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FCC Acts on 911 Accuracy

It's time for the annual assessment of 911 law and policy both in the U.S. and here in Erie County, New York, where I live. You've heard of spoiler alerts? Don't let this be a snooze alert. Knowledge about how 911 works could save your life or the life of someone you love, and you do need to be aware of significant developments, mostly related to location identification.

While we're still a long way from an optimal state, the laws and rules that govern American wireless carriers and the (mostly) municipally-owned public safety access points (PSAP) ultimately connecting a caller to a first responder are evolving slowly but surely. Maybe someday the laws will match the technology. But, as I said, we're not there yet. Not anywhere close.


When the FCC's rules governing wireless access to 911 were drafted in 1996, most calls from wireless devices were made from outside. Further, most people used landlines for the majority of their calls. As technology has evolved, individuals have become much less tethered to landlines. As a result, more calls than ever before are made to 911 from wireless devices, located indoors, where accurate location information is often a challenge to identify.

At an open meeting on Thursday, Jan. 29, FCC commissioners voted to adopt 911 accuracy rules. These represent a huge step forward in providing location information to first responders when callers dial 911 from within buildings. The rules do not, however, alleviate the problem -- they just clear one critical part of the path between a caller and the help that he or she needs.

Locating Points X,Y, and Z
After announcing some details on the extended deployment schedule, yesterday the FCC published the final report and order from last week's action. Included in this is a plan for nationwide and smaller carriers to deploy sophisticated location information based on both horizontal (X and Y coordinates) and vertical (Z coordinates) caller location. Major nationwide wireless providers must be prepared with an implementation plan within 18 months, with deployment taking place within 3 to 8 years. The catchphrase is "dispatchable location information," and it's a big step forward, although it won't happen fast. The good news is that it will happen, and those responsible for making it work should be busy planning now.

Specifically, the recent action has established a number of timelines for both nationwide and regional wireless providers to meet certain accuracy benchmarks for both horizontal and vertical location identification. Wireless providers will be required to identify on what floor and from within a 50-meter radius a call has been made. Accurate location information has been a huge problem for first responders, since in many circumstances the person making the call is unable to speak, and the first responder is unable to identify where precisely the help is needed.

However, this is only part of the picture. When an individual places a call (and I mean "call," not text -- more on this in a minute) to 911 from a mobile device, some identifying information is provided as part of the signal. That information goes from the location of the caller's device to the PSAP, which, more often than not, is owned and operated by a municipality, but never by the wireless provider. So any additional information that's potentially useful (the keyword is "potentially") is only beneficial if, in fact, the PSAP is able to receive and understand it.

As Avaya's Mark Fletcher, emergency number professional and chief architect – Public Safety Solutions, said recently, "I love to watch people design, build and show off their 220-mph Ferraris only to see them cringe when the only road they have is dirt and full of potholes. Nice car, [but] you sure can't drive it on that road!"

The same is true for the existing infrastructure supporting wireless calls to 911.

Breakdown at the PSAP
According to the National Emergency Number Association, slightly less than 6,600 PSAPs are located throughout the U.S. The vast majority of these are not capable of completing the link between the person texting for assistance and the responder. In May 2014, the four major carriers announced their compliance with text-to-911 requirements established by the FCC. In fact, they had reached compliance, but their action represents only an interim -- and by definition partial -- move toward reliable nationwide text-to-911 service because, unfortunately, the PSAPs are not capable of handling information that comes in text format.

While the four major carriers can support text-to-911 services, most PSAPs cannot. This means that the hearing and speech-impaired, one of the largest forces behind the push for text-to-911 capability, are still extremely limited in their collective ability to communicate with first responders when the need arises. As I mentioned previously on No Jitter, an estimated 37 million Americans are deaf, hard of hearing, or have a speech disability. The current step forward continues to leave this disenfranchised group out because of the technical limitations that currently exist on the infrastructure side, not due to carrier limitations.

On the infrastructure side, the first next step belongs to the municipalities and others that operate PSAPs. They must secure and deploy funding to provide sufficiently sophisticated equipment able to handle the additional data. Text-to-911 still doesn't work in most places for precisely this reason. As Fletcher pointed out: "While the 'visionaries' love to talk about all of this new stuff, the fact of the matter is that very few are addressing the fact that the existing network will not support anything other than voice!"

Without a 21st century PSAP, all of the useful location identification information possible isn't worth much. It's one thing for the carriers to provide greater quantities of critical granular location identification, but until services are deployed at the PSAP that can accommodate and process the additional information (both in terms of volume and content) and get that information to first responders (police, fire, medical), the additional information isn't useful. Someday it will be, but not yet.