CTIA and our members have a long history of supporting the first responder community, and we share the FCC’s goal to provide them, including those in the Public Safety Answering Points (PSAPs), with the tools needed to accurately identify a 911 caller’s location, regardless of whether they are located indoors or outside. Our member companies’ engineers and technical teams are hard at work every day trying to improve our subscribers’ experience and tackling challenges like potential improvements to the E-911 system.
As we shared with the FCC yesterday, we noticed three themes the Commission should consider before moving forward with timelines, benchmarks and regulations:
- Multiple stakeholders, including public safety representatives, share the view that a consensus plan offers a promising path towards achieving lasting improvements in 9-1-1 and warrants pursuit.
- There is no verified evidence in the record that demonstrates any current technology meets the location requirements in the FCC’s proposed timetable.
- Rather than pursuing the proposed initial indoor accuracy benchmarks, the Commission should encourage a focus on technologies that show promise for provisioning a dispatchable address to 911 call centers, often viewed as the “gold standard” of 911 location accuracy.
Prior to implementing any new benchmarks, the Commission should allow a test bed to validate the technical feasibility and commercial reasonableness of candidate technologies. By conducting an independent testing process, we’ll be able to see what technology is available, and whether it’s deployable and scalable. And a test bed would independently verify that proposed solutions could meet new regulations, accuracy requirements and timelines sought by the FCC.
Further, many stakeholders watching this issue expressed widespread support for the test bed “safe harbor” approach, where a carrier is deemed in compliance with accuracy requirements once the test bed-certified technology is deployed in a manner consistent with the test bed methodology.
We remain committed to working with the Commission and first responders on a collaborative process to advance indoor location accuracy for 911 callers.