By Jerry Wilke Director, Customer Team, West Safety Services
On March 15, 2019, the Federal Communications Commission (FCC) initiated the rulemaking process to review vertical location accuracy requirements for wireless carriers. In the FCC’s Fourth Further Notice of Proposed Rulemaking (Fourth FNPRM), the Commission stated that the vertical location metric will “more accurately identify the floor level for most 911 calls, reduce emergency response times, and save lives.”
The proposal put forth by the FCC suggests that nationwide Commercial Mobile Radio Service (CMRS) operators must provide the vertical location coordinates for wireless 911 callers within +/- three meters of the device, for 80% of wireless 911 calls in the top 25 Cellular Market Areas (CMAs) by April 3, 2021. This requirement would then become effective in the top 50 CMAs by April 3, 2023. Non-nationwide CMRS providers, including resellers that serve any of the top 25 or 50 CMAs would have an additional year to meet each of these benchmarks in the relevant CMAs.
What is interesting, is that the FCC proposal calls for a higher level of accuracy than CMRS carriers and CTIA originally suggested, but is not as stringent as some public safety representatives would like. Even some FCC commissioners felt that this three-meter metric doesn’t go far enough.
If you did not see this proposed rulemaking coming from the FCC’s 2015 Fourth Report and Order, it helps to read closely into the vertical location section, which explains what CMRS carriers are required to provide to the FCC for vertical compliance reporting. In 2018, the nationwide carriers were mandated to file a “Z” axis metric recommendation, and devices that provided “Z” location had to send that location through to Public Safety Answering Points (PSAPs). We have yet to see if the FCC will require PSAPs to provide a valid Request for Service (RFS) to the CMRS carriers to deploy and test “Z” axis measurements, but we recommend that you work with your regulatory and legal counsel to find out if an RFS is required, and/or file comments on the record within the comment period for this FNPRM. (The comment deadlines are not yet known, but Initial Comments are due 45 days from the date of publication in the Federal Register and Reply Comments are due 30 days later, or 75 days from the date of publication in the Federal Register.*)
Regardless of the final outcome of the proposed rulemaking, CMRS carriers do have options for compliance. CMRS carriers can use either a dispatchable address or “Z” axis metric to help with their vertical location compliance in the top 50 CMAs, as suggested under the current FCC proposal. At first glance, I can see two key solutions that could enable CMRS compliance.
The first option is the NEAD database. The NEAD database stores the dispatchable addresses of Bluetooth beacons and Wi-Fi hot-spot locations, which can then be used at the time of a 911 call for CMRS carrier compliance with the FCC’s Fourth Report and Order. For this to be an appropriate solution in accordance with FCC rules, the percentage of address location points stored in NEAD in the top 25 and 50 CMAs needs to be 25% of the population.
The second option is West’s Wireless Dispatchable Location Services (WDLS) solution. WDLS is a suite of wireless 911 location solutions (including the data points housed in the NEAD, device-based hybrid location data, and more) that, when bundled together, route emergency calls more accurately and deliver a 911 caller’s location data to the nearest PSAP more quickly than via traditional methods. Because of the breadth of data sources bundled into WDLS, it would allow CMRS operators to include that requisite “Z” location with their calls.
What also remains to be seen, is the position that CMRS carriers will take regarding vertical location. Under the proposed rules, carriers have two years to get vertical locations working to meet the benchmark of 80% and +/-3 meters, or they will need to deliver a dispatchable address to PSAPs. CMRS carriers hold the key to determining what level of wireless caller location is delivered to PSAPs, and how that location is delivered. If a better, more detailed location comes in sooner, it will be easier for the PSAPs to quickly dispatch public safety resources to the 911 caller’s location. Hopefully that results in more lives saved; ultimately, that’s something we can all get behind.
*Update: The dates were not known at the time of publication. Initial comments were due May 20, 2019 and reply comments were due June 18, 2019.