FCC Releases PN Seeking to Update the Record on Wireless 911 Call Location-Based Routing

On June 9, 2022, the FCC released a Public Notice (“Notice”) seeking comment on Improving Wireless 911 Call Routing, which was adopted at the June Open Meeting.  The FCC asks parties to refresh the record on issues raised in the 2018 Location-Based Routing for Wireless 911 Calls Notice of Inquiry (“NOI”), which sought comment on the feasibility of location-based routing as a means of reducing the incidence of misrouted wireless calls to 911 and improving emergency response times.  In the Notice, the FCC seeks comment on enhancements in 911 location accuracy and intervening developments in location-based routing.

More specifically, the Notice seeks comment on the following:

  • Cell Sector-Based Misroutes: The Notice seeks updated information on the frequency of 911 call misrouting and its impact on public safety, including but not limited to, how many calls are misrouted per year, what proportion of wireless 911 calls are delayed due to the need to reroute them to the correct PSAP, the time of these delays, whether the delays are getting shorter or longer, and any other information that would help characterize the problem of cell sector-based misroutes, such as whether there particular locations or characteristics of locations where misroutes tend to occur.
  • Wireless Carrier Implementation of Location-Based Routing: The Notice seeks comment on wireless carrier implementation of location-based routing, including but not limited to, the extent of location-based routing solution implementation, the experience of PSAPs receiving wireless 911 calls via these solutions, the strengths and shortfalls experienced during implementation or testing, and any reasons why implementation of location-based routing would not be achievable.  The Notice asks for information on the one-time and ongoing costs for wireless carriers to implement location-based routing solutions in legacy E911, transitional, and NG911 environments, including any costs related to updating system architecture, testing, ongoing operation, and satisfying security requirements.  Comment is also sought on obstacles for implementing location-based routing, and whether there are specific considerations for small carriers for implementing location-based routing for 911 calls.
  • Transitions to Next Generation 911 and Location-Based Routing: The Notice seeks comment on the interdependencies of location-based routing technology and Next Generation 911 to optimize emergency response, including but not limited to, whether the availability of location-based routing has incentivized the transition to NG911, or, whether the implementation of NG911 incentivized wireless carriers to transition to location-based routing.  Additionally, the Notice asks whether the availability, speed, accuracy, or reliability of location-based routing capabilities improve as PSAPs transition from legacy 911 to NG911 operations, whether the transition to NG911 has caused additional routing issues, and the progress carries have made in implementing IP-to-IP interconnection.
  • Current State of Location-Based Routing Technologies: The Notice seeks comment on the current state of location-based routing technologies, including but not limited to, the five technologies identified by CSRIC V, and the extent to which such technologies would be capable of supporting location-based routing today within the time constraints defined by CSRIC V.  The Notice specifically seeks comment on how quickly 911 calls can be routed using DBH location technology in cold-start and warm-start scenarios, and whether location based routing technologies still result in a misroute.  In addition, the Notice seeks comment on the availability of location-based routing technologies for wireless subscribers and scenarios in which location-based routing is not feasible, including how widely available DBH solutions are on handsets on a carrier’s network, what percentage of handsets are capable of supporting location-based routing, and in what scenarios would location-based routing not be a feasible routing method (e.g. is it feasible on devices such as non-service initialized phones or for subscribers who choose not to or cannot use Wi-Fi or GPS).
  • Location-Based Routing for Text-to-911: The Notice seeks comment on the feasibility of implementing location-based routing for text-to-911, including but not limited to, whether location-based routing is a viable means of routing 911 text messages to the appropriate PSAP, whether implementation would require changes to carriers’ networks, SMS servers, or handsets, and what percentage of devices on wireless networks could support location-based routing for text-to-911.
  • Other Considerations: The Notice seeks comment on security, reliability, and privacy considerations related to location-based routing approaches.
  • Means Available to the Commission to Improve 911 Routing: The Notice seeks comment on how the Commission can advance implementation of location-based routing, including but not limited to, incentives to encourage the development and implementation of location-based routing for wireless 911 calls, if there are any regulatory steps to help with this implementation, and if there are pre-existing regulatory impediments to the development and implementation of location-based routing.
  • Digital Equity and Inclusion: The Notice seeks comment on digital equity and inclusion, including but not limited to, the ways in which improving wireless location-based routing may promote or inhibit advances in diversity, equity, inclusion, and accessibility, as well the scope of the Commission’s relevant legal authority.

Comments will be due 30 days after publication in the Federal Register and reply comments will be due 45 days after publication in the Federal Register.

Please Contact Us if you have any questions.

Recent Posts

June 29, 2022 Weekly Wireless Wrap-Up

Good afternoon from Washington, DC!  Below you will find our Weekly Wireless Wrap-Up, your update on the wireless telecommunications regulatory landscape, important wireless decisions, and

Read More