Reader Forum: FCC poised to tighten E-911 location accuracy rules and focus on future evolution

Editor’s Note: Welcome to our weekly Reader Forum section. In an attempt to broaden our interaction with our readers we have created this forum for those with something meaningful to say to the wireless industry. We want to keep this as open as possible, but maintain some editorial control so as to keep it free of commercials or attacks. Please send along submissions for this section to our editors at: dmeyer@ardenmedia.com or tford@ardenmedia.com.
Since the Obama Administration took office last year, the Federal Communications Commission, under its newly appointed Chairman Julius Genachowski, has adopted an ambitious and aggressive wireless agenda. The sheer volume of issues the FCC has chosen to tackle has created an environment of fast-paced action on initiatives of critical importance, such as creating the National Broadband Plan released in March of this year.
From the beginning, wireless enhanced-911 has been on the agenda, but it now appears to be working its way up the priority list for action in the coming months. Advances in E-911 technologies keep the U.S. industry competitive on a global scale, spurring innovation in an area where this country has been a leader since creating E-911 a decade and a half ago. The FCC, wireless carriers and public safety agencies all share credit for playing a cooperative role in getting E-911 to this point; this next phase will face challenges but will benefit customers and public safety agencies, and will ensure continued U.S. leadership in this area.
The FCC’s E-911 rules are designed to provide public safety call takers and dispatchers with location information for wireless emergency calls. Historically, the FCC divided wireless E-911 location functionality into two phases: Phase I (which provided the location of the cell site or base station handling the call); and Phase II (which provided more precise location, including the latitude and longitude of the caller).
The Phase II location services must meet FCC accuracy standards, which are different for carriers selecting network-based technologies versus those choosing handset-based technologies (GPS or Assisted GPS). For network-based carriers, the location systems must be better than 100 meters for 67% of the cases and better than 300 meters for 95% of cases. The tighter accuracy requirements for handset-based carriers essentially cut these in half, to better than 50 meters for 67% and better than 150 meters for 95% of cases.
These E-911 Phase II rules have been in place since the mid-90s and have remained essentially unchanged, despite advances in technology and maturity in the deployments. That situation looked like it was going to change in 2007, when the FCC issued a notice that proposed moving accuracy requirements to smaller geographical areas and sought comment on new proposals for testing and moving to a single standard. The FCC’s proposal to apply accuracy requirements at smaller geographical areas – specifically, at the Public Safety Answering Point level – was controversial. Carriers had been using nationwide or network-wide aggregation of accuracy performance, which allowed errors in rural areas to offset those in urban areas, or vice versa.
Late in 2007, the FCC released an order imposing the new E-911 accuracy standards at the PSAP level. It appeared that E-911 location accuracy would be improving, but those new rules were short-lived. The rules were appealed to the courts and in 2008 the D.C. Circuit Court stayed the accuracy order on procedural grounds, and the issue eventually returned to the FCC.
In response, the FCC modified the proposal to address some of the concerns and sought comment on county-level, rather than PSAP-level, accuracy standards proposed by public safety groups, APCO and NENA, and carriers, Verizon Wireless and AT&T Mobility. At that point, time ran out for the FCC as the Bush Administration left office and the Obama Administration came in.
After the new Administration appointed Chairman Genachowski, the FCC issued a notice to refresh the record on E-911, presumably in preparation to take action on new rules. Right now, the final FCC order on wireless E-911 location accuracy standards is expected to be released soon. It seems clear that the new rules will be established at the county level, perhaps with some modifications to take into account the very real challenges affecting rural and regional network-based carriers.
In addition, future advances in E-911 may be addressed in a further notice on other wireless E-911 standards, which is slated on the FCC’s action agenda for third quarter of this year. This upcoming further notice is likely to cover many of the challenges associated with next generation E-911, such as requirements for indoor accuracy testing and possible unification of standards. Indoor standards for E-911 are important because the majority of wireless calls are made indoors and there is a growing trend for wireless replacement of wireline services. Current E-911 accuracy standards are only for outdoor calls, which can paint an overly optimistic picture for performance indoors, where GPS technologies do not work well because of obstructions to the distant satellite signals. In addition, the FCC’s action agenda proposes a notice of inquiry on next generation E-911 issues in the fourth quarter, which may raise how the FCC should approach new licensed and unlicensed technologies, dual-mode handsets, and the role of E-911 for the rapidly changing broadband sector.
Some contributors have proposed combining handset-based GPS/A-GPS systems with network-based approaches into hybrid systems. Network-based technologies work best in high density environments, such as urban and indoors. In contrast, handset-based GPS systems work best in open sky rural and suburban settings. Blending the two approaches together into hybrid systems has the potential to provide consistent location performance across the range of environments, including indoors. Clearly this would benefit E-911 callers.
Expect to hear more in the coming weeks and months about FCC actions to tighten E-911 accuracy standards to the county-level and inquiries to address a range of future issues, like indoor performance. Many of these E-911 evolution steps being contemplated are likely to be controversial, as wireless service providers compete in a complex marketplace where the wireless and Internet worlds are rapidly merging.
Marty Feuerstein often represents Polaris Wireless on industry advisory committees, such as the FCC’s Communications, Security, Reliability, and Interoperability Council’s Working Group on E-911 Location Accuracy. He is a frequent invited speaker and panel session moderator at wireless conferences and tradeshows and holds 16 patents in wireless telecom, spanning the areas of communications systems, adaptive arrays, self-optimizing networks and position location methods. He can be reached at mfeuerstein@polariswireless.com.