Google said the FCC should consider allowing carriers to transmit information on the floor level of a wireless call to 911 as an alternative to providing height above ellipsoid (HAE) data. Commissioners are to vote on an order Friday (see 1911130030). “An HAE estimate may not provide actionable information in the short term, particularly with regard to identifying which floor to search,” Google said in a filing posted Monday in docket 07-114: Google understands that “not every person in public safety is (or is on a clear path to be) equipped with technology capable of interpreting HAE information.” The National Emergency Number Association disagreed. “A handset’s location, including z-axis, must be delivered to the 9-1-1 system in its original format,” NENA said. “Google’s proposal -- to the extent it removes z-axis HAE from the location payload -- would reduce overall vertical location accuracy and upend the marketplace for downstream mapping and location solutions, disrupting many of the benefits of a ubiquitous standard for vertical elevation measurement.” NENA said “the vast majority of organizations representing public safety” support the z-axis mandate. A Monday news release from the FCC chairman's office laid out public safety support for the z-axis mandate.

Lobbying continues for and against proposed rules requiring carriers to identify the vertical location of indoor wireless calls to 911. APCO questions whether the requirement will help first responders locate callers (see 1911130030). Officials in the office of FCC Chairman Ajit Pai say the preponderance of public safety groups support the order, set for a commissioner vote at the Nov. 22 meeting.

The FCC's likely to approve a draft order Nov. 22 requiring carriers identify the vertical axis of wireless calls to 911. Many questions are expected when commissioners vote. The FCC's proposing to mandate 3-meter z-axis 911 location accuracy starting in April 2021. Public safety is divided. Carriers are concerned whether industry can meet the timetable. They have been relatively quiet, however, FCC officials said.

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CTIA and the national wireless carriers sounded a note of caution on the timetable proposed in a draft FCC order requiring that carriers be able to identify within 3 meters the vertical location, or z-axis, of wireless calls to 911. Commissioners are to vote Nov. 22 (see 1910290054). “Further testing is currently underway and planned during 2020 to better determine the extent to which ± 3 meters for 80 percent of wireless calls as measured in the 9-1-1 Location Accuracy Test Bed is achievable by April 2021,” CTIA said in docket 07-114, posted Wednesday. The draft “presumes that technologies studied in the earlier test campaigns … are technically feasible and commercially available to meet the Commission’s April 2021 benchmark because firmware or software upgrades could load these technologies onto existing wireless handsets.” It likely “overstates the extent to which these solutions are scalable and deployable by April 2021,” CTIA said. The group and members proposed technical changes to the rules. Instead of referring to an “z-axis capable device,” the FCC could cite “any device capable of measuring and reporting vertical location with a wireless 9-1-1 call without a hardware upgrade.” The association said the text should more accurately reflect “the cautionary views” of industry and public safety groups. CTIA and representatives from AT&T, Sprint, T-Mobile and Verizon met with Public Safety Bureau staff. 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 supported the FCC proposal Wednesday. Three meters "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," IAFC said.

APCO said that without "significant changes," it can't support the FCC's push for final rules requiring that carriers be able to identify within 3 meters the vertical location, or z-axis, of calls to 911. APCO had earlier voiced concerns, though the draft order asserts the group is now onboard. “APCO’s revised position aligns with the views of all other public safety commenters that adopting a z-axis metric remains an essential measure to ensure that first responders receive important location information when providing dispatchable location is not feasible,” the draft said (see 1910290054). But "the proposal does not ensure that first responders will know a 9-1-1 caller’s vertical position within 3 meters for 80 percent of calls, as the metric seemingly requires,” APCO said in a filing posted Tuesday in docket 07-114: “Worse, 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 shared its concerns with staff for Chairman Ajit Pai, and Commissioners Mike O’Rielly and Jessica Rosenworcel.

Industry groups representing telcos, cable companies and telecom service bundlers endorsed an FCC draft declaratory ruling to ensure 911 regulatory fee parity between VoIP and functionally equivalent traditional phone services, in interviews last week. Commissioners will vote on the draft at Friday's meeting (see 1910040053). The ruling, on docket 19-44, is an attempt to answer a referral from the U.S. District Court for the Northern District of Alabama on litigation between AT&T's BellSouth and some 911 districts (see 1909110027).

The National Emergency Number Association said the FCC should require carriers to be able to locate the vertical location of wireless callers. NENA opposes CTIA’s “phased in” approach (see 1910100030), it told an aide to Commissioner Geoffrey Starks, said a filing in docket 07-114, posted Friday. “Emphasizing public safety’s sensitivity to timeline slip, we noted that the proposed benchmarks have been in place since the Commission’s 2015 Roadmap,” NENA said. But NENA agrees with CTIA that the national emergency address database faces challenges. “We remain concerned that the NEAD could generate dangerously inaccurate location results for public safety, and that its compliance regime creates the potential for vast swaths of unserved 9-1-1 callers,” the group said. Top officials at NextNav met with Public Safety Bureau staff on the proposed requirement. “A major point of discussion during the meeting was the manner in which the Commission should determine compliance with its vertical location requirements in terms of handset penetration,” the company said: “The discussion included the definition of ‘z-axis capable devices’ and whether this could be defined as handsets manufactured after a certain date that include appropriate hardware components, such as a barometric pressure sensor or other capable component necessary to calculate altitude.”

Executive Vice President Brad Gillen and others from CTIA met FCC Chief of Staff Matthew Berry and Aaron Goldberger, an aide to Chairman Ajit Pai, on the agency’s regulatory framework for giving public safety answering points vertical location information for wireless calls to 911. Carriers' June comments supported a 3-meter standard for indoor wireless 911 calls but warned technological challenges remain (see 1906190011). “CTIA reiterated the wireless industry’s on-going commitment to enhancing wireless 9-1-1 location accuracy, particularly indoors, and provided a status update on the nationwide wireless providers’ efforts to meet the Fourth Report and Order’s vertical location requirements,” said a filing posted Thursday in docket 07-114. “CTIA reviewed the nationwide wireless providers’ significant efforts to work across the wireless ecosystem to deliver actionable vertical location information to PSAPs [public safety answering points] during a wireless 9-1-1 call. However, CTIA noted that third-party adoption and scalability issues remain substantial challenges to National Emergency Address Database (NEAD)-based dispatchable location solutions.”

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