Updated: Aug 17, 2018

In the March Open Meeting, the Federal Communications Commission (the “Commission” or “FCC”) adopted a Notice of Inquiry (“NOI”) (FCC 18-32) exploring how delays that arise from the misrouting of wireless 911 calls can be avoided, possibly resulting in faster response times, via the implementation of location-based routing solutions (rather than the current tower-based routing system). The current 911 system is configured to route wireless 911 calls to PSAPs based on the location of the cell tower that handles the call, which may be a great distance from the caller’s location. Therefore, in some circumstances, the call may be answered by a different PSAP from the one that serves the caller’s location. In an effort to combat these delays, the FCC seeks comment on the following:

  • The current frequency of wireless 911 call misrouting and its impact on public safety; whether there are particular geographic areas or situations in which 911 calls are more likely to be misrouted;
  • Consumer expectations with respect to wireless 911 calling;
  • The CSRIC V LBR Report and the state of location-based routing technologies:
    • The finding that effective routing by location requires that a location be available to the Mobile Switching Center (“MSC”) in five seconds or less, however most currently deployed wireless 911 location technologies take an average of 15 to 23 seconds to calculate a Phase II fix.
    • The potential implementation of holding a wireless 911 call at a wireless MSC or the PSAP gateway until Phase II location is available (even if it is longer than six seconds). Neither CSRIC nor the Commission believes this should be pursued as an approach, but the FCC seeks comment on any new or additional information regarding this proposal.
    • The exploration of an interim or quick fix method of location-based routing where a wireless 911 call is held at a wireless MSC or the PSAP gateway for up to six seconds to allow the CMRS provider time to deliver X/Y coordinates that are plotted on a geospatial shape file to determine the appropriate PSAP. CSRIC finds that this will not require operational changes at the PSAP if CMRS providers generate the information, although additional work is needed to ensure that location and emergency call servers can appropriately process and handle an interim location fix and that device chipsets transmit timely measures.
    • The examination of the potential for a registered or provisioned civic address to be used as the basis for location-based routing of wireless 911 calls.
    • Whether the time taken for a 911 caller to reach a PSAP would be reduced to acceptable levels if handsets relied on environmental location information, e.g., signals from wireless routers or Bluetooth devices. The CSRIC Report finds that this method provides a latency of approximately five seconds, high location accuracy in many environments (including indoors), and is available from a wide variety of location providers.
  • The CSRIC V LBR Report and Wireless 911 Location Accuracy Emerging Technologies:
    • Whether indoor location technologies can also provide a location-based solution that will accelerate the time taken to route a 911 call to the proper PSAP.
    • Whether the NEAD will be capable of being leveraged to obtain a wireless 911 caller’s location for the purpose of routing a 911 call in five seconds or less.
    • The Report recommends that the FCC seek assurances from providers of location fixes that utilize proprietary standards-compliant databases that their databases and algorithms are maintained in a manner that assures consistent and accurate locations required for emergency services. The Report also recommends the FCC allow for periodic, standardized accuracy testing conducted by users and recipients of device-based hybrid locations; and provide metrics and other performance verification tools to CMRS providers to ensure location fixes meet accuracy and quality requirements.
  • Any additional solutions that can be leveraged to provide location-based routing for wireless 911 calls.
  • The implementation and relative merits and viability of each of the location-based routing solutions discussed above, for instance:
    • Existing 911 location routing standards that may be implicated;
    • Capabilities of location-based routing in a NG911 environment.
  • Means to Advance E911 Location-Based Routing: encouraging voluntary best practices or technical/operational implementation, incentive-based mechanisms or regulatory actions.
  • Other costs and benefits relating to location-based routing for E911.

Comments are due May 7, 2018.

Reply comments are due June 21, 2018

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