Before the Federal Communications Commission
Need for, and Objectives of, the Rules Adopted
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- A.Summary of Significant Issues Raised by Public Comments in Response to the IRFA
Need for, and Objectives of, the Rules AdoptedCCXVI.In this Fourth Report and Order, the Commission adopts measures that will significantly enhance the ability of Public Safety Answering Points (PSAPs) to accurately identify the location of wireless 911 callers when the caller is located indoors, and strengthen existing E911 location accuracy rules to improve location determination for outdoor as well as indoor calls. These actions respond to major changes in the wireless landscape since the Commission first adopted its wireless Enhanced 911 (E911) location accuracy rules in 1996 and since the last significant revision of these rules in 2010. As consumers increasingly replace traditional landline telephony with wireless phones, a majority of wireless calls are now made indoors, increasing the likelihood that wireless 911 calls will come from indoor environments where traditional location accuracy technologies optimized for outdoor calling often do not work effectively or at all. A significant objective of this proceeding is to close the gap between the performance of 911 calls made from outdoors with similar calls made indoors. CCXVII.The Commission adopts rules applicable to CMRS providers that reflect technical feasibility and are technologically neutral, so that providers can choose the most effective solutions from a range of options. Further, the rules allow sufficient time for development of applicable standards, establishment of testing mechanisms, and deployment of new location technology in both handsets and networks, on timeframes that account for the ability of PSAPs to process enhancements in the location data they receive. In determining the appropriate balance to strike between its requirements and timeframes, the Commission gave significant weight to the “Roadmap for Improving E911 Location Accuracy” (Roadmap) that was agreed to in November 2014 by the Association of Public Safety Communications Officials (APCO), the National Emergency Number Association (NENA), and the four national wireless CMRS providers,0 as well as the “Parallel Path for Competitive Carriers’ Improvement of E911 Location Accuracy Standards” (“Parallel Path”) that was submitted by the Competitive Carriers Association (CCA).0 At the same time, in order to provide greater certainty and accountability in areas that the Amended Roadmap does not fully address, the rules incorporate “backstop” requirements derived from the Commission’s original proposals in the Third Further Notice. CCXVIII.The rules the Commission adopts are designed to increase indoor location accuracy in a commercially reasonable manner by leveraging many aspects of the Amended Roadmap. They do not change, or seek to change, the commitment that the four nationwide CMRS providers voluntarily entered into and have already made progress towards. The Amended Roadmap is intended to build confidence in the technical solutions outlined therein, and it establishes clear milestones to gauge progress and ensure that if the signatory parties fail to deliver on their commitments, there is clear accountability for the integrity of location accuracy using metrics adopted at earlier stages in this proceeding. The rules the Commission adopts are in addition to, not a replacement of, its existing E911 location rules applicable to outdoor calls, which remain in effect, unless otherwise amended herein. In establishing these requirements, the Commission’s objective is that all Americans using mobile phones – whether they are calling from urban or rural areas, from indoors or outdoors – have technology that is functionally capable of providing accurate location information so that they receive the support they need in times of emergency. A.Summary of Significant Issues Raised by Public Comments in Response to the IRFACCXIX.No comments were submitted specifically in response to the IRFA. Nevertheless, small and rural CMRS providers suggested that compliance with the rules (as proposed in both the Third Further Notice and the Roadmap) could be burdensome:
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