Carriers Tell FCC They're Committed to Improving Wireless 911 Location Accuracy

The FCC can accomplish the most by “supporting and learning from the efforts” of its Communications Security, Reliability and Interoperability Council on better 911 location accuracy, Verizon said (http://bit.ly/16tkMi4). “That group has been expressly tasked with establishing a permanent public test bed that will provide the Commission ‘with regular comprehensive, unbiased and actionable data on the efficacy of location technologies.'” Verizon has had a “longstanding, demonstrated commitment to improving location accuracy and public safety for its customers, and this commitment applies to Phase II accuracy as well,” the carrier said.

While much has been made of the explosive growth in the number of indoor 911 calls on cellphones, carriers don’t have data on the origination point of emergency calls, AT&T said. “Not all indoor locations are equal, and not all indoor calls are equal,” the carrier said (http://bit.ly/190f7QK). “For example, a call from a single family dwelling may be just as accurate as an outdoor call. Or a call from an office building made close to a window may be as accurate as well. There are simply too many variables at play to make constructive statements of broad applicability. That said, however, there have been no comprehensive studies that confirm the supposition that there has been an increase in the number of wireless calls being placed from indoors. And, to AT&T’s knowledge, there hasn’t been any study showing a decrease in wireless Phase II location information provided to” public safety answering points.

"In some cases, T-Mobile believes that confusion over the state of wireless 911 location technologies may stem from imprecise use of key terminology,” the carrier said (http://bit.ly/194ps89). “The Commission must ensure that all stakeholders understand and are correctly using those terms, in order to avoid misunderstanding. For instance, T-Mobile has noticed that some commenters use the terms ‘accuracy,’ ‘yield,’ and ‘uncertainty’ loosely or interchangeably, making it difficult to know what problem they are trying to solve. Dialog on all of these issues will be most productive if all parties are assured that ... terminology is being used uniformly.” T-Mobile also supported the work of CSRIC. “The CSRIC Working Group 3 Indoor Accuracy Test Bed was a significant step forward, allowing three location technology solutions to be examined side-by-side with respect to their indoor performance,” the carrier said. “However, as CSRIC Working Group 3 itself concluded, further standardized testing is necessary. This should especially include technologies that either withdrew from the Working Group 3 test or were not yet available.”

CTIA’s comments were similar to those of its carrier members. “CSRIC has already launched the next phase of its Test Bed initiative, and the FCC should support widespread participation -- including by all interested vendors -- to enable side-by-side comparisons and verifiable data,” CTIA said (http://bit.ly/18rT57e). “As AT&T observed, ‘Phase II location information is not pushed by wireless carriers all the way to the PSAP.’ Indeed, the Commission does not require it to be. Commission decisions ‘establish a specific demarcation point between wireless carrier and PSAP responsibilities.'"

The National Emergency Number Association said its members have noted a “decrease in the fraction of wireless calls for which Phase II location data is available early in the call” and urged the FCC to take steps to make some limited changes to its location accuracy rules. “The Commission’s existing E9-1-1 wireless location accuracy rules have served the public and the public safety community well over the past decade, and have been the driving force behind billions of dollars of infrastructure, hardware, and software investments by wireless service providers, platform vendors, and handset developers,” the group said (http://bit.ly/1bIIyrE). “NENA therefore does not believe that those rules should be subject to wholesale revision. Given all of the remarkable technological advances described above, and the categorical findings of the CSRIC test bed, NENA believes that the Commission should immediately open a proceeding to address three essential tasks: a minor revision of the existing E9-1-1 wireless location accuracy requirements to more carefully and completely describe carriers location performance obligations; the phase-in of a z-axis performance requirement; and the introduction of an indoor location accuracy standard.”