On June 3, the Federal Communication Commission (FCC) issued three Consent Decrees regarding the enforcement action taken against Verizon, T-Mobile, and AT&T for not releasing vertical 9-11 location accuracy information (z-axis) in a timely matter. The IAFC has emphasized the need for accurate z-axis 911 location accuracy to be nationally distributed as quickly as possible.
Section 9.10(i)(2)(ii)(C) of the FCC’s rules require nationwide Commercial Mobile Radio Service (CMRS) providers to deploy either dispatchable location or z-axis technology in the top 25 cellular market areas (CMAs) by April 3, 2021. Section 9.10(i)(2)(iii) requires providers to certify their compliance via the 9-1-1 Location Technologies Test Bed with the requirements in section 9.10(i)(2)(ii)(C) sixty days thereafter. In November 2019, the FCC’s Fifth Report and
Order relating to vertical 9-11 location accuracy adopted a z-axis location accuracy metric of 3 meters above or below the handset (plus or minus 3 meters) for 80% of wireless E911 calls made from z-axis capable devices.
In February Verizon, T-Mobile, and AT&T filed petitions for waivers, requesting an 18-month extension to the April 3 deadline. The IAFC has actively been in contact with the FCC, strongly advocating for the national distribution of accurate z-axis information as quickly as possible and for the denial of Verizon, T-Mobile, and AT&T’s petitions for waiver.
The Consent Decrees issued on June 3 deny the 18-month extension requested in the petitions of waivers submitted by Verizon, T-Mobile, and AT&T (the carriers), fine each carrier $100,000 and require the following from the carriers:
(1) Delivery of Available Z-Axis Data: No later than seven days after the effective date of the Consent Decree, the carriers must deliver the z-axis location information that is available everywhere they are capable of delivering z-axis data and are not limited to the top 25 CMAs.
(2) Testing Milestones:
A. No later than 30 days after the effective date of this Consent Decree, the carriers must complete an initial round of testing in one CMA of the vertical location technologies. The testing must be conducted in dense urban, urban, and suburban morphologies.
B. No later than 45 days after the effective date of this Consent Decree, the carriers must submit a joint report to the FCC containing the aggregated results this testing by morphology.
C. No later than 75 days after the effective date of this Consent Decree, the carriers either directly or using must complete additional testing in two of the top 25 CMAs, including all of the morphologies (dense urban, urban, suburban, and rural).
D. No later than 90 days after the effective date of this Consent Decree, the carriers must submit a joint report to the FCC containing the aggregated results of this testing by morphology.
E. No later than 90 days after the effective date of this Consent Decree, the carriers must submit a report documenting individual testing to meet the testing conditions required within 30- and 75-day benchmarks.
(3) Dispatchable Location and Floor Level: No later than 90 days after the effective date of this Consent Decree, the carriers each must submit an initial progress report to the FCC describing what technologies are available to provide dispatchable location and floor level information, and how the carrier intends to implement such technologies, including any funding for testing of potential candidate technologies. Thereafter, the carriers shall submit biannual status reports due on June 15, 2022; December 15, 2022; June 15, 2023; and December 15, 2023.
(4) Provider Support to Public Safety Campaign/Best Practices on how PSAPs Can Receive and Use Z-Axis Location Information: No later than 180 days after the effective date of this Consent Decree, the carriers must develop and submit to the FCC’s Public Safety and Homeland Security Bureau a proposal for a campaign to educate PSAPs on the availability and delivery of z-axis location information from all technologies.
(5) Data on Z-Axis Capable Devices: No later than 90 days after the effective date of this Consent Decree, the carriers shall report to the FCC on z-axis-capable devices in its subscriber handset base to help illustrate its specific efforts to come into compliance with the FCC’s location accuracy rules.
(6) Compliance and Certification:
A. By April 3, 2022, the carriers must fully comply with all z-axis deployment requirements that would have been applicable to it on April 3, 2021, including provision of z-axis location information that meets the FCC’s metric and validation of all z-axis location solutions in the Test Bed.
B. By June 2, 2022, the carriers must submit a compliance certification that would have been due on June 2, 2021 consistent with the requirements of 47 CFR § 9.10(i)(2)(iii) and certifying that it has complied with all requirements of this Consent Decree, except for any such requirements that extend beyond June 2, 2022.
Though these Consent Decrees are not perfect, the IAFC approves the national dissemination of z-axis data and views them as step in the right direction. The IAFC will continue to work with the FCC to ensure that the deadlines and metrics set in these consent decrees will be met by the carriers and ensure that accurate z-axis information is distributed nationwide as quickly as possible.
Ryan Woodward is a government relations manager for the IAFC.