11806 Federal Register / Vol. 80, No. 42 / Wednesday, March 4, 2015 / Rules and Regulations 

FEDERAL COMMUNICATIONS 

COMMISSION 

47 CFR Part 20 

[PS Docket No. 07–114; FCC 15–9] 

Wireless E911 Location Accuracy 

Requirements 

AGENCY: Federal Communications 

Commission. 

ACTION: Final rule. 

SUMMARY: In this Fourth Report and 

Order, the Federal Communications 

Commission (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 indoors. It also strengthens 

its existing E911 location accuracy rules 

to improve location determination for 

outdoor as well as indoor calls. 

DATES: This final rule is effective April 

3, 2015 except for 47 CFR 

20.18(i)(2)(ii)(A) and (B); 20.18(i)(2)(iii); 

20.18(i)(3)(i) and (ii); 20.18(i)(4)(i), (ii), 

(iii) and (iv); and 20.18(j)(2) and (3), 

which contains information collection 

requirements that have not been 

approved by the Office of Management 

and Budget. The Commission will 

publish a document in the Federal 

Register announcing OMB approval and 

the effective date. 

FOR FURTHER INFORMATION CONTACT: 

Dana Zelman of the Policy and 

Licensing Division of the Public Safety 

and Homeland Security Bureau, (202) 

418–0546 or dana.zelman@fcc.gov. For 

additional information concerning the 

Paperwork Reduction Act information 

collection requirements contained in 

this document, contact Benish Shah, 

(202) 418–7866, or send an email to 

PRA@fcc.gov. 

SUPPLEMENTARY INFORMATION: This is a 

summary of the Commission’s Fourth 

Report and Order in PS Docket No. 07– 

114, released on February 3, 2015. The 

full text of this document is available for 

public inspection during regular 

business hours in the FCC Reference 

Center, Room CY–A257, 445 12th Street 

SW., Washington, DC 20554, or online 

at https://apps.fcc.gov/edocs_public/

Query.do?numberFld=15- 

9&numberFld2=&docket=07- 

114&dateFld=&docTitleDesc=. 

Synopsis of the Fourth Report and 

Order 

I. 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; 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, 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). We believe the Roadmap and the 

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, 79 FR 17820 (Mar. 28, 2014), 

and recent ex parte submissions by the 

parties to the Roadmap. 

6. Incorporating all of these elements, 

we adopt the following E911 location 

rules: 

Horizontal Location 

• All CMRS providers must 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 

rules adopted in this Order (‘‘Effective 

Date’’): 

Æ Within 2 years: 40 percent of all 

wireless 911 calls. 

Æ Within 3 years: 50 percent of all 

wireless 911 calls. 

Æ Within 5 years: 70 percent of all 

wireless 911 calls. 

Æ 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. 


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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: 

Æ 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. 

Æ 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. 

Æ 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): 

D 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. 

D Where z-axis technology is used: 

CMRS providers must deploy z-axis 

technology to cover 80 percent of the 

CMA population. 

Æ 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. 

Æ 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 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. 

• 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 encourage CMRS providers to take 

advantage of the potential of rapidlydeveloping 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. 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. 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. 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. 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 (A– 

GNSS) technology in wireless networks 

and the prospect of improved location 

technologies that will soon support 911 

communication over LTE networks. 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 


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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. 

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.’’ 

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 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,’’ adding that ‘‘the 

Roadmap commits to meaningful 

improvements and FCC-enforceable 

timeframes to deliver effective location 

solutions.’’ On November 20, 2014, we 

sought expedited comment on the 

Roadmap. 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. The Parallel 

Path for the most part tracks the 

Roadmap, and commits the nonnationwide 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. 

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. 

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. 

15. The record in this proceeding— 

including the CSRIC test bed results, 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. 

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. 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. In response to this inquiry, 

commenters indicate an ‘‘ongoing, 

dramatic increase’’ in the number of 

wireless calls placed from indoors. 

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. 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. 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.’’ 

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. 

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. By the 

end of 2013, there were nearly 336 

million wireless subscriber connections. 

At the end of 2007, only 15.8 percent of 

American households were wirelessonly. 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. 

Furthermore, adults living in or near 

poverty and younger Americans are 

more likely to live in wireless-only 

homes than are higher-income adults. 

Several major CMRS providers reflect 

this trend by marketing wireless service 

as a replacement in the home for 

traditional landline service. 

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 

accurate location data for many wireless 

calls placed from indoor locations, 

particularly in urban areas where a 

growing number of Americans reside. 

This highlights the critical importance 

of the enhanced indoor wireless indoor 

location accuracy rules that we adopt 


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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. 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). 

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 within five years. We proposed 

establishment of an indoor location 

accuracy test bed for demonstrating 

compliance with these requirements, 

and asked about other approaches to 

validating compliance. 

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. 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. 

24. Subsequent to the close of the 

comment period, NENA, APCO, and the 

four national CMRS providers submitted 

the Roadmap agreement. 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). 

The Roadmap also specifies that, 

beginning at Year 2 of Roadmap 

implementation and extending through 

Year 8, the CMRS providers will 

introduce VoLTE-capable 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. 

25. As originally proposed, the 

Roadmap contained the following 

horizontal location accuracy 

performance benchmarks: 

Æ 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) Satellitebased (A–GNSS) location, (2) 

dispatchable location, or (3) ‘‘any other 

technology or hybrid of technologies 

capable of location accuracy 

performance of 50 m[enters].’’ 

Æ 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). 

Æ 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). 

Æ 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). 

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 

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. 

27. The Roadmap commits CMRS 

providers to use live 911 call data to 

demonstrate compliance with these 

metrics. 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). 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. 

28. Rather than propose a specific zaxis 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 standardsbased z-axis solution (e.g., use of 

barometric sensors in handsets). 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. 

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 nonVoLTE) 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. 


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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. 

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. 

32. Some vendors praise the Roadmap 

as a meaningful step toward improved 

indoor location. 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. 

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. 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. 

The Associated Firefighters of Illinois 

believe that the Roadmap pushes out the 

timeline for improved location accuracy 

too far. IACP and Fairfax County 

support the concept of dispatchable 

location, but question the feasibility of 

the Roadmap’s dispatchable location 

provisions. Multiple commenters 

express concern at the Roadmap’s 

blended metric for indoor and outdoor 

calls. TruePosition cautions that the use 

of GLONASS for 911 may raise political 

and security issues, though APCO, CTIA 

and TCS dispute that use of GLONASS 

poses a security threat. Numerous 

parties highlight concerns with the 

Roadmap’s proposal for the National 

Emergency Address Database (NEAD). 

Some Roadmap Parties submit rebuttals 

to these concerns raised in the record. 

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. 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. 

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. 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. CTIA, 

however, explains that ‘‘the Roadmap 

never states that GLONASS will be the 


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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.’’ 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.’’ 

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) 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. 

Moreover, any such request will be 

subject to a full review and federal interagency 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, 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. 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. 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. 

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, apartment or similar information 

that may be needed to adequately 

identify the location of the calling 

party.’’ 

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. 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. 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, 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. 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. For 

the reasons stated below, we believe the 

Roadmap commitments, including those 


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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 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, 

distributed antenna systems (DAS), WiFi access points, beacons, commercial 

location-based services (cLBS), 

institutional and enterprise location 

systems, and smart building technology. 

These technologies can 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. 

47. The record also confirms that 

many of these technologies can 

contribute to the development of 

dispatchable location solutions in the 

near term. Nearly all wireless phones 

are now equipped with Bluetooth and 

Wi-Fi capabilities, though some 

standardization work remains. 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, 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. 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. 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. 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. Nevertheless, some 

commenters still argue that beacon and 

Wi-Fi technologies have not been 

thoroughly enough tested to justify 

reliance on them in any dispatchable 

location solution. Others submit that the 

Commission should open a separate 

proceeding dedicated to dispatchable 

location. 

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 

third-party stakeholders to be involved 

in the deployment process. 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.’’ T-Mobile suggests that state 

and local governments should modify 

building and fire codes to require 

deployment of such devices throughout 

a building. 

(ii) Handset Hardware and Software 

Changes 

49. Despite the widespread 

availability of Wi-Fi- and Bluetoothequipped phones, 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. 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. The Roadmap Parties commit to 

work with device manufacturers and 

operating system developers in order to 

implement these changes. 

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. The parties also agree to 

enable their VoLTE networks to deliver 

beacon-based location information from 

handsets within 24 months after the 

completion of relevant standards. 

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. 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). 

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. 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. 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. 

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.’’ 

53. The Roadmap commits the four 

nationwide CMRS providers to promote 


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development and approval of standards 

within 18 months of the date of the 

Agreement, as well as to formally 

sponsor standards efforts regarding the 

use and delivery of Bluetooth LE and 

Wi-Fi information to the network. 

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. The parties also 

agree to sponsor standards activities to 

operationalize the display of 

dispatchable location in pre-NG911 

PSAPs. 

(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. 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 WiFi nodes to assist in locating users of 

cLBS applications. 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, verify the 

trustworthiness and accuracy of the 

data, and keep the data up-to-date. 

CMRS providers also contend that 

developing and managing secure 

location databases will require the 

cooperation of building owners and 

state and local governments. 

55. The Roadmap addresses the 

database issue by proposing a plan for 

the implementation of a National 

Emergency Address Database (NEAD). 

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. When the device ‘‘sees’’ the 

MAC address of this particular device, 

the CMRS network would crossreference 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 

months of the Agreement. The Parallel 

Path makes a similar commitment 

within the 12-month timeframe. 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.’’ 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. 

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. For example, 

NASNA states that ‘‘the carriers 

promised to ‘take steps to make nonNEAD 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.’’ 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. 

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.’’ 

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. 

Specifically, Public Knowledge cautions 

that the NEAD would contain sensitive 

personal information, 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.’’ 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. 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), and 

determine what safeguards would apply 

to information that may not constitute 

CPNI. Public Knowledge urges that the 

Commission address these privacy 

issues now and encourages the 

Commission to adopt a ‘‘privacy by 

design’’ approach. 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.’’ 

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.’’ TCS adds that 

‘‘our current public safety infrastructure 

contains much more sensitive 

information than what the Roadmap 

envisions.’’ 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 be limited ‘‘to access for 911 

purposes and only during the 

processing of 911 calls.’’ Sprint states 

that privacy related concerns ‘‘will be 

addressed in the context of working 

groups.’’ 

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.’’ 

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. 

(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. 

NASNA submits that ‘‘E911 location 

databases and call-handling software 


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products have a field that is used in 

wireline calls to identify apartment 

numbers. This field could be used to 

display this information.’’ 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.’’ 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,’’ a process 

which it describes as ‘‘relatively simple 

straightforward.’’ Nevertheless, Intrado 

and TCS caution that changes at the 

PSAP level would be necessary. 

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 the Roadmap. 

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.’’ 

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. 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.’’ 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. 

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. 

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.’’ 

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 nonnationwide CMRS providers. In light of 

the Amended Roadmap and Parallel 

Path, 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. 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. 

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. 

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. 

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. 

Although some commenters contend 

that the NEAD does not present a greater 

threat to data privacy than already exists 

today, the Roadmap and Parallel Path 

Parties agree that there is a need for 

privacy and security measures to be 

implemented with the NEAD. 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 


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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. We note that the Roadmap Parties 

specifically commit ‘‘to 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.’’ 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.’’ 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. 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, 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 non-emergency purposes. 

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 will be 

used exclusively for 911 purposes.’’ 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, 

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. 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. 

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. 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. However, as 

many commenters point out, the 

Roadmap contains no guarantee that 

dispatchable location will be 

successfully deployed or will function 

as intended. Therefore, to ensure 

sufficient location accuracy for all 

wireless indoor 911 calls, we find it 

necessary to adopt coordinate-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. 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 


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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, 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’’): 

Æ Within 2 years: 40 percent of all 

wireless 911 calls. 

Æ Within 3 years: 50 percent of all 

wireless 911 calls. 

Æ Within 5 years: 70 percent of all 

wireless 911 calls. 

Æ Within 6 years: 80 percent of all 

wireless 911 calls. 

• Non-nationwide CMRS providers 

are subject to the same two- and threeyear 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: 

Æ 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 

Æ 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). 

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. We reasoned that a search 

radius of 50 meters had a reasonable 

likelihood of identifying the building 

from which the call originated, while a 

search radius larger than 50 meters was 

unlikely to assist first responders in 

building identification. 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). We noted that our current 

outdoor-based 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. 

76. Public safety commenters 

overwhelmingly support the proposed 

50-meter standard, although some 

express a preference for a smaller search 

radius than 50 meters. 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.’’ 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. 

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. 

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 

incorporate and distinguish accurate 

WLAN-based signals of opportunity as 

well as by providing more accurate 

geodetic location information for reverse 

geo-coding. 

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. 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. 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. Many other commenters, 

however, argue that the Third Further 

Notice’s benchmarks and timeframes are 

both achievable and reasonable. 

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. 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. 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. 

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. 

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. Many other commenters cite 

similar reasons for supporting the 

proposed Roadmap horizontal location 

metrics. For example, CCA believes the 

Roadmap ‘‘is a well-balanced proposal 

aimed at improving enhanced location 


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accuracy standards for both outdoor and 

indoor calls to 911, while also 

establishing benchmarks for providing 

‘dispatchable location’ to first 

responders.’’ 

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. 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), 

and extends the overall implementation 

period from five to six years. Many 

commenters also object strongly to the 

five- and six-year Roadmap benchmarks 

because they only consider VoLTE 911 

calls in measuring compliance. These 

commenters generally argue that the 

Commission should reject the Roadmap 

and simply adopt the original 

benchmarks and timeframes proposed 

in the Third Further Notice. 

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. CMRS providers 

plan to implement OTDOA in 

conjunction with the rollout of VoLTE. 

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,’’ 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.’’ 

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 secondgeneration system has achieved 

significantly improved horizontal 

accuracy in urban, dense urban, and 

suburban areas, and could meet a fiveyear performance metric of 50 meters for 

80 percent of indoor calls. 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. 

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. 

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; it also asserts that UTDOA 

is commercially available, that LMUs 

could be deployed rapidly, and that 

implementation does not require 

replacement or upgrading of handsets. 

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. 

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. 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. 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. 

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,’’ 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.’’ 

(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 testbased 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. 

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 and in the rules we adopt in 

this Report and Order, 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 


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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. 

92. Regarding horizontal location 

information, the Parallel Path commits 

the non-nationwide 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. 

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 indoorspecific 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 

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. 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.’’ 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.’’ 

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. 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. 

96. In addition to dispatchable 

location and OTDOA, CMRS providers 

have several other technologies to 

choose from. While NextNav’s firstgeneration beacon technology fell short 

of 50-meter accuracy in some 

environments in the CSRIC test bed, 

subsequent testing indicates that its 

second-generation MBS technology can 

achieve 50-meter accuracy in suburban, 

urban, and dense urban environments. 

Moreover, the additional year CMRS 

providers will have to meet our 

benchmarks should provide sufficient 

time for deployment of MBS-capable 

handsets. 

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 . . .’’ 

UTDOA is already commercially 

available from two different vendors 

and does not require any handset 

replacement, only updates to the CMRS 

providers’ networks. 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, 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. We also find that should 

CMRS providers decide to pursue 


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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, 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. 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. We 

also sought comment on whether 

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. 

100. In response to the Third Further 

Notice, several commenters express 

support for a targeted application of 

indoor location requirements based on 

population density. 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. 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. SouthernLINC submits that 

‘‘a significant proportion of the nation’s 

regional and rural carriers are . . . 

transitioning their networks and 

systems to LTE’’ 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.’’ Similarly, CCA 

remarks that non-nationwide providers 

are not on the same LTE and VoLTE 

deployment timelines as the nationwide 

CMRS providers. In the Parallel Path, 

CCA urges the Commission to consider 

providing non-nationwide providers 

additional time to meet the five and sixyear horizontal location accuracy 

benchmarks of the Roadmap, so that 

those providers can ‘‘gain access’’ to 

VoLTE handsets. 

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 ‘‘nonnationwide providers.’’ 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 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. 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 naturally-formed 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 non-nationwide 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 nonnationwide CMRS providers that use 

handset-based location technologies 

already rely extensively on satellitebased 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 nonnationwide 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. 

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 

network 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. Non-nationwide 


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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 deploy LTE (much less 

VoLTE) on the same or even similar 

timeline as the nationwide carriers.’’ 

More specifically, due to the limited 

scale and scope of their networks, nonnationwide CMRS providers often have 

limited access to handsets that 

incorporate the latest technologies 

driven by the handset product cycles of 

the nationwide CMRS providers. In light 

of these challenges, some nonnationwide provides may face 

unavoidable delays in obtaining VoLTEcapable handsets and testing and 

deploying them in their networks. 

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. 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 percentile and demonstrated 

improvements in subsequent testing, 

and other vendors estimated having 

similar granular capabilities within 

three to five years. 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. These 

developments indicated that vertical 

location technology had sufficiently 

matured to propose the inclusion of 

vertical location information for indoor 

wireless 911 calls. We sought comment 

on whether an initial benchmark of 

three years would be achievable. 

106. Public safety and consumer 

commenters urge the Commission to 

adopt indoor location accuracy 

requirements as quickly as possible, 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. 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. 

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. 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. 

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. 

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. These commenters stress that 

barometer readings must be calibrated 

in order to provide first responders with 

meaningful information, a process 

which is currently unstandardized. 

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. 

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 zaxis vertical location information. 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. 

Second, they commit ‘‘to develop a 

specific z-axis location accuracy metric 

that would be used as the standard for 

any future deployment of z-axis 

solutions.’’ To demonstrate progress 

along this path, the parties agree to 

‘‘promote the development and 

approval of standards’’ for barometerbased solutions within 18 months. 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. The Addendum 

further commits the nationwide CMRS 

providers to deploy z-axis solutions 

according to specific benchmarks for 

major population centers in the event 

they are unable to provide dispatchable 

location. 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. 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 zcapable by year 7, and 100% of all new 

handset models by year 8.’’ 

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. On the other hand, the parties 

to the Roadmap offer a vigorous defense 

of its vertical location proposals. 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.’’ NENA argues that 

the Roadmap adequately addresses 


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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. Also, CCA 

supports a requirement for nonnationwide 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. Several other parties offer 

their support for the Roadmap’s 

proposals for vertical location, 

including two public safety 

commenters. iPosi suggests a 

compromise that there be a vertical 

location accuracy ‘‘target’’ of 10 meters 

within two years of the adoption of 

rules. Further still, several commenters 

raise concerns that the Addendum fails 

to offer specific benchmarks for vertical 

location. 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. 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.’’ 

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. Some 

commenters argue that PSAPs could 

receive and process vertical location 

information immediately on existing 

consoles, even if they have not 

upgraded to NG911. Other commenters 

argue that even if vertical location 

information were available, a majority of 

PSAPs will not be able to use it 

effectively. Verizon argues that any 

implementation deadlines for vertical 

location information should be tied to 

PSAP readiness across large regional 

areas. 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. 

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. 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 floor-level 

information, we believe that, in light of 

the substantial dispute in the record 

about the feasibility of achieving a zaxis 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, 

and multiple vendors, including those 

who participated in the CSRIC test bed, 

have continued to develop and test 

vertical location technologies, 

challenges remain. We note that vertical 

location information can be provided at 

varying 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. 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. 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 zaxis 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. 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, 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. 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 


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capabilities. We also recognize that nonnationwide 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 z-axis 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 zaxis 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 eightyear 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 nonnationwide 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 z-axis 

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, 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. 

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. 

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. 

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. 

122. Commenters generally support 

the establishment of a test bed for 

technology vendors and CMRS 

providers to demonstrate indoor 

location accuracy. 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. 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 marketby-market testing. Other commenters 

argue that live 911 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. 

123. In June 2014, CSRIC IV WG1 

released its Final Report on 

specifications for an indoor location 


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accuracy test bed that included 

recommendations for methodology, 

management framework, funding, and 

logistical processes. 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. 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. 

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. 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/A–GNSS, dispatchable 

location solutions, and other possible 

location solutions (including but not 

limited to technologies described in PS 

Docket No. 07–114).’’ 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. 

125. Most commenters approve of the 

Roadmap’s commitment to establish a 

test bed consistent with CSRIC III’s 

recommendations. 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. 

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. Some commenters 

contend that the Roadmap test bed 

proposal leaves out key performance 

indicators which serve to demonstrate 

whether a technology meets 

Commission benchmarks. 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. 

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. We believe these 

morphologies are sufficiently 

representative and inclusive of the 

variety of indoor environments in which 

wireless 911 calls are made. 

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. 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.’’ 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. In order to protect vendors’ 

proprietary information, only summary 

data was made available to all other 

parties. 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’ 


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certification is sufficient notification 

that a technology meets our key 

performance indicators. 

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. 

134. In response to the Roadmap, 

multiple commenters support the 

collection and reporting of 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.’’ 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. The Lackawanna County, 

PA District Attorney argues that this 

information should also be made 

available to law enforcement upon 

request. Small and rural CMRS 

providers, however, argue that live 911 

call tracking and reporting would be 

overly burdensome for them. 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. 

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. 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 

morphology. They suggest that such 

reports would be provided within 60 

days following each of the two-, 

three-, five-, and six-year benchmarks. 

135. Discussion. We adopt a modified 

version of the Roadmap’s commitment 

to quarterly reporting of aggregate live 

911 call data for nationwide providers. 

We require the nationwide CMRS 

providers, subject to certain 

confidentiality protections, 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 providerspecific data, but may publish aggregate 

data on its Web site. 

136. We further adopt the Parallel 

Path’s proposal for non-nationwide 

CMRS providers. We modify, however, 

the frequency of reporting for nonnationwide 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, such that the test bed results 

can be reasonably relied upon as 

representative of the technology’s realword performance. Each CMRS provider 

must make this certification on or before 

our 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. 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 


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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. 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. 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. Ultimately, we 

proposed that enforcement of our indoor 

location accuracy requirements would 

be measured with actual call data 

within a PSAP’s jurisdiction, 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 pursuant to our rules. 

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. 

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.’’ 

NextNav submits that applying a PSAPlevel enforcement regime to indoor calls 

‘‘would ensure that compliance testing 

reflects the actual makeup 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.’’ 

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. 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.’’ 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.’’ 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.’’ 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 FCCsanctioned test-bed mechanism that 

accounts for all the morphologies by 

which conformance to the standards 

could be fairly measured for all PSAPs.’’ 

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.’’ 

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. 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. Some public 

safety groups support this approach, in 

hopes of encouraging expeditious 

resolution of location accuracy issues, 

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 inbuilding 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.’’ 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.’’ 

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. In addition, we require 

CMRS providers to collect live 911 call 

data for its entire service area to make 

available to PSAPs upon request. 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 calls and (2) 

provide the CMRS provider with [30] 

days written notice of the PSAP’s 

intention to seek Commission 

enforcement, which shall include all of 


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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. 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. 

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. 

Nevertheless, we sought comment on 

whether there are additional steps the 

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. 

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. BRETSA emphasizes that 

liability protection for 911 services 

should be a matter of state—not 

federal—law. 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.’’ 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. 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. 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. In general, the 

Commission’s rules may be waived for 

good cause shown, pursuant to a request 

or by the Commission’s own motion. 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. 

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 

benchmark, despite good faith efforts, 

may submit a certification to this effect 

six months prior to the applicable 

benchmark. 

156. A number of commenters 

support, or at least do not oppose, the 

idea of an E911-specific waiver relief 

process. 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.’’ BRETSA submits a similar 

argument for ‘‘good faith efforts’’ as a 

basis for granting waiver relief. 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.’’ 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. 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.’’ CTIA argues further that 

‘‘the waiver process should not be a 


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Federal Register / Vol. 80, No. 42 / Wednesday, March 4, 2015 / Rules and Regulations 11827 

weigh station [sic] on the way to 

enforcement.’’ 

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 regulatory 

framework for indoor location accuracy, 

our objective is to implement rules that 

serve the public safety goals established 

by Congress. 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. 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. 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. 

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). 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. 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). 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. 

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. 

161. The large majority of commenters 

affirm the importance of improvements 

to indoor location accuracy. Several 

commenters state that improved 

location accuracy would lead to more 

rapid response time by eliminating time 

and resources spent pursuing incorrect 

addresses and locations. 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. 

Many commenters also agree that 

shorter response times lead to not only 

reductions in mortality, but better 

prognoses for many non-life-threatening 

cases. 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. 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. 

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.’’ 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 lifesaving 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) 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. 

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. 

Sudden cardiac arrest is the leading 

cause of death of American adults over 

age 40, with 9 out of 10 incidents 

resulting in death. 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.’’ 


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Considering the high mortality rate and 

time-sensitive 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. We also 

disagree with AT&T’s argument that the 

Salt Lake City Study’s findings are 

inapposite because the increase in 

wireless cellular phone usage has 

already shortened the amount of time 

that individuals delay before calling 

911. 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. 

165. The DoT’s VSL was designed to 

calculate the value of preventing 

injuries or deaths. 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. 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. 

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. 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. 

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 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. 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. 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. 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. 

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. 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. 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.’’ 

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. Finally, Rx Networks, on 

behalf of smaller CMRS providers, 

advocates for the establishment of a 

centralized and standardized service to 

process location requests. Such a 

clearinghouse solution would entail a 

base station almanac of Cell-IDs and WiFi access point locations, and costeffective provisioning of A–GNSS and 

barometric pressure data among CMRS 

providers. Rx Networks asserts that such 

a solution bridges technical gaps, and 

simplifies business relationships while 

minimizing capital outlays. 

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. 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. 

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. 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 circuitswitched copper-loop networks and 

complete their transition to an all-digital 

IP ecosystem. 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.’’ 

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. In 

light of our commitment to technology 

neutrality, as we emphasized in the 


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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. That 

said, we note that NextNav reports on 

their Web site that it recently secured 

$70 million in funding to maintain and 

operate its MBS network. 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. 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. 

IV. 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). 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. 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. 

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. Some commenters, 

however, urge the Commission to set 

maximum latency at less than 30 

seconds. Industry commenters also 

oppose the proposal to exclude only 

calls of less than 10 seconds. 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 

calculating the location-accuracy 

success rate’’ and that to ‘‘do [otherwise] 

would unfairly mischaracterize the 

provider’s compliance with locationaccuracy benchmarks.’’ 

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 IIcompliant 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 IIcompliant calls, CMRS providers must 

include calls lasting 30 seconds or more 

for which they are unable to deliver a 

Phase II location fix. 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. 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.’’ The record in this proceeding 

similarly indicates that a maximum 

latency interval of 30 seconds is 

technically achievable using current 

location technology, and that improved 

chipsets in devices will further reduce 

the frequency of calls where the TTFF 

takes longer than 30 seconds. 

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. For example, newergeneration A–GNSS may be capable of 

generating a location fix within 12–15 

seconds. 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. 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 


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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. Prior to the submission of 

the Roadmap, some public safety and 

industry commenters supported a 

unitary accuracy standard. Other 

commenters expressed that it is 

premature for the Commission to 

establish such a standard. 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. 

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 handsetbased standard of 50-meter accuracy for 

67 percent of calls, based on outdoor 

measurements only. The last handsetbased benchmark under the current 

Phase II requirements will occur in 

January 18, 2019. 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. 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. The Third Further Notice 

recognized, however, that C/U data is 

not always 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. Additionally, the Third Further 

Notice sought comment on 

standardization of the delivery and 

format for C/U data to PSAPs. 

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. 

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. 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 calltakers. 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. 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.’’ 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. 

185. Moreover, the record indicates 

that a standardized 90 percent 

confidence value will serve to eliminate 

confusion on the part of emergency calltakers and is supported by numerous 

commenters. 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].’’ 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. 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.’’ We find that a 


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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. As 

technology evolves and as location 

accuracy improves over time, we may 

revisit whether to adopt an even higher 

required confidence level. 

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 

approach makes sense . . .’’ Others 

contend that further study is necessary, 

especially as location technologies 

evolve. 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.’’ CSRIC 

IV adds that these parameters can be 

‘‘formatted appropriately for legacy 

PSAPs as well as NG9–1–1 PSAPs.’’ 

188. We find that the costs of 

implementing a standardized 

confidence level should be minimal. 

Because CMRS providers are currently 

required to deliver C/U data to 

requesting PSAPs on a per-call basis, 

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. 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 percall basis. 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. 

189. Finally, we note that commenters 

generally support the delivery of C/U 

data to PSAPs using a consistent format. 

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 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. We also encourage the 

public safety community to continue to 

take measures to ensure that PSAP calltakers 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, and if so, on the 

scope of information that should be 

reported. Numerous commenters 

support this proposal. 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.’’ 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. 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. 

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. 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; (4) confidence 

and uncertainty data for each call; and 

(5) the positioning source method used 

for determining a location fix. 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, 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. In this 

regard, our call tracking requirement 

will serve to encourage transparency, 

accountability, and cooperation among 

stakeholders. 

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. We also 

sought comment on the 


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recommendations set forth in CSRIC 

WG3’s Outdoor Location Accuracy 

Report. 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. 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 ‘spot-checking,’ ’’ as 

previously recommended by CSRIC 

WG3. 

194. Public safety commenters 

support the periodic testing proposal 

and suggest that testing requirements 

should cover both indoor and outdoor 

location accuracy performance. 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.’’ 

195. CMRS providers oppose the 

Commission’s proposal as costly and 

unnecessary. For example, RWA and 

CCA oppose periodic testing as 

burdensome on small rural CMRS 

providers. However, both RWA and 

CCA submit that periodic testing is 

appropriate in case of substantial 

network changes. 

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. 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. 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. 

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 more efficiently and without 

the cost burdens associated with 

periodic testing pursuant to a 

mandatory, established timetable (e.g., 

every two years). 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.’’ 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.’’ 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. 

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.’’ 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,’’ 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. 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 

been addressed by the evolution of 

location technology. 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. 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.’’ As TruePosition submits, ‘‘it 

is entirely likely that complementary 

technologies will exist and operate sideby-side in a given city, town or county.’’ 

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 email to fcc504@

fcc.gov or call the Consumer & 

Governmental Affairs Bureau at 202– 

418–0530 (voice), 202–418–0432 (TTY). 

B. Paperwork Reduction Analysis 

202. 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, we seek 

specific comment on how we might 

‘‘further reduce the information 

collection burden for small business 

concerns with fewer than 25 

employees.’’ 

C. Congressional Review Act 

203. The Commission will send a 

copy of this Fourth Report and Order in 

a report to be sent to Congress and the 


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Government Accountability Office 

pursuant to the Congressional Review 

Act (CRA), see 5 U.S.C. 801(a)(1)(A). 

VI. Final Regulatory Flexibility 

Analysis 

204. As required by the Regulatory 

Flexibility Act of 1980, as amended 

(RFA), an Initial Regulatory Flexibility 

Analysis (IRFA) was incorporated into 

the Third Further Notice of Proposed 

Rulemaking in this proceeding. 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. 

A. Need for, and Objectives of, the Rules 

Adopted 

205. 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. 

206. 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, 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). At the same time, in order to 

provide greater certainty and 

accountability in areas 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. 

207. 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 

208. 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.’’ 

• 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 RF-based technology), 

possibly placing a substantial burden on 

these smaller CMRS providers. 

• 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. 

• 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. 

• Small and rural CMRS providers 

generally believe that live 911 call 

tracking and reporting will be overly 

burdensome for them. 

• Regarding outdoor compliance and 

reporting, RWA and CCA oppose 

periodic testing as burdensome on small 

rural CMRS providers, but both agree 

that periodic testing is appropriate in 

case of substantial network changes. 

• 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. 

C. Description and Estimate of the 

Number of Small Entities to Which 

Rules Will Apply 

209. 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. The RFA generally 

defines the term ‘‘small entity’’ as 

having the same meaning as the terms 

‘‘small business,’’ ‘‘small organization,’’ 

and ‘‘small governmental jurisdiction.’’ 

In addition, the term ‘‘small business’’ 

has the same meaning as the term 

‘‘small business concern’’ under the 

Small Business Act. A small business 


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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). 

210. 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. First, nationwide, there 

are a total of approximately 27.9 million 

small businesses, according to the SBA. 

In addition, a ‘‘small organization’’ is 

generally ‘‘any not-for-profit enterprise 

which is independently owned and 

operated and is not dominant in its 

field.’’ Nationwide, as of 2007, there 

were approximately 1,621,315 small 

organizations. 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.’’ 

Census Bureau data for 2011 indicate 

that there were 89,476 local 

governmental jurisdictions in the 

United States. We estimate that, of this 

total, as many as 88,506 entities may 

qualify as ‘‘small governmental 

jurisdictions.’’ Thus, we estimate that 

most governmental jurisdictions are 

small. 

1. Telecommunications Service Entities 

a. Wireless Telecommunications Service 

Providers 

211. Pursuant to 47 CFR 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.’’ 

212. 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. 

213. 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. 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. For this 

category, census data for 2007 show that 

there were 11,163 establishments that 

operated for the entire year. Of this 

total, 10,791 establishments had 

employment of 999 or fewer employees 

and 372 had employment of 1000 

employees or more. 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. 

214. 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. 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. Of these 

1,307 carriers, an estimated 1,006 have 

1,500 or fewer employees and 301 have 

more than 1,500 employees. 

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. 

215. 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. 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. 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. Of these 1,442 

carriers, an estimated 1,256 have 1,500 

or fewer employees and 186 have more 

than 1,500 employees. 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. In addition, 72 

carriers have reported that they are 

Other Local Service Providers. Of the 

72, seventy have 1,500 or fewer 

employees and two have more than 

1,500 employees. 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. 

216. 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. 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. These small business 

size standards, in the context of 


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broadband PCS auctions, have been 

approved by the SBA. 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. On April 15, 

1999, the Commission completed the 

reauction of 347 C-, D-, E-, and F-Block 

licenses in Auction No. 22. Of the 57 

winning bidders in that auction, 48 

claimed small business status and won 

277 licenses. 

217. 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. 

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. 58. Of the 24 winning 

bidders in that auction, 16 claimed 

small business status and won 156 

licenses. On May 21, 2007, the 

Commission completed an auction of 33 

licenses in the A, C, and F Blocks in 

Auction No. 71. Of the 12 winning 

bidders in that auction, five claimed 

small business status and won 18 

licenses. On August 20, 2008, the 

Commission completed the auction of 

20 C-, D-, E-, and F-Block Broadband 

PCS licenses in Auction No. 78. Of the 

eight winning bidders for Broadband 

PCS licenses in that auction, six claimed 

small business status and won 14 

licenses. 

218. 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. 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. 

219. 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 (AWS– 

3)). 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. In 2006, the Commission 

conducted its first auction of AWS–1 

licenses. In that initial AWS–1 auction, 

31 winning bidders identified 

themselves as very small businesses. 

Twenty-six of the winning bidders 

identified themselves as small 

businesses. In a subsequent 2008 

auction, the Commission offered 35 

AWS–1 licenses. Four winning bidders 

identified themselves as very small 

businesses, and three of the winning 

bidders identified themselves as a small 

business. For 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. 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. 

220. 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. 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. 

221. 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. The SBA 

has approved these definitions. 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. 

222. 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. A small 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. 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. SBA approval of these 

definitions is not required. An auction 

of 52 Major Economic Area (MEA) 

licenses commenced on September 6, 

2000, and closed on September 21, 

2000. 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. 

223. Upper 700 MHz Band Licenses. 

In the 700 MHz Second Report and 

Order, the Commission revised its rules 

regarding Upper 700 MHz licenses. On 

January 24, 2008, the Commission 

commenced Auction 73 in which 

several licenses in the Upper 700 MHz 

band were available for licensing: 12 


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Regional Economic Area Grouping 

licenses in the C Block, and one 

nationwide license in the D Block. 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. 

224. 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. 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. 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 the preceding 

three years. 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. The SBA approved these 

small size standards. 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. A second auction 

commenced on May 28, 2003, closed on 

June 13, 2003, and included 256 

licenses. Seventeen winning bidders 

claimed small or very small business 

status, and nine winning bidders 

claimed entrepreneur status. In 2005, 

the Commission completed an auction 

of 5 licenses in the Lower 700 MHz 

band. All three winning bidders claimed 

small business status. 

225. In 2007, the Commission 

reexamined its rules governing the 700 

MHz band in the 700 MHz Second 

Report and Order. An auction of A, B 

and E block 700 MHz licenses was held 

in 2008. 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). 

226. 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. 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. 

Census data for 2007, which supersede 

data contained in the 2002 Census, 

show that there were 1,383 firms that 

operated that year. 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. 

227. 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). Under the SBA small business 

size standard, a business is small if it 

has 1,500 or fewer employees. 

According to Trends in Telephone 

Service data, 413 carriers reported that 

they were engaged in wireless 

telephony. Of these, an estimated 261 

have 1,500 or fewer employees and 152 

have more than 1,500 employees. 

Therefore, more than half of these 

entities can be considered small. 

228. 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.’’ For this category, Census 

Bureau data for 2007 show that there 

were a total of 2,623 firms that operated 

for the entire year. 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 

229. 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. Thus, under this size 

standard, the majority of firms can be 

considered small. 

230. 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.’’ 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 employees; 219 had from 20 to 

99 employees; and 190 had 100 or more 

employees. 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 

231. In this Fourth Report and Order, 

we require nationwide CMRS providers 


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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, nonnationwide 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. 

232. 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: 

Æ Within 2 years: 40 percent of all 

wireless 911 calls. 

Æ Within 3 years: 50 percent of all 

wireless 911 calls. 

Æ Within 5 years: 70 percent of all 

wireless 911 calls. 

Æ Within 6 years: 80 percent of all 

wireless 911 calls. 

• 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. 

233. All CMRS providers must meet 

the following requirements for provision 

of vertical location information with 

wireless 911 calls: 

Æ 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. 

Æ 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. 

Æ 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: 

D 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. 

D CMRS providers must deploy z-axis 

technology to cover 80 percent of the 

CMA population if z-axis technology is 

used. 

Æ 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. 

Æ 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). 

234. 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. 

235. 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. 

236. 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 

237. 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.’’ 

238. 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, and raising the 

possibility of exemptions or waivers for 

small or rural entities. In the Fourth 

Report and Order, we explicitly 

acknowledge that the costs imposed by 

the rules adopted herein ‘‘may present 

a proportionately greater burden to 

smaller CMRS providers, including the 

costs associated with participation in 

the test bed.’’ 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. 

239. 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 


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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. 

240. 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. 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. Absent any such exclusion, 

RWA believes the ability of small and 

rural CMRS providers to achieve 

compliance with the indoor horizontal 

location accuracy requirements in the 

proposed timeframe would be 

problematic. 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. 

241. 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. In particular, 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 benchmark, despite 

good faith efforts, may certify this six 

months prior to the applicable 

benchmark. In response, RWA suggests 

the Commission adopt a safe harbor for 

waiver applicants based on a showing of 

technical infeasibility or financial 

difficulty, 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. 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 . . .’’ 

F. Report to Congress 

242. 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. 

VII. Ordering Clauses 

243. 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, 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, Public Law 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, Public Law 

111–260, 47 U.S.C. 615c, that this 

Fourth Report and Order is hereby 

adopted. 

244. It is further ordered that part 20 

of the Commission’s rules, 47 CFR part 

20, is amended as specified in this 

order, effective April 3, 2015, 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. 

245. It is further ordered that the Final 

Regulatory Flexibility Analysis in 

Appendix C hereto is adopted. 

246. 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. 

247. 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. 

List of Subjects in 47 CFR Part 20 

Communications common carriers, 

Communications equipment, Radio. 

Federal Communications Commission. 

Marlene H. Dortch, 

Secretary. 

Final Rules 

For the reasons discussed in the 

preamble, the Federal Communications 

Commission amends 47 CFR part 20 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 

revising paragraph (h)(3) and redesignating paragraphs (i) through (n) as 

paragraphs (l) through (q), and adding 

new paragraphs (i) through (k), and 

revising newly redesignated paragraph 

(m)(1) to read as follows: 


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Federal Register / Vol. 80, No. 42 / Wednesday, March 4, 2015 / Rules and Regulations 11839 

§ 20.18 911 Service. 

* * * * * 

(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 WiFi 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. 

(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; dispatchable location, or ; 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; dispatchable location or; 

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 zaxis accuracy metrics validated by an 

independently administered and 

transparent test bed process as 

described in paragraph (i)(3)(i) 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;) dispatchable 

location, or ; 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. 

(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) and (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) of this section 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 


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11840 Federal Register / Vol. 80, No. 42 / Wednesday, March 4, 2015 / Rules and Regulations 

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; 

(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. 

Non-nationwide 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 nonnationwide CMRS provider serves more 

than one of the 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) of 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) and 

(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 


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Federal Register / Vol. 80, No. 42 / Wednesday, March 4, 2015 / Rules and Regulations 11841 

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 

(i) The caller’s location with a 

uniform confidence level of 90 percent, 

and; 

(ii) 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 

(j)(1) of this section. 

(3) Upon meeting the 6-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 

(j)(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) through (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) Conditions for enhanced 911 

services—(1) Generally. The 

requirements set forth in paragraphs (d) 

through (h)(2) and in paragraph (j) 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. 

* * * * * 

[FR Doc. 2015–04424 Filed 3–3–15; 8:45 am] 

BILLING CODE 6712–01–P 


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