In the last few months, there’s been a lot of talk about the location data used by the public safety community to locate wireless 911 callers and on Monday the FCC will hold a workshop to discuss wireless location accuracy. So, I think it is important to highlight that CTIA and its members have a long history of developing and deploying 911 solutions and working with the public safety community on 911 implementation and continued improvement. The industry also has a long history of meeting its obligations, and the facts show wireless carriers continue to deliver the important information that is used to respond to 911 calls.
That is why it is troubling to see some recent press releases by a new organization that ignore key and well-recognized aspects of wireless technology and our 911 system. These press reports, which appear to rely on misleading claims, seem designed to undermine public trust in the 911 system, rather than to advance the discussion about continually improving 911. As 911 stakeholders know all too well, progress in this field requires hard work and clarity of purpose – and to do that, it’s important to get the facts straight. I’d like to do that here.
For nearly twenty years, the wireless industry has been committed to advancing 911 and working with the public safety community. In fact, wireless carriers and the public safety community have a history of working together to come up with common understandings of providing Public Safety Answering Points (PSAPs) with wireless 911 callers’ location information. Since the more recent debate has specifically focused on the delivery of “Phase II” E-911 location information to PSAPs, here’s what we know:
- In 2008, wireless carriers and public safety organizations, NENA and APCO, agreed on an approach to provide granular location data. The new location technologies used to generate more accurate location data (Phase II) had specific technical parameters that would need to be considered in PSAP operational procedures.
- Determining a wireless caller’s location in topographically diverse mobile environments is technically challenging. In many instances, cell-site (Phase I) location information is delivered with the 911 call to allow the call-taker to begin responding to the emergency. While wireless carriers have expended significant resources to deploy innovative technologies to acquire enhanced location data, these more granular types of location fixes can take more time to acquire the data. Thus, Phase II location information is made available to a PSAP as soon as possible, usually within 30 seconds of the call initiation.
- As a result, the FCC’s technical standards and NENA and APCO’s PSAP best practices recognize these technical realities and recommend that PSAPs engage in a process known as “re-bidding” 30 seconds after the call’s initial delivery, if necessary, to acquire Phase II location information.
More recently, a handful of public safety representatives and a new organization have sent reports to the press and policymakers that claim there is a problem with wireless carriers’ delivery of “Phase II” location information with 911 calls. Wireless carriers took these claims seriously and promptly investigated, and a number of PSAPs also looked at their own data. In filings to the FCC, wireless carriers and several PSAPs submitted detailed data that demonstrates that wireless carriers deliver Phase II location information with calls to 911 in accordance with FCC rules, technical standards as well as NENA and APCO best practices. This data makes clear that wireless carriers are meeting their 911 commitments to consumers and the public safety community.
So, why is there a discrepancy in these findings? Well, the reports claiming the lack of Phase II location information do not account for the practice of “re-bidding.” In fact, AT&T, Sprint, T‑Mobile and Verizon Wireless each reported that the relevant PSAPs did not appear to perform re-bids for many 911 calls in accordance with NENA and APCO best practices, leading to inaccurate conclusions about carrier performance. CTIA and our member companies have offered to partner with the public safety community in further study about PSAP re-bid utilization and have suggested guidelines to ascertain more accurate results. We stand by that offer.
Unfortunately, a newly formed organization is choosing to ignore the key technical and operational aspects of Phase II location information delivery. The Find Me 911 Coalition, funded by an E-911 technology vendor, recently issued press releases with data filed with the FCC by PSAPs in Texas and Delaware County, Pennsylvania that claims to show more than 2/3 of 911 calls from cellphones being delivered without Phase II location information. But, as I’ve noted in this blog, these claims don’t account for the well-established principles and practices of Phase II location information delivery.
In fact, the coalition’s releases continue to ignore data filed by PSAPs in the very same FCC docket that takes these factors into account and shows that wireless carriers provide Phase II location information at high levels.
- For example, in the San Antonio, Texas area, the Bexar Metro 911 Network District concluded that “Bexar Metro is satisfied that all wireless carriers within our area of responsibility are meeting or exceeding the minimum Phase 2 accuracy requirements set by the FCC.” Bexar Metro further observed that the “data collected confirms there is no degradation of Phase 2 accuracy within the Bexar Metro service area or with a carrier’s ability to provide Phase 2 location data upon receipt of a manual rebid request from the PSAP.”
- In addition, King County, Wash., the 14th most populous county in the country, implemented E911 nearly 30 years ago and has been a PSAP leader in E911 policy for many years. In response to the FCC’s outreach on location data, King County provided data and explained the challenges associated with E911 location data: “we recognize that today’s wireless 911 location technologies are not perfect” and so “we have prioritized the accuracy of the location above the speed with which the location is delivered.” As the filing noted, “doing a rebid allows the PSAP to obtain the Phase II location that becomes available after the call has been delivered.” King County reported that its percentage of calls with Phase II location was “much higher” than what was reported by PSAPs asserting Phase II problems, and the imporant difference was King County’s rebid policy.
So, as the FCC convenes its workshop on 911 issues today, I remain optimistic that, working together, we can make accurate assessments of the progress we have made so far, the strengths that currently exist and the challenges that remain in our continuing efforts to enhance 911. It is worth repeating one more time: CTIA and wireless carriers are committed to work with those public safety entities interested in holding a reasonable discussion about continuing to enhance our 911 system to benefit the American public. Working together, we can identify valid issues, devise meaningful solutions and invest the appropriate resources to continue to advance wireless caller location data and the safety of consumers.