If you’ve been following the latest news about the FCC and 9-1-1 location accuracy, you know that 9-1-1 public safety communications suffered one of the most disappointing rule changes to come out of the FCC in recent memory. In the lead-up to the FCC’s action, APCO was very vocal that the FCC wasn’t doing what’s best for 9-1-1. I’m writing to explain APCO’s position on what we believed happened and why opinions by others differ. If you take away nothing else, please let it be this: APCO believes the FCC could and should have done better for 9-1-1 and the citizens of the United States.

Here’s what happened. The FCC has established rules for the location information wireless carriers like AT&T, Verizon, etc. that they must provide to help ECCs identify the vertical height of 9-1-1 callers in multi-story buildings. Despite relentless advocacy from APCO and dozens of 9-1-1 directors across the country, the FCC did not require carriers to identify the floor number of the caller. Instead, carriers will only have to provide a caller’s estimated “height above ellipsoid” (HAE), which is a technical measurement of elevation. (HAE is different from height above ground level or sea level.)  In other words, carriers will only have to provide 9-1-1 with x/y/z coordinates – GPS (“x/y”) coordinates and now an “HAE” (“z-axis”) measurement. The z-axis information is supposed to be accurate within 3 meters 80% of the time (but there are several reasons that might not happen, which is a whole other story). (For more information, read APCO’s press release and recent blog.)

Imagine it is Friday evening around 6:00 pm and you get a call from someone having a heart attack or stroke in a multi-floor apartment building. APCO was trying to convince the FCC that for 9-1-1 professionals trying to save a life, having location information like “101 Main Street, 7th floor” is obviously better than something like “101 Main Street; 76 meters, +/- 3 meters HAE.” APCO made clear that technologies exist today that the carriers can use to provide a floor level, and Google even asked the FCC to allow the provision of a floor label instead of relying on raw elevation measurements alone. The FCC wasn’t convinced and went with the “height above ellipsoid” approach. To make matters worse, with the FCC’s new rules, the carriers achieved what they wanted and won’t have to try providing better location info – “dispatchable locations” (meaning the apartment number, office suite, etc.) – for 9-1-1 callers. I think you will agree that you would much rather have an actionable floor number than a height above ellipsoid when you are trying to direct responders to save a life. We all know seconds count!!

Back in 2014, APCO and NENA worked together to negotiate an agreement with the wireless carriers and FCC and we jointly succeeded. The FCC’s rules became focused on getting carriers to provide a dispatchable location and set a backup option of x/y/z coordinates.  APCO continues to support dispatchable location as the gold standard for 9-1-1, which is why in this recent FCC fight we were asking that the x/y/z option include at least the floor number of the caller (instead of just a raw elevation). But based on NENA’s formal comments to the FCC and other public statements, NENA no longer supports dispatchable location as the goal and thinks getting the floor level is impossible – even though carriers have previously promised APCO and NENA to use technologies at their disposal to do this, and a tech giant like Google was urging the FCC to permit floor levels as an option!

How did APCO and NENA end up so far apart?

NENA has explained its reversal by arguing that having an inaccurate floor number or dispatchable location would be so bad, that dispatchers would be worse off than if they only had x/y/z-based information. But it doesn’t make sense to argue against floor level or dispatchable location on the assumption that carriers will do a bad job. It’s the FCC’s job to require the carriers to provide actionable location information for 9-1-1. That is exactly what APCO has been fighting for, and at least in 2014 that is what APCO and NENA were trying to achieve. NENA’s new position is in line with what the carriers wanted. The carriers want to do the bare minimum – just passing along raw data – and leave to ECCs the job of figuring out how to make this raw data actionable and shoulder all the costs involved. In a blog, NENA says it would “envision a future in which 9-1-1 has 3D maps of every multistory building in its jurisdiction.”

How great would it be if 9-1-1 centers across the country had accurate maps of every building and software to use those maps to operationalize an x/y/z coordinate. But in reality how long will that take? How much will that cost? Even New York City’s 9-1-1 director said they don’t have the resources to create and maintain indoor maps for thousands of buildings. How’s this supposed to work nationwide if it can’t work in NYC? And more importantly, why would we let the wireless carriers off the hook and simultaneously place the burden on ECCs to figure all this out and pay for it? Other options are available to the carriers right now that wouldn’t require this kind of effort. That is why APCO pressed the FCC to require the carriers to provide a floor number.

For APCO, 9-1-1 location information must be about what’s best for locating 9-1-1 callers. The FCC’s coordinate-based approach is too problematic and unlikely to result in meaningful improvements for 9‑1-1 location accuracy. That is why 9-1-1 directors around the country filed comments with the FCC agreeing with APCO.

I believe, as does the rest of the Executive Committee, that APCO’s advocacy was on-target and that the FCC’s decision was wrong and can potentially cost lives because of unnecessary delays. We’re going to keep pressing for the best possible location information for 9-1-1. Know that APCO’s elected leaders and staff are 100% committed to doing what is in the best interests of our public safety members. You protect and save lives every day. You’re the ones we’re here to serve.