FCC Proposes Single E-911 Location Requirement for All Carriers
The FCC said in a rulemaking on E-911 location requirements all carriers -- GSM and CDMA -- likely will be required to meet the same accuracy standards. The text of the rulemaking also says the Commission believes it has the authority to order carriers to meet tougher testing requirements proposed by the Assn. of Public Safety Communications Officials, but is seeking comment anyway “out of an abundance of caution.” The FCC approved the item (CD June 1 p2) last Thurs., but released the text late Fri.
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“I was surprised,” a wireless industry source said: “The network-based spec is half as tight of a spec… That was not something I knew they were going to be interested in asking about.” The source said the key question is what the FCC does going forward: “You can regulate it down. You can make it effective in 6 months. You can make it effective in 6 years. I can’t tell you what’s troubling and what’s not troubling.”
Carriers with handset-based systems for E-911, relying on satellite identification of a GPS chip in the phone, must be able to locate 95% of callers within 150 m and 67% within 50 m under current rules. Carriers using network-based technology, using towers and triangulation, must be able to locate 95% of calls within 300 m and 67% within 100 m. The agency said it is “inclined” to impose the tougher handset-based requirement industrywide. Verizon Wireless, Sprint Nextel and other CDMA carriers use handset-based technology for E-911. AT&T and T-Mobile, the major GSM carriers, use the network-based method.
“Consumers cannot reasonably be expected to recognize the implications of the location technology used by their carrier, nor understand why one carrier would provide better reliability in an emergency than another,” the FCC said in the text of the rulemaking: “Accordingly, we tentatively conclude that the public interest would be better served by a single location accuracy requirement rather than the current separate accuracy requirements for network-and handset-based technologies.”
APCO asked the FCC to measure wireless carrier success in locating E-911 calls at the public safety answering point (PSAP) level, holding carriers accountable in areas where their performance lags. Carriers favor statewide averaging, which is an easier standard to meet.
Chmn. Martin originally proposed adopting the APCO request without seeking comment. But at last week’s agenda meeting, the Commission voted to roll the APCO proposal into a larger rulemaking. The Commission also imposed a tight schedule for comments on just that section of the rulemaking -- requiring initial comments 14 days after publication in the Federal Register, with replies due 7 days later. Comments on other sections of the rulemaking are due 60 days after publication, replies 30 days later.
“At its core, the goal of our E911 rules is to provide meaningful automatic location identification information that permits first responders to render aid, regardless of the technology or platform employed,” the FCC said: “While measuring location accuracy at the PSAP level may present challenges to both carriers and technology providers, the public interest demands that carriers and technology providers strive to ensure that when wireless callers dial 911, emergency responders are provided with location information that enables them to reach the site of the emergency as quickly as possible.”
The Commission said that while the Communications Act “does not expressly state that accuracy must be measured and tested at the PSAP level, we note that the Commission has never suggested that it is appropriate to average accuracy results over an entire state, much less over a multi-state carrier’s entire service area.” But the FCC said it decided to seek comment out of caution and to “ensure that we have full public input.”
The FCC also asks general questions about whether the standard should be tightened. “Is this standard still appropriate, given the advances in location technology that have occurred since the Commission adopted the current location accuracy standards in 1999?” the NPRM asks: “Should the Commission adopt more stringent accuracy requirements? Should the standard now include additional information, such as elevation?” The Commission also asks for comments on whether and how long to defer enforcement of new standards.
The NPRM asks a battery of questions on such issues as when and how compliance should be tested and how the standards could apply to subscribers who make a 911 call while roaming on another carrier’s system.
The NPRM also asks a series of questions about possible rules to be followed by interconnected VoIP operators whose service may be used in multiple locations as subscribers move devices to other computers. The FCC said it tentatively concludes that these carriers should have to follow the same accuracy standards as wireless carriers. “In light of this tentative conclusion, we ask that commenters provide input on all issues raised in this notice as though the accuracy requirements for those CMRS services would apply to all interconnected VoIP services that can be used in more than one location,” the FCC said.