911 Update: All About Location, Location, Location911 Update: All About Location, Location, Location

If you’re not into communications technology, watching paint dry is way more exciting then talking about 911 and 911 policy -- that’s because you just expect 911 to work in the unlikely but critically important occasion when it’s needed. But lots of talking among many parties, from first responders to communications technology companies to civilians, have gone into formulating the policy decisions that have resulted in the dramatically improved 911 infrastructure and capabilities developed over the past 10 years, and well-publicized issues such as Kari’s Law have continued to help drive the relevant discussions forward. This is all good news.

Now, and through Dec. 10, 2018, we all have the opportunity to get involved ourselves by commenting on a proposed FCC rulemaking focused on the commission’s interest in securing more accurate and platform/vendor-neutral location-specific identification information provided to Public Safety Access Points (PSAPs) when 911 is dialed. In the proposed rulemaking, dispatchable location information must be provided when individuals call 911 not only from multiline telephone systems (MLTS) such as in use at hospitals, universities, and corporate campuses, but also from PBXs, Centrex, key telephone, IP, and hybrid systems.

A few words on history. Kari’s Law Act of 2017 is a federal law requiring that MLTS provide direct access 911 dialing and on-site notification systems, and Ray Baum’s Act requires the FCC to complete a proceeding to consider the adoption of rules that “ensure that the dispatchable location is conveyed with a 911 call, regardless of the technological platform used and including all calls from MLTS.” Under Kari’s Law, all MLTS installed, sold, operated, or managed must be configured to allow a user direct access to 911 without the need for dialing an extra digit, code, prefix, or suffix. In addition, under Kari’s Law, the system must notify a central location at the facility that an emergency call has been made. As rules currently stand, any MLTS manufactured, imported, offered for initial sale or lease, or installed after Feb. 16, 2020, must be compliant with these rules.

Too Much or Just Enough Information?

Is such specificity necessary? That depends on your perspective. But before we get to the question of perspective, consider this input from Steve Souder, former director for the Fairfax County, Va., Public Safety Center, and still very active participant in 911 policy and practice in Maryland, with an incredible 60 years of experience in the field. “With respect to 911 information, the singular most important piece is the ‘where.’ All of the other questions can be answered later, but the ‘where’ is the most important piece of information when the call comes in,” he said.

In January 2015, the FCC determined that all carriers should plan to deploy sophisticated location information based on both horizontal (X and Y coordinates) and vertical (Z coordinates) to identify a caller’s location. It specified that major nationwide wireless providers have their implementation plans ready within 18 months, with deployment to take place by 2021. In 2015, a 2021 deadline seemed a long way in the future, but not so much anymore. “The reality is that the [existing] rules have never required that the carriers provide a useful level of accuracy. In fact, the X and Y coordinates only represent the front door. It’s the Z coordinates that are even more essential and largely not mandated to be in place for some providers until 2021,” Souder said. “Further, the current rules require that by 2021 only 80% of calls made from each carrier must present the accurate location information. For the remaining 20%, the 2021 deadline still doesn’t help.”

With this deadline looming and at least some carriers taking their time (not totally their faults to be sure), and with the passage of both Kari’s Law and Ray Baum’s Act, the FCC has issued the aforementioned Notice of Proposed Rulemaking (NPRM) to clarify requirements on the detail and extent of location information the carriers must provide.

Point Me to Cubicle 2C-231

The matter of what constitutes “dispatchable location information” is constantly debated, as 911 authority Mark Fletcher, Avaya’s chief architect worldwide for public safety, pointed out. “The first thing to consider is the intended recipient of that information. Internal responders have different points of reference than do external responders. Cubicle 2C-231 may be easily cross-referenceable by an internal resource; however, an external resource, unfamiliar with the mapping criteria, would be completely in the dark, despite the ‘accuracy’ of the location information,” he recently reminded me.

Obviously 911 call location is as critical to the caller as the first responder, noted Dan Henry, director of government affairs at the National Emergency Number Association (NENA), in a recent conversation. “Between 70 and 80% of calls made to 911 originate from mobile devices and getting accurate location information is essential. However complex the challenges of mobile location accuracy, identifying actual location from VoIP systems can be more difficult, because instead of being yards off, inaccuracies can be hundreds -- or even thousands -- of miles off,” he said.

As Fletcher noted, the problem is exacerbated when the number of reportable endpoints is an unmanageable quantity. “This is where workflow or the operational procedures become the critical components. What do external responders need to report in order to get the police, fire, or ambulance resources to respond to the right entrance to a building as quickly as possible? How do they gain access to that facility? How do first responders know where cubicle 2C-231 is actually located?” he said, adding, “the problem goes well beyond the quantity and quality of data. The essential challenge is that whatever data is presented must be meaningful and actionable to the person receiving it.”

And then there’s one other issue. Recognizing that location-specific information is valuable, what kind of expenses will providers, and those they’ll pass the charges along to -- i.e., end users -- incur? These expenses will relate not only to setting up the initial database for cross-referencing locations and station IDs, but also to maintaining the information so that it is accurate at all times.

As to whether the NPRM requests too much information, Chris Carver, NENA’s PSAP operations director, told me: “Sometimes FCC reports and orders and government actions do not serve as important a role in providing solutions as they do in stimulating innovation toward new products. The current FCC is fairly adamant about not prescribing specific technologies to fix problems. The NPRM, and FCC action generally seeks to define the problem, but how it’s solved is up to the market.” This approach, he added, “provides an opening for innovators to address public safety challenges.”