The accuracy of wireless 911 location data, while defined within FCC Docket #94-102, remains the topic of continued debate in both technical and political forums. Declarations of compliance across networks, including national markets and reported as pass or fail to the FCC, have left many public-safety answering points to resort to the most basic efforts to obtain the location or proximity to a landmark of a caller in need of prompt dispatch of emergency services.

These honorable attempts aren't always successful, and we are reminded of this by the numerous national stories highlighting the inability of 911 to locate citizens, sometimes ending tragically. The story that immediately comes to mind is the story of the 19-year-old Rochester, N.Y. college student who was abducted and subsequently killed. The victim called 911 from her cell phone, but operators could not locate her and listened in on the entire attack while trying to identify her location. Her father is New York Assemblyman David Koon who has, as a result, made wireless 911 one of his top priorities.

APCO International believes that wireless 911 accuracy testing should be required at the local community level, and we believe this was the FCC's intent when it issued its landmark wireless implementation order in 1994. Earlier this year, APCO International submitted a negative vote when the Network Reliability and Interoperability Council (NRIC) VII Focus Group on E911 presented a report to the NRIC VII Steering Committee stating that accuracy testing should only be required at the state level. In addition, APCO International submitted supporting comments relative to its Oct. 6, 2004, Petition for Declaratory Ruling to the FCC in February outlining its position. Several other public-safety agencies sent a statement to the FCC supporting APCO International's position.

The public-safety community remains puzzled by an assertion that there should be no expectation for the accountability of accuracy at the local level. For better or worse, Phase II services are requested, deployed and utilized at the local level, contracts between wireless carriers and PSAPs are initiated at the local level and emergency response begins at the local level.

APCO International's Project LOCATE supports the deployment of wireless 911 service by providing practical guidance and support to those PSAPs nationwide that have deployed E911 Phase II and those still considering deployment. Essential to effective deployment of wireless 911 service is the delivery of credible, predictable location data to the serving PSAP, which must struggle to identify the actual location of the crisis.

In June, the Public Safety Foundation of America granted Project LOCATE $750,000 to conduct independent testing of wireless location data delivered to the PSAP. Project LOCATE will define test areas nationwide based upon unique combinations of real-world variables and engage independent testing companies to perform accuracy tests utilizing OET-71 criteria. In addition, Project LOCATE will work with designated PSAPs to participate in the testing process, review results and coordinate efforts to resolve issues between the PSAP and the wireless service providers. Project LOCATE will report these results and resolution efforts to the wireless industry, the FCC and the PSAP community as a whole.

The quality of wireless location data delivered to the PSAP, the essential end user of such information, has continued to be an inconsistent and unreliable variable to be managed by PSAP personnel. The delivery of wireless location data that allows the receiving PSAP to promptly and effectively dispatch the appropriate emergency services to the correct location is essential to wireless 911 service. APCO International is proud of its position on this important issue, and we are confident that the FCC will clarify that wireless accuracy at the PSAP level is a vital component to successful implementation of E911.


Greg Ballentine is the director of public-safety and emergency services for the Mid-America Regional Council in Kansas City, Mo. Ballentine has 20 years experience in various emergency service communications operations. Ballentine holds a seat on the U.S. Department of Transportation Public Safety Advisory Group and was recently appointed by Missouri Gov. Bob Holden to the Governor's Advisory Board for 911 Oversight.