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911 Indoor Location Accuracy: Can a Caller Be Located?

Early in 2014, the Federal Communications Commission (FCC) proposed draft regulations to improve first responders’ ability to find people calling 911 using wireless devices. The regulations required carriers to meet standards for both horizontal (the X and Y axis) and vertical (the Z axis) location of such callers.

The draft FCC regulations would have required the wireless carriers to report the location of a wireless caller to a public-safety answering point (PSAP) accurately within 50 meters on the X and Y axis for 67% of the 911 calls from wireless devices within two years of the promulgation of the FCC’s rules.

The carriers would have to be able to report accurately the location of the caller on the Z axis within three meters on 67% of the 911 calls from wireless devices within three years of the promulgation of the regulations.

Within 5 years, the carriers would have to be able to report the location of the 911 caller from a wireless device accurately within 50 meters on the X and Y axis and 3 meters on the Z axis for 80% of the 911 calls from wireless devices.

In November 2014, a roadmap agreement, which differed from the proposed FCC rules, was entered into by the four nationwide wireless carriers (AT&T, Sprint, T-Mobile, Verizon), the Association of Public Safety Communications Officials International (APCO) and the National Emergency Number Association (NENA).

The roadmap proposed an alternative to the proposed rules, which would provide a dispatchable location (DL). On December 15, 2014, CTIA (the association representing all the major wireless carriers) submitted comments discussing the roadmap. In part II of the filing, CTIA stated that the roadmap establishes a near-term path to deliver DL information. The roadmap cites DL as the gold standard for wireless location information.

In the discussion, CTIA stated that “like an address sent with traditional wireline 911 calls today, DL provides an address for wireless 911 calls plus more specific information to send first responders the right door to kick in.” >(December 15, 2014, filing of comments of CTIA in docket 07-114, Wireless Location Accuracy Requirements, Roadmap for improving E911 Location Accuracy.)

T-Mobile filed similar comments in January 2015.

The 4th Rule and Order was released by the FCC on February 5, 2015, and became effective April 3, 2015. The FCC 4th Report and Order defines DL as being “the verified or corroborated street address of the calling party plus additional information such as floor, suite, apartment or similar information that may be needed to adequately identify the location of the calling party.”(FCC 4th Report and Order, February 2, 2015, effective April 3, 2015, paragraph 44)

The FCC 4th Report and Order cites the roadmap as using the term DL rather than a dispatchable address to describe the objective of the FCC’s Third Further Notice, which proposed indoor accuracy requirements based on X/Y/Z coordinates.

The FCC noted that public safety would be better served if PSAPs could receive the caller’s building address, floor level and suite or room number.

The 4th Report and Order allowed the roadmap signatories to use DL since the wireless carriers specified that in-building technology, such as small cells and WiFi and Bluetooth beacons, would make DL solutions technically feasible in a much shorter timeframe than anticipated.

The IAFC, the International Association of Chiefs of Police (IACP) and the National Association of State Emergency Medical Services Officials (NASEMSO) were asked by CTIA to join its 911 Advisory Group. As part of this effort, CTIA is leading an effort to develop the National Emergency Address Database (NEAD), which is intended to securely and privately store the already available millions of WiFi access points and Bluetooth beacons to help provide a DL to PSAPs.

The NEAD LLC was formed as an independent entity to administer and operate the NEAD consistent with the FCC’s rules. The NEAD LLC then selected the Alliance for Telecommunications Industry Solutions (ATIS) as the program manager for the NEAD. Through the NEAD and associated technology standards, the goal is that wireless carriers will be able to deliver a DL to a PSAP that will provide first responders with information to more quickly, effectively and safely respond to emergencies. The IAFC, IACP and NASEMSO have concerns with the standard.

At the Advisory Group’s quarterly meeting held in September 2016, the ATIS standards development process was discussed. The ATIS standard planned on having two levels of DL.

DL level 1 is information provided to the PSAP that will provide location information if the location is nearby or is either one floor above or below the individual in a multi-level structure.

In addition, it appears from the ATIS standard that an adjacent building or one across the street could qualify as DL level 1. The ATIS standard describes a situation where the building an individual calls from has no WiFi access points; an adjacent building has registered WiFi points and the NEAD sends the emergency responders to that building and describes this as the DL.

We strenuously disagree with this situation being deemed DL. 

DL level 2 as defined by the ATIS standard is the information that finds the individual on the same floor and the suite (in other words, “the right door to kick in”). DL level 2 follows the definition of DL in the roadmap and the FCC’s 4th Report and Order.

We raised our concerns with the standard at the meeting and in subsequent discussions with CTIA, the wireless carriers and APCO/NENA.

The IAFC, IACP and NASEMSO are adamant that only DL level 2 meets the FCC’s definition; describing level 1 as DL creates confusion and walks back from the FCC definition of DL.

We believe that DL is information that tells the emergency responders where the caller is located in a building. To use the term DL to describe a situation where an access point is located—and not necessarily where the person is located—will water down what the wireless carriers and APCO/NENA agreed to in the roadmap and the 4th Rule and Order.

The IAFC, IACP and NASEMSO have suggested that level 1 information be called “vicinity location” or a similar term to describe a location other than where the caller is located. Our suggestions have fallen on deaf ears.

The IAFC, the IACP, NASEMSO and the National Sheriffs Association recently filed comments with the FCC on this issue and will continue to monitor this situation to ensure that frontline first responders have the best information available to locate a person calling 911. We will continue to work to ensure the fire and EMS personnel receive accurate information for 911 calls.

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