New enhanced 911 location accuracy proposals endorsed by public-safety groups and the nation’s three largest mobile-phone carriers, while less stringent than now-defunct 2007 federal guidelines, have failed to win ringing endorsements by T-Mobile USA Inc., small and mid-size operators and major wireless vendors.
Indeed, T-Mobile USA teamed up with the Rural Cellular Association in raising questions about a network-based E-911 location accuracy proposal developed by the Association of Public Safety Communications Officials International, the National Emergency Number Association and AT&T Mobility.
“Although they [the proposed guidelines] provide a potentially usable framework, these proposals will not be technically and economically feasible for network-based carriers unless they are provided the same amount of time as AT&T has had from 3G network deployment to roll out assisted-GPS capable handsets to customers, and unless, among other things, counties in which terrestrial triangulation is impossible are excluded from compliance assessments until A-GPS handsets are sufficiently deployed so that compliance in those counties can be measured through the use of only A-GPS measurements and standards,” the parties claimed in a joint filing.
Likewise, in a separate filing, RCA told the Federal Communications Commission that handset-based E-911 location accuracy standards crafted by APCO, NENA and Verizon Wireless need refinement. Moreover, the trade group linked compliance challenges to national mobile phone operators’ clout in the handset market.
“Until the commission takes action to rein in the use of exclusivity arrangements by carriers like AT&T, Verizon Wireless and Sprint Nextel, smaller wireless carriers must be afforded more time to comply with heightened E-911 location accuracy requirements being proposed for carriers,” RCA stated. The FCC is seeking public comment on RCA’s request that handset exclusivity arrangements be investigated to determine whether they are anti-competitive.
Loosened standards
The E-911 location accuracy debate took a dramatic turn in July when APCO and NENA told the FCC they were willing to accept E-911 location accuracy compliance based at the county level rather than at public safety answering points as public safety groups previously advocated. The FCC, whose PSAP-based E-911 location accuracy rule faced legal challenges by RCA and national cellular operators, subsequently asked a federal appeals court to throw out the rule and return the matter to the agency.
While progress is being made, many in the wireless industry believe E-911 location accuracy proposals crafted by Verizon Wireless, AT&T Mobility and the public safety community need further scrutiny and should not be rushed into enactment. The Telecommunications Industry Association has recommended the creation of an E-911 technical advisory group, or ETAG, to address the issue.
“We appreciate public safety’s work with two major wireless providers to propose new E-911 rules,” said Danielle Coffey, VP for government affairs at TIA. “However, regardless of the specific provisions ultimately adopted by the FCC, efficient and accurate implementation of new E-911 accuracy requirements will be impossible without wireless network and device manufacturers working alongside public safety and wireless carriers.”
A number of vendors favor a deliberate approach that utilizes an industry advisory group to sort out technical and operational issues. So do many wireless providers.
“An ETAG will enhance the likelihood that the commission establishes technologically-feasible, attainable E-911 location accuracy requirements for all wireless carriers rather than the two largest carriers in the country,” U.S. Cellular Corp. told the FCC.
Under current rules, cellular operators must locate emergency callers anywhere between 50 meters and 300 meters of their actual position, depending on the type of technology used. CDMA carriers utilize handset-based technology, while GSM operators opt for network-based solutions.
Numbers debate
For carriers employing handset-based E-911 technology, the public safety-Verizon Wireless plan would require that calls be accurate within 50 meters 67% of the time and that 80% of calls be accurate within 150 meters within two years. At the eight-year mark, the percentage of calls that must be accurate within 150 meters would rise to 90%. The proposal would also provide compliance leeway for heavily wooded areas, such as those typically found in rural locales. Rural cellular carriers insist that excluding up to 15% of counties with heavy forestation is not adequate and that the exclusion should be increased to 25%.
Accuracy standards proposed by public safety groups and AT&T Mobility for carriers using network-based location solutions would require 67% of calls to be located with 100 meters within five years, 90% of calls within 300 meters by the end of year eight. Both standards would have interim compliance benchmarks, which could present problems for small and mid-size carriers.
Fines levied
In its September 2007 decision, the FCC ordered operators to meet interim and annual benchmarks during the next five years to ensure full compliance by Sept. 11, 2012. But those E-911 guidelines never went into effect as the U.S. Court of Appeals for the District of Columbia Circuit agreed to stay the ruling.
The FCC has fined a number of national operators in recent years for failure to meet E-911 obligations.
The FCC, wireless providers and the public-safety community have struggled to improve wireless E-911 for more than a decade, a situation complicated by technological capability, local and state budgets and shifting trends that have Americans increasingly making mobile phones their primary communications devices. The E-911 location accuracy debate has gained urgency with findings that current technology may be inadequate to locate the many emergency calls made indoors and in rural areas.
Federal telecom policymakers are examining whether there should be one, technology-neutral standard for wireless E-911 accuracy. Some companies, like Polaris Wireless, TruePosition Inc. and Rosum Corp., would stand to gain commercially if a hybrid approach is ultimately adopted.
