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Closing Loopholes

Z-Axis Order Poses Tough Questions for Commissioners; Approval Expected

The vertical location order is expected to be approved largely as proposed by Chairman Ajit Pai, though some concerns are expected to be raised and a few tweaks are likely, FCC and industry officials said in interviews last week. Aides to commissioners have taken numerous meetings and are wading through the arguments made for and against the draft, officials said. Public safety groups have come in with different views.

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Commissioner Jessica Rosenworcel was the lone dissenter when commissioners approved the initial rules in November (see 1911220034). She's “still reading, still evaluating,” an aide said.

APCO said the order should be revised to eliminate loopholes, warning the FCC’s approach could cause more confusion (see 2007070041). The group made similar comments in filings posted Friday based on meetings with aides to commissioners. The wireless industry also sought changes. AT&T warned that next year’s initial deadline will be difficult to meet, especially as the COVID-19 pandemic continues (see 2007090057).

APCO hopes for broad support on closing loopholes, said Director-Government Relations Jeff Cohen. “If this isn’t addressed now, it’s going to have to be addressed eventually,” he told us. Commissioners vote Thursday.

New York City Police Department Deputy Chief Richard Napolitano slammed the draft for not doing more to require dispatchable location. The draft “includes ambiguous language that would fail to provide useful locations,” he said in a filing posted Friday in docket 07-114: “Dispatchable location will save lives. In New York and other cities like ours, a densely woven network of residential and commercial structures requires not only a building number to locate a caller in need, but when possible, the floor and apartment number as well.”

Lobbying

Industry has weighed in with concerns.

T-Mobile said the FCC wrongly ignored wireless industry arguments for an alternate schedule using z-axis capable handsets deploying Google or Apple technology. “The Draft Order would promulgate regulations that essentially force carriers to pursue specific technology solutions promoted by NextNav and Polaris that have not been tested in their to-be-deployed configurations and which are going to deliver ± 3 meter z-axis estimates for 911 calls from far fewer Americans compared to the available handset-based solutions,” T-Mobile said. “Simple math shows that the third-party solutions are highly unlikely to provide ± 3 meter z-axis capability for as many Americans as the carriers’ proposal will, whether in April 2021 or April 2025, and that the third-party solutions will only benefit the limited subset of users with the most costly devices.”

Wireless 9-1-1 callers would be best served if the FCC recognizes mobile Operating System (OS) z-axis solutions as compliant with the FCC’s rules by April 2021,” CTIA said in Friday posting.

Five first responder groups endorsed the FCC’s approach in general, while asking the regulator to narrow the z-axis metric. “Although the Draft Order declined to adopt our recommendation, the FCC should nonetheless evaluate the status of location accuracy technology on an biannual basis and consider narrowing the metric should it become clear that achieving a narrower metric is technically feasible,” said 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.

The National Public Safety Telecommunications Council, noting the z-axis standards have been under discussion since 1994, said the FCC should stick with the proposed deadlines. “The general public and public safety have already waited far too long for the provision of highly accurate location information with wireless calls to E911 emergency services,” NPSTC said. The Safer Buildings Coalition also asked the FCC not to weaken the rules. “The public safety community has clearly indicated that 3-meter accuracy is the minimum threshold necessary to reliably locate wireless callers in distress,” the group said: “The provision of 3-meter accuracy for anything less than 80% of calls from z-axis capable handsets would be insufficiently accurate to be useful as actionable information to support first responders in the field.”

National Association of State 911 Administrators Executive Director Harriet Rennie-Brown told us she's comforted by the FCC clarifying that the order would put the onus on carriers, not the public safety answering point community, to implement the policy. NASNA asked the FCC last month to take the rest of 2020 to gather more information. “The FCC is moving forward,” Rennie-Brown said. “It needs to, yet there are still going to be limitations on how the PSAPs can process the information.” PSAPs are focused on deploying next-generation 911,” while “a number of our members have seen their states and their 911 centers extremely busy over the last six months with the pandemic,” she noted. Vendors can’t come into many centers due to COVID-19 restrictions on nonessential personnel.

NGA 911’s next generation network “is ready to receive this information and deliver it” to public safety answering points that are “next-gen enabled,” CEO Don Ferguson told us Friday: “We have encouraged our PSAPs to request this feature, and engage in testing. Many PSAP are anxious to receive this additional information, and believe it will save lives.”

The draft rules will further enhance vertical location accuracy for wireless 911 calls, said National Emergency Number Association Director-Government Affairs Dan Henry in an emailed statement. "Based on our initial review, the Sixth Report and Order follows in the Fifth R&O’s footsteps by striking a good balance between public safety’s needs and what is technically feasible. We look forward to working with the public safety community, including public safety operations, standards development, and vendor partners to provide interoperable means to implement these orders, including handling of a caller’s location in three-dimensional space and making that information actionable for telecommunicators."