Public Safety Advocate: Location Services, When?

The FCC has new rules for locating calls that come into the Public Safety Answering Points (PSAPs), and eventually they will include a third dimension, that being height of the phone above ground. Sadly, the requirements imposed on the carriers for next-generation 9-1-1 are watered down from what is truly needed. I have been told the Federal Communications Commission (FCC) relaxed its requirements at the request of carriers and the national carrier association. In any event, the new rules for incoming location are totally inadequate for locating citizen 9-1-1 callers and first responders who may be in trouble inside a building or other structure.

Further, while I have no visibility into the FirstNet state plans, I am told the requirement for better inbuilding location seems to indicate these services may not be implemented until 2022. This is too long to wait when there are technologies available today that can meet the most stringent of the public safety requirements and could be put into play much earlier. The FCC has been running test beds for several types of location-based services including GPS and cellular network-based, building a database of Wi-Fi hotspots, using beacons, and other types or combinations of technologies. It appears as though the systems approved by the FCC will be a blend of several different technologies for rural, suburban, and metro-area location services. As stated above, none of the FCC rules currently require anything close to what is needed by the public safety community.

FCC Rules
(taken directly from the FCC Final Report and Order dated January 29, 2015 (PS Docket No. 67-114))

Horizontal location requirements:

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

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

Vertical location requirements:

All CMRS providers must also meet the following requirements for provision of vertical location information with wireless 911 calls, within the following timeframes measured from the Effective Date:

• Within 3 years: All CMRS providers must make uncompensated barometric data available to PSAPs from any handset that has the capability to deliver barometric sensor data.

• Within 3 years: Nationwide CMRS providers must use an independently administered and transparent test bed process to develop a proposed z-axis accuracy metric, and must submit the proposed metric to the Commission for approval.
• Within 6 years: Nationwide CMRS providers 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):
  • Where dispatchable location is used: the National Emergency Address Database (NEAD) must be populated with a total number of dispatchable location reference points in the CMA equal to 25 percent of the CMA population.
  • Where z-axis technology is used: CMRS providers must deploy z-axis technology to cover 80 percent of the CMA population.

• Within 8 years: Nationwide CMRS providers must deploy dispatchable location or z-axis technology in accordance with the above benchmarks in each of the top 50 CMAs.

• Non-nationwide carriers that serve any of the top 25 or 50 CMAs will have an additional year to meet these benchmarks.

Like all FCC rules, some things need clarification. First, the percentages in the horizontal list above are averaged based on the average number of calls received by a PSAP from a given network. They may include rural, suburban, and metro averages to meet the total percentages required.

The dispatchable location must be part of the known addresses in a database that is collected in several ways including Wi-Fi access point locations and other methods. This database is only required to be partially complete.

You can see from the above rules and regulations that none of what the FCC is requiring comes close to being able to accurately locate a  9-1-1 caller. Even when the vertical portion of the rules take effect it appears as though they will fall short of being able to provide an accurate location inside a structure for a 9-1-1 caller or first responders who might be in trouble or need to be directed to a specific location within the structure.

There are FCC test beds set up to test all of the different types of location methods being evaluated and the acronyms will make your head swim. However, the top contenders for meeting the FCC’s rules in the time allocated come down to the following:

• The National Emergency Address Database (NEAD)
• Crowd-sourced Wi-Fi
• Dedicated or managed Wi-Fi locations
• Observed Time Difference of Arrival (OTDOA), based on LTE
• Metropolitan Beacon System (MBS)

Not Good Enough

I do believe that in reality, what the FCC is requiring is not even good enough for 9-1-1 call centers let alone the more granular type of location needed for first responders, and the timeframes for vertical location are a long way out. There are issues with each and every one of the above solutions. Some are not accurate enough to actually locate the 9-1-1 caller or first responder, others, such as the database and Wi-Fi access points, are prone to becoming out of date or unreliable very quickly and they are expensive to maintain. The Metropolitan Beacon System (MBS) system, which does exceed all of the FCC’s requirements is, in reality, the only system good enough for inbuilding location in metro areas but it requires another receiver in every device and it is economical only in metro areas.

The tests continue for 9-1-1 systems, and NIST, PSCR, and many different vendors are pouring money into inbuilding location services sufficient for public safety. One of the above methodologies already meets all of the requirements so there are solutions that can be deployed well ahead of the 2022 timeframe , which I believe is included in the state plans. I believe the states should push back on this date (if it is indeed the date in the plans) and request it be moved up two years. Think about how many public safety lives a solution could save in that two-year period of time.

I do not know which of these solutions or how many of them AT&T and FirstNet are considering to solve the inbuilding issue for location of first responders. I suspect they are evaluating all of them and perhaps some we have not even heard about. But I believe there are technology solutions today that are good enough to solve the inbuilding location problems at least in metro areas, and there are enough other technologies under test, some combination of which will provide for vertical location accuracy precise enough to find people inside buildings in suburban and rural areas. As mentioned, most of the location services offered will be a blend of different technologies. For example, in metro areas, Metropolitan Beacon Systems (MBS) far exceed the FCC requirements while providing the level of 3-axis location required to locate a person inside a building in the metro area. In suburban and rural areas, GPS coupled with one or more of the other technologies already in test should be able to provide a higher level of location than the FCC rules call for.

GPS is a great technology for those outside and with the new systems being launched into space thata are to be integrated into the GPS receivers, it will only improve and become more accurate but it is an outdoor technology and even in a metro area with urban canyons it fails to be sufficiently accurate. The other technologies under investigation and a few more I have heard rumblings about make me believe the three-dimensional location accuracy needed to save lives can be accomplished and can be, and should be, incorporated into the FirstNet network as soon as possible.

At the FirstNet Board meeting held in Reston on June 28, 2017, considerable time was devoted to discussing the urgent need for improved location-based services. It appears that the only way to speed up the process is to include it as a service in the Nationwide Public Safety Broadband Network being developed by FirstNet and AT&T.

Tests are underway and the needed accuracy can be demonstrated in large urban areas today. We can at least solve the location problem for metro areas well before the 2022 date, and perhaps the rest of the FirstNet coverage areas before that deadline as well. It is up to the public safety community to make it known to both FirstNet and AT&T that being able to find personnel inside buildings should be a priority and needs to be tested and proven in the field and then implemented as quickly as possible.

Andrew M. Seybold
©2017, Andrew Seybold, Inc.