FCC wireless 911 location-accuracy rules should demand accountability, long-term improvement

On Thursday, FCC commissioners are scheduled to vote on 911 location-accuracy rules that—for the first time—would address requirements for wireless emergency calls made from indoor locations. This is a much-needed measure, as the percentage of calls to 911 from wireless phones continues to increase as a growing number of Americans do not have wireline phone service.

With wireline phone service, a 911 caller’s location generally can be found in a database that provides a street address that corresponds with the phone number  (issues remain with multiline telephone systems—MLTS—that are being scrutinized by FCC Commissioner Ajit Pai and others). Having this location data is important, particularly if callers cannot speak or are in unfamiliar territory, which can prevent them from sharing information with a 911 call-taker.

For wireless calls to 911, such location information has been little more than an estimate. Initially, the information shared on a wireless call made from an outdoor location was just the location of the tower being used for the call. With today’s Phase 2 E-911 systems, satellite GPS technology primarily is used to provide XY coordinates, with inconsistent results that are understandable–it doesn't work as well when the calleer does not have a clear view to the satellite, such as in an urban setting or wooded environment. Meanwhile, the matter of location information for indoor wireless 911 calls was not mentioned in the rules.

That’s expected to change at this week’s FCC meeting. After the FCC announced its intentions and made an initial proposal last February, the commission conducted a proceeding to get input from all stakeholders.

After the proceeding concluded, the four nationwide carriers—AT&T, Verizon, Sprint and T-Mobile—worked with the National Emergency Number Association (NENA) and the Association of Public-Safety Communications Officials (APCO) to develop a proposed “roadmap” for indoor 911 location-accuracy rules that would supplant the FCC’s proposed rules.

Last week, the four carriers submitted an amended roadmap that was designed to address some of the concerns raised by critics regarding the initial roadmap proposal, including location-database privacy concerns and new metrics regarding indoor location accuracy, particularly as it relates to vertical Z-axis coordinates. This amended roadmap was updated yesterday with further carrier commitments.

In the past, public-safety organizations have reached agreements with wireless carriers on key issues and taken the agreement to the FCC for codification. More than a decade ago, such an agreement provided the structure for 800 MHz rebanding; however, the FCC wisely altered the business model by removing the proposed funding cap. A deal struck by the carriers, NENA and APCO in 2012 formed the basis of current text-to-911 rules.

With indoor location accuracy, the FCC again has been presented with an agreement between the carriers and public safety (albeit not all of public safety, as many organizations that were not invited to the negotiating table with NENA and APCO have criticized the deal). As in the past, it is up to the FCC to determine which aspects of the proposal should be adopted as proposed and which ones should be ignored or modified.