A.Recent Comments on E911 Phase II Location Accuracy and Call Tracking Data

A.Recent Comments on E911 Phase II Location Accuracy and Call Tracking Data

21.The Commission subsequently received E911 Phase II call tracking data sets from several other state and local public safety entities that either oversee or administer E911 service, which in some cases also indicated a decrease in the percentage of calls to PSAPs that included Phase II location.¹ In September 2013, the Commission’s Public Safety and Homeland Security Bureau (Bureau) announced that it would host a public workshop to discuss the issues raised by CALNENA and other E911 Phase II call tracking data sets, as well as recent developments in wireless location technology.² The Bureau also invited interested parties to file comments on the E911 call tracking data and related topics for discussion, including current trends that may be affecting the provision and quality of E911 location information delivered to PSAPs.³

22.Twenty-two parties filed comments, including four CMRS providers,¹ nine public safety organizations and entities, and eight vendors of location technologies, Next Generation system components, or PSAP consumer premises equipment. On November 18, 2013, the Bureau hosted the E911 Phase II Location Accuracy Workshop.²

23.Providers uniformly attribute the declining rates of delivery of Phase II data observed by some PSAPs primarily to PSAPs’ not “rebidding,” i.e., affirmatively seeking to “pull” the data from its source location, to obtain the Phase II data that the carriers are, in fact, providing.¹ Carriers indicate that while Phase II data is not always available to the PSAP on call set-up, it is subsequently delivered to the Mobile Positioning Center (MPC) (for GSM networks) or the Gateway Mobile Location Center (GMLC) (for CDMA networks) and is available for PSAPs through the “rebidding” process.² Other commenters contend, however, that even if PSAPs were to rebid more frequently, a 30-second delay in obtaining Phase II information is highly undesirable, given that a large percentage of 911 calls are under 30 seconds.³

24.There was general agreement among public safety commenters that the majority of calls to 911 are now coming from wireless phones, that this trend is increasing, and that a large number of these calls are made from indoor environments.¹ Vendors argue that indoor location technology has since evolved considerably, suggesting the provision of indoor location information may be within reach.² TruePosition suggests that a combination of handset- and network-based location technology can provide Phase II location information for both indoor and outdoor calls.³

25.proposed indoor location accuracy requirements

27.While PSAPs and CMRS providers may be able to address some of the challenges through technological and operational improvements, the record also indicates that the outdoor-oriented focus of the Commission’s Phase II rules to date has created a regulatory “gap”: by focusing on outdoor measurements for verifying compliance, our rules provide no remedy to address poor performance of location technologies indoors.

28.^{In addition to changes in wireless usage, there has also been recent progress in the development of technologies that could support improved indoor location accuracy. The CSRIC test bed results, together with parties’ representations that they have since been working on improvements to indoor location technologies, suggest that it is likely that location technologies can begin to be deployed in the near term that would deliver 50-meter location accuracy for many indoor environments with a high degree of reliability. The record also contains data suggesting the feasibility of using barometric pressure sensors in mobile devices to provide rough z-axis information when calls are placed from multi-story buildings. Finally, providers assert that the deployment of LTE networks will be accompanied by improvements in location technology that could drive improved performance for both indoor and outdoor calls,1 but they also express concern about whether they can realistically meet the proposed requirements based on currently available technology.2}

29.We believe that it is now appropriate to propose measures designed to address public safety’s critical need for obtaining indoor location information, and to ensure that wireless callers receive the same protection whether they place a call indoors or outdoors. In the following discussion, we propose a regulatory framework for addressing indoor location accuracy for wireless calls to 911 from indoors that includes a near-term requirement to achieve approximate indoor location information, comprised of horizontal (x- and y-axis) and vertical (z-axis) location information. We also seek comment on how to formulate a long-term requirement with an increased degree of location accuracy, sufficient to identify the caller’s specific address, floor level, and suite/room number within a building. We discuss below the achievability of these technical requirements on our proposed time frames, the potential benefits and costs of our proposed indoor location accuracy requirements, a proposed compliance testing framework, and possible exclusions from the proposed requirements to ensure they are imposed in a way that maximizes the rules’ effectiveness while mitigating the potential burdens on CMRS providers. We also seek comment on alternative approaches and, in this regard, invite relevant stakeholders – including public safety and industry – to propose a consensus approach that would help ensure that consumers placing wireless calls to 911 from indoor environments receive the same protections as callers in outdoor environments.