Recent FCC Action 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.  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.  There have been some significant developments in the past 12 months, mostly related to location identification. While we’re a still a long way from an optimal state, slowly but surely, the laws and rules that govern American wireless carriers and the (mostly) municipally-owned Public Safety Access Points (PSAP) that are the bones of the network infrastructure that ultimately connect the caller to the first responder, are evolving all the time. Maybe someday, the laws will match the technology. But 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.  Today’s action, while an important step forward, doesn’t alleviate the problem—it just clears one critical part of the path between a caller and the help that he/she needs.

At the FCC’s Open Meeting on January 29th, the FCC Commissioners voted to adopt 911 accuracy rules which represent a huge step forward in providing location information to first responders when callers dial 911 from within buildings.  Although the final report and order have not yet been published, some details on the extended deployment schedule were announced during the Open Meeting.  Included in this are a plan for nationwide and smaller carriers to deploy sophisticated location information based on both horizontal (X and Y coordinates) and vertical (Z coordinates) location of the caller. Major nationwide wireless providers must be prepared with a plan for implantation within 18 months, with actual deployment taking place over between 3 and 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 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 a call (and I mean “call,” not text. More on this in a minute) is made 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, never by the wireless provider.  So any additional information that’s potentially useful (key word is “potentially”) is only beneficial if, in fact, the PSAP is able to receive and understand it. As Mark Fletcher, ENP, and Chief Architect – Public Safety Solutions for major telecom equipment provider Avaya said recently, “I love to watch people design, build and show off their 220MPH Ferraris only to see them cringe when the only road they have is dirt and full of potholes. Nice car, you sure can’t drive it on that road!”  The same is true for the existing infrastructure supporting wireless calls to 911.
Of the just under 6600 PSAPs (according to NENA, the National Emergency Number Association) located throughout the U.S., the vast majority are not capable of completing the link between the texter and the responder.  Last May, the four major carriers announced that they were complaint 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 towards nationwide reliable text-to-911 service because, unfortunately, the PSAPs are not capable of handling information that comes in any format other than text.
While the four major carriers can support text-to-911 services, most PSAPs cannot. This means that one of the largest forces behind the push to text-to-911 capability, advocates of the hearing and speech-impaired population, are still extremely limited in their collective ability to communicate with first responders when the need arises.  As has been mentioned in a previous column for No Jitter, an estimated 37,000,000 Americans who are deaf, hard of hearing or with a speech disability, the current step forward continues to leave this disenfranchised group out because of the technical limitations that currently exist, not on the carrier/provider side, but on the infrastructure side.

On the infrastructure side, the first next step belongs to the municipalities and others that operate PSAPs. Funding to provide sufficiently sophisticated equipment to handle the additional data must be secured and deployed.  Text-to-911 still doesn’t work in most places for precisely this reason. And, according to Mr. Fletcher, “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.