Before the Federal Communications Commission

272^ TruePosition January 22 Ex Parte at 2. Additionally, TruePosition questions the viability of the carriers’ commitment to provide z-axis capable handsets because “it will be more than a decade before there is significant penetration of the z-axis capable handsets throughout the U.S., hence, they can make this proposal now knowing that six years from now they will ask the FCC for a waiver citing “lack of availability” of the devices that would provide them an alternative means of complying with these horrible guidelines.” Id.

273^ Third Further Notice, 29 FCC Rcd at 2405 ¶ 80.

274^ See NextNav Comments at 20 (“[t]he vertical location systems of NextNav and other vendors can easily be integrated into PSAP operations because messaging protocols for vertical information between the handset, the carrier network, and the PSAPs are largely in place already.”); NENA Comments at 21 (stating that PSAPs have been anticipating vertical location, and showing a sample PSAP call-taker screen which includes an optional field for vertical information). See also Letter from Mary L. Brown, Senior Director, Government Affairs, Cisco Systems, Inc., and Timothy Lorello, SVP, Chief Marketing Officer, TeleCommunication Systems, Inc., to Marlene Dortch, Secretary, Federal Communications Commission (dated Oct. 16, 2014), at 2 (PSAPs “with advanced 911 capability could take advantage of its floor map function, which would enable them to better utilize vertical location information.”)(Cisco/TCS Sept. 12, 2014 ex parte).

275^ AT&T Comments at 17; CCA Reply at 7; Sprint Comments at 7; Sprint Reply at 14-15; T-Mobile Comments at 10; Motorola Comments at 15; TIA Comments at 8; Qualcomm Comments at 16.

276^ Verizon Comments at 26-27.

277^ APCO Comments at 6 and Reply Comments at 3.

278^ Addendum at 3 (“the revised deployment commitments also assure a quantifiable Z-axis backstop if a carrier has not met the dispatchable location benchmark by year 6 in any of the most populous 50 CMAs”).

279^ See, e.g., Samenow, Jason, “Slow clap: New iPhone6 has a barometer,” Washington Post (Sept. 9, 2014), available at http://www.washingtonpost.com/blogs/capital-weather-gang/wp/2014/09/09/slow-clap-new-iphone6-has-a-barometer/ (last visited Jan. 21, 2015).

280^ For example, NextNav has continued to refine its Metropolitan Beacon System, which uses “readily-available barometers combined with real-time reference data provided by NextNav’s beacon network to enable the accurate computation of altitude.” NextNav Comments at 19. See also Letter from Bruce Olcott, Counsel, NextNav LLC, to Marlene H. Dortch, Secretary, FCC (dated Dec. 9, 2014) at 2 (describing a demonstration of its vertical technology to Commission staff). Polaris Wireless likewise demonstrated its vertical location capabilities in an ex parte meeting with Commission staff, indicating that its technology would be a viable path to vertical location accuracy within the proposed timeframe. See Letter from Michelle C. Farquhar, Counsel, Polaris Wireless, to Marlene Dortch, Secretary, Federal Communications Commission (Sept. 26, 2014), Attachment at 15 (Polaris Wireless Sept. 26 ex parte). Polaris Wireless uses 3D radio prediction maps based on RF signatures found in multiple sources of information, including Wi-Fi access points and small cell nodes, with 3D RF pattern matching location algorithms to provide an indoor location estimate of a device. Polaris Wireless Comments at 5-6. iPosi uses advanced signal processing to extract weak indoor GPS and GNSS satellite signals, and then determines a device’s location based on its client and network servers, and submits that its solution “has demonstrated vertical GNSS/GPS accuracy error levels … less than three meters.” iPosi Comments at 1, 5.

281^ This would enable the phone to distinguish between two Wi-Fi access points that it may “see,” but which may be on different floor levels.

282^ See, e.g., Motorola Mobility Roadmap Comments at 2 (The Roadmap “correctly articulates the need for separate work streams on implementation solutions for providing a dispatchable location, improvement of horizontal location information, and development of basic standards for delivery and use of vertical location information.”).

283^ Roadmap at Section 5(c); Parallel Path at Section 4(a).

284^ Motorola Mobility Reply Comments at 12-14.

285^ NENA Comments at 23 (“[a] responder entering a building with only uncalibrated barometry data available could still locate the correct floor, provided she had available her own barometer. In a simplified sense, responders could be instructed to ‘look at the barometer and go up until the numbers match.’ This is admittedly a cumbersome process, but NENA is convinced that it is preferable to the lack of any z-axis data today.”). See also NextNav Reply Comments at 22; IAFF Comments at 3; IACP and NSA Comments at 2.

286^ Roadmap at Section 5(a).

287^ See e.g., IAFF Roadmap Comments at 2; NENA Comments at 23.

288^ Third Further Notice, 29 FCC Rcd at 2407 ¶ 84.

289^ Id.

290^ APCO Comments at 7; NASNA Comments at 4; Texas 911 Reply Comments at 15; ATIS Reply Comments at 3; NextNav Comments at 47.

291^ AT&T Comments at 28; CTIA Comments at 16 and Reply Comments at 15-16; Sprint Comments at 12; Verizon Comments at 22-23; T-Mobile Reply Comments at 7.

292^ ATIS Reply Comments at 4-5; NextNav Comment at 52; Qualcomm Comments at 19; TCS Comments at 10; TruePosition Comments at 18; RWA Comments at 5.

293^ BRETSA Comments at 19-21; NASNA Comments at 8.

294^ CSRIC IV Working Group 1, Final Report: Specification for Indoor Location Accuracy Test Bed, June 2014, available at http://transition.fcc.gov/pshs/advisory/csric4/CSRIC_IV_WG-1_Subgroup3_061814.pdf (last visited Dec. 30, 2014) (CSRIC Test Bed Final Report).

295^ CSRIC Test Bed Final Report at 3. According to the signatories, the test bed will be “consistent with the elements recommended by the [CSRIC] III Working Group and with the work undertaken by the Emergency Services Interconnection Forum (ESIF) established by ATIS.” Further, although the test bed will be open for use by any technology vendor, whether or not the technology is standardized or available commercially, the signatories state that only testing of solutions “based on industry standards and commercial configurations will be relied on to verify performance expectations to an E911 location benchmark.” The signatories agree “to work together to develop an appropriate funding framework for the test bed that includes funding support from carriers and affected E911 location vendors, and also to investigate the potential for obtaining other sources of funding (e.g., government grants).” See ATIS Reply Comments at 4 & n.6 (referring to the Feb. 7, 2014 ATIS ESIF Emergency Services & Methodologies (ESM) Subcommittee document concerning the selection of the six cites). See also http://www.atis.org/legal/Docs/ESIF%20DOCS/ESIF_Letter_DeLorenzo_Feb2014.pdf. (last visited Jan. 29, 2015) (containing ATIS Document, “Considerations in Selecting Indoor Test Regions,” for testing of indoor location technologies).

296^ CSRIC Test Bed Final Report at 8.

297^ Roadmap at Section 1(a)(iii).

298^ Id. at Section 1(a). According to the Roadmap, the test bed will be managed by a non-governmental entity, such as ATIS, and “operated in an open, transparent, and competitively neutral manner, as to technologies, carriers and location solution vendors” to enable them to “demonstrate vendor performance of E911 location solutions and to characterize performance of E911 location technologies, including OTDOA/A-GNSS, in order to establish appropriate E911 location benchmarks.” Id. at Section 1(a)(ii). See also AT&T Roadmap Comments at 8 (stating that cost efficiencies of the Roadmap are derived from allowing wireless providers to choose from among proven wireless location-accuracy solutions that have been appropriately tested in the test bed under real-world conditions “in an open, transparent, and competitively neutral manner” (emphasis in original)).

299^ Id. at Section 4(b).

300^ See, e.g., iCERT Roadmap Comments at 2; Motorola Comments at 4; NASNA Comments at 2-5; Qualcomm Comments at 7-8.

301^ BRETSA Roadmap Comments at 8-9 (testing of beacon-based technologies or other locally deployed systems can only demonstrate that the technology is capable of meeting certain accuracy standards in the test bed but the accuracy in non-test bed markets is not likely to be equivalent to test bed performance). See also Texas 911 Entities Roadmap Comments at 15-16, iPosi Roadmap Comments at 4 (recommending establishing a multi-city test bed using in-building sites offering public access such as hotels, train stations, and temporary office rental services).

302^ NextNav Roadmap Comments at 29 (also arguing that the carriers “appear to be offering to finally test their deployed OTDOA location capability in a single test bed market, measure the expected modest improvement over AFLT, and declare a new benchmark to be whatever accuracy OTDOA is capable of providing”).

303^ See, e.g., NASNA Roadmap Comments at 2 (arguing that the Roadmap test bed commitment only includes testing location accuracy but should also include TTFF and yield as key performance indicators consistent with the Commission’s proposed approach in the Third Further Notice).

304^ CCA Roadmap Comments at 6.

305^ CSRIC LBS Report at 57; Indoor Location Test Bed Report at 12.

306^ Specifically, for location accuracy, the test bed must compute the error in estimating the location of the device under test by comparing each vendor’s reported horizontal position to the surveyed ground truth position of the test location (determined through a precise land survey). Each test call (or equivalent) must be independent from prior calls and accuracy will be based on the first location delivered by the vendor after he call is initiated. With regard to latency, TTFF must be calculated by establishing the precise time for call initiation (or an equivalent initiation event if the vendor’s test configuration does not support the placement of an emulated emergency test call). Specifically, latency must be measured from the time the user presses SEND after dialing 911, to the time the location fix appears at the location information center.

307^ Indoor Location Test Bed Report at 14.

308^ Id. at 12.

309^ See Presentation by CSRIC WG3, Indoor Location Accuracy – Test Bed Framework (Sept. 12, 2012), at 6, available at http://transition.fcc.gov/pshs/advisory/csric3/3-WG%20Presentation%209-12-12.pdf (last visited Dec. 19, 2014) (noting agreement reached among test bed participants that CMRS providers could only view raw results if they signed a nondisclosure agreement). See also Indoor Location Test Bed Report at 12.

310^ Roadmap at Section 4. The Roadmap states that data on the “‘positioning source method’ would include dispatchable location methods as well as positioning based on latitude/longitude (e.g., A-GPS, GLONASS, OTDOA, AFLT, RTT, Cell ID, or a hybrid of any of the listed or future technologies).” Id. at Section 4(a)(i).

311^ CCA Roadmap Comments at 3; NASNA Roadmap Comments at 2, 5; TCS Roadmap Comments at 5-6; PCIA Roadmap Reply Comments at 4; Mobile Future Roadmap Reply Comments at 7; NextNav Roadmap Comments at 21 (stating that following successful tests in a test bed, a CMRS network’s performance should be evaluated by looking at live call data).

312^ Cisco Roadmap Comments at 3.

313^ NASNA Roadmap Comments at 5 (referencing 47 C.F.R. § 20.18(h)(1)(vi) and (h)(2)(iii)).

314^ Lackawanna County PA District Attorney Roadmap Comments at 1.

315^ CCA Roadmap Comments at 3; RWA Roadmap Reply Comments at 6. See also NTCA Roadmap Reply Comments at 5 (highlighting that requesting a waiver of the Commission’s rule can be a burdensome process for small and rural CMRS providers).

316^ CCA Roadmap Comments at 6-7.

317^ Parallel Path at Section (5)(a)(ii).

318^ Id.

319^ Id.

320^ Roadmap at Section 4(b). While the Roadmap indicates these test regions were selected to represent common indoor use cases, the regions include a range of morphologies and should also be representative of the areas where outdoor wireless calls to 911 are placed. The Roadmap commits to obtaining data for “all live wireless 9-1-1 calls” in these regions, regardless of whether the call is placed from indoors or outdoors; we emphasize that for purposes of this reporting requirement, we expect the live call data to reflect the quality of both indoor and outdoor call location information.

321^ In order for this data to serve as a reasonable measure of the efficacy of indoor location solutions, it will be necessary for the Roadmap parties to make information available on the system deployment and the live 911 call data, such that smaller CMRS providers who do not cover territory in one of the six ATIS ESIF test cities could certify whether their deployments is consistent with one of the four nationwide providers in the six test cities. As such, CMRS providers may request confidential treatment of their live 911 call data reports, but the Commission reserves the right to release aggregate or anonymized data on a limited basis in order to facilitate compliance with its rules. In addition, nothing in this Order is intended to limit the authority of state and local 911 agencies to publish 911 call data to the extent authorized under state or local law.

322^ The Commission will not publish any personally identifiable information, such as 911 callers’ phone numbers or the locations to which first responders were dispatched. The Commission may, however, publish aggregate information on CMRS providers’ performance in a given geographic area, or on the percentage of calls using a particular positioning source method across all CMRS providers. We believe that this information will enable the Commission to better monitor location accuracy performance as a whole and will serve as a self-evaluation tool for CMRS providers.

323^ For nationwide carriers, this will include the six test regions. For non-nationwide carriers, this will include the appropriate test region, county or other test area in accordance with the Parallel Path as adopted herein.

324^ Addendum at 3.

325^ See 47 C.F.R. §20.18(h).

326^ Third Further Notice, 29 FCC Rcd at 2415-16 ¶ 110-11.

327^ Id. See also Section III.B.5.a.

328^ Id. at 2416 ¶ 111.

329^ Id.

330^ Id.

331^ NASNA Comments at 7-8

332^ NextNav Comments at 52-53.

333^ Verizon Comments at 22 and Reply Comments at 16; AT&T Comments at 5, 29-32; CTIA Comments at 16-17; NASNA Comments at 7-8; NextNav Comments at 55-56; T-Mobile Comments at 20; RWA Comments at 5; see also TCS Comments at 3, 9 (market-specific testing may impose burden on wireless providers with little improvement in performance).

334^ Verizon Comments at 27.

335^ Sprint Comments at 16.

336^ Id.

337^ AT&T Reply Comments at 7.

338^ APCO Comments at 9.

339^ Third Further Notice, 29 FCC Rcd at 2430 ¶ 171.

340^ Id.

341^ APCO Comments at 8; NASNA Comments at 8.

342^ CTIA Comments at 18.

343^ Verizon Comments at 33; CCA Reply Comments at 17.

344^ See supra Section CXXXV.A.1.a. CMRS providers that do not provide service in any of the six cities may satisfy this requirement by certifying in their 36- and 72-month certifications that (1) they have deployed technology throughout their network consistent with a technology deployment that was certified in the test bed, and (2) that their network does not cover any territory in any of the six test cities. If a CMRS provider expands its network coverage into one of the six test cities, it must re-certify the compliance of its deployed technology as well as begin reporting live call data from that portion of its network to NENA, APCO, NASNA, and the Commission.

345^ See infra Section CXCIII.A.

346^ This includes, but is not limited to, evidence of a PSAP’s reasonable bidding and rebidding activity throughout the duration of a 911 call.

347^ See 47 U.S.C. §§ 1.711-1.736 et seq. CMRS providers will have 30 days to respond to the Commission following notification of any such complaint.

348^ In 2008, Congress enacted the New and Emerging Technologies 911 Improvement Act (NET 911 Act), which provides that a “wireless carrier, IP-enabled voice service provider, or other emergency communications provider … shall have” the same liability protection as a local exchange provider under federal and state law. 47 U.S.C. § 615a. In February 2012, Congress further extended state liability protection to providers of NG911 service in the Next Generation 9-1-1 Advancement Act of 2012, enacted as subtitle E of the Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. No. 112-96, 126 Stat 156, 237-45. The Next Generation 9-1-1 Advancement Act of 2012 provides that “[a] provider or user of Next Generation 9-1-1 services…shall have immunity and protection from liability under Federal and State law [to the extent provided under section 4 of the Wireless Communications and Public Safety Act of 1999],” with respect to “the release of subscriber information related to emergency calls or emergency services,” “the use or provision of 9-1-1 services, E9-1-1 services, or Next Generation 9-1-1 services,” and “other matters related to 9-1-1 services, E9-1-1 services, or Next Generation 9-1-1 services.” 47 U.S.C. § 1472. In addition, Section 6503 of the Act amends the National Telecommunications and Information Administration Organization Act to define “emergency call” as “any real-time communication with a public safety answering point or other emergency management or response agency,” including communication “through voice, text, or video and related data.” 47 U.S.C. § 942(e)(4).

349^ Third Further Notice, 29 FCC Rcd at 2416 ¶ 113.

350^ Id.at 2417 ¶ 114. See also Signal Booster Report and Order, 28 FCC Rcd at 1696 ¶ 90 n. 206.

351^ CTIA Reply Comments at 20.

352^ BRETSA Comments at 24-25.

353^ Qualcomm Reply Comments at 8.

354^ Facilitating the Deployment of Text-to-911 & Other Next Generation 911 Applications, Framework for Next Generation 911 Deployment, Second Report and Order, 29 FCC Rcd 9846, 9876-77 ¶ 65 (2014).

355^ See, e.g., NextNav Comments at iv (“The Commission has acknowledged that the adoption of clear, near-term requirements will remove regulatory uncertainty, add needed impetus to carrier adoption, and hasten the eventual development of long-term solutions capable of delivering the dispatch-able address-level information that is ultimately sought by public safety.”).

356^

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