Concerns Remain with 911 Indoor Location Accuracy Implementation

In the March issue, On Scene asked on this topic, Can a Caller Be Located? This month, I want to touch on a couple of important issues to public safety and to the public in general. These include:

  • Dispatchable location and what it means to public safety and public expectations
  • Transparency in the testing process of technologies to accomplish the goal of finding someone calling 911

Wireless phones are now an undisputedly ubiquitous and critical link to 911 for most of the population. Estimates from industry groups and the public-safety community broadly agree that calls from mobile phones account for more than 70 percent of 911 calls, and many of these calls originate from indoors particularly in urban markets. With this understanding, it is critical that the 911 system meet the expectations of consumers when they call 911. There is a strong expectation that first responders will be able to locate 911 callers regardless of the device or location from which the call originates.

Dispatchable Location

In the March article, we provided information about the Alliance for Telecommunications Industry Solutions (ATIS) standard on location accuracy improvements for emergency calls, which has two levels of DL, and we explained what Public Safety’s concerns are with DL Level 1.

As noted in March, the IAFC, the International Association of Chiefs of Police (IACP), the National Association of State EMS Officials (NASEMSO) and the National Sheriffs Association filed comments with the FCC on February 21.

The ATIS standards were developed without the agreement of the CTIA location accuracy advisory group, in which we participate. Our concerns on having two levels of DL have fallen on deaf ears.

We cannot agree or support the description of DL Level 1 information as DL. Fire chiefs, police chiefs, EMS officials and sheriffs will not accept a DL Level 1 as being the “gold standard.”

Only calls with location information identified as DL Level 2, which is consistent with the FCC order, should count toward compliance with the carriers’ obligations to provide DL of the caller and not the location of a Wi-Fi hotspot.  To allow DL Level 1 to count toward compliance percentages is inconsistent with the true definition of DL in the Order and would remove every incentive for the carriers to improve performance and identify the location of the caller (DL-2) versus the location of the access point (DL-1). Test bed processes for DL accuracy testing should reflect this reality and match requirements of DL in the Order.

We filed comments on April 28 expressing our concerns on this.

Transparency, or the Lack Thereof

In our February 21 and April 28 submissions, our associations pointed out that a transparent process is clearly intended in the 4th Report and Order and in the Roadmap. The wireless carriers cited the FCC 4th Report and Order (paragraphs 131 & 132) as justification that during Stage 1 testing they’re not required to make public the details of test results for technologies that have been certified by the Test Bed LLC.

The carriers held a meeting on April 11 with the FCC on the issue of live call data, requesting the FCC to modify its reporting requirements to eliminate the need to report yield (or accuracy) as part of their live call reports.

We strongly agree with the FCC’s position on the need to provide this data. As the carriers note, the Order says the test bed results are used to determine “the degree to which that method can be counted towards the required location accuracy thresholds.”

The FCC’s reporting template simply requires that the resultant calculations of the ATIS 0500031 standard for the relevant market be included in the report. In our view, this all goes to the heart of the issue of transparency in the process.

The carriers indicate they’re providing data on a voluntary and confidential basis to help the FCC evaluate the 911 location-accuracy solutions. We take exception to this statement and believe the carriers have an obligation to provide data for the six (FCC) monitored markets, validating their compliance with the order.

Whether the FCC agrees to restrict public access to some portion of this data for confidentiality reasons, the summary levels of performance by the carrier, by market, by morphology and by technology are very valid elements of public interest, most particularly to our organizations and members who are highly dependent on the underlying accuracy that is being provided in emergency situations.

As we stated in our February 21 filing, the carriers are using confidentiality as a shield from providing an open and transparent process. The public at large and public safety need visibility into the technology-testing processes (including independent indoor location testing through the test beds and carrier-conducted outdoor testing), as well as ongoing live call accuracy performance in the six monitored markets.

 To cloak all test data from the public through a veil of confidentiality provisions and to disclose only the carriers’ certifications that they are in compliance is antithetical to the very concept of a transparent and open process.

Ultimately, finding an individual in a building is critical to satisfying the FCC Order and the need to assure the public that they can be found wherever they’re located. Also, finding a firefighter in a building that is on fire and full of smoke is essential.

There are outstanding questions that haven’t been addressed about how Wi-Fi, Bluetooth, small cells and other technologies the carriers are relying on to satisfy the Order will work in fire and smoke-filled environments. At this time, it’s unclear that Wi-Fi access points are located where the person is located.

The IAFC, along with our partners in public safety, will continue to insist that the carriers provide the technology that will pinpoint where a person is located and not an access point to fulfill the obligations of the Order. It’s also critical that these technologies can work in a building with its power off and full of fire and smoke. Otherwise, it’s incumbent upon the carriers to use other technologies that may only be useful for 911 purposes and location-based services (as opposed to Wi-Fi that’s used for wireless internet and other purposes).

The cost of not doing so and jeopardizing lives is unacceptable.

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