Questions Expected, Member Concern Possible, as FCC Votes on Z-Axis Rules Next Friday

Vertical location data would help 911 call takers, but it may not be useful to dispatchers in the form the FCC plans to require, local 911 officials said in interviews this month. Supporting the plan, National Association of State 911 Administrators incoming Executive Director Harriet Rennie-Brown (see 1911130032) responded, “We have to start somewhere.”

Commissioner Jessica Rosenworcel dissented on a March Further NPRM proposing the standard because of concerns whether it would do any good (see 1903150067). Commissioner Geoffrey Starks voted for part of the FNPRM and concurred on part. He's weighing arguments, industry and agency officials said. Everyone involved got extra time when this coming meeting was delayed three days. Commissioner Mike O’Rielly said in March that he wished technology would allow more specific coordinates. The agency didn't comment Wednesday.

APCO's leading opposition. APCO reported, posted Wednesday in docket 07-114, on meetings with Rosenworcel, Commissioner Brendan Carr and an aide to Starks. “Absent a more comprehensive approach to the z-axis metric and the location accuracy rules, carriers could comply with the rules without ensuring that public safety professionals receive actionable information,” APCO said: “At a minimum, the Commission’s Order should require that an estimated floor level be included as part of the z-axis information provided to emergency communications centers and ensure that the accuracy requirements defined in the metric translate to real-world performance.”

Richard Napolitano, commander of the New York Police Department Communications Division, told the FCC information carriers would provide wouldn’t help first responders. A “raw vertical estimate is of little operational value if it is relative to ‘height above ellipsoid,’” he said. First responders don’t necessarily carry devices that measure that distance and 911 centers don’t have the resources to create 3D maps they would need, NYPD said. At least require a floor-level estimate, NYPD said.

Draft backers include the International Association of Fire Chiefs, International Association of Fire Fighters, International Association of Chiefs of Police, National Sheriffs' Association and National Association of State EMS Officials. “A three meter z-axis metric not only provides emergency responders with actionable location information, but it also gives the public greater assurance that when they dial 9-1-1 from their cell phones, emergency responders can find them more quickly,” the groups announced. The National Public Safety Telecommunications Council also supports the order.

Tweaks

The order could change between now and the meeting.

FCC officials said revisions are unlikely to be proposed before the start of the sunshine period Friday. That period bars lobbying. One area that could have changes is language on privacy, officials said. The FNPRM was tweaked to ask additional questions.

Apple raised continuing concerns in a meeting with an aide to Chairman Ajit Pai. “Consumers should not have to choose between 911 and privacy,” Apple said. It asked that the order's privacy language be tightened to assure that information collected be protected. Apple suggested the order state “providers must certify that neither they nor any z-axis technology vendor they rely on to obtain this information will use the information or associated data for any non-911 purpose, except as otherwise required by law, and that they will not require or permit disclosure of a user’s precise location to any z-axis technology vendor.”

Public Knowledge said Wednesday the FCC is right to consider privacy in the order. “We thank Chairman Pai for clarifying that enhanced geolocation information collected for 911 purposes requires the highest degree of protection by carriers,” said Senior Vice President Harold Feld.

“Done right,” z-axis will be a “game changer,” but distance above ground or sea level is tough to use and could lead to costly mistakes, said Marshall County, Kentucky, E-911 Director Christopher Freeman. “It’s better than nothing.” The data isn’t helpful if dispatchers don’t know how to use it, he said.

Useful Information

Those on the ambulance, fire and police dispatch front lines want more, they told us.

There’s no point sending dispatchers “information we can’t use,” said District of Columbia Office of Unified Communications Director Karima Holmes. “I can’t see it making a difference in how we take the calls.”

A dispatchable location means knowing the floor number, Holmes said. Calls happen fast, and “you don’t want a 911 call taker having to plug in 20 numbers” when the caller might be on “the cusp of their life,” she said. Call takers sometimes are giving CPR instructions over the phone, and it would be tough to simultaneously convert a meters-above-ground metric into a dispatchable location, she said.

Knowing the right floor could be “the difference between life and death,” said Lora Ueland, executive director of Valley Communications Center in Kent, Washington. Cellphones send more than 80 percent of calls to Ueland’s call center in the Seattle area, which has many buildings with multiple floors, the 911 official said. If the incident is a fire or shooting, “getting to the wrong floor number is death.”

Getting a vertical location within 3 meters is acceptable, but if call takers get a figure “like 40 meters above median sea level, we’re going to have to somehow translate that into something meaningful,” said Ueland. Call takers wouldn’t ignore the data, but “they would be scrambling” to decipher it, and “that takes time from putting the incident in for dispatch and getting first responders to the scene,” said the 911 official: “Seconds truly count.”

Call takers must know building codes and convert meters to feet, since they don’t have an app that can automatically take the number and spit out a floor number, said Marshall County, Kentucky's Freeman. If the call taker doesn’t know about a certain building eccentricity, like a lobby that’s as tall as two regular floors, responders could be sent to the wrong place, he said.

A dispatcher who makes an incorrect calculation based on z-axis data could be liable to lawsuits, Freeman said. Emergency call takers get sued when they send first responders to the wrong location, and Freeman fears that adding a tough-to-decipher z-axis metric will only compound the problem.

There might not be technology to guarantee what floor number someone is on, but even an estimate from the carrier side would help, said Freeman. Vendors “have it within their skill set” to develop a way to provide actionable information, and an FCC mandate would give them “a reason,” said Ueland. “Uber Eats and Grubhub can find you down to the floor and suite number, but 911 can’t?”

Problem Not Solved

While there are some fans of the proposal, they want further location specificity when technologically possible.

The rules and proposals "would be a great step forward for 911,” emailed Dan Henry, National Emergency Number Association director-government affairs. The order “would help ensure that the telecommunications industry keeps the promises it made to the public in the 2015 Z-axis roadmap, and the FNPRM tees up further proceedings on important issues we will face,” he said: “There will be more work to do before 911 has access to highly accurate and instantaneously actionable 3D-location and address information, but the FCC’s actions are moving us closer to that goal.”

NASNA supports the FCC proposal as "a start that gives the 911 centers at least a basic level of knowledge on a wireless call," Rennie-Brown said. “It's not yet a dispatchable location, but it's a step in that direction.” More information would be useful, and Rennie-Brown expects vertical location data will evolve over time like horizontal location did.

Whether doing conversions with z-axis data would delay response would depend on each individual public safety answering points and how it processes that information, the NASNA official said. Each dispatch center will need to evaluate how it will process the data, and any impact to liability, she said.

“I would rather they do something than nothing,” said Ueland. “My fear is the FCC is going to pass this as-is” and say the problem is solved, “when it’s not.”