacturers to develop and deploy equipment and infrastructure to support the newly promulgated E911 location accuracy requirements,” CTIA said. “The wireless industry should be provided the time needed to implement these new rules and benchmarks for enhanced E911 location information prior to the Commission again revising these requirements."

AT&T called a further rulemaking “premature” since the FCC just imposed tougher standards. The revised rules “will necessitate significant investment and impose operational challenges for wireless providers” over the eight-year implementation period,” AT&T said. “In light of these new requirements, the Commission should refrain from further modification of the 911 and E911 rules and enable carriers to focus on satisfying the demanding location accuracy requirements the Commission just adopted."

"Successful implementation” of revised location accuracy rules “will require substantial focused efforts and needs to be the centerpiece of improvements in E911 over that time period,” T-Mobile said. Any additional changes should be based on recommendations by a “consensus-based group comprised of representatives from the industry and public safety community,” Sprint Nextel said. But the FCC should “take into account the valuable time and resources carriers and manufacturers have invested in making the existing E-911 system a reality,” the carrier said.

But the Association of Public-Safety Communications Officials and the National Emergency Number Association said in separate comments that the FCC should be able to impose tougher requirements as the data available to carriers improves. The Communications Security Reliability, and Interoperability Council is preparing a report on existing and prospective location technologies, APCO noted. “In general, we urge the Commission to require that communications providers adopt the very best location technologies available in the most expeditious manner feasible,” APCO said. “The state-of-the-art has advanced significantly over the last ten years and those advancements should be implemented as soon as possible."

The commission should also impose requirements to ensure that a wireless subscriber’s location can be determined “to a minimum degree of accuracy while roaming on any compatible network,” NENA said.