Last week, FCC Chairman Pai announced a proposed draft called the Fifth Report & Order and Further Notice of Proposed Rulemaking with the stated intent of improving 911 vertical location accuracy (known as z-axis) when someone calls 911 using a mobile phone in a multi-story building.
The solution outlined in the Report and Order (R&O), based only on studies performed in a lab, will not meaningfully improve location accuracy or emergency response. Delivering an altitude estimate (z-axis) to a fireman is not useful – they need the floor/unit number. They don’t have the time to calculate the likely floor level…plus or minus nine feet. Furthermore, it will cost millions if not billions in wasted money by local governments to try and use the new unproven z-axis location technology.
Testing new technology under isolated, controlled conditions does not validate its viability in real-world situations. To-date, no live field trials using actual 911 calls have been conducted to validate the accuracy or usefulness of the z-axis technology. In fact, Apple cautioned the FCC about the limitations of deploying the new technology solely based on controlled experiments. At the same time, other promising dispatchable location solutions that could provide an accurate address, floor and unit with most 911 calls today have not been considered.
The FCC fact sheet for this proceeding makes the following claims:
“What the Fifth Report and Order Would Do:
- Adopt a z-axis accuracy metric of plus or minus 3 meters for 80 percent of wireless E911 calls from z-axis capable handsets.
- Require wireless carriers to validate through testing that their z-axis technology meets this metric.”
Most importantly, the R&O only requires wireless carriers to achieve these results in controlled test-bed environments – not live 911 calls.
Unlike horizontal location (x/y or street address) accuracy, which requires proof-of-performance measurements using actual live 911 call data, this new Order does not subject the wireless carriers to any proof-of-performance compliance using live 911 call data with respect to vertical z-axis location. In fact, the Order specifically states that:
- “We decline to require live call proof-of-performance testing”, and
- “We emphasize, however, that live call z-axis data reported by [wireless] providers will be used solely for informational purposes, not compliance purposes.”
In practice, the R&O does not require that any percentage of actual 911 calls made from within multi-story buildings will be accurate to within any vertical height range of where the handset is located. Not 80% or 8% of calls. Not 3 meters or 30 meters.
Dispatchable location has been kicked down the road
The new Fifth Further Notice of Proposed Rulemaking proceeding regarding dispatchable location (i.e., actual floor number) does not propose any new rules, nor does it provide any timeline for when a new rulemaking could be made. It is only a request for input. This is because the original dispatchable location option (National Emergency Address Database “NEAD”) adopted by the FCC in 2015 did not prove to be viable in practice. In this new Fifth Proposed Notice of Rulemaking, the whole concept of actual floor level information is now only provided as a question to be considered for the long term, asking, “would a 5, 7, or 10-year timeline be sufficient to achieve floor level accuracy?”
No incentives for private industry to solve the 911 location accuracy problem
The US government does not invest in or offer incentives for developing new technologies to solve problems of emergency location accuracy. It expects the private sector to develop the most innovative, cost-effective solutions. However, without any fixed time period for implementing a cost-effective solution and without any accurate measurement that will be subject to any proof-of-performance compliance criteria, there is no incentive for the private sector to solve this problem. In 2015, the FCC created a mandate for a dispatchable location option (floor level) in addition to z-axis to be implemented by the wireless carriers by 2021. By removing any live 911 call performance criteria for z-axis and pushing dispatchable location solutions into the distant, undetermined future, what incentives are there for wireless carriers, Internet Service Providers, and entrepreneurs to invest in solving this important problem?
The adoption of z-axis without additional location information does not save first responder and civilian lives
There have been multiple incidents in recent years where police have entered the wrong address based on faulty 911 location information, too often with tragic results. Lack of accurate location information in emergency situations places civilians, police and other emergency personnel at great risk.
AT&T, T-Mobile, Verizon, Apple, Google, Qualcomm, and APCO have all filed comments with the FCC expressing serious doubts about the state of reliability, accuracy and usability of z-axis technologies where the rubber meets the road – when first responders and civilian lives are on the line. Twenty-nine local police departments and 911 agencies sent letters to the FCC explaining that significant investments, to be paid for by local taxpayers, would be required in order for emergency communication centers and first responders to be able to use the z-axis data, regardless of accuracy. This is an unfunded mandate.
We strongly urge interested parties to request that the FCC remove the Fifth Report & Order and Fifth Further Notice of Proposed Rulemaking from the agenda for November 22, 2019. The FCC can and should do better! Kicking the can for 5 to 10 years on Floor/Unit Number is not displaying leadership on a complex issue. Perceived accomplishment is no substitute for real-world results.
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