A.Provision of Live 911 Call Data

A.Provision of Live 911 Call Data

CXCV.Discussion. We require all CMRS providers to collect and retain for two years 911 call tracking data for all wireless 911 calls placed on their networks. This requirement is separate from, and in addition to, the provisions for quarterly reporting of live call data by CMRS providers in the six test cities as discussed in Section CXXXV.A.1.a above, though for CMRS providers in the six test cities, some of the data will overlap. Aside from those quarterly aggregate reporting requirements, we do not require CMRS providers to report general call tracking data. However, upon request of a PSAP within a CMRS provider’s service area, the CMRS provider must provide the PSAP with call tracking data for all 911 calls delivered to that PSAP.⁵⁵ The call tracking data should include, but need not be limited to: (1) the date, time, and length of each call; (2) the class of service of the call (i.e., whether a call was delivered with Phase I or Phase II information, or other type of information); (3) the percentage of calls lasting 30 seconds or more that achieved a Phase II-compliant fix;⁵⁶ (4) confidence and uncertainty data for each call; and (5) the positioning source method used for determining a location fix.⁵⁷ In order to comply with this requirement and to be able to provide such data upon individual PSAP request, CMRS providers must collect data on all 911 calls throughout their service area. Some commenters suggest that delivering this additional information in real time may be confusing to PSAP call-takers,⁵⁸ but our requirement requires only that CMRS providers collect this information; the PSAP must request to receive some or all of the data in real time, or in the aggregate on a monthly or quarterly basis.

CXCVI.In sum, our call tracking requirements will empower multiple stakeholders to monitor and ensure that location information is compliant with our E911 requirements, and will provide PSAPs and CMRS providers with an objective set of data that can help inform decision-making in the event of a service issue or dispute between the parties as to E911 compliance.⁵⁹ In this regard, our call tracking requirement will serve to encourage transparency, accountability, and cooperation among stakeholders.⁶⁰

A.Outdoor Compliance Testing and Reporting

CXCVIII.Public safety commenters support the periodic testing proposal and suggest that testing requirements should cover both indoor and outdoor location accuracy performance.⁶⁵ For instance, APCO agrees with the recommendations in the CSRIC WG3 report and “urg[ed] the Commission to adopt appropriate rules to implement those recommendations.”⁶⁶

CXCIX.CMRS providers oppose the Commission’s proposal as costly and unnecessary.⁶⁷ For example, RWA and CCA oppose periodic testing as burdensome on small rural CMRS providers.⁶⁸ However, both RWA and CCA submit that periodic testing is appropriate in case of substantial network changes.⁶⁹

CC.Discussion. We believe that conducting periodic testing continues to be appropriate to ensure compliance with outdoor location accuracy parameters. CMRS providers’ efforts to measure for, and ensure continuing compliance with, the Commission’s outdoor-based location accuracy requirements are critical to public safety, particularly as new networks and technologies are implemented.⁷⁰ Further, we find that periodic testing will support the reporting of outdoor call data that is included in the Roadmap as part of the live call data.⁷¹ Because CMRS providers will blend all 911 call data, CMRS providers should incorporate an approach to test for compliance with the current outdoor-based location accuracy standards. For instance, CMRS providers may need to undertake drive testing in certain counties or PSAP service areas where they have migrated to VoLTE and that are outside the six test regions.⁷²

CCI.While we do not codify any particular approach, we find that the ongoing maintenance testing framework set forth in the CSRIC III WG3 and CSRIC IV WG1 recommendations provides a reasonable and adequate basis for ensuring continued compliance with our E911 location accuracy requirements. We urge CMRS providers to undertake periodic testing to ensure continued compliance accordingly. Moreover, such ongoing testing enables CMRS providers to implement testing protocols more efficiently and without the cost burdens associated with periodic testing pursuant to a mandatory, established timetable (e.g., every two years).⁷³ Consistent with CSRIC’s recommendations, CMRS providers should conduct testing upon any significant technology changes or upgrades to their networks, including those changes accompanying the deployment of VoLTE networks. As CSRIC IV WG 1 emphasizes, “the goal of maintenance testing is to identify a method that verifies continued optimal performance of E9-1-1 location systems at the local level.”⁷⁴ This recommended testing protocol includes several components, including: (1) Key Performance Indicators (KPIs) that “are routinely monitored to help identify instances where system performance has degraded”; and (2) “[s]pot-checking using empirical field-testing . . . on an as needed basis, for example, as determined by KPI monitoring or legitimate performance concerns from a PSAP.”⁷⁵ We find that this emphasis on KPI testing will provide CMRS providers with a testing approach that they can apply in a variety of circumstances. Moreover, this ongoing testing approach provides CMRS providers with the means to validate latency (TTFF) and C/U Data, as standardized in the rule changes we adopt today.⁷⁶

CCII.Finally, consistent with our views on KPI testing, we are revising the Commission’s outdoor requirement for C/U data, which currently specifies that “[o]nce a carrier has established baseline confidence and uncertainty levels in a county or PSAP service area . . . additional testing shall not be required.”⁷⁷ We remove the language excluding additional testing. Although CSRIC III WG3 stated that “[u]ncertainty estimates, when taken on average over time, can indicate a trend that may reflect continued proper system operation or system problems,”⁷⁸ CSRIC III WG3 also noted the importance of C/U data for monitoring location accuracy as one part of a CMRS providers testing program for other KPIs.⁷⁹ As discussed above, KPI testing should continue as part of CMRS providers’ best practices, along with other recommended testing procedures, such as spot-testing.