Wireless E911 Location Accuracy Requirements

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Wireless E911 Location Accuracy Requirements

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Federal Communications Commission

FCC 15-9

Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Wireless E911 Location Accuracy Requirements

)
)
)

PS Docket No. 07-114

FOURTH REPORT AND ORDER
Adopted: January 29, 2015

Released: February 3, 2015

By the Commission: Chairman Wheeler and Commissioners Rosenworcel, Pai, and O’Rielly issuing
separate statements; Commissioner Clyburn concurring and issuing a statement.
TABLE OF CONTENTS
Heading

Paragraph #

I. INTRODUCTION AND EXECUTIVE SUMMARY ........................................................................... 1
II. BACKGROUND.................................................................................................................................... 9
III. INDOOR LOCATION ACCURACY REQUIREMENTS .................................................................. 14
A. Ubiquity and Challenges of Indoor Wireless Calling .................................................................... 16
B. E911 Location Accuracy Requirements ........................................................................................ 20
1. Incorporation of Roadmap and Parallel Path Commitments ................................................... 22
2. Dispatchable Location............................................................................................................. 41
3. Horizontal Location Information............................................................................................. 74
4. Vertical Location Information............................................................................................... 105
5. Implementation Issues........................................................................................................... 121
C. Benefits and Costs of Indoor Location Accuracy ........................................................................ 158
1. Benefits of Improved Indoor Wireless Location Accuracy................................................... 159
2. Costs of Improved Indoor Wireless Location Accuracy ....................................................... 167
IV. IMPROVING THE DELIVERY OF PHASE II LOCATION INFORMATION .............................. 171
A. Latency (Time to First Fix).......................................................................................................... 172
B. Retaining E911 Phase II Location Accuracy Standards for Outdoor Measurements .................. 179
C. Confidence and Uncertainty (C/U) Data...................................................................................... 182
D. Provision of Live 911 Call Data .................................................................................................. 190
E. Outdoor Compliance Testing and Reporting ............................................................................... 193
F. Roaming Issues ............................................................................................................................ 199
V. PROCEDURAL MATTERS.............................................................................................................. 201
A. Accessible Formats ...................................................................................................................... 201
B. Regulatory Flexibility Analysis ................................................................................................... 202
C. Paperwork Reduction Analysis.................................................................................................... 203
D. Congressional Review Act........................................................................................................... 204
VI. ORDERING CLAUSES..................................................................................................................... 205
APPENDIX A – List of Commenters
APPENDIX B – List of Top 50 Cellular Market Areas
APPENDIX C – Final Regulatory Flexibility Analysis
APPENDIX D – Final Rules

Federal Communications Commission
I.

FCC 15-9

INTRODUCTION AND EXECUTIVE SUMMARY

1.
In this Fourth Report and Order, we adopt measures that will significantly enhance the
ability of Public Safety Answering Points (PSAPs) to accurately identify the location of wireless 911
callers when the caller is indoors. We also strengthen our existing E911 location accuracy rules to
improve location determination for outdoor as well as indoor calls.
2.
Our actions in this order respond to major changes in the wireless landscape since the
Commission first adopted its wireless Enhanced 911 (E911) location accuracy rules in 1996 and since the
last significant revision of these rules in 2010. Consumers are increasingly replacing traditional landline
telephony with wireless phones;1 the majority of wireless calls are now made indoors; and the majority of
calls to 911 are from wireless phones. This increases the likelihood that wireless 911 calls will come
from indoor environments where traditional location accuracy technologies optimized for outdoor calling
often do not work effectively or at all. This gap in the performance of 911 location service needs to be
closed: the public rightfully expects 911 location technologies to work effectively regardless of whether a
911 call originates indoors or outdoors.
3.
The record in this proceeding also indicates that a range of potential solutions to this gap
already exist and have the potential to be implemented over the next few years through concerted effort
by Commercial Mobile Radio Service (CMRS) providers and PSAPs. These solutions will both lead to
more accurate horizontal location of indoor calls, and add the capacity to provide vertical location
information for calls originating in multi-story buildings. In addition, the record makes clear that the
potential exists to move beyond coordinate-based location and to provide PSAPs with “dispatchable
location” information for many indoor 911 calls, i.e., a street address plus sufficient information, such as
floor and room number, to identify the location of the caller in the building.
4.
To be sure, no single technological approach will solve the challenge of indoor location,
and no solution can be implemented overnight. The requirements we adopt are technically feasible and
technologically neutral, so that providers can choose the most effective solutions from a range of options.
In addition, our requirements allow sufficient time for development of applicable standards, establishment
of testing mechanisms, and deployment of new location technology in both handsets and networks. Our
timeframes also take into account the ability of PSAPs to process enhancements in the location data they
receive. Clear and measurable timelines and benchmarks for all stakeholders are essential to drive the
improvements that the public reasonably expects to see in 911 location performance.
5.
In determining the appropriate balance to strike in our requirements and timeframes, we
give significant weight to the “Roadmap for Improving E911 Location Accuracy” (Roadmap) that was
agreed to in November 2014 by the Association of Public Safety Communications Officials (APCO), the
National Emergency Number Association (NENA), and the four national wireless CMRS providers,2 and
supplemental commitments related thereto as discussed below. We give similar weight to the “Parallel
Path for Competitive Carriers’ Improvement of E911 Location Accuracy Standards” (“Parallel Path”) that
was submitted by the Competitive Carriers Association (CCA).3 We believe the Roadmap and the
1

For purposes of this notice, we use the terms “mobile” and “wireless” interchangeably. These terms do not
encompass, for example, cordless telephones such as those using the DECT standard or PBX handsets using Wi-Fi
connectivity.
2

See Letter, John Wright, APCO International (APCO); Charles W. McKee, Sprint Corporation (Sprint); Joan
Marsh, AT&T Services, Inc. (AT&T); Kathleen O’Brien Ham, T-Mobile USA, Inc. (T-Mobile); Christy Williams,
National Emergency Number Association (NENA); Kathleen Grillo, Verizon Wireless (Verizon), to Marlene H.
Dortch, Secretary, Federal Communications Commission, PS Docket No. 07-114 (filed Nov. 18, 2014) (Roadmap
Cover Letter), Attachment A, “Roadmap for Improving E911 Location Accuracy” (Roadmap), available at
http://apps.fcc.gov/ecfs/document/view?id=60000986637 (last visited Jan. 13, 2015).
3

See Competitive Carrier Association Ex Parte Letter (filed Jan. 23, 2015) (Parallel Path Cover Letter), and
Competitive Carrier Association Ex Parte Letter, Attachment “Parallel Path” (filed Jan. 16, 2015) (Parallel Path).

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FCC 15-9

Parallel Path establish an essential foundation for driving improvements to indoor location accuracy, and
we therefore incorporate their overall timelines and many of their provisions into the rules adopted in this
order. In addition, to provide greater certainty and accountability in areas that the Roadmap and the
Parallel Path do not fully address, the rules we adopt today include additional elements with “backstop”
requirements derived from our proposals in the Third Further Notice and recent ex parte submissions by
the parties to the Roadmap.4
6.

Incorporating all of these elements, we adopt the following E911 location rules:

Horizontal Location


All CMRS providers must provide (1) dispatchable location,5 or (2) x/y location within 50
meters, for the following percentages of wireless 911 calls within the following timeframes,
measured from the effective date of rules adopted in this Order (“Effective Date”):
 Within 2 years: 40 percent of all wireless 911 calls.
 Within 3 years: 50 percent of all wireless 911 calls.
 Within 5 years: 70 percent of all wireless 911 calls.
 Within 6 years: 80 percent of all wireless 911 calls.



Non-nationwide CMRS providers (regional, small, and rural carriers) can extend the five- and
six-year deadlines based on the timing of Voice over Long Term Evolution (VoLTE) deployment
in the networks.

Vertical Location


All CMRS providers must also meet the following requirements for provision of vertical location
information with wireless 911 calls, within the following timeframes measured from the Effective
Date:
 Within 3 years: All CMRS providers must make uncompensated barometric data
available to PSAPs from any handset that has the capability to deliver barometric sensor
data.
 Within 3 years: Nationwide CMRS providers must use an independently administered
and transparent test bed process to develop a proposed z-axis accuracy metric, and must
submit the proposed metric to the Commission for approval.
 Within 6 years: Nationwide CMRS provides must deploy either (1) dispatchable location,
or (2) z-axis technology that achieves the Commission-approved z-axis metric, in each of
the top 25 Cellular Market Areas (CMAs)6:
 Where dispatchable location is used: the National Emergency Address Database
(NEAD) must be populated with a total number of dispatchable location
reference points in the CMA equal to 25 percent of the CMA population.
 Where z-axis technology is used: CMRS providers must deploy z-axis
technology to cover 80 percent of the CMA population.

See Ex Parte Letter from APCO, AT&T, NENA, T-Mobile, Sprint, and Verizon (filed Jan. 23, 2015); CTIA Ex
Parte Letter (filed Jan. 23, 2015).
5

See infra Section III.B.2 paras. 43-44.

Cellular Market Areas (CMAs) consist of both Metropolitan Statistical Areas (MSAs) and Rural Service Areas
(RSAs). The commitments in the Roadmap Addendum were based on CMAs as defined by 2010 census data. For
purposes of this Report and Order, CMAs will be delineated based on information from the 2010 Census. See infra
Appendix B for a list of the top 50 CMAs.

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


FCC 15-9

Within 8 years: Nationwide CMRS providers must deploy dispatchable location or z-axis
technology in accordance with the above benchmarks in each of the top 50 CMAs.
Non-nationwide carriers that serve any of the top 25 or 50 CMAs will have an additional
year to meet these benchmarks.

Reporting and Compliance Measures




Compliance with the above metrics will be determined by reference to quarterly live 911 call data
reported by CMRS providers in six cities (San Francisco, Chicago, Atlanta, Denver/Front Range,
Philadelphia, and Manhattan Borough, New York City) and their surrounding areas that have
been determined to be representative of dense urban, urban, suburban, and rural areas nationally.
Quarterly reporting of this data will begin no later than 18 months from the Effective Date.
Beginning no later than 18 months from the Effective Date, CMRS providers in the six cities will
also provide quarterly live call data on a more granular basis that allows evaluation of the
performance of individual location technologies within different morphologies (e.g., dense urban,
urban, suburban, rural). This more granular data will be used for evaluation and not for
compliance purposes.
PSAPs will be entitled to obtain live call data from CMRS providers and seek Commission
enforcement of these requirements within their jurisdictions, but they may seek enforcement only
so long as they have implemented policies that are designed to obtain all 911 location information
made available by CMRS providers pursuant to our rules.
In order to gauge progress on the development of improved indoor location accuracy solutions
and the implementation of these rules, nationwide CMRS providers must submit reports on their
initial plans for implementing improved indoor location accuracy and must submit subsequent
reports on their progress.

The foregoing rules leverage many aspects of the Roadmap and the Parallel Path to improve indoor
location accuracy in a commercially reasonable manner. They do not change, or seek to change, the
voluntary commitment that both nationwide and non-nationwide CMRS providers voluntarily have
entered into and have already made progress towards. The rules are intended to build confidence in the
technical solutions outlined in the Roadmap and Parallel Path, and to establish clear milestones that gauge
progress and ensure that there is clear accountability for all CMRS providers.
7.
In addition, we revise our regulatory framework for all 911 calls, both indoor and
outdoor, as follows:


We adopt a 30-second limit on the time period allowed for a CMRS provider to generate a
location fix in order for the 911 call to be counted towards compliance with existing Phase II
location accuracy requirements that rely on outdoor testing, but we do not extend this provision to
the new indoor-focused requirements adopted in this order.



We require that confidence and uncertainty data for all wireless 911 calls – whether placed from
indoors or outdoors – be delivered at the request of a PSAP, on a per-call basis, with a uniform
confidence level of 90 percent.



We require CMRS providers to provide 911 call data, including (1) the percentage of wireless
911 calls to the PSAP that include Phase II location information, and (2) per-call identification of
the positioning source method or methods used to derive location coordinates and/or dispatchable
location, to any requesting PSAP. Compliance with the 30-second time limit will also be
measured from this data.

8.
In establishing these requirements, our ultimate objective is that all Americans using
mobile phones – whether they are calling from urban or rural areas, from indoors or outdoors – have
technology that is functionally capable of providing accurate location information so that they receive the
support they need in times of emergency. We also view these requirements as a floor, not a ceiling. We
4

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FCC 15-9

encourage CMRS providers to take advantage of the potential of rapidly-developing location technology
to exceed the thresholds and timelines established by this order. In addition, we encourage CMRS
providers to work with public safety organizations and consumer organizations, including disability
organizations, to develop new and innovative solutions that will make all Americans safer.
II.

BACKGROUND

9.
In February 2014, we released the Third Further Notice in which we proposed to revise
our existing E911 framework to require delivery of accurate location information to PSAPs for wireless
911 calls placed from indoors.7 In the near term, we proposed to establish interim indoor accuracy
metrics that would provide approximate location information sufficient to identify the building for most
indoor calls, as well as vertical location (z-axis or elevation) information that would enable first
responders to identify floor level for most calls from multi-story buildings.8 In the long term, we sought
comment on how to develop more granular indoor location accuracy requirements that would provide for
delivery to PSAPs of in-building location information at the room or office suite level.9 In addition, we
sought comment on other steps the Commission should take to strengthen our existing E911 location
accuracy rules to ensure delivery of more timely, accurate, and actionable location information for all 911
calls.10 We also asked whether we should revisit the timeframe established by the Commission in 2010
for replacing the current handset- and network-based outdoor location accuracy requirements with a
unitary requirement, in light of the rapid proliferation of Assisted Global Navigation Satellite Systems (AGNSS)11 technology in wireless networks and the prospect of improved location technologies that will
soon support 911 communication over LTE networks.12 A detailed examination of these proposals and
the subsequent comment record is discussed below.
10.
In setting forth these proposals, we emphasized that our ultimate objective was that all
Americans using mobile phones – whether calling from urban or rural areas, from indoors or outdoors –
have technology that is capable of providing accurate location information in times of an emergency.13
We sought comment on whether our proposals were the best way to achieve this objective, and we also
“encourage[d] industry, public safety entities, and other stakeholders to work collaboratively to develop
alternative proposals for our consideration.”14
11.
On November 18, 2014, APCO, NENA, AT&T Mobility, Sprint Corporation, T-Mobile
USA, Inc., and Verizon Wireless (collectively, “Roadmap Parties”) submitted the Roadmap. According
7

Wireless E911 Location Accuracy Requirements, Third Further Notice of Proposed Rulemaking, 29 FCC Rcd
2374 (2014) (Third Further Notice). The Third Further Notice includes a detailed history of this proceeding,
including inter alia an overview of the regulatory background on E911; certain findings on indoor location accuracy
made by Working Group 3 (WG3) of the Communications Security, Reliability, and Interoperability Council
(CSRIC); and data on E911 location accuracy and call tracking, in particular regarding an apparent significant
decrease in the percentage of wireless 911 calls that were delivering Phase II location information to public safety
answering points (PSAPs).
8

Third Further Notice, 29 FCC Rcd at 2375-76 ¶ 2.

Id.

Id. at 2376 ¶ 4.

GNSS is a system of satellites that provide autonomous geo-spatial positioning with continuous global coverage;
GPS is considered to be the first GNSS system. GNSS receivers operate primarily in the 1559-1610 MHz
Radionavigation Satellite Service (RNSS) allocation. Other GNSS operations include Russia’s Global Navigation
Satellite Systems (GLONASS) system (which is the only globally operational system other than GPS), and the
Chinese BeiDou (COMPASS) and European Galileo systems (which are not yet operating globally).
12

Third Further Notice, 29 FCC Rcd at 2376 ¶ 4.

Id. at 2377 ¶ 6.

Id.

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FCC 15-9

to the Roadmap Parties, the Roadmap “marks a new course using indoor technologies to deliver a
‘dispatchable location’ for indoor 9-1-1 calls” and “contrasts with current and proposed outdoor
technologies that provide estimates of location and face challenges with indoor location accuracy,”15
adding that “the Roadmap commits to meaningful improvements and FCC-enforceable timeframes to
deliver effective location solutions.”16 On November 20, 2014, we sought expedited comment on the
Roadmap.17 We received extensive comment in response, both supportive and critical of the Roadmap.
12.
Following the submission of comments on the Roadmap, CCA submitted its Parallel Path
proposal on behalf of its members, which include most of the nation’s non-nationwide CMRS providers,
including small, regional, and rural carriers.18 The Parallel Path for the most part tracks the Roadmap,
and commits the non-nationwide CMRS providers to the same approach and requirements for improving
indoor location that the nationwide CMRS providers committed to in the Roadmap. However, the
Parallel Path proposes to modify certain Roadmap benchmarks and timeframes to afford non-nationwide
CMRS providers more time and flexibility to meet their commitments.
13.
Most recently, in response to criticism of the Roadmap by some commenters and to
concerns raised by Commission staff, the Roadmap Parties have amended the Roadmap to strengthen
certain provisions and incorporate additional commitments by the nationwide CMRS providers,
particularly with respect to deployment of dispatchable location and z-axis technologies.19
III.

INDOOR LOCATION ACCURACY REQUIREMENTS

14.
The record in this proceeding demonstrates that circumstances affecting wireless location
accuracy have changed dramatically since the Commission first adopted its Phase II location accuracy
rules. As discussed in the Third Further Notice, the great majority of calls to 911 now originate on
wireless phones, and the majority of wireless calls now originate indoors.20 These changes increase the
importance of ensuring that indoor 911 calls can be accurately located. The record also indicates that,
while PSAPs and CMRS providers may be able to address some of the challenges through technological
and operational improvements, the outdoor-oriented focus of the Commission’s Phase II rules to date has
created a regulatory gap: by focusing on outdoor requirements for verifying compliance, our rules
currently provide no remedy to address poor performance of location technologies indoors.

Roadmap Cover Letter at 1.

Id. at 2.

Public Safety and Homeland Security Bureau Seeks Comment in the E911 Location Accuracy Proceeding on the
Location Accuracy “Roadmap” Submitted by APCO, NENA, and the Four National Wireless Carriers, Public
Notice, PS Docket No. 07-114 (rel. Nov. 20, 2014) (Roadmap PN). In addition, the Commission has received
several thousand e-mail messages from individuals with respect to its proposals and/or the Roadmap. As noted in
Appendix A, these have been incorporated into the record of this docket.
18

See Competitive Carrier Association Ex Parte Letter, Attachment “Parallel Path” (filed Jan. 16, 2015) and
Competitive Carrier Association Ex Parte Letter (filed Jan. 23, 2015).
19

See AT&T, Sprint, T-Mobile, and Verizon Ex Parte Letter at 3 (“Addendum”) (filed Jan. 21, 2015). See also
APCO Ex Parte Letter (filed Jan. 21, 2015) and NENA Ex Parte Letter (filed Jan. 21, 2015) (both expressing
support for the Addendum). The parties to the Roadmap, after reviewing various comments and ex partes filed in
this proceeding, and pursuant to consultation with public safety entities, sought to modify certain aspects of the
initial Roadmap. See also APCO, AT&T, CTIA, NENA, Sprint, T-Mobile USA, and Verizon Ex Parte Letter (filed
Jan. 23, 2015) (modifying certain aspects of the Addendum). We refer to the Roadmap, Addendum, and
modifications to the Addendum collectively as the “Amended Roadmap.”
20

Third Further Notice, 29 FCC Rcd at 2387 ¶ 29.

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FCC 15-9

15.
The record in this proceeding – including the CSRIC test bed results,21 the Amended
Roadmap and Parallel Path, and other evidence indicating further improvements to indoor location
technologies – also demonstrates that there has also been progress in the development of technologies that
can support improved indoor location accuracy. Accordingly, we find that it is now appropriate to
implement measures designed to address public safety’s critical need for obtaining indoor location
information, and to ensure that wireless callers receive the same protection whether they place a 911 call
indoors or outdoors.
A.

Ubiquity and Challenges of Indoor Wireless Calling

16.
Background. In the Third Further Notice, we noted that the large increase in indoor
wireless usage over the last decade has made indoor location accuracy increasingly important.22
Accordingly, we sought more granular information regarding the percentage of wireless calls placed from
indoors and, to the extent available, the percentage of wireless calls to 911 from indoors.23 We also
sought further data on the types of indoor environments from which 911 calls are placed, e.g., in the
caller’s own home, his or her work location or in public accommodations such as airports, schools and
movie theaters; and whether it is possible to identify the type of building morphology where current
location technologies routinely fail to provide accurate location information.24 In response to this inquiry,
commenters indicate an “ongoing, dramatic increase” in the number of wireless calls placed from
indoors.25
17.
In the Third Further Notice, we also noted that indoor locations pose particular
challenges for first responders attempting to find the caller. We sought comment on whether and how the
increase in wireless calls to 911 from indoors has affected the delivery of E911 information and the
ability of public safety officials to respond to calls for help.26 APCO indicates that location accuracy for
wireless calls placed from indoors is currently inferior to both wireline calls placed from indoors and
wireless calls placed from outdoors.27 The Department of Emergency Management for San Francisco
(DEMSF) states that problems with wireless indoor location accuracy are particularly acute “in dense
urban environments with multiple, adjacent high-rise buildings.”28 Commenters indicate that the increase
in wireless 911 calls from indoors has affected the delivery of E911 information and eroded the ability of
public safety officials to respond to calls for help, and to keep first responders safe.29
21

See generally CSRIC III Working Group 3, Indoor Location Test Bed Report (Mar. 14, 2013), available at
http://transition.fcc.gov/bureaus/pshs/advisory/csric3/CSRIC_III_WG3_Report_March_%202013_ILTestBedReport
.pdf (last visited Jan. 2, 2015) (Indoor Location Test Bed Report).
22

Third Further Notice, 29 FCC Rcd at 2387 ¶ 30.

Id.

APCO Comments at 1. See also IAFC Comments at 1; NENA Comments at 13 (“NENA’s members report that
more than 80% of 9-1-1 calls in many jurisdictions now come from wireless devices, and that a large-but-difficultto-quantify fraction of those calls come from indoors . . . More than 40% of U.S. households are now wireless-only,
and that fraction will continue to grow.”); FindMe911 Reply Comments at 4 (stating that 64 percent of wireless calls
to 911 are made from inside buildings).
26

Third Further Notice, 29 FCC Rcd at 2387 ¶ 31.

APCO Comments at 2; see also IACP Comments at 1; FindMe911 Survey at 4-5 (stating that 82 percent of 911
professionals said that “they do not have a great deal of confidence in location information provided by carriers, and
54 [percent] said that the latitude and longitude data provided by carriers is ‘regularly’ inaccurate.”).
28

DEMSF Comments at 2; see also NENA Comments at 13 (stating that “[t]his trend must be reversed to ensure
that 9-1-1 centers can locate callers in need, regardless of the location from which their call originates”).
29

See APCO Comments at 2 (“location information is especially important for indoor calls to [911], as the
emergency . . . may not be visible to first responders arriving at the approximate address.”); IACP Comments at 2
(continued….)

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FCC 15-9

18.
Discussion. The record confirms that more wireless 911 calls are coming from indoors,
and indoor 911 calls pose challenges for location that will lead to further degradation of 911 services if
not addressed. In 1996 there were approximately 33 million cellular subscribers in the United States.30
By the end of 2013, there were nearly 336 million wireless subscriber connections.31 At the end of 2007,
only 15.8 percent of American households were wireless-only.32 During the first half of 2014, that
number increased to 44 percent (more than two of every five American homes), an increase of more than
3.0 percentage points since the second half of 2013.33 Furthermore, adults living in or near poverty and
younger Americans are more likely to live in wireless-only homes than are higher-income adults.34
Several major CMRS providers reflect this trend by marketing wireless service as a replacement in the
home for traditional landline service.35
19.
The record also indicates that the increase in wireless calls to 911 from indoors has
reduced the quality of location information available to first responders in the absence of compensatory
technologies to enhance location. Specifically, satellite-based location technologies do not provide
(Continued from previous page)
(stating that improved indoor location accuracy will help incident command to know the location of their firefighters
and policemen in burning buildings or where criminal incidents are occurring).
30

See Revision of the Commission’s Rules to Ensure Compatibility with Enhanced 911 Emergency Calling
Systems, CC Docket No. 94-102, Report and Order and Further Notice of Proposed Rulemaking, 11 FCC Rcd
18676, 18680, ¶ 6 (1996) (First E911 Report and Order).
31

See CTIA, Annual Wireless Survey, available at http://www.ctia.org/your-wireless-life/how-wirelessworks/annual-wireless-industry-survey (last visited Jan. 13, 2015). The Commission’s sixteenth annual report on
the state of competition in the mobile services marketplace, released in March 2013, estimated that the “total number
of mobile wireless connections now exceeds the total U.S. population.” See Implementation of Section 6002(b) of
the Omnibus Budget Reconciliation Act of 1993; Annual Report and Analysis of Competitive Market Conditions
With Respect to Mobile Wireless, Including Commercial Mobile Services, WT Docket No. 11-186, Sixteenth
Report, 28 FCC Rcd 3700, 3854 ¶ 244 (2013). The Commission based this estimate on year-end 2010 and year-end
2011 Numbering Resource Utilization Forecast (NRUF) filings, adjusted for porting, and CTIA’s Year-End 2011
Wireless Indices Report. Id. at 3854-55 ¶ 244. “Mobile Wireless Connections” refers to the number of connected
devices rather than the number of individual subscribers. Id. at 3708 ¶ 2.
32

See CTIA, Wireless Quick Facts, available at http://www.ctia.org/your-wireless-life/how-wirelessworks/wireless-quick-facts (last visited Jan. 13, 2015) (CTIA Wireless Quick Facts).
33

See Blumberg, Stephen & Luke, Julian, Center for Disease Control National Center for Health Statistics,
“Wireless Substitution: Early Release of Estimates from the National Health Interview Survey, January- June 2014,”
at 2, available at http://www.cdc.gov/nchs/data/nhis/earlyrelease/wireless201412.pdf (last visited Dec. 30, 2014)
(CDC Wireless Substitution Survey).
34

CDC Wireless Substitution Survey at 2 (reporting that by the second half of 2014, 59.1 percent of adults living in
poverty live in wireless-only homes, and 50.8 percent of adults living near poverty live in wireless-only homes, as
compared to 40.8 percent of higher income adults. Also, more than two-thirds of adults aged 25-29 (69.3 percent)
lived in wireless-only households. For adults aged 18–24 the rate was 57.8 percent and for adults aged 30–34, the
rate was 64.9 percent).
35

See, e.g., Verizon Wireless, Verizon Wireless Home Phone Connect (“Home Phone Connect offers… a reliable,
portable, low-cost alternative to traditional home phone service using the Verizon Wireless Network all while
keeping your same number and home phone.”), available at http://www.verizonwireless.com/b2c/device/homephone-connect (last visited Dec. 1, 2014); AT&T, AT&T Wireless Home Phone (“Now you can connect the home
telephone you already have to the AT&T wireless network.”), available at
http://www.att.com/shop/wireless/devices/att/wireless-home-phone-silver.html#fbid=BT-M86RbotW (last visited
Dec. 1, 2014); Sprint Nextel, Sprint Phone Connect, (“Replace your current landline or digital phone service with
unlimited Sprint phone service at your home or office.”) available at
http://shop.sprint.com/mysprint/shop/plan_details.jsp?tabId=plnTab4410001&planCatId=pln590002cat&planFamily
Type=&flow=AAL (last visited Dec. 1, 2014).

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accurate location data for many wireless calls placed from indoor locations,36 particularly in urban areas
where a growing number of Americans reside.37 This highlights the critical importance of the enhanced
indoor wireless indoor location accuracy rules that we adopt today, which will enhance public safety and
address the need to develop alternative technological approaches to address indoor location.
B.

E911 Location Accuracy Requirements

20.
In this Fourth Report and Order, we adopt E911 location accuracy requirements that
codify major elements of the Roadmap, the Parallel Path, and the additional commitments that CMRS
providers have made in recent ex parte filings. These requirements afford CMRS providers flexibility to
develop dispatchable location solutions, but also include requirements and timeframes for provision of x/y
and z-axis information in the event that dispatchable location is not available.
21.
CMRS providers must certify at 36 months and again at 72 months that they have
deployed compliant technology throughout their networks to improve indoor location accuracy, consistent
with the compliant technology’s performance in an independent test bed.38 To demonstrate further
compliance with these metrics, CMRS providers must submit aggregated live 911 call data from the six
cities recommended for indoor testing by the Alliance for Telecommunications Industry Solutions
Emergency Services Interconnection Forum (ATIS ESIF).39 CMRS providers that provide dispatchable
location must also provide x/y coordinates to the PSAP (as well as z coordinates where feasible and
appropriate). This will enable PSAPs to corroborate the validity of dispatchable location information, but
the coordinates will not be considered for FCC compliance purposes.
1.

Incorporation of Roadmap and Parallel Path Commitments

22.
Background. In the Third Further Notice, we proposed that within two years of the
Effective Date CMRS providers must locate 67 percent of indoor 911 calls within 50 meters, and that
within five years, they must achieve 50-meter accuracy for 80 percent of indoor 911 calls. We further
proposed that within three years of the Effective Date, CMRS providers must deliver vertical (z-axis) data
within 3 meters accuracy for 67 percent of indoor calls, and 3-meter accuracy for 80 percent of calls

Farid, Z., Nordin, R., and Ismail, M., “Recent Advances in Wireless Indoor Localization Techniques and System,”
JOURNAL OF COMPUTER NETWORKS AND COMMUNICATIONS (Vol. 2013) at Section 1.1, available at
http://www.hindawi.com/journals/jcnc/2013/185138/#B4 (last visited Jan. 8, 2015) (“GPS works extremely well in
outdoor positioning. Unfortunately, GPS does not perform well in urban canyons, close to walls, buildings, trees,
indoors, and in underground environments as the signal from the GPS satellites is too weak to come across most
buildings thus making GPS ineffective for indoor localization.”) (footnote omitted). See also Schneider, David,
“New Indoor Navigation Technologies Work Where GPS Can’t,” IEEE SPECTRUM (Nov. 20, 2013), available at
http://spectrum.ieee.org/telecom/wireless/new-indoor-navigation-technologies-work-where-gps-cant (last visited
Jan. 8, 2015).
37

See Frequently Asked Questions, UNITED STATES CENSUS BUREAU (2010),
https://ask.census.gov/faq.php?id=5000&faqId=5971 (last visited Jan. 21, 2015) (reporting that 81 percent of the
American population lives in urban areas); see also Westcott, Lucy, “More Americans Moving to Cities, Reversing
Suburban Exodus,” THEWIRE.COM (Mar. 27, 2014), available at http://www.thewire.com/national/2014/03/moreamericans-moving-to-cities-reversing-the-suburban-exodus/359714/ (last visited Jan. 21, 2015) (reporting that “[t]he
shift in population to America’s metro areas has been increasing since 2010, when the economic recovery began
picking up”).
38

See infra Section III.B.5.a (describing compliance testing).

ATIS Reply Comments at 4 n. 6. See also Letter from Thomas Goode, General Counsel, Alliance for
Telecommunications Industry Solutions, to David DeLorenzo, Chairman, CSRIC IV Working Group 1, Task Group
3 (dated Feb. 7, 2014), at 3-4, available at
http://www.atis.org/legal/Docs/ESIF%20DOCS/ESIF_Letter_DeLorenzo_Feb2014.pdf (last visited Jan, 8, 2015).

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within five years.40 We proposed establishment of an indoor location accuracy test bed for demonstrating
compliance with these requirements, and asked about other approaches to validating compliance.41
23.
We also invited comment on alternative approaches that would best weigh the costs and
benefits of implementing an indoor location requirement with technical feasibility, timing, and other
implementation concerns.42 In particular, we invited industry and public safety stakeholders to propose
consensus-based, voluntary commitments that would address the public safety goals set forth in this
proceeding and facilitate closing the regulatory gap between indoor and outdoor location accuracy
without the need to adopt regulatory requirements.43
24.
Subsequent to the close of the comment period, NENA, APCO, and the four national CMRS
providers submitted the Roadmap agreement.44 The Roadmap provides that, within one year, the signatory
CMRS providers will establish a test bed for 911 location technologies and, within three years, they will
establish a national location database for provision of dispatchable location information from in-building
beacons and hotspots (e.g., Wi-Fi and Bluetooth).45 The Roadmap also specifies that, beginning at Year 2
of Roadmap implementation and extending through Year 8, the CMRS providers will introduce VoLTEcapable handsets that (1) support satellite-based location using multiple positioning systems (e.g.,
GLONASS in addition to GPS), (2) can deliver Wi-Fi and Bluetooth beacon information, and (3) can
deliver z-axis information.46
25.
As originally proposed, the Roadmap contained the following horizontal location
accuracy performance benchmarks:


Within two years of the Roadmap’s execution, CMRS providers will use “heightened location
accuracy technologies” to locate 40 percent of all 911 calls (indoor and outdoor). “Heightened
location accuracy technologies” consist of: (1) satellite-based (A-GNSS) location, (2)
dispatchable location, or (3) “any other technology or hybrid of technologies capable of
location accuracy performance of 50 m[enters].”



Within three years, CMRS providers will use the above “heightened location accuracy
technologies” to provide location for 50 percent of all 911 calls (indoor and outdoor).



Within five years, CMRS providers will use the above “heightened location accuracy
technologies” to provide location for 75 percent of all VoLTE 911 calls (indoor and outdoor).



Within six years, CMRS providers will use the above “heightened location accuracy
technologies” to provide location for 80 percent of all VoLTE 911 calls (indoor and outdoor).47

26.
In recent ex parte filings, the nationwide CMRS providers have modified the five-year
and six-year Roadmap benchmarks so that they will apply to all wireless 911 calls, not just VoLTE calls.
To adjust for the inclusion of non-VoLTE calls, the nationwide CMRS providers propose to lower the
40

Third Further Notice, 29 FCC Rcd at 2391 ¶ 38.

Id.

Third Further Notice, 29 FCC Rcd at 2396 ¶ 54.

Id.

Roadmap Cover Letter at 1.

Roadmap at Section 2(e).

Roadmap at Sections 2(f), 3(c), and 6(b)(ii)(2)(a). VoLTE provides voice service delivered over the LTE network
rather than voice delivered over legacy networks. See http://en.wikipedia.org/wiki/VoLTE (last visited Dec. 30,
2014).
47

Roadmap at Section 4(c).

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five-year benchmark from 75 percent to 60 percent. No adjustment is proposed to the six-year deadline or
the 80 percent benchmark for all calls, however.48
27.
The Roadmap commits CMRS providers to use live 911 call data to demonstrate
compliance with these metrics.49 The data will be collected monthly in the six cities that ATIS ESIF has
recommended for indoor location technology testing (San Francisco, Chicago, Atlanta, Denver/Front
Range, Philadelphia, and Manhattan).50 Providers will provide reports to APCO and NENA on a
quarterly basis, subject to appropriate confidentiality protections, with the first report due 18 months after
the Effective Date. All CMRS providers, along with APCO and NENA, will use the data from these
reports to assess the trend in positioning performance over time.51
28.
Rather than propose a specific z-axis metric, the Roadmap focuses on dispatchable
location solutions to identify floor level. After 36 months, the parties will determine if these efforts are
“on track,” and only if they are “off track” are the CMRS providers obligated to pursue development of a
standards-based z-axis solution (e.g., use of barometric sensors in handsets).52 In recent ex parte filings,
however, the nationwide CMRS providers have committed to begin delivering uncompensated barometric
data from barometer-equipped handsets within three years, and have offered additional commitments with
respect to deployment of both dispatchable location and z-axis solutions.53
29.
The Parallel Path incorporates the same two- and three-year horizontal accuracy
benchmarks as the Roadmap, and proposes slightly different five- and six-year benchmarks. Under the
Parallel Path, non-nationwide CMRS providers would use heightened accuracy technologies in 70 percent
of all wireless 911 calls (VoLTE and non-VoLTE) within five years or within six months of having a
commercially operating VoLTE platform in their network, whichever is later. Similarly, non-nationwide
CMRS providers would achieve heightened accuracy for 80 percent of all wireless 911 calls within six
years or within one year of having a commercially operating VoLTE platform in their network, whichever
is later.
30.
Regarding data reporting, the Parallel Path commits non-nationwide CMRS providers to
collect data for live wireless 911 calls that would show the percentage of time that each “positioning source
method” (e.g., dispatchable location, A-GPS, A-GNSS, OTDOA, AFLT, RTT, Cell ID, which are discussed
in greater detail in Section III.B.3.b(i) below) is used to deliver a wireless 911 call. Small CMRS providers
that operate in one of the six ATIS ESIF regions will collect and report data for that region.54
48

The nationwide CMRS providers initially proposed to extend the 80 percent deadline from six to seven years, but
subsequently agreed to retain the six-year deadline. See Ex Parte Letter from APCO, AT&T, NENA, T-Mobile,
Sprint, and Verizon (filed Jan. 23, 2015).
49

Roadmap at Section 4(a).

Id. at Section 4(a)(ii). See also ATIS Reply Comments at 4 n. 6 (listing the six cities).

Roadmap at Section 4(b).

Id. at Section 6.

See Addendum at Section 6. These additional commitments are discussed in greater detail in Section III.B.4.a,
infra.
54

If a non-nationwide carrier operates in more than one of the six geographic areas that correspond to the six geographic
test regions recommended by ATIS ESIF, data will be collected in and reported for one half of the total number of regions
where the non-nationwide carrier operates, with the reporting areas selected by each such carrier. Once the region or
regions are selected, however, the carrier must consistently report data from the selected region(s) for the remainder of
the benchmarks. See Parallel Path at Section 5(a). For small CMRS providers not operating in any of the six regions, data
will be collected in and reported for the largest county by population within the carrier’s footprint. To the extent the
carrier’s footprint encompasses more than one of the four morphologies found in the ATIS ESIF test regions (dense urban,
urban, suburban, and rural), the carrier will collect data from a sufficient number of counties so as to provide data covering
each of the morphologies found in the carrier’s footprint. Id.

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31.
For z-axis location information, the Parallel Path provides that for small CMRS providers
whose service footprints include any county or county equivalent with a population density of 20.0 people
per square mile or more (per most recent U.S. Census data), those providers agree to deliver
uncompensated barometric pressure data to PSAPs from any voice-capable handset that supports such a
capability within four (4) years of that agreement, while such providers whose serve designated areas with
population densities of 19.9 or less will be exempt from providing any uncompensated barometric pressure
data to PSAPs.55
32.
Some vendors praise the Roadmap as a meaningful step toward improved indoor
location.56 For example, TCS states that the proposals in the Roadmap are more realistic than the
proposals in the Third Further Notice because it acknowledges CMRS providers’ inability to distinguish
between indoor and outdoor wireless calls.57
33.
However, some public safety entities, consumer advocacy groups, and other vendors
express strong concern about the Roadmap proposals. Multiple commenters argue that the Roadmap
dilutes the Commission’s efforts to adopt indoor location accuracy rules and does not present a viable
alternative to the proposals in the Third Further Notice.58 Though it regards the Roadmap as a step in the
right direction, TDI submits that the Roadmap should serve only as a complement, not a replacement, to
the Commission’s rules.59 The Associated Firefighters of Illinois believe that the Roadmap pushes out the
timeline for improved location accuracy too far.60 IACP and Fairfax County support the concept of
dispatchable location, but question the feasibility of the Roadmap’s dispatchable location provisions.61
Multiple commenters express concern at the Roadmap’s blended metric for indoor and outdoor calls.62
TruePosition cautions that the use of GLONASS for 911 may raise political and security issues,63 though
APCO, CTIA and TCS dispute that use of GLONASS poses a security threat.64 Numerous parties
highlight concerns with the Roadmap’s proposal for the National Emergency Address Database
(NEAD).65 Some Roadmap Parties submit rebuttals to these concerns raised in the record.66
55

See Parallel Path at Sections 4(a) and (b).

See, e.g., Qualcomm Roadmap Comments at 3.

TCS Roadmap Reply Comments at 2.

BRETSA Roadmap Comments at 27; Enid OK Fire Department Roadmap Comments at 1; IMSA Roadmap
Comments at 1, 7; San Louis Obispo County, CA, District Attorney Roadmap Comments at 1; Hampstead NH
Roadmap Comments at 1; TruePosition Roadmap Comments at iv and Roadmap Reply Comments at 3; NARUC
Roadmap Comments at 5; Plaistow, NW Fire Department Roadmap Comments at 1; Polaris Wireless Roadmap
Comments at 2, Woburn MA Police Department Roadmap Comments at 1.
59

TDI Roadmap Reply Comments at 2-3.

Associated Firefighters of Illinois Roadmap Comments at 2.

IACP et al Roadmap Reply Comments at 2; Fairfax Roadmap Comments at 1 and Reply Comments at 1-2.

TruePosition Roadmap Comments at 18 and Reply Comments at 14-15; NextNav Roadmap Comments at 17-18.

See, e.g., TruePosition Roadmap Comments at 27-31.

APCO Roadmap Reply Comments at 7; CTIA Roadmap Reply Comments at 27; TCS Roadmap Reply Comments
at 9.
65

See, e.g., Public Knowledge Roadmap Comments throughout. See also IMSA Roadmap Comments at 5; iPosi
Roadmap Comments at 4; Fairfax Roadmap Comments at 1 and Reply Comments at 2; TruePosition Roadmap
Comments at 9-10 and Reply Comments at 13; CSR Roadmap Comments at 3; IACP et al Roadmap Comments at
2; IMSA Roadmap Comments at 5; iCERT Roadmap Comments at 2; NextNav Roadmap Comments at ii, 9, 14;
Polaris Wireless Roadmap Comments at 4.
66

See, e.g., CTIA Roadmap Reply Comments at 24 (saying that a blended metric is not problematic because indoor
calls will make up too large a portion of all calls to allow carriers to “mask inferior indoor location accuracy
(continued….)

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34.
Discussion. As discussed in detail below, the Roadmap and Parallel Path contain
numerous positive elements that will help drive improvements in indoor location. In particular, they lay
the foundation for development of a location technology test bed, a national location database, and
introduction of improved location technology into VoLTE handsets and networks. The Roadmap and
Parallel Path also for the first time commit CMRS providers to using live 911 call data, not just test data,
to measure progress and compliance with location accuracy metrics. They also commit CMRS providers
to a timetable for achieving improved horizontal and vertical location accuracy in the absence of a
dispatchable location solution.
35.
Critics of the Roadmap and the Parallel Path have raised legitimate concerns regarding
the sufficiency of the commitments made by CMRS providers therein. However, we believe that the
recent amendments to both the Roadmap and the Parallel Path have substantially strengthened these
commitments and provide the basis for ensuring measurable improvements in indoor location while
holding CMRS providers accountable for results. Of particular significance, the horizontal accuracy
benchmarks in both the Amended Roadmap and the Parallel Path now apply uniformly to all wireless 911
calls rather than some benchmarks applying to VoLTE calls only. Similarly, the nationwide CMRS
providers’ commitment to begin delivering uncompensated barometric data within three years will
provide an important near-term opportunity for PSAPs that have the strongest interest in obtaining
vertical location information, while development of enhanced vertical location technologies proceeds in
parallel. Finally, the new provisions in the Amended Roadmap for development of a z-axis standard and
the inclusion of timeframes for deployment of dispatchable location and z-axis technology will drive
investment in solutions to the challenge of identifying the floor level – or preferably, the dispatchable
location – of 911 calls originated from multi-story buildings.
36.
We applaud the process that resulted in these commitments and the benefits that will flow
to the American people as a result. To ensure that all parties make progress as promised, and to ensure
that all stakeholders and the Commission have adequate assurances that parties are held accountable, we
are codifying these commitments through the rules we adopt today. We are also including reporting,
recordkeeping, and retention obligations associated both with the technology test bed and live 911 call
information that will illuminate the implementation of the dispatchable location standard, and the real
world performance of the horizontal and vertical location technologies that have been put forward in the
record.
37.
In this respect, to ensure transparency and accountability, we require that nationwide
CMRS providers report to the Commission on their plans and progress towards implementing improved
indoor location accuracy no later than 18 months from the Effective Date, and that non-nationwide CMRS
providers submit their plans no later than 24 months from the Effective Date. These reports should
include details as to each provider’s implementation plan to meet our requirements. For the nationwide
CMRS providers, this report must also include detail as to steps taken and future plans to implement the
NEAD, which is discussed in further detail below.67 These reports will provide a baseline for measuring
the subsequent progress made by each provider toward improving indoor location accuracy. In addition
we require each CMRS provider to file a progress report at 36 months indicating what progress the
provider has made consistent with its implementation plan. Nationwide CMRS providers shall include in
their 36-month reports an assessment of their deployment of dispatchable location solutions. For any
CMRS provider participating in the development of the NEAD database, this progress report must also
include detail as to implementation of the database. Furthermore, we encourage CMRS providers to share
these reports and discuss their implementation plans with public safety, consumer, and disability groups.
We incorporate these requirements into our rules.
(Continued from previous page)
performance”); Sprint Roadmap Reply Comments at 15 and Verizon Roadmap Reply Comments at 12 (asserting
that privacy issues will be worked out among the Roadmap Parties’ working groups).
67

See supra paras. 68-69.

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38.
In the Roadmap, the CMRS providers state that within six to twelve months they intend
to test “improved” A-GNSS technologies that can augment GPS-only geolocation by obtaining
positioning information from other international satellite positioning systems, including the Russian
GLONASS system.68 TruePosition contends that the potential use of GLONASS to support E911
location “raises a wide range of national security, reliability, liability, and economic trade issues,” and
should be rejected by the Commission.69 CTIA, however, explains that “the Roadmap never states that
GLONASS will be the exclusive source of user location data, and instead makes clear that both GPS and
GLONASS will be tested as positioning sources… this bogeyman is nothing more than a desperate
attempt to distract the stakeholders and the Commission and undermine the actual merits of the
Roadmap.”70 CTIA asserts that “the use of GLONASS chips in handsets does not give Russia power over
U.S. wireless communications,” and that “[t]here simply is no national security risk whatsoever with the
Roadmap.”71
39.
To date, none of the CMRS provider parties to the Roadmap have submitted, nor has the
Commission approved, any waiver petition or application that would seek authorized use of any non-U.S.
Radionavigation Satellite Service (RNSS)72 system to support E911 location or general location-based
services. Indeed, the Roadmap only states that the signatory CMRS providers intend to test the potential
use of non-U.S. systems (such as GLONASS or Galileo) to support E911 location. It does not call for the
Commission to approve operations with any non-U.S. satellite systems, either explicitly or implicitly, in
this proceeding, and we decline to do so. Thus, the parties to the Roadmap and other CMRS providers
must comply with the location accuracy requirements established by this order regardless of the
disposition of any future request they may make under FCC rules to operate with any non-U.S. satellite
systems in support of E911 location.73 Moreover, any such request will be subject to a full review and
federal inter-agency coordination of all relevant issues, including technical, economic, national security,
and foreign policy implications.
40.
We do not decide the issue of operating with non-U.S. satellite signals in this proceeding,
which would require consideration of a variety of issues, including its potential impact on the use of
adjacent bands. Therefore, nothing in today’s decision authorizes the use of any non-U.S. satellite system
in conjunction with the 911 system, including the 911 location accuracy rules we adopt today. Moreover,
68

Roadmap at Section 1(a).

TruePosition Roadmap Comments at 27-31.

CTIA Roadmap Reply Comments at 26-27, noting that the Commission “has repeatedly stressed that receive-only
operations cannot cause interference.” See Amendment of the Commission’s Space Station Licensing Rules and
Policies, Second Report and Order, IB Docket Nos. 02-34 and 00-248, and Declaratory Order, IB Docket No. 96,
111, 18 FCC Rcd 12507 at ¶ 21 (2003).
71

CTIA Roadmap Reply Comments at 27.

RNSS is a radiodetermination-satellite service used for the purpose of radionavigation. A radiodeterminationsatellite service is a radio communication service for the purpose of radiodetermination (position determination via
the propagation properties of radio waves) involving the use of one or more space stations. Among others, the 15591610 MHz (L1) frequency band is allocated to the RNSS (space-to-Earth) on a primary basis worldwide. See 47
C.F.R. §§ 2.1, 2.106.
73

We note that manufacturers are already mass producing chipsets that are capable of receiving simultaneous signals
from multiple RNSS systems, including GPS, GLONASS, the Chinese COMPASS, and European Galileo systems,
and the global availability of such capabilities is anticipated and likely to become standard in most future handsets.
See Frank Van Diggelen, Charlie Abraham, Javier de Salas, Randy Silva, “GNSS Inside Mobile Phones,” INSIDE
GNSS (Mar. & Apr. 2011), available at http://www.insidegnss.com/node/2507 (last visited Jan. 2, 2015). Some
receiver equipment in use today includes un-activated GLONASS chipsets. The capability to operate with foreign
satellite signals presents regulatory concerns of unauthorized use if that capability can be activated either
intentionally or unintentionally by end users prior to FCC authorization. We encourage CMRS providers seeking to
employ foreign satellite navigation systems to begin the approval process as soon as possible.

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A-GNSS technologies used to augment GPS may increase the potential exposure of devices to
interference by increasing the number of unwanted signals and the number of signals that can introduce
data integrity problems. We believe that CMRS providers seeking to use non-U.S. satellites should also
conduct testing to ensure that operation with these signals does not inadvertently introduce vulnerabilities
to the devices that could impair E911 performance or compromise data integrity. For example, devices
that are augmented to receive signals from multiple satellite constellations may be more susceptible to
radio frequency interference than devices that receive signals from GPS alone.74 Devices should also be
evaluated to determine their capabilities to detect and mitigate the effects of inaccurate or corrupted data
from any RNSS system that could result in incorrect location information, or no information at all, being
relayed to a PSAP.75 We expect CMRS providers, at the time they certify their compliance with the
Commission’s location accuracy requirements, to also certify that any devices on their network operating
with foreign A-GNSS signals for 911 location accuracy have proper authorizations in place to permit such
use. Before incorporating foreign A-GNSS into E911, CMRS providers must coordinate plans for foreign
A-GNSS signal integration with the Public Safety and Homeland Security Bureau to confirm that signals
are interoperable with GPS and that measures to prevent interference are appropriate. Furthermore,
CMRS providers are expected to certify that the devices have been tested to determine their ability to
detect and mitigate the effects of harmful interference.
2.

Dispatchable Location

41.
In the Third Further Notice, we identified the delivery by CMRS providers to PSAPs of
“dispatchable address” information as a long-term objective to improve indoor location. While we
proposed indoor accuracy requirements based on x/y/z coordinate information, we noted that public safety
needs would be better served if PSAPs could receive the caller’s building address, floor level, and
suite/room number. Therefore, we sought comment on whether to adopt an alternative indoor location
requirement that CMRS providers could satisfy by delivering a caller’s building address and floor level.76
42.
Although we viewed development of dispatchable location capability as a long-term goal
in the Third Further Notice, the subsequent comment record and the Roadmap indicate the proliferation
of in-building technology such as small cells and Wi-Fi and Bluetooth beacons, which can be used
together, has made dispatchable location solutions technically feasible in a much shorter timeframe than
we initially anticipated. Therefore, as described below, we conclude that CMRS providers should be
allowed to use dispatchable location to comply with our indoor location accuracy requirements.
a.

Definition of Dispatchable Location

43.
The Roadmap uses the term “dispatchable location” rather than “dispatchable address” to
describe the same objective identified in the Third Further Notice. The Roadmap defines “dispatchable
location” as “the civic address of the calling party plus additional information such as floor, suite,

GLONASS signals, for example, are located in the upper portion of the 1559-1610 MHz RNSS allocation while
the GPS signals are located in the lower portion of the RNSS allocation. Since GPS and GLONASS use different
spectrum segments, a device that is designed to receive signals from both GPS and GLONASS will be open to
receiving unwanted signals from transmitters that operate above 1610 MHz that could interfere with A-GNSS
functions.
75

On April 1, 2014, all GLONASS satellites started to transmit wrong Broadcast Messages (BM) resulting in a total
disruption of the globally operational GNSS constellation. All satellites in the constellation broadcasted corrupt
information for 11 hours rendering the system unusable to GLONASS receivers.
76

Third Further Notice, 29 FCC Rcd at 2395 ¶ 50.

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apartment or similar information that may be needed to adequately identify the location of the calling
party.”77
44.
For the purposes of this rulemaking, we define “dispatchable location” as the verified or
corroborated street address of the calling party plus additional information such as floor, suite, apartment
or similar information that may be needed to adequately identify the location of the calling party. We
note that while all dispatchable addresses are necessarily civic addresses, not all civic addresses are
“dispatchable,” e.g., P.O. Boxes, diplomatic or armed forces pouch addresses, etc.78 PSAPs currently use
street address in dispatch systems, the very essence of any “dispatchable” location solution. Public safety
organizations have described dispatchable location as the “gold standard” in terms of location accuracy
and utility for allocating emergency resources in the field.79 Accordingly, we adopt a definition similar to
the one offered in the Roadmap, but substitute the term “street address” to provide clarity and ensure that
dispatchers are not sent to addresses which may not be street addresses, and therefore, may not be
“dispatchable.” Although IMSA contends that the Roadmap’s definition of dispatchable location lacks
specificity,80 we find that this definition strikes the appropriate balance between specificity and flexibility.
b.

Technological Feasibility and Implementation Issues

45.
In the Third Further Notice, we recognized that provision of a dispatchable location
would most likely be through the use of in-building location systems and network access devices, which
could be programmed to provide granular information on the 911 caller’s location, including building
address and floor level.81 We noted that CMRS providers are already deploying in-building technologies
to improve and expand their network coverage and speed, and asked how these technologies could be
leveraged to support indoor 911 location, as well as any challenges to implementation.82 For the reasons
stated below, we believe the Roadmap commitments, including those made in the Addendum, and the
comments in the record demonstrate that a dispatchable location solution is feasible and achievable on the
timetable we establish, and that in light of our predictive judgment about the future course of
development of various wireless location technologies, this approach provides appropriate incentives for
77

Roadmap at Section 2(a). The parties also state that “the civic address of the calling party number will be
validated. In addition, the civic address will be corroborated against other location information prior to delivery of
the address with the 9-1-1 call to the PSAP to the extent possible.” See id.
78

See NENA, NENA NG911 United States Civic Location Data Exchange Format (CLDXF) Standard (Mar. 23,
2014) at Introductory Note to Section 3.2, available at
https://c.ymcdn.com/sites/www.nena.org/resource/resmgr/Standards/NENA-STA-004.1-2014_CLDXF.pdf (last
visited Dec. 30, 2014) (describing legislative, postal, and unofficial place names and how they impact addressing).
See also Addressing Guidelines, Canada Post, available at http://www.canadapost.ca/tools/pg/manual/PGaddresse.asp?ecid=murl10006450#1417752 (last visited Dec. 30, 2014) (distinguishing civic address from other types of
postal addresses).
79

See, e.g., Letter from Derek Poarch, Executive Director, APCO to Marlene Dortch Secretary, Federal
Communications Commission (dated January 22, 2015) at 1.
80

IMSA Roadmap Comments at 3-4 (expressing concern that the Roadmap does not state specifically how it will
help identify and direct responders to dispatchable locations, and that “[t]hese concerns, if left unaddressed, prevent
the Roadmap from being a reasonable alternative to the performance-based metrics proposed by the Commission.”).
81

Third Further Notice, 29 FCC Rcd at 2395 ¶ 50.

Id. See also, e.g., PR NEWSWIRE, “Verizon Wireless Activates DAS System In Empire State Plaza,” Sept. 16,
2013, available at http://www.prnewswire.com/news-releases/verizon-wireless-activates-das-system-in-empirestate-plaza-223946991.html (last visited Oct. 29, 2014); DeGrasse, Martha, “Small cells: Carriers focus on handoffs
to legacy networks,” RCR WIRELESS, Nov. 21, 2013, available at
http://www.rcrwireless.com/article/20131121/heterogeneous-networks-2/small-cells-carriers-focus-on-handoff-tolegacy-networks/ (last visited Jan. 21, 2015); AT&T, “Small Cells, Big Steps,” available at
http://www.att.com/Common/about_us/pdf/small_cell.pdf (last visited Jan. 21, 2015) (“by 2015, AT&T plans to
deploy 40,000 small cells in the network”).

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CMRS providers to achieve our foregoing goals as effectively and promptly as practicable. In the
absence of an approved z-axis metric alternative, CMRS providers will be obligated to rely on
dispatchable location.
(i)

In-Building Infrastructure

46.
Commenters confirm that the feasibility of dispatchable location is linked to the
proliferation of indoor, infrastructure-based technologies, including small cell technology, 83 distributed
antenna systems (DAS),84 Wi-Fi access points,85 beacons, 86 commercial location-based services (cLBS),87
institutional and enterprise location systems,88 and smart building technology.89 These technologies can
83

Rx Networks at 5; Qualcomm Comments at 5; iPosi Comments at 6; CTIA Comments at 22; TCS Comments at
19-20; 4G Americas Reply Comments at 2; AT&T Comments at 24; Rx Networks Comments at 5. But see
TruePosition Reply Comments at 44 (arguing that small cells are not well-suited for dispatchable location, because
handsets today are not equipped to communicate with small cells in the control plane layer, something it describes as
“the very essence of E911.”).
84

A DAS is “[a] network of spatially separated antenna nodes connected to a common source via transport medium
that provides wireless service within a geographic area or structure.” DAS Forum, “Distributed Antenna Systems
(DAS) and Small Cell Technologies Distinguished,” available at http://www.thedasforum.org/wpcontent/uploads/2014/07/DAS-and-Small-Cell-Technologies-Distinguished_HNForum.pdf (last visited Jan. 21,
2015). Most commenters argue that DAS is not well suited for E911 purposes. See Rx Networks Comments at 6;
Transit Wireless Comments at 3; TCS Comments at 20. But see Polaris Wireless Comments at 3; Rx Networks
Comments at 6; Sprint Reply Comments at 8.
85

Cisco already utilizes Wi-Fi access points to provide indoor location data, and is in discussions with competitors
Aruba and Ruckus on how all three vendors – which comprise nearly 80 percent of the Wi-Fi market – can work
together to provide a robust indoor location solution using Wi-Fi access points. See Cisco/TCS Sept. 12, 2014 ex
parte at 17.
86

See e.g., AT&T Comments at 3-4. Beacons are Bluetooth hardware devices that can be detected by and wirelessly
exchange data with other Bluetooth-enabled devices, all of which are part of a Bluetooth network “stack.” See
Android, “Bluetooth,” available at http://developer.android.com/guide/topics/connectivity/bluetooth.html (last
visited Jan. 21, 2015).
87

Commercial location-based services (cLBS) are applications that providers load, or consumers download, onto
their phones to provide location services. Third Further Notice, 29 FCC Rcd at 2320-21 ¶ 127. cLBS are currently
implemented in all major commercial mobile operating systems with multiple independent Wi-Fi access location
databases, maintained by Google, Apple, and Skyhook, among others. See, e.g., Google, “Configure access points
with Google Location Service,” available at https://support.google.com/maps/answer/1725632?hl=en (last visited
Jan. 21, 2015); Cox, John, “Apple Leverages Wi-Fi location with latest acquisition,” NETWORK WORLD, Mar. 25,
2013, available at http://www.networkworld.com/news/2013/032513-apple-wifislam-268054.html (last visited Jan.
21, 2015); Skyhook, Coverage Area, available at http://www.skyhookwireless.com/locationtechnology/coverage.php (last visited Jan. 21, 2015).
88

Cisco submits that it would not be difficult to leverage its existing location systems for E911 indoor location
accuracy use, and that doing so would not raise the kind of security concerns associated with using crowdsourced
Wi-Fi data. See Cisco/TCS Sept. 12, 2014 ex parte at 11 (“Enterprises deploying [local area] networks do so for
their own benefit” and “Enterprises manage and maintain their location infrastructure as it’s $$ to them.”) and 15
(ranking information from enterprise-based networks as more trustworthy than crowdsourced location information);
Cisco Comments at 15 (“Although these consumer systems historically were viewed as untrustworthy, they can
allow PSAPs unprecedented location accuracy when coupled with currently deployed CMRS E911 location
technologies and trustworthy location information from Enterprise Wi-Fi.”).
89

“Smart buildings” integrate hardware like Wi-Fi antennas, beacons, motion and light sensors, and corresponding
wiring into a building’s infrastructure, and shares information from each source to optimize building system
function with respect to, inter alia, heating and ventilation, power consumption, equipment maintenance, and
security. See Institute for Building Efficiency, “What is a Smart Building?”, available at
http://www.institutebe.com/smart-grid-smart-building/What-is-a-Smart-Building.aspx (last visited Jan. 21, 2015).

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be used in a location system information “stack” that would allow a CMRS provider’s location server to
compile and compare location fixes from multiple sources, to identify and disregard inaccurate fixes, and
otherwise synthesize available location data.90
47.
The record also confirms that many of these technologies can contribute to the
development of dispatchable location solutions in the near term.91 Nearly all wireless phones are now
equipped with Bluetooth and Wi-Fi capabilities, though some standardization work remains.92 Small cells
are increasingly deployed in urban areas, and all four nationwide CMRS providers currently sell or plan
to sell in-home consumer products designed to provide improved wireless coverage indoors,93 but which
could also be leveraged to provide dispatchable location information. Indeed, the Roadmap commits to
making all CMRS provider-provided small cell equipment compatible with any dispatchable location
solution.94 Additionally, Bluetooth beacons and Wi-Fi hotspots are increasingly deployed in public
spaces. For example, TCS estimates that there are more than 126 million Wi-Fi access points nationwide,
with approximately 40 million in commercial settings and 86 million in residential settings.95 Cisco and
TCS assert that, using Cisco’s wireless local area network and TCS’s gateway client technology for
commercial location solutions, they can already provide a “‘dispatchable’ location – indicating street
address, building identifier, floor number, and suite number ‒ along with a floor plan … showing the
location of the phone,” with accuracy between five and ten meters.96 Though much of the deployment of
indoor location-capable infrastructure thus far has been commercial, there are a growing number of
residential products that easily be used as a source of location in a comprehensive dispatchable location
solution.97 Nevertheless, some commenters still argue that beacon and Wi-Fi technologies have not been
90

See, e.g., Polaris Wireless Comments (corrected) at 3-4 (stating that its “hybrid model includes additional layers
above the base layer, such as location data derived from [DAS], metro cells and pico cells, data derived from WiFi
access points, and finally data derived from sensors,” and that this “stack of location” would enable it to achieve
compliance with the Commission’s proposed requirements).
91

See e.g., Sunsight Instruments Roadmap Reply Comments at 2.

See CSRIC LBS Report at 34; Galbraith, Craig, “Number of Wi-Fi Access Points Growing Quickly,” BILLING AND
OSS WORLD (Sept. 6, 2013), available at http://www.billingworld.com/news/2013/09/number-of-wi-fi-accesspoints-growing-quickly.aspx (last visited Jan. 21, 2015); Apple, iPhone Tech Specs, available at
http://www.apple.com/iphone/specs.html (last visited Jan. 21, 2015); Android, Developers, Connectivity, available
at http://developer.android.com/guide/topics/connectivity/bluetooth.html (last visited Jan. 21, 2015); Bluetooth,
“Mobile Telephony Market” (2014), available at http://www.bluetooth.com/Pages/Mobile-Telephony-Market.aspx
(last visited Jan. 21, 2015). See also Panzarino, Michael, “The Open Secret Of iBeacon: Apple Could Have 250M
Potential Units In The Wild By 2014,” TECHCRUNCH (Dec. 7, 2013), available at
http://techcrunch.com/2013/12/07/the-open-secret-of-ibeacon-apple-could-have-250m-units-in-the-wild-by-2014/
(last visited Jan. 21, 2015).
93

See http://www.verizonwireless.com/accessories/samsung-network-extender-scs-2u01/ (last visited Jan. 21, 2015);
http://www.sprintenterprise.com/airave/faq.html (last visited Jan. 21, 2015);
http://www.att.com/standalone/3gmicrocell/?fbid=W5aTdQD6xi9 (last visited Jan. 21, 2015);
http://www.tmonews.com/2014/09/t-mobile-asus-personal-cellspot-lte-cel-fi/ (last visited Jan. 21, 2015).
94

Roadmap at Section 2(b)(i) (“To the extent that a carrier plans to introduce new wireless consumer home
products, such carrier agrees to introduce such products that will provide dispatchable location within 18-24 months
of the date of the Agreement. Products not installed by carrier representatives may require the customer to input
dispatchable location data (e.g., apartment number) into the product or device.”).
95

Letter from H. Russell Frisby, Counsel, TeleCommunication Systems, Inc., to Marlene H. Dortch, Secretary,
Federal Communications Commission (filed Jan. 16, 2015), Attachment at 28 (TCS Jan. 16 Ex Parte).
96

Cisco/TCS Sept. 12, 2014 ex parte at 2

See Nest Protect, https://nest.com/smoke-co-alarm/life-with-nest-protect/ (last visited Jan. 6, 2015); August Smart
Lock, http://august.com/ (last visited Jan. 5, 2015); Smarter Socket, http://smartersocket.com (last visited Jan. 6,
2015).

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thoroughly enough tested to justify reliance on them in any dispatchable location solution.98 Others
submit that the Commission should open a separate proceeding dedicated to dispatchable location.99
48.
CMRS commenters note that much of the in-building infrastructure that will be needed to
support dispatchable location lies outside their control and will require building owners and other thirdparty stakeholders to be involved in the deployment process.100 T-Mobile submits that “[t]o attain truly
actionable indoor locations requires buy-in and development from all stakeholders—not just wireless
carriers, but also public safety, … state and local governments who regulate building codes, and, perhaps
most critically, premises owners.”101 T-Mobile suggests that state and local governments should modify
building and fire codes to require deployment of such devices throughout a building.102
(ii)

Handset Hardware and Software Changes

49.
Despite the widespread availability of Wi-Fi- and Bluetooth-equipped phones,103
commenters observe that implementation of dispatchable location solutions may require hardware,
firmware, and/or software modifications to handsets to enable them to communicate with in-building
infrastructure such as Wi-Fi or Bluetooth beacons.104 Several commenters also note that in order for
handsets to use Wi-Fi or Bluetooth to search for nearby location beacons when a caller places a 911 call,
handset operating systems will need to be configured to activate Wi-Fi and Bluetooth automatically, in
the same manner that current GPS-capable handsets activate GPS automatically when the user calls
911.105 The Roadmap Parties commit to work with device manufacturers and operating system
developers in order to implement these changes.106
50.
The Roadmap also anticipates the need for deployment of new handsets to accommodate
dispatchable location technologies, and commits the signatory CMRS providers to equip all carrierprovided VoLTE handset models with the “capability to support delivery of beacon information, e.g.,
Bluetooth LE and WiFi, to the network” no later than 36 months after completion of relevant standards,
including interim benchmarks at the 24 and 30 month timeframes.107 The parties also agree to enable their
98

IACP et al Roadmap Comments at 2; IMSA Roadmap Comments at 5; TruePosition Roadmap Comments at 5-6.
But see CCIA Roadmap Reply Comments at 2 (“WiFi and Bluetooth technologies are fully integrated into the
existing mobile wireless ecosystem and are not “untested” as some parties claim. The roadmap accelerates progress
on location accuracy also by leveraging existing commercial location services.”); Cisco Roadmap Comments at 1012.
99

Hawaii E911 Board Roadmap Comments at 2; AARP Roadmap Comments at 2.

100

See, e.g., 4G Americas Aug. 11, 2014 ex parte at 2; T-Mobile Comments at 2.

101

T-Mobile Comments at 2.

102

T-Mobile Comments at 2 and Reply Comments at 12. See also Sprint Reply Comments at 12; iPosi Reply
Comments at 5-6; 4G Americas Aug. 11, 2014 ex parte at 2.
103

See, e.g., AT&T Comments at 2 (pointing out that many existing smartphones are capable of sensing nearby WiFi and Bluetooth beacons for cLBS purposes and suggests that these capabilities could be similarly exploited for 911
purposes).
104

See, e.g., TIA Comments at 4 (“new user devices will need to be deployed to support this feature in order to be
available to support the Commission’s location accuracy objectives.”).
105

Cisco Comments at 9; AT&T Comments at 2; Sprint Comments at 1; TCS Comments at 32.

106

Roadmap at Section 2(f)(i)-(ii).

107

Id. at Section 2(f). The Roadmap commits to equipping 25 percent of VoLTE handsets with this capability
within 18-24 months from the completion of standards and 50 percent of VoLTE handsets within 24-30 months. Id.
at Section 2(f)(iv). The Roadmap similarly commits to improvements in x/y location related to VoLTE handset
deployments to support A-GNSS 911 capabilities, including 50% of new VoLTE handsets within 24 months, 75%
of VoLTE handsets within 36 months, and 100% of VoLTE handsets within 48 months. Id. at Section 3(c).

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VoLTE networks to deliver beacon-based location information from handsets within 24 months after the
completion of relevant standards.108
51.
The Parallel Path offers similar commitments on a longer timeframe, including a
suggestion that all VoLTE handset models for non-nationwide CMRS providers would support the same
delivery of beacon information no later than 48 months after the completion of relevant standards.109 The
Parallel Path commits to the delivery of beacon information by their VoLTE networks within 36 months
after completion of standards, or 12 months of their VoLTE networks becoming operational, with full end
to end functionality for dispatchable location for their VoLTE networks within 60 months (or 12 months
of becoming operational).110
52.
Some commenters stress the need for further development of standards to ensure that
location applications originally developed for cLBS have the level of quality, reliability and redundancy
needed to support emergency location.111 We note that efforts are already under way to develop such
standards. The 3rd Generation Partnership Project (3GPP) and Open Mobile Alliance (OMA) have been
in cooperative efforts to enhance LTE to meet public safety application requirements, and 3GPP has been
prioritizing indoor positioning in developing its most recent release for LTE.112 In addition, CSRIC IV
Working Group 1 was charged to examine whether CMRS providers transitioning to VoLTE platforms
should still heed recommendations from an earlier CSRIC report on testing methodology and parameters
as they began “blending” GPS handset-based location data with network-based data, per Section 20.18(h)
of the Commission’s rules.113 Among other findings, CSRIC notes that “[i]n addition to the committed
LTE location methods discussed …, other location methods such as Wi-Fi for VoLTE have been
standardized. Wi-Fi for position calculation has been standardized in Secure User Plane (“SUPL”) 2.0 and
is available for deployment on GSM, UMTS, CDMA and LTE.”114
53.
The Roadmap commits the four nationwide CMRS providers to promote development
and approval of standards within 18 months of the date of the Agreement, as well as to formally sponsor

108

Roadmap at Section 2(g).

109

Parallel Path at Section 2(d). The Parallel Path suggests non-nationwide carriers equipping 25 percent of VoLTE
handsets with this capability within 30-36 months from the completion of standards and 50 percent of VoLTE
handsets within 36-42 months. Id. With respect to x/y enhancement, the Parallel Path also commits to deployment
of A-GNSS capable VoLTE handsets along the following timetable: 50% at 36 months; 75% at 48 months and
100% within 54 months. If, however, the nationwide carriers offer four or less VoLTE-capable handsets at any of
these benchmarks, then only a minimum of one handset will have the capability of supporting A-GNSS for 911. Id.
at Section 3(c).
110

Parallel Path at Section 2(e) and (f).

111

Sprint Comments at 13(footnote omitted).

112

See Flore, Dino, 3GPP RAN Chairman, “Initial priorities for the evolution of LTE in Release-13” (Sept. 20,
2014), available at http://www.3gpp.org/news-events/3gpp-news/1628-rel13 (last visited Dec. 29, 2014). See also
Korinek, Frank and Vadalà, Francesco, “Mobile Network Operators Can Offer Strong Services for Public Safety
Networks with the Help of OMA Standards,” 911 MAGAZINE (May 12, 2014), available at
http://openmobilealliance.org/mobile-network-operators-can-offer-strong-services-for-public-safety-networks-withthe-help-of-oma-standards/ (last visited Dec. 29, 2014) (OMA 911 Article).
113

See CSRIC IV, Working Group 1, Final Report – Location Accuracy and Testing for Voice-over-LTE Networks
(Sept. 2014) at 3, available at
http://transition.fcc.gov/pshs/advisory/csric4/CSRIC%20IV%20WG1%20TG2%20Report.pdf (last visited Jan. 29,
2015) (CSRIC VoLTE Report).
114

CSRIC VoLTE Report at 13. CSRIC caveats that “Wi-Fi support for control plane UE-Assisted call flows is
standardized only for LTE in the LPPe protocol.” Id.

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standards efforts regarding the use and delivery of Bluetooth LE and Wi-Fi information to the network.115
Additionally, the Roadmap Parties committed to participate actively in standards setting work, as well as
to engage with technology companies and others in the private sector to promote the prioritization and
completion of standards setting work.116 The parties also agree to sponsor standards activities to
operationalize the display of dispatchable location in pre-NG911 PSAPs.117
(iii)

Location Database Development and Management

54.
We sought comment in the Third Further Notice on the use of location databases by
CMRS providers to verify location information, as well as the privacy and security implications raised by
these databases.118 Commenters note that some of the database infrastructure that would be needed to
support dispatchable location already exists. TCS states that it has database access to the location of more
than 38 million Wi-Fi nodes to assist in locating users of cLBS applications.119 However, existing
databases that map in-building infrastructure may not provide the level of reliability and security needed
to support 911 location. Commenters assert that any database used to support dispatchable location will
require mechanisms to enable PSAPs to access the location data,120 verify the trustworthiness and
accuracy of the data, and keep the data up-to-date.121 CMRS providers also contend that developing and
managing secure location databases will require the cooperation of building owners and state and local
governments.122
55.
The Roadmap addresses the database issue by proposing a plan for the implementation of
a National Emergency Address Database (NEAD).123 As envisioned in the Roadmap, the NEAD will
contain media access control (MAC) address information of fixed indoor access points, which a device
would “see” upon initiating a wireless 911 call.124 When the device “sees” the MAC address of this
particular device, the CMRS network would cross-reference this MAC address with a dispatchable
address, which would be made available to the PSAP. The Roadmap Parties have committed to work
together to develop the design, operations, and maintenance requirements for the NEAD within 12
115

Roadmap at Section 2(d) (agreeing to “formally sponsor 3GPP Study Item RP-141003 as the standards vehicle
that will allow handsets to deliver Bluetooth LE and WiFi information to the network, and to work through the
standards process to incorporate the Bluetooth LE and WiFi dispatchable location concept into the 3GPP technical
report within 12 months of the Agreement.”).
116

Roadmap at Section 2(d)(ii) (“at a minimum including – (1) Relevant 3GPP Specifications (e.g., LTE control
plane location 3GPP LPP spec 36.355), and (2) Standards to support dispatchable location (e.g., J-STD-036).”).
117

Roadmap at Section 2(d)(iii).

118

Third Further Notice, 29 FCC Rcd at 2425 ¶ 136.

119

TCS Comments at 22.

120

Sprint Reply Comments at 11. See also Cisco Comments at 9-10 (“current Wi-Fi location mechanisms require
access to the Wi-Fi identifier, the MAC address. To obtain this information, a 911 Service Provider may require
access to a database or a protocol enhancement might be necessary to allow the 911 Service Provider to query the
information from the device itself. 911 Service Providers also may need gateway devices to enable them to query
participating enterprise networks to find the Wi-Fi based location of the phone.”).
121

TCS Comments at 21. Some commenters argue that CMRS providers cannot control when a Wi-Fi hotspot or
small cell installed by a third party is moved to a different location, and therefore cannot be certain that location
information associated with the device is up-to-date. See e.g., iPosi Comments at 3-4. Other commenters contend
that technology exists that would enable small cells to self-locate and provide automatic updates to a location
database when moved. See Rx Networks Comments at 5.
122

NextNav Reply Comments at 47; 4G Americas ex parte at 2; Cisco Comments at 10; Sprint Comments at 17-18.

123

Roadmap at Section 2(e).

124

Id. at Section 2(e)(i).

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months of the Agreement.125 The Parallel Path makes a similar commitment within the 12-month
timeframe.126 The parties also agree to “work together to establish a database owner, funding
mechanisms, provisions for defining security/privacy, performance, and management aspects, and to
launch the initial database within 12-24 months after the development of the design requirements.”127
Finally, the parties agree to work together to integrate dispatchable location information from third-party
sources into the NEAD, and to enlist the support of other organizations to achieve this goal.128
56.
In response to the Roadmap’s NEAD proposal, numerous commenters express concern
that the proposal lacks critical details and leaves too many issues unresolved, some of which could
hamper development.129 For example, NASNA states that “the carriers promised to ‘take steps to make
non-NEAD dispatchable location information available for delivery of PSAPs,’ but did not describe when
or how those steps would be taken. It may be surmised from the discussion in the Roadmap at 2.b.i, ii and
iii that this would occur within 30 days of the anniversary of the agreement, but that is not clear.”130
NASNA also notes that Roadmap does not specify how it will incorporate existing legacy location
databases and new or soon-to-be operational NG911 location databases.131 To address this concern,
Sprint submits that the Commission could play an important role in the development and implementation
of the NEAD: “the Commission could, for example, include in its equipment authorization rules,
procedures or training materials for telecommunications certification bodies a labeling requirement
instructing the consumer or installer of the equipment to register it in the NEAD.”132
57.
Additionally, a number of commenters express concern with regard to the preservation of
individual privacy throughout the implementation and subsequent use of the NEAD.133 Specifically,
125

Id. at Section 2(e)(ii).

126

Parallel Path at Section 2(c)(i).

127

Roadmap at Section 2(e)(iii); see also Parallel Path at Section 2(c)(ii).

128

Roadmap at Section 2(e)(iv); see also Parallel Path at Section 2(c)(iii).

129

See, e.g., Fairfax County VA Roadmap Comments at 1 (“We support the intent … but feel that certain elements
of the Roadmap, such as the [NEAD] should be addressed as a secondary discussion, as the costs, location,
management, and provisioning of the NEAD are so preliminary in scope and definition that an agreement to its
purpose and role in NG9-1-1 make signing an agreement to it…premature. The concept of NEAD is interesting, but
the practical impact of who will pay for the implementation is currently unclear and an area the PSAP community
needs to better understand before endorsing its adoption.”); Reply Comments at 2. See also CSR Roadmap
Comments at 3; IACP et al Roadmap Comments at 2; IMSA Roadmap Comments at 5; iCERT Roadmap Comments
at 2; NextNav Roadmap Comments at ii, 9, 14; Polaris Wireless Roadmap Comments at 4; TruePosition Roadmap
Comments at 9-10.
130

NASNA Roadmap Comments at 3.

131

NASNA Roadmap Comments at 3-4 (“Today’s E911 methodology for validating a location involves several
databases. Addresses must conform to the number range in the Master Street Address Guide (MSAG) before they
are added to the [ALI] database. NG911 also relies on databases to validate addresses, but the functions provided by
the ALI and MSAG databases have been replaced by GIS databases and a new location validation function (LVF).
NG911 systems, including the new databases, are being implemented across the country today, and more will
become operational in the next 36 months. Within the timeframe of this Roadmap and beyond, the environment will
be a patchwork of legacy and NG911 systems. The Roadmap does not clearly state that the NEAD will be required
to use available standards-based legacy MSAGs where applicable or available standards-based NG911 LVFs where
applicable.”).
132

Sprint Roadmap Reply Comments at 9.

133

Public Knowledge Roadmap Comments throughout; IMSA Roadmap Comments at 5; iPosi Roadmap Comments
at 4 (suggesting that a federal entity be in charge of the NEAD to eliminate some of these privacy concerns);
NextNav Roadmap Comments at 14; Fairfax County VA Roadmap Reply Comments at 2; TruePosition Roadmap
Reply Comments at 13.

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Public Knowledge cautions that the NEAD would contain sensitive personal information,134 and that the
proposal as written in the Roadmap lacks safeguards to ensure “that the database will be secure, used only
for E911 purposes, and never sold to or otherwise shared with third parties, including government
entities.”135 Public Knowledge suggests that the Commission should require communications providers,
cable operators, and satellite providers offering wireless consumer home products to allow consumers to
“opt out” of including their products in such a database.136 Public Knowledge asks the Commission to
clarify that location information collected from a consumer’s device and stored in the NEAD would be
considered customer proprietary network information (CPNI),137 and determine what safeguards would
apply to information that may not constitute CPNI.138 Public Knowledge urges that the Commission
address these privacy issues now and encourages the Commission to adopt a “privacy by design”
approach.139 Public Knowledge also recommends that the Commission adopt regulations that “require
CMRS carriers and others to treat mobile 911 location information and NEAD as protected information
and prohibit its sharing with third parties.”140
58.
On the other hand, TCS states that “the technologies suggested by the Roadmap raise no
new privacy concerns that do not already exist with today’s 9-1-1 solutions; and the security concerns
raised are no greater than those already facing public safety with regards to [NG911] technologies.”141
TCS adds that “our current public safety infrastructure contains much more sensitive information than
what the Roadmap envisions.”142 AT&T submits that the Roadmap’s proposal is “basically analogous to
how 911 location has always been performed on the PSTN,” and stresses that the NEAD database would

134

Public Knowledge Roadmap Comments at 2. Public Knowledge argues that “users of networked devices likely
do not expect that information about their device and physical address will be stored in a national database that is
accessible to multiple parties,” that “as the database is updated over time, it could reveal the exact address of
individuals who have moved from one location to another and brought their networked devices with them,” and that
“software vulnerabilities make it possible for malicious third parties to obtain their victims’ MAC addresses
remotely, which … could then be used to derive physical address as well.” Id. at 3. Public Knowledge also points
out that “mobile devices are used by teens and even children—users whose location might be considered more
sensitive than adults’, and who are less equipped to consider the implications of sharing location information with
third parties.” Id. at 11.
135

Public Knowledge Roadmap Comments at 4.

136

Id. at 2, 13.

137

Id. at 6-7, n.12 (quoting Implementation of the Telecommunications Act of 1996: Telecommunications Carriers’
Use of Customer Proprietary Network Information and Other Customer Information, Declaratory Ruling, 28 FCC
Rcd 9609, 9611 (June 27, 2013) at ¶ 8 ‘[T]he definition of CPNI in section 222 and the obligations flowing from
that definition apply to information that telecommunications carriers cause to be stored on their customers’ devices
when carriers or their designees have access to or control over that information.’”
138

Public Knowledge Roadmap Comments at 7.

139

Id.

140

Id.at 12. Specifically, Public Knowledge urges the Commission to require that (1) CMRS providers must treat
location information derived from responsive technologies as CPNI; (2) CMRS providers must afford all entries in
NEAD the same protections afforded to CPNI; (3) telecommunications providers, cable operators, and satellite
operators that offer wireless consumer home products must provide consumers who purchase or use such products
the ability to opt out of participating in the NEAD; and (4) CMRS providers ensure that location information and
NEAD are secure. Id. at 12-13.
141

TCS Roadmap Reply Comments at 7.

142

Id. at 9.

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be limited “to access for 911 purposes and only during the processing of 911 calls.”143 Sprint states that
privacy related concerns “will be addressed in the context of working groups.”144
59.
In response to these concerns, the Roadmap Parties filed an Addendum that sets forth
measures they will take to address privacy and security concerns related to the implementation of the
NEAD. In particular, the Roadmap Parties commit to (1) “engage with various industry experts on
privacy and security to ensure that best practices are followed in the development and operation of the
database”; and (2) “require the vendor(s) selected for the NEAD administration to develop a Privacy and
Security Plan in advance of going live and transmit it to the FCC.”145 New America, Public Knowledge,
and other privacy advocates suggest that these measures remain insufficient, however, and urge the
Commission to take additional actions to promote privacy and security.146
(iv)

PSAPs’ Ability to Use Dispatchable Location Information

60.
Finally, we sought comment in the Third Further Notice on whether and how PSAPs
would be able to use dispatchable location information.147 NASNA submits that “E911 location databases
and call-handling software products have a field that is used in wireline calls to identify apartment
numbers. This field could be used to display this information.”148 In addition, NASNA states that “[i]f the
LBS data are converted to lat/long or a civic address, NASNA does not know why it would cause any
issues.”149 Cisco states that “a 911 Service Provider, would query enterprise networks located in and
around the cell site where a 911 call originates, using a new gateway device to access the location data for
that particular end user device,”150 a process which it describes as “relatively simple straightforward.”151
Nevertheless, Intrado and TCS caution that changes at the PSAP level would be necessary.152
61.
The commitments in the Roadmap regarding dispatchable location are not contingent on
a PSAP’s ability to accept such information, but the Roadmap does include a caveat that “implementation
and execution of the elements within this document may be subject to a number of variables, including
but not limited to… third party resources, which may require the signatories to reassess the progress” of
143

AT&T Roadmap Reply Comments at 6.

144

Sprint Roadmap Reply Comments at 15. See also NENA Roadmap Reply Comments at 8.

145

Addendum at 4.

146

See Letter from Laura M. Moy, Open Technology Institute, New America, to Marlene H. Dortch, Secretary,
Federal Communications Commission (filed Jan. 22, 2015) (New America Jan. 22, 2015 Ex Parte); Letter from
Laura M. Moy, Open Technology Institute, New America, et al., to Marlene H. Dortch, Secretary, Federal
Communications Commission (filed Jan. 22, 2015) (New America et al. Jan. 22, 2015 Ex Parte).
147

Third Further Notice, 29 FCC Rcd at 2419-20 ¶ 123.

148

NASNA Comments at 12. NASNA goes into further detail: “In the current environment, location information
from wireless calls is delivered to the PSAP in x- and y-coordinates. Geographic Information System (GIS) software
is then required at the PSAP to convert this to a civic address. This could be changed by moving the GIS software
further back in the delivery process. Latitude and longitude data could be converted to a civic address at the Mobile
Positioning Center (MPC), then delivered through a shell ALI record to the PSAP in the same way that VoIP calls
are. In a NG911 environment, that conversion to a civic address could occur after the lat/long are delivered to the
NG911 network.” See id.
149

NASNA Comments at 12.

150

Cisco Comments at 10.

151

Id.

152

Intrado Comments at 8-9 (“[t]here would need to be procedural or ALI format changes made at the PSAP so that
the PSAP would know that these are dispatchable address originating from small indoor cells versus Phase I
macrocell addresses.”); TCS Comments at 8 (“work may still be needed for PSAP customer premises equipment
(CPE) to display all of the information that can be conveyed.”).

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the Roadmap.153 However, the Roadmap also states that the parties “will work with public safety to study
and consider further steps to providing wireline-equivalent routing for wireless consumer home products
that provide a dispatchable location.”154
c.

Discussion

62.
Although we originally proposed dispatchable location as a long-term goal, the record
shows that technology exists today that could be used to implement various dispatchable location
solutions in the near term, as evidenced by the Amended Roadmap’s provisions for immediate
commencement of development of dispatchable location solutions and the Parallel Path’s provisions
committing to the implementation of dispatchable location technologies into wireless consumer home
products and wireless handsets.155 Moreover, CMRS providers are already incentivized to deploy many
of these technologies to expand coverage and to manage network capacity more efficiently. For example,
Cisco notes that in 2013, “approximately 45 percent of all mobile data traffic was offloaded on the fixed
network via Wi-Fi or femtocell” and further estimates that “by 2018, more traffic will be offloaded on to
Wi-Fi networks than will be carried over cellular networks.”156 Given the commercial benefits of
deploying the technologies that would support improved indoor location accuracy, we anticipate that
commercial location systems will continue to proliferate, providing additional resources that could be
leveraged for E911 use.157
63.
The record also confirms the clear public safety benefits of implementing dispatchable
location as a core component of our approach to improving wireless indoor location. As APCO and
NENA point out, dispatchable location represents the “gold standard” for first responders, because it
provides the functional equivalent of address-based location information provided with wireline 911 calls.
We note that wireline-equivalent location accuracy is of particular importance to individuals who are
deaf, hard of hearing, deaf-blind, and/or have speech disabilities, and we believe the approach adopted
here serves as a significant step in the right direction towards achieving such location accuracy.158
64.
We recognize, nonetheless, that dispatchable location cannot be achieved overnight, that
the implementation concerns raised by commenters must be addressed, and that we must adopt
timeframes that afford sufficient time to address these concerns. We agree with Verizon that any indoor
location solution that can be scaled nationwide “will depend on third parties or require cooperation with
vendors in order to comply with any standards the Commission may adopt,” but also that “[t]he need for
engagement with other stakeholders merely reflects the diversity of the wireless communications
ecosystem consisting of service providers, solution vendors, manufacturers, and others and already exists
today.”159
65.
We believe the Amended Roadmap provides the appropriate foundation for our approach.
With regard to standards, as described above, the standards development process for many dispatchable
location technologies is already under way, and the Amended Roadmap contains commitments to advance
the development and approval of standards for many relevant technologies. The Amended Roadmap also
offers a reasonable path forward with respect to deployment of in-building infrastructure and introducing
necessary hardware and software modifications into new handsets. The Parallel Path makes similar
commitments for non-nationwide CMRS providers. In light of the Amended Roadmap and Parallel Path,
153

Roadmap Cover Letter at 2.

154

Roadmap at Section 2(b)(i)(1).

155

Id. at Section 2(b)(i); Parallel Path at Section 2(b)(i) and (2)(D).

156

Cisco Comments at 6 (footnotes omitted).

157

See generally, Roberson Report.

158

TDI Roadmap Comments at 2.

159

Verizon Roadmap Reply Comments at 19 (footnotes omitted).

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we find that the implementation timeframes adopted today sufficiently consider these issues and provide
adequate time for all CMRS providers to plan for and implement a compliant dispatchable location
solution if they so choose.
66.
In evaluating dispatchable location, the Addendum also proposes that compliance with
vertical accuracy requirements would be satisfied in a CMA where the total number of “dispatchable
location reference points” in that CMA meets or exceeds the population of the CMA divided by a
concentration factor of 4 within six years, based on 2010 census data.160 The Addendum commits parties
to populate the NEAD with MAC address or Bluetooth reference points for dispatchable location
reference points under their direct control for all CMAs. We agree with this approach, and find that a
location solution that provides dispatchable location information to PSAPs in accordance with the
prescribed benchmarks and meets the density calculation recommended by the Addendum will be
considered in compliance with the vertical location accuracy requirements adopted herein.161 We concur
that given the average population per household in the top 50 CMAs and typical Wi-Fi usage scenarios,
the density calculation recommended in the Addendum should provide adequate coverage, particularly in
light of the horizontal accuracy benchmarks described below that CMRS providers using dispatchable
location must ensure that they meet.162
67.
The Parallel Path suggests that non-nationwide providers would be able to take certain
steps in advance of the NEAD’s implementation to develop dispatchable location ability, and that such
CMRS providers commit to development, design and implementation of the NEAD, population of its
data, and support of the database in concert with NENA, APCO and other stakeholders. They also
commit to certain timeframes associated with handset and network design and development to support
delivery of beacon information.163
68.
With respect to the proposal to develop and implement the NEAD to support dispatchable
location, we recognize that while the NEAD has significant public safety value, there are significant
privacy and security concerns associated with the aggregation of critical infrastructure and private
intellectual property data.164 Although some commenters contend that the NEAD does not present a
greater threat to data privacy than already exists today,165 the Roadmap and Parallel Path Parties agree that
there is a need for privacy and security measures to be implemented with the NEAD.166 We emphasize
that privacy and security concerns must be addressed during the design and development of the NEAD
from its earliest stages. We will hold the NEAD administrator, as well as individual CMRS providers that
utilize the NEAD, accountable for protecting the privacy and security of consumers’ location information.
69.
Development of the NEAD Privacy and Security Plan. We require each of the nationwide
CMRS providers to develop and submit for Commission approval a detailed Privacy and Security Plan for
the NEAD, to be submitted with the interim progress reports discussed above, due 18 months from the
Effective Date.167 We note that the Roadmap Parties specifically commit “to require the vendor(s)
160

Addendum at 3.

161

See supra Section III.B.3.b.

162

CTIA Ex Parte Letter (dated Jan. 21, 2015), at 3 n.3.

163

Parallel Path at Section 2(d)-(f).

164

See, e.g., Public Knowledge Roadmap Comments at 2-6; Fairfax County VA Roadmap Reply Comments at 2;
TruePosition Roadmap Reply Comments at 13.
165

Verizon Roadmap Reply Comments at 14; TCS Roadmap Reply at 7-8.

166

NENA Roadmap Reply Comments at 8; CTIA Roadmap Reply Comments at 18 n. 71; Roadmap Addendum at 4
(committing to developing best practices in coordination with industry experts and requiring the vendor selected to
administer the NEAD to develop a “Privacy and Security Plan”); Parallel Path at Section (2)(c)(i).
167

See supra para. 36. We emphasize that the development of the Privacy and Security Plan should not delay or
otherwise affect the development and prototyping of the NEAD. The development of the NEAD should be pursued
(continued….)

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selected for the NEAD administration to develop a Privacy and Security Plan in advance of going live and
transmit it to the FCC.”168 While we require the nationwide CMRS providers (rather than the vendor) to
submit the Privacy and Security Plan, our approach is otherwise consistent with this commitment. The
Roadmap Parties also pledge to collaborate with “industry experts on privacy and security to ensure that
best practices are followed in the development and operation of the database.”169 In this regard, we expect
the providers to develop the plan in close collaboration with a broad range of relevant stakeholders,
including network security and reliability experts, equipment manufacturers (including device, software
and network manufacturers), public interest advocacy groups (including privacy advocates, and consumer
and disabilities rights groups), and other, non-nationwide communications service providers.170 The plan
should appoint an administrator for the NEAD, prior to the database’s activation, who will serve as a
single point of contact for the Commission on the security, privacy, and resiliency measures that will be
implemented in the NEAD.
70.
We will make the NEAD Privacy and Security Plan available for public notice and
comment to promote openness and transparency,171 and to ensure that the plan addresses the full range of
security and privacy concerns that must be resolved prior to use of the database. Upon review of the plan
and the record generated in response, we will evaluate the need to take any additional measures to protect
the privacy, security, and resiliency of the NEAD and any associated data. In this respect, while
commenters have raised important issues, we need not address their specific concerns regarding the
treatment of data within the NEAD at this time, as such concerns can be raised and fully addressed in
connection with our evaluation of any specific plan that may be filed.
71.
Privacy and Security Measures Applicable to Individual CMRS Providers. In addition to
the NEAD Privacy and Security Plan, we believe that certain explicit requirements on individual CMRS
providers are necessary to ensure the privacy and security of NEAD data and any other information
involved in the determination and delivery of dispatchable location. We require that, as a condition of
using the NEAD or any information contained therein to meet our 911 location requirements, and prior to
use of the NEAD, CMRS providers must certify that they will not use the NEAD or associated data for
any purpose other than for the purpose of responding to 911 calls, except as required by law.
Additionally, should aspects of a CMRS provider’s dispatchable location operations not be covered by the
NEAD privacy and security plan, the provider should file an addendum to ensure that the protections
outlined in the NEAD plan will cover the provider’s dispatchable location transactions end-to-end. We
note that there is support for this requirement in the record, including by the Roadmap Parties. For
example, AT&T pledges that the information contained in the NEAD will not be used for any nonemergency purposes.172 Likewise, Verizon affirms that “the Roadmap signatories committed to
addressing the security and privacy of customers’ information as part of the NEAD’s development, which
(Continued from previous page)
in parallel with the development of the Privacy and Security Plan, in order to ensure the NEAD is ready and
operational in a timeframe consistent with the deadlines set forth herein.
168

Roadmap Addendum at 4. We note that the signatory parties also voluntarily commit to assessing dispatchable
location at 36 months from the date of the Roadmap. See Roadmap at Section 2(i)(i).
169

Roadmap Addendum at 4.

170

See New America et al. January 22, 2015 Ex Parte at 5 (“The Commission should encourage carriers to consult
with privacy and consumer organizations as they develop E911 technology and privacy and security plans.”)
171

TDI requests that “[t]he Commission should encourage further effort by having appropriate open and transparent
bodies (e.g., CSRIC) study elements of the Roadmap,” including the privacy and reliability of the NEAD. See
Letter from Claude L. Stout, Executive Director, TDI, to Marlene H. Dortch, Secretary, Federal Communications
Commission (filed Jan. 22, 2015) at 2. We expect the providers to consult with relevant stakeholders, including
members of the CSRIC, and emphasize the importance of an open and transparent process throughout the
development of the NEAD Privacy and Security Plan.
172

AT&T Roadmap Reply Comments at 6.

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will be used exclusively for 911 purposes.”173 To the extent location information (by itself or in
conjunction with other data concerning the customer) constitutes proprietary information protected under
Section 222 of the Communications Act,174 we note that Section 222 expressly allows for the provision of
a user’s call location information to certain emergency response providers, in order to respond to the
user’s call for emergency services.175 In light of the Section 222 exception for 911 calls and the required
certification by CMRS that NEAD data will only be used for 911 location purposes, nothing in this
Fourth Report and Order should be construed to permit any use of customer or location information
stored in the NEAD in any other context.
72.
PSAP Ability To Use Dispatchable Location Information. We disagree with commenters
who argue that PSAPs will not be able to accept dispatchable location information. First, PSAPs already
receive location data in street address format (as opposed to geodetic coordinates) for wireline 911 calls.
This capacity to receive non-geodetic data can be readily leveraged to accept delivery of dispatchable
location information from wireless calls as well. Second, under the approach we adopt today, PSAPs
retain the choice of whether to accept dispatchable location information (where available) or to request
that the CMRS provider provide only geodetic coordinates to that PSAP.176 Even where PSAPs choose to
accept dispatchable location information with 911 calls, CMRS providers should also make coordinate
information for such calls available to the PSAP whenever feasible.177 Although PSAPs may need to
make adjustments in procedure and additional personnel training may be necessary, we do not believe
these factors justify a delay in adopting indoor location accuracy requirements that encourage
dispatchable location solutions.
73.
We applaud the commitments for dispatchable location set forth in the Amended
Roadmap and Parallel Path, as they represent a meaningful and actionable plan for achieving dispatchable
location for wireless 911 calls, particularly indoor calls. The Roadmap and Parallel Path also state that
the signatory CMRS providers will work with public safety to study and consider further steps to
providing wireline-equivalent routing for wireless consumer home products that provide a dispatchable
location.178 However, as many commenters point out, the Roadmap contains no guarantee that
dispatchable location will be successfully deployed or will function as intended.179 Therefore, to ensure
sufficient location accuracy for all wireless indoor 911 calls, we find it necessary to adopt coordinate173

Verizon Roadmap Reply Comments at 12-13 (emphasis in original).

174

47 U.S.C. § 222.

175

See 47 U.S.C. § 222(d)(4)(A) (providing that a telecommunications carrier may provide call location information
concerning the user of a commercial mobile service or IP-enabled voice service “to a public safety answering point,
emergency medical service provider or emergency dispatch provider, public safety, fire service, or law enforcement
official, or hospital emergency or trauma care facility, in order to respond to the user’s call for emergency
services”).
176

While the record indicates that PSAPs should be able to receive dispatchable location information as well as
geodetic coordinates, some PSAPs may prefer some current call processing systems that may not enable PSAPs to
receive both sets of information simultaneously. See Verizon Roadmap Reply Comments at 12.
177

Providing coordinate information in addition to dispatchable location information will enable PSAPs to continue
using coordinates as part of their emergency response data set and to corroborate the validity of the dispatchable
location information. However, where the CMRS provider provides dispatchable location information, the
corroborating coordinate information associated with the call need not meet coordinate-based accuracy thresholds
and will not be considered for compliance purposes.
178

Roadmap at Section 2(b)(i)(1); Parallel Path at Section 2(b)(3).

179

AARP Roadmap Comments at 1; IAFF Roadmap Comments at 1; FindMe911 Coalition Roadmap Comments at
26; Hawaii E911 Board Roadmap Comments at 2; IACP et al Roadmap Comments at 2; NASNA Roadmap
Comments at 8; NextNav Roadmap Comments at 10; Polaris Wireless Roadmap Comments at 3; TruePosition
Roadmap Comments at 4, 17.

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based requirements for both the x- and y-axes and the z-axis as alternatives to dispatchable location. We
discuss these requirements below.
3.

Horizontal Location Information

74.
In the Third Further Notice, we proposed a horizontal accuracy standard of 50 meters for
indoor wireless calls, to be achieved by 67 percent of indoor 911 calls within two years and 80 percent of
indoor 911 calls within five years.180 As discussed in Section III.B.2, supra, we are incorporating the
Roadmap’s provisions for implementation of dispatchable location as an alternative means to provide
accurate indoor location information with a 911 call. However, the Roadmap also provides that CMRS
providers will meet their commitments by providing coordinate information based on a 50-meter
standard, in the event a dispatchable location solution is unavailable. Therefore, the rules we adopt
include a standard for coordinate-based location as an alternative to dispatchable location. In addition, we
modify our originally proposed horizontal location benchmarks and timelines to incorporate elements
from the Roadmap (including the slightly more generous timeframes and percentage benchmarks from the
Addendum and the Parallel Path), but we also include backstop elements adapted from our original
proposals:


Nationwide CMRS providers must provide (1) dispatchable location,181 or (2) x/y location within
50 meters, for the following percentages of wireless 911 calls within the following timeframes,
measured from the effective date of rules adopted in this Order (“Effective Date”):







Within 2 years: 40 percent of all wireless 911 calls.
Within 3 years: 50 percent of all wireless 911 calls.
Within 5 years: 70 percent of all wireless 911 calls.
Within 6 years: 80 percent of all wireless 911 calls.

Non-nationwide CMRS providers are subject to the same two- and three-year benchmarks as
nationwide CMRS providers (i.e., 40 percent at 2 years, and 50 percent at 3 years). At years 5
and 6, non-nationwide CMRS providers are subject to the rules as follows:


within the later of five years from the Effective Date or six months of having an
operational VoLTE platform in their network, 70 percent of all wireless 9-1-1 calls
(including VoLTE calls); and



within the later of six years from the Effective Date or six months of having an
operational VoLTE platform in their network, 80 percent of all wireless 9-1-1 calls
(including VoLTE calls).182

We discuss the elements of these requirements below.
a.

50-Meter Search Ring

75.
Background. In the Third Further Notice, we proposed to require CMRS providers to
identify an indoor 911 caller’s horizontal location within 50 meters.183 We reasoned that a search radius
of 50 meters had a reasonable likelihood of identifying the building from which the call originated, while

180

Third Further Notice, 29 FCC Rcd at 2393 ¶ 44.

181

See supra Section III.B.2 .

182

See Competitive Carrier Association Ex Parte Letter, Attachment “Parallel Path,” at 6 (Sec. 5(b)) (filed Jan. 16,
2015) and Competitive Carrier Association Ex Parte Letter at 3 (filed Jan. 23, 2015).
183

Third Further Notice, 29 FCC Rcd at 2393 ¶ 44.

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a search radius larger than 50 meters was unlikely to assist first responders in building identification.184
We also proposed to implement the 50-meter accuracy requirement in two stages with different reliability
thresholds (67 percent in two years and 80 percent in five years).185 We noted that our current outdoorbased location accuracy rules use a “dual search ring” approach, with separate metrics for 50-meter and
150-meter accuracy. However, given the limited utility of a search radius larger than 50 meters for indoor
location, we proposed a single-ring rather than a dual-ring approach.186
76.
Public safety commenters overwhelmingly support the proposed 50-meter standard,187
although some express a preference for a smaller search radius than 50 meters.188 Some CMRS providers
argue against setting a 50-meter standard. AT&T, for example, argues that such a requirement is of
“dubious value to public safety” for indoor location dense-urban and urban morphologies.”189 CMRS
providers also argue that it is more efficient to concentrate their resources on achieving dispatchable
location rather than meeting a 50-meter standard that provides only approximate location.190 The
Roadmap, however, provides that technologies capable of achieving 50-meter indoor horizontal accuracy
qualify as “heightened location accuracy technologies” that may be used to meet the accuracy
benchmarks in the agreement.191
77.
Discussion. We find it in the public interest to require CMRS providers to provide
location information based on a horizontal 50-meter search radius where a dispatchable location is not
available. Public safety commenters overwhelmingly confirm that a 50-meter x/y capability would be of
significant benefit in helping to locate indoor 911 callers. Moreover, the Roadmap effectively adopts a
50-meter standard for indoor horizontal location. The record further indicates that provision of tighter
geodetic data can contribute to better provision of a dispatchable location by, for example, helping to

184

Id. at 2393 ¶ 45. For example, a 100-meter requirement would only narrow the search radius to a city block at
best. A Manhattan city block is 80 meters by 270 meters. See “City block,” available at
http://en.wikipedia.org/wiki/City_block (last visited Jan. 16, 2015).
185

Third Further Notice, 29 FCC Rcd at 2394 ¶ 48.

186

Id. at 2395 ¶ 51.

187

NENA Comments at 14; NASNA Comments at 4-5; IAFC Reply Comments at 1-2; IAFF Comments at 3;
Metropolitan Fire Chiefs Reply Comments at 2; IACP Comments at 1; NextNav Comments at 28; Letter from Terry
Hall, President, APCO International, to Marlene H. Dortch, Secretary, FCC, WT Docket No. 11-49, at 2 (filed May
6, 2013); Letter from Adam D. Kennard, Executive Director, National Sheriffs’ Association, to Julius Genachowski,
Chairman, FCC, WT Docket No. 11-49 (filed Apr. 3, 2013), at 1; Letter from Telford E. Forgety, III, Director of
Government Affairs & Regulatory Counsel, NENA: The 9-1-1 Association, to Julius Knapp, Chief Engineer, Office
of Technology, FCC, WT Docket No. 11-49 (filed Mar. 22, 2013), at 2.
188

See, e.g., APCO Comments at 4; Texas 911 Entities Comments at 2; BRETSA Comments at 16.

189

AT&T Comments at 10-11. See also CTIA Reply Comments at 12 (calling the proposed indoor requirements
only “marginal improvements”); Intrado Comments at 4 (“if the X,Y coordinate is not accurate enough to locate
which door the emergency caller is behind, there is little additional value to the first responder.”); Blooston
Comments at 5 (the “added costs of compliance with the proposed rules will make only (at best) a marginal
contribution to public health and safety.”).
190

See, e.g., AT&T Reply Comments at 5-6 (“by the time that CMRS providers are in a position to meet any
proposed new location-accuracy standards, they could be well-under way to providing a dispatchable-address
solution … in light of the time it would take CMRS providers to implement any plan to incrementally improve ALI
for the short-term, they could be ready to finalize implementation on the ultimate solution.”). See also AT&T
Comments at 3-4; Sprint Reply Comments at 10; Verizon Reply Comments at 12; CTIA Reply Comments at 1;
CCA Reply Comments at 9, 11; Blooston Comments at 2.
191

Roadmap at Section 4(c).

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incorporate and distinguish accurate WLAN-based signals of opportunity as well as by providing more
accurate geodetic location information for reverse geo-coding.192
b.

50-Meter Compliance Thresholds and Timeframes
(i)

Background

78.
In the Third Further Notice, we proposed a two-stage implementation timeframe for the
50-meter horizontal requirement, with a reliability threshold of 67 percent to be achieved in two years and
an 80 percent threshold to be achieved in five years.193 We stated our belief that even if currently
available location technology could not satisfy the proposed 50-meter standard in the most challenging
indoor environments, the proposed timeframe would be sufficient for the development of improved
technology and deployment of such technology by CMRS providers as needed to comply with the
proposed requirements.194 We sought comment on our proposed timeframe and various alternatives, and
received substantial comment on these issues.
79.
CMRS providers generally object to the Third Further Notice proposal, contending that
the proposed two- and five-year benchmarks cannot be met with existing technology and do not provide
enough time for technological improvements.195 Many other commenters, however, argue that the Third
Further Notice’s benchmarks and timeframes are both achievable and reasonable.196
80.
The Roadmap proposes horizontal location benchmarks and timeframes that, like those in
the Third Further Notice, require CMRS providers to achieve a defined level of accuracy for a specified
percentage of 911 calls over a series of interim and longer-term deadlines. The details of the Roadmap
proposal, however, differ from the Third Further Notice proposal in several respects. First, the Roadmap
proposes to use live call data that would combine indoor and outdoor calls for purposes of measuring
location accuracy performance, where the Third Further Notice proposed an indoor-specific standard with
test-bed data used to measure compliance.197 Second, the Roadmap sets forth different compliance
percentages and timeframes than the Third Further Notice: as an interim threshold, the Third Further
Notice proposes 50-meter accuracy for 67 percent of indoor calls after two years, while the Roadmap
would require heightened accuracy for 40 percent of combined indoor and outdoor calls after two years
and for 50 percent of combined calls after three years.198 For the longer term, the Third Further Notice
proposes 50-meter accuracy for 80 percent of indoor calls after five years, while the Roadmap sets
benchmarks of 75 and 80 percent of combined indoor and outdoor calls for the fifth and sixth years,
respectively, and would have limited the calculation to VoLTE calls.199

192

See, e.g., TruePosition Ex Parte Letter at 1 (filed Oct. 9, 2014) (); Intrado Ex Parte Letter, Attachment at 11
(filed Sep. 26, 2014) (“Improved accuracy of X/Y/Z … reduces the total error of reverse geocoding”).
193

Third Further Notice, 29 FCC Rcd at 2396 ¶ 55.

194

Id. at 2394 ¶ 47.

195

Transit Reply Comments at ii; ITI Comments at 3-4; Motorola Comments at 3; TIA Comments at 3; Qualcomm
Comments at 4; SouthernLINC Reply Comments at 2; 4G Americas Ex Parte at 1-2 (8/11/14).
196

See, e.g., AdGen Comments at 1; NASNA Comments at 4; NextNav Comments at 3; TruePosition Comments at
6-7; NARUC Comments at 8; NPSC Comments at 1; TDI Comments at 3-4; IAFF Comments at 5; NENA
Comments at 14; IAFC Reply Comments at 2; Metropolitan Fire Chiefs Reply Comments at 2.
197

Roadmap at Section 4(a).

198

Roadmap at Section 4(c).

199

Id. We note that in the Addendum, the nationwide carrier signatories committed to a 60 percent metric at Year 5
for all calls including non-VoLTE calls (as opposed to the 75 percent offered in the Roadmap for VoLTE calls), and
an 80 percent metric for all calls at Year 7 (as opposed to the 80 percent offered for VoLTE calls at Year 6). See
AT&T Services, Inc., Sprint, T-Mobile USA, and Verizon Letter at 4 (“Addendum”) (filed Jan. 21, 2015). See also
(continued….)

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81.
The parties to the Roadmap contend that the Roadmap benchmarks and timelines offer
significant advantages over the corresponding proposals in the Third Further Notice.200 The Roadmap
parties also argue that the proposals included in the Roadmap are technically achievable, whereas the
proposals of the Third Further Notice were not.201 Many other commenters cite similar reasons for
supporting the proposed Roadmap horizontal location metrics.202 For example, CCA believes the
Roadmap “is a well-balanced proposal aimed at improving enhanced location accuracy standards for both
outdoor and indoor calls to 911, while also establishing benchmarks for providing ‘dispatchable location’
to first responders.”203
82.
However, many other commenters criticize the proposed Roadmap benchmarks and
timeframes as inadequate to improve indoor location accuracy. These commenters contend that because
the Roadmap accuracy benchmarks blend indoor and outdoor measurements, CMRS providers can meet
the benchmarks primarily through improvements to satellite-based location that enhance outdoor location
accuracy without achieving any significant improvement to indoor location accuracy.204 They also
criticize the fact that the Roadmap sets lower percentage thresholds than the Third Further Notice,
particularly in the early stages (e.g., 40 percent of calls compared to 67 percent of calls at the two year
mark),205 and extends the overall implementation period from five to six years. 206 Many commenters also
object strongly to the five- and six-year Roadmap benchmarks because they only consider VoLTE 911
calls in measuring compliance.207 These commenters generally argue that the Commission should reject

(Continued from previous page)
APCO Ex Parte Letter (filed Jan. 21, 2015) and NENA Ex Parte Letter (filed Jan. 21, 2015) (both expressing
support the Addendum).
200

See, e.g., NENA Roadmap Comments at 1; APCO Roadmap Comments at 2; CTIA Roadmap Reply Comments
at ii-iii.
201

AT&T Roadmap Reply Comments at 1-2; T-Mobile Roadmap Reply Comments at 1-2.

202

APCO Roadmap Comments at 2; Intrado Roadmap Comments at 2; TIA Roadmap Comments at 2; NATOA
Roadmap Comments at 3; Mobile Future Roadmap Comments at 2; ILA Roadmap Comments at 1; CTIA
Comments at 12; Pennsylvania NENA Roadmap Comments at 1; Garfield County Roadmap Comments at 1;
Colorado NENA Roadmap Comments at 1; iCERT Roadmap Comments at 2; TCS Roadmap Comments at 4; CSR
Roadmap Comments at 3.
203

Competitive Carrier Association Ex Parte Letter at 1 (filed Jan. 16, 2015) (“Parallel Path”). CCA qualified its
endorsement of the Roadmap, believing the Roadmap as initially presented should be adopted by the Commission
“exclusively for the four nationwide carriers,” id. at 1, because of the impact on smaller carriers of the Roadmap’s
testing, reporting, and deployment arrangement. Regarding horizontal location accuracy, CCA offered a ‘parallel
path” for smaller, non-nationwide carriers to achieve the same percentage benchmarks and timetable as the
nationwide carriers for Years 2 and 3, and in fact offered a more aggressive benchmark for small carriers to meet (70
percent of all wireless 911 calls at Year 5, provided they had operational VoLTE platforms, contrasted with the 60
percent offered in the Addendum); similarly, the Parallel Path would, under appropriate conditions, have small
carriers reach an 80 percent rate for location fix for all calls at Year 6, contrasted with the Addendum similar rate for
all calls at Year 7. See Parallel Path at Section 5(b).
204

Hawaii Roadmap Comments at 2; AARP Roadmap Comments at 1: Nebraska Roadmap Comments at 2; NASNA
Comments at 6; Fairfax Roadmap Comments at 1; CFSI Roadmap Comments at 1; NextNav Roadmap Comments at
iii, 7, 9, 17, 18, 20; FindMe911 Roadmap Comments at 3, 33; TruePosition Roadmap Comments at 17.
205

NARUC Roadmap Comments at 5; NASNA Roadmap Comments at 6; Fairfax Roadmap Comments at 1.

206

NARUC Roadmap Comments at 5-6; Hawaii Roadmap Comments at 2.

207

NASNA Roadmap Comments at 5; NextNav Roadmap Comments at 24; FindMe911 Roadmap Comments at 3,
25, 26, 41; Hawaii Roadmap Comments at 2; TruePosition Roadmap Comments at 12-13.

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the Roadmap and simply adopt the original benchmarks and timeframes proposed in the Third Further
Notice.208
83.
In debating the relative merits of the proposed benchmarks and timeframes for horizontal
location in the Third Further Notice and the Roadmap, commenters present contrasting views of the
viability of certain location technologies to improve horizontal location accuracy, particularly indoors. In
particular, commenters focus on the following technologies: (1) Observed Time Distance of Arrival
(OTDOA), (2) terrestrial beacon systems, (3) Uplink Time Distance to Arrival (UTDOA), (4) Radio
Frequency (RF) fingerprinting, and (5) in-building infrastructure, including Wi-Fi and Bluetooth.
84.
OTDOA. OTDOA is a location technology that uses the time difference observed by user
equipment between the reception of downlink signals from two different cells.209 CMRS providers plan
to implement OTDOA in conjunction with the rollout of VoLTE.210 While Qualcomm states that initial
field trials have shown that OTDOA “is able to provide accuracy to within a few tens of meters both
indoors and outdoors when carriers deploy and configure their networks appropriately,”211 it adds that
OTDOA has not been sufficiently tested yet and that its deployment “will require extensive infrastructure
improvements and capital expenditures by each carrier.”212
85.
Terrestrial Beacons. The principal proponent of terrestrial beacons is NextNav, which
tested a first-generation version of its Metropolitan Beacon System (MBS) in the 2013 CSRIC test bed.
NextNav asserts that its second-generation system has achieved significantly improved horizontal
accuracy in urban, dense urban, and suburban areas, and could meet a five-year performance metric of 50
meters for 80 percent of indoor calls.213 NextNav also believes its technology will be standardized in
2015 and that comprehensive network construction would require fifteen to eighteen months in most
urban markets.214 Commenters challenge NextNav’s ability to meet the indoor horizontal requirement in
the timeframe proposed in the Third Further Notice, arguing, for example, that NextNav’s claimed indoor
location accuracy results may be overstated because it has only tested a technology prototype.215
86.
UTDOA. This is a network-based system developed by TruePosition that determines
location based on the time it takes the 911 caller’s cell phone signal to travel to nearby receivers called
Location Measurement Units (LMUs). TruePosition claims that 2014 test results demonstrate that
UTDOA technology could meet the Commission’s proposed two-year accuracy standard today, and could
meet the proposed five-year standard assuming sufficient density of LMU deployments;216 it also asserts
208

See, e.g., Calif. State Firefighters’ Assoc. Roadmap Comments at 1; Congressional Fire Services Institute
Roadmap Comments at 1; Fraternal Order of Police of Ohio Roadmap Comments at 1; Hawaii E911 Roadmap
Comments at 1; NARUC Roadmap Comments at 5; San Francisco Dept. of Emergency Management Roadmap
Comments at 1.
209

See Sven Fischer, “Observed Time Difference of Arrival (OTDOA) Positioning in 3GPP LTE” at 8, available at
https://www.qualcomm.com/media/documents/files/otdoa-positioning-in-3gpp-lte.pdf (last visited Jan. 5, 2015).
210

4G Americas Ex Parte at 2 (8/11/14) (footnotes omitted). See also AT&T Ex Parte at 3 (8/26/14).

211

Qualcomm Reply Comments at 6.

212

Id.

213

NextNav Reply Comments at 6-7.

214

NextNav Comments at 10.

215

T-Mobile Comments at 15-16; T-Mobile Reply Comments at 19 (footnote omitted). See, also Transit Reply
Comments at 6; CTIA Reply Comments, Bokath Report at 10. Several commenters also contend that NextNav has
underestimated the time required to develop MBS-capable chipsets and integrate them into handsets, which they
argue could take four to six years. See, e.g., TCS Comments at 23. See also AT&T Comments at 9, T-Mobile
Reply Comments at 18, CTIA Reply Comments at 11.
216

TruePosition Reply Comments at 15

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that UTDOA is commercially available, that LMUs could be deployed rapidly, and that implementation
does not require replacement or upgrading of handsets.217 CMRS providers dispute these assertions,
arguing that UTDOA is not compatible with the evolving design of 3G and 4G networks and that it
requires handsets to operate at increased power that will cause disruptive interference.218
87.
RF Fingerprinting. This technology locates wireless calls by analyzing radio frequency
measurements from all available sources (including A-GNSS, OTDOA, and small cells or Wi-Fi
hotspots), and matching them against a geo-referenced database of the radio environment.219 Its principal
proponent, Polaris, states that it has been able to “demonstrate [] indoor location accuracies of
approximately 30-40m across a variety of indoor morphologies” and that it can meet the Commission’s
proposed horizontal accuracy requirements within the proposed timeframe.220 Some commenters,
however, question the viability of Polaris’ technology, arguing that it has received only limited testing
and that its accuracy in measuring horizontal location degrades with the height of the test point.221
88.
In-Building Infrastructure. Several commenters note that indoor, infrastructure-based
technologies that can support dispatchable location, as discussed in Section III.B.2.b infra, may also be
able to provide geodetic coordinates that could improve indoor location. For example, Rx Networks
submits that “proliferation of Wi-Fi enabled devices such as door locks, thermostats, security systems,
and light bulbs will increase the density of indoor Wi-Fi devices thereby providing a greater number of
points that can be located (either through self-location or crowd sourcing the location) which will result in
improved multilateration fixes,”222 while TIA asserts that application of this standard to Wi-Fi based
location “will be capable of producing 10 feet of accuracy on a horizontal X/Y axis 90% of the time.”223
(ii)

Discussion

89.
As noted, both the Third Further Notice and the Amended Roadmap propose horizontal
location benchmarks and timeframes that require CMRS providers to achieve a defined level of accuracy
for a specified percentage of 911 calls over a series of deadlines, but the proposals diverge in some
details. In comparing the two, we conclude that some elements of the Amended Roadmap proposal offer
advantages over our original proposal. In particular, the Amended Roadmap offers more clarity by
identifying the categories of technologies that would be deemed to provide “heightened location
accuracy” sufficient to meet its benchmarks. At the same time, it provides flexibility for CMRS providers
to choose from a wide array of different technological approaches to achieve heightened location
accuracy, and provides a mechanism for development and test-based validation of new location
technologies. These elements are consistent with our strong preference for flexible and technologically
neutral rules, as we stated in the Third Further Notice.224
90.
Another key strength of the Amended Roadmap is its use of live 911 call data as opposed
to relying solely on test data to measure compliance with location accuracy requirements. While test data
also plays an important role in validating location accuracy performance, both in the Amended Roadmap
217

TruePosition Comments at 7.

218

CTIA Reply Comments at 7-8; T-Mobile Reply Comments at 21; T-Mobile ex parte, Attachment at 5 (filed
10/9/14).
219

Polaris Comments at 3.

220

Id. at 5 (emphasis in original).

221

Transit Reply Comments at 6, T-Mobile Reply Comments at 22. See also CCA Reply Comments at 6.

222

Rx Networks Comments at 15.

223

TIA Comments at 4. While CSRIC notes use of Wi-Fi nodes for position calculation has been standardized is
available for deployment on GSM, UMTS, CDMA and LTE networks, it added that “Wi-Fi support for control
plane UE-Assisted call flows is standardized only for LTE in the LPPe protocol.” See CSRIC VoLTE Report at 13.
224

Third Further Notice, 29 FCC Rcd at 2393 ¶ 44.

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and in the rules we adopt in this Report and Order,225 the Amended Roadmap commitment to use live call
data establishes for the first time an empirical basis for measuring the use and performance of different
technologies in delivering location data to PSAPs, and holds CMRS providers accountable based on
actual 911 calls rather than solely on test calls. Therefore, we believe it is appropriate to incorporate this
element of the Amended Roadmap into our rules.
91.
We also modify our original proposal to establish horizontal location benchmarks at two
and five years, instead adopting benchmarks at two, three, five, and six years that are more reflective of
the Amended Roadmap timetable. While many commenters would prefer us to adopt our original
timetable, we also received extensive comment indicating that adhering to overly aggressive deadlines
could end up being counterproductive. In this respect, we believe the general timeframes and benchmarks
offered in the Amended Roadmap, which were the product of intense negotiation among the Roadmap
parties, are more realistic and therefore more likely to result in concrete improvements in location
accuracy. We also note that Roadmap’s six-year timeframe is not significantly longer than the five-year
timeframe proposed in the Third Further Notice.226
92.
Regarding horizontal location information, the Parallel Path commits the nonnationwide CMRS providers to providing dispatchable location or x/y location within 50 meters for the
following percentages of calls:





40 percent of all wireless 911 calls within two (2) years;
50 percent of all wireless 911 calls within three (3) years;
70 percent of all wireless 911 calls (including VoLTE calls) within the later of five (5) years,
from the date of this Agreement or six months of having an operational VoLTE platform in
their network; and
80 percent of all wireless 911 calls (including VoLTE calls) within the later of six (6) years
from the date of this Agreement or one year of having an operational VoLTE platform in
their network.227

93.
We conclude that it is in the public interest to codify the horizontal location benchmarks
in the Amended Roadmap (as modified for small CMRS providers in the Parallel Path) in this Report and
Order. We recognize that this approach differs from that of the Third Further Notice, which proposed
indoor-specific benchmarks for which compliance would be measured by testing in a variety of indoor
environments. However, the approach adopted here, based on the Amended Roadmap, will enable
measurement of location accuracy performance based on live calls, an approach that has substantial
benefits. When using live call data, it is difficult to distinguish individual 911 calls based on whether
they were originated indoors or outdoors, as numerous commenters point out. Thus, establishing an
indoor-specific benchmark that relies solely on live call data may not be practical.
94.
As noted above, some commenters have criticized allowing CMRS providers to blend
location accuracy data from outdoor as well as indoor calls. However, we do not believe it is practical or
appropriate to establish compliance benchmarks that are limited to indoor calls or indoor-oriented
solutions, or that the foregoing concerns outweigh the substantial benefits of live call data. For example,
the record indicates that satellite-based A-GNSS location is not only capable of providing a location fix of
50 meters or less outdoors, but will also be able to locate callers in indoor environments where satellite
signal reception is not compromised (e.g., in single-story wood frame buildings or in larger structures
225

See supra Section III.B.5.b.

226

As described at note [180] supra, the Roadmap signatories, in the Addendum, sought to adjust certain metrics (at
Year 5 from 75 percent for VoLTE calls, to 60 percent for all calls, and at Year 7 (not Year 6 as initially proposed)
for 80 percent of all calls, not VoLTE calls alone. In their January 23, 2015, ex parte letter, the Amended Roadmap
parties put forth a Year 3/50 percent/all calls metric, and a Year 6/80 percent/all calls metric.
227

See Parallel Path at Section 5(b).

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where the caller is located near a window). NextNav has cited data from the 2013 CSRIC III test bed
report indicating that the percentage of successful indoor GPS fixes was 23 percent in urban environments
and 11 percent even in dense urban environments.228 We see no reason to discount reliance by CMRS
providers on such successful indoor fixes in promoting our goals for indoor location accuracy.
Conversely, particularly in light of the rapidly accelerating trend toward indoor wireless calls, we do not
believe these figures provide any significant disincentive for CMRS providers to pursue alternative
solutions for indoor calls in more challenging indoor locations. Indeed, CMRS providers have significant
incentive in many indoor situations to pair A-GNSS with other location technologies. As CSRIC notes,
“[m]ultiple combinations of different technologies can be combined together to produce a more reliable
and accurate position estimate than any one system alone.”229 In regard to LTE specifically, CSRIC notes
that “[location a]ccuracy may be improved because LTE supports more flexible hybrid positioning
methods than 2G/3G. The [Serving Mobile Location Center] can initiate multiple location methods at
once.”230
95.
CMRS providers will be able to choose from a variety of technology solutions that are
either already commercially available or close to commercial availability, because they have already
recognized the potential need to rely on these technologies to meet their commitments if there is no timely
dispatchable location solution, and because CMRS providers will have substantial time and flexibility to
implement the best solution or combination of solutions. 231 To the extent that CMRS providers choose to
move forward with dispatchable location, as discussed in Section III.B.2.b, infra, any dispatchable
location solution will count towards the horizontal benchmark at the appropriate thresholds. In addition,
CMRS providers have the option of leveraging indoor infrastructure such as small cells and Wi-Fi
hotspots to provide x/y location within 50 meters as opposed to dispatchable location. Similarly,
providers may use OTDOA to comply with the horizontal benchmark to the extent that OTDOA is
determined through testing to meet the 50-meter standard. This is consistent with the CMRS providers’
commitment in the Roadmap to deploy OTDOA in their roll-out of VoLTE and to use it in conjunction
with A-GNSS as a primary location solution.232
96.
In addition to dispatchable location and OTDOA, CMRS providers have several other
technologies to choose from. While NextNav’s first-generation beacon technology fell short of 50-meter
accuracy in some environments in the CSRIC test bed, subsequent testing indicates that its secondgeneration MBS technology can achieve 50-meter accuracy in suburban, urban, and dense urban

228

NextNav Ex Parte Letter, Jan. 25, 2015, at 2.

229

CSRIC VoLTE Report at 14.

230

CSRIC VoLTE Report at 11.

231

See, e.g., AT&T Roadmap Comments at 8 (“With the addition of the NEAD, wireless providers can now choose
from an array of technologies that generally fall into two distinct categories: (1) outside-based technologies (e.g.,
OTDOS, A-GPS, RF fingerprinting, network beacons, satellite-based positioning), and (2) inside-based technologies
(e.g., Wi-Fi hot spots and Bluetooth Low Energy beacons”); TIA Roadmap Comments at 5 (by leveraging improved
satellite, LTE-based and commercial location based technologies such as Wi-Fi, First Responders will receive
improved location information and when indoor networks can be leveraged, a dispatchable address for an indoor
wireless 9-1-1 call); AT&T Roadmap Reply Comments at 17 (“we will be able to empirically demonstrate the
benefits of leveraging WiFi and Bluetooth beacons, both via dispatchable address and crowdsourcing.”); Motorola
Mobility Roadmap Comments at 2 (The Roadmap is the product of positive collaboration between the public and
private sectors and further evidences the wireless industry’s commitment to leveraging new technologies to provide
first responders with a “dispatchable location” for 911 calls placed indoors).
232

Roadmap at Section 1(a).

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environments.233 Moreover, the additional year CMRS providers will have to meet our benchmarks
should provide sufficient time for deployment of MBS-capable handsets.234
97.
UTDOA technology is also sufficiently developed to present a viable option for CMRS
providers. Although TruePosition has not tested UTDOA with LTE networks, CSRIC notes that
“[l]ocation accuracy of UTDOA deployed on LTE networks should be comparable to, or better than, the
accuracy achieved by UTDOA deployed on 3G or 2G networks …”235 UTDOA is already commercially
available from two different vendors and does not require any handset replacement, only updates to the
CMRS providers’ networks.236 While some commenters question UTDOA’s viability because it relies on
“powering up” by the handset, this is not an insurmountable problem. Powering up already occurs for
emergency voice calls on GSM networks,237 adjustment of handset power is incorporated into industry
standards, and any power-up requirements for emergency calls would be fairly brief and limited
exclusively to 911 calls.238 We also find that should CMRS providers decide to pursue UTDOA as a
solution, the additional year afforded them to meet the benchmarks should provide sufficient time to
address any issues regarding the impact of LMU deployment on network performance.
98.
Polaris Wireless’ RF fingerprinting technology will also likely be able to meet our
requirements in many indoor environments when used in conjunction with other location technologies.
Radio Frequency (RF) fingerprinting can be used in conjunction with OTDOA and other location
technologies, with no handset replacement necessary because the RF mapping capability is implemented
from the network side. Thus, if CMRS providers wish to use RF mapping, the technology is also likely to
be sufficiently developed that it can be used in a hybrid solution to help meet both our horizontal location
accuracy requirements.
c.

Geographic Scope of Horizontal Location Requirements for NonNationwide CMRS Providers

99.
In the Third Further Notice, we proposed to apply the horizontal indoor location accuracy
requirements on a nationwide-basis, across all geographic areas,239 under the belief that only a limited
number of environments would require CMRS providers to deploy additional infrastructure to satisfy our
proposed indoor accuracy requirements, so that applying the requirements nationwide would be both
technologically feasible and economically reasonable.240 Nevertheless, we sought comment on an
alternative proposal to apply the proposed indoor location accuracy requirement in a more targeted
fashion based on population and multi-story building density.241 We also sought comment on whether
233

NextNav Test Report at 2. Although some commenters criticized NextNav’s testing for using a prototype rather
than commercially available handsets, we believe NextNav’s test results are reasonably reflective of real world
conditions because all of the basic components of a commercial handset were tested.
234

Rx Network Comments at 7 (“Up to 24 months for mandating and realizing the necessary features and APIs on
smartphones”); Motorola Comments at 14 (“integration of GPS into digital cellular handsets took approximately 24
months”).
235

CSRIC VoLTE Report at 13.

236

TruePosition Comments at 7.

237

TechnoCom Reply, TruePosition Report at 1.

238

TruePosition Comments at 10.

239

Third Further Notice, 29 FCC Rcd at 2413-15 ¶¶ 104-09.

240

Id. at 2414 ¶ 105.

241

Id. at 2414 ¶ 106. We sought specific comment on whether to use the definition of “urban” as provided by the
U.S. Census Bureau (“[c]ore census block groups or blocks that have a population density of at least 1,000 people
per square mile (386 per square kilometer) and surrounding census blocks that have an overall density of at least 500
people per square mile (193 per square kilometer).”) or ATIS (“an area with [h]igh population density where multi(continued….)

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exclusions based on population density or dense forestation should apply, as well as how compliance
based on one or more test beds would affect the definition of areas to exclude.242
100.
In response to the Third Further Notice, several commenters express support for a
targeted application of indoor location requirements based on population density.243 Taking it a step
further, several small and regional CMRS providers argue that it would also be appropriate to exclude
rural areas from indoor-focused location accuracy requirements.244 Absent any such exclusion, RWA
expresses concerns about the ability of small and rural CMRS providers to achieve compliance with the
indoor horizontal location accuracy requirements in the proposed timeframe.245 SouthernLINC submits
that “a significant proportion of the nation’s regional and rural carriers are . . . transitioning their networks
and systems to LTE”246 and adds that if the nationwide carriers are able to achieve” the proposed
milestones of the Roadmap, “regional and rural carriers should be able to achieve them . . . , but would
need additional time because the necessary technology, equipment, and vendor support will generally not
become available to them until after the nationwide carriers have completed . . . implementation.”247
Similarly, CCA remarks that non-nationwide providers are not on the same LTE and VoLTE deployment
timelines as the nationwide CMRS providers.248 In the Parallel Path, CCA urges the Commission to
consider providing non-nationwide providers additional time to meet the five and six-year horizontal
location accuracy benchmarks of the Roadmap, so that those providers can “gain access” to VoLTE
handsets.249
101.
Discussion. To ensure compliance with our indoor-focused location accuracy standards,
we provide an approach that addresses the concerns of non-nationwide CMRS providers and provides
them flexibility as they migrate to VoLTE networks. For purposes of the instant Report and Order, we
refer to providers with networks that are limited to regional and local areas – as “non-nationwide
providers.”250 We recognize that, compared to the four nationwide CMRS providers that are parties to the
Roadmap, our indoor-focused location accuracy requirements will substantially affect non-nationwide
CMRS providers, particularly in years five and six under horizontal location accuracy requirements we
(Continued from previous page)
story apartment and office buildings are observed, and with [h]igh [cell] site concentration due to capacity
requirements and high signal penetration margins are encountered.”).
242

Third Further Notice, 29 FCC Rcd at 2415 ¶ 107. See 47 C.F.R. § 20.18(h) (1)(vi) (permitting exclusions for
counties or portions of counties where triangulation is not technically possible); 20.18(h)(2)(iii) (permitting
exclusions for heavily forested areas).
243

APCO Comments at 4; TruePosition Comments at 20; Verizon Comments at 25 (stating that such an approach
“will reward providers for focusing initial deployments on the very urban areas where the CSRIC III report and
public safety stakeholders indicate that indoor accuracy concerns are highest”); Sprint Comments at 18.
244

See NCTA Reply Comments at 2; RWA Comments at 6; Blooston Rural Reply Comments at 2-3; SouthernLINC
Wireless Reply Comments at 6.
245

RWA Comments at 6 (stating that“[t]he length of the exclusion will depend on the degree of accuracy and
deadlines the Commission ultimately adopts, but should extend at least two years beyond the time urban carriers are
required to come into compliance” and “should ensure that carriers operating in such rural areas have sufficient time
to come into compliance with the standards ultimately adopted without requiring such carriers to incur financial
hardship to come into compliance.”).
246

SouthernLINC Wireless Reply Comments at 7.

247

SouthernLINC Wireless Jan. 23, 2014 Ex Parte at 2.

248

CCA Jan. 23, 2015 Ex Parte at 2, citing CCA Jan. 16, 2015 Ex Parte at 1-2.

249

Id. at 2-3.

250

See Policies Regarding Mobile Spectrum Holdings and Expanding the Economic and Innovation Opportunities of
Spectrum Through Incentive Auctions, WT Docket No. 12-269 and Docket No. 12-268, Report and Order, 29 FCC
Rcd 6133, 6206 & n.502 (2014)

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adopt today. In this regard, we decline to phase in our horizontal location requirements based on
population density. Satellite-based location technology has already proven able to meet our horizontal
location requirements in rural areas and should provide the same capability soon in urban clusters.251
Accordingly, small and rural, as well as some regional, CMRS providers will likely need to make little
additional expenditure to comply with our two and three-year horizontal location accuracy requirements.
Similarly, we do not expect other providers to need to expend substantial additional resources to meet our
requirements in the less densely populated areas that they serve. Rather, the non-nationwide providers
can focus their resources on investing for and meeting our indoor-focused horizontal location
requirements in years five and six as set forth below.
102.
Moreover, our existing E911 exclusions apply only to outdoor areas in which naturallyformed physical characteristics of the area prevent the CMRS provider from obtaining accurate location
information on the 911 caller. Because the rules we adopt today are focused on indoor 911 calls – which
are not hindered by naturally-formed physical characteristics – there is no need to adopt similar
exclusions here. Moreover, applying these requirements uniformly nationwide is consistent with the
principle that improving 911 location is just as important in the least populous markets as in the most
populous.
103.
First, for compliance with the horizontal indoor location metrics, we require that the nonnationwide CMRS providers provide either dispatchable location or x/y location within 50 meters for the
same percentages of all wireless 911 calls, applicable to the nationwide providers, 40 and 50 percent at
the two-year and three-year timeframes, respectively, that are measured from the Effective Date. As
noted above, the record shows that non-nationwide CMRS providers that use handset-based location
technologies already rely extensively on satellite-based location technologies. Further, our requirement
allows them to comply with the indoor-based location accuracy requirements by using any location
technologies or combinations thereof. Similarly, current network-based non-nationwide CMRS providers
can either continue to use their non-satellite technologies that provide x/y coordinates or combine them
with implementing hybrid location technologies within the initial timeframes we require. These providers
also have the option and incentive to commence working on dispatchable location technologies and
resources to satisfy both our horizontal and vertical requirements.252
104.
Second, compared to the horizontal location metrics for years five and six under the
Roadmap, we require that non-nationwide CMRS providers that have deployed a commercially operating
VoLTE platform in their network253 shall provide dispatchable location or x/y location within 50 meters
for the same percentages of all wireless 911 calls applicable to the nationwide providers as follows: (i) 70
percent within the later of five years or six months of deploying a commercially operating VoLTE
platform, and (ii) 80 percent of all wireless 911 calls within the later of six years or one year of deploying
a commercially operating VoLTE platform. We agree with CCA that the disadvantages non-nationwide
CMRS providers face in deploying LTE networks warrant flexibility as they migrate to VoLTE networks
over the next few years.254 Non-nationwide providers are not on the same LTE and VoLTE deployment
timelines as the nationwide providers. As CCA notes, non-nationwide providers face “resource
constraints, spectrum constraints, and lack of equipment availability” that mean they “are often not able to
251

See “2010 Census Urban and Rural Classification and Urban Area Criteria,” UNITED STATES CENSUS BUREAU,
available at https://www.census.gov/geo/reference/ua/urban-rural-2010.html (last visited Dec. 30, 2014). NextNav
Reply Comments at 11. See also NextNav Test Report at 3 (“These test results confirm that, in the Urban Cluster
tested, A-GNSS meets the proposed horizontal location threshold of 50m for more than 80% of the test calls…”).
252

See infra Sec.III.B.4, addressing Vertical Location.

253

CCA describes a commercially-operating VoLTE platform “as the point in time when a non-nationwide carrier is
commercially offering VoLTE service to any subscriber in any portion of its service footprint.” See CCA Jan. 23,
2015 Ex Parte at 3, n.22, citing Parallel Path at Section 5(b).
254

See CCA Jan. 23, 2015 Ex Parte; CCA Roadmap Comments at 4-5.

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deploy LTE (much less VoLTE) on the same or even similar timeline as the nationwide carriers.”255 More
specifically, due to the limited scale and scope of their networks, non-nationwide CMRS providers often
have limited access to handsets that incorporate the latest technologies driven by the handset product
cycles of the nationwide CMRS providers.256 In light of these challenges, some non-nationwide provides
may face unavoidable delays in obtaining VoLTE-capable handsets and testing and deploying them in
their networks.257 Therefore, we conclude it is reasonable to provide non-nationwide CMRS providers
with greater flexibility than the nationwide providers to extend the five and six-year benchmarks until
they have had a reasonable opportunity to deploy and begin offering VoLTE on their networks. This
additional flexibility will enable non-nationwide small CMRS providers to integrate the measures needed
to meet our location accuracy standards into their plans to acquire, test, and deploy VoLTE handsets and
networks.
4.

Vertical Location Information
a.

Background

105.
In the Third Further Notice, we proposed that CMRS providers identify an indoor caller’s
vertical location within 3 meters for 67 percent of calls within three years, and for 80 percent of calls
within five years.258 We noted that at least one vendor had developed and tested vertical location
technology that could locate callers to within 2.9 meters at the 90th percentile259 and demonstrated
improvements in subsequent testing,260 and other vendors estimated having similar granular capabilities
within three to five years.261 Moreover, by the time the Third Further Notice was released, nearly all
smartphones had been equipped with sensors that can determine speed, compass direction, and
movement, and in some cases, height above sea level.262 These developments indicated that vertical
location technology had sufficiently matured to propose the inclusion of vertical location information for
indoor wireless 911 calls.263 We sought comment on whether an initial benchmark of three years would
be achievable.264

255

CCA Roadmap Comments at 4.

256

Id. at 5.

257

See CCA Roadmap Comments at 6-7 (noting, among various testing challenges, the difficulties and costs of drive
testing by non-nationwide CMRS providers that serve rural areas).
258

Third Further Notice, 29 FCC Rcd at 2402-03 at ¶ 73.

259

In the CSRIC test bed, NextNav was able to locate a caller’s vertical location within 3 meters more than 67
percent of the time in dense urban, urban, and rural morphologies. See Indoor Location Test Bed Report at 36.
NextNav conducted additional testing on the second generation of its location technology and reported
improvements in both horizontal and vertical location accuracy. It provided callers’ vertical location within 3.2
meters 80 percent of the time, across all morphologies. See NextNav Aug. 14, 2013 Ex Parte Letter at 3-11.
260

NextNav Aug. 14, 2013 ex parte at 1-2.

261

Polaris Workshop Comments at 3 (estimating that its vertical location accuracy performance “should achieve
floor-level precision across all indoor environments in the 3-5 year timeframe”).
262

Third Further Notice, 29 FCC Rcd at 2405 ¶ 79, citing Lawson, Stephen, “Ten Ways your Smartphone Knows
Where You Are,” PC WORLD, Apr. 6, 2012, available at
http://www.pcworld.com/article/253354/ten_ways_your_smartphone_knows_where_you_are.html (last visited Jan.
13, 2015).
263

Third Further Notice, 29 FCC Rcd at 2402-03 ¶ 73.

264

Id. at 2405 ¶ 79.

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106.
Public safety and consumer commenters urge the Commission to adopt indoor location
accuracy requirements as quickly as possible,265 but the record is divided with regard to the technical
feasibility of the proposed vertical location accuracy requirements and timeframe for implementation.
Some commenters argue that the proposed requirements are technically feasible, particularly if
multifaceted approaches are used.266 Other commenters, however, argue that current vertical location
technologies are not sufficiently precise to support the proposed level of vertical accuracy, and that it will
take significantly more time than estimated in the Third Further Notice to achieve such accuracy levels.267
107.
The comments suggest two potential paths for providing floor-level information with
indoor 911 calls: (1) programming physical fixed infrastructure such as beacons or Wi-Fi access points
with accurate floor-level information, and (2) using barometric pressure sensors in handsets to determine
the caller’s altitude, which is then used to identify the caller’s floor level.268 With respect to the second
option, commenters note that barometric sensors are increasingly common in handsets, and some analysts
project that the number of smartphones equipped with such sensors will increase to 681 million new units
per year in 2016.269 Bosch, a leading international supplier of sensors, notes that the large volume of
sensors being produced has resulted in significant economies of scale, which it estimates will drive the
per-unit cost downward to between $0.24 and $0.35 by 2017.270
108.
Despite the widespread commercial availability of barometric sensors, CMRS providers
question the accuracy of the current generation of sensors and argue that it will take significant time to
develop and standardize barometrically-generated vertical location information for 911 calls.271 These
commenters stress that barometer readings must be calibrated in order to provide first responders with
265

See IAFF January 23 Ex Parte at 1 (stating that “the proposal to establish a three meter vertical accuracy
requirement will vastly improve the ability of first responders to locate indoor calls, reducing response times and
significantly enhancing the public safety. Vertical accuracy requirements will also improve the safety of responding
personnel by providing for a directed search and thus reducing responder stress and disorientation). See also IACP
Comments at 1; IAFC Comments at 2; NASEMSO Comments at 2.
266

iPosi Comments at 6; NextNav Comments at 52, Reply at 13; Polaris Comments at 6-7; TruePosition Comments
at 17; Bosch Comments at 2-3. NextNav Comments at 18; NASNA Comments at 7; Rx Networks Comments at 7.
267

AT&T Reply Comments at 5-6 (“[I]nstead of seeing incremental improvement in wireless ALI on either the x/yor z-axis within the Commission’s projected two-to-three year timeframe, the actual timeframe for improvements
might easily be three to four times longer.”); AT&T Comments at 6, 8-9; CTIA Comments at 1 and Reply
Comments at 9-11; TIA Comments at 7, Reply Comments at 7-8; CCA Reply Comments at 6, 8; T-Mobile
Comments at 4-5; Verizon Comments at 21; RWA Comments at 2; CTIA Reply Comments at 11; Qualcomm
Comments at 11, 13; Motorola Comments at 6-12; ITI Comments at 5.
268

See Franczek, Witold, “Mean Sea Level, GPS, and the Geoid,” ESRI, available at
http://www.esri.com/news/arcuser/0703/geoid1of3.html (last visited Dec. 9, 2014). Barometric pressure sensors
could be used in multiple ways: in conjunction with other fixed physical infrastructure (i.e., disambiguating
between two Wi-Fi locations that are on different floors but both within range of the device calling 911), or as a
measurement of vertical height (using calibrated or uncalibrated air pressure readings for a vertical height estimate).
269

See Happich, Julien, “Samsung Leads the Adoption of Pressure Sensors in Smartphones, for Floor-Accurate
Indoor Geolocation,” EE TIMES EUROPE, Mar. 21, 2013, available at http://www.electronicseetimes.com/en/samsung-leads-the-adoption-of-pressure-sensors-in-smartphones-for-floor-accurate-indoorgeolocation.html?cmp_id=7&news_id=222916211 (last visited Jan. 21, 2015) (noting that new units per year in
2014 were more than eight times the 82 million new units per year in 2012).
270

Bosch Comments at 6.

271

See, e.g., Sprint Comments at 7-8; Verizon Reply Comments at ii; AT&T Comments at iii, 9, and 10. See also
Qualcomm Comments at 14 (stating that “barometric sensors offer some promise, but not all cell phones today
include such sensors…” and that “the positioning technologies that are being considered for z-axis location
information not only require consumers to acquire handsets but they also require mobile carriers to deploy new
network equipment.”).

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meaningful information, a process which is currently unstandardized.272 However, NENA and several
vendor commenters submit that calibration is not a difficult process, and that while calibrated data would
provide more accurate information and is preferable, even uncalibrated data would be useful to first
responders.273
109.
The Roadmap, Addendum, and additional filings reflect the parties’ preference for using
dispatchable location as the primary means to provide vertical location information, but they also make
specific and measureable commitments to develop and deploy capabilities to determine z-axis vertical
location information.274 First, in the Amended Roadmap, the CMRS provider parties commit to develop
and deliver uncompensated barometric pressure sensor data to PSAPs from compatible handsets that
support such a delivery capability within three years.275 Second, they commit “to develop a specific zaxis location accuracy metric that would be used as the standard for any future deployment of z-axis
solutions.”276 To demonstrate progress along this path, the parties agree to “promote the development and
approval of standards” for barometer-based solutions within 18 months.277 The parties also agree to
complete (i) a study within six months to evaluate options for using barometric pressure data to obtain a
z-axis, and (ii) a further study within 24 months that would include test bed evaluation of barometric and
other z-axis solutions.278 The Addendum further commits the nationwide CMRS providers to deploy zaxis solutions according to specific benchmarks for major population centers in the event they are unable
to provide dispatchable location.279 The Addendum provides a quantifiable z-axis backstop if a provider
has not met the dispatchable location benchmark by year 6 in any of the most populous 50 CMAs.280
Further, a CMRS provider “will be deemed to have implemented a Z-axis location solution in that CMA
if its Z-axis solution provides coverage for at least 80% of the population of the CMA within 8 years” and
“at least 50% of all new handset model offerings everywhere must be z-capable by year 7, and 100% of
all new handset models by year 8.”281
110.
Numerous commenters oppose the Roadmap’s vertical location provisions, particularly
objecting to the fact that the Roadmap proposes no specific standard for providing vertical location
information in the event that a dispatchable location solution cannot be achieved. 282 On the other hand,

272

T-Mobile Comments at 13 and Reply Comments at 6; AT&T Comments at 15; Sprint Comments at 7-8.

273

NENA Comments at 23-24 (“Once responders reach the correct lateral area, barometric sensors in their own
devices . . . will be subject to exactly the same systemic errors. That is, a responder entering a building with only
uncalibrated barometry data available could still locate the correct floor, provided she had available her own
barometer.”)(emphasis in original); NextNav Comments at 23 (“first responders are expected to have their own
devices…that can allow the responder to match his or her elevation to the conveyed elevation of the emergency,
removing the need for integrating databases or guesswork by dispatchers and responders on scene.”).
274

Roadmap at Section 5; Addendum at 2; CTIA January 23 Ex Parte.

275

CTIA January 23 Ex Parte at 2.

276

Id.

277

Roadmap at Section 5(a).

278

Id. at Section 5(b)(i)-(ii).

279

Addendum at 3-4.

280

Id. at 3.

281

Id.

282

National Association of EMS Roadmap Comments at 2; Polaris Wireless Roadmap Comments at 2; NARUC
Roadmap Comments at 5; NASNA Roadmap Comments at 7; IMSA Roadmap Comments at 6; Find Me 911
Roadmap Comments at 41; TruePosition Roadmap Comments at 2, 4, 16; Hawaii E911 Roadmap Comments at 2;
IACP et al, Roadmap Comments at 2; IAFF et al Roadmap Comments at 1; NextNav Roadmap Comments at 9, 25.

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the parties to the Roadmap offer a vigorous defense of its vertical location proposals.283 For example,
Verizon submits that “Roadmap opponents that support the NPRM’s proposed vertical location rules …
disregard critical facts that would limit the availability of barometric pressure sensor-based solutions like
NextNav’s and Polaris Wireless’s to consumers in even the best of circumstances,” as well as “vendors’
dependence on spectrum licenses; their ability and willingness to deploy their solution throughout its
licensed area; and a PSAP’s need to update its own system and equipment to handle the vertical
information.”284 NENA argues that the Roadmap adequately addresses vertical location and does not
foreclose the possibility of the four nationwide CMRS providers providing a comprehensive vertical
location accuracy solution independent from dispatchable location.285 Also, CCA supports a requirement
for non-nationwide providers operating in the top 25 to 50 CMAs “to count uncompensated barometric
pressure data towards meeting additional [z-axis] requirements” following the 36 month assessment of
dispatchable location solutions.286 Several other parties offer their support for the Roadmap’s proposals
for vertical location, including two public safety commenters.287 iPosi suggests a compromise that there
be a vertical location accuracy “target” of 10 meters within two years of the adoption of rules.288 Further
still, several commenters raise concerns that the Addendum fails to offer specific benchmarks for vertical
location.289 Polaris Wireless believes that CMRS providers are restricting indoor solutions to just a
fraction of their networks and questions the impact on communities, including two-thirds of state capitols,
that are not included within the top 50 CMAs.290 TruePosition argues that the Addendum proposes to use
“an alternative z-axis solution, but one that is far inferior and much later in availability than what the FCC
has proposed.”291
111.
We also sought comment in the Third Further Notice on whether PSAPs are ready to
accept z-axis information today, and if not, how long it will take for a sufficient number of PSAPs to
develop this capability so that it would be reasonable to impose a z-axis requirement on CMRS
providers.292 Some commenters argue that PSAPs could receive and process vertical location information
283

AT&T Roadmap Comments at 9; CTIA Roadmap Comments at 13 and Roadmap Reply Comments at 9-10, 19;
Sprint Roadmap Comments at Roadmap Reply Comments at 13; T-Mobile Roadmap Comments at 12 and Roadmap
Reply Comments at 5; Verizon Wireless Roadmap Comments at 3 and Roadmap Reply Comments at 22-24.
284

Verizon Roadmap Reply Comments at 23-24.

285

NENA Roadmap Comments at 4.

286

CCA Jan. 23, 2015 Ex Parte at 5, citing Parallel Path at Section 6; Roadmap at Section 6.

287

Qualcomm Roadmap Comments at 8-10; TCS Roadmap Comments at 1, 5; Motorola Roadmap Comments at 2;
DEMSF Roadmap Comments at 2; National Fraternal Order of Police Roadmap Comments at 1.
288

iPosi Roadmap Comments at 4.

289

See, e.g., NextNav January 22 Ex Parte at 7 (arguing that the Addendum does not specify any level of accuracy
associated with its Z-axis approach and continues to assert that the carriers will establish their own Z-axis
benchmark based on the results of testing in a test bed based on numerous and subjective requirements that could
result in the carriers dismissing any solution or establishing a vertical benchmark that is so lenient that it provides no
real value to the public or to public safety); IAFF January 23 Ex Parte at 1 (stating that the final rule include a three
meter vertical accuracy requirement within three years because establishing a three year timeline will ensure that
carriers begin to implement new technology today).
290

Polaris Wireless January 22 Ex Parte at 1.

291

TruePosition January 22 Ex Parte at 2. Additionally, TruePosition questions the viability of the carriers’
commitment to provide z-axis capable handsets because “it will be more than a decade before there is significant
penetration of the z-axis capable handsets throughout the U.S., hence, they can make this proposal now knowing that
six years from now they will ask the FCC for a waiver citing “lack of availability” of the devices that would provide
them an alternative means of complying with these horrible guidelines.” Id.
292

Third Further Notice, 29 FCC Rcd at 2405 ¶ 80.

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immediately on existing consoles, even if they have not upgraded to NG911.293 Other commenters argue
that even if vertical location information were available, a majority of PSAPs will not be able to use it
effectively.294 Verizon argues that any implementation deadlines for vertical location information should
be tied to PSAP readiness across large regional areas.295 APCO argues that even if many PSAPs currently
cannot process vertical location information, the Commission should establish vertical location accuracy
requirements and timetables now because PSAPs are unlikely to make the necessary upgrades to their
systems without certainty that CMRS providers will begin delivery of such information by a specified
deadline.296
b.

Discussion

112.
Based on the record, we find that there is a need for vertical location information in
connection with indoor 911 calls, and that adopting clear timelines for providers to deliver vertical
location information is in the public interest. The Amended Roadmap affirms the importance and need
for floor-level location information to be provided to emergency responders. Moreover, the Roadmap,
the Addendum, and additional filings provide a backstop mechanism using both uncompensated
barometric data and a specific z-axis location accuracy metric to obtain vertical location information for
PSAPs as an alternative to dispatchable location. 297 Therefore, while 911 calls that provide dispatchable
location information, as discussed in Section III.B.2 above, will count towards the vertical location
accuracy requirement, the vertical location rules adopted herein are also designed to provide for a
potential alternative to the Road Map parties’ preferred solution.
113.
We find that it is reasonable to establish a z-axis metric standard for vertical accuracy as
an alternative to providing floor-level accuracy by means of dispatchable location. Although some
commenters support immediate adoption of a three-meter standard to provide PSAPs with accurate floorlevel information, we believe that, in light of the substantial dispute in the record about the feasibility of
achieving a z-axis metric on the timetable proposed in the Third Further Notice, additional testing and
standardization are appropriate in order to determine the appropriate accuracy benchmark. Although
market availability of devices with barometric devices has increased,298 and multiple vendors, including
those who participated in the CSRIC test bed, have continued to develop and test vertical location
technologies,299 challenges remain. We note that vertical location information can be provided at varying
293

See NextNav Comments at 20 (“[t]he vertical location systems of NextNav and other vendors can easily be
integrated into PSAP operations because messaging protocols for vertical information between the handset, the
carrier network, and the PSAPs are largely in place already.”); NENA Comments at 21 (stating that PSAPs have
been anticipating vertical location, and showing a sample PSAP call-taker screen which includes an optional field
for vertical information). See also Letter from Mary L. Brown, Senior Director, Government Affairs, Cisco
Systems, Inc., and Timothy Lorello, SVP, Chief Marketing Officer, TeleCommunication Systems, Inc., to Marlene
Dortch, Secretary, Federal Communications Commission (dated Oct. 16, 2014), at 2 (PSAPs “with advanced 911
capability could take advantage of its floor map function, which would enable them to better utilize vertical location
information.”)(Cisco/TCS Sept. 12, 2014 ex parte).
294

AT&T Comments at 17; CCA Reply at 7; Sprint Comments at 7; Sprint Reply at 14-15; T-Mobile Comments at
10; Motorola Comments at 15; TIA Comments at 8; Qualcomm Comments at 16.
295

Verizon Comments at 26-27.

296

APCO Comments at 6 and Reply Comments at 3.

297

Addendum at 3 (“the revised deployment commitments also assure a quantifiable Z-axis backstop if a carrier has
not met the dispatchable location benchmark by year 6 in any of the most populous 50 CMAs”).
298

See, e.g., Samenow, Jason, “Slow clap: New iPhone6 has a barometer,” WASHINGTON POST (Sept. 9, 2014),
available at http://www.washingtonpost.com/blogs/capital-weather-gang/wp/2014/09/09/slow-clap-new-iphone6has-a-barometer/ (last visited Jan. 21, 2015).
299

For example, NextNav has continued to refine its Metropolitan Beacon System, which uses “readily-available
barometers combined with real-time reference data provided by NextNav’s beacon network to enable the accurate
(continued….)

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levels of accuracy. For example, uncalibrated barometric pressure data provides some idea of the vertical
height of a device, but would become more accurate with calibration. Even more accurate than calibrated
barometric data would be floor-level information included as part of the programmed dispatchable
location of a fixed beacon or Wi-Fi access point, which could be validated as the proper location by a
barometric pressure sensor on the phone.300 We recognize the challenges with standardization and
achieving sufficient handset penetration to be able to implement a calibrated barometric pressure-based
solution within three years, as proposed in the Third Further Notice. We find that at present, vertical
technologies are not as tested nor widely deployed as horizontal ones, which justifies applying tailored
implementation timeframes for achieving indoor location accuracy in the two different dimensions, as
reflected in the Addendum proposals and the rules we adopt here.301 We conclude that more than three
years is likely to be needed for industry to deploy infrastructure, to change out handset models, and to
configure networks and location systems to incorporate vertical location information.
114.
Therefore, we adopt rules that (1) require the provision of uncompensated barometric
pressure readings to PSAPs from capable devices within three years of the Effective Date, and (2) require
CMRS providers to meet a specific z-axis metric and deploy such technology in major CMAs beginning
six years from the Effective Date.
115.
Uncompensated Barometric Data. Within three years of the Effective Date, all CMRS
providers must provide uncompensated barometric data to PSAPs from any handset that has the capability
of delivering barometric sensor data. This codifies the commitment that CMRS providers have made in
the Roadmap and Parallel Path to provide such data.302 The record indicates that handsets with barometric
sensors are already widely available and we expect the total number of handsets with this capability to
increase over the next three years. Moreover, while some commenters assert that uncompensated
barometric data is not reliable,303 NENA notes that uncompensated barometric pressure data would be
useful to first responders searching for a 911 caller within a building, because once in the building, the
first responders could compare barometric readings from their own devices to the barometric readings
from the caller’s handset in the same building, eliminating the need for compensated data.304
(Continued from previous page)
computation of altitude.” NextNav Comments at 19. See also Letter from Bruce Olcott, Counsel, NextNav LLC, to
Marlene H. Dortch, Secretary, FCC (dated Dec. 9, 2014) at 2 (describing a demonstration of its vertical technology
to Commission staff). Polaris Wireless likewise demonstrated its vertical location capabilities in an ex parte
meeting with Commission staff, indicating that its technology would be a viable path to vertical location accuracy
within the proposed timeframe. See Letter from Michelle C. Farquhar, Counsel, Polaris Wireless, to Marlene Dortch,
Secretary, Federal Communications Commission (Sept. 26, 2014), Attachment at 15 (Polaris Wireless Sept. 26 ex
parte). Polaris Wireless uses 3D radio prediction maps based on RF signatures found in multiple sources of
information, including Wi-Fi access points and small cell nodes, with 3D RF pattern matching location algorithms to
provide an indoor location estimate of a device. Polaris Wireless Comments at 5-6. iPosi uses advanced signal
processing to extract weak indoor GPS and GNSS satellite signals, and then determines a device’s location based on
its client and network servers, and submits that its solution “has demonstrated vertical GNSS/GPS accuracy error
levels … less than three meters.” iPosi Comments at 1, 5.
300

This would enable the phone to distinguish between two Wi-Fi access points that it may “see,” but which may be
on different floor levels.
301

See, e.g., Motorola Mobility Roadmap Comments at 2 (The Roadmap “correctly articulates the need for separate
work streams on implementation solutions for providing a dispatchable location, improvement of horizontal location
information, and development of basic standards for delivery and use of vertical location information.”).
302

Roadmap at Section 5(c); Parallel Path at Section 4(a).

303

Motorola Mobility Reply Comments at 12-14.

304

NENA Comments at 23 (“[a] responder entering a building with only uncalibrated barometry data available could
still locate the correct floor, provided she had available her own barometer. In a simplified sense, responders could
be instructed to ‘look at the barometer and go up until the numbers match.’ This is admittedly a cumbersome
(continued….)

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Uncompensated barometric data also serves as a readily available data point for calls for which
dispatchable location is not available or a z-axis metric solution has not yet been deployed. Nevertheless,
we do not require CMRS providers to begin delivery of uncompensated barometric data immediately.
Although barometric sensors are available in handsets today, CMRS providers, service providers, and
PSAPs alike will need time to incorporate and configure this new data into their systems. We believe that
a three-year deadline provides sufficient time for development of these capabilities. We also recognize
that non-nationwide CMRS providers seek an additional year before being required to provide this
information, but we find that is not necessary. The rule we adopt today applies only to devices with
barometric sensors and delivery capability that the CMRS provider may choose to offer to consumers and
does not require any CMRS provider to make such devices available to subscribers.
116.
Z-Axis Metric. Within three years of the Effective Date, we require nationwide CMRS
providers to use an independently administered and transparent test bed process to develop a proposed zaxis accuracy metric and to submit the proposed metric to the Commission for approval. We believe the
testing, standard setting process and formal showing to the Commission will ensure industry-wide
cooperation to determine the most feasible z-axis metric that can be established within the timeframes
adopted today. We intend that the proposal will be placed out for public comment. Any such z-axis
metric approved, and, if adopted by the Commission, will serve as an alternate six- and eight-year
benchmark for vertical location should dispatchable location not be utilized by a CMRS provider for
compliance.
117.
Within six years of the Effective Date, nationwide CMRS providers will be required to
either (1) meet the dispatchable location benchmark described herein; or (2) deploy z-axis technology that
achieves any such Commission-approved z-axis metric in each of the top 25 CMAs and covers 80 percent
of the population in each of those CMAs. Within eight years of the Effective Date, nationwide CMRS
providers will be required to either meet the dispatchable location benchmark described herein, or (2)
deploy z-axis technology that achieves any such Commission approved z-axis metric in the top 50 CMAs
and covers 80 percent of the population in each of those CMAs. The same requirements will apply to
non-nationwide CMRS providers serving the top 25 and top 50 CMAs, except that the six- and eight-year
benchmarks will be extended to 7 and 9 years, respectively. Taken together, and based on the progress
identified to date in concert with the rapid rollout of VoLTE phones, it is our predictive judgment that the
extended six- and eight-year timetable for compliance will be more than adequate for nationwide CMRS
providers, as will the extension by one year each for non-nationwide CMRS providers. Our solution
recognizes the substantial but still incomplete technological progress achieved to date and makes the most
effective use of the Amended Roadmap to work toward a backstop solution in the event the failure of a
dispatchable location approach requires it. It also provides reasonable and appropriate incentives for
CMRS providers to ensure the success of their preferred dispatchable location solution and/or a z-axis
metric alternative.
118.
To further ensure that nationwide CMRS providers are on track to provide a proposed zaxis metric for vertical location at three years, we require that they report to the Commission on their
progress towards testing and developing the proposed metric 18 months from the Effective Date. As part
of the 18-month report, at a minimum, CMRS providers must show how they are testing and developing
z-axis solutions and, consistent with their commitment in the Roadmap,305 demonstrate their efforts to
promote the development and approval of standards to support such solutions. We find that the
requirements and adjusted timeframe we adopt today sufficiently address concerns raised by commenters
with regard to technical feasibility, the time necessary for standards development and deployment of new
technologies, and for integration into PSAP systems and procedures.
(Continued from previous page)
process, but NENA is convinced that it is preferable to the lack of any z-axis data today.”). See also NextNav Reply
Comments at 22; IAFF Comments at 3; IACP and NSA Comments at 2.
305

Roadmap at Section 5(a).

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119.
We also find that the current limitations on the ability of PSAPs to use vertical location
information fail to justify delaying adoption of vertical location accuracy requirements beyond the
timeframes adopted in this order. Indeed, public safety commenters argue that even imperfect vertical
location information would be of use to them.306 We believe the provision of uncompensated barometric
pressure data mitigates that problem in the near term. We also agree with APCO that PSAPs are unlikely
to invest in upgrading their equipment and software unless there are requirements in place to ensure that
the information will soon be available to them. While PSAPs may not be able to utilize vertical location
information immediately, the six-year timeframe associated with this requirement provides ample time for
PSAPs to develop such capability.
120.
Finally, although we adopt a nationwide requirement for all CMRS providers to provide
uncompensated barometric pressure data to PSAPs from any capable handset, we decline to apply a
similar requirement at this time to the deployment of z-axis metric solution. We anticipate that the
provision of dispatchable location obviates the need for nationwide deployment within the timeframes
adopted today. Again, we find that the requirements and adjusted timeframe adopted herein sufficiently
take into account concerns raised by commenters with regard to technical feasibility, the time necessary
for standards development and deployment of new technologies, and for integration into PSAP systems
and procedures even in rural areas.
5.

Implementation Issues
a.

Compliance Testing for Indoor Location Accuracy Requirements

121.
Background. In the Third Further Notice, we found that CSRIC WG3 demonstrated the
feasibility of establishing a test bed for purposes of evaluating the accuracy of different indoor location
technologies across various indoor environments.307 Accordingly, we found that a test bed approach,
representative of real-life call scenarios, would be the most practical and cost-effective method for testing
compliance with indoor location accuracy requirements. We proposed two approaches based on
representative real-life call scenarios, one centered on participation in an independently administered test
bed program and the second centered on alternative but equivalent testing methodologies. Under either
proposal, certification would provide a “safe harbor” in which CMRS providers, upon certification that a
technology meets our location requirements and has been deployed in a manner consistent with the test
bed parameters, would be presumed to comply with the Commission’s rules, without the need for the
provider to conduct indoor testing in all locations where the technology is actually deployed.308
122.
Commenters generally support the establishment of a test bed for technology vendors and
CMRS providers to demonstrate indoor location accuracy.309 CMRS providers urge establishment of an
independent test bed, and argued that requiring testing in all markets served by CMRS providers could
delay or impede identifying candidate technologies.310 A number of commenters agree that testing in
representative environments that include rural, suburban, urban and dense urban morphologies provides
an acceptable proxy to conducting market-by-market testing.311 Other commenters argue that live 911

306

See e.g., IAFF Roadmap Comments at 2; NENA Comments at 23.

307

Third Further Notice, 29 FCC Rcd at 2407 ¶ 84.

308

Id.

309

APCO Comments at 7; NASNA Comments at 4; Texas 911 Reply Comments at 15; ATIS Reply Comments at 3;
NextNav Comments at 47.
310

AT&T Comments at 28; CTIA Comments at 16 and Reply Comments at 15-16; Sprint Comments at 12; Verizon
Comments at 22-23; T-Mobile Reply Comments at 7.
311

ATIS Reply Comments at 4-5; NextNav Comment at 52; Qualcomm Comments at 19; TCS Comments at 10;
TruePosition Comments at 18; RWA Comments at 5.

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call data should be compared to any certified results achieved in a test bed environment in order for
PSAPs to determine if service providers are meeting compliance requirements in their area.312
123.
In June 2014, CSRIC IV WG1 released its Final Report on specifications for an indoor
location accuracy test bed that included recommendations for methodology, management framework,
funding, and logistical processes.313 CSRIC IV recommended adopting the CSRIC III test methodology
and establishing permanent regional test bed facilities in six representative cities distributed across the
U.S.314 While CSRIC IV focused on development of the test bed for experimental testing, it did not
extend the scope of its recommendations to the potential use of test bed data to demonstrate compliance
with location accuracy benchmarks.315
124.
The Roadmap provides for establishment of a test bed modeled on the CSRIC III
recommendations. The Roadmap test bed would facilitate testing of both indoor and outdoor 911 location
technologies and would include both experimental testing and compliance components.316 The Roadmap
signatories pledge to establish the test bed by November 2015 and to operate it in a technology neutral
manner in order to test and validate existing and future location technologies, including “OTDOA/AGNSS, dispatchable location solutions, and other possible location solutions (including but not limited to
technologies described in PS Docket No. 07-114).”317 The Roadmap also provides for use of the test bed
data to demonstrate CMRS provider compliance with location accuracy performance benchmarks.
However, rather that measuring compliance based on test data alone, the Roadmap would measure
compliance based on actual use of the tested technologies in live 911 calls.318

312

BRETSA Comments at 19-21; NASNA Comments at 8.

313

CSRIC IV Working Group 1, Final Report: Specification for Indoor Location Accuracy Test Bed, June 2014,
available at http://transition.fcc.gov/pshs/advisory/csric4/CSRIC_IV_WG-1_Subgroup3_061814.pdf (last visited
Dec. 30, 2014) (CSRIC Test Bed Final Report).
314

CSRIC Test Bed Final Report at 3. According to the signatories, the test bed will be “consistent with the
elements recommended by the [CSRIC] III Working Group and with the work undertaken by the Emergency
Services Interconnection Forum (ESIF) established by ATIS.” Further, although the test bed will be open for use by
any technology vendor, whether or not the technology is standardized or available commercially, the signatories
state that only testing of solutions “based on industry standards and commercial configurations will be relied on to
verify performance expectations to an E911 location benchmark.” The signatories agree “to work together to
develop an appropriate funding framework for the test bed that includes funding support from carriers and affected
E911 location vendors, and also to investigate the potential for obtaining other sources of funding (e.g., government
grants).” See ATIS Reply Comments at 4 & n.6 (referring to the Feb. 7, 2014 ATIS ESIF Emergency Services &
Methodologies (ESM) Subcommittee document concerning the selection of the six cites). See also
http://www.atis.org/legal/Docs/ESIF%20DOCS/ESIF_Letter_DeLorenzo_Feb2014.pdf. (last visited Jan. 29, 2015)
(containing ATIS Document, “Considerations in Selecting Indoor Test Regions,” for testing of indoor location
technologies).
315

CSRIC Test Bed Final Report at 8.

316

Roadmap at Section 1(a)(iii).

317

Id. at Section 1(a). According to the Roadmap, the test bed will be managed by a non-governmental entity, such
as ATIS, and “operated in an open, transparent, and competitively neutral manner, as to technologies, carriers and
location solution vendors” to enable them to “demonstrate vendor performance of E911 location solutions and to
characterize performance of E911 location technologies, including OTDOA/A-GNSS, in order to establish
appropriate E911 location benchmarks.” Id. at Section 1(a)(ii). See also AT&T Roadmap Comments at 8 (stating
that cost efficiencies of the Roadmap are derived from allowing wireless providers to choose from among proven
wireless location-accuracy solutions that have been appropriately tested in the test bed under real-world conditions
“in an open, transparent, and competitively neutral manner” (emphasis in original)).
318

Id. at Section 4(b).

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125.
Most commenters approve of the Roadmap’s commitment to establish a test bed
consistent with CSRIC III’s recommendations.319 However, some commenters question whether test bed
performance data can provide sufficient certainty that the tested technologies will perform as well in the
real world environment as in the test environment.320 Other commenters contend that the Roadmap test
bed proposal has limited value because the Roadmap does not contain sufficiently rigorous requirements
to deploy successfully tested technologies.321 Some commenters contend that the Roadmap test bed
proposal leaves out key performance indicators which serve to demonstrate whether a technology meets
Commission benchmarks.322 Finally, rural CMRS providers express concern that due to the limited
number of test bed locations, there will be no test bed facilities in their service areas and they therefore
may be forced to conduct more expensive individualized testing.323
126.
Discussion. The record strongly supports establishing a test bed regime modeled on the
CSRIC III recommendations that CMRS providers can use to test and verify that location technologies are
capable of meeting our indoor accuracy requirements. CSRIC III demonstrated the feasibility of
establishing a test bed and methodology for purposes of evaluating the accuracy of different indoor
location technologies across various indoor environments. CSRIC IV WG1 further validated this
approach, formally recommending that the Commission adopt CSRIC III’s methodologies and outlining
additional recommendations regarding the management, funding and logistical aspects of operating a test
bed. The Roadmap builds on these recommendations with its commitment to establish a test bed regime
consistent with the CSRIC principles.
127.
Test Bed Requirements. While the Roadmap establishes an appropriate framework for
development of a test bed regime, we believe that the test bed must conform to certain minimal
requirements in order for test results derived from the test bed to be considered valid for compliance
purposes. Specifically, the test bed must (1) include testing in representative indoor environments; (2)
test for certain performance attributes (known as key performance indicators, or KPIs); and (3) require
CMRS providers to show that the indoor location technology used for purposes of its compliance testing
is the same technology (or technologies) that it is deploying in its network, and is being tested as it will
actually be deployed in the network.
128.
Representative Environment. The test bed shall reflect a representative sampling of the
different real world environments in which CMRS providers will be required to deliver indoor location
information. Therefore, each test bed should include dense urban, urban, suburban and rural
morphologies, as defined by the ATIS-0500013 standard.324 We believe these morphologies are
sufficiently representative and inclusive of the variety of indoor environments in which wireless 911 calls
are made.
319

See, e.g., iCERT Roadmap Comments at 2; Motorola Comments at 4; NASNA Comments at 2-5; Qualcomm
Comments at 7-8.
320

BRETSA Roadmap Comments at 8-9 (testing of beacon-based technologies or other locally deployed systems
can only demonstrate that the technology is capable of meeting certain accuracy standards in the test bed but the
accuracy in non-test bed markets is not likely to be equivalent to test bed performance). See also Texas 911 Entities
Roadmap Comments at 15-16, iPosi Roadmap Comments at 4 (recommending establishing a multi-city test bed
using in-building sites offering public access such as hotels, train stations, and temporary office rental services).
321

NextNav Roadmap Comments at 29 (also arguing that the carriers “appear to be offering to finally test their
deployed OTDOA location capability in a single test bed market, measure the expected modest improvement over
AFLT, and declare a new benchmark to be whatever accuracy OTDOA is capable of providing”).
322

See, e.g., NASNA Roadmap Comments at 2 (arguing that the Roadmap test bed commitment only includes
testing location accuracy but should also include TTFF and yield as key performance indicators consistent with the
Commission’s proposed approach in the Third Further Notice).
323

CCA Roadmap Comments at 6.

324

CSRIC LBS Report at 57; Indoor Location Test Bed Report at 12.

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129.
Performance Attributes. Testing of any technology in the test bed must include testing of
the following key performance attributes: location accuracy, latency (Time to First Fix), and reliability
(yield). For purposes of determining compliance with location accuracy and latency requirements, testing
should at a minimum follow the CSRIC III test bed methodology.325 With respect to yield, the CSRIC
test bed defined the “yield of each technology … as the [percentage] of calls with delivered location to
overall ‘call attempts’ at each test point.”326 As with indoor calls in real-world scenarios, however, not all
test call attempts will actually connect with the testing network established for the test bed and therefore
constitute “completed” calls. In view of the difficulties that CSRIC III encountered in testing indoor
locations, we adopt the following definition of yield for testing purposes: the yield percentage shall be
based on the number of test calls that deliver a location in compliance with any applicable indoor location
accuracy requirements, compared to the total number of calls that successfully connect to the testing
network. CMRS providers may exclude test calls that are dropped or otherwise disconnected in 10
seconds or less from calculation of the yield percentage (both the denominator and numerator). We
require CMRS providers to measure yield separately for each individual indoor location morphology
(dense urban, urban, suburban, and rural) in the test bed, and based upon the specific type of location
technology that the provider intends to deploy in real-world areas represented by that particular
morphology.
130.
Testing to Emulate Actual Network Deployment. CMRS providers must show both (1)
that any indoor location technology used in compliance testing is the same technology that will be
deployed in its network, and (2) that the technology is being tested as it will actually be deployed in the
CMRS provider’s network. In order to count use of any tested technology towards any of our accuracy
thresholds, CMRS providers must certify that they have deployed the technology throughout their
networks in the same manner as tested. CMRS providers must also update their certifications whenever
they introduce a new technology into their networks or otherwise modify their technology use in such a
manner that previous compliance testing in the test bed would no longer be representative of the
technology’s current use.
131.
Confidentiality of Test Results. In the Third Further Notice, we noted that under the
CSRIC III test bed regime, all parties agreed that raw test results would be made available only to the
vendors whose technology was to be tested, to the participating CMRS providers, and to the third-party
testing house.327 In order to protect vendors’ proprietary information, only summary data was made
available to all other parties.328 At this time, we will not require CMRS providers to make public the
details of test results for technologies that have been certified by the independent test bed administrator.
We believe the test administrators’ certification is sufficient notification that a technology meets our key
performance indicators.

325

Specifically, for location accuracy, the test bed must compute the error in estimating the location of the device
under test by comparing each vendor’s reported horizontal position to the surveyed ground truth position of the test
location (determined through a precise land survey). Each test call (or equivalent) must be independent from prior
calls and accuracy will be based on the first location delivered by the vendor after he call is initiated. With regard to
latency, TTFF must be calculated by establishing the precise time for call initiation (or an equivalent initiation event
if the vendor’s test configuration does not support the placement of an emulated emergency test call). Specifically,
latency must be measured from the time the user presses SEND after dialing 911, to the time the location fix appears
at the location information center.
326

Indoor Location Test Bed Report at 14.

327

Id. at 12.

328

See Presentation by CSRIC WG3, Indoor Location Accuracy – Test Bed Framework (Sept. 12, 2012), at 6,
available at http://transition.fcc.gov/pshs/advisory/csric3/3-WG%20Presentation%209-12-12.pdf (last visited Dec.
19, 2014) (noting agreement reached among test bed participants that CMRS providers could only view raw results
if they signed a nondisclosure agreement). See also Indoor Location Test Bed Report at 12.

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132.
With regard to non-nationwide CMRS providers that cannot participate directly in the test
bed, we find that the test bed administrator shall make available to them the same data available to
participating CMRS providers and under the same confidentiality requirements established by the test bed
administrator. This will enable such CMRS providers to determine whether to deploy that technology in
their own networks. Enabling non-nationwide CMRS providers to access test data under the same
confidentiality conditions as participating CMRS providers obviates the need for individual testing by
those providers.
b.

Use of Live 911 Call Data to Verify Compliance

133.
Background. The Roadmap submitted by the four nationwide providers commits to
collecting and reporting live 911 call data in six test cities recommended by ATIS ESIF on a quarterly
basis to NENA and APCO, including data on the “positioning source method” used to deliver each
wireless 911 call.329
134.
In response to the Roadmap, multiple commenters support the collection and reporting of
330
live call data. For example, Cisco submits that “[l]ive call data is an important step and necessitated by
the commitments made in the Roadmap.”331 NASNA contends that CMRS providers should report live
call data to NASNA and the Commission as well, consistent with existing outdoor location accuracy
reporting requirements.332 The Lackawanna County, PA District Attorney argues that this information
should also be made available to law enforcement upon request.333 Small and rural CMRS providers,
however, argue that live 911 call tracking and reporting would be overly burdensome for them.334 For
example, though it supports the use of live call data, CCA notes that its members “may not hold licenses
for spectrum or otherwise operate in any of the six ATIS ESIF regions, much less the single location
ultimately selected for the test bed,” and therefore, the Commission should improve upon the proposal
included in the Roadmap to accommodate smaller CMRS providers.335 In its Parallel Path proposal, CCA
suggests that non-nationwide providers would also collect and report data if a given provider operates in
one of the six regions, and if it operates in more than one it would collect and report only in half of the
regions (as selected by the CMRS provider) in order to minimize burdens.336 For those providers not
operating in any of the six regions, CCA suggests that a provider would collect and report data based on
the largest county within its footprint, and in where serving more than one of the ATIS ESIF
morphologies it would also include a sufficient number of representative counties to cover each

329

Roadmap at Section 4. The Roadmap states that data on the “‘positioning source method’ would include
dispatchable location methods as well as positioning based on latitude/longitude (e.g., A-GPS, GLONASS,
OTDOA, AFLT, RTT, Cell ID, or a hybrid of any of the listed or future technologies).” Id. at Section 4(a)(i).
330

CCA Roadmap Comments at 3; NASNA Roadmap Comments at 2, 5; TCS Roadmap Comments at 5-6; PCIA
Roadmap Reply Comments at 4; Mobile Future Roadmap Reply Comments at 7; NextNav Roadmap Comments at
21 (stating that following successful tests in a test bed, a CMRS network’s performance should be evaluated by
looking at live call data).
331

Cisco Roadmap Comments at 3.

332

NASNA Roadmap Comments at 5 (referencing 47 C.F.R. § 20.18(h)(1)(vi) and (h)(2)(iii)).

333

Lackawanna County PA District Attorney Roadmap Comments at 1.

334

CCA Roadmap Comments at 3; RWA Roadmap Reply Comments at 6. See also NTCA Roadmap Reply
Comments at 5 (highlighting that requesting a waiver of the Commission’s rule can be a burdensome process for
small and rural CMRS providers).
335

CCA Roadmap Comments at 6-7.

336

Parallel Path at Section (5)(a)(ii).

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morphology.337 They suggest that such reports would be provided within 60 days following each of the
two-, three-, five-, and six-year benchmarks.338
135.
Discussion. We adopt a modified version of the Roadmap’s commitment to quarterly
reporting of aggregate live 911 call data for nationwide providers.339 We require the nationwide CMRS
providers, subject to certain confidentiality protections,340 to aggregate live 911 call data on a quarterly
basis and report that data to APCO, NENA, the National Association of State 911 Administrators
(NASNA), and the Commission, with the first report due 18 months after the Effective Date of this
requirement. CMRS providers must retain this data for two years. The Commission will not publish
provider-specific data, but may publish aggregate data on its website.341
136.
We further adopt the Parallel Path’s proposal for non-nationwide CMRS providers. We
modify, however, the frequency of reporting for non-nationwide providers to every six months, beginning
at 18 months following the Effective Date of the reporting requirement. In this respect, and as herein, we
seek to inform our understanding of z-axis technologies by providing clear, real world data to augment
the record data to date. While this may represent a slight increase in burden for smaller providers, we
find that the clear benefit of this actual data in our future review of z-axis metrics outweighs those
considerations. However, as discussed in Section IV.D, all CMRS providers must retain and will be
required to produce live call data to requesting PSAPs in their service areas as a check on such
certification.
137.
We will use this data as a complement to the test bed in determining compliance. The
performance of positioning source methods, whether based on geodetic coordinate information or
dispatchable location, will first be determined based on performance of the technology in the test bed.
CMRS providers must then certify to the Commission that they have deployed the tested technology
throughout their service areas in a manner that is consistent with the deployment of that technology in the
test bed,342 such that the test bed results can be reasonably relied upon as representative of the
technology’s real-word performance. Each CMRS provider must make this certification on or before our
337

Id.

338

Id.

339

Roadmap at Section 4(b). While the Roadmap indicates these test regions were selected to represent common
indoor use cases, the regions include a range of morphologies and should also be representative of the areas where
outdoor wireless calls to 911 are placed. The Roadmap commits to obtaining data for “all live wireless 9-1-1 calls”
in these regions, regardless of whether the call is placed from indoors or outdoors; we emphasize that for purposes
of this reporting requirement, we expect the live call data to reflect the quality of both indoor and outdoor call
location information.
340

In order for this data to serve as a reasonable measure of the efficacy of indoor location solutions, it will be
necessary for the Roadmap parties to make information available on the system deployment and the live 911 call
data, such that smaller CMRS providers who do not cover territory in one of the six ATIS ESIF test cities could
certify whether their deployments is consistent with one of the four nationwide providers in the six test cities. As
such, CMRS providers may request confidential treatment of their live 911 call data reports, but the Commission
reserves the right to release aggregate or anonymized data on a limited basis in order to facilitate compliance with its
rules. In addition, nothing in this Order is intended to limit the authority of state and local 911 agencies to publish
911 call data to the extent authorized under state or local law.
341

The Commission will not publish any personally identifiable information, such as 911 callers’ phone numbers or
the locations to which first responders were dispatched. The Commission may, however, publish aggregate
information on CMRS providers’ performance in a given geographic area, or on the percentage of calls using a
particular positioning source method across all CMRS providers. We believe that this information will enable the
Commission to better monitor location accuracy performance as a whole and will serve as a self-evaluation tool for
CMRS providers.
342

For nationwide carriers, this will include the six test regions. For non-nationwide carriers, this will include the
appropriate test region, county or other test area in accordance with the Parallel Path as adopted herein.

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three- and six-year benchmarks, and will need to re-certify when implementing new technology or
otherwise making a significant change to its network, such that previous test bed performance is no longer
representative of the network or technology as now deployed. The certification will establish a
presumption that 911 location performance results derived from live call data from the six ATIS ESIF test
cities are representative of the CMRS provider’s E911 location performance throughout in areas outside
the reporting areas.
138.
In this respect, submission of test and live call data will augment our understanding of
the progress of such technologies as we consider the providers’ proposal for a six-year benchmark when
filed in the future. In order to maximize the utility of such data for those purposes, as well as for
compliance, while balancing the potential burden of such reporting, we require all providers to include the
following in their reports.
139.
First, the live call data will include identification of the positioning source method or
methods used for each call. The test bed performance of each positioning source method will then
determine the degree to which that method can be counted towards the required location accuracy
thresholds each time that positioning source method is used.
140.
Second, to the extent available, live call data for all providers shall delineate based on a
per technology basis accumulated and so identified for: (1) each of the ATIS ESIF morphologies; (2) on a
reasonable community level basis; or (3) by census block. In this respect, we expect that data will
provide a viable, real world evaluation of particular indoor location technologies that will inform our
ability to evaluate the nationwide providers’ six-year bench mark proposal, and to prove out the various
claims in the record as to technical achievability.
141.
Finally, in order to verify compliance based on dispatchable location, we adopt the
Addendum’s proposed calculation regarding reference point “density” within a CMA.343 We require that
nationwide CMRS providers include such calculation for relevant CMAs in their quarterly reporting. We
find that this formulation will be reasonably representative of the capability of a provider to utilize
dispatchable location in a particular CMA.
c.

Enforcement of Location Accuracy Requirements

142.
Background. Under Section 20.18(h) of the Commission’s rules, licensees subject to
Section 20.18(h) must satisfy the existing E911 Phase II requirements at either a county- or PSAP-based
geographic level.344 In the Third Further Notice, we proposed to adopt this same approach to
enforcement for indoor location accuracy requirements, noting that CMRS providers could choose
different technologies to best meet the needs of a given area based on individualized factors like natural
and network topographies.345 We also recognized, however, that a county- or PSAP-based requirement
may be difficult to verify if testing is performed within a more geographically constrained test bed, as
discussed above.346 Ultimately, we proposed that enforcement of our indoor location accuracy
requirements would be measured with actual call data within a PSAP’s jurisdiction,347 but as a
precondition, the PSAP would be required to demonstrate that they have implemented bid/re-bid policies
that are designed to obtain all 911 location information made available to them by CMRS providers

343

Addendum at 3.

344

See 47 C.F.R. §20.18(h).

345

Third Further Notice, 29 FCC Rcd at 2415-16 ¶ 110-11.

346

Id. See also Section III.B.5.a.

347

Id. at 2416 ¶ 111.

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pursuant to our rules.348 We observed that accurate and reliable delivery of E911 location information
depends upon the willingness and readiness of PSAPs and CMRS providers to work together.349
143.
In response, NASNA supports enforcement on a county/PSAP-level basis, and “agrees
with the concept of a CMRS provider being required to demonstrate compliance with the test,” but also
expresses concern that any presumptive compliance demonstrated in the test bed “not hinder or prevent a
state or local jurisdiction from taking effective action to resolve a problem with any carrier that does not
meet the location accuracy requirements.”350 NextNav submits that applying a PSAP-level enforcement
regime to indoor calls “would ensure that compliance testing reflects the actual makeup up in each county
and would ensure the performance fulfills the expectations of the callers in each area,” as well as
“facilitate comparison of county or PSAP level compliance testing with the actual daily operational
results experienced in each county or PSAP service area.”351
144.
On the other hand, several commenters argue that the proposed test bed approach would
obviate the need for a county- or PSAP-level enforcement regime.352 Verizon states that compliance
testing at the county- or PSAP-level “is not feasible without different test bed parameters for each county
or PSAP,” and therefore, enforcement at this level would “defeat the purpose and promised efficiencies of
a test bed in the first place.”353 Sprint submits that the Third Further Notice “does not explain how the
specific morphology associated with a particular county or PSAP will be defined,” and that “[t]here will
be PSAPs and counties that contain multiple different morphologies, which will make it more difficult to
assess overall compliance.”354 Sprint then suggests that “building morphology districts be identified
within PSAP jurisdictions. Within each morphology district, the various building use types and any
exempt spaces within a specific building should be identified.”355 AT&T argues that the number of
jurisdictions and PSAPs creates an “administrative nightmare” and that “the only realistic and reasonable
way to measure compliance would be to establish an independently administered and FCC-sanctioned
test-bed mechanism that accounts for all the morphologies by which conformance to the standards could
be fairly measured for all PSAPs.”356
145.
With respect to whether enforcement should be preconditioned on PSAPs’ use of all
available location data, APCO “understands the Commission’s desire to ensure that PSAPs use rebidding
before filing complaints, but is concerned that the proposed standard is vague as there may be differing
views regarding what constitutes a ‘rebidding policy.’ Moreover, the proposed rebidding condition on
complaints will be irrelevant and unnecessary to the extent that future location technologies do not require
rebidding to meet accuracy requirements.”357

348

Id.

349

Id.

350

NASNA Comments at 7-8

351

NextNav Comments at 52-53.

352

Verizon Comments at 22 and Reply Comments at 16; AT&T Comments at 5, 29-32; CTIA Comments at 16-17;
NASNA Comments at 7-8; NextNav Comments at 55-56; T-Mobile Comments at 20; RWA Comments at 5; see
also TCS Comments at 3, 9 (market-specific testing may impose burden on wireless providers with little
improvement in performance).
353

Verizon Comments at 27.

354

Sprint Comments at 16.

355

Id.

356

AT&T Reply Comments at 7.

357

APCO Comments at 9.

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146.
We also sought comment in the Third Further Notice on whether we should establish a
specialized complaint process as part of our E911 enforcement strategy.358 We proposed that, with the
filing of an informal complaint, PSAPs would have to demonstrate that they have implemented bid/re-bid
policies designed to enable PSAPs to obtain the 911 location information that CMRS providers make
available.359 Some public safety groups support this approach, in hopes of encouraging expeditious
resolution of location accuracy issues,360 but CMRS providers generally oppose such a process. For
example, CTIA submits that “the test bed safe harbor approach will become useless if the FCC entertains
complaints seeking in-building field testing in particular markets. Such a complaint process would
effectively require CMRS providers to test deployments in all markets, which would be inconsistent with
the Commission’s findings that ubiquitous testing is both costly and impractical.”361 Verizon and CCA
argue that “a PSAP that believes it is experiencing degraded performance in its area should first bring its
concerns to the service provider before lodging an informal complaint with the Commission, so that the
provider has an opportunity to work in good faith to timely address it.”362
147.
Discussion. Consistent with our existing E911 requirements, the rules we adopt today
will be enforced by measuring the provider’s performance at the county or PSAP level. In response to
commenters’ arguments that the test bed regime obviates the need for enforcement at a more granular
level, we note that a CMRS provider’s test bed results create only a presumption of compliance with the
location accuracy standards with respect to a particular technology used within the provider’s network. If
that presumption can be rebutted with live call data or other objective measurements showing lack of
compliance with our location accuracy requirements, we must be able to enforce our rules.
148.
We agree with Verizon and CCA, however, that PSAPs should first engage with relevant
service providers to see whether an issue could be resolved without Commission involvement. As
discussed above, we require CMRS providers to collect live call data to the extent of their coverage
footprint in the six ATIS ESIF test cities, for purposes of compliance and quarterly reporting to NENA,
APCO, NASNA, and the Commission.363 In addition, we require CMRS providers to collect live 911 call
data for its entire service area to make available to PSAPs upon request.364 By enabling PSAPs to obtain
meaningful data regarding the quality of location fixes delivered with 911 calls, we intend to facilitate the
ability of PSAPs and CMRS providers to troubleshoot and identify issues regarding E911 location
accuracy. Accordingly, before a PSAP may seek an enforcement action through the Commission, PSAPs
should first attempt to resolve the issue with the CMRS provider. We also require that, before seeking
enforcement action, a PSAP must show that (1) it has implemented policies (whether through re-bidding
or other mechanisms) to retrieve all location information being made available by the CMRS provider in
conjunction with 911 calls365 and (2) provide the CMRS provider with [30] days written notice of the
358

Third Further Notice, 29 FCC Rcd at 2430 ¶ 171.

359

Id.

360

APCO Comments at 8; NASNA Comments at 8.

361

CTIA Comments at 18.

362

Verizon Comments at 33; CCA Reply Comments at 17.

363

See supra Section III.B.5.b. CMRS providers that do not provide service in any of the six cities may satisfy this
requirement by certifying in their 36- and 72-month certifications that (1) they have deployed technology throughout
their network consistent with a technology deployment that was certified in the test bed, and (2) that their network
does not cover any territory in any of the six test cities. If a CMRS provider expands its network coverage into one
of the six test cities, it must re-certify the compliance of its deployed technology as well as begin reporting live call
data from that portion of its network to NENA, APCO, NASNA, and the Commission.
364

See infra Section IV.D.

365

This includes, but is not limited to, evidence of a PSAP’s reasonable bidding and rebidding activity throughout
the duration of a 911 call.

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PSAP’s intention to seek Commission enforcement, which shall include all of the documentation upon
which the PSAP intends to rely in demonstrating the CMRS provider’s noncompliance to the
Commission. We believe these conditions will serve to foster cooperation and transparency among the
parties.
149.
PSAPs may also file an informal complaint pursuant to the Commission’s existing
complaint procedures.366 We find that our existing informal complaint procedures should be sufficient to
address PSAP concerns. At the same time, however, given the critical importance of addressing any
concerns regarding the delivery of location information in connection with wireless 911 calls, we
encourage parties submitting informal complaints to provide copies to PSHSB staff directly. In this
regard, we seek to ensure that PSAPs and other stakeholders receive immediate consideration in the event
there is an issue regarding E911 location accuracy.
150.
Finally, we emphasize that CMRS providers and other stakeholders, such as SSPs, share
responsibility to ensure the end-to-end transmittal of wireless 911 call location information to PSAPs, in
compliance with our E911 location accuracy requirements. All stakeholders must collaborate to ensure
the delivery of accurate location information, as well as the delivery of associated data to help PSAPs
interpret location information, such as confidence and uncertainty data. PSAP call-takers must be able to
quickly evaluate, trust, and act on such information to dispatch first responders to the correct location. In
the event any party in the end-to-end delivery of location information fails to satisfy its obligation under
our E911 location accuracy requirements, we reserve the right to pursue enforcement action or take other
measures as appropriate.
d.

Liability Protection

151.
Background. In general, liability protection for provision of 911 service is governed by
state law and has traditionally been applied only to local exchange carriers (LECs). However, Congress
has expanded the scope of state liability protection by requiring states to provide parity in the degree of
protection provided to traditional and non-traditional 911 providers, and more recently, to providers of
NG911 service.367
152.
We understand commenters’ arguments that liability protection is necessary in order for
CMRS providers to fully comply with location accuracy requirements. In the Third Further Notice, we
noted that the recent NET 911 Act and Next Generation 911 Advancement Act significantly expanded the
scope of available 911 liability protection, and that we believe this provides sufficient liability protection
for CMRS providers.368 Nevertheless, we sought comment on whether there are additional steps the
366

See 47 U.S.C. §§ 1.711-1.736 et seq. CMRS providers will have 30 days to respond to the Commission
following notification of any such complaint.
367

In 2008, Congress enacted the New and Emerging Technologies 911 Improvement Act (NET 911 Act), which
provides that a “wireless carrier, IP-enabled voice service provider, or other emergency communications provider …
shall have” the same liability protection as a local exchange provider under federal and state law. 47 U.S.C. § 615a.
In February 2012, Congress further extended state liability protection to providers of NG911 service in the Next
Generation 9-1-1 Advancement Act of 2012, enacted as subtitle E of the Middle Class Tax Relief and Job Creation
Act of 2012, Pub. L. No. 112-96, 126 Stat 156, 237-45. The Next Generation 9-1-1 Advancement Act of 2012
provides that “[a] provider or user of Next Generation 9-1-1 services…shall have immunity and protection from
liability under Federal and State law [to the extent provided under section 4 of the Wireless Communications and
Public Safety Act of 1999],” with respect to “the release of subscriber information related to emergency calls or
emergency services,” “the use or provision of 9-1-1 services, E9-1-1 services, or Next Generation 9-1-1 services,”
and “other matters related to 9-1-1 services, E9-1-1 services, or Next Generation 9-1-1 services.” 47 U.S.C. § 1472.
In addition, Section 6503 of the Act amends the National Telecommunications and Information Administration
Organization Act to define “emergency call” as “any real-time communication with a public safety answering point
or other emergency management or response agency,” including communication “through voice, text, or video and
related data.” 47 U.S.C. § 942(e)(4).
368

Third Further Notice, 29 FCC Rcd at 2416 ¶ 113.

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Commission could or should take – consistent with our regulatory authority – to provide additional
liability protection to CMRS providers. We also sought comment on liability concerns that may be
raised in conjunction with the possible adverse effect on indoor location accuracy from signal boosters, as
CMRS providers commenting in the Signal Booster Report and Order were concerned about liability for
location accuracy when those capabilities are affected by signal booster use.369
153.
The record in response to the Third Further Notice contains little substantive comment
with regard to liability protection issues. CTIA calls for a nationwide liability protection standard for
entities providing 911 service.370 BRETSA emphasizes that liability protection for 911 services should
be a matter of state – not federal – law.371 Qualcomm states that “[t]o the extent the Commission seeks to
encourage CMRS providers to incorporate potentially inaccurate Wi-Fi location information into the
location determinations calculus, clarification of liability for such unreliable data sources will be
needed.”372 No commenter discussed how liability protection would be impacted by the use of signal
boosters.
154.
Discussion. In our Text-to-911 Order, we construed the Next Generation 911
Advancement Act’s definition of “other emergency communication service providers” as inclusive of
over-the-top interconnected text providers to the extent that they provide text-to-911 service.373 Similarly,
we believe that the term “other emergency communications service providers” also reasonably includes
any communications service provider to the extent that it provides E911 service. We believe that the
liability protection set forth in the Next Generation 911 Advancement Act and other statutes provide
adequate liability protection for CMRS providers subject to our rules. Moreover, we find that the rules
we adopt today serve to mitigate or eliminate any regulatory uncertainty about 911 indoor location
accuracy requirements.374 We take no action at this time with regard to liability protection of E911
service providers.
e.

Specialized Waiver Process

155.
Background. We sought comment in the Third Further Notice on whether we should
adopt a specific waiver process for CMRS providers who seek relief from our indoor location accuracy
requirements.375 In general, the Commission’s rules may be waived for good cause shown, pursuant to a
request or by the Commission’s own motion.376 In the context of its E911 Phase II requirements, the
Commission recognized that technology-related issues or exceptional circumstances could delay
providers’ ability to comply with the requirements, and that such cases could be dealt with through
individual waivers as implementation issues were more precisely identified.377 Accordingly, we sought
comment on whether and what criteria would be appropriate for any E911-specific waiver process, as
well as whether providers who believe they cannot comply with a particular indoor location accuracy
369

Id.at 2417 ¶ 114. See also Signal Booster Report and Order, 28 FCC Rcd at 1696 ¶ 90 n. 206.

370

CTIA Reply Comments at 20.

371

BRETSA Comments at 24-25.

372

Qualcomm Reply Comments at 8.

373

Facilitating the Deployment of Text-to-911 & Other Next Generation 911 Applications, Framework for Next
Generation 911 Deployment, Second Report and Order, 29 FCC Rcd 9846, 9876-77 ¶ 65 (2014).
374

See, e.g., NextNav Comments at iv (“The Commission has acknowledged that the adoption of clear, near-term
requirements will remove regulatory uncertainty, add needed impetus to carrier adoption, and hasten the eventual
development of long-term solutions capable of delivering the dispatch-able address-level information that is
ultimately sought by public safety.”).
375

Third Further Notice, 29 FCC Rcd 2417 ¶¶ 115-16.

376

See 47 C.F.R. §§1.3 and 1.925.

377

First E911 Report and Order, 11 FCC Rcd at 18710 ¶ 66, 18718 ¶ 84.

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benchmark, despite good faith efforts, may submit a certification to this effect six months prior to the
applicable benchmark.378
156.
A number of commenters support, or at least do not oppose, the idea of an E911-specific
waiver relief process.379 TruePosition identifies several factors specific to indoor 911 location that may
be appropriate as a basis for an E911-specific waiver process: “if a carrier has ordered the necessary
equipment (network hardware, handsets, etc.) that would, if delivered on time, meet the indoor safety
standards, that type of ‘good faith’ effort should be considered as fair grounds for granting the service
provider additional time.”380 BRETSA submits a similar argument for “good faith efforts” as a basis for
granting waiver relief.381 RWA submits that the Commission “should adopt a safe harbor for waiver
applicants based on a showing of technical infeasibility or financial difficulty,” which should “on its own
should justify a waiver.”382 NTCA notes that “for the small rural carriers who comprise NTCA’s
membership, the expense of a waiver can impose a substantial financial burden, and the regulatory
uncertainty can be disruptive to business planning and operations,” but nevertheless supports the adoption
of a streamlined waiver process if the Commission were to adopt the location requirements.383 However,
CTIA opposes the establishment of a specific waiver process, arguing that “a waiver standard that
requires a commitment to achieve compliance within a specific timeframe … is problematic given the
uncertainties associated with technology availability and deployability.”384 CTIA argues further that “the
waiver process should not be a weigh station [sic] on the way to enforcement.”385
157.
Discussion. Any CMRS provider that is unable to comply with the rules or deadlines
adopted herein may seek waiver relief. The Commission may grant relief pursuant to the waiver
standards set forth in Sections 1.3 and 1.925 of its rules, and we believe these provisions are sufficient to
address any requests for relief of the indoor location accuracy requirements, which we will evaluate based
on the facts and circumstances of the particular request. Therefore, we decline to adopt additional waiver
criteria at this time that would be specific to waiver requests of our indoor accuracy requirements.
C.

Benefits and Costs of Indoor Location Accuracy

158.
In this section, we demonstrate that the benefits of building upon the Amended Roadmap and
Parallel Path with the wireless location accuracy rules we adopt today outweigh the costs. In developing a
378

Third Further Notice, 29 FCC Rcd 2417 ¶ 116.

379

BRETSA Comments at 25; FindMe911 Coalition Comments at 10; NASNA Comments at 11; Blooston
Comments at 5-7; CCA Reply Comments at 13; SouthernLINC Wireless Reply Comments at 8; TIA Comments at
6; TruePosition Comments at 15-16; NTCA Comments at 2; Transit Wireless Reply Comments at 11.
380

True Position Comments at 15-16. The Commission has adopted “proof of timely ordering of equipment” as a
consideration in specific waiver processes for the construction of broadcast, mobile radio and telephone stations.
See, e.g., Consolidated Request of the WCS Coalition for Limited Waiver of Construction Deadline, Order, 21 FCC
Rcd. 14134 ¶¶ 9, 12 (WTB 2006) (three-year extension of deployment deadline granted where licensees where
confronted with “factors beyond their control” and the public interest would not have been advanced by strict
compliance with construction deadlines); Applications Filed by Licensees in the Local Multipoint Distribution
Service, Memorandum Opinion and Order, 23 FCC Rcd 5894 ¶ 25 (WTB 2008) (finding that public interest was
served by extending 10-year construction requirement because licensees “faced factors beyond their control”).
381

BRETSA Comments at 25 (“The Commission should grant waivers of its deadlines for provision of indoor
location information upon a showing by the provider that it was unable to meet a deadline due to circumstances
beyond its control, such as the inability of location information providers to install their systems in all markets
required within the time allotted.”).
382

RWA Comments at 7.

383

NTCA Comments at 5 and Reply Comments at 7.

384

CTIA Comments at 20.

385

Id.

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regulatory framework for indoor location accuracy, our objective is to implement rules that serve the public
safety goals established by Congress.386 While in the Third Further Notice we acknowledged the potential
difficulty of quantifying benefits and burdens, we sought to measure how the availability of indoor location
information will benefit the public through reduced emergency response times, as well as how to maximize
these benefits, while taking into consideration the burden of compliance to CMRS providers.387 We discuss
these issues here.
1.

Benefits of Improved Indoor Wireless Location Accuracy

159.
Background. In the Third Further Notice, we sought comment on the extent to which
improvements in indoor location accuracy would result in tangible benefits with respect to the safety of
life and property.388 We also noted our belief that improving location accuracy for wireless calls to 911,
including from indoor environments, would be particularly important for persons with disabilities and for
those who may not be able to provide their address or otherwise describe their location and sought
comment on the increased value and benefits of providing more accurate location information for certain
populations, such as people with disabilities, victims of crime, senior citizens and children.389
160.
We cited to a study examining emergency incidents during 2001 in the Salt Lake City
area which found that a decrease in ambulance response times reduced the likelihood of mortality (Salt
Lake City Study).390 From the results of this study, we reasoned that the location accuracy improvements
we proposed could save approximately 10,120 lives annually, at a value of $9.1 million per life, for an
annual benefit of approximately $92 billion.391 We also noted a 2002 study focusing on cardiac
emergencies in Pennsylvania, which showed that when location information was provided
contemporaneously with a 911 call, the reduction in response time correlated with a reduction in mortality
rates from cardiac arrest (Cardiac Study).392 Based on this study, we estimated that for cardiac incidents
alone, the proposed indoor location rules may well save at least 932 lives nationwide each year, yielding
an annual benefit of almost $8.5 billion.393 Furthermore, as location information quality improves and
latency declines, we noted our expectation that this will result in an even greater improvement in patient
medical outcomes. We sought comment on the reasonableness of our analyses of these studies and our
underlying assumptions, as well as on whether the time benefit of vertical location, given the spread in
horizontal location, is likely to be more, less, or comparable to the estimated gains in the Salt Lake City
Study and the Cardiac Study when moving from basic 911 to enhanced 911 services.394
161.
The large majority of commenters affirm the importance of improvements to indoor
location accuracy.395 Several commenters state that improved location accuracy would lead to more rapid
386

Section 1 of the Communications Act of 1934 (as amended) (the “Act”), 47 U.S.C § 151.

387

Third Further Notice, 29 FCC Rcd at 2387 ¶ 30.

388

Third Further Notice, 29 FCC Rcd at 2388 ¶ 33.

389

Id.at 2389 ¶ 34.

390

Id.at 2388 ¶ 33.

391

Id.

392

Id.

393

Id.

394

Id.

395

See, e.g., BRETSA Comments at 15; CALNENA Comments at 3; DEMSF Comments at 1-2; FindMe911
Comments at 3-7; NENA Comments at 13; Letter from Terry Hall, President, APCO International, to Marlene H.
Dortch, Secretary, FCC, WT Docket No. 11-49, at 2 (filed May 6, 2013) (“APCO has consistently supported
regulatory and technical initiatives targeted at achieving even incremental steps toward ensuring accurate, actionable
location information is available for every 911 call.”); Letter from Adam D. Kennard, Executive Director, National
Sheriffs’ Association, to Julius Genachowski, Chairman, FCC, WT Docket No. 11-49 (filed Apr. 3, 2013), at 1
(continued….)

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response time by eliminating time and resources spent pursuing incorrect addresses and locations.396 The
Commission’s expectation that improving location information quality would lead to a decline in latency
was further confirmed by recent testing conducted by public safety representatives in the CSRIC test
bed.397 Many commenters also agree that shorter response times lead to not only reductions in mortality,
but better prognoses for many non-life-threatening cases.398 Many commenters also concur that improved
location information can be particularly important for saving the lives of persons with disabilities and for
those who may not be able to adequately communicate their location to a 911 call-taker.399 AT&T is the
only commenter that does not agree that the Salt Lake City Study’s findings are indicative of benefits that
the public should expect from the implementation of tighter location accuracy requirements.400
(Continued from previous page)
(“Even a modest improvement in capabilities above the current 100-300 meter standards would represent a
significant benefit to public safety.”); Letter from Telford E. Forgety, III, Director of Government Affairs &
Regulatory Counsel, NENA: The 9-1-1 Association, to Julius Knapp, Chief Engineer, Office of Technology, FCC,
WT Docket No. 11-49 (filed Mar. 22, 2013), at 2 (“Any significant improvement over the current regime of
impossibly-large out-door search rings and indeterminate indoor search rings must be encouraged, whether or not it
can reach our ultimate ideal right away.”).
396

AARP Comments at 5-6 (“[s]tudies have identified the following favorable outcomes arising from more rapid
response time: improved cardiac outcomes; improved stroke treatment and outcomes; fewer complications from
multiple fracture injuries; as well as generally improved treatment outcomes.”); Salvucci Comments at 3 (“In order
to achieve the short time intervals necessary to save lives, immediate and accurate location determination is
essential.”); APCO Comments, PS Docket No. 07-114 (filed Sept. 25, 2013), at 3 (APCO Workshop Comments)
(noting that in “the absence of accurate location data associated with a wireless call, the caller must be questioned in
detail to provide verbal information regarding their location. This process can be time consuming and callers are
sometimes unable to speak or provide correct information.”); IAFC Workshop Comments at 1 (deployment of
advanced location technologies is critical to … public safety response capabilities, and to the personal safety of all
first responders”).
397

The test included buildings that were previously used by CSRIC for the indoor location test bed. The results
showed that a 90 percent reduction in first responder search area led to a dramatic reduction in latency, between 4
and 17 minutes. See NextNav Reply Comments at 54, citing Letter from William Storti, Battalion Chief, San
Francisco Fire Department; Robert Smuts, Deputy Director, Division of Emergency Communications; Tom
O’Connor, President, San Francisco Fire Fighters, to Marlene H. Dortch, Secretary, Federal Communication
Commission (dated July 14, 2014), at 2.
398

See NASEMSO Reply Comments at 2-3 (“for every minute without life-saving CPR and defibrillation, chance of
survival decrease 7%-10%”); NASNA Comments at 2-3 ( “A faster response time generally results in lives saved,
but there is a broader societal issue here. Resources saved in terms of faster response time helps to contribute to the
overall quality of life of a given area. We locate in communities because of schools and low cost of living; why not
faster response times?”); IAFC Reply Comments at 2; American Heart Association Comments at 1. See Salvucci
Comments at 5 (citing a Blanchard study on EMS response times and mortality in urban areas (where indoor
wireless location accuracy is least accurate) that concluded that “patients suffered a 35 [percent] greater mortality
rate when the response was greater than 4 minutes compared to less than 4 minutes.”); see also ARA Comments at 1
(citing better health outcomes particularly for older Americans, a group that uses the healthcare system more than
any other); Salvucci Comments at 2 (citing better health outcomes for patients suffering from Sudden Cardiac Arrest
(SCA)); NextNav Comments at 36; FindMe911 Comments at 8.Improved survival rates and health outcomes also
lead to lower healthcare costs. See Americans Heart Association Comments at 2 (stating that “[f]aster treatment for
a patient suffering a STEMI, for example, reduced the average hospital stay by two days and average hospital costs
declined by nearly $10,000 per patient from $26,826 to $18,280.”).
399

See, e.g., DEMSF Comments at 1-2; ARA Comments at 2; Alzheimer’s Association Comments at 1; FindMe911
Reply Comments at 10; AARP Comments at 7; FindMe911 Survey at 1 (sharing that their survey of 911
professionals shows that the most common instances of callers who are unable to tell the 911 dispatcher their
location were either suffering from age-related confusion or a medical emergency, was deaf or hard-of hearing, did
not speak English, or was too young to know their address).
400

AT&T Comments at 21-22.

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162.
Discussion. We conclude that the location accuracy rules we adopt today will improve
emergency response times, which, in turn, will improve patient outcomes, and save lives. Requiring
location information for wireless calls to 911 from indoors is thus consistent with our statutory goal of
“promoting safety of life and property.”401 Further, we must be more inclusive in our requirements than
those proposed by the Roadmap because its five-year and six-year location accuracy metrics risk
stranding non-VoLTE consumers without the life-saving benefits of improved wireless indoor location
accuracy technology. Finally, by providing a z-axis metric as a backstop to dispatchable location for
identifying floor level of 911 calls from multi-story buildings, we ensure that vertical location accuracy is
achieved within the timeframe laid out by the Roadmap. These commercially reasonable requirements
ensure that the full benefits of improved wireless indoor location accuracy are realized by addressing gaps
in the Roadmap proposal while adopting and codifying its major elements and adapting our rules to its
overall timeframe.
163.
The location accuracy rules we adopt today are a measured response to the critical public
safety need for improved wireless indoor location accuracy. While AT&T makes an array of arguments
against the benefits the Commission has identified as a likely result of improved indoor location accuracy,
we find that the Salt Lake City Study offers a relevant basis upon which to base the projected benefits of
the location accuracy requirements we adopt in this item, and that the value of statistical life (VSL)402
offers an appropriate measurement for the public’s valuation of lives saved as a result of these rules.
164.
The Salt Lake City Study demonstrates that faster response time lowers mortality risk.
Changes in cellphone usage patterns do not undermine this finding. AT&T argues that even if the Salt
Lake City Study demonstrated that delayed response time might increase mortality, it does not necessarily
follow that improved response times would reduce mortality.403 However, the record shows that for
certain medical emergencies like sudden cardiac arrest (SCA), the length of response time may be
determinative of whether or not a patient survives.404 Sudden cardiac arrest is the leading cause of death
of American adults over age 40, with 9 out of 10 incidents resulting in death.405 The Sudden Cardiac
Arrest Foundation states that “SCA victims can survive if they receive immediate CPR and are treated
quickly with defibrillators,” but caveats that “[t]o be effective, this treatment must be delivered quickly—
ideally, within three to five minutes after collapse.”406 Considering the high mortality rate and timesensitive nature of this increasingly widespread health risk, it follows that improved location accuracy
leading to shorter response times would reduce mortality rates for this very large group of medical
emergencies.407 We also disagree with AT&T’s argument that the Salt Lake City Study’s findings are
401

47 U.S.C. § 151.

402

The United States Department of Transportation defines value of a statistical life (VSL) as “the additional cost
that individuals would be willing to bear for improvements in safety (that is, reductions in risks) that, in the
aggregate, reduce the expected number of fatalities by one.” DoT presently estimates the VSL at $9.1 million. See
Memorandum from Polly Trottenberg, Assistant Secretary for Transportation Policy, and Robert S. Rivkin, General
Counsel, to Secretarial Officers and Modal Administrators, U.S. Department of Transportation, “Treatment of the
Economic Value of a Statistical Life in Departmental Analysis” (Feb. 28, 2013), available at
http://www.dot.gov/sites/dot.dev/files/docs/VSL%20Guidance_2013.pdf (last visited Jan. 21, 2015).
403

AT&T Comments at 21.

404

See, e.g., Salvucci Comments at 2, 5.

405

Sudden Cardiac Arrest Foundation, “Sudden Cardiac Arrest: A Healthcare Crisis,” available at http://www.scaaware.org/about-sca (last visited Jan. 22, 2015) (About Sudden Cardiac Arrest Article).
406

About Sudden Cardiac Arrest Article.

407

The Sudden Cardiac Arrest Foundation estimates that there are 424,000 SCA incidents requiring immediate
medical attention in the United States each year. See About Sudden Cardiac Arrest Article. It also notes that the
number of deaths resulting from SCA annually “is roughly equivalent to the number of people who die from
Alzheimers’ disease, assault with firearms, breast cancer, cervical cancer, colorectal cancer, diabetes, HIV, house
(continued….)

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inapposite because the increase in wireless cellular phone usage has already shortened the amount of time
that individuals delay before calling 911.408 The time that it takes for an individual to respond
appropriately to an unexpected emergency is a function of a wide variety of factors beyond cellphone
proximity.409
165.
The DoT’s VSL was designed to calculate the value of preventing injuries or deaths.410
That makes VSL an appropriate metric for our analysis of the projected benefits of the wireless location
accuracy rules we adopt today. AT&T argues that our use of DoT’s VSL statistic is inapposite because
those affected by our wireless location accuracy rules have already contracted a disease or been seriously
injured.411 As stated by AARP, however, the relevant timeframe during which a life should be valued for
the purpose of our analysis is not the moment at which that individual dials 911, but the time when a
presumptively healthy consumer decides whether to buy a given cellphone product based at least in part
on their perception that they will be able to use that cellphone to timely summon life-saving assistance.412
166.
We conclude that the location accuracy improvements we adopt today have the potential
to save approximately 10,120 lives annually, at a value of $9.1 million per life, for an annual benefit of
approximately $92 billion, or $291 per wireless subscriber.413 We find that our reliance on the Salt Lake
City Study to arrive at those figures is well-placed, and that our analysis as to the applicability of that
study to the rules we adopt today is fundamentally sound. We are not persuaded by AT&T’s
counterarguments with respect to the projected benefits because of its unsupported assumptions about the
relationship between response time and mortality risk, and its misguided approach to valuing human life
that presupposes life-threatening conditions. Even if we were to adopt AT&T’s perspective, however, it
still stands to reason that the average wireless subscriber would likely be willing to pay $291 per year to
live an extra 23.7 days, the average increase in life expectancy that the Salt Lake City Study leads us to
believe should be expected to result from the rules we adopt today.414
2.

Costs of Improved Indoor Wireless Location Accuracy

167.
Background. In the Third Further Notice we noted that implementation of stricter indoor
location accuracy requirements will likely impose significant costs on providers and sought comment
(Continued from previous page)
fires, motor vehicle accidents, prostate cancer and suicides combined. In fact, the incidence of sudden cardiac death
is nearly 10 times higher than the incidence of death from breast cancer.” Id (emphasis in original).
408

AT&T Comments at 21-22.

409

Additionally, we find AT&T’s observation that the latency measured in the Salt Lake City Study was due to
increased distance from dispatch, rather than improved location accuracy, is a distinction without a difference. See
AT&T Comments at 22-23. Time saved will have the same effect on risk of mortality regardless of when and how
that time was saved.
410

NextNav Reply Comments at 55 (footnote omitted).

411

AT&T Comments at 26.

412

AARP Comments at 4.

413

Third Further Notice, 29 FCC Rcd at 2388-89 ¶ 33; see also Implementation of Section 6002(b) of the Omnibus
Budget Reconciliation Act of 1993 Annual Report and Analysis of Competitive Market Conditions With Respect to
Mobile Wireless, Including Commercial Mobile Services, WT Docket No. 11-186, Sixteenth Report, 28 FCC Rcd
3700, 3708 (2013) (reporting that the total number of mobile wireless connections . . . grew 11 percent from 285.6
million at the end of 2009 to 316.0 million at the end of the fourth quarter of 2011).
414

AT&T’s statement that a one-minute reduction in response time saves 23.7 days of life is potentially misleading,
because the figure expresses expected life savings as an average among all 911 callers, including individuals not at
risk of death, and those at risk of death who are not timely saved. See AT&T Comments at 26. In fact, most
individuals whose lives are saved because of improved emergency response times will live beyond what would
otherwise have been their life expectancy than the Salt Lake City Study’s 23.7 day figure suggests.

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FCC 15-9

generally on the costs of such requirements, as well as detailed information on all of the costs providers
estimate our proposed indoor location rules would impose on them, and how these costs were
determined.415 We also sought comment on what universal costs would be necessary across all indoor
location technologies, as well as on any specific costs that are unique to different technologies; and on
whether additional costs would be passed on to consumers, resulting in higher rates and, if so, how much
rates would increase.416 Finally, we indicated our belief that any costs imposed by our rules might be
mitigated, at least to some degree, by the fact that providers are already undertaking significant indoor
location technology research and development on their own for commercial, non-911 reasons and sought
further comment on the degree to which commercial development – unrelated to any Commission indoor
location capability requirement – could be leveraged to mitigate the costs of compliance.417 We asked
whether additional costs would be imposed by the potential indoor location requirements set forth in the
Third Further Notice above and beyond the costs that CMRS providers would already have in
implementing indoor location capabilities for commercial purposes.418
168.
Technology-Specific Costs. While commenters do not make nuanced statements about
costs that will confront the industry in order to attain compliance with our proposed indoor location
accuracy standards, they offer a variety of opinions on the costs presented by the adoption of specific
technologies. Commenters agree that barometric pressure sensors are already “relatively inexpensive,”
and, consistent with the general cost-based observations made in Section III.B.4.a above, conclude that
the price should be expected to continue to fall at a rate of approximately 15 percent per year as adoption
grows.419 Commenters also agree that establishing improved wireless indoor location accuracy through a
solution utilizing terrestrial beacons would entail an additional per-unit cost of $1,500 ‒ $3,000, plus
additional site lease charges.420 According to NextNav, receivers utilizing UTDOA are already deployed
within CMRS networks and are already supported by handsets, and such a “broadcast-only location
network requires no additional transmitters or spectrum, nor does it entail expensive backhaul, or
extensive antennae arrays.”421 Commenters also state that consumer handsets already contain GPS
receivers, and the technology has robustly responded to technological change, proving highly reliable
results across multiple generations of technology, and avoiding the risk of stranded investment.422
Finally, Rx Networks, on behalf of smaller CMRS providers, advocates for the establishment of a
centralized and standardized service to process location requests.423 Such a clearinghouse solution would
entail a base station almanac of Cell-IDs and Wi-Fi access point locations, and cost-effective provisioning
of A-GNSS and barometric pressure data among CMRS providers.424 Rx Networks asserts that such a
solution bridges technical gaps, and simplifies business relationships while minimizing capital outlays.425
415

Third Further Notice, 29 FCC Rcd at 2390 ¶ 35.

416

Id.at 2390 ¶ 36.

417

Id.at 2390 ¶ 37.

418

Id.

419

NextNav Comments at 26 (projecting that the average sales price of these devices will be between $0.25 and
$0.35 by 2017 as a direct result of the commercial demand that already exists for such components); accord Bosch
Comments at 2.
420

iPosi Comments at 12 (stating that roof-top antennae installations cost $1,500 - $3,000, plus additional site lease
charges). See also NextNav Comments at 27.
421

NextNav Comments at 25, 27-28. See also AdGen Comments at 16.

422

iPosi Comments at 12. See also NextNav Comments at 33.

423

Rx Networks Comments at 4.

424

Id.

425

Id.

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169.
Cost Mitigation. Commenters agree that CMRS provider costs can be diminished
through the sharing of infrastructural solutions and that the growth in national demand for these
technologies will eventually drive these costs down.426 Commenters also agree that CMRS providers are
already in the midst of a transition to all-digital, all-IP networks, and have already begun work to improve
location accuracy within their systems for commercial reasons.427 For these reasons, according to
Motorola, CMRS providers have already added the permanent employees needed to engineer and manage
the processes required for further improvements to location accuracy.428 Additionally, TruePosition
opines that one of the benefits of today’s proceeding is that it may entail cost savings upwards of $100
billion for CMRS providers who ultimately retire their traditional circuit-switched copper-loop networks
and complete their transition to an all-digital IP ecosystem.429 Moreover, according to NENA, “[u]nlike
2000, handsets today can already leverage existing capabilities for horizontal and, in some cases, vertical
location determination. This means that carriers need only close the gap between already-deployed
capabilities and the Commission’s proposed requirement, rather than starting from scratch.”430
170.
Discussion. We find that among the myriad potential costs posed by the variety of
location accuracy technologies discussed in this section, all share the commonality that their price will
decline as demand grows.431 In light of our commitment to technology neutrality, as we emphasized in
the Third Further Notice, we do not mandate any particular model for implementing the location accuracy
rules we adopt today, and apply these requirements on a technologically neutral and provider-neutral
basis.432 That said, we note that NextNav reports on their website that it recently secured $70 million in
funding to maintain and operate its MBS network.433 This indicates that there are solutions available to
achieve the indoor wireless location accuracy standards we adopt today at a cost that is far less than their
$92 billion minimum benefit floor. Finally, we acknowledge that the costs imposed by the rules we adopt
today may present a proportionately greater burden to smaller CMRS providers, including the costs
associated with participation in the test bed.434 So, although the cost of meeting our indoor location
accuracy rules has not yet been determined to a dollar amount, commenters provide the Commission with
a paradigm for understanding the shape that such costs will take.435

426

TruePosition Reply Comments at 31. See also NextNav Comments at 26-27.

427

Motorola Comments at 16. See also TruePosition Reply Comments at 27.

428

Motorola Comments at 16.

429

TruePosition Reply Comments at 27 (stating that there “could be roughly $100 billion” in real estate cost savings
alone for such CMRS providers).
430

NENA Reply Comments at 7 (comparing CMRS providers’ response to the proposed indoor location rules with
CMRS providers’ response to the Commission’s Phase II rules adopted in the E911 Fourth Memorandum Report
and Order (2000)).
431

We also recognize that the regulatory scheme we have set forth will also impose reporting burdens and the costs
associated with those requirements. See CCA Comments at 6. The record keeping and reporting costs are set forth
in our Paperwork Reduction Analysis.
432

Third Further Notice, 29 FCC Rcd at 2391 ¶ 39.

433

Press Release, “NextNav Closes $70 Million Series D Financing,” (Jul. 24, 2014), available at
http://www.nextnav.com/news/nextnav-closes-70-million-series-d-financing (last visited Dec. 30, 2014).
434

CCA Reply Comments at 15.

435

See e.g., Sprint Commenters at 9 (“Before CMRS carriers can begin to estimate costs accurately, standards work
must be closer to completion in order to guide hardware and software development, and the field of potential
solutions and vendors needs to broaden so that carriers can receive competitive pricing.”).

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IV.

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IMPROVING THE DELIVERY OF PHASE II LOCATION INFORMATION

171.
In the following sections, we adopt measures to ensure that PSAPs receive Phase II
information in a swift and consistent format, and to improve the quality of the Phase II information.
Through these measures, we seek to ensure that PSAPs receive the full breadth of information they need
to respond swiftly and effectively to emergency calls.
A.

Latency (Time to First Fix)

172.
Background. The Commission’s current E911 location accuracy rules do not require
CMRS providers to test for or to meet a specific latency threshold, commonly known as “Time to First
Fix” (TTFF).436 In the Third Further Notice, we proposed to require CMRS providers to deliver Phase
II-compliant location information to the network’s location information center within 30 seconds in order
for the location fix to count in a CMRS provider’s calculation of percentage of calls that comply with our
rules.437 We also proposed to exclude from this compliance calculation any wireless 911 calls lasting 10
seconds or less, an interval which is often too short for a CMRS network to feasibly generate and deliver
a location fix to its location information center. We ultimately proposed to include calls lasting more than
10 seconds in the calculation.438
173.
A number of public safety and industry commenters support a maximum latency of 30
seconds for obtaining a location fix as reasonable based on the performance of current handset and
network-based technologies.439 Some commenters, however, urge the Commission to set maximum
latency at less than 30 seconds.440 Industry commenters also oppose the proposal to exclude only calls of
less than 10 seconds.441 They argue that it is unreasonable to allow CMRS providers up to 30 seconds to
obtain a location fix while also including calls lasting more than 10 but less than 30 seconds in the
compliance calculation. AT&T submits that “all calls should be given at least 30 seconds for purposes of

436

47 C.F.R. § 20.18(h)(1)-(2) (for the currently specified accuracy standards for outdoor measurements only).

437

Third Further Notice, 29 FCC Rcd at 2428-29 ¶ 144. The Third Further Notice used the term “location
information center” to refer to either the Mobile Positioning Center (MPC) or Gateway Mobile Location Center
(GMLC), which perform essentially the same function but are specific to the CMRS network’s design. See id. at ¶
21 n.47. Once the CMRS provider generates the location fix, it is transmitted to the location information center,
where it is available for retrieval by PSAPs through their initial bidding or re-bidding process. This proposal is
consistent with CSRIC Outdoor Location Accuracy Report, which suggests a TTFF of 30 seconds as an acceptable
time limit for delivering location information. See Outdoor Location Accuracy Report at 12.
438

Third Further Notice, 29 FCC Rcd at 2430 ¶ 147.

439

APCO Comments at 7; NENA Reply Comments at 18; AT&T Comments at 34; CTIA Comments at 18-19; TMobile Comments at 20; NextNav Comments at 41; TCS Comments at 24 (“The average TTFF for an A-GPS
location solution is well within . . . 30-second[s] . . . typically 12 to 15 seconds.”); Sprint Comments at 19 and
Reply Comments at 13; Verizon Reply Comments at 19 (asserting that “nothing in the record suggest[s] that a . . .
significantly shorter latency standard than the 30-second standard . . . is technically feasible”).
440

CALNENA Comments at 1 (“30 seconds is too long to wait for accurate caller location information, especially if
there is any hope of routing wireless 911 calls to the correct PSAP using GPS coordinates.”); Salvucci Comments at
4; BRETSA Comments at 3 (informing that its “PSAPs and a number of other [Colorado] PSAPs . . . report that
Phase II locations are generally available within ten seconds”) NARUC Comments at 12 (advocating that the
Commission “reduc[e] the 30-second maximum time period for the delivery of an accurate location.”). See also id.
at 11 & n.15. NARUC highlights (1) CSRIC III’s view of OET Bulletin No. 71 guideline of “30 seconds as the ‘de
facto standard for maximum latency’”, and (2) the results of a survey by the FindMe911 Coalition, as justification
for “targeting response times below 30 seconds.”
441

CTIA Comments at 19; T-Mobile Comments at 21; Sprint Comments at 19 (noting that the [Commission’s]
proposals are in conflict . . . because carriers have 30 seconds, not 10 seconds, to generate and deliver the first 9-1-1
location fix.”).

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calculating the location-accuracy success rate” and that to “do [otherwise] would unfairly mischaracterize
the provider’s compliance with location-accuracy benchmarks.”442
174.
Discussion. We add a maximum latency requirement of 30 seconds to the existing E911
Phase II rules applicable to outdoor calls, but we conclude it is premature to include this requirement as
part of the new rules adopted in this order for indoor location. Thus, for a 911 call to meet Phase II
requirements, a CMRS provider must deliver Phase II-compliant information to its location information
center within 30 seconds, as measured from the start of the call to when the information is delivered to the
location information center. In calculating percentages of Phase II-compliant calls, CMRS providers
must include calls lasting 30 seconds or more for which they are unable to deliver a Phase II location
fix.443 We apply this requirement only to our existing E911 regime, which determines compliance based
on outdoor measurements only. Thus, compliance with our TTFF requirement will be based on the
results of outdoor testing, and will not be measured from the live 911 call data from the six test cities.
175.
We find that a 30-second maximum latency period appropriately balances the need for
first responders to obtain a prompt location fix and the need to allow sufficient time for location accuracy
technologies to work effectively.444 Excessive delay in the provision of location information can
undermine or negate its benefits to public safety, but providing sufficient time for location technologies to
work can lead to improved accuracy that reduces overall response time. As CSRIC III noted, 30 seconds
is “generally accepted as the de facto standard for maximum latency in E9-1-1 location delivery.”445 The
record in this proceeding similarly indicates that a maximum latency interval of 30 seconds is technically
achievable using current location technology,446 and that improved chipsets in devices will further reduce
the frequency of calls where the TTFF takes longer than 30 seconds.447
176.
In fact, we expect technology to reduce latency for many wireless 911 calls to
significantly less than 30 seconds. CMRS providers indicate that new satellite positioning technologies
they are planning to implement in conjunction with deployment of VoLTE will likely reduce latency fix
for wireless 911 calls from outdoor locations.448 For example, newer-generation A-GNSS may be capable
442

AT&T Comments at 34. See also NextNav Comments at 43-44 (remarking that the proposal “raises the question
of how calls will be treated when they are interrupted after 10 seconds but before 30 seconds has elapsed”); NTCA
Comments at 6-7 (asserting that “the record has not been fully developed on this point, and an industry standard
different than 30 seconds has not been established.”); T-Mobile Comments at 21 (although it supports a maximum
TTFF of 30 second, T-Mobile asserts that the Commission “should exclude calls of less than 30 seconds’ duration
from consideration” in carriers’ complying with the Phase II rules); CTIA Reply Comments at 9 (favoring including
“only calls lasting 30 seconds or more in yield”).
443

For example, in a calculation of the yield percentage, all 911 calls with compliant location fixes within 30
seconds would be included in the numerator, and calls with a non-compliant TTFF would be in the total of all 911
calls in the denominator.
444

Third Further Notice, 29 FCC Rcd at 2427-28 ¶ 143; and at 2434 ¶ 160 (describing trade-off between accuracy
and latency). See also NENA Workshop Comments at 3 (asserting that “existing network-based and networkassisted location technologies can provide very fast first fixes, which are valuable to public safety, even if they are
subject to larger uncertainties than final GNSS [satellite] fixes.”).
445

Outdoor Location Accuracy Report at 12.

446

See supra para. 173 note 439.

447

Verizon Comments at 28-29.

448

For example, Verizon has previously stated that it has taken “steps … to improve the location information
delivered to PSAPs,” such as “[m]aking caller location information available within an average of 12-15 seconds,
and within 25 seconds for 99 percent of all calls for which the information is available.” See Verizon Dec. 19, 2013
Ex Parte Letter at 1 (referring to the improvements in the context of “enhancing the A-GPS location accuracy
solution for VoLTE . . . including coupling location data from additional satellite systems (GLONASS) and OTDOA
with GPS data.”). Additionally, TCS submits that “[t]he higher bandwidth capability of an LTE network may lower
the time that it takes for the network to push GNSS assistance data to the handset.” TCS Comments at 25.

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of generating a location fix within 12-15 seconds.449 Nevertheless, even in such cases, allowing up to 30
seconds provides additional time to refine the location information and potentially return a more accurate
location fix.450 On balance, we find that a 30-second maximum latency period will encourage solutions
that deliver location information to first responders quickly while providing flexibility for solutions that
can deliver greater accuracy over a modestly longer time interval. Establishing a maximum latency
period will also ensure that PSAPs and CMRS providers have the same expectations regarding the
timeframe for delivering location information.
177.
While we adopt the 30-second maximum latency period for outdoor calls as proposed in
the Third Further Notice, we decline to adopt our proposal to exclude calls of 10 seconds or less while
including calls of 10 to 30 seconds in the compliance calculation. We agree with industry commenters
that where a call lasts less than 30 seconds, we should not penalize the provider for failing to obtain a
Phase II-compliant fix that requires up to 30 seconds to generate and that would count towards
compliance if the call lasted 30 seconds or more. Therefore, we will allow CMRS providers to exclude
from their compliance calculation any wireless 911 call lasting less than 30 seconds for which the
provider is unable to deliver a Phase II-compliant fix. On the other hand, to provide an incentive for
CMRS providers to reduce latency below 30 seconds, CMRS providers may count any Phase II-compliant
call in which the location fix is delivered in less than 30 seconds, regardless of the duration of the call.
178.
Finally, as noted above, we limit the scope of the 30-second latency requirement to
wireless 911 calls covered by our existing Phase II rules, as we believe it is premature to impose a latency
standard for indoor calls at this time. Compliance will be measured by evaluating the results of each
CMRS providers’ outdoor drive testing. CMRS providers have yet to test location for latency, among
other metrics, in generating dispatchable location information derived from various indoor access points
or beacons. Moreover, although location information from beacons and small cells could likely be
determined almost instantaneously, the various new technologies that are included in “heightened location
accuracy technologies” under the Roadmap have not yet been tested for latency. Therefore, while the
record suggests that existing and developing indoor location technologies should be capable of delivering
accurate location information in 30 seconds or less for most calls, we conclude that consideration of this
issue should be deferred. Once there has been an opportunity to evaluate the performance of indoor
location technologies based on test bed results and live call data from the six geographic test regions, we
will be better able to determine whether to extend latency requirements to these new location
technologies.
B.

Retaining E911 Phase II Location Accuracy Standards for Outdoor Measurements

179.
Background. In light of advancements made in A-GPS technology and the migration of
some CMRS providers from GSM networks and network-based location to 4G and LTE networks and
handset-based location, the Third Further Notice sought comment on whether all CMRS providers
reasonably could comply with a 50-meter accuracy/67 percent reliability requirement within two years
pursuant to a unitary location accuracy requirement for both indoor and outdoor calls.451 Prior to the
449

TCS Comments at 24; Sprint Reply Comments at 13 (“There are multiple variables outside of the control of
CMRS carriers that affect the TTFF, such as the number of satellites that are visible and atmospheric conditions.”).
See also id. (noting that “when turning on location for any call, a device takes time to acquire the necessary satellites
to determine location”).
450

TCS Comments at 24 (“The average TTFF for an A-GPS location solution is well within . . . 30-second[s] . . .
typically 12 to 15 seconds.”); Verizon Sept. 11, 2013 Ex Parte Letter at 5 (noting that a precise Phase II fix via GPS
can take up to 30 seconds but in most instances is generated within 12-15 seconds but can be generated in as few as
5 seconds). See also Third Further Notice, 29 FCC Rcd at 2433-34 ¶ 159 (observing that, if A-GPS generated
location fix cannot be obtained due to the blocking of GPS signals in a challenging environment, CMRS providers
networks trigger a “fall-back” location technology, which may take longer than 30 seconds to obtaining the fix.).
451

Third Further Notice, 29 FCC Rcd at 2435-37 ¶¶ 164-166.

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submission of the Roadmap, some public safety and industry commenters supported a unitary accuracy
standard. 452 Other commenters expressed that it is premature for the Commission to establish such a
standard.453 However, because CMRS providers do not yet have the technical capability to distinguish
indoor from outdoor calls, we address below the reasons for retaining our existing E911 location rules
that are based on outdoor testing measurements.
180.
Discussion. We find that it is premature to eliminate the current E911 Phase II rules and
replace them with a unitary location accuracy standard at this time. The current E911 Phase II rules
provide a set of established outdoor-focused location accuracy benchmarks for CMRS providers using
either network-based or handset-based location technologies and allow the network-based CMRS
providers to switch to handset-based technologies.454 The current outdoor-based rules thus serve to
maintain regulatory certainty for CMRS providers that continue to provide service on their legacy systems
while they are planning to migrate to VoLTE networks. The major CMRS providers that either have
initiated VoLTE service or plan to deploy it in 2015 must also continue to comply with the benchmarks
under the Commission’s rules for measuring the accuracy of outdoor calls. Thus, the additional location
accuracy requirements we adopt in this order, which focus on improving indoor location accuracy, will
serve to complement rather than replace the existing Phase II rules based on outdoor testing
measurements.
181.
We recognize that the six-year timeframe adopted in this order for indoor-focused
accuracy standards may ultimately moot the issue of whether to replace the current outdoor-based
accuracy requirements for E11 Phase II. The five and six-year benchmarks in the new rules, set to take
effect in 2020 and 2021, will require 50-meter accuracy for 70 and 80 percent of all wireless 911 calls,
respectively, and will apply to indoor and outdoor calls, thus exceeding the current Phase II handset-based
standard of 50-meter accuracy for 67 percent of calls, based on outdoor measurements only.455 The last
handset-based benchmark under the current Phase II requirements will occur in January 18, 2019.456
Thus, once the last Phase II benchmark has passed, we may revisit the issue of when to sunset date the
current Phase II requirements and establish a unitary accuracy standard.
C.

Confidence and Uncertainty (C/U) Data

182.
Background. The Commission’s current E911 Phase II rules require that CMRS
providers provide confidence and uncertainty (C/U) data on a per-call basis upon PSAP request.457 C/U
data reflects the degree of certainty that a 911 caller is within a specified radius of the location provided
by the CMRS provider.458 The Third Further Notice recognized, however, that C/U data is not always
452

NENA Comments at 4-5; AT&T Comments at 35; Verizon Comments at 32; NextNav Comments at 32; Rx
Networks Comments at 3.
453

T-Mobile Comments at 21-22; Sprint Comments at 20; CCA Reply Comments at 16-17; Verizon Comments at
32.
454

47 C.F.R. § 20.18(h)(1)(iv)-(v) (permitting the use of handset-based accuracy data with respect to evaluating
outdoor measurements).
455

47 C.F.R. § 20.18(h)(2)(i).

456

47 C.F.R. § 20.18(h)(2)(ii).

457

47 C.F.R. § 20.18(h)(3) (providing that “all carriers subject to this section shall be required to provide confidence
and uncertainty data on a per-call basis upon the request of a PSAP,” and that “[a]ll entities responsible for
transporting confidence and uncertainty between wireless carriers and PSAPs, including LECs, CLECs, owners of
E911 networks, and emergency service providers (collectively, System Service Providers (SSPs)) must implement
any modifications that will enable the transmission of confidence and uncertainty data provided by wireless carriers
to the requesting PSAP”).
458

The confidence level is expressed as a percentage, indicating the statistical probability that the caller is within the
area defined by the “uncertainty” statistical estimate, while uncertainty is expressed as a radius in meters around the
(continued….)

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utilized by PSAPs and that sought comment on how C/U data could be provided in a more useful manner.
In particular, we sought comment on the provision of C/U data for all wireless 911 calls, whether outdoor
or indoor, on a per-call basis at the request of a PSAP, with a uniform confidence level of 90 percent.459
Additionally, the Third Further Notice sought comment on standardization of the delivery and format for
C/U data to PSAPs.460
183.
In response, most public safety and industry commenters agree that a standardized
confidence level of 90 percent would provide important, useful information to PSAPs in interpreting the
quality of location information and would rectify the current CMRS provider practice of using varying
confidence levels in providing uncertainty data.461
184.
Discussion. We find that requiring CMRS providers to furnish C/U data based on a
standardized confidence value will provide significant benefits to PSAP call-takers and can be furnished
to PSAPs at minimal cost to CMRS providers.462 We therefore require that C/U data for all wireless 911
calls – whether placed from indoors or outdoors – be delivered on a per-call basis at the request of a
PSAP, with a uniform confidence level of 90 percent. The record reflects that CMRS providers currently
use varying levels of confidence in their C/U data, resulting in potential confusion among call-takers.463
We find that a uniform confidence level will help PSAPs understand and better utilize location
information. By standardizing confidence levels, call-takers will more easily be able to identify when a
location fix is less trustworthy due to larger uncertainties.464 As TCS explains, with a standardized
confidence value, “if the uncertainty of the location fix . . . is within a reasonable margin,” the PSAP “call
taker should have enough assurance to dispatch emergency services.”465 Further, the magnitude of the
uncertainty value varying with a standardized confidence value could also convey meaningful information
to the call-taker regarding the type of location fix being provided. For example, in the event a CMRS
provider is delivering dispatchable location information, the uncertainty value would either be zero or a
very tight geometric figure with a radius less than 50 meters.466
(Continued from previous page)
reported position. Third Further Notice, 29 FCC Rcd at 2431 ¶ 150. For example, the E911 Phase II location
information that CMRS providers provide to PSAPs is accompanied by a 90 percent/35 meter “C/U score,”
reflecting 90 percent confidence that the caller is within 35 meters of the estimated location. See Second Report and
Order, 25 FCC Rcd at 18928-30 ¶¶ 51-53.
459

Third Further Notice, 29 FCC Rcd at 2431-33 ¶¶ 150-156 & Appendix C.

460

Id.at 2433 ¶¶157-58.

461

NASNA Comments at 13; NENA Comments at 8; Texas 9-1-1 Comments at 3, 11 (expressing its understanding
that Verizon, AT&T (including former Leap/Cricket), and T-Mobile (including former MetroPCS) currently use 90
percent, while Sprint uses 63 percent); APCO Reply Comments at 4; AT&T Comments at 35; T-Mobile Comments
at 21. CSRIC III also noted this ATIS standard with respect to a standardized confidence level. See Outdoor
Location Accuracy Report at 19. See also ATIS Reply Comments at 6 (referring to the ATIS-ESIF recommendation
that “[confidence] should be normalized at 90 percent to provide for the consistent interpretation of location data by
the PSAP staff without significantly affecting the integrity of the calculated [uncertainty]”). See id. at n.9 (citing
ATIS ESIF Issue 70 (Final Closure Date: November 29, 2010), High Level Requirements for Accuracy Testing
Methodologies (ATIS-0500001)).).
462

See infra para. 188.

463

See supra para. 183 note 461.

464

TCS Comments at 2 (if the call-taker does “not have enough trust in the location fix [because] the uncertainty
level is too high,” it should perceive the need to obtain further location information from the caller before
dispatching emergency services).
465

TCS Comments at 2.

466

Comments indicate that the uncertainty value sent from a small cell location would approach zero. See AT&T
Comments at 35 (with “the long-term solution of a dispatchable address, certainty-uncertainty data would be
(continued….)

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185.
Moreover, the record indicates that a standardized 90 percent confidence value will serve
to eliminate confusion on the part of emergency call-takers and is supported by numerous commenters.467
As ATIS explains, a 90 percent confidence level will provide “for the consistent interpretation of location
data by the PSAP staff without significantly affecting the integrity of the calculated [uncertainty].”468 We
note that some commenters recommend an even higher standardized confidence value, e.g., 95 percent,
either in the near term or as new technologies are implemented in the long-term.469 On the other hand,
RWA alleges in its initial comments that “[a] confidence level of 90% is too high for rural carriers to
meet without the expensive construction of additional cell sites.”470 We find that a confidence level of 90
percent, while accompanied by an uncertainty radius that will vary, strikes an appropriate balance. While
we recognize that a standardized value of 90 percent will result in larger reported uncertainties for some
911 calls, there will be a greater probability that callers will be found within the area of uncertainty.471 As
technology evolves and as location accuracy improves over time, we may revisit whether to adopt an even
higher required confidence level.472
186.
In light of these public interest benefits, we disagree with commenters who oppose
standardizing a set of confidence and uncertainty values. For example, while Verizon “agrees that there
may be value” in establishing a uniform confidence level, it nevertheless asserts that the delivery of C/U
data should be “appropriately left to standards or best practices, as PSAP[s] need to determine what
(Continued from previous page)
unnecessary, except in cases where latitude/longitude ALI was provided because a dispatchable address was
unavailable”). See also Intrado Comments at 13 (“[w]ith the introduction of femtocells and small cells, the concept
that a Phase I location is less accurate than a Phase II location is not always true.”).
467

NASNA Comments at 13; NENA Comments at 8; Texas 9-1-1 Comments at 3, 11; APCO Reply Comments at 4;
AT&T Comments at 35; T-Mobile Comments at 21; Intrado Comments at 13; TCS Comments at 7; Rx Networks
Comments at 16.
468

ATIS Reply Comments at 6 (concerning ATIS standard 0500001); AT&T Comments at 35. CSRIC III also
noted this ATIS standard with respect to a standardized confidence level. See Outdoor Location Accuracy Report at
19.
469

TCS Comments at 7, 13 (submitting that IETF RFC 5491 establishes the “mechanism” that is “foundational” for
“NG9-1-1 as defined by the NENA 08-003 standard.”). See also APCO Reply Comments at 4 (“There may be merit
in revisiting the 90% confidence metric as emerging technologies are analyzed and evaluated . . . .”). NENA
submits that “[t]he Commission should announce a longer term goal of implementing a 95% confidence level” as the
“existing standard for location representation in NG9-1-1 systems. NENA Comments at 9. NENA asserts that as
“improvements in positioning technology . . . trickle-down to consumer devices and ‘consumer-facing’ networks…
the required confidence level for position fixes can be increased without inducing a corresponding increase in
reported uncertainties.” Id.
470

RWA Comments at 8.

471

NENA Comments at 8.

472

We also urge CMRS providers to consider public safety concerns, expressed by NENA and Intrado, on how the
capability for more discrete location information from PSAPs’ GIS-mapping and reverse geo-coding systems may
affect accuracy and uncertainty representations. For example, NENA submits that “[c]oincident with the
deployment of NG9-1-1 systems, PSAP systems and processes” will be capable of “support[ing] ever more powerful
GIS-based mapping and reverse-geocoding systems[,]” and PSAPs “will gain the ability to display more complex
location uncertainty representations . . . .” See NENA Comments at 9 (informing that “carrier network standards
like ATIS/TIA J-STD-036 already support the use of some such uncertainty representations”). Intrado reports that
current PSAP mapping programs providing reverse geo-coding of x/y coordinates may generate “address location
error that often results in a failure to meet public safety’s needs.” Letter from Craig W. Donaldson, Senior Vice
President Regulatory & Government Affairs, Intrado, to Marlene H. Dortch, Secretary, Federal Communications
Commission, filed Sept. 26, 2014 (Intrado Sept. 26, 2014 Ex Parte). See also id., Attachment at 8. Intrado suggests
that “improvements to underlying base mapping could substantially improve the accuracy of a dispatchable
address.” Intrado Comments at 13.

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approach makes sense . . . .”473 Others contend that further study is necessary, especially as location
technologies evolve.474 We see no reason to delay the delivery of more uniform C/U data. By reducing
the variability in C/U information, we can help ensure that call-takers more fully understand the location
information that is provided to them, enabling them to respond more efficiently to emergencies.
187.
Requiring a standardized confidence level of 90 percent (with varying uncertainty values)
will also provide CMRS providers with regulatory certainty as they configure C/U data using newly
implemented location technologies. Ensuring the continued provision of C/U data, in a manner that
allows PSAPs to fully utilize and understand that data, is particularly timely as providers migrate to 4G
VoLTE networks. CSRIC IV WG1 reports that “[t]he content of the Phase II location estimate delivered
to the PSAP” for a VoLTE 4G network “includes the same position, confidence, and uncertainty
parameters used in 2G/3G networks for technologies that directly generate geographic (i.e., X,Y)
location.”475 CSRIC IV adds that these parameters can be “formatted appropriately for legacy PSAPs as
well as NG9-1-1 PSAPs.”476
188.
We find that the costs of implementing a standardized confidence level should be
minimal.477 Because CMRS providers are currently required to deliver C/U data to requesting PSAPs on
a per-call basis,478 they have already programmed their networks to furnish a confidence value, with some
CMRS providers already either delivering or testing for it with a 90 percent confidence level.479
Moreover, RWA does not offer support for its allegation that a 90 percent standard confidence level
would necessitate the construction of additional cell sites and therefore create a burden on small CMRS
providers. Likewise, we find that the costs for SSPs to continue to transport C/U data to ensure its
delivery to PSAPs would be minimal. Like CMRS providers, SSPs currently must ensure that PSAPs
receive C/U data on a per-call basis.480 The requirement we adopt for C/U data will continue to apply to
all entities responsible for transporting C/U data between CMRS providers and PSAPs, including LECs,
CLECs, owners of E911 networks, and emergency service providers, to enable the transmission of such
data to the requesting PSAP.481
189.
Finally, we note that commenters generally support the delivery of C/U data to PSAPs
using a consistent format.482 As discussed above, we believe that consistency in the delivery of C/U data
will promote PSAP call-takers’ ability to more readily evaluate the C/U data being delivered. We
473

Verizon Comments at 30-31.

474

Sprint Comments at 20; iCERT Reply Comments at 2-3.

475

CSRIC VoLTE Report at 7.

476

Id.

477

See, e.g., Rx Networks Comments at 16 (generally indicating that “the cost of implementing this requirement is
low given the technology available today.”).
478

47 C.F.R. § 20.18(h)(3).

479

Letter from Allison M. Jones, Counsel-Legal/Government Affairs, Sprint Corporation, to the Marlene H. Dortch,
Secretary, Federal Communications Commission, PS Docket No. 07-114 (filed Sept. 30, 2013), Attachment at 9, 11,
13, 15, 17 (Sprint Sept. 30, 2013 Ex Parte Letter).
480

47 C.F.R. § 20.18 (h)(3).

481

All SSPs, including LECs, must continue to provide the technical capabilities and any modifications necessary to
ensure that PSAPs receive C/U data in accordance with our requirements. See generally Sprint Comments at 20
(indicating that PSAPs may not be receiving C/U data “because the LEC S/R may be truncating it or the PSAP may
have turned off such functionality.”).
482

NENA Comments at 9; Sprint Comments at 20. See also NASNA Comments at 13 (“the format of C/U
requirements should [not] differ for indoor versus outdoor calls [as this] would complicate its display at the
PSAP.”).

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therefore urge stakeholders to work together to develop a consistent format for the delivery of C/U data
that considers the different capabilities of PSAPs to receive both geodetic and dispatchable location
information.483 We also encourage the public safety community to continue to take measures to ensure
that PSAP call-takers can fully benefit from the availability of C/U data, including obtaining upgraded
CPE and programming, as well as providing relevant education and training.
D.

Provision of Live 911 Call Data

190.
Background. The Third Further Notice sought comment on whether the Commission
should require providers to periodically report E911 Phase II call tracking information,484 and if so, on the
scope of information that should be reported.485 Numerous commenters support this proposal.486 For
instance, Verizon submits that such data could be “helpful in evaluating… delivery issues associated with
particular PSAPs, or in assessing if a location solution faces particular topology and RF challenges in a
particular geographic area.”487 NextNav submits that reporting the TTFF, yield, and type of technology
used to obtain a location fix should be sufficient to evaluate whether a CMRS provider’s performance is
consistent with test bed performance.488 RWA, however, contends that “the cost of providing the FCC
with call tracking information is high,” with “little certainty” as to its utility to the Commission.489
191.
Discussion. We require all CMRS providers to collect and retain for two years 911 call
tracking data for all wireless 911 calls placed on their networks. This requirement is separate from, and in
addition to, the provisions for quarterly reporting of live call data by CMRS providers in the six test cities
as discussed in Section III.B.5.b above, though for CMRS providers in the six test cities, some of the data
will overlap. Aside from those quarterly aggregate reporting requirements, we do not require CMRS
providers to report general call tracking data. However, upon request of a PSAP within a CMRS
provider’s service area, the CMRS provider must provide the PSAP with call tracking data for all 911
calls delivered to that PSAP.490 The call tracking data should include, but need not be limited to: (1) the
date, time, and length of each call; (2) the class of service of the call (i.e., whether a call was delivered
with Phase I or Phase II information, or other type of information); (3) the percentage of calls lasting 30
seconds or more that achieved a Phase II-compliant fix;491 (4) confidence and uncertainty data for each

483

See, e.g., Roadmap, at 5, Sec. 2(d)(iii) (concerning “standards activities to operationalize the display of
dispatchable location in pre NG-911 PSAPs”). Similarly, we encourage stakeholders to develop a consistent format
and approach for the delivery of C/U data for vertical location information. See T-Mobile Reply Comments at 15
(concerning the possibility that vertical location information may have an independent uncertainty value, “[a]ll
PSAP interfaces and PSAP operational procedures may not support presentation of vertical location uncertainty
information”).
484

Third Further Notice, 29 FCC Rcd at 2437-38 ¶ 169.

485

Id. at 2437-38 ¶¶ 169-70.

486

APCO Comments at 8; CALNENA Comments at 2; NARUC Comments at 3; NASNA Comments at
13(suggesting annual reports that “break down . . . how many calls are delivered as Phase I vs. Phase II”); BRETSA
Reply Comments at 4, 7; Consumers Union Reply Comments at 2; TruePosition Comments at 18.
487

Verizon Comments at 36.

488

NextNav Comments at 56.

489

RWA Comments at 8.

490

See infra Section III.B.5.c. In light of differing PSAP capabilities, a PSAP may request that the CMRS provider
make this information available to the PSAP in the aggregate or in real time. CMRS providers should accommodate
such requests, in order to allow PSAPs access to call tracking information in whatever format best suits their needs
and capabilities.
491

This percentage would compare the number of calls that generate requisite location information within the
required TTFF of 30 seconds to the total number of 911 calls lasting 30 seconds or more.

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call; and (5) the positioning source method used for determining a location fix.492 In order to comply with
this requirement and to be able to provide such data upon individual PSAP request, CMRS providers must
collect data on all 911 calls throughout their service area. Some commenters suggest that delivering this
additional information in real time may be confusing to PSAP call-takers,493 but our requirement requires
only that CMRS providers collect this information; the PSAP must request to receive some or all of the
data in real time, or in the aggregate on a monthly or quarterly basis.
192.
In sum, our call tracking requirements will empower multiple stakeholders to monitor
and ensure that location information is compliant with our E911 requirements, and will provide PSAPs
and CMRS providers with an objective set of data that can help inform decision-making in the event of a
service issue or dispute between the parties as to E911 compliance.494 In this regard, our call tracking
requirement will serve to encourage transparency, accountability, and cooperation among stakeholders.495
E.

Outdoor Compliance Testing and Reporting

193.
Background. In the Third Further Notice, we proposed that periodic testing would be
necessary as providers upgrade their networks and migrate to handset-based technologies.496 We also
sought comment on the recommendations set forth in CSRIC WG3’s Outdoor Location Accuracy
Report.497 CSRIC WG3’s central recommendation was that “[a]lternative testing methods replace full
compliance testing” every 24 months, using a testing scheme that rested on certain ATIS Technical
Reports.498 Subsequently, CSRIC IV WG1 found the “location performance with VoLTE to be slightly
better than or equivalent to 2G and 3G performance,” and recommended that “these expectations should
be validated via the maintenance testing methodology, including representative testing or ‘spotchecking,’” as previously recommended by CSRIC WG3.499

492

As new technologies enter the E911 ecosystem, we recognize that it may not be immediately feasible to
incorporate the new technology into the call tracking system. See Verizon Comments at 31 (contending that
identifying the location technology “is a more appropriate subject for standards or best practices . . . , given rapidly
evolving wireless technology”). We do not require CMRS providers to deliver information on the type of location
technology used to provide a location fix with active 911 calls unless (1) a PSAP specifically requests this data, and
(2) it is technically feasible to do so.
493

BRETSA Comments at 29; T-Mobile Comments at 21; Rx Networks Comments at 17.

494

See infra Section III.B.5.b.

495

See, e.g., TruePosition Comments at 18.

496

Third Further Notice, 29 FCC Rcd at 2440-41 ¶ 178.

497

In the Third Report and Order, the Commission concluded that periodic testing should be implemented, but
tasked CSRIC with recommending how it should best be implemented. See Third Report and Order, 26 FCC Rcd at
10088 ¶ 34 (stating that “requiring CMRS providers to periodically test their outdoor periodic testing requirements
were important to ensure location accuracy… is important to ensure that…location accuracy requirements are being
met”; and that “[t]he lack of available data has also made it difficult to assess the effects of emerging technologies
on location accuracy results….”).
498

Third Further Notice, 29 FCC Rcd at 2441 ¶ 179. The ATIS Reports set forth best practices and alternative
testing concepts. See id. at 2440-41, ¶ 178 & n.384 (citing ATIS Technical Report numbers 0500001 (High Level
Requirements for Accuracy Testing Methodologies), 0500009 (High Level Requirements for End-to-End Functional
Testing), 0500011 (Define Topologies & Data Collection Methodology), 0500010 (Maintenance Testing), and
0500013 (Approaches to Wireless Indoor Location)).
499

CSRIC VoLTE Report at 17. The Commission tasked CSRIC IV WG1 with examining the extent to which
CSRIC WG3’s recommendations would for reconfiguring to VoLTE platforms. See id. at Sec. 1.1, 3.

Federal Communications Commission

FCC 15-9

194.
Public safety commenters support the periodic testing proposal and suggest that testing
requirements should cover both indoor and outdoor location accuracy performance.500 For instance,
APCO agrees with the recommendations in the CSRIC WG3 report and “urg[ed] the Commission to
adopt appropriate rules to implement those recommendations.”501
195.
CMRS providers oppose the Commission’s proposal as costly and unnecessary.502 For
example, RWA and CCA oppose periodic testing as burdensome on small rural CMRS providers.503
However, both RWA and CCA submit that periodic testing is appropriate in case of substantial network
changes.504
196.
Discussion. We believe that conducting periodic testing continues to be appropriate to
ensure compliance with outdoor location accuracy parameters. CMRS providers’ efforts to measure for,
and ensure continuing compliance with, the Commission’s outdoor-based location accuracy requirements
are critical to public safety, particularly as new networks and technologies are implemented.505 Further,
we find that periodic testing will support the reporting of outdoor call data that is included in the
Roadmap as part of the live call data.506 Because CMRS providers will blend all 911 call data, CMRS
providers should incorporate an approach to test for compliance with the current outdoor-based location
accuracy standards. For instance, CMRS providers may need to undertake drive testing in certain
counties or PSAP service areas where they have migrated to VoLTE and that are outside the six test
regions.507
197.
While we do not codify any particular approach, we find that the ongoing maintenance
testing framework set forth in the CSRIC III WG3 and CSRIC IV WG1 recommendations provides a
reasonable and adequate basis for ensuring continued compliance with our E911 location accuracy
requirements. We urge CMRS providers to undertake periodic testing to ensure continued compliance
accordingly. Moreover, such ongoing testing enables CMRS providers to implement testing protocols
500

NENA Comments at 27 (submitting that carriers who certify, on the basis of periodic testing, that they meet the
revised outdoor location accuracy standards and use one or more certified technologies to reach the [adopted] indoor
standards . . . should be rebuttably presumed to be in compliance . . . .”). See also NASNA Comments at 4 (asking
the Commission “to consider expanding the test bed for outdoor location accuracy compliance, as well”).
501

APCO Comments at 9.

502

Verizon Comments at 33 (viewing the proposed testing requirement as “micromanag[ing] [testing] processes”
and submitting that Verizon “already tests 911 functionalities . . . after significant changes in accordance with
existing best practices . . . .”). See also Sprint Comments at 21 (mandated testing and reporting “would further
constrain limited resources . . . when carriers are focused on other important public safety initiatives, including textto-911 and Next Generation 9-1-1”); T-Mobile Comments at 20 (contending that, after a demonstration of
compliance through the test bed process, . . . periodic compliance testing should not be required”). See also
TruePosition Comments at 19.
503

RWA Comments at 8 (opposing a requirement for periodic testing every 24 months and contending that
“[t]esting accuracy compliance on a periodic basis is extremely burdensome, particularly for small rural carriers”).
RWA asserts that one of its members estimates “the cost of each test to be in the neighborhood of $100,000.” Id. &
at note 8. See also CCA Reply Comments at 17.
504

RWA Comments at 5 (asserting that “only substantial network changes, such as deployment of a new technology,
or vendor, or frequency band chances, should warrant re-testing”); CCA Reply Comments at 17 (supporting a
requirement for retesting only “upon the occurrence of a substantial network change”).
505

See, e.g., Third Report and Order, 26 FCC Rcd at 10088 ¶ 36 (finding that periodic testing is important to ensure
that test data and accuracy performance do not become obsolete as a result of environmental changes and network
reconfigurations by CMRS providers as they implement new technologies).
506

Roadmap at Sections 4(a) and (c).

507

The Roadmap indicates that the available data used for blending indoor and outdoor calls will come “from a test
bed and/or drive test performance.” See Roadmap at Section 4(c).

Federal Communications Commission

FCC 15-9

more efficiently and without the cost burdens associated with periodic testing pursuant to a mandatory,
established timetable (e.g., every two years).508 Consistent with CSRIC’s recommendations, CMRS
providers should conduct testing upon any significant technology changes or upgrades to their networks,
including those changes accompanying the deployment of VoLTE networks. As CSRIC IV WG 1
emphasizes, “the goal of maintenance testing is to identify a method that verifies continued optimal
performance of E9-1-1 location systems at the local level.”509 This recommended testing protocol
includes several components, including: (1) Key Performance Indicators (KPIs) that “are routinely
monitored to help identify instances where system performance has degraded”; and (2) “[s]pot-checking
using empirical field-testing . . . on an as needed basis, for example, as determined by KPI monitoring or
legitimate performance concerns from a PSAP.”510 We find that this emphasis on KPI testing will provide
CMRS providers with a testing approach that they can apply in a variety of circumstances. Moreover,
this ongoing testing approach provides CMRS providers with the means to validate latency (TTFF) and
C/U Data, as standardized in the rule changes we adopt today.511
198.
Finally, consistent with our views on KPI testing, we are revising the Commission’s
outdoor requirement for C/U data, which currently specifies that “[o]nce a carrier has established baseline
confidence and uncertainty levels in a county or PSAP service area . . . additional testing shall not be
required.”512 We remove the language excluding additional testing. Although CSRIC III WG3 stated that
“[u]ncertainty estimates, when taken on average over time, can indicate a trend that may reflect continued
proper system operation or system problems,”513 CSRIC III WG3 also noted the importance of C/U data
for monitoring location accuracy as one part of a CMRS providers testing program for other KPIs.514 As
discussed above, KPI testing should continue as part of CMRS providers’ best practices, along with other
recommended testing procedures, such as spot-testing.
F.

Roaming Issues

199.
The Third Further Notice sought comment on whether the provision of Phase II
information continues to be a concern for consumers when they are roaming, or whether this concern has
508

Third Further Notice, 29 FCC Rcd 2430-31 ¶ 148. CSRIC III WG3 found that costs for testing can be high. For
instance, CSRIC notes that the deployment of field test resources can range from $250 to $1000 per cell site, and
that, for testing systems with the capability to monitor Key Performance Indicators (KPIs), the annual costs “to
maintain reporting and data storage” range from $500,000 to $1,500,000 for a large network. CSRIC observes,
however, that “[l]imited resources are best utilized through a systematic method of maintenance which utilizes other
available performance indicators and simplifying assumptions, in addition to empirical testing.” See Outdoor
Location Accuracy Report at 25.
509

CSRIC VoLTE Report at 15.

510

CSRIC VoLTE Report at 17 (also stating that “Empirical data for maintenance testing may be collected
incrementally over time.”). See Outdoor Location Accuracy Report at 4-5, (referencing, e.g., ATIS Technical
Reports ATIS-0500001, ATIS-0500010; and recommending monitoring KPIs and conducting spot-checking); at
Sec. 5.1.2., at 16 (concerning spot-checking: where “county-level compliance has been certified to meet accuracy
requirements, a systematic method of ‘spot-checking’ representative areas that have previously been tested and
shown compliant can be employed to verify that changes (such as a different radio access network) have not resulted
in any significant deviations from expected performance levels.”).
511

WG3 reported that performance testing systems afford the capability to monitor KPIs, including yield, latency
and uncertainty estimate trends. See Outdoor Location Accuracy Report at 20-21.
512

47 C.F.R. § 20.18(h)(3) (stating that “ongoing accuracy shall be monitored based on trending of uncertainty
data…”).
513

Outdoor Location Accuracy Report at 22 (basing the finding on an assessment that “uncertainty estimates on a
call-by-call basis are not a reliable substitute for empirical location accuracy testing.”).
514

Indoor Location Test Bed Report at 39 (“in the context of location system testing in general (not only indoors) the
results provide an indication of how well a location system under test is performing in a certain environment.”).

Federal Communications Commission

FCC 15-9

been addressed by the evolution of location technology.515 Specifically, we invited comment on whether
the implementation of our indoor location proposals would create any challenges in the roaming context
that the Commission should address.516 The few comments filed generally indicate that the migration to
VoLTE networks should resolve the roaming issue because it is probable “that all emergency calls
(routing and location) will either be handled by the visited network or through a location roaming
scenario.”517 As TruePosition submits, “it is entirely likely that complementary technologies will exist
and operate side-by-side in a given city, town or county.”518
200.
After considering the views of the commenters, we refrain from taking action with
respect to roaming at this time. We believe the better course is to monitor progress on the roaming issue
as CMRS providers fully deploy VoLTE, and to examine any problems that may arise during this
implementation process. We reserve the right to take action in the future, if necessary, to ensure that
accurate location information is provided for wireless calls to 911 while roaming.
V.

PROCEDURAL MATTERS
A.

Accessible Formats

201.
To request materials in accessible formats for people with disabilities (braille, large print,
electronic files, audio format), send an e-mail to [email protected] or call the Consumer & Governmental
Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (TTY).
B.

Regulatory Flexibility Analysis

202.
As required by the Regulatory Flexibility Act of 1980, see 5 U.S.C. § 604, the
Commission has prepared a Final Regulatory Flexibility Analysis (FRFA) of the possible significant
economic impact on small entities of the policies and rules addressed in this document. The FRFA is set
forth in Appendix C.
C.

Paperwork Reduction Analysis

203.
This Fourth Report and Order contains proposed new information collection
requirements. The Commission, as part of its continuing effort to reduce paperwork burdens, invites the
general public and OMB to comment on the information collection requirements contained in this
document, as required by Paperwork Reduction Act (PRA). In addition, pursuant to the Small Business
Paperwork Relief Act of 2002,519 we seek specific comment on how we might “further reduce the
information collection burden for small business concerns with fewer than 25 employees.”520
D.

Congressional Review Act

204.
The Commission will send a copy of this Fourth Report and Order in a report to be sent
to Congress and the Government Accountability Office pursuant to the Congressional Review Act
(CRA), see 5 U.S.C. § 801(a)(1)(A).
VI.

ORDERING CLAUSES

205.
IT IS FURTHER ORDERED, pursuant to Sections 1, 2, 4(i), 7, 10, 201, 214, 222,
251(e), 301, 302, 303, 303(b), 303(r), 307, 307(a), 309, 309(j)(3), 316, 316(a), and 332, of the
Communications Act of 1934, 47 U.S.C. §§ 151, 152(a), 154(i), 157, 160, 201, 214, 222, 251(e), 301,
515

Third Further Notice, 29 FCC Rcd at 2442 ¶ 183.

516

Id. at 2443 ¶ 184.

517

TCS Comments at 30.

518

TruePosition Comments at 14.

519

Pub. L. No. 107-198.

520

44 U.S.C. § 3506(c)(4).

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FCC 15-9

302, 303, 303(b), 303(r), 307, 307(a), 309, 309(j)(3), 316, 316(a), 332; the Wireless Communications and
Public Safety Act of 1999, Pub. L. No. 106-81, 47 U.S.C. §§ 615 note, 615, 615a, 615b; and Section 106
of the Twenty-First Century Communications and Video Accessibility Act of 2010, Pub. L. No. 111-260,
47 U.S.C. § 615c, that this Fourth Report and Order is hereby ADOPTED.
206.
IT IS FURTHER ORDERED that Part 20 of the Commission’s Rules, 47 C.F.R. Part 20,
IS AMENDED as specified in Appendix D, effective 30 days after publication in the Federal Register,
except that those amendments which contain new or modified information collection requirements that
require approval by the Office of Management and Budget under the Paperwork Reduction Act WILL
BECOME EFFECTIVE after the Commission publishes a notice in the Federal Register announcing such
approval and the relevant effective date.
207.
IT IS FURTHER ORDERED that the Final Regulatory Flexibility Analysis in Appendix
C hereto IS ADOPTED.
208.
IT IS FURTHER ORDERED that, pursuant to Section 801(a)(1)(A) of the Congressional
Review Act, 5 U.S.C. § 801(a)(1)(A), the Commission SHALL SEND a copy of this Report and Order to
Congress and to the Government Accountability Office.
209.
IT IS FURTHER ORDERED that the Commission’s Consumer and Governmental
Affairs Bureau, Reference Information Center, SHALL SEND a copy of this Fourth Report and Order,
including the Final Regulatory Flexibility Analysis, to the Chief Counsel for Advocacy of the Small
Business Administration.
FEDERAL COMMUNICATIONS COMMISSION

Marlene H. Dortch
Secretary

Federal Communications Commission

FCC 15-9

APPENDIX A
List of Commentersi
In response to Wireless E911 Location Accuracy Requirements, Public Notice, PS Docket No. 07-114, 29
FCC Rcd 3203 (rel. Mar. 28, 2014) (seeking comment on Third Further Notice); Order, PS Docket No.
07-114, 29 FCC Rcd 5923 (rel. Jun. 4, 2014) (extending comment deadlines):
In response to Wireless E911 Location Accuracy Requirements, Public Notice, PS Docket No. 07-114, 29
FCC Rcd 3203 (rel. Mar. 28, 2014) (seeking comment on Third Further Notice); Order, PS Docket No.
07-114, 29 FCC Rcd 5923 (rel. Jun. 4, 2014) (extending comment deadlines):
Comments
AARP, Inc. (AARP)
Alexandra Folmer
Alfred Conklin
Alliance for Retired Americans
Allison K.
Alyssa Juliano
Alzheimer’s Association
American Heart Association
Amish Dangodara
Andrea Schnietz
Andrew Anderson
Angelo Salvucci, MD
Ann Cude
Anonymous
Anthony Santoro
Association of Public-Safety Communications
Officials-International, Inc. (APCO)
Arlene Edwards
Arnold Champlain
Ashlie Bowen
AT&T Services, Inc. (AT&T)
Bernadette House
Betty Wallace
Beverly Conroy
Beverly Harris
Bill Fries
Blooston Rural Carriers
Bobby Robertson
Bosch Sensortec (Bosch)
Boulder Regional Emergency Telephone Service
Authority (BRETSA)
Brandon Cobb
Brendhan Sears
Brett Kruse
Brian Schoen
Brieanne Fluewelling
C. Born
California NENA (CALNENA)

Cameron Gardin
Carol Glaws
Cassandra Braswell
Chantelle Tait
Charles Daniels
Charles Udriet
Charlotte Benton
Cherryl Askew
Chris Kargl
Christa Laub
Christina Mendrinos
Christine Alvarado
Christine Carbone
Cindy Guarnieri
Cindy Thies
Cisco Systems, Inc. (Cisco)
Clair Childers
Cliff Berman
Competitive Carriers Association (CCA)
Corey Mock
Crissy Livengood
CTIA-The Wireless Association (CTIA)
D. Goldsmith
Dan Simonelli
Daniel Hulbert
Darren Strickland
Dave Maloney
Dave Mount
David Carlson
David Helmer
David Kaus
David Schneider
David Strompf
Debra Danna
Dee Emrich
Denise Driscoll
Diana McNair
Dianne Sullivan
78

Federal Communications Commission
Dina Benyo
Don Hawkins
Donna Baer
Donna Daniels
Dorothy Vyskocil
Douglas DeCarlo
Ed Avila
Eileen Black
Ellen Sweets
Emily Bartow
Emily Hendricks
Emmanuela Bowman
Eric Singer
Ericsson
Fairfax County (VA) Dept. of Public Safety
Communications (Fairfax County)
FindMe911 Coalition (FindMe911)
Fran Giboney
Frances Brown
Frances Rove
Frederic Chrislip
Gary Chase
Gene Cox
General Communication, Inc.
George Huckins
Gil Carpenter
Gilberto Rivera
Ginny Hemmeter
Glenda Roddy
Greg Liesenfelt
H. Horne
Helena M.
Herb Sayas
International Association of Chiefs of Police
(IACP) and National Sheriffs’ Association
(NSA)
Information Technology Industry Council (ITI)
International Association of Fire Chiefs (IAFC)
International Association of Fire Fighters (IAFF)
Intrado, Inc. (Intrado)
iPosi, Inc. (iPosi)
Jackie Kilby Richards
Jacob McCulley
Jaime Elder
Jan Lindeman
Jan Lutz
Jane Williams
Jean Walsh
Jeffrey Jones
Jennifer Baker
Jennifer Eads

Jessica Aliberti
JeVerna Haynes
Jill Anderson
Jill Cyr
Jim Snee
Joan Churton
Joan Dougherty
Jocelyn Finnegan
Joel Scott Strauss
John Cobb
John E. Warwick
John Glova
John Merklinger
Joyce Marino
Julie Evans
Julie Ponce-Doyle
Julie Spickler
Kami Erland
Karen Roy
Karen Vaughn
Kathey Good
Kathy Bradley
Kay Wapman
Kelley Odom
Kelly Donoghue
Kenneth Wheelock
Kevin Hall
Kirk Kraft
Kirsten McGovern
Kyle Bracken
Laura Caldwell
Laura Carroll
Laura Colegrove
Laura Jobe
Laurence McNamara
LaVonne Whinery
Leischen Celsur
Leo Kucewicz
Lester Federoff
Lewis Blanchard
Linda Brown
Linda I. Hixson
Linda Wolschlager
Lisa J. Hoffmann
Lisa Johnson
Lisa Ross
Lydia Hay
Lynda Marquardt
Lynn Signorelli
M. Herndon
Marc Simon
79

FCC 15-9

Federal Communications Commission
Maria Lemonds
Marjo Nordhorn
Mark Leicester
Mary Hill
Mary Jean Collins
Mary Longstreth
Mary Van Son
Mashell Colwell
Matthew Berg
Matthew Felegy
Maureen Anderson
Maureen Walsh
Meghan Sugrue
Meghana Khanolkar
Melanie Binkley
Melanie Cantrell
Me'Lissa King
Melissa Waller
Michael McLeod
Michael Rostagno-Lasky
Michael Rowland
Michael Woolever
Michelle Kerr
Mike Hancock
Mobile Future
Monika Winchester
Monty King
Mordy Kaplinsky
Motorola Mobility LLC (Motorola)
Murray McAndrew
Nancy Cha
Nancy Dolman
Nancy Stamm
Nancy Williams
Naomi Moody
Nathan Lee
Nathan Watts
National Association of Regulatory Utility
Commissioners (NARUC)
National Association of State Emergency
Medical Services EMS Officials
(NASEMSO), National Association of EMS
Physicians (NAEMSP), National Association
of EMTs (NAEMT), and National EMS
Management Association (NEMSA)
National Association of State 911
Administrators (NASNA)
National Public Safety Telecommunications
Council (NPSTC)
Nebraska Public Service Commission (NPSC)
NENA: The 9-1-1 Association (NENA)

FCC 15-9

NextNav, LLC (NextNav)
Nick Dickens
Nicole Schnittger
Norris Williams
NTCA–The Rural Broadband Association
(NTCA)
Pam Pfeifer
Pamela Dodd
Patricia Mensler
Pattie Johnston
Patty Stokes
Paul Gaultieri
Paul Stevens
Paula Washam
Peter Voorhees
Phyllis Meyer-Parthermore
Polaris Wireless, Inc. (Polaris)
QUALCOMM Incorporated (QUALCOMM)
Ray Jagger
Raymond Nolan
Rea Brown
Rebecca Tucker
Regina Nelson
Regina Schulter
Ricardo Reyes
Richard Hanson
Richard Loveday
Robert Kaiser
Robert Knott
Robert Oenning
Robert Wells
Roberta Tomaino
Robin Moore
Robin Murphy
Rosalinda Rodriguez
Rural Wireless Association, Inc. (RWA)
Rx Networks Inc. (Rx Networks)
Samuel Johnson
San Francisco Dept. of Emergency
Management, Div. of Emergency
Communications (DEMSF)
Sandra Martine
Sandra Reed
Shari Farrar
Sheri Lemming
Sheryl King
Sonja Yefsky
Sprint Corporation (Sprint)
Stanley Kite
Stephanie Newton
Stephen A. Cannon
80

Federal Communications Commission
Stephen Graff
Stephen Makovec
Steve Graff
Sue and Tom W.
Susan Crimmins
Susan Marie Frontczak
Suzanne Kesel
Tammy Grant
Tania Cole
TeleCommunication Systems, Inc. (TCS)
Telecommunications for the Deaf and Hard of
Hearing, Inc. (TDI); National Association of
the Deaf (NAD); Association of LateDeafened Adults, Inc. (AL-DA); Cerebral
Palsy and Deaf Organization, Inc. (CPDO);
California Coalition of Agencies Serving the
Deaf and Hard of Hearing (California
Coalition); Deaf and Hard of Hearing
Consumer Advocacy Network (Consumer
Advocacy Network), and Technology Access
Program, Gallaudet University (Gallaudet
TAP)
Telecommunications Industry Association (TIA)
Teresa Hamilton
Terri Brooks
Texas 911 Alliance, Texas Commission on

FCC 15-9

State Emergency Communications (Texas
CSEC), and Municipal Emergency
Communication Districts Association
(MECDA) (Texas 911 Entities)
Tim Claflin
Tim Zagorski
Tina Wall
T-Mobile USA, Inc. (T-Mobile)
Tracey DeRosa
Tracey Kesler
Trina Beck
Trish Brown
TruePosition, Inc. (TruePosition)
Ursula Freer
Valerie Kokoszka
Verizon and Verizon Wireless (Verizon)
Vicki Dowell
Victor Kordish
Victor Martin
Voiance Language Services
Wiliam Schoene
Willa Strauss
William Powell
William D.
Yvette Palmer

Reply Comments
Alliance for Telecommunications Industry
Solutions (ATIS)
APCO
AT&T
BRETSA
CCA
Consumers Union
CTIA
Find Me 911
IACP & NSA
iCERT
IAFC
iPosi
IAFC/NFPA Metropolitan Fire Chiefs
Association
Motorola
NASEMSO, NAEMSP, NAEMT, and NEMSA
NENA
NPSTC

NextNav
NTCA
QUALCOMM
San Francisco Fire Department, IAFF, and
DEMSF
SouthernLINC Wireless (SouthernLINC)
Sprint
TDI, NAD, AL-DA, CPDO, California
Coalition, Consumer Advocacy Network,
American Association of the Deaf-Blind, and
Rehabilitation Engineering Research Center
on Telecommunications Access
TIA
Texas 911 Entities
T-Mobile
Transit Wireless LLC
TruePosition
Verizon

Ex Parte Submissions
4G Americas
AdGen Telecom Group, Inc.

American Heart Association
Angelo Salvucci, M.D.
81

Federal Communications Commission
ASL Services Holdings LLC
AT&T
Azert LLC
Bonnie Campbell
Bosch
CALNENA, Alliance for Retired Americans,
Angelo Salvucci, M.D., DEAF Seniors of
America, Consumer Advocacy Network,
California Coalition, American Association of
the Deaf-Blind, NAD, and CPDO
Cisco
CCA
Congressional Fire Services Institute (CFSI)
Consumer Action
CTIA
Denise Amber Lee Foundation
Find Me911
HTC America, Inc.

FCC 15-9

IAFF
International Union of Police Associations
Intrado
NARUC
NextNav
Polaris
Public Knowledge
QUALCOMM
Rural Broadband Policy Group
SouthernLINC
TCS
TDI
TechnoCom Corporation
Texas 911 Entities
Texas CSEC
T-Mobile
TruePosition
Verizon

In response to Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114, DA 14-1680,
Public Notice (rel. Nov. 20, 2014) (seeking comment on Roadmap); DA 14-1794, Order (rel. Dec. 9,
2014) (extending Roadmap comment deadline):
Comments
AARP
Adam Welland
Al Studt
Alona Mendoza
American Association of People with
Disabilities, American Foundation for the
Blind, National Council of Independent
Living, United Spinal Association, and World
Institute on Disability
Andy Sayles
Anthony Santoro
APCO
April Schmitt
AT&T
Bob Heck
BRETSA
Bozena Lahtinen
California State Firefighters’ Association
Canyons School Dist., Sandy, UT
Cisco
CCA
Colorado Chapter of NENA
CSR
CTIA
D. Goldsmith
Eddie Burchell, ENP

Enid (OK) Fire Department
FindMe911
Florida Sheriffs’ Association
Garfield County (CO) Emergency
Communications Authority
George DiBlasi
Hampstead (NH) Police Department
iCERT
InLocation Alliance
IAFC
IAFF and CFSI
International Municipal Signal Association
Intrado
iPosi
James Galbreath
John Cipora
Jules McNeff
Kevin S. O'Donnell
Lackawanna County (PA) District Attorney
Andrew Jarbola
Martin P. Montgomery
Minnesota Chiefs of Police
Mobile Future
Motorola Mobility
NARUC
NASEMSO, NAEMSP, NAEMT, and NEMSA
82

Federal Communications Commission
NASNA
National Conference of State Legislatures
National Fraternal Order of Police
National Association of Telecommunications
Officers and Advisors
NPSC
NENA
NextNav
NTCA
Pat Devaney
Pennsylvania Chapter of NENA
Plaistow (NH) Fire Department
Polaris
Public Knowledge, Alvaro Bedoya, American
Civil Liberties Union, Benton Foundation,
Center for Democracy & Technology, Center
for Digital Democracy, Common Sense
Media, Consumer Action, Consumer
Federation of America, Consumer Federation
of California, Consumer Watchdog, Electronic
Frontier Foundation, Electronic Privacy
Information Center, New America
Foundation’s Open Technology Institute,
Privacy Rights Clearinghouse, U.S. PIRG, and
World Privacy Forum
QUALCOMM
Robert G. Oenning
Robert Hawley
San Luis Obispo County (CA) District Attorney
Dan Dow
Sprint
Stafford County (VA) Sheriff’s Office
State of Hawaii Enhanced 911 Board
Stephanie Klenotich
Sue Korlan
TCS
TDI, NAD, AL-DA, CPDO, California
Coalition, Consumer Advocacy Network,
Gallaudet TAP, Hearing Loss Association of
America, Deaf Seniors of America, and
American Association of the Deaf-Blind
TIA
Terry Skinner
Texas 911 Entities
Thomas J Smoot
T-Mobile
Tom Lackey, California Assembly Member
TruePosition
Valarina Johnson
Verizon
William P. Ostrander, Jr.

Woburn (MA) Police Department

FCC 15-9

Federal Communications Commission

FCC 15-9

Reply Comments
American Ambulance Association
Angelo Salvucci, MD
APCO
AT&T
Computer & Communications Industry
Association (CCIA)
CTIA
IACP, IAFC, NASEMSO, NSA, and National
Volunteer Fire Council
iPosi, Inc.
Mobile Future

NENA
NextNav
PCIA - The Wireless Infrastructure Association
RWA
SouthernLINC
Sprint
TCS
Texas State Troopers' Association
T-Mobile
TruePosition, Inc.
Verizon

Ex Parte Submissions
4G Americas
Aaron Pippin
Adair County (MO) Sheriff Robert Hardwick
Alma Safety
American Civil Liberties Union, American
Library Association, Benton Foundation,
Brennan Center for Justice, Center for
Democracy & Technology, Center for Digital
Democracy, Consumer Action, Consumer
Federation of America, Consumer Federation
of California, Consumer Watchdog,
Defending Dissent Foundation, Electronic
Frontier Foundation, New America
Foundation’s Open Technology Institute,
Privacy Rights Clearinghouse, Public
Knowledge, U.S. PIRG, and World Privacy
Forum
APCO
Arkansas Ambulance Association
Arkansas Sheriffs’ Association
Armstrong Ambulance
Associated Fire Fighters of Illinois
Atlanta (MO) Volunteer Fire Department
AT&T
Bath (ME) Vol. Fire Department
BRETSA
Brian C. Schu
CALNENA
Carol A. Ferratella
Carolyn Allen
Cayuga County (NY) E-911 Communications
Chief Thomas L. McPherson Jr.
Chris Parsons
Cook County (IL) Sheriff Tom Dart
County Judges Association of Arkansas
CTIA
David Cook
Davlynn Racadio, Pres., APCO/NENA Joint
Pacific Chapter

Douglas County (NE) Sheriff Timothy Dunning
Fairfax County (VA) Emergency
Communications, Steve Souder
Florida Police Benevolent Association, Inc.
Florida Sheriffs Association
Fraternal Order of Police of Ohio, Inc.
Fraternal Order of Police, Columbus, OH
Fraternal Order of Police, Dayton, OH
Graham Fountain
Green Bay (WI) Police Chief Tom Molitor
Greer County (OK) Emergency Management
Hon. Anthony D'Amelio, Connecticut State Rep.
Hon. Arnie Roblan, Oregon State Senate
Hon. Charles Anderson, Texas State Rep.
Hon. Greg Smith, Kansas State Senate
Hon. Jay Hoffman, Illinois State Rep.
Hon. Jeff Dial, Arizona State Senate
Hon. Jon Woods, Arkansas State Senate
Hon. N. Daughtry, North Carolina State Rep.
Hon. P O’Malley, Lackawanna Co. (PA) Comm.
Hon. Scott Martin, Lancaster Co. (PA) Comm.
Hon. Stan Klitzman, Waller Co. (TX) Comm.
Hon. Terry Seitz, Mayor, Jasper, IN
Illinois NENA
Indiana NENA
Indianapolis (IN) EMS
James Franklin
James Patton
Jane Lynch
Jim Arts
Jim Sabin
John Giese
Johnston County (NC) Sheriff Steve Bizzell
Lee Vasquez
Lewis County (NY) Sheriff Michael Carpinelli
Liberty Media Corporation
Lowndes County (AL) E911
Macon County (MO) Enhanced 911
Madison County (OH) Sheriff Jim Sabin
84

Federal Communications Commission
Madison County (NY) Emergency
Communications
Maine NENA
Maricopa County (AZ) Sheriff’s Office
Marion County (IN) Sheriff John Layton
Mesa (AZ) Fire and Medical Department
Michael Lincoln
Michigan NENA
Middle Smithfield Township (PA) Emergency
Coordinator
Midway (FL) Police Department
Mike Kundert
Minnesota Professional Fire Fighters
Minnesota Sheriffs’ Association
Mississippi Center for Police & Sheriffs
Missouri NENA
NARUC
National Asian Peace Officers Association
NENA
New Haven (CT) Police Department
New Jersey NENA
New York State 911 Coordinators Association
NewYork State NENA
NextNav
Oregon Coalition Against Domestic and Sexual
Violence
Orleans County (NY) Sheriff’s Office
Oswego County (NY) Emergency
Communications Department
Philip Byers
Polaris
Public Knowledge
Rivada Networks
Rochester (NY) Emergency Communication

FCC 15-9

Department
Shawnee County (KS) Sheriff’s Office
SouthernLINC
Spotsylvania County (VA) Sheriff's Office
Sprint
Stephen P. Martini, ENP
Steuben County (NY) Fire Service
Steuben County (NY) Legislature:
Hon. Brian Schu
Hon. Carol Ferratella
Hon. Gary D. Swackhamer
Hon. Gary Roush
Hon. Joseph J. Hauryski, Chair
Hon. K. Michael Hanna
Hon. Patrick F. McAllister
Hon. Scott J. Van Etten
Steuben County (NY) Manager Mark Alger
Steve Davidson
Steve Saltsman
Steven Mael
Steven Pickett
Stoughton (WI) Police Lt. Patrick Conlin
Sunsight Instruments, LLC
TDI
Tennessee Emergency Number Association
Texas State Troopers Association
Thom Goolsby
Thomas E Nesbitt
T-Mobile
Verizon
Virginia NENA
Wakulla (FL) Senior Citizens Council, Inc.
Windham (NH) Fire Department
Yazoo City (MS) Fire Department

The parties listed in this Appendix filed directly into PS Docket No. 07-114 through the Commission’s Electronic
Comment Filing System (ECFS). We note that a separate email box, [email protected], was set up in
July 2014 to facilitate input from members of the public regarding wireless location accuracy. This email box
contains several thousand identical or near-identical emails with respect to the proposals in the Third Further Notice
and/or the Roadmap. Like the comments listed in this Appendix, these emails have been included in the docket and
can be accessed by following this link: http://appsint.fcc.gov/ecfs/comment_search/input, and inserting “07-114” in
the Proceeding Number box.

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APPENDIX B
List of Top 50 Most Populous Cellular Market Areas1
1. New York-Northern New Jersey-Long
Island, NY-NJ-PA
2. Los Angeles-Long Beach-Santa Ana,
CA
3. Chicago-Joliet-Naperville, IL-IN-WI
4. Dallas-Fort Worth-Arlington, TX
5. Philadelphia-Camden-Wilmington, PANJ-DE-MD
6. Houston-Sugar Land-Baytown, TX
7. Washington-Arlington-Alexandria, DCVA-MD-WV
8. Miami-Fort Lauderdale-Pompano
Beach, FL
9. Atlanta-Sandy Springs-Marietta, GA
10. Boston-Cambridge-Quincy, MA-NH
11. San Francisco-Oakland-Fremont, CA
12. Detroit-Warren-Livonia, MI
13. Riverside-San Bernardino-Ontario, CA
14. Phoenix-Mesa-Glendale, AZ
15. Seattle-Tacoma-Bellevue, WA
16. Minneapolis-St. Paul-Bloomington,
MN-WI
17. San Diego-Carlsbad-San Marcos, CA
18. St. Louis, MO-IL
19. Tampa-St. Petersburg-Clearwater, FL
20. Baltimore-Towson, MD
21. Denver-Aurora-Broomfield, CO
22. Pittsburgh, PA
23. Portland-Vancouver-Hillsboro, OR-WA
24. Sacramento--Arden-Arcade--Roseville,
CA

25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
50.

San Antonio-New Braunfels, TX
Orlando-Kissimmee-Sanford, FL
Cincinnati-Middletown, OH-KY-IN
Cleveland-Elyria-Mentor, OH
Kansas City, MO-KS
Las Vegas-Paradise, NV
San Jose-Sunnyvale-Santa Clara, CA
Columbus, OH
Charlotte-Gastonia-Rock Hill, NC-SC
Indianapolis-Carmel, IN
Austin-Round Rock-San Marcos, TX
Virginia Beach-Norfolk-Newport News,
VA-NC
Providence-New Bedford-Fall River,
RI-MA
Nashville-Davidson--Murfreesboro-Franklin, TN
Milwaukee-Waukesha-West Allis, WI
Jacksonville, FL
Memphis, TN-MS-AR
Louisville/Jefferson County, KY-IN
Richmond, VA
Oklahoma City, OK
Hartford-West Hartford-East Hartford,
CT
New Orleans-Metairie-Kenner, LA
Buffalo-Niagara Falls, NY
Raleigh-Cary, NC
Birmingham-Hoover, AL
Salt Lake City, UT

See UNITED STATES CENSUS BUREAU, 2012 Statistical Abstract at Table 20, available at
http://www.census.gov/compendia/statab/2012/tables/12s0020.pdf (last visited Jan. 29, 2015)

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APPENDIX C
Final Regulatory Flexibility Analysis
1.
As required by the Regulatory Flexibility Act of 1980, as amended (RFA),1 an Initial
Regulatory Flexibility Analysis (IRFA) was incorporated into the Third Further Notice of Proposed
Rulemaking in this proceeding.2 The Commission sought written public comment on the proposals in the
Notice, including comment on the IRFA. Any comments received are discussed below. This present
Final Regulatory Flexibility Analysis (FRFA) conforms to the RFA.3
A.

Need for, and Objectives of, the Rules Adopted

2.
In this Fourth Report and Order, the Commission adopts measures that will significantly
enhance the ability of Public Safety Answering Points (PSAPs) to accurately identify the location of
wireless 911 callers when the caller is located indoors, and strengthen existing E911 location accuracy
rules to improve location determination for outdoor as well as indoor calls. These actions respond to
major changes in the wireless landscape since the Commission first adopted its wireless Enhanced 911
(E911) location accuracy rules in 1996 and since the last significant revision of these rules in 2010. As
consumers increasingly replace traditional landline telephony with wireless phones, a majority of wireless
calls are now made indoors, increasing the likelihood that wireless 911 calls will come from indoor
environments where traditional location accuracy technologies optimized for outdoor calling often do not
work effectively or at all. A significant objective of this proceeding is to close the gap between the
performance of 911 calls made from outdoors with similar calls made indoors.
3.
The Commission adopts rules applicable to CMRS providers that reflect technical
feasibility and are technologically neutral, so that providers can choose the most effective solutions from
a range of options. Further, the rules allow sufficient time for development of applicable standards,
establishment of testing mechanisms, and deployment of new location technology in both handsets and
networks, on timeframes that account for the ability of PSAPs to process enhancements in the location
data they receive. In determining the appropriate balance to strike between its requirements and
timeframes, the Commission gave significant weight to the “Roadmap for Improving E911 Location
Accuracy” (Roadmap) that was agreed to in November 2014 by the Association of Public Safety
Communications Officials (APCO), the National Emergency Number Association (NENA), and the four
national wireless CMRS providers,4 as well as the “Parallel Path for Competitive Carriers’ Improvement
of E911 Location Accuracy Standards” (“Parallel Path”) that was submitted by the Competitive Carriers
Association (CCA).5 At the same time, in order to provide greater certainty and accountability in areas

5 U.S.C. § 603. The RFA, see 5 U.S.C. § 601 – 612, has been amended by the Small Business Regulatory
Enforcement Fairness Act of 1996 (SBREFA), Pub. L. No. 104-121, Title II, 110 Stat. 857 (1996).
2

Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114, Third Further Notice of Proposed
Rulemaking, 29 FCC Rcd 2374 (2014) (“Third Further Notice” or “Notice”).
3

5 U.S.C. § 604.

Letter from John Wright, APCO International; Charles W. McKee, Sprint Corporation; Joan Marsh, AT&T
Services, Inc.; Kathleen O’Brien Ham, T-Mobile USA, Inc.; Christy Williams, National Emergency Number
Association; Kathleen Grillo, Verizon Wireless, to Marlene H. Dortch, Secretary, Federal Communications
Commission, PS Docket No. 07-114 (filed Nov. 18, 2014) (Roadmap Cover Letter), Attachment A, “Roadmap for
Improving E911 Location Accuracy” (Roadmap),; see also AT&T, Sprint, T-Mobile, and Verizon Ex Parte Letter at
3 (Addendum) (filed Jan. 21, 2015). Together, the Roadmap and the Addendum are known as the “Amended
Roadmap.”
5

See Competitive Carrier Association Ex Parte Letter, Attachment “Parallel Path” (filed Jan. 16, 2015) and
Competitive Carrier Association Ex Parte Letter (filed Jan. 23, 2015).

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that the Amended Roadmap does not fully address, the rules incorporate “backstop” requirements derived
from the Commission’s original proposals in the Third Further Notice.
4.
The rules the Commission adopts are designed to increase indoor location accuracy in a
commercially reasonable manner by leveraging many aspects of the Amended Roadmap. They do not
change, or seek to change, the commitment that the four nationwide CMRS providers voluntarily entered
into and have already made progress towards. The Amended Roadmap is intended to build confidence in
the technical solutions outlined therein, and it establishes clear milestones to gauge progress and ensure
that if the signatory parties fail to deliver on their commitments, there is clear accountability for the
integrity of location accuracy using metrics adopted at earlier stages in this proceeding. The rules the
Commission adopts are in addition to, not a replacement of, its existing E911 location rules applicable to
outdoor calls, which remain in effect, unless otherwise amended herein. In establishing these
requirements, the Commission’s objective is that all Americans using mobile phones – whether they are
calling from urban or rural areas, from indoors or outdoors – have technology that is functionally capable
of providing accurate location information so that they receive the support they need in times of
emergency.
B.

Summary of Significant Issues Raised by Public Comments in Response to the IRFA

5.
No comments were submitted specifically in response to the IRFA. Nevertheless, small
and rural CMRS providers suggested that compliance with the rules (as proposed in both the Third
Further Notice and the Roadmap) could be burdensome:


Blooston believes “that substantial investments in new E911 equipment that small rural
carriers will be required to make in order to comply with the proposed new E911
requirements will soon become unrecoverable stranded investments when NG911
technology is deployed.”6



CCA is concerned that small and rural CMRS providers may not hold licenses for
spectrum or otherwise operate in the single location defined implied in the Roadmap and
will thus be forced to commit to individualized testing of a particular heightened location
accuracy technology should it utilize any component of their network (such as an RFbased technology), possibly placing a substantial burden on these smaller CMRS
providers.7



Several small and regional CMRS providers argue that it would also be appropriate either
to exclude rural areas from indoor location accuracy requirements, or to phase-in any
requirements.8



Regarding technology-specific costs, Rx Networks proposes establishment of a central
and standardized service to process location requests. Such a clearinghouse solution
would entail a base station almanac of Cell-IDs and Wi-Fi access point locations, and
cost-effective provisioning of A-GNSS and barometric pressure data among CMRS
providers, which could bridge technical gaps while minimizing capital outlays.9

Blooston Comments at 2-3.

CCA Roadmap Comments at 6.

CCA Reply Comments at 12; NCTA Reply Comments at 2; RWA Comments at 6; Blooston Rural Reply
Comments at 2-3; SouthernLINC Wireless Reply Comments at 6.
9

Rx Networks Comments at 4.

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

Small and rural CMRS providers generally believe that live 911 call tracking and
reporting will be overly burdensome for them.10



Regarding outdoor compliance and reporting, RWA and CCA oppose periodic testing as
burdensome on small rural CMRS providers,11 but both agree that periodic testing is
appropriate in case of substantial network changes.12



SouthernLINC Wireless believes that any delays in implementing any adopted rules by
the nationwide carriers will necessarily create downstream delays for regional and rural
carriers that are beyond the smaller carriers’ control.13
Description and Estimate of the Number of Small Entities to Which Rules Will
Apply

6.
The RFA directs agencies to provide a description of and, where feasible, an estimate of
the number of small entities that may be affected by the proposed rules.14 The RFA generally defines the
term “small entity” as having the same meaning as the terms “small business,” “small organization,” and
“small governmental jurisdiction.”15 In addition, the term “small business” has the same meaning as the
term “small business concern” under the Small Business Act.16 A small business concern is one which:
(1) is independently owned and operated; (2) is not dominant in its field of operation; and (3) satisfies any
additional criteria established by the Small Business Administration (SBA).17
7.
Small Businesses, Small Organizations, and Small Governmental Jurisdictions. Our
action may, over time, affect small entities that are not easily categorized at present. We therefore
describe here, at the outset, three comprehensive, statutory small entity size standards.18 First,
nationwide, there are a total of approximately 27.9 million small businesses, according to the SBA.19 In
addition, a “small organization” is generally “any not-for-profit enterprise which is independently owned

RWA Comments at 8 (opposing a requirement for periodic testing every 24 months and contending that “[t]esting
accuracy compliance on a periodic basis is extremely burdensome, particularly for small rural carriers”). RWA
asserts that one of its members estimates “the cost of each test to be in the neighborhood of $100,000.” Id. & n.8.
See also CCA Reply Comments at 17.
12

SouthernLINC Ex Parte Letter at 2 (filed Jan. 23, 2015).

5 U.S.C. §§ 603(b)(3), 604(a)(3).

5 U.S.C. § 601(6).

5 U.S.C. § 601(3) (incorporating by reference the definition of “small business concern” in the Small Business
Act, 15 U.S.C. § 632). Pursuant to 5 U.S.C. § 601(3), the statutory definition of a small business applies “unless an
agency, after consultation with the Office of Advocacy of the Small Business Administration and after opportunity
for public comment, establishes one or more definitions of such terms which are appropriate to the activities of the
agency and publishes such definitions(s) in the Federal Register.”
17

15 U.S.C. § 632.

See 5 U.S.C. §§ 601(3)–(6).

See SBA, Office of Advocacy, available at http://www.sba.gov/sites/default/files/FAQ_Sept_2012.pdf (last visited
Jan. 31, 2014).

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and operated and is not dominant in its field.”20 Nationwide, as of 2007, there were approximately
1,621,315 small organizations.21 Finally, the term “small governmental jurisdiction” is defined generally
as “governments of cities, towns, townships, villages, school districts, or special districts, with a
population of less than fifty thousand.”22 Census Bureau data for 2011 indicate that there were 89,476
local governmental jurisdictions in the United States.23 We estimate that, of this total, as many as 88,506
entities may qualify as “small governmental jurisdictions.”24 Thus, we estimate that most governmental
jurisdictions are small.
1.

Telecommunications Service Entities
a. Wireless Telecommunications Service Providers

8.
Pursuant to 47 C.F.R. § 20.18(a), the Commission’s 911 service requirements are only
applicable to Commercial Mobile Radio Service (CMRS) “[providers], excluding mobile satellite service
operators, to the extent that they: (1) Offer real-time, two way switched voice service that is
interconnected with the public switched network; and (2) Utilize an in-network switching facility that
enables the provider to reuse frequencies and accomplish seamless hand-offs of subscriber calls. These
requirements are applicable to entities that offer voice service to consumers by purchasing airtime or
capacity at wholesale rates from CMRS licensees.”
9.
Below, for those services subject to auctions, we note that, as a general matter, the
number of winning bidders that qualify as small businesses at the close of an auction does not necessarily
represent the number of small businesses currently in service. Also, the Commission does not generally
track subsequent business size unless, in the context of assignments or transfers, unjust enrichment issues
are implicated.
10.
Wireless Telecommunications Carriers (except satellite). This industry comprises
establishments engaged in operating and maintaining switching and transmission facilities to provide
communications via the airwaves. Establishments in this industry have spectrum licenses and provide
services using that spectrum, such as cellular phone services, paging services, wireless Internet access,
and wireless video services.25 The appropriate size standard under SBA rules is for the category Wireless
Telecommunications Carriers. The size standard for that category is that a business is small if it has 1,500
or fewer employees.26 For this category, census data for 2007 show that there were 11,163
20

5 U.S.C. § 601(4).

INDEPENDENT SECTOR, THE NEW NONPROFIT ALMANAC & DESK REFERENCE (2010).

5 U.S.C. § 601(5).

U.S. CENSUS BUREAU, STATISTICAL ABSTRACT OF THE UNITED STATES: 2011, Table 427 (2007).

The 2007 U.S Census data for small governmental organizations are not presented based on the size of the
population in each such organization. There were 89, 476 small governmental organizations in 2007. If we assume
that county, municipal, township and school district organizations are more likely than larger governmental
organizations to have populations of 50,000 or less, , the total of these organizations is 52,125. If we make the same
assumption about special districts, and also assume that special districts are different from county, municipal,
township, and school districts, in 2007 there were 37,381 special districts. Therefore, of the 89,476 small
governmental organizations documented in 2007, as many as 89,506 may be considered small under the applicable
standard. This data may overestimate the number of such organizations that has a population of 50,000 or less. U.S.
CENSUS BUREAU, STATISTICAL ABSTRACT OF THE UNITED STATES 2011, Tables 427, 426 (Data cited therein are
from 2007).
25

U.S. Census Bureau, North American Industry Classification System, Definition of “Wireless
Telecommunications Carriers (except Satellite),” NAICS code 517210, available at http://www.census.gov/cgibin/sssd/naics/naicsrch?code=517210&search=2007%20NAICS%20Search (last visited Jan. 31, 2013).
26

See id. See also 13 C.F.R. § 121.201, NAICS code 517210.

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establishments that operated for the entire year.27 Of this total, 10,791 establishments had employment of
999 or fewer employees and 372 had employment of 1000 employees or more.28 Thus under this category
and the associated small business size standard, the Commission estimates that the majority of wireless
telecommunications carriers (except satellite) are small entities that may be affected by our proposed
action.29
11.
Incumbent Local Exchange Carriers (Incumbent LECs). Neither the Commission nor the
SBA has developed a small business size standard specifically for incumbent local exchange services.
The appropriate size standard under SBA rules is for the category Wired Telecommunications Carriers.
Under that size standard, such a business is small if it has 1,500 or fewer employees.30 Census Bureau
data for 2007, which now supersede data from the 2002 Census, show that there were 3,188 firms in this
category that operated for the entire year. Of this total, 3,144 had employment of 999 or fewer, and 44
firms had had employment of 1000 or more. According to Commission data, 1,307 carriers reported that
they were incumbent local exchange service providers.31 Of these 1,307 carriers, an estimated 1,006 have
1,500 or fewer employees and 301 have more than 1,500 employees.32 Consequently, the Commission
estimates that most providers of local exchange service are small entities that may be affected by the rules
and policies proposed in the Notice. Thus under this category and the associated small business size
standard, the majority of these incumbent local exchange service providers can be considered small.33
12.
Competitive Local Exchange Carriers (Competitive LECs), Competitive Access Providers
(CAPs), Shared-Tenant Service Providers, and Other Local Service Providers. Neither the Commission
nor the SBA has developed a small business size standard specifically for these service providers. The
appropriate size standard under SBA rules is for the category Wired Telecommunications Carriers. Under
that size standard, such a business is small if it has 1,500 or fewer employees.34 Census Bureau data for
2007, which now supersede data from the 2002 Census, show that there were 3,188 firms in this category
that operated for the entire year. Of this total, 3,144 had employment of 999 or fewer, and 44 firms had
had employment of 1,000 employees or more. Thus under this category and the associated small business
size standard, the majority of these Competitive LECs, CAPs, Shared-Tenant Service Providers, and
Other Local Service Providers can be considered small entities.35 According to Commission data, 1,442
carriers reported that they were engaged in the provision of either competitive local exchange services or
competitive access provider services.36 Of these 1,442 carriers, an estimated 1,256 have 1,500 or fewer
27

U.S. Census Bureau, Subject Series: Information, Table 5, “Establishment and Firm Size: Employment Size of
Firms for the United States: 2007 NAICS Code 517210” (issued Nov. 2010), available at
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ECN_2007_US_51SSSZ2&prod
Type=table (last visited Jan. 31, 2014).
28

Id. Available census data do not provide a more precise estimate of the number of firms that have employment of
1,500 or fewer employees; the largest category provided is for firms with “100 employees or more.”
29

Id.

13 C.F.R. § 121.201, NAICS code 517110.

See Trends in Telephone Service, Federal Communications Commission, Wireline Competition Bureau, Industry
Analysis and Technology Division at Table 5.3 (Sept. 2010) (Trends in Telephone Service).
32

See id.

See http://factfinder.census.gov/servlet/IBQTable?_bm=y&-fds_name=EC0700A1&-geo_id=&-_skip=600&ds_name=EC0751SSSZ5&-_lang=en.
34

13 C.F.R. § 121.201, NAICS code 517110.

See http://factfinder.census.gov/servlet/IBQTable?_bm=y&-fds_name=EC0700A1&-geo_id=&-_skip=600&ds_name=EC0751SSSZ5&-_lang=en.
36

See Trends in Telephone Service at Table 5.3.

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employees and 186 have more than 1,500 employees.37 In addition, 17 carriers have reported that they
are Shared-Tenant Service Providers, and all 17 are estimated to have 1,500 or fewer employees.38 In
addition, 72 carriers have reported that they are Other Local Service Providers.39 Of the 72, seventy have
1,500 or fewer employees and two have more than 1,500 employees.40 Consequently, the Commission
estimates that most providers of competitive local exchange service, competitive access providers,
Shared-Tenant Service Providers, and Other Local Service Providers are small entities that may be
affected by rules adopted pursuant to the Notice.
13.
Broadband Personal Communications Service. The broadband personal communications
services (PCS) spectrum is divided into six frequency blocks designated A through F, and the
Commission has held auctions for each block. The Commission initially defined a “small business” for
C- and F-Block licenses as an entity that has average gross revenues of $40 million or less in the three
previous calendar years.41 For F-Block licenses, an additional small business size standard for “very
small business” was added and is defined as an entity that, together with its affiliates, has average gross
revenues of not more than $15 million for the preceding three calendar years.42 These small business size
standards, in the context of broadband PCS auctions, have been approved by the SBA.43 No small
businesses within the SBA-approved small business size standards bid successfully for licenses in Blocks
A and B. There were 90 winning bidders that claimed small business status in the first two C-Block
auctions. A total of 93 bidders that claimed small business status won approximately 40 percent of the
1,479 licenses in the first auction for the D, E, and F Blocks.44 On April 15, 1999, the Commission
completed the reauction of 347 C-, D-, E-, and F-Block licenses in Auction No. 22.45 Of the 57 winning
bidders in that auction, 48 claimed small business status and won 277 licenses.
14.
On January 26, 2001, the Commission completed the auction of 422 C and F Block
Broadband PCS licenses in Auction No. 35. Of the 35 winning bidders in that auction, 29 claimed small
business status.46 Subsequent events concerning Auction 35, including judicial and agency
determinations, resulted in a total of 163 C and F Block licenses being available for grant. On February
15, 2005, the Commission completed an auction of 242 C-, D-, E-, and F-Block licenses in Auction No.

See id.

See Amendment of Parts 20 and 24 of the Commission’s Rules – Broadband PCS Competitive Bidding and the
Commercial Mobile Radio Service Spectrum Cap; Amendment of the Commission’s Cellular/PCS Cross-Ownership
Rule; WT Docket No. 96-59, GN Docket No. 90-314, Report and Order, 11 FCC Rcd 7824, 7850–52, paras. 57–60
(1996) (PCS Report and Order); see also 47 C.F.R. § 24.720(b).
42

See PCS Report and Order, 11 FCC Rcd at 7852 ¶ 60.

See Letter from Aida Alvarez, Administrator, Small Business Administration, to Amy Zoslov, Chief, Auctions
and Industry Analysis Division, Wireless Telecommunications Bureau, Federal Communications Commission (Dec.
2, 1998) (Alvarez Letter 1998).
44

See Broadband PCS, D, E and F Block Auction Closes, Public Notice, Doc. No. 89838 (rel. Jan. 14, 1997).

See C, D, E, and F Block Broadband PCS Auction Closes, Public Notice, 14 FCC Rcd 6688 (WTB 1999). Before
Auction No. 22, the Commission established a very small standard for the C Block to match the standard used for F
Block. Amendment of the Commission’s Rules Regarding Installment Payment Financing for Personal
Communications Services (PCS) Licensees, WT Docket No. 97-82, Fourth Report and Order, 13 FCC Rcd 15743,
15768, ¶ 46 (1998).
46

See C and F Block Broadband PCS Auction Closes; Winning Bidders Announced, Public Notice, 16 FCC Rcd
2339 (WTB 2001).

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58. Of the 24 winning bidders in that auction, 16 claimed small business status and won 156 licenses.47
On May 21, 2007, the Commission completed an auction of 33 licenses in the A, C, and F Blocks in
Auction No. 71.48 Of the 12 winning bidders in that auction, five claimed small business status and won
18 licenses.49 On August 20, 2008, the Commission completed the auction of 20 C-, D-, E-, and F-Block
Broadband PCS licenses in Auction No. 78.50 Of the eight winning bidders for Broadband PCS licenses
in that auction, six claimed small business status and won 14 licenses.51
15.
Narrowband Personal Communications Services. To date, two auctions of narrowband
personal communications services (PCS) licenses have been conducted. For purposes of the two auctions
that have already been held, “small businesses” were entities with average gross revenues for the prior
three calendar years of $40 million or less. Through these auctions, the Commission has awarded a total
of 41 licenses, out of which 11 were obtained by small businesses. To ensure meaningful participation of
small business entities in future auctions, the Commission has adopted a two-tiered small business size
standard in the Narrowband PCS Second Report and Order.52 A “small business” is an entity that,
together with affiliates and controlling interests, has average gross revenues for the three preceding years
of not more than $40 million. A “very small business” is an entity that, together with affiliates and
controlling interests, has average gross revenues for the three preceding years of not more than $15
million. The SBA has approved these small business size standards.53
16.
AWS Services (1710–1755 MHz and 2110–2155 MHz bands (AWS-1); 1915–1920 MHz,
1995–2000 MHz, 2020–2025 MHz and 2175–2180 MHz bands (AWS-2); 2155–2175 MHz band (AWS3)). For the AWS-1 bands, the Commission defined a “small business” as an entity with average annual
gross revenues for the preceding three years not exceeding $40 million, and a “very small business” as an
entity with average annual gross revenues for the preceding three years not exceeding $15 million.54 In
2006, the Commission conducted its first auction of AWS-1 licenses.55 In that initial AWS-1 auction, 31
winning bidders identified themselves as very small businesses.56 Twenty-six of the winning bidders
identified themselves as small businesses.57 In a subsequent 2008 auction, the Commission offered 35
47

See Broadband PCS Spectrum Auction Closes; Winning Bidders Announced for Auction No. 58, Public Notice,
20 FCC Rcd 3703 (WTB 2005).
48

See Auction of Broadband PCS Spectrum Licenses Closes; Winning Bidders Announced for Auction No. 71,
Public Notice, 22 FCC Rcd 9247 (WTB 2007).
49

Id.

See Auction of AWS-1 and Broadband PCS Licenses Closes; Winning Bidders Announced for Auction 78, Public
Notice, 23 FCC Rcd 12749 (WTB 2008).
51

Id.

Amendment of the Commission’s Rules to Establish New Personal Communications Services, Narrowband PCS,
GEN Docket No. 90-314, ET Docket No. 92-100, PP Docket No. 93-253, Second Report and Order and Second
Further Notice of Proposed Rulemaking, 15 FCC Rcd 10456 (2000).
53

See Alvarez Letter 1998.

See Service Rules for Advanced Wireless Services in the 1.7 GHz and 2.1 GHz Bands, Report and Order, 18 FCC
Rcd 25162, App. B (2003), modified by Service Rules for Advanced Wireless Services In the 1.7 GHz and 2.1 GHz
Bands, Order on Reconsideration, 20 FCC Rcd 14058, App. C (2005).
55

See Auction of Advanced Wireless Services Licenses Scheduled for June 29, 2006; Notice and Filing
Requirements, Minimum Opening Bids, Upfront Payments and Other Procedures for Auction No. 66, AU Docket
No. 06-30, Public Notice, 21 FCC Rcd 4562 (2006) (Auction 66 Procedures Public Notice).
56

See “Auction of Advanced Wireless Services Licenses Closes; Winning Bidders Announced for Auction No. 66,”
Public Notice, 21 FCC Rcd 10,521 (2006) (Auction 66 Closing Public Notice).
57

See id.

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FCC 15-9

AWS-1 licenses.58 Four winning bidders identified themselves as very small businesses, and three of the
winning bidders identified themselves as a small business.59For AWS-2 and AWS-3, although we do not
know for certain which entities are likely to apply for these frequencies, we note that the AWS-1 bands
are comparable to those used for cellular service and personal communications service. The Commission
has adopted size standards for the AWS-2 or AWS-3 bands similar to broadband PCS service and AWS-1
service due to the comparable capital requirements and other factors, such as issues involved in relocating
incumbents and developing markets, technologies, and services.60 In the AWS-3 auction, 70 applicants
were found qualified to participate, and 46 of those have claimed themselves eligible for a designated
entity bidding credit.61
17.
Rural Radiotelephone Service. The Commission has not adopted a size standard for
small businesses specific to the Rural Radiotelephone Service. A significant subset of the Rural
Radiotelephone Service is the Basic Exchange Telephone Radio System (“BETRS”). In the present
context, we will use the SBA’s small business size standard applicable to Wireless Telecommunications
Carriers (except Satellite), i.e., an entity employing no more than 1,500 persons.62 There are
approximately 1,000 licensees in the Rural Radiotelephone Service, and the Commission estimates that
there are 1,000 or fewer small entity licensees in the Rural Radiotelephone Service that may be affected
by the rules and policies adopted herein.
18.
Wireless Communications Services. This service can be used for fixed, mobile,
radiolocation, and digital audio broadcasting satellite uses in the 2305-2320 MHz and 2345-2360 MHz
bands. The Commission defined “small business” for the wireless communications services (WCS)
auction as an entity with average gross revenues of $40 million for each of the three preceding years, and
a “very small business” as an entity with average gross revenues of $15 million for each of the three
preceding years.63 The SBA has approved these definitions.64 The Commission auctioned geographic
area licenses in the WCS service. In the auction, which commenced on April 15, 1997 and closed on
April 25, 1997, there were seven bidders that won 31 licenses that qualified as very small business
entities, and one bidder that won one license that qualified as a small business entity.
19.
700 MHz Guard Band Licenses. In the 700 MHz Guard Band Order, the Commission
adopted size standards for “small businesses” and “very small businesses” for purposes of determining
their eligibility for special provisions such as bidding credits and installment payments.65 A small
58

See AWS-1 and Broadband PCS Procedures Public Notice, 23 FCC Rcd at 7499. Auction 78 also included an
auction of broadband PCS licenses.
59

See Auction of AWS-1 and Broadband PCS Licenses Closes, Winning Bidders Announced for Auction 78, Down
Payments Due September 9, 2008, FCC Forms 601 and 602 Due September 9, 2008, Final Payments Due
September 23, 2008, Ten-Day Petition to Deny Period, Public Notice, 23 FCC Rcd 12749 (2008).
60

Service Rules for Advanced Wireless Services in the 1915–1920 MHz, 1995–2000 MHz, 2020–2025 MHz and
2175–2180 MHz Bands et al., Notice of Proposed Rulemaking, 19 FCC Rcd 19263, App. B (2005); Service Rules
for Advanced Wireless Services in the 2155–2175 MHz Band, Notice of Proposed Rulemaking, 22 FCC Rcd 17035,
App. (2007); Service Rules for Advanced Wireless Services in the 2155-2175 MHz Band, Further Notice of
Proposed Rulemaking, 23 FCC Rcd 9859, App. B (2008).
61

See Auction of Advanced Wireless Services (AWS-3) Licenses; 70 Bidders Qualified to Participate in Auction 97,
Public Notice, 29 FCC Rcd 13465 (WTB 2014).
62

NAICS Code 51210.

Amendment of the Commission’s Rules to Establish Part 27, the Wireless Communications Service (WCS),
Report and Order, 12 FCC Rcd 10785, 10879 ¶ 194 (1997).
64

See Alvarez Letter 1998.

Service Rules for the 746-764 MHz Bands, and Revisions to Part 27 of the Commission’s Rules, Second Report
and Order, 15 FCC Rcd 5299 (2000). Service rules were amended in 2007, but no changes were made to small
business size categories. See Service Rules for the 698-746, 747-762 and 777-792 MHz Bands, WT Docket No. 06(continued….)

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FCC 15-9

business in this service is an entity that, together with its affiliates and controlling principals, has average
gross revenues not exceeding $40 million for the preceding three years.66 Additionally, a “very small
business” is an entity that, together with its affiliates and controlling principals, has average gross
revenues that are not more than $15 million for the preceding three years.67 SBA approval of these
definitions is not required.68 An auction of 52 Major Economic Area (MEA) licenses commenced on
September 6, 2000, and closed on September 21, 2000.69 Of the 104 licenses auctioned, 96 licenses were
sold to nine bidders. Five of these bidders were small businesses that won a total of 26 licenses. A
second auction of 700 MHz Guard Band licenses commenced and closed in 2001. All eight of the
licenses auctioned were sold to three bidders. One of these bidders was a small business that won a total
of two licenses.70
20.
Upper 700 MHz Band Licenses. In the 700 MHz Second Report and Order, the
Commission revised its rules regarding Upper 700 MHz licenses.71 On January 24, 2008, the
Commission commenced Auction 73 in which several licenses in the Upper 700 MHz band were
available for licensing: 12 Regional Economic Area Grouping licenses in the C Block, and one
nationwide license in the D Block.72 The auction concluded on March 18, 2008, with 3 winning bidders
claiming very small business status (those with attributable average annual gross revenues that do not
exceed $15 million for the preceding three years) and winning five licenses.
21.
Lower 700 MHz Band Licenses. The Commission previously adopted criteria for
defining three groups of small businesses for purposes of determining their eligibility for special
provisions such as bidding credits.73 The Commission defined a “small business” as an entity that,
together with its affiliates and controlling principals, has average gross revenues not exceeding $40
million for the preceding three years.74 A “very small business” is defined as an entity that, together with
its affiliates and controlling principals, has average gross revenues that are not more than $15 million for
(Continued from previous page)
150, Revision of the Commission’s Rules to Ensure Compatibility with Enhanced 911 Emergency Calling Systems,
CC Docket No. 94-102, Section 68.4(a) of the Commission’s Rules Governing Hearing Aid-Compatible
Telephones, WT Docket No. 01-309, Biennial Regulatory Review – Amendment of Parts 1, 22, 24, 27, and 90 to
Streamline and Harmonize Various Rules Affecting Wireless Radio Services, WT Docket 03-264, Former Nextel
Communications, Inc. Upper 700 MHz Guard Band Licenses and Revisions to Part 27 of the Commission’s Rules,
WT Docket No. 06-169, Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700
MHz Band, PS Docket No. 06-229, Development of Operational, Technical and Spectrum Requirements for
Meeting Federal, State and Local Public Safety Communications Requirements Through the Year 2010, WT Docket
No. 96-86, Report and Order and Further Notice of Proposed Rulemaking, 22 FCC Rcd 8064 (2007).
66

Id. at 5343 ¶ 108.

Id.

Id. at 5343 ¶ 108 n.246 (for the 746-764 MHz and 776-704 MHz bands, the Commission is exempt from 15
U.S.C. § 632, which requires Federal agencies to obtain Small Business Administration approval before adopting
small business size standards).
69

See 700 MHz Guard Bands Auction Closes: Winning Bidders Announced, Public Notice, 15 FCC Rcd 18026
(WTB 2000).
70

See 700 MHz Guard Bands Auction Closes: Winning Bidders Announced, Public Notice, 16 FCC Rcd 4590
(WTB 2001).
71

700 MHz Second Report and Order, 22 FCC Rcd 15289.

See Auction of 700 MHz Band Licenses Closes, Public Notice, 23 FCC Rcd 4572 (WTB 2008).

See Reallocation and Service Rules for the 698–746 MHz Spectrum Band (Television Channels 52–59), Report
and Order, 17 FCC Rcd 1022 (2002) (Channels 52–59 Report and Order).
74

See id., 17 FCC Rcd at 1087–88 ¶ 172.

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FCC 15-9

the preceding three years.75 Additionally, the lower 700 MHz Service had a third category of small
business status for Metropolitan/Rural Service Area (MSA/RSA) licenses—“entrepreneur”—which is
defined as an entity that, together with its affiliates and controlling principals, has average gross revenues
that are not more than $3 million for the preceding three years.76 The SBA approved these small size
standards.77 An auction of 740 licenses (one license in each of the 734 MSAs/RSAs and one license in
each of the six Economic Area Groupings (EAGs)) was conducted in 2002. Of the 740 licenses available
for auction, 484 licenses were won by 102 winning bidders. Seventy-two of the winning bidders claimed
small business, very small business or entrepreneur status and won licenses.78 A second auction
commenced on May 28, 2003, closed on June 13, 2003, and included 256 licenses.79 Seventeen winning
bidders claimed small or very small business status, and nine winning bidders claimed entrepreneur
status.80 In 2005, the Commission completed an auction of 5 licenses in the Lower 700 MHz band. All
three winning bidders claimed small business status.
22.
In 2007, the Commission reexamined its rules governing the 700 MHz band in the 700
MHz Second Report and Order.81 An auction of A, B and E block 700 MHz licenses was held in 2008.82
Twenty winning bidders claimed small business status (those with attributable average annual gross
revenues that exceed $15 million and do not exceed $40 million for the preceding three years). Thirty
three winning bidders claimed very small business status (those with attributable average annual gross
revenues that do not exceed $15 million for the preceding three years).
23.
Offshore Radiotelephone Service. This service operates on several UHF television
broadcast channels that are not used for television broadcasting in the coastal areas of states bordering the
Gulf of Mexico.83 There are presently approximately 55 licensees in this service. We are unable to
estimate at this time the number of licensees that would qualify as small under the SBA’s small business
size standard for the category of Wireless Telecommunications Carriers (except Satellite). Under that
SBA small business size standard, a business is small if it has 1,500 or fewer employees.84 Census data
for 2007, which supersede data contained in the 2002 Census, show that there were 1,383 firms that
operated that year.85 Of those 1,383, 1,368 had fewer than 100 employees, and 15 firms had more than
100 employees. Thus, under this category and the associated small business size standard, the majority of
firms can be considered small.
24.
Wireless Telephony. Wireless telephony includes cellular, personal communications
services, and specialized mobile radio telephony carriers. As noted, the SBA has developed a small
business size standard for Wireless Telecommunications Carriers (except Satellite).86 Under the SBA
75

See id.

See id., 17 FCC Rcd at 1088 ¶ 173.

See Alvarez Letter 1998.

See Lower 700 MHz Band Auction Closes, Public Notice, 17 FCC Rcd 17272 (2002).

See Lower 700 MHz Band Auction Closes, Public Notice, 18 FCC Rcd 11873 (2003).

See id.

700 MHz Second Report and Order, Second Report and Order, 22 FCC Rcd 15,289, 15,359 n.434 (2007).

See Auction of 700 MHz Band Licenses Closes, Public Notice, 23 FCC Rcd 4572 (2008).

This service is governed by Subpart I of Part 22 of the Commission’s Rules. See 47 C.F.R. §§ 22.1001-22.1037,
NAICS code 517210.
84

13 C.F.R. § 121.201, NAICS code 517210.

2007 Economic Census Report Employment Size of Firms, at NAICS Code 517210.

13 C.F.R. § 121.201, NAICS code 517210.

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FCC 15-9

small business size standard, a business is small if it has 1,500 or fewer employees.87 According to
Trends in Telephone Service data, 413 carriers reported that they were engaged in wireless telephony.88
Of these, an estimated 261 have 1,500 or fewer employees and 152 have more than 1,500 employees.89
Therefore, more than half of these entities can be considered small.
25.
The second category, i.e., “All Other Telecommunications,” comprises “establishments
primarily engaged in providing specialized telecommunications services, such as satellite tracking,
communications telemetry, and radar station operation. This industry also includes establishments
primarily engaged in providing satellite terminal stations and associated facilities connected with one or
more terrestrial systems and capable of transmitting telecommunications to, and receiving
telecommunications from, satellite systems. Establishments providing Internet services or Voice over
Internet Protocol (VoIP) services via client-supplied telecommunications connections are also included in
this industry.”90 For this category, Census Bureau data for 2007 show that there were a total of 2,623
firms that operated for the entire year.91 Consequently, the Commission estimates that the majority of All
Other Telecommunications firms are small entities that might be affected by rules proposed in the Third
Further Notice.
b.

Equipment Manufacturers

26.
Radio and Television Broadcasting and Wireless Communications Equipment
Manufacturing. The Census Bureau defines this category as follows: “This industry comprises
establishments primarily engaged in manufacturing radio and television broadcast and wireless
communications equipment. Examples of products made by these establishments are: transmitting and
receiving antennas, cable television equipment, GPS equipment, pagers, cellular phones, mobile
communications equipment, and radio and television studio and broadcasting equipment.” The SBA has
developed a small business size standard for Radio and Television Broadcasting and Wireless
Communications Equipment Manufacturing which is: all such firms having 750 or fewer employees.
According to Census Bureau data for 2007, there were a total of 939 establishments in this category that
operated for part or all of the entire year. Of this total, 784 had less than 500 employees and 155 had more
than 100 employees.92 Thus, under this size standard, the majority of firms can be considered small.
27.
Semiconductor and Related Device Manufacturing. These establishments manufacture
“computer storage devices that allow the storage and retrieval of data from a phase change, magnetic,
optical, or magnetic/optical media. The SBA has developed a small business size standard for this
category of manufacturing; that size standard is 500 or fewer employees storage and retrieval of data from
a phase change, magnetic, optical, or magnetic/optical media.”93 According to data from the 2007 U.S.
Census, in 2007, there were 954 establishments engaged in this business. Of these, 545 had from 1 to 19
87

Id.

TRENDS IN TELEPHONE SERVICE, tbl. 5.3.

Id.

See http://www.census.gov/cgi-bin/sssd/naics/naicsrch?code=517919&search=2007%20NAICS%20Search.(last
viewed Jan. 31, 2014).
91

See
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ECN_2007_US_51SSSZ1&prod
Type=table (last viewed Jan. 31, 2014).
92

The NAICS Code for this service 334220. See 13 C.F.R 121/201. See also
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ECN_2007_US_00A1&prodTyp
e=table (last viewed Jan. 31, 2014).
93

U.S. Census Bureau, 2007 Economic Census, Industry Series: Manufacturing, “Semiconductor and Related
Device Manufacturing,” NAICS code 334413.

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employees; 219 had from 20 to 99 employees; and 190 had 100 or more employees.94 Based on this data,
the Commission concludes that the majority of the businesses engaged in this industry are small.
D.

Description of Projected Reporting, Recordkeeping, and Other Compliance
Requirements for Small Entities

28.
In this Fourth Report and Order, we require nationwide CMRS providers report to the
Commission on their plans for implementing improved indoor location accuracy no later than 18 months
from the date when the rules contained herein become effective. To address concerns raised by small and
regional CMRS providers, non-nationwide CMRS providers will have an additional six months to submit
their plans. These initial reports will include details as to the CMRS provider’s implementation plan to
meet our requirements in the three- and six-year timeframes, and these one-time reports will ensure that
each CMRS provider (including small and/or rural) makes at least some progress toward improving
indoor location accuracy in the near term. Furthermore, all CMRS providers must also report to the
Commission on their progress toward implementation of their plans no later than 36 months from the
Effective Date. We believe the global data provided through these reports may enable the Commission to
identify efficiencies and facilitate coordination among providers, and may help ensure that CMRS
providers do not invest too heavily in duplicative technologies or in technology and system design that
proves unusable.
29.


The rules we adopt today require that:

All CMRS providers must provide (1) dispatchable location, or (2) x/y (horizontal) location
within 50 meters, for the following percentages of wireless 911 calls within the following
timeframes, measured from the Effective Date of rules adopted in this Fourth Report and Order:







Non-nationwide CMRS providers (regional, small, and rural providers) can extend the five and
six-year deadlines based on the timing of VoLTE deployment in the networks.

30.
All CMRS providers must meet the following requirements for provision of vertical
location information with wireless 911 calls:




Within 3 years, all CMRS providers must make uncompensated barometric data available
to PSAPs from any handset that has the capability to deliver barometric sensor data.
Within 3 years, nationwide CMRS providers must use an independently administered and
transparent test bed process to develop a proposed z-axis accuracy metric, and must
submit the proposed metric to the Commission for approval.
Within 6 years, nationwide CMRS provides must deploy either (1) dispatchable location,
or (2) z-axis technology that achieves the Commission-approved z-axis metric, in each of
the top 25 CMAs:
 The National Emergency Address Database (NEAD) must be populated with a
total number of dispatchable location reference points in the CMA equal to 25
percent of the CMA population if dispatchable location is used.

See http://factfinder.census.gov/servlet/IBQTable?_bm=y&-geo_id=&-_skip=300&-ds_name=EC0731I1&_lang=en.

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FCC 15-9






CMRS providers must deploy z-axis technology to cover 80 percent of the CMA
population if z-axis technology is used.
Within 8 years, nationwide CMRS providers must deploy dispatchable location or z-axis
technology in accordance with the above benchmarks in each of the top 50 CMAs.
Non-nationwide carriers that serve any of the top 25 or 50 CMAs will have an additional
year to meet the latter two benchmarks (i.e., relating to years 6 and 8).

31.
Quarterly reporting of live 911 data will begin no later than 18 months from the date the
rules become effective; CMRS providers will also provide quarterly live call data on a more granular
basis that allows evaluation of the performance of individual location technologies within different
morphologies (e.g., dense urban, urban, suburban, rural). Public Safety Answering Points (PSAPs) will
be entitled to obtain live call data from CMRS providers and seek Commission enforcement of these
requirements within their jurisdictions, but they may seek enforcement only so long as they have
implemented policies that are designed to obtain all 911 location information made available by CMRS
providers pursuant to our rules.
32.
We adopt a 30-second limit on the time period allowed for a CMRS provider to generate
a location fix in order for the 911 call to be counted towards compliance with existing Phase II location
accuracy requirements that rely on outdoor testing, but we do not extend this provision to the new indoorfocused requirements adopted in this order. We require that confidence and uncertainty data for all
wireless 911 calls – whether placed from indoors or outdoors – be delivered at the request of a PSAP, on
a per-call basis, with a uniform confidence level of 90 percent.
33.
We require CMRS providers to provide 911 call data, including (1) the percentage of
wireless 911 calls to the PSAP that include Phase II location information, and (2) per-call identification of
the positioning source method or methods used to derive location coordinates and/or dispatchable
location, to any requesting PSAP. Compliance with the 30-second time limit will also be measured from
this data.
E.

Steps Taken to Minimize the Significant Economic Impact on Small Entities, and
Significant Alternatives Considered

34.
The RFA requires an agency to describe any significant alternatives that it has considered
in developing its approach, which may include the following four alternatives (among others): “(1) the
establishment of differing compliance or reporting requirements or timetables that take into account the
resources available to small entities; (2) the clarification, consolidation, or simplification of compliance
and reporting requirements under the rule for such small entities; (3) the use of performance rather than
design standards; and (4) an exemption from coverage of the rule, or any part thereof, for such small
entities.”
35.
We received comments from entities representing small and/or rural interests, suggesting
that the rules would apply a unique burden on small and/or rural entities,95 and raising the possibility of
exemptions or waivers for small or rural entities.96 In the Fourth Report and Order, we explicitly
acknowledge that the costs imposed by the rules adopted herein “may present a proportionately greater

See, e.g., Blooston Comments at 2-3 (suggesting that substantial investments in new E911 equipment that small
rural carriers will be required to make in order to comply with the proposed new E911 requirements will soon
become unrecoverable stranded investments when NG911 technology is deployed); CCA Roadmap Comments at 6
(expressing concern that small and rural carriers may not hold licenses for spectrum or otherwise operate in the
single location defined implied in the Roadmap and will thus be forced to commit to individualized testing of a
particular heightened location accuracy technology should it utilize any component of their network);
96

CCA Reply Comments at 12; NCTA Reply Comments at 2; RWA Comments at 6; Blooston Rural Comments at
2-3; SouthernLINC Wireless Reply Comments at 6.

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FCC 15-9

burden to smaller CMRS providers, including the costs associated with participation in the test bed.”97
Nevertheless, we conclude that overriding public safety concerns require our rules to apply equally to all
CMRS providers, regardless of location or size – 911 location accuracy is paramount in all portions of the
Nation, and all CMRS providers must be on an equal footing in their ability to provide correct 911
location accuracy.
36.
To accommodate the unique circumstances facing small and rural carriers, the rules we
adopt today include the following steps that we believe will minimize the impact on such carriers:


While all CMRS providers (including small providers) must provide dispatchable
location or x/y (horizontal) location within 50 meters for certain percentages of wireless
911 calls at Years 2, 3, 5, and 6 after the rules in this Fourth Report and Order become
effective, non-nationwide CMRS providers (i.e., regional, small, and rural carriers) can
extend the five and six-year deadlines based on the timing of Voice-over-LTE (VoLTE)
deployment in their networks.



Regarding vertical location accuracy, while all CMRS providers (including small
providers) must make uncompensated barometric data available to PSAPs from any
handset that has the capability to deliver barometric sensor data within 3 years of the
rules in this Fourth Report and Order becoming effective, small carriers have an
additional year beyond what nationwide carriers must comply with (i.e., Year 6
requirements extend to Year 7; Year 8 requirements extend to Year 9).



While nationwide CMRS providers must report to the Commission on their plans and
progress towards implementing improved indoor location accuracy no later than 18
months of the date the rules in this Fourth Report and Order become effective, smaller
CMRS providers have 24 months.



While nationwide CMRS providers must aggregate live 911 call data on a quarterly basis
and report that data to the Association of Public-Safety Communications Officials
(APCO), National Emergency Number Association (NENA), and the National
Association of State 911 Administrators (NASNA), small providers must do so on a
biannual basis.

37.
Regarding the overall scope of the indoor 911 location accuracy rules we adopt in this
Fourth Report and Order, we note that in the Third Further Notice, we proposed to apply the horizontal
indoor location accuracy requirements on a nationwide-basis, across all geographic areas.98 In response,
several small and regional CMRS providers proposed that rural areas from indoor location accuracy
requirements be excluded from the rules, either entirely or for a certain “phase-in” period.99 Absent any
such exclusion, RWA believes the ability of small and rural CMRS providers to achieve compliance with

Fourth Report and Order at para. 154, citing CCA Reply Comments at 15.

Third Further Notice, 29 FCC Rcd at 2413-15 ¶¶ 104-09.

NCTA Reply Comments at 2 (“The Commission should exclude rural areas with a low density of multistory
commercial buildings (e.g., less than 10 multi-story buildings per square mile) from the indoor location accuracy
requirements for a minimum of two years past the initial compliance deadline placed upon urban carriers.”); RWA
Comments at 6 (“RWA would also support limiting the application of the vertical location requirement to certain
urban areas with a high density of multi-story commercial buildings.”); Blooston Rural Comments at 2-3 (“The
much smaller carriers that are serving rural areas have limited resources. To require them to install new E91 l
equipment and shortly thereafter replace it with NG911 equipment would constitute an undue financial hardship that
will impair their ability in the long term to provide emergency services to their customers. This waste of scarce
resources would be all the more regrettable since there are far fewer high rise buildings in rural areas than in urban
areas, making the need for vertical location information less pressing.”).

100

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the indoor horizontal location accuracy requirements in the proposed timeframe would be problematic.100
In response, we state that because the rules we adopt today relate to indoor 911 calls – and therefore are
not hindered by naturally-formed physical characteristics – there is no need to adopt similar exclusions.
We believe that the design of our indoor location accuracy requirements and the timeframe allotted for
compliance adequately addresses commenters’ concerns about being able to implement indoor location
solutions throughout all morphologies within their coverage footprint. Moreover, applying these
requirements uniformly nationwide is consistent with the principle that improving 911 location is just as
important in the least populous markets as in the most populous.101
38.
We sought comment in the Third Further Notice on whether we should adopt a specific
waiver process for CMRS providers who seek relief from our indoor location accuracy requirements.102
In particular, we sought comment on whether and what criteria would be appropriate for any E911specific waiver process, as well as whether providers who believe they cannot comply with a particular
indoor location accuracy benchmark, despite good faith efforts, may certify this six months prior to the
applicable benchmark.103 In response, RWA suggests the Commission adopt a safe harbor for waiver
applicants based on a showing of technical infeasibility or financial difficulty,104 while NTCA notes that
the expense of a waiver can impose a substantial financial burden for small rural carriers, and the
regulatory uncertainty can be disruptive to business planning and operations.105 We ultimately determined
not to adopt a specific waiver standard applicable only to the indoor location accuracy requirements we
adopt today, noting that ‘[a]ny CMRS provider that is unable to meet the deadlines adopted herein may
seek waiver relief. The Commission may grant relief pursuant to the waiver standards set forth in
Sections 1.3 and 1.925 of its rules, and we believe these provisions are sufficient to address any requests
for relief of the indoor location accuracy requirements…”106
F.

Report to Congress

39.
The Commission will send a copy of the Report and Order, including this FRFA, in a
report to be sent to Congress pursuant to the Congressional Review Act. In addition, the Commission
will send a copy of the Report and Order, including this FRFA, to the Chief Counsel for Advocacy of the
SBA. A copy of the Report and Order and FRFA (or summaries thereof) will also be published in the
Federal Register.

100

See supra Fourth Report and Order para. 97.

102

Third Further Notice, 29 FCC Rcd at 2417 ¶¶ 115-16.

103

Third Further Notice, 29 FCC Rcd at 2417 ¶ 116.

104

RWA Comments at 7.

105

NTCA Comments at 5 and Reply Comments at 7. NTCA does, however, support adoption of a streamlined
waiver process were the Commission to adopt the location requirements proposed in the Third Further Notice.
106

See supra para. 140.

101

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APPENDIX D
Final Rules
Part 20 of the Code of Federal Regulations is amended as follows:
PART 20 – COMMERCIAL MOBILE RADIO SERVICES
1.

The authority for Part 20 is revised to read as follows:

Authority: 47 U.S.C. §§ 151, 152(a), 154(i), 157, 160, 201, 214, 222, 251(e), 301, 302, 303, 303(b),
303(r), 307, 307(a), 309, 309(j)(3), 316, 316(a), 332, 615, 615a, 615b, 615c.
2.
Section 20.18 is amended by amending paragraph (h)(3) and re-designating paragraphs (i)
through (n) as paragraphs (o) through (t), adding new paragraphs (i) through (n), and revising paragraph
(1) of re-designated new paragraph (n) to read as follows:
*
*
*
*
*
(h)(3) Latency (Time to First Fix). For purposes of measuring compliance with the location accuracy
standards of this paragraph, a call will be deemed to satisfy the standard only if it provides the specified
degree of location accuracy within a maximum latency period of 30 seconds, as measured from the time
the user initiates the 911 call to the time the location fix appears at the location information center:
Provided, however, that the CMRS provider may elect not to include for purposes of measuring
compliance therewith any calls lasting less than 30 seconds.
(i) Indoor location accuracy for 911 and testing requirements.
(1) Definitions: The terms as used in this section have the following meaning:
i. Dispatchable location: A location delivered to the PSAP by the CMRS provider with a
911 call that consists of the street address of the calling party, plus additional information
such as suite, apartment or similar information necessary to adequately identify the location
of the calling party. The street address of the calling party must be validated and, to the
extent possible, corroborated against other location information prior to delivery of
dispatchable location information by the CMRS provider to the PSAP.
ii. Media Access Control (MAC) Address. A location identifier of a Wi-Fi access point.
iii. National Emergency Address Database (NEAD). A database that utilizes MAC address
information to identify a dispatchable location for nearby wireless devices within the
CMRS provider’s coverage footprint.
iv. Nationwide CMRS provider: A CMRS provider whose service extends to a majority of the
population and land area of the United States.
v. Non-nationwide CMRS provider: Any CMRS provider other than a nationwide CMRS
provider.
vi. Test Cities. The six cities (San Francisco, Chicago, Atlanta, Denver/Front Range,
Philadelphia, and Manhattan Borough) and surrounding geographic areas that correspond
to the six geographic regions specified by the February 7, 2014 ATIS Document,
“Considerations in Selecting Indoor Test Regions,” for testing of indoor location
technologies.

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(2) Indoor location accuracy standards: CMRS providers subject to this section shall meet the
following requirements:
i.

Horizontal location.
(A) Nationwide CMRS providers shall provide (1) dispatchable location, or (2) x/y
location within 50 meters, for the following percentages of wireless 911 calls
within the following timeframes, measured from the effective date of the
adoption of this rule:
(1) Within 2 years: 40 percent of all wireless 911 calls.
(2) Within 3 years: 50 percent of all wireless 911 calls.
(3) Within 5 years: 70 percent of all wireless 911 calls.
(4) Within 6 years: 80 percent of all wireless 911 calls.
(B) Non-nationwide CMRS providers shall provide (1) dispatchable location or (2)
x/y location within 50 meters, for the following percentages of wireless 911 calls
within the following timeframes, measured from the effective date of the
adoption of this rule:
(1) Within 2 years: 40 percent of all wireless 911 calls.
(2) Within 3 years: 50 percent of all wireless 911 calls.
(3) Within 5 years or within six months of deploying a commerciallyoperating VoLTE platform in their network, whichever is later: 70
percent of all wireless 911 calls.
(4) Within 6 years or within one year of deploying a commercially-operating
VoLTE platform in their network, whichever is later: 80 percent of all
wireless 911 calls.

ii.

Vertical location. CMRS providers shall provide vertical location information with
wireless 911 calls as described in this section within the following timeframes measured
from the effective date of the adoption of this rule:
(A) Within 3 years: All CMRS providers shall make uncompensated barometric data
available to PSAPs with respect to any 911 call placed from any handset that
has the capability to deliver barometric sensor information.
(B) Within 3 years: Nationwide CMRS providers shall develop one or more z-axis
accuracy metrics validated by an independently administered and transparent
test bed process as described in paragraph (i)(3)(a) of this section, and shall
submit the proposed metric or metrics, supported by a report of the results of
such development and testing, to the Commission for approval.
(C) Within 6 years: In each of the top 25 CMAs, nationwide CMRS providers shall
deploy either (1) dispatchable location, or (2) z-axis technology in compliance
with any z-axis accuracy metric that has been approved by the Commission,
(1) In each CMA where dispatchable location is used: nationwide CMRS
providers must ensure that the NEAD is populated with a sufficient
number of total dispatchable location reference points to equal 25 percent
of the CMA population.
(2) In each CMA where z-axis technology is used: nationwide CMRS
providers must deploy z-axis technology to cover 80 percent of the CMA
population.
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(D) Within 8 years: In each of the top 50 CMAs, nationwide CMRS providers shall
deploy either (1) dispatchable location or (2) such z-axis technology in
compliance with any z-axis accuracy metric that has been approved by the
Commission.
(E) Non-nationwide CMRS providers that serve any of the top 25 or 50 CMAs will
have an additional year to meet each of the benchmarks in paragraphs
(i)(2)(ii)(C)-(D) of this section.
iii.

Compliance. Within 60 days after each benchmark date specified in paragraphs (i)(2)(i)
and (ii) of this section, CMRS providers must certify that they are in compliance with the
location accuracy requirements applicable to them as of that date. CMRS providers shall
be presumed to be in compliance by certifying that they have complied with the test bed
and live call data provisions described in paragraph (i)(3) of this section.
(A) All CMRS providers must certify that the indoor location technology (or
technologies) used in their networks are deployed consistently with the manner
in which they have been tested in the test bed. A CMRS provider must update
certification whenever it introduces a new technology into its network or
otherwise modifies its network, such that previous performance in the test bed
would no longer be consistent with the technology’s modified deployment.
(B) CMRS providers that provide quarterly reports of live call data in one or more
of the six test cities specified in paragraph (i)(1)(vi) of this section must certify
that their deployment of location technologies throughout their coverage area is
consistent with their deployment of the same technologies in the areas that are
used for live call data reporting.
(C) Non-nationwide CMRS providers that do not provide service or report quarterly
live call data in any of the six test cities specified in paragraph (i)(1)(vi) must
certify that they have verified based on their own live call data that they are in
compliance with the requirements of paragraphs (i)(2)(i)(B) and (ii) of this
section.

iv.

Enforcement. PSAPs may seek Commission enforcement within their geographic service
area of the requirements of paragraphs (i)(2)(i) and (ii) of this section, but only so long as
they have implemented policies that are designed to obtain all location information made
available by CMRS providers when initiating and delivering 911 calls to the PSAP. Prior
to seeking Commission enforcement, a PSAP must provide the CMRS provider with [30]
days written notice, and the CMRS provider shall have an opportunity to address the
issue informally. If the issue has not been addressed to the PSAP’s satisfaction within 90
days, the PSAP may seek enforcement relief.

(3) Indoor location accuracy testing and live call data reporting.
i.

Indoor location accuracy test bed. CMRS providers must establish the test bed described
in this section within 12 months of the effective date of this rule. CMRS providers must
validate technologies intended for indoor location, including dispatchable location
technologies and technologies that deliver horizontal and/or vertical coordinates, through
an independently administered and transparent test bed process, in order for such
technologies to be presumed to comply with the location accuracy requirements of this
paragraph. The test bed shall meet the following minimal requirements in order for the
test results to be considered valid for compliance purposes:
(A) include testing in representative indoor environments, including dense urban,
urban, suburban and rural morphologies;
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(B) test for performance attributes including location accuracy (ground truth as
measured in the test bed), latency (Time to First Fix), and reliability (yield); and
(C) Each test call (or equivalent) shall be independent from prior calls and accuracy
will be based on the first location delivered after the call is initiated.
(D) In complying with paragraph (i)(3)(i)(B) of this section, CMRS providers shall
measure yield separately for each individual indoor location morphology (dense
urban, urban, suburban, and rural) in the test bed, and based upon the specific
type of location technology that the provider intends to deploy in real-world areas
represented by that particular morphology. CMRS providers must base the yield
percentage based on the number of test calls that deliver a location in compliance
with any applicable indoor location accuracy requirements, compared to the total
number of calls that successfully connect to the testing network. CMRS
providers may exclude test calls that are dropped or otherwise disconnected in 10
seconds or less from calculation of the yield percentage (both the denominator
and numerator).
ii.

Collection and reporting of aggregate live 911 call location data. CMRS providers
providing service in any of the Test Cities or portions thereof must collect and report
aggregate data on the location technologies used for live 911 calls in those areas.
(A) CMRS providers subject to this section shall identify and collect information
regarding the location technology or technologies used for each 911 call in the
reporting area during the calling period.
(B) CMRS providers subject to this section shall report Test City call location data
on a quarterly basis to the Commission, the National Emergency Number
Association, the Association of Public Safety Communications Officials, and the
National Association of State 911 Administrators, with the first report due 18
months from the effective date of rules adopted in this proceeding.
(C) CMRS providers subject to this section shall also provide quarterly live call data
on a more granular basis that allows evaluation of the performance of individual
location technologies within different morphologies (e.g., dense urban, urban,
suburban, rural). To the extent available, live call data for all CMRS providers
shall delineate based on a per technology basis accumulated and so identified for:
(1) each of the ATIS ESIF morphologies; (2) on a reasonable community level
basis; or (3) by census block. This more granular data will be used for evaluation
and not for compliance purposes.
(D) Non-nationwide CMRS providers that operate in a single Test City need only
report live 911 call data from that city or portion thereof that they cover. Nonnationwide CMRS providers that operate in more than one Test City must report
live 911 call data only in half of the regions (as selected by the provider). In the
event a non-nationwide CMRS provider begins coverage in a Test City it
previously did not serve, it must update its certification pursuant to paragraph
(i)(2)(iii)(C) of this section to reflect this change in its network and begin
reporting data from the appropriate areas. All non-nationwide CMRS providers
must report their Test City live call data every 6 months, beginning 18 months
from the effective date of rules adopted in this proceeding.
(E) Non-nationwide CMRS providers that do not provide coverage in any of the Test
Cities can satisfy the requirement of paragraph (i)(3)(ii) of this section by
collecting and reporting data based on the largest county within its footprint. In
addition, where a non-nationwide CMRS provider serves more than one of the
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ATIS ESIF morphologies, it must include a sufficient number of representative
counties to cover each morphology.
iii.

Data retention. CMRS providers shall retain testing and live call data gathered pursuant
to this section for a period of 2 years.

(4) Submission of plans and reports. The following reporting and certification obligations apply to
all CMRS providers subject to this section, which may be filed electronically in PS Docket No.
07-114:
i.

Initial implementation plan. No later than 18 months from the effective date of the
adoption of this rule, nationwide CMRS providers shall report to the Commission on their
plans for meeting the indoor location accuracy requirements of paragraph (i)(2) this
section. Non-nationwide CMRS providers will have an additional 6 months to submit
their implementation plans.

ii.

Progress reports. No later than 18 months from the effective date of the adoption of this
rule, each CMRS provider shall file a progress report on implementation of indoor
location accuracy requirements. Non-nationwide CMRS providers will have an
additional 6 months to submit their progress reports. All CMRS providers shall provide
an additional progress report no later than 36 months from the effective date of the
adoption of this rule. The 36-month reports shall indicate what progress the provider has
made consistent with its implementation plan, and the nationwide CMRS providers shall
include an assessment of their deployment of dispatchable location solutions. For any
CMRS provider participating in the development of the NEAD database, this progress
report must include detail as to the implementation of the NEAD database described in
paragraphs (i)(4)(iii)-(iv) of this section.

iii.

NEAD privacy and security plan. Prior to activation of the NEAD but no later than 18
months from the effective date of the adoption of this rule, the nationwide CMRS
providers shall file with the Commission and request approval for a security and privacy
plan for the administration and operation of the NEAD. The plan must include the
identity of an administrator for the NEAD, who will serve as a point of contact for the
Commission and shall be accountable for the effectiveness of the security, privacy, and
resiliency measures.

iv.

NEAD use certification. Prior to use of the NEAD or any information contained therein
to meet such requirements, CMRS providers must certify that they will not use the
NEAD or associated data for any non-911 purpose, except as otherwise required by law.

(j) Confidence and uncertainty data.
(1) Except as provided in paragraphs (j)(2)-(3) of this section, CMRS providers subject to this section
shall provide for all wireless 911 calls, whether from outdoor or indoor locations, x- and y-axis
(latitude, longitude) confidence and uncertainty information (C/U data) on a per-call basis upon
the request of a PSAP. The data shall specify (1) the caller’s location with a uniform confidence
level of 90 percent, and (2) the radius in meters from the reported position at that same
confidence level. All entities responsible for transporting confidence and uncertainty between
CMRS providers and PSAPs, including LECs, CLECs, owners of E911 networks, and emergency
service providers, must enable the transmission of confidence and uncertainty data provided by
CMRS providers to the requesting PSAP.
(2) Upon meeting the 3-year timeframe pursuant to paragraph (i)(2)(i) of this section, CMRS
providers shall provide with wireless 911 calls that have a dispatchable location the C/U data for
the x- and y-axis (latitude, longitude) required under paragraph (k)(1) of this section.
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(3) Upon meeting the 6-year timeframe pursuant to paragraph (i)(2)(b) of this section, CMRS
providers shall provide with wireless 911 calls that have a dispatchable location the C/U data for
the x- and y-axis (latitude, longitude) required under paragraph (k)(1) of this section.
(k) Provision of live 911 call data for PSAPs. Notwithstanding other 911 call data collection and
reporting requirements in paragraph (i) of this section, CMRS providers must record information on all
live 911 calls, including, but not limited to, the positioning source method used to provide a location fix
associated with the call. CMRS providers must also record the confidence and uncertainty data that they
provide pursuant to paragraphs (j)(1)-(3) of this section. This information must be made available to
PSAPs upon request, and shall be retained for a period of two years.
(m) Reports on Phase II plans. *
(n) *

(1) Generally. The requirements set forth in paragraphs (d) through (n) of this section shall be applicable
only to the extent that the administrator of the applicable designated PSAP has requested the services
required under those paragraphs and such PSAP is capable of receiving and utilizing the requested data
elements and has a mechanism for recovering the PSAP’s costs associated with them.

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STATEMENT OF
CHAIRMAN TOM WHEELER
Since I arrived at the Commission, one of our top public safety priorities has been improving the
effectiveness of 911. Last February, we adopted an NPRM that proposed aggressive but achievable goals
for improved location accuracy. Through the hard, diligent work of many people at the FCC, in the public
safety community, and in industry, we have before us today an Order that significantly improves our 911
location accuracy rules.
Everybody agrees on the problem: When the FCC adopted its original wireless 911 rules in 1996,
most wireless usage occurred outdoors. But times and technology have changed. The vast majority of 911
calls now come from wireless phones, increasingly from indoors.
This has generated a 911 readiness gap. First responders are less able to rapidly and accurately
locate a significant percentage of calls for help than they could in previous years.
We need to update our wireless 911 rules to solve this problem. The record that was developed in
response to our proposals tells us that there have been significant advances in technology, including
technologies that have the potential to locate indoor callers by address, floor, and apartment or room
number. We all know how commercial location-based services like Uber can find their users reliably and
consistently. If we can have an app that gets a car service to the right door, we certainly should be able to
get 911 to the right door consistently and reliably. It is a simple public interest obligation.
Late last year, the four largest wireless carriers and two national public safety organizations
submitted their own proposed “roadmap” to address this challenge. The roadmap was a novel approach
that has the potential to close the readiness gap through use of known locations of indoor wireless nodes.
The roadmap proposal was a big step forward, but we also understand and appreciate the valid
criticisms raised by some public safety stakeholders. Our response was to challenge industry to address
the concerns raised by other public safety stakeholders. The carriers responded, and their additional
commitments substantially strengthened the roadmap approach. We will have better data than ever before
about carriers’ location accuracy performance, and we will hold them to account if they do not live up to
their commitments. In addition, the smaller wireless carriers have agreed to the same commitments as the
nationwide carriers, with certain adjustments to reflect their position in the marketplace and their more
limited resources.
The result of these efforts is today’s Order. It is an action that will lead to significant
improvements in 911 location accuracy: taking advantage of the good work done by the carriers, APCO,
and NENA, while also providing confidence-building measures, setting clear targets and deadlines for
improving indoor location, and holding parties accountable for results. This order establishes achievable
benchmarks centered around the commitments made by the carriers and public safety assurances that will
close the 911 readiness gap. That is why I support it.
But let there be no mistake – we are establishing a floor, not a ceiling. It is a beginning, not an
end. We should not be satisfied with a situation where Uber can consistently find a user’s house via an
app, but the EMT’s location fix is within half a football field 80 percent of the time. I hope our efforts
will encourage app developers to work with the public safety community to develop an “Uber for 911.”
Imagine – the carriers would be improving their capabilities, while “there’s an app for that” could harness
the capabilities that enable Google, Uber, or Waze to find a consumer with pinpoint accuracy.
Together we can and will deliver on the promise of new technology to make Americans safer.
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CONCURRING STATEMENT OF
COMMISSIONER MIGNON L. CLYBURN
“Police dispatchers could do little but listen to Reinaldo Zayas scream, as he was tortured to death
by a gang of kidnappers… The 25-year-old somehow managed to dial 9-1-1 twice from his cell phone
after his abduction. One chilling call lasted 18 minutes, during which dispatchers heard Zayas beg for his
life…Unable to speak, and no way to trace the calls, investigators sat helpless as he was repeatedly
stabbed. Not all cell phones and systems are equipped for wireless tracking, but the federal government
has ordered all carriers to include the technology by 2005.”1
By now, you probably surmised that the sentences I just read were lifted from a news article
about a young man who made not one, but two 9-1-1 calls. However, because no information about his
location was forwarded, those who were in the best position to help could not and he died. But what you
might be even more surprised to learn is since that article was written in June 2003, little has actually
changed. Almost 12 years have passed, yet as I sit before you today, it pains me to say we are far from
meeting reasonable expectations when consumers dial 9-1-1 from their cellphone that law enforcement or
emergency responders will automatically receive the information they need to find you.
Given the current rate at which Americans are adopting mobile services, improving response
times for 9-1-1 calls from cellphones should be an even higher national priority than it was in 2003. The
number of wireless only American households has grown from roughly 16 percent, in 2007, to 44 percent
today. And, for those living below the poverty line, that number has risen to 59.1 percent. An increase in
the number of people, who rely solely on cellphones, means an increase in wireless calls to 911 from
indoors. Indoor 911 calls are more difficult to locate especially in dense urban environments with
multiple, adjacent high-rise buildings. In these indoor environments, it is critical that public safety
entities have horizontal and vertical data about where the 9-1-1 call was made.
In order to improve the accuracy of wireless 9-1-1 location information, all relevant stakeholders
must do their part. I commend Chairman Wheeler for circulating, last February, a Further Notice that put
us on a path toward an efficient development of rules. That item was the first time the Commission had
proposed accuracy standards for wireless 9-1-1 calls from indoor locations. It had stronger 9-1-1 location
accuracy requirements at the two and three-year benchmarks, than what we are adopting today and yes, I
would have preferred the rules that we originally proposed. So today I am concurring.
In my separate statement in support of the 2014 Further Notice, I called on the wireless industry
to show leadership, and move ahead of schedule, to implement the proposed location accuracy rules that
our nation needs. I must commend CTIA, the four nationwide carriers, and APCO and NENA, for
stepping up and answering my call. Last November, they presented us with a roadmap with commitments
to provide more accurate 9-1-1 location information, earlier than the two-year benchmark originally
proposed. For example, within one year of signing the roadmap agreement, the four nationwide wireless
carriers will establish a test bed for 9-1-1 location technologies. Within 18 months, these carriers also
agreed to promote standards that would enable the delivery of barometric pressure data to PSAPs with 91-1 calls and send us reports with their plans for meeting the benchmarks we adopt today. I want to thank
those entities, and my colleagues, for supporting the decision to turn some of those voluntary
commitments, into rules.
Second, this Order has rules that will require industry to demonstrate progress towards providing
vertical location information, which is critical for finding those in high rise buildings. It gives the
1

http://tucsoncitizen.com/morgue2/2003/06/16/188977-legislators-raid-funds-from-911-cell-upgrade/

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industry a reasonable opportunity to pursue a dispatchable location solution, that would send the street
address and if relevant, suite or apartment number, of the calling party.
As APCO and a number of public entities have mentioned, dispatchable location technology,
could put wireless 9-1-1 calls on an equal footing with wireline calls. But as the International Association
of Firefighters told me recently, we should still encourage the development of other vertical location
technology.
I am glad to say today, that within three years of the effective date of this order, we will require
nationwide wireless providers to develop a vertical, or z-axis, location information proposal and submit it
to the Commission for approval. It is my hope that the industry will provide both solutions to firefighters.
To Admiral Simpson, and the dedicated staff of the Public Safety Homeland Security Bureau,
thank you for working so hard on an Order that seeks to close long-standing public safety gaps.

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STATEMENT OF
COMMISSIONER JESSICA ROSENWORCEL
Re:

Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114

I want to start with two stories—two stories that illustrate why what the Commission is doing
today is so important.
First story. The summer before last, Shanika Parker finished working the night shift at her job
outside of Indianapolis. She was on her way home when exhaustion got the better of her. She dozed off
behind the wheel. The next thing Ms. Parker knew, her car was upside down—and quickly filling with
water.
Ms. Parker acted fast. She called 911 from her mobile phone. But when the operator asked
where she was, Ms. Parker could only answer: “I don’t know. I don’t know. Can you please help me?”
Using location information from her mobile phone, local police were able to trace the call. Using
their knowledge of the area, responding officers were able to figure out that her car slid into a pond next
to an interstate on her way home. When the officers arrived on the scene, they found her overturned car.
Mud was oozing through the windows and doors. Time was running out.
Fortunately, this story ends well. But by the time the police pulled Ms. Parker out from the car
she had only eight inches of air left. Still, this story shows very clearly what first responders can do with
the right tools—that is, with accurate location information.
Second story. Mary Thomas suffered a stroke in New York. Ms. Thomas knew something was
wrong. So she mustered up the strength to call 911. But the stroke had taken its toll. Her speech was
slurred. She was unable to tell the dispatcher where she was and what help she needed.
So the first responders turned to technology. The tower information for Ms. Thomas’s mobile
phone gave an address for the call. But the address was wrong. It turns out that on the Upper East Side
of Manhattan, it can be easy to get lost. Lots of buildings, lots of floors, lots of apartments stacked high
in the sky. In fact, first responders in New York followed several false leads trying to track the call. All
in all, they searched for eight hours before they found Ms. Thomas. She died the next day.
These stories illustrate very clearly what we all know intuitively. When the unthinkable occurs
you want first responders to find you—no matter where you are—indoors or out—and no matter what
kind of phone you use to make that call.
That is why what we do here today is so critical. The number of wireless calls to 911 is
skyrocketing. In fact, more than 70 percent of 911 calls are now made from wireless phones. That is
more than 400,000 calls across the country every day. This number is only going to grow. Because
today, for roughly 2 in 5 households, their wireless phone is their only phone.
So the way we connect and call is changing. But until today our policies providing first
responders with information about where we are when we call 911 have been stranded in the calling
practices of the last century. They provide for location information for 911 calls made using wireline
phones. They provide for location information for 911 calls made outdoors using wireless phones. But
for calls made indoors using wireless phones your best bet would be to cross your fingers and hope and
pray, because no location accuracy standards apply. This gap is unacceptable. It does not reflect the way
we now reach out for help in our moment of greatest need.
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Today, at long last, we take steps to fix this problem and close this gap. For the first time, we
bring indoor dispatchable location into our wireless location accuracy policies. This is big—and it is
bound to save lives. Because, as Steve Souder from the Fairfax County Department of Public Safety
Communications suggests, before a blue and red light flashes, before a whistle on the volunteer fire
station blows, before a pager rings, or an air horn blares—the front line of public safety in the United
States are the people who answer your 911 call. When they have more information about where you are
when you call, we are all safer. He’s right—and his words illustrate the importance of that call made by
Ms. Parker in Indiana, by Ms. Thomas in New York, and by hundreds of thousands of us each and every
year.
Our effort today has taken a lot of work and wrangling. Thank you to the countless first
responders and the authorities at the Association of Public Safety Communications Officials International
and National Emergency Number Association who helped us in this process. Your insights and assistance
have been invaluable. Thank you also to the Chairman for making this effort a priority and Admiral
Simpson and the Public Safety and Homeland Security Bureau for pushing this issue forward.
Finally, we owe a debt of gratitude to the bipartisan support this initiative has received from
Capitol Hill. Last year, the Senate Committee on Commerce, Science, and Transportation held a hearing
to bring focus to this problem. Senator Schumer also pressed us to modernize our rules—and get this
right. In particular, he called for us to update our policies to give first responders the information they
need to help us in our hour of need. In addition, Congressman Upton and Congressman Pallone
encouraged this agency to put a premium on dispatchable location—and get this done. For their support
and willingness to champion this important public safety matter, we are grateful.

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STATEMENT OF
COMMISSIONER AJIT PAI
Whoever you are or from wherever you are calling, 911 has to work. It doesn’t matter if you’re
in a school or library, a hotel or motel, an office or government building; your call needs to go through,
and emergency responders need to be able to find you.
That is why I supported the commencement of this proceeding last February—because it is time
that 911 calls provide emergency responders with accurate location information regardless of whether the
caller is indoors or outdoors. My goal, as I said back then, was to adopt rules that are both “aggressive
and achievable.”1 At the time, I expressed concern that the NPRM’s proposals would fail to meet that
test. And that concern was borne out by the record in this proceeding, which shows that our original
proposals were impractical and unrealistic.
So I am pleased that we’ve adjusted course and are now adopting requirements that meet those
two watchwords. I am also glad that the framework we’re putting in place puts us on a path to providing
emergency responders with a “dispatchable location”—that’s the room, office, or suite number where the
911 caller is located. Public safety organizations have described this as the “gold standard” for indoor
location accuracy because it tells first responders exactly which door they need to knock on, or in some
cases, kick in during an emergency.2
I commend all the parties that worked cooperatively on this important issue. Although I had
concerns with this Order when it first circulated, I appreciate the changes that have been made and would
like to thank Commissioner Rosenworcel in particular for helping steer the item down a better path. I am
pleased too that the Order now makes it clear that nothing in our decision authorizes the use of any nonU.S. satellite system in conjunction with the 911 system. I will thus be voting to approve.
Finally, I would be remiss if I did not take a moment to mention another issue that affects
millions of Americans when they dial 911 from indoor locations. As some of you might recall, I
launched an inquiry a year ago to ensure that dialing 911 always works.3 I started the effort after hearing
about the tragic death of Kari Rene Hunt Dunn in a Marshall, Texas hotel room. As I’ve recounted
before, Kari’s daughter tried calling 911 four times, but the call never went through because the hotel’s
911 system required guests to first dial a “9” to get an outside line.
After hearing this story, I gave Kari’s father, Hank Hunt, my personal commitment that I would
do my best to ensure that no one—and no child—would ever again confront that situation. Last week, I
had the chance to visit Marshall, Texas and the 911 dispatch center where the call from Kari’s daughter
would have—and should have—gone. I was honored to stand with Kari’s father, Hank—someone whose

Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114, Notice of Proposed Rulemaking 29 FCC
Rcd. 2374 (2014) (Statement of Commissioner Ajit Pai Approving in Part and Concurring in Part),
http://go.usa.gov/SQXV.
2

See, e.g., Letter from Derek Poarch, Executive Director, APCO International to Marlene Dortch, Secretary, FCC
(Jan. 21, 2015), http://go.usa.gov/SQXH.
3

See Statement of FCC Commissioner Ajit Pai on the Importance of Connecting Americans to Emergency
Personnel Whenever They Dial 911 (Jan. 13, 2014), http://go.usa.gov/9DxJ; Remarks of Commissioner Ajit Pai at
the 9-1-1 Goes to Washington Conference (Mar. 24, 2014), http://go.usa.gov/9DjA; Statement of FCC
Commissioner Ajit Pai Regarding the Ongoing Inquiry into Consumers’ Ability to Reach Emergency Personnel
Whenever They Dial 911 (June 24, 2014), http://go.usa.gov/NNj4.

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courage, fortitude, and determination is humbling and inspiring. And I was pleased to report on the
progress that’s been made in just one year’s time.4
While both my progress report and a shorter summary are available on the Commission’s
website, I wanted to take just a minute to highlight some of the progress that’s been made. By raising
awareness and through voluntary efforts, we are now on track to have solved this problem by the end of
the year at all Country Inn & Suites, Crowne Plaza, Doubletree, Embassy Suites, Fairfield Inn, Four
Points, Gaylord, Hampton Inn, Hilton, Holiday Inn, Hyatt, InterContinental, La Quinta, Marriott, Motel 6,
Park Plaza, Radisson, Residence Inn, Ritz-Carlton, St. Regis, Sheraton, Staybridge, W, and Westin
properties. That’s real progress.
Manufacturers and vendors of multi-line telephone systems (MLTS) have also stepped up to the
plate. Today, half of surveyed vendors ship all of their MLTS products with a default setting of direct
911 dialing—this includes NEC, Shortel, Vertical, and Windstream—and 100% recommend that their
products be set up to allow for direct 911 dialing.
Bottom line: we’re getting serious and substantial results. It’s been an honor to work alongside
Hank, Mark Fletcher, the American Hotel & Lodging Association, the National Emergency Number
Association, and many others to solve this problem. I look forward to continuing our labors and making
further progress in the time to come.

See Remarks of FCC Commissioner Ajit Pai on Connecting Americans to Emergency Personnel Whenever They
Dial 911 (Jan. 23, 2015), http://go.usa.gov/SQ5k; see also Summary of FCC Commissioner Ajit Pai’s Report on the
Progress Being Made to Ensure that Dialing 911 Always Works (Jan. 23, 2015), http://go.usa.gov/SQ5P.

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STATEMENT OF
COMMISSIONER MICHAEL O’RIELLY
Over the past few months, I have been fortunate to visit several Public Safety Answering Points
(PSAPs). From New York City, to Fairfax County, Virginia, to Anchorage, Alaska, dedicated and
hardworking 911 call takers have expressed the great need for better location information. The location
of the caller can be the single most critical data point taken during each emergency call, as demonstrated
by the fact that the first thing some call centers ask is “where is your emergency?” not “what is your
emergency?” For this reason, I support today’s item that will facilitate the ability of 911 call takers to
access quicker and more accurate location information for wireless callers that contact 911 during
emergencies, especially when they are indoors. This is a particular concern as it pertains to more densely
populated locations, including urban centers with skyscrapers and high-rises.
In the February 2014 Notice of Proposed Rulemaking (Notice), the Commission challenged the
wireless sector and public safety community to develop a “consensus approach” to improve indoor
location accuracy.5 I applaud the wireless industry, NENA and APCO for stepping up to the plate and
putting forth a “roadmap” to deliver “dispatchable location,” the so-called gold standard of emergency
location information, sooner than expected. By providing the address, along with other information such
as floor, apartment or suite, emergency services will be able to locate the person in need and administer
assistance faster than ever before, when seconds count.
By setting a goal to provide dispatchable location to first responders within specified timeframes
and with specific performance results, however, we are tasking industry with a quite a challenge. In
response to the 2014 Notice, I cautioned that deadlines needed to be realistic and that we should not adopt
rules based on unproven technologies that have not been commercially deployed. Within the modified
roadmap confines, industry and public safety are prepared to take on this challenge, along with testing
alternative technologies if dispatchable address cannot be timely deployed. In fact, I am able to support
today’s item because we are adopting a compromise that addresses many of the concerns raised on this
issue. I am sure that everyone – including my colleagues and stakeholders alike – can look at what is
being adopted today and see particular portions that they would have done differently, but this is a
consensus document receiving all of my colleagues’ support and it skillfully balances all of the competing
interests.
Ultimately, this item should serve to bring tremendous benefits forward for all concerned. The
public safety community will receive more precise information, in the desired format, to increase
efficiency and rapidly respond to emergencies. Industry has a path forward that will likely be achievable
in the timeframes provided. Moreover, companies will not be faced with a single vendor solution or
possibly forced to build out multiple indoor location solutions, wasting money and stranding investment.
And, the real winners, of course, are American consumers, who, in time, will be more locatable by first
responders when placing a wireless call.
Today, the Commission is successfully implementing a voluntary industry and public sector
compromise, albeit after several rounds of revisions. And, the plan put forth will hopefully reduce the
need for future action and waivers down the road, as experienced during the previous location accuracy
proceeding.
Separately, I renew my concern that the location information resulting from the implementation
of this item could be used by government agencies to pinpoint the location of law abiding Americans.
5

Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114, Third Further Notice of Proposed
Rulemaking, 29 FCC Rcd 2374 (2014).

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While this is not the direct responsibility of the Commission, I trust that appropriate oversight, including
congressional involvement, will seek to ensure that this information is not used or abused to the detriment
of the American people. Improving location accuracy for wireless 911 callers should not happen at the
expense of greater exposure to surveillance or monitoring by government officials. It is to help public
safety during emergencies, not limit the freedoms and lawful activities of American citizens.
I thank the Chairman and my fellow Commissioners for agreeing to this approach, and I thank the
Public Safety and Homeland Security Bureau for their hard work.

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