On Sept. 11 the FCC adopted a Report and Order clarifying that wireless carriers must meet FCC wireless E911 location accuracy requirements at the public-safety answering point level. To accomplish this, the order requires carriers to meet interim, annual benchmarks over the next five years to ensure they achieve PSAP-level compliance no later than Sept. 11, 2012. (See story on page 12.)

While appreciating the complexity of the order and the difficulty carriers will face in some areas to meet the rule, the National Emergency Number Association welcomed the FCC's decision. As I stated when the order was released, cell phones can certainly be a life-saving tool with nearly 100 million wireless 911 calls being made annually, more than half of all 911 calls in some areas. However, when a caller is unable to describe his or her location during an emergency, the ability of a 911 call-taker to provide help is often only as good as the location information provided with the call. It is therefore essential that we continue to take steps to improve the accuracy of wireless 911 calls.

From NENA's perspective, the rules adopted set a reasonable compliance deadline with meaningful benchmarks along the way to ensure measurable progress is made on the path toward full compliance. Like any regulatory action, the FCC's decision is likely to make few, if any, parties 100% happy. Many PSAP managers and call-takers will think the timeline for meeting the rule is too long and that such accuracy is needed for all calls today, not five years from now. Carriers will argue that five years is not enough time, and they don't believe that technology is currently available for them to meet the FCC's rules in all PSAP service areas. Some will argue that a decision on this issue was premature and that what is needed is more time to discuss the issue in the form of industry working groups and other collaborative efforts.

Unfortunately, that is the reality of 911 regulation. It is sometimes an imperfect process in which the regulators do the best they can with the information available to them in an attempt to establish aggressive, but achievable rules. I think Commissioner Michael Copps put it well when the order was adopted, saying, “While I believe that the benchmarks we set today are achievable, if the record that develops between now and one year from now suggests otherwise, I am willing to revisit the timeframes we establish today. The important point is today's action provides what seem to be realistic parameters and timeframes for getting the job done.”

While the wireless industry is currently in reaction mode to the commission's order, I believe it is crucial for wireless carriers, public-safety organizations and PSAPs to stay in touch now and throughout the period of implementation for new accuracy rules. We announced our intent to sponsor, with the Association of Public-Safety Communications Officials, a forum to stay in touch and discuss the issues. We also need the FCC's help and encouragement. The commission itself played host in 1999 to a public safety/wireless carrier/vendor roundtable on issues of wireless emergency caller location. (Go to www.fcc.gov/pshs/911/enhanced911/archives.html.) Other similar FCC conferences have been held since. The existence of accuracy rules in 1999 and after did not preclude these gatherings, but instead made them more important. The same is true now in the wake of the commission's Sept. 11 decision.

Whether you agree or disagree with the recent actions taken by the FCC, we can all agree that improving the location accuracy of all 911 calls, regardless of the service type, is of paramount importance to the safety of our nation's citizens. There are still numerous details to emerge as a result of this order that must be worked out. While there will be differences of opinion, let's make sure that we work together as much as possible moving forward.


Jason Barbour is the current president of NENA. He is the 911 director for Johnston County, N.C.