Find Me 911 coalition makes its case in opposition to cellular carriers’ indoor 911 location proposal

In the past, carriers have indicated that tests of network-based location solutions from companies like NextNav, Polaris Wireless and TruePosition—a key funding contributor to the Find Me 911 coalition—are not reliable enough to meet the FCC’s proposed rules of providing XY coordinates that are accurate within 50 meters indoors and a Z-axis vertical coordinate that is accurate within 3 meters. Barnett said that such assertions are “incorrect,” noting numerous third-party testing.

However, the technologies specified in the carriers’ proposal—notably, the Russian satellite GLONASS system and Observed Time Difference of Arrival (OTDOA)—have not been subjected to similar testing, Barnett said.

“But here’s the other side of it: Their technology has not been tested at all,” he said. “So, we don’t know how the GLONASS system will do it, but we know that GPS doesn’t work well indoors. We don’t know how OTDOA works, although a previous edition of that did not work well, and some people have suggested that there would only be a 20% improvement indoors—not near what would be needed.

“So, it’s ludicrous to me for them to say that there’s nothing in the record that would show that any of this would work when of course there is, and then they are promoting something that’s completely untested.”

Perhaps the biggest issue that Barnett has with the carriers’ agreement with APCO and NENA are the performance benchmarks included in the deal.

Although the carriers’ proposal talks about providing 911 centers with a dispatchable address, the benchmarks only indicate that certain technologies will be used for a percentage of the calls.

“There is no commitment in the agreement to deliver even one dispatchable address,” Barnett said.

The benchmarks do not require accuracy that is better than the 50 meters for XY that is in the FCC proposal, and there are no vertical benchmarks in the carriers’ proposal, Barnett said.

Furthermore, the carriers’ proposal does not differentiate between indoor and outdoor 911 calls, so the accuracy thresholds do not guarantee that there will be any improvement in indoor location, Barnett said.

“Literally, they can boost outdoor performance and reduce their indoor location accuracy to almost zero [under the carriers’ proposal],” he said.