T-Mobile, Verizon, and AT&T enter into Consent Decrees re: E 911 Z-Axis Reporting Rules

On Thursday, June 3, 2021, the FCC announced that it reached settlements with three nationwide wireless carriers concerning their compliance with obligations to deploy vertical location technology in each of the top 25 cellular market areas by the deadlines established by the Commission.  The three consent decrees with T-Mobile USA (DA 21-625), Cellco Partnership d/b/a Verizon Wireless (DA 21-626), and AT&T Services (DA 21-627) require each carrier to provide available z-axis location information on a nationwide basis within seven days, implement a compliance plan that includes testing, reporting, and public interest conditions, and pay a $100,000 settlement amount.

As a reminder, the Commission’s rules require nationwide wireless providers to deploy dispatchable location or meet certain z-axis location accuracy requirements in the nation’s largest 25 markets by April 3, 2021, and to certify this information by June 2, 2021.  Each of the carriers filed for a waiver and extension of these deadlines, prompting the Enforcement Bureau to inquire about the provider’s compliance with FCC deadlines.  Subsequently, the carriers and the Enforcement Bureau entered into settlement negotiations, resulting in the present consent decrees.

The consent decrees requires the carriers to comply with the following conditions:

  • Compliance Officer:  The carriers must designate a Compliance Officer within 30 days to implement and administer the compliance plan proscribed by the consent decree.
  • Compliance Plan:  The carrier must implement a compliance plan which requires the following reporting requirements:
    • Delivery of Available Z-Axis Data:  The carrier must deliver all available z-axis location information within seven days.  This requirement applies everywhere the carrier is capable of delivering z-axis data and is not limited to the top 25 CMAs.
    • Testing Milestones:  The carrier must complete an initial round of testing of their vertical location technologies in one CMA within 30 days.  Further, the carrier must complete additional testing in two of the top 25 CMAs within 75 days.  The carrier must submit a report detailing its findings within 90 days.
    • Dispatchable Location and Floor Level:  The carrier must submit an initial progress report describing its dispatchable location and floor level technologies within 90 days, and must file biannual status reports thereafter and until December 15, 2023.
    • Provider Support to Public Safety Campaign:  The carrier must work alongside the other two carriers and a public safety entity to develop a proposal for a campaign to educate PSAPs on the availability and delivery of z-axis location information.
    • Data on Z-axis Capable Devices:  The carrier must file a report on the Z-axis capable devices in its subscriber handset base within 90 days.
    • Compliance and Certification:  The carrier must full comply with all z-axis deployment requirements that would have been applicable to it on April 3, 2021 as well as the June 2, 2021 certification requirements by April 3, 2022 and June 2, 2022, respectively.
  • Settlement Amount:  The carrier must pay a settlement amount of $100,000 to the United States Treasury.
  • Reporting Noncompliance:  The carrier must report any noncompliance within fifteen days of discovery of noncompliance.
  • Termination Date:  The consent decree and its requirements expire on December 21, 2023.

The Commission hopes to use the testing and reporting required by the consent decree to further public safety objectives and improve 911 location accuracy capabilities throughout the country.

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