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Proposes new indoor requirements and revisions to existing E911 rules

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Released: February 21, 2014

Federal Communications Commission

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Before the

FEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

In the Matter of
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Wireless E911 Location Accuracy Requirements
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PS Docket No. 07-114
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THIRD FURTHER NOTICE OF PROPOSED RULEMAKING

Adopted: February 20, 2014

Released: February 21, 2014

By the Commission: Chairman Wheeler and Commissioners Clyburn and Rosenworcel issuing statements;
Commissioners Pai and O’Rielly approving in part, concurring in part and issuing separate statements.
Comment Date: (45 days after publication in the Federal Register)
Reply Comment Date: (75 days after publication in the Federal Register)

TABLE OF CONTENTS

Heading
Paragraph #
I. INTRODUCTION AND EXECUTIVE SUMMARY ........................................................................... 1
II. BACKGROUND.................................................................................................................................... 7
A. E911 Regulatory History ................................................................................................................. 7
B. CSRIC Indoor Location Accuracy Test Bed Report...................................................................... 12
C. Recent Comments on E911 Phase II Location Accuracy and Call Tracking Data........................ 18
III. PROPOSED INDOOR LOCATION ACCURACY REQUIREMENTS............................................. 23
A. Costs and Benefits of Indoor Location Accuracy .......................................................................... 27
B. Near-Term Indoor E911 Location Accuracy Requirements .......................................................... 38
1. Horizontal Location Information............................................................................................. 40
2. Vertical Location Information................................................................................................. 65
3. Implementation Issues............................................................................................................. 81
a. Compliance Testing for Indoor Location Accuracy Requirements .................................. 81
(i) Test Bed Methodology ............................................................................................... 86
(ii) Alternative Testing Methods ...................................................................................... 98
(iii) Test Frequency ......................................................................................................... 100
(iv) Confidentiality of Test Results................................................................................. 101
(v) Cost/Benefit Analysis............................................................................................... 102
b. Applicability of Indoor Location Accuracy Requirements............................................. 104
c. County/PSAP-Level Measurements; Enforcement Tied to PSAP Readiness................. 110
d. Liability Protection ......................................................................................................... 112
e. Waiver Process ............................................................................................................... 115
C. Long-Term Indoor E911 Location Accuracy Requirements ....................................................... 117
1. Leveraging Indoor Network Access Technologies ............................................................... 119
2. Differentiating Between Indoor and Outdoor Calls .............................................................. 124

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3. Leveraging Commercial Location-Based Services, Emerging Technologies, and other
Sources of Location Information........................................................................................... 127
IV. IMPROVING THE DELIVERY OF PHASE II LOCATION INFORMATION .............................. 141
A. Time to First Fix (TTFF) ............................................................................................................. 142
B. Confidence and Uncertainty Data................................................................................................ 150
C. Identifying the Type of Technology Used to Deliver the E911 Location Fix ............................. 159
D. Updating the E911 Phase II Requirements Based on Outdoor Measurements............................ 163
E. Monitoring E911 Phase II Call Tracking Data ............................................................................ 167
F. Monitoring and Facilitating Resolution of E911 Compliance Concerns ..................................... 171
G. Periodic Outdoor Compliance Testing and Reporting................................................................. 173
H. Roaming Issues ............................................................................................................................ 182
V. CONCLUSION .................................................................................................................................. 185
VI. PROCEDURAL MATTERS.............................................................................................................. 186
A. Ex Parte Presentations ................................................................................................................. 186
B. Comment Filing Procedures ........................................................................................................ 187
C. Accessible Formats ...................................................................................................................... 188
D. Regulatory Flexibility Analysis ................................................................................................... 189
E. Paperwork Reduction Analysis.................................................................................................... 190
VII.ORDERING CLAUSES..................................................................................................................... 191
APPENDIX A – Commonly Used Abbreviations for Organizations/Entities
APPENDIX B – Initial Regulatory Flexibility Analysis
APPENDIX C – Proposed Rules

I.

INTRODUCTION AND EXECUTIVE SUMMARY

1.
The wireless landscape has changed significantly since the Commission first adopted its
wireless Enhanced 911 (E911) location accuracy rules in 1996, and even since the last significant revision
of these rules in 2010. Consumers are increasingly replacing traditional landline telephony with wireless
phones,1 and a majority of wireless calls are now made indoors. This increase in wireless usage is
reflected in how Americans call for help when they need it: today, the majority of 911 calls come from
wireless phones. In light of these circumstances, it is increasingly important for Public Safety Answering
Points (PSAPs) to have the ability to accurately identify the location of wireless 911 callers regardless of
whether the caller is located indoors or outdoors.
2.
We believe the time has come to propose specific measures in our E911 location
accuracy rules to ensure accurate indoor location information. In this Third Further Notice of Proposed
Rulemaking (Third Further Notice)
,2 we propose to revise our regulatory framework to require delivery of

1 For purposes of this notice, we use the terms “mobile” and “wireless” interchangeably. These terms do not
encompass, for example, cordless telephones such as those using the DECT standard or PBX handsets using Wi-Fi
connectivity.
2 We limit the scope of this proceeding and the applicability of the proposed requirements set forth in this Third
Further Notice
to CMRS providers (and in limited instances, to their E911 System Service Providers, as discussed
below) subject to Section 20.18 of the Commission’s rules. See 47 C.F.R. §20.18(a) (setting forth scope of Section
20.18 of the Commission’s rules). We note, however, that we will continue to examine whether it is appropriate to
establish indoor location requirements for other categories of services – including services by VoIP and over-the-top
providers. In addition, as required by the Next Generation 9-1-1 Advancement Act of 2012, 47 U.S.C. § 1401 note,
the Public Safety and Homeland Security Bureau has sought comment on the feasibility of providing precise
location in connection with wireline 911 calls using multi-line telephone systems (MLTSs) serving office, university
campus, and other environments. Public Safety and Homeland Security Bureau Seeks Comment on Multi-line
Telephone Systems Pursuant to the Next Generation 911 Advancement Act of 2012, Public Notice, 27 FCC Rcd
5329 (PSHSB 2012).
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accurate location information to PSAPs for wireless 911 calls placed from indoors. Our proposal includes
both near- and long-term components. In the near term, we propose to establish interim indoor accuracy
metrics that will provide approximate location information sufficient to identify the building for most
indoor calls. We also propose to add a requirement for provision of 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 seek comment on how to develop more granular indoor location accuracy
requirements, consistent with the evolving capabilities of indoor location technology and increased
deployment of in-building communications infrastructure. These requirements would provide for
delivery to PSAPs of in-building location information at the room or office suite level.
3.
In particular, we seek comment on the following proposals, and potential alternatives to
these proposals, with respect to indoor location accuracy:
 CMRS providers would be required to provide horizontal location (x- and y-axis) information
within 50 meters of the caller for 67 percent of 911 calls placed from indoor environments within
two years of the effective date of adoption of rules, and for 80 percent of indoor calls within five
years.
 CMRS providers would be required to provide vertical location (z-axis) information within 3
meters of the caller for 67 percent of indoor 911 calls within three years of the adoption of rules,
and for 80 percent of calls within five years.
 As is the case of our existing E911 location rules, CMRS providers would be required to meet
these indoor requirements at either the county or PSAP geographic level.
 CMRS providers would demonstrate compliance with indoor location accuracy requirements
through participation in an independently administered test bed program modeled on the indoor
test bed administered by the Communications Security, Reliability, and Interoperability Council
(CSRIC), but providers would have the option to demonstrate compliance through alternative
means so long as they provide the same level of test result reliability.
 PSAPs would be entitled to seek Commission enforcement of these requirements within their
jurisdictions, but only so long as they have implemented location bid/re-bid policies that are
designed to obtain all 911 location information made available by CMRS providers pursuant to
our rules.
4.
In addition, we examine whether there are additional 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 seek comment on whether we should revisit the
timeframe established by the Commission in 2010 for replacing the current handset- and network-based
accuracy requirements with a unitary requirement, in light of the rapid proliferation of Assisted Global
Navigation Satellite Systems3 (A-GNSS) technology in wireless networks and the prospect of improved
location technologies that will soon support 911 communication over LTE networks.

3 Global (satellite) navigation systems describe satellite navigation systems with global coverage. Currently
operational GNSS systems include the Global Positioning System (GPS) and GLONASS, and the Galileo satellite
system is scheduled to become operational in 2014. See http://en.wikipedia.org/wiki/Satellite_navigation (last
visited Feb. 3, 2014). Assisted GNSS systems use data from the cellular network to enable faster position
determination, using one or more satellite constellations. See http://www.insidegnss.com/node/769 (last visited Feb.
18, 2014). A-GPS refers to an assisted GNSS that only relies on the GPS satellite constellation; the term is
sometimes used informally to refer to any assisted satellite navigation system. For our purposes here, we continue to
refer to A-GPS in light of common usage and practice. However, references to A-GPS are intended to include
multi-constellation GNSS systems and are not exclusive to the Global Positioning System.
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5.
Specifically, we seek comment on whether to implement the following measures:
 Adopt a 30-second requirement for the maximum time period allowed for a CMRS provider to
generate a location fix (“time to first fix”) in order for the 911 call to be counted towards
compliance with location accuracy requirements.
 When measuring compliance with location accuracy requirements, allow CMRS providers to
exclude short 911 calls (e.g., calls lasting 10 seconds or less) that may not provide sufficient time
to generate a location fix.
 Standardize the content and the process for delivery of confidence and uncertainty data that is
generated by CMRS providers for each wireless 911 call and delivered to PSAPs on request.
 Require CMRS providers to inform PSAPs of the specific location technology or technologies
used to generate location information for each 911 call.
 Accelerate the previously established timeframe for replacing the current handset- and network-
based accuracy requirements with a unitary requirement.
 Require that CMRS providers periodically report E911 Phase II call tracking information,
indicating what percentage of wireless 911 calls include Phase II location information.
 Establish a separate process by which PSAPs or state 911 administrators could raise complaints
or concerns regarding the provision of E911 service.
 Require CMRS providers to conduct periodic compliance testing.
6.
In setting forth these proposals, we emphasize that 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 an emergency. We seek comment on whether our
proposals in this notice are the best way to achieve this objective, and we encourage industry, public
safety entities, and other stakeholders to work collaboratively to develop alternative proposals for our
consideration.

II.

BACKGROUND

A.

E911 Regulatory History

7.
In 1996, the Commission first adopted rules to require CMRS providers to implement
basic 911 and E911 services.4 The Commission divided its wireless E911 service requirements into two
stages.5 The initial stage – Phase I – required CMRS providers to deliver, by April 1998, E911 service
that includes the telephone number of the wireless 911 caller and the location of the cell site or base
station that received the call.6 Phase II requires delivery, under a phased-in schedule now extending until
January 2019,7 of E911 service that includes the latitude and longitude of the 911 call within specific

4 See Revision of the Commission’s Rules to Ensure Compatibility with Enhanced 911 Emergency Calling Systems,
CC Docket No. 94-102, RM-8143, Report and Order and Further Notice of Proposed Rulemaking, 11 FCC Rcd
18676, 18683 ¶ 10 (1996) (First E911 Report and Order). The basic 911 service requirement, which is not at issue
in this proceeding, is the simple requirement of transmission of wireless 911 calls to the PSAP (or designated default
answering point or appropriate local emergency authority) without respect to their call validation process, and
without reference to location accuracy. 47 C.F.R. § 20.18(b).
5 These E911 obligations are triggered only upon request by a PSAP that is capable of receiving and utilizing the
data and has implemented a mechanism for recovering its costs. 47 C.F.R. § 20.18(j).
6 See First E911 Report and Order, 11 FCC Rcd at 18708-18710. See also 47 C.F.R. § 20.18(d).
7 For network-based technologies, the requirement reaches 85 percent of counties or PSAP service areas by January
2019; for hand-set based technologies, the 90 percent requirement for placement of location within 150 meters by
(continued….)
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accuracy and reliability parameters, depending on the location technology that the carriers have chosen:
(1) for network-based technologies, within 100 meters for 67 percent of calls, and 300 meters for 90
percent of calls; (2) for handset-based technologies, within 50 meters for 67 percent of calls, and 150
meters for 90 percent of calls.8 Under the Commission’s rules, CMRS providers must file with the
Commission reports on their plans for implementing Phase II, describing their location technology, and
any changes thereto. While these reports must also describe the provider’s intended conformance
verification procedure, they do not require the provider to file the results of its conformance verification.9
8.
The Commission’s E911 Phase II requirements do not distinguish between indoor and
outdoor 911 calls. In 2000, the Office of Engineering and Technology (OET) published Bulletin No. 71,
providing testing guidelines for wireless licensees to comply with the location accuracy requirements set
by the Commission.10 Later that same year, the Commission noted that the guidelines “express[ed] a
preference for basing testing on locations from which 911 calls actually are placed.”11 Further, the
Commission construed the OET guidelines as confirming that, for testing accuracy performance, carriers
could exclude areas “where wireless calls cannot be completed,”12 such as inside high-rise buildings and
parking garages.13 The Commission later clarified that its Phase II requirements apply to outdoor
measurements only.14
9.
As more and more wireless calls were successfully placed from within buildings, the
Commission examined new approaches and technological advances for improving location accuracy of
wireless 911 calls from difficult environments, including indoor locations.15 In 2010, in the E911
(Continued from previous page)
that same date extends on a per county or per PSAP basis, with a 15 percent exception based on heavy forestation.
See 48 C.F.R. § 20.18(h).
8 47 C.F.R. § 20.18(h)(1)(i), (ii) (applying to network-based technologies); 47 C.F.R. § 20.18(h)(2)(i), (ii) (applying
to handset-based technologies). See Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114,
Second Report and Order, 25 FCC Rcd 18909, 18947-48 (2010) (E911 Location Accuracy Second Report and
Order
). Network-based location technologies use “hardware and/or software in the CMRS network and/or another
fixed infrastructure” and do “not require the use of special location-determining hardware and/or software in the
caller's portable or mobile phone.” 47 C.F.R. § 20.3. Handset-based technologies use “special location-determining
hardware and/or software in a portable or mobile phone” and “may also employ additional location-determining
hardware and/or software in the CMRS network and/or another fixed infrastructure.” 47 C.F.R. § 20.3.
9 See 48 C.F.R. § 20.18(i).
10 OET Bulletin No. 71, Guidelines for Testing and Verifying the Accuracy of Wireless E911 Location Systems
(April 12, 2000), available at
http://transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet71/oet71.pdf (last visited Feb. 3,
2014) (OET Bulletin No. 71). Rather than establishing mandatory procedures, OET Bulletin No. 71 states that
compliance with the guidelines would establish “a strong presumption that appropriate means have been applied to
ensure that an ALI system complies with the Commission's Rules.” Id. at 2.
11 Revision of the Commission’s Rules To Ensure Compatibility with Enhanced 911 Emergency Calling Systems,
CC Docket No. 94-102, Fourth Memorandum Opinion and Order, 15 FCC Rcd 17442, 17451 ¶ 22 (2000) (Fourth
Memorandum Opinion and Order
) (citing OET Bulletin No. 71 at 4).
12 Fourth Memorandum Opinion and Order, 15 FCC Rcd at 17451 ¶ 22 (citing OET Bulletin No. 71 at 3).
13 Id. at 17451 ¶ 22.
14 See E911 Location Accuracy Second Report and Order, 25 FCC Rcd at 18920 ¶ 29, 18927-28 ¶¶ 48-49 (2010).
See also 47 C.F.R. § 20.18(h).
15 In 2007, the Commission sought comment on several issues relating to wireless E911 location accuracy,
including the capabilities and limitations of existing and new location technologies, the advantages of hybrid
solutions combining handset-based and network-based location technologies, and compliance testing methodologies
in different environments, such as indoor versus outdoor use and urban versus rural areas. Wireless E911 Location
Accuracy Requirements; Revision of the Commission’s Rules to Ensure Compatibility with Enhanced 911
(continued….)
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Location Accuracy Further Notice and NOI, the Commission sought comment on how location accuracy
could be improved in indoor settings and other more challenging environments.
10.
In 2011, the Commission found indoor location accuracy to be a significant public safety
concern because indoor incidents may not be visible to first responders, and a location accuracy of
“100/300 meters . . . would only identify the city block in which a building is located.”16 Rather than
attempting to impose an immediate solution, however, the Commission determined that “further work
[was] needed in this area” and sought further comment on whether to require indoor location accuracy
testing and whether the standards and testing methodologies for outdoor and indoor location accuracy
testing should be different.17
11.
Finally, the Commission tasked the Communications Security, Reliability, and
Interoperability Council (CSRIC) with evaluating the performance and viability of various location
technologies to support E911 services for indoor environments.18 The Commission directed CSRIC to
provide initial findings and technical recommendations and consider “the cost effectiveness of any
recommendations.”19 In addition, the Commission directed CSRIC “to explore and make
recommendations on methodologies for leveraging commercial location-based services for 911 location
determination.”20

B.

CSRIC Indoor Location Accuracy Test Bed Report

12.
In June 2012, the CSRIC III Working Group 3 (WG3) released a report concerning its
goals and recommendations for an indoor location accuracy test bed.21 WG3 indicated that the purpose of
(Continued from previous page)
Emergency Calling Systems for IP-Enabled Service Providers, PS Docket No. 07-114, CC Docket No. 94-102, WC
Docket No. 05-196, Notice of Proposed Rulemaking, 22 FCC Rcd 10609, 10613-16 ¶¶ 8-19 (2007) (E911 Location
Accuracy Notice
). In 2010, the Commission sought further comment on the following issues: the adoption of a
unitary location accuracy requirement; the methodology providers should use to verify compliance for initial and
ongoing testing; and whether the Commission’s location accuracy requirements should include a vertical elevation
(z-axis) component. See Wireless E911 Location Requirements, PS Docket No. 07-114, Further Notice of Proposed
Rulemaking and Notice of Inquiry
, 25 FCC Rcd 18957, 18963-64 ¶ 17 (2010) (E911 Location Accuracy Further
Notice and NOI
). The Commission also initiated an inquiry requesting comment on how IP-enabled wireless
devices and services, including Wi-Fi positioning capabilities, could support location accuracy determination in
indoor environments such as residences and public hotspot locations. See E911 Location Accuracy Further Notice
and NOI
, 25 FCC Rcd at 18971-73 ¶¶ 36-38.
16 See E911 Location Accuracy Second Further Notice, 26 FCC Rcd at 10103 ¶ 86.
17 See id. at 10104 ¶ 87 (also seeking comment on the indoor location accuracy testing methodologies available and
“the costs and benefits associated with each.”).
18 See id. at 10104 ¶¶ 87-88. CSRIC is a Federal Advisory Committee that was tasked with providing guidance and
expertise on the nation’s communications infrastructure and public safety communications. See CSRIC III Working
Group Descriptions and Leadership (updated Nov. 15, 2012) at 3, available at
http://transition.fcc.gov/pshs/advisory/csric3/wg-descriptions.pdf (last visited Feb. 3, 2014).
19 See id. at 10104 ¶ 88.
20 See id. at 10102 ¶ 79.
21 See CSRIC III Working Group 3, E9-1-1 Location Accuracy Final Report v2 (June 1, 2012), available at
http://transition.fcc.gov/bureaus/pshs/advisory/csric3/CSRICIII_6-6-12_WG3-Final-Report.pdf (last visited Feb. 3,
2014) (CSRIC E911 Location Accuracy Report). Prior to the June 2012 Report, CSRIC III WG3 released a report in
March 2012 that addressed outdoor accuracy. See CSRIC III Working Group 3, E9-1-1 Location Accuracy Final
Report – Outdoor Location Accuracy
(Mar. 14, 2012), at 9 (focusing “exclusively on outdoor accuracy testing”),
available at http://transition.fcc.gov/bureaus/pshs/advisory/csric3/CSRIC-III-WG3-Final-Report.pdf (last visited
Feb. 3, 2014) (CSRIC Outdoor Location Accuracy Report). In that report, Working Group 3 (WG3) also made
recommendations on outdoor compliance testing and maintenance testing based on the approaches in technical
reports and the best practices recently developed by an industry standards body group. WG3 found those
(continued….)
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such a test bed would be to provide insight into which technologies are technically feasible and
economically reasonable for providing indoor location for wireless emergency calls. WG3 conducted the
indoor location test bed during the winter of 2012-2013.22 The test bed examined whether indoor location
technologies could achieve the location result needed for improved public safety response – “actionable
location” with dispatchable address within a tight search ring – for the representative environments
(morphologies) where wireless devices are expected to be used, i.e., urban, dense urban, suburban, and
rural.23
13.
WG3 selected the San Francisco Bay Area because it included a variety of different
environments within a fairly limited geographic area. The area chosen included several building types
(steel, glass, concrete, and masonry) and different building heights that were representative of urban and
dense urban environments.24 The close proximity of the different environments selected allowed for
testing by just one test team.25 In addition, WG3 observed that multiple carriers use San Francisco “to
assess location technologies.”26
14.
WG3 tested the indoor location capability of three technologies: (1) AGPS/AFLT by
Qualcomm, (2) RF fingerprinting by Polaris, and (3) network beacon technology by NextNav.27 The first
two technologies are currently commercially available. The third technology is an in-building beacon
technology that is independent of the CMRS provider’s wireless network and uses calibrated, atmospheric
pressure sensors in handsets to provide vertical location information.28
(Continued from previous page)
approaches and best practices more current and relevant to indoor location testing than the guidelines in the OET
Bulletin No. 71. See id. at 3-5. We seek comment on these recommendations below, in Section IV.E.
22 See CSRIC III WG3, Indoor Test Report to CSRIC III WG3 Bay Area Stage-1 Test Bed (Jan. 31, 2013), available
at
http://transition.fcc.gov/bureaus/pshs/advisory/csric3/WG3_Indoor_Test_Report_Bay_Area_Stage_1_Test_Bed_Jan
_31%20_2013.pdf (last visited Feb. 3, 2014) (CSRIC Indoor Location Test Bed Interim Report). WG3 selected
TechnoCom, a location technology vendor, as the “independent test house” for the indoor testing. See id. at 2.
23 See CSRIC III WG3, Indoor Location Test Bed Report (Mar. 14, 2013), at 8-9, available at
http://transition.fcc.gov/bureaus/pshs/advisory/csric3/CSRIC_III_WG3_Report_March_%202013_ILTestBedReport
.pdf (last visited Jan. 14, 2014) (CSRIC Indoor Location Test Bed Report) (defining “actionable location” as
including the “essential” elements of location accuracy and “the ability to provide high reliability and consistency of
[location] data” so that “telecommunicators and first responders have confidence in the underlying information”).
WG3 selected the above four environment on the basis of industry standard, ATIS-0500011, defining the wireless
use environments as Dense Urban, Urban, Suburban, and Rural. See id. at 11.
24 CSRIC Indoor Location Test Bed Report at 12-13.
25 Id. at 11.
26 CSRIC E911 Location Accuracy Report at 14.
27 CSRIC Indoor Location Test Bed Report at 54. Qualcomm, Polaris, and NextNav are location technology
vendors. AGPS/AFLT combines GPS location technology with terrestrial wireless network technology, creating a
significant range of hybrid solutions. Id. at 25. “RF fingerprinting,” also referred to as RF pattern matching, uses
radio frequency pattern matching to compare mobile measurements against a geo-referenced database of the mobile
operator’s radio environment. Id. at 24-25. Four vendors of other location technologies showed initial interest in
the test bed effort but did not participate. These technologies included U-TDOA positioning, DAS proximity-based
positioning, AGNSS/Wi-Fi/MEMS sensor hybrid, and LEO Iridium satellite-based positioning. See CSRIC Indoor
Location Test Bed Report
at 55. We discuss these technologies in greater detail below. See infra Section III.
28 See CSRIC Indoor Location Test Bed Report at 8, 24, 45. NextNav’s beacon technology operates in spectrum
licensed to Progeny LMS, LLC in the Multilateration Location and Monitoring Service (M-LMS) at 902-928 MHz.
See Request by Progeny LMS, LLC for Waiver of Certain Multilateration Location and Monitoring Service Rules,
Progeny LMS, LCC Demonstration of Compliance with Section 90.353(d) of the Commission’s Rules, WT Docket
No. 11-49, Order, 28 FCC Rcd 8555, 8569 ¶ 32 (rel. June 6, 2013) (NextNav Order).
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15.
In March 2013, WG3 issued a report discussing the results of the test bed and making
recommendations about how best to move forward on indoor location accuracy. In general, WG3 found
that for the four representative environments analyzed, the test bed results “show significant promise with
respect to high yield, relatively high confidence factors and reliability,” and “the ability to achieve
improved search rings in the horizontal dimension (often identifying the target building, or those
immediately adjacent).”29 WG3 concluded that “additional development is required to ensure” the
provision of an “actionable location,” especially in urban and dense urban environments.30 Moreover, the
test bed found “substantial progress” in the beacon technology’s capability to provide vertical (z-axis)
location information, providing approximate floor-level accuracy in a significant percentage of calls.31
16.
To be sure, accuracy results varied by technology and the particular environment. As
summarized in Table 1 below, depending on the representative environment and building structure tested,
each technology demonstrated particular capabilities, advantages, and disadvantages.32 The CSRIC
Indoor Location Test Bed Report
observed that all three vendors participating in the test bed were in the
process of making improvements to their location technologies.33

29 See, e.g., CSRIC Indoor Location Test Bed Report at 9. See also id. at 27-36 (summarizing the location accuracy
results for the three technologies tested in each of the representative indoor environments).
30 See CSRIC Indoor Location Test Bed Report at 8.
31 The beacon technology provided, across all indoor environments, vertical location accuracy for the median, 67th
and 90th percentiles at 2 m, 2.9 m and 4.8 m, respectively (compared to an average floor separation of 3 meters). See
id.
at 9, 39.
32 See CSRIC Indoor Location Test Bed Report at 27-36 (summarizing the location accuracy results for the three
technologies tested in each of the representative indoor environments). For example, in a “dense urban
environment,” horizontal accuracy ranged between 57 meters/102 meters for NextNav, 156 meters/268 meters for
Qualcomm, and 117 meters/400 meters for Polaris, for 67 and 90 percent of calls, respectively. In a “rural
environment,” the range was between 28 meters/45 meters for NextNav, 48 meters/210 meters for Qualcomm, and
576 meters/3005.1 meters for Polaris. Results for the rural morphology are generally dependent on the density of
cell site locations and location fixes are spread along relatively long stretches of rural roads. Id. at 34.
33 See id.. at 39-41 (noting that NextNav is working on “its next generation system;” that Polaris acknowledges that
providing location information for the upper floors of a building presented a particular challenge, but it is improving
its technology to address this challenge; and that Qualcomm is working on improvements to its hybrid GPS-AFLT
technology using OTDOA for 4G LTE networks). OTDOA, or the Observed Time Difference of Arrival, is a
location method “based on Reference Signal Time Difference (‘RSTD’) measurements conducted on downlink
positioning reference signals received by the UE [User Equipment].” See CSRIC III WG3, Leveraging LBS and
Emerging Location Technologies for Indoor Wireless E9-1-1 (Mar. 14, 2013), at 35, available at
http://transition.fcc.gov/bureaus/pshs/advisory/csric3/CSRIC_III_WG3_Report_March_%202013_LeveragingLBS.
pdf (last visited Feb. 20, 2014) (CSRIC LBS Report). User Equipment includes “mobile devices such as feature
phones, smartphones, and even tablets having a CMRS modem embedded.” Id. at 8.
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Table 1.

CSRIC San Francisco Test Bed - Location Accuracy Results by Technology (in meters)

Technology

Morphology

NextNav

Polaris

Qualcomm

Percent of Calls
67%
90%
67%
90%
67%
90%
Dense Urban
57
102
117
400
156
268
Urban
63
141
198
448
227
449
Suburban
29
53
232
421
75
205
Rural
28
45
576
3005.1
48
210
17.
Following the WG3 test bed in San Francisco, TruePosition, which did not participate in
the test bed, commissioned TechnoCom to test TruePosition’s indoor location solution, which is based on
hybrid technology consisting of UTDOA and assisted Global Positioning System (A-GPS).34 In February
and early March 2013, TechnoCom conducted the testing, utilizing similar testing standards and
methodology as used in the CSRIC test bed.35 TechnoCom reports that, overall, “[t]he Hybrid [UTDOA
and AGPS] system performed well indoors.”36 In the urban setting, 67 percent of calls were located
within 87.3 meters and 90 percent of calls were located within 140.7 meters.37 For the suburban
environment, 67 percent of test calls were located within 66.1 meters and 90 percent of test calls were
located within 116.2 meters.38

C.

Recent Comments on E911 Phase II Location Accuracy and Call Tracking Data

18.
In August 2013, the California chapter of the National Emergency Number Association
(CALNENA) filed an ex parte with the Commission raising concerns about what it noted to be a
“significant decrease in the percentage of wireless 9-1-1 calls that delivered Phase II location
information” to its PSAPs.39 According to CALNENA, California State 911 Office data indicated that
more than 55% of the over 1.5 million wireless 911 calls throughout the state in the month of March 2013
did not include Phase II location information. CALNENA noted that this phenomenon was much worse

34 UTDOA is a network-based multilateral system that “determines location based on the time it takes a signal to travel
from a mobile phone to a number of sensitive, well calibrated receivers called Location Measurement Units (LMUs).
See Letter from Masoud Motamedi, President, TechnoCom Corporation, to Marlene H. Dortch, Secretary, FCC, PS
Docket No. 07-114, Attachment at 7 (filed Apr. 22, 2013) (TruePosition Wilmington Test Bed Results) (detailing
TruePosition’s use of UTDOA and its test results for Wilmington, Delaware). See also TruePosition, “About
TruePosition UTDOA,” available at http://www.trueposition.com/resource-center/fact-sheets/trueposition-u-tdoa-
overview-fact-sheet/DownloadSecured.pdf (last visited Feb. 3, 2014). We describe A-GPS above. See supra note 3.
35 TruePosition Wilmington Test Bed Results at 2.
36 Id. at 1.
37 Id.at 28.
38 Id.at 29.
39 Letter from Danita L. Crombach, ENP, CALNENA, to the Honorable Mignon Clyburn, Chairwoman, Federal
Communications Commission, PS Docket No. 07-114 (filed Aug. 12, 2013), at 1 (CALNENA Ex Parte Letter). See
also
Letter, Karen Wong, Assistant Director, Public Safety Communications, CalOES, to Marlene H. Dortch,
Secretary, FCC, PS Docket No. 07-114 (filed Sept. 26, 2013), at 2 (CalOES Workshop Comments) (In “a
comparison of Phase I and Phase II location information for wireless 9-1-1 calls from 2007 through June 2013,
California has seen a 15.6% decrease in Phase II location information within the call detail records.”).
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in urban areas, “possibly suggesting that whatever 9-1-1 technologies the wireless carriers may be using
lately are not working for wireless calls placed in or near high rise buildings.”40
19.
The Commission subsequently received E911 Phase II call tracking data sets from several
other state and local public safety entities that either oversee or administer E911 service, which in some
cases also indicated a decrease in the percentage of calls to PSAPs that included Phase II location.41 In
September 2013, the Commission’s Public Safety and Homeland Security Bureau (Bureau) announced
that it would host a public workshop to discuss the issues raised by CALNENA and other E911 Phase II
call tracking data sets, as well as recent developments in wireless location technology.42 The Bureau also
invited interested parties to file comments on the E911 call tracking data and related topics for discussion,
including current trends that may be affecting the provision and quality of E911 location information
delivered to PSAPs.43
20.
Twenty-two parties filed comments, including four CMRS providers,44 nine public safety
organizations and entities, and eight vendors of location technologies, Next Generation system
components, or PSAP consumer premises equipment. On November 18, 2013, the Bureau hosted the
E911 Phase II Location Accuracy Workshop.45
21.
Providers uniformly attribute the declining rates of delivery of Phase II data observed by
some PSAPs primarily to PSAPs’ not “rebidding,” i.e., affirmatively seeking to “pull” the data from its
source location, to obtain the Phase II data that the carriers are, in fact, providing.46 Carriers indicate that
while Phase II data is not always available to the PSAP on call set-up, it is subsequently delivered to the
Mobile Positioning Center (MPC) (for GSM networks) or the Gateway Mobile Location Center (GMLC)
(for CDMA networks) and is available for PSAPs through the “rebidding” process.47 Other commenters

40 CALNENA Ex Parte Letter at 2.
41 The entities are the California Governor’s Office of Emergency Services (all PSAPs, plus charts on 24 urban and
rural PSAPs); North Carolina (statewide aggregate Phase II data); Oregon (statewide aggregate Phase II data);
Pennsylvania (Delaware County); Texas (statewide aggregate Phase II data, Bexar Metro 911 District, Greater
Harris County 911 Emergency Network, Capital Area Emergency Communications District, El Paso); Utah; and
Washington (King County E-911 Program Office). All data sets are available at
http://www.fcc.gov/encyclopedia/phase-2-data-sets (last visited Feb. 3, 2014).
42 See Public Safety and Homeland Security Bureau Announces Workshop of E911 Phase II Location Accuracy,
Public Notice, PS Docket No. 07-114, DA 13-1873 (PSHSB Sept. 9, 2013) (E911 Location Accuracy Workshop
Notice
).
43 See E911 Location Accuracy Workshop Notice at 1-3.
44 CTIA also filed comments.
45 Participants included public safety entities, as well as carrier industry and location technology vendor
representatives. A webcast of the E911 Location Accuracy Workshop is available at
http://www.fcc.gov/events/workshop-e911-phase-ii-location-accuracy (last visited Feb. 3, 2014). See also Public
Safety and Homeland Security Bureau Announces Availability of Webcast and Additional Materials from
November 18, 2013 Workshop on E911 Phase II Location Accuracy, Public Notice, PS Docket No. 07-114, DA 13-
2226 (rel. Nov. 20, 2013).
46 See, e.g., Sprint Nextel Comments, PS Docket No. 07-114 (filed Sept. 25, 2013), at 2-5 (Sprint Workshop
Comments); T-Mobile USA, Inc. Comments, PS Docket No. 07-114 (filed Sept. 25, 2013), at 5, 19-20, 24 (T-
Mobile Workshop Comments).
47 In this item we refer to a network’s MPC or GMLC as a “location information center.”
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contend, however, that even if PSAPs were to rebid more frequently, a 30-second delay in obtaining Phase
II information is highly undesirable, given that a large percentage of 911 calls are under 30 seconds.48
22.
There was general agreement among public safety commenters that the majority of calls
to 911 are now coming from wireless phones, that this trend is increasing, and that a large number of
these calls are made from indoor environments.49 Vendors argue that indoor location technology has
since evolved considerably, suggesting the provision of indoor location information may be within
reach.50 TruePosition suggests that a combination of handset- and network-based location technology can
provide Phase II location information for both indoor and outdoor calls.51

III.

PROPOSED INDOOR LOCATION ACCURACY REQUIREMENTS

23.
The record in this proceeding demonstrates that circumstances affecting wireless location
accuracy have changed dramatically since the Commission adopted its original Phase II location accuracy
rules. As discussed below, the great majority of calls to 911 now originate on wireless phones, and the
majority of wireless calls now originate indoors. These changes elevate the importance of ensuring that indoor
911 calls can be accurately located.
24.
While PSAPs and CMRS providers may be able to address some of the challenges through
technological and operational improvements, the record also indicates that the outdoor-oriented focus of the
Commission’s Phase II rules to date has created a regulatory “gap”: by focusing on outdoor measurements for
verifying compliance, our rules provide no remedy to address poor performance of location technologies indoors.
25.
In addition to changes in wireless usage, there has also been recent progress in the
development of technologies that could support improved indoor location accuracy. The CSRIC test bed
results, together with parties’ representations that they have since been working on improvements to indoor
location technologies, suggest that it is likely that location technologies can begin to be deployed in the near
term that would deliver 50-meter location accuracy for many indoor environments with a high degree of
reliability. The record also contains data suggesting the feasibility of using barometric pressure sensors in
mobile devices to provide rough z-axis information when calls are placed from multi-story buildings. Finally,

48 TruePosition Reply Comments, PS Docket No. 07-114 (filed Nov. 13, 2013), at 6-7 (TruePosition Workshop
Reply Comments); CalOES Comments, PS Docket No. 07-114 (filed Sept. 25, 2013), at 2 (CalOES Workshop
Comments).
49 See, e.g., CalOES Workshop Comments at 1 (43.8 percent increase in wireless 911 calls since 2007; in June 2013,
comprised 72.7 percent of 911 volume); International Association of Chiefs of Police (IACP) Comments, PS Docket
No. 07-114 (filed Sept. 24, 2013), at 1 (IACP Workshop Comments) (more than 70 percent of 911 calls from mobile
phones, many from indoors); King County Comments, PS Docket No. 07-114 (filed Sept. 25, 2013), at 1-2 (King
County Workshop Comments) (steady increase in percentage of 911 calls from wireless indicating increasing
number from indoors); NENA Comments, PS Docket No. 07-114 (filed Sept. 25, 2013), at 1, 2-3 (NENA Workshop
Comments) (70 percent or more of 911 calls now from wireless, increasing indoor environment challenge); Oakland
Comments, PS Docket No. 07-114 (filed Sept. 25, 2013), at 1 (Oakland Workshop Comments) (in 2012, 77 percent
of 911 calls from wireless); Letter from William Jenaway, President, CFSI, to Marlene H. Dortch, Secretary, FCC,
PS Docket No. 07-114 (Nov. 13, 2013), at 1 (increasing number of 911 calls from wireless; many are placed from
indoors).
50 NextNav, for example, indicates that the “capabilities of current and near-future wireless location technologies
can provide sufficient horizontal accuracy, vertical accuracy, and yield to warrant the adoption of concrete indoor
location standards.” NextNav Comments, PS Docket 07-114 (filed Sept. 25, 2013), at ii (NextNav Workshop
Comments). See also Polaris Wireless Comments, PS Docket 07-114 (filed Sept. 25, 2013), at 3 (Polaris Workshop
Comments) (“changes occurring within the wireless industry … are projected to improve both horizontal as well as
vertical location… performance” (emphasis omitted)).
51 TruePosition Comments, PS Docket No. 07-114 (filed Sept. 25, 2013), at 5 (TruePosition Workshop Comments)
(“combination of handset … and network based location technology … provides prompt and Phase II accurate
location information both indoors and outdoors”).
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providers assert that the deployment of LTE networks will be accompanied by improvements in location
technology that could drive improved performance for both indoor and outdoor calls,52 but they also express
concern about whether they can realistically meet the proposed requirements based on currently available
technology.53
26.
We believe that it is now appropriate to propose 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 call indoors or outdoors. In the following discussion, we propose a regulatory
framework for addressing indoor location accuracy for wireless calls to 911 from indoors that includes a near-
term requirement to achieve approximate indoor location information, comprised of horizontal (x- and y-axis)
and vertical (z-axis) location information. We also seek comment on how to formulate a long-term
requirement with an increased degree of location accuracy, sufficient to identify the caller’s specific address,
floor level, and suite/room number within a building. We discuss below the achievability of these technical
requirements on our proposed time frames, the potential benefits and costs of our proposed indoor location
accuracy requirements, a proposed compliance testing framework, and possible exclusions from the proposed
requirements to ensure they are imposed in a way that maximizes the rules’ effectiveness while mitigating the
potential burdens on CMRS providers. We also seek comment on alternative approaches and, in this regard,
invite relevant stakeholders – including public safety and industry – to propose a consensus approach that
would help ensure that consumers placing wireless calls to 911 from indoor environments receive the same
protections as callers in outdoor environments.

A.

Costs and Benefits of Indoor Location Accuracy

27.
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 we acknowledge the
potential difficulty of quantifying benefits and burdens, we seek to measure how the availability of indoor
location information will benefit the public through reduced emergency response times. We also seek to
maximize these benefits, while taking into consideration the burden of compliance to carriers. These costs and
benefits can have many dimensions and affect many parties, including, for example, more efficient use of
public safety resources; cost and revenue implications for the communications industry; health and financial
benefits to the public; as well as other less tangible benefits, such as the value of any reduced or avoided pain
and suffering, or the apprehension of criminal suspects. Providing accurate E911 information is particularly
important in instances where a caller cannot provide information directly – either because they do not know or

52 See, e.g., T-Mobile Workshop Comments at 19, 34 (describing how “the transition to LTE promises the
opportunity to select from multiple location methods, to maximize accuracy and yield, within the same overall
latency budget,” and that “the best opportunity for implementing improved location technology is as carriers and
consumers implement Voice Over LTE.”); Verizon and Verizon Wireless Comments, PS Docket No. 07-114 (filed
Sept. 25, 2013), at 6 (Verizon Workshop Comments) (discussing Verizon’s efforts to improve E911 service for a
forthcoming Voice over LTE offering, including supplementing GPS information with GLONASS and improved
OTDOA performance as LTE small cells are deployed); see also Letter from Michele C. Farquhar, Counsel to
Polaris Wireless, Inc., to Marlene H. Dortch, Secretary, FCC, PS Docket No. 07-114 (filed Aug. 14, 2013), at 1
(“[T]he ongoing deployment of LTE technology with O-TDOA … measurements combined with the increased
availability of Inter-RAT measurements will deliver positive impacts on future network-based indoor location
systems.”) (Polaris Aug. 14, 2013 Ex Parte Letter).
53 See, e.g., Letter from Brian Josef, CTIA-The Wireless Association, to Marlene Dortch, Secretary, FCC, PS
Docket 07-114 (filed Feb. 14, 2014), at 2 (“It is hoped that such [indoor location] technologies would be tested and
validated in future test bed campaigns.”); Letter from Joseph P. Marx, Assistant Vice President, AT&T Services,
Inc., to Marlene Dortch, Secretary, FCC, PS Docket 07-114 (filed Feb. 13, 2014), at 1 (“[T]he time [is] right to
begin discussing Indoor Location Accuracy for E911” but the “FCC should be careful to ensure that any proposed
rules on location accuracy are aligned with proven capabilities of the current state of technology and they should set
realistic accuracy benchmarks that the industry and public safety can embrace.”).
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cannot communicate their location.54 We therefore request comment on a wide range of questions that will
enable us to weigh the costs and benefits associated with the rules we propose in this Third Further Notice.
28.
First, in order to assess the potential scope of benefits from our proposed rules, we think it is
relevant to assess the scope of current wireless usage, both indoors and outdoors. Overall wireless usage has
increased substantially since the Commission adopted its E911 location accuracy rules in 1996. At that time,
there were approximately 33 million cellular subscribers in the United States.55 By the end of 2012, there were
more than 326 million wireless subscriber connections.56 At the end of 2007, only 15.8 percent of American
households were wireless only.57 During the first half of 2013, that number had increased to 39.4 percent
(nearly two in every five American homes).58 Furthermore, certain subsets of American consumers are more
likely to use wireless phones – for example, adults living in poverty (54.7 percent) were more likely to be
living in households with only wireless phones than adults living near poverty (47.5 percent) and higher
income adults (35.3 percent).59 In addition, younger Americans are more likely to live in households with only
wireless phones.60 Supporting this trend, several major CMRS providers now market wireless service as a
replacement in the home for traditional landline service, using the same location determination technology for
911 as for mobile devices.61

54 As we discuss in the benefits discussion above, location accuracy can be especially important where voice is not
an option, e.g., for people with disabilities, for those experiencing stroke, or others in extreme danger. See supra
Section III.A. See also TDI Comments, PS Docket No. 07-114 (filed Sept. 25, 2013), at 1 (“Ensuring reliable access
to emergency services is an extremely important concern for Consumer Groups and TAP, and improved location
identification technology has the ability to dramatically increase the effectiveness of 9-1-1 for Americans who are
deaf or hard of hearing as well as for others who make emergency calls over voice and text.”).
55 First E911 Report and Order, 11 FCC Rcd at 18680 ¶ 6.
56 See CTIA, Wireless Quick Facts, available at http://www.ctia.org/advocacy/research/index.cfm/aid/10323 (last
visited Jan. 28, 2014) (CTIA Wireless Quick Facts). The Commission’s sixteenth annual report on the state of
competition in the mobile services marketplace, released in March 2013, estimated that the “total number of mobile
wireless connections now exceeds the total U.S. population.” See Implementation of Section 6002(b) of the
Omnibus Budget Reconciliation Act of 1993; Annual Report and Analysis of Competitive Market Conditions With
Respect to Mobile Wireless, Including Commercial Mobile Services, WT Docket No. 11-186, Sixteenth Report, 28
FCC Rcd 3700, 3854 ¶ 244 (2013). The Commission based this estimate on year-end 2010 and year-end 2011
Numbering Resource Utilization Forecast (NRUF) filings, adjusted for porting, and CTIA’s Year-End 2011
Wireless Indices Report. Id. at 3854-55 ¶ 244. “Mobile Wireless Connections” refers to the number of connected
devices rather than the number of individual subscribers. Id. at 3708 ¶ 2.
57 See CTIA Wireless Quick Facts.
58 See Blumberg, Stephen & Luke, Julian, Center for Disease Control National Center for Health Statistics,
“Wireless Substitution: Early Release of Estimates from the National Health Interview Survey, January- June 2013,”
at 2, available at http://www.cdc.gov/nchs/data/nhis/earlyrelease/wireless201312.pdf (last visited Feb. 14, 2014)
(CDC Wireless Substitution Survey).
59 See CDC Wireless Substitution Survey at 3.
60 For example, by the end of 2012 nearly two-thirds of adults aged 25-29 (65.6 percent) lived in wireless-only
households. See id. at 2. For adults aged 18–24 the rate was 54.3 percent and for adults aged 30–34, the rate was
59.9 percent. Id.
61 See, e.g., Verizon Wireless, Verizon Wireless Home Phone Connect (“Home Phone Connect offers… a reliable,
portable, low-cost alternative to traditional home phone service using the Verizon Wireless Network all while
keeping your same number and home phone.”), available at http://www.verizonwireless.com/b2c/device/home-
phone-connect (last visited Feb. 18, 2014); AT&T, AT&T Wireless Home Phone (“Now you can connect the home
telephone you already have to the AT&T wireless network.”), available at
http://www.att.com/shop/wireless/devices/att/wireless-home-phone-silver.html#fbid=BT-M86RbotW (last visited
Feb. 18, 2014); Sprint Nextel, Sprint Phone Connect, (“Replace your current landline or digital phone service with
unlimited Sprint phone service at your home or office.”) available at
(continued….)
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29.
Significantly, the majority of 911 calls also now come from wireless phones. In January
2011, Consumer Reports reported that 60 percent of 911 calls were placed through wireless phones.62
More recently, the California Office of Emergency Services indicates that the percentage of 911 calls that
came from wireless devices increased from 55.8 percent in 2007 to 72.7 percent as of June 2013.63
Furthermore, an increasing percentage of wireless calls are placed from indoors. A 2011 study showed
that an average of 56 percent of wireless calls were made from indoors, up from 40 percent in 2003.64
That number is even higher for smartphone users, who represent the majority of wireless phone owners,
as 80 percent of smartphone usage occurs inside buildings.65
30.
The large increase in indoor wireless usage over the last decade has made indoor location
accuracy increasingly important. Accordingly, we seek 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 seek data on the types of indoor environments 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. Is it possible to identify the type of building morphology where current
location technologies routinely fail to provide accurate location information?
31.
We know that indoor locations pose particular challenges for first responders in finding
the caller. Indoor incidents are often not visible to the first responder, and a city block in an urban
environment could potentially contain thousands of apartments.66 We seek 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. Has there been a market failure in the
provision of E911 information for wireless calls originating indoors? We seek comment on this issue.
32.
We believe that requiring location information for wireless calls to 911 from indoors will
result in significant public interest benefits, most importantly in “promoting safety of life and property.”67
(Continued from previous page)
http://shop.sprint.com/mysprint/shop/plan_details.jsp?tabId=plnTab4410001&planCatId=pln590002cat&planFamily
Type=&flow=AAL (last visited Feb. 18, 2014).
62 See Consumer Reports Magazine, For 911, is a Cell Phone as Safe as a Landline?” (Jan. 2011), available at
http://www.consumerreports.org/cro/magazine-archive/2011/january/electronics/best-cell-phones/911-from-cell-
phone/index.htm (last visited Jan. 28, 2014).
63 See CalOES Workshop Comments at 1. See also King County Workshop Comments at 1 (“Statewide, the PSAPs
are … seeing 70% of 911 calls made from wireless phones.”); NENA Workshop Comments at 1 (“70% or more of
all 9-1-1 calls now originating from wireless subscribers in many jurisdictions.”); Oakland Workshop Comments at
1 (“In 2012 ... 77% of … calls [to Oakland County PSAPs] were wireless”).
64 See J.D. Power and Associates, 2011 U.S. Wireless Call Quality Performance Study, available at
http://www.jdpower.com/content/press-release/Kp2D0Ys/wireless-call-quality-performance-study.htm (last visited
Feb. 3, 2014) (J.D. Power 2011 Study). According to a recent letter from the San Francisco Department of
Emergency Management, 70 percent of all wireless 911 calls originate indoors. See Letter from Lisa Hoffman,
Deputy Director, Division of Emergency Communications, San Francisco Department of Emergency Management,
to Julius Genachowski, Chairman, FCC, WT Docket No. 11-49 (Mar. 25, 2013) (SFDEM Mar. 25 Letter). See also
King County Workshop Comments at 2 (stating that “wireline phone service has continually declined and now
makes up only 22% of phone service in King County,” and that “this trend would indicate that wireless phones are
now making the 911 calls from homes that used to be made on the home wireline phone”); IAFC Comments, PS
Docket No. 07-114 (filed Sept. 25, 2013), at 1 (stating that the “majority of emergency calls placed to Emergency
911 are made from indoors”) (IAFC Workshop Comments).
65 See Carle, Christian, “Indoor Location: The Mobile Revolution Starts Now,” DIRECTIONS MAGAZINE, June 24,
2013, available at http://www.directionsmag.com/articles/indoor-location-the-mobile-revolution-starts-now/334122
(last visited Feb. 3, 2014) (Indoor Location Mobile Revolution Article).
66 See E911 Location Accuracy Second Further Notice, 26 FCC Rcd 10074, 10103 ¶ 86.
67 47 U.S.C. § 151.
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As APCO notes, in “the absence of accurate location data associated with a wireless call, the caller must
be questioned in detail to provide verbal information regarding their location. This process can be time
consuming and callers are sometimes unable to speak or provide correct information.”68 A number of
public safety commenters state that virtually any improvements in indoor location capabilities would be
desirable, even if relatively modest or incremental.69
33.
We seek comment on the extent to which such improvements would result in tangible
benefits with respect to safety of life and property. A study examining 73,706 emergency incidents
during 2001 in the Salt Lake City area found that on average, a one-minute decrease in ambulance
response times reduced the likelihood of 90-day mortality from 6 percent to 5 percent, i.e., a 17 percent
reduction in the total number of deaths.70 This implies that, in the Salt Lake City area, a one-minute
reduction in response times would have resulted in an annual saving of 746 lives. If we assume that this
outcome is reasonably reflective of the country as a whole, we estimate that the location accuracy
improvements we propose could save approximately 10,120 lives annually,71 for an annual benefit of

68 See APCO Comments, PS Docket No. 07-114 (filed Sept. 25, 2013), at 3 (APCO Workshop Comments). See also
IACP Workshop Comments at 1 (“The limitations of [indoor wireless] location information are already having a
negative impact on our public safety response”); IAFC Workshop Comments at 1 (deployment of advanced location
technologies is critical to … public safety response capabilities, and to the personal safety of all first responders”).
69 See, e.g., Letter from Terry Hall, President, APCO International, to Marlene H. Dortch, Secretary, FCC, WT
Docket No. 11-49, at 2 (filed May 6, 2013) (“APCO has consistently supported regulatory and technical initiatives
targeted at achieving even incremental steps toward ensuring accurate, actionable location information is available
for every 911 call.”); Letter from Adam D. Kennard, Executive Director, National Sheriffs’ Association, to Julius
Genachowski, Chairman, FCC, WT Docket No. 11-49 (filed Apr. 3, 2013), at 1 (“Even a modest improvement in
capabilities above the current 100-300 meter standards would represent a significant benefit to public safety.”);
Letter from Telford E. Forgety, III, Director of Government Affairs & Regulatory Counsel, NENA: The 9-1-1
Association, to Julius Knapp, Chief Engineer, Office of Technology, FCC, WT Docket No. 11-49 (filed Mar. 22,
2013), at 2 (“Any significant improvement over the current regime of impossibly-large out-door search rings and
indeterminate indoor search rings must be encouraged, whether or not it can reach our ultimate ideal right away.”).
70 See Wilde, Elizabeth Ty, “Do Emergency Medical System Response Times Matter for Health Outcomes?,” 22
Health Econ. 7, pp. 790-806 (2013), available at http://www.ncbi.nlm.nih.gov/pubmed/22700368 (last visited Feb.
6, 2014) (Salt Lake City Study). The study finds that the one-minute increase in response time caused annual
mortality to increase 17 percent, i.e., an increase of 746 deaths, from a mean of 4,386 deaths to 5,132
deaths. Because the regression is linear, this result implies that a one-minute reduction in response time also saves
746 lives, i.e., a 17 percent reduction from a mean of 4,386 deaths to 3,640 deaths. The study also finds that a one-
minute increase in response times increases mortality by 8 percent when measured one day after the initial
incident. See id. at 791.
71 For the approximately 25 million individuals call for an ambulance each year (i.e., 746 lives saved divided by
73,706 observed incidents multiplied by the 25 million callers seeking an ambulance = 253,032). See Key, Craig,
Paul Pepe, David Persse, and Darrell Calderon, “Can First Responders Be Sent to Selected 911 Emergency Medical
Service Calls without an Ambulance?” 10 Academic Emergency Medicine 4 (Apr. 2003), pp. 339-346, available at
http://onlinelibrary.wiley.com/doi/10.1111/j.1553-2712.2003.tb01346.x/pdf (last visited Feb. 18, 2014). This
assumes 80 percent of these calls are from mobile phones, and that only 5 percent of those wireless calls experience
a one-minute reduction in response time due to the location accuracy improvements we propose (i.e., 0.8 x 0.05 x
253,000 deaths = 10,120 expected lives saved). As discussed earlier, the proportion of 911 calls made from mobile
phones was estimated to be 73 percent a year ago and has been rising every year. See CalOES Location Accuracy
Workshop Presentation (Nov. 18, 2013) at 5, available at
http://transition.fcc.gov/bureaus/pshs/911/Phase%202/Workshop_11_2013/California_911_Wong_Nov2013.pdf
(last visited Jan. 29, 2014) (for the period from January through September 2013, 73.1 percent of all calls to 911
were from wireless phones); see also Knutson, Ryan, “Cellphones Leave Gaps for Emergency Services,” WALL
STREET JOURNAL, Dec. 1, 2013, available at
http://online.wsj.com/news/articles/SB10001424052702304579404579231913503559556 (last visited Jan. 29,
2014) (stating that, “[i]n California alone, 75% of 911 calls placed in the state during a recent 18-month period were
(continued….)
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approximately $92 billion.72 The Commission has also previously relied on 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 an over 34 percent
reduction in mortality rates from cardiac arrest within the first 48 hours following the incident.73 Based on
this study, we estimate 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.74 Furthermore,
as location information quality improves and latency declines, we expect it will result in an even greater
improvement in patient medical outcomes. We seek comment on the reasonableness of our analyses of
these studies and our underlying assumptions. We also seek comment 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.
34.
We also believe that improving location accuracy for wireless calls to 911, including
from indoor environments, is particularly important for persons with disabilities and for those who may
not be able to provide their address or otherwise describe their location. In recent testimony before the
Senate Commerce Committee, Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI) noted
the importance of automatic and immediate provision of accurate location information, stating that
“[p]eople with visual, speech, cognitive, or mobility disabilities will not have to worry about consuming
additional minutes trying to identify their location.”75 We seek comment on the increased value and
benefits of providing more accurate location information to certain populations, such as people with
disabilities, victims of crime, senior citizens and children. All such groups may have less ability to
(Continued from previous page)
made using cellphones”); J.D. Power 2011 Study (56 percent of wireless calls from indoors); SFDEM Mar. 25
Letter (70 percent of wireless 911 calls from indoors).
72 An accepted model developed by the United States Department of Transportation presently estimates the value of
a statistical life (VSL) at $9.1 million. See Memorandum from Polly Trottenberg, Under Secretary for Policy,
Office of the Secretary for Transportation, and Robert S. Rivkin, General Counsel, Department of Transportation,
Guidance on Treatment of the Economic Value of a Statistical Life in U.S. Department of Transportation Analyses
(Feb. 28, 2013), at 1, available at http://www.dot.gov/sites/dot.gov/files/docs/VSL Guidance_2013.pdf (last visited
Feb. 14, 2014). The Department of Transportation defines VSL as “the additional cost that individuals would be
willing to bear for improvements in safety (that is, reductions in risks) that, in the aggregate, reduce the expected
number of fatalities by one.” Id. at 2. Assuming a VSL of $9.1 million, 10,120 x $9.1 million = $92,092,000,000.
73 See Facilitating the Deployment of Text-to-911 & Other Next Generation 911 Applications Framework for Next
Generation 911 Deployment, Further Notice of Proposed Rulemaking, 27 FCC Rcd 15659, 15687 ¶¶ 69-71 (2012),
citing Athey, Susan and Stern, Scott, “The Impact of Information Technology on Emergency Health Care
Outcomes,” 22 The RAND J. of Econ. 3 (Autumn 2002), pp. 399-432, available at
http://kuznets.fas.harvard.edu/~athey/itemer.pdf (last visited Jan. 30, 2014) (Cardiac Study). The study notes that
cardiac emergencies account for only 20 percent of medical emergency calls to 911, and that it is a subset of
emergencies “for which timeliness is especially important.” See id. at 401, 428.
74 As in the Text-to-911 proceeding, we assume 4,142 lives are saved per year nationally. Text-to-911 FNPRM at ¶
71 n. 174. We then assume that 75 percent of cardiac incidents are reported to 911 on wireless phones, that 60
percent of those wireless calls are placed indoors, and that half of those incidents benefit from a quicker emergency
response time due to the improved indoor location accuracy (i.e., .75 x .6 x .5 x 4,142 lives = 932 lives).
75 See Written Testimony of Claude L. Stout, Executive Director, Telecommunications for the Deaf and Hard of
Hearing, Inc., before the Senate Commerce Committee, Subcommittee on U.S. Senate Committee on Commerce,
Science, and Transportation Communications, Technology, and the Internet, “Locating 911 Callers in a Wireless
World” (Jan. 16, 2014) at 4, available at
http://www.commerce.senate.gov/public/?a=Files.Serve&File_id=d561dcfb-a31f-432e-a600-0a804f76274c (last
visited Feb. 3, 2014) (Stout Location Accuracy Testimony).
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identify and relate to a 911 call-taker where they are located, especially in an emergency situation.76 In
such circumstances, accurate, automatically-generated location information can be critical to saving lives.
We seek comment regarding the value and scope of benefits that improved location accuracy would
provide in such circumstances.
35.
We understand that implementation of indoor location accuracy will likely impose
significant costs on providers. We seek comment generally on the costs of indoor location accuracy
requirements. The CSRIC indoor location test bed report indicates that while CSRIC “attempted to
provide some initial insight into costs associated with implementation of these new technologies, [it] did
not attempt to quantify cost to deploy, cost to operate and maintain, and cost impact to the
handset.”77 According to the report:
Some technologies have relatively low costs upfront to deploy but are relatively costly to
operate and maintain. Others have relatively high upfront costs and have lower
operational/maintenance costs. Some methods have cost implications in the handset,
some to the wireless network, and some impact both. Others require infrastructure
development independent of the wireless network. Some require the development and
maintenance of various databases to operate… Overall, each location technology requires
substantial investment in both time and resources.78
We seek detailed information on all of the costs providers estimate our proposed indoor location rules
would impose on them, including how these costs were determined.
36.
We anticipate that providers may implement different solutions to determine a caller’s
indoor location, and that each of these solutions may present unique costs. We seek 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. We understand that the specific manner in which we
implement any indoor location accuracy requirement, including the degree of accuracy required and the
timeframe for implementing any such requirement, potentially would affect providers’ costs of
compliance. We seek comment on these specific factors and how they might affect costs.79 Additionally,
we seek comment on whether additional costs would be passed on to consumers, resulting in higher rates.
If costs are likely to be passed on to consumers, we request information regarding how much rates would
increase.
37.
Finally, we believe 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. We seek 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. What additional costs would be
imposed by the potential indoor location requirements set forth in this Third Further Notice above and
beyond the costs that commercial carriers would already have in implementing indoor location
capabilities for commercial purposes?

B.

Near-Term Indoor E911 Location Accuracy Requirements

38.
As discussed in greater detail below, we propose that after a reasonable implementation
period, CMRS providers subject to Section 20.18 of the Commission’s rules must (1) locate callers within

76 For example, a person who is experiencing a heart attack may not be able to communicate verbally. See
Rosenworcel, Jessica, “Bring Wireless 911 Up to Date,” The Hill, Jan. 14, 2014, available at
http://thehill.com/opinion/op-ed/195446-bring-wireless-911-up-to-date (last visited Feb. 5, 2014).
77 See CSRIC Indoor Location Test Bed Report at 54.
78 See id. at 53.
79 We discuss these factors in greater detail in the implementation discussion below. See infra Section III.B.3.
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50 meters for 67 percent and 80 percent of indoor calls within two years and five years of the effective
date of adoption of rules, respectively, and (2) provide vertical (z-axis) data, within 3 meters accuracy, for
67 percent and 80 percent of indoor calls within three years and five years of the effective date of
adoption of rules, respectively. We propose that these indoor location accuracy requirements be
implemented nationwide. Finally, we propose the institutionalization of an indoor location accuracy test
bed for purposes of demonstrating compliance with these requirements and ask about other approaches to
validating compliance.
39.
We seek to promote several key objectives through these proposed rules: (1) make indoor
location as widely available as technically and economically feasible, tracking recent improvements in
location technology; (2) help CMRS providers, public safety entities, and the Commission to monitor
performance and compliance; and (3) adopt rules that are technology-neutral, cost-efficient, and easy to
understand and administer. We seek comment on how our proposed approach, as well as any potential
alternatives – particularly any consensus proposals from industry and public safety stakeholders – might
promote these objectives most effectively. We also seek comment on whether there are any other
engineering or other issues, not raised in this Third Further Notice, that the Commission should consider
with regard to promoting the location accuracy goals in this rulemaking proceeding.
1.

Horizontal Location Information

40.
Background. Prior to the CSRIC Indoor Location Test Bed Report, the record in response
to the E911 Location Accuracy Second Further Notice generally reflected a consensus that it was
premature to impose indoor location accuracy requirements. For example, while public safety entities
generally expressed concern regarding the lack of indoor location accuracy requirements,80 they
acknowledged that further exploration of indoor testing would be necessary before any such requirements
could be adopted.81 Industry representatives generally opposed the adoption of indoor accuracy
requirements pending further study and testing.82 They also pointed out the difficulty of creating an
adequate testing environment and the lack of currently available technologies.83 Additionally, vendors’
initial comments varied with regard to the speed and method by which they thought the Commission
should adopt indoor location requirements, or even whether it should adopt such requirements.84

80 See, e.g., APCO Comments, PS Docket No. 07-114 (filed Oct. 3, 2011) at 8 (APCO Second Further Notice
Comments); IACP, et al. Comments, PS Docket No. 07-114 (filed Oct. 3, 2011) at 1 (IACP Second Further Notice
Comments).
81 See, e.g., NENA Comments, PS Docket No. 07-114 (filed Nov. 1, 2011) at 13 (NENA Second Further Notice
Comments); APCO Further Notice Comments, PS Docket No. 07-114 (filed Jan. 18, 2011) at 3 (APCO Further
Notice Comments).
82 See, e.g., AT&T Comments, PS Docket No. 07-114 (filed Oct. 3, 2011) at 7 (AT&T Second Further Notice
Comments); CTIA Comments, PS Docket No. 07-114 (filed Oct. 3, 2011) at 4 (CTIA Second Further Notice
Comments); MetroPCS Comments, PS Docket No. 07-114 (filed Oct. 3, 2011) at 9 (MetroPCS Second Further
Notice Comments).
83 See, e.g., CTIA Second Further Notice Comments at 3.
84 See, e.g., TruePosition Comments, PS Docket No. 07-114 (filed Oct. 3, 2011) at 2 (TruePosition Second Further
Notice Comments) (Commission should apply location accuracy metrics to indoor environments and test for
compliance); CommLabs Reply Comments, PS Docket No. 07-114 (filed Oct. 3, 2011) at 8 (CommLabs Second
Further Notice Reply Comments) (Commission should not wait until the CSRIC report has been published before
initiating next regulatory step); Boeing Comments, PS Docket No. 07-114 (filed Oct. 3, 2011) at 20 (Boeing Second
Further Notice Comments) (Commission should not implement rules mandating specific technology or standard);
TeleCommunications Systems, Inc. Comments, PS Docket No. 07-114 (filed Oct. 3, 2011) at 12 (TCS Second
Further Notice Comments) (location accuracy for indoor calls requires more study); Motorola Comments, PS
Docket No. 07-114 (filed Oct. 3, 2011) at 9 (Motorola Second Further Notice Comments) (Commission should not
require indoor location accuracy testing by providers).
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41.
More recently, after CSRIC’s submission of its indoor location test bed report and
recommendations in March 2013, some public safety groups and technology vendors now urge the
Commission to require some level of accuracy for indoor 911 calls. For instance, APCO urges the
Commission to begin “now to develop rules and policies” to provide “a reasonable level” of indoor
accuracy.85 NENA suggests the “introduction of an indoor location accuracy standard” and “the phase-in
of a z-axis performance requirement.”86 TruePosition submits that the Commission “now has enough
information about indoor location technologies to move forward.”87 At the same time, however, some
industry representatives suggest that “future progress [is] needed to meet the expressed needs of the
public safety community.”88 However, as discussed above, CMRS providers express concern about the
ability to move forward with indoor location accuracy requirements at this time.89
42.
WG3 concluded approximately a year ago that “additional development is required to
ensure” the provision of an “actionable location,” especially in urban and dense urban environments.90
However, participants in the WG3 test bed have indicated that they were then in the process of making
improvements to their technologies. Other parties submit that recent developments in hybrid technologies
and solutions show that improvements in location accuracy are being implemented. Verizon submits that
it has been working “to improve the sensitivity of its [handsets’] GPS chipsets to satellite signals.”91 T-
Mobile asserts that “[t]he best opportunity for implementing improved location technology is as carriers
and consumers implement [VoLTE].”92
43.
Some industry representatives note the possibility for improved indoor accuracy with the
implementation of small cell networks. Verizon notes that “indoor small cell deployments, WLAN
location information, and hotspot or femtocell technologies, all of which can be designed with a very

85 Letter from Robert M. Gurss, Senior Regulatory Counsel, APCO International, to Marlene H. Dortch, Secretary,
FCC, PS Docket No.07-114 (filed Apr. 15, 2013), at 1 (APCO Apr. 15, 2013 Ex Parte Letter); see also APCO
Workshop Comments at 5; IACP Workshop Comments at 1; IAFC Workshop Comments at 1.
86 NENA Workshop Comments at 3.
87 Letter from James Arden Barnett, Jr., Counsel for TruePosition, Inc., to Marlene H. Dortch, Secretary, FCC, PS
Docket No. 07-114 (filed June 25, 2013), at Attachment, “Wireless 911 and Indoor Location Accuracy”
(TruePosition June 25, 2013 Ex Parte Letter). See also Letter from James Arden Barnett, Jr., Counsel for
TruePosition, Inc., to Marlene H. Dortch, Secretary, FCC, PS Docket No. 07-114 (filed June 14, 2013)
(TruePosition June 14, 2013 Ex Parte Letter), attaching Letter from Commissioner Charles H. Ramsey, President,
Major Cities Chiefs Association, to Julius Genachowski (filed May 27, 2013) (“urg[ing] … the Commission to
consider regulations that require telecommunications providers to provide indoor cellular location data to law
enforcement”). See also Letter from Tom W. Davidson, Counsel for TruePosition, Inc., to Marlene H. Dortch,
Secretary, FCC, PS Docket No. 07-114 (filed Apr. 25, 2013) at Attachment 1, page 22 (TruePosition Apr. 25, 2013
Ex Parte Letter) (“The FCC now has enough information . . . to move forward to solve the increasing problem of
inadequate indoor location coverage.”).
88 Letter from Bruce A. Olcott, Counsel for NextNav LLC (NextNav), to Marlene H. Dortch, Secretary, FCC, PS
Docket No.07-114 (filed June 28, 2013), at 2 (NextNav June 28, 2013 Ex Parte Letter). See also T-Mobile
Workshop Comments at 13 (near-term indoor accuracy deadlines are not feasible because, among several factors,
“[s]ome technologies . . . show promise, but those are not yet near-term commercialized solutions”).
89 See supra Section III, para. 25 note 53.
90 CSRIC Indoor Location Test Bed Report at 8.
91 Verizon Workshop Comments at 3 (also asserting that its “AFLT has become increasingly accurate” as it “has
worked with vendors to optimize antenna placement and base station information”). Verizon adds that
“enhancements to A-GPS and other location technologies . . . for VoLTE service will enable service providers to
improve indoor location accuracy” to “leverage the existing A-GPS configuration.” Id. at 5.
92 T-Mobile Workshop Comments at 34.
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small coverage area, have the potential to provide very accurate location information….”93 Sprint asserts
that “the addition of ‘small cells’ into carrier networks, along with other in-building solutions, may hold
some promise to help not only resolve coverage issues related to signal strength indoors….”94
44.
Discussion. We propose a near-term requirement to achieve “rough” indoor location
information. We propose to require CMRS providers subject to Section 20.18 of the Commission’s rules
to provide horizontal (x- and y-axis) information for wireless 911 calls that originate indoors.95
Specifically, we propose to require CMRS providers to identify an indoor caller’s horizontal location
within 50 meters.96 We propose that CMRS providers must satisfy this accuracy requirement for 67
percent of calls within two years from the effective date of the adoption of any rules, and for 80 percent of
calls within five years from the effective date of the adoption of any rules. Under this proposal, the
requirement would apply uniformly to all indoor calls and would be technology-neutral; CMRS providers
could use any location technology or combination of location technologies to meet this requirement.
45.
We believe that a search radius of 50 meters will provide meaningful information while
being attainable in the near-term. A larger search ring, while easier to implement, would not yield
sufficiently granular information to be of use to first responders.97 In the longer term, location
information should be sufficiently granular to provide a specific residential or business address, including
floor and suite or apartment information. Nevertheless, based on existing technological considerations
and the needs of the public safety community, we find that the public safety and interest would be better
served by adopting this requirement in the near term rather than allowing a regulatory gap to grow. We
agree with CSRIC’s observation that the objective should “be for the smallest possible search ring,” and
we seek comment on our proposed location accuracy requirement of 50 meters.98
46.
The CSRIC Indoor Location Test Bed Report also observed that the participating vendors
are currently working on improvements to their location technologies that show promise toward achieving
more precise accuracy performance.99 Additionally, the record and the CSRIC Indoor Location Test Bed
Report
indicate that other vendors are actively working on advances in improving location
technologies.100 We seek comment on the extent to which mandating a 50-meter accuracy requirement to

93 Verizon Workshop Comments at 7, citing Qualcomm Aug. 15, 2013 Ex Parte Letter, Att. at 10-11.
94 Sprint Workshop Comments at 8 (adding that such technologies might “be able to provide additional assistance in
locating callers with some specificity at indoor locations”). See also T-Mobile Workshop Comments at 12.
95 We characterize this near-term indoor accuracy level as “rough” in view of CSRIC WG3’s test bed results that
“[h]orizontal positional accuracy within 50 meters can provide a meaningful indoor location, particularly in rural or
suburban environments,” but that “even this accuracy within heavily urbanized areas or downtown settings may still
result in positions outside the actual building where the emergency call originated.” CSRIC Indoor Location Test
Bed Report
at 9.
96 See 47 C.F.R. § 20.18(h)(2)(i)-(ii).
97 For example, a 100-meter requirement would only narrow the search radius to a city block at best. A Manhattan
city block is 80 meters by 270 meters. See “City block,” available at http://en.wikipedia.org/wiki/City_block (last
visited Feb. 3, 2014). See also Third E911 Report and Order, 14 FCC Rcd at 17422 ¶ 74 (observing that “the 100
meter radius standard implies a circular area of 31,416 square meters”; but with a 50-meter requirement, “the area
enclosed would be only a quarter the size, 7,854 square meters”).
98 See CSRIC Indoor Location Test Bed Report at 9.
99 See id. at 40–41 (discussing NextNav’s next generation system, Polaris’s improvements to its “signature
representation” technology to solve signal path problems on the upper floors of buildings; and Qualcomm’s
improvements to its 3G AFLT technology that will incorporate OTDOA location technology in 4G LTE networks).
100 See TruePosition Wilmington Test Bed Results; Letter from Bruce A. Olcott, Counsel, NextNav, LLC, to
Marlene H. Dortch, Secretary, FCC, PS Docket No. 07-114 (filed Aug. 14, 2013) (NextNav Aug. 14, 2013 Ex Parte
Letter) (reporting the test results for a second generation of NextNav’s technology); Cisco July 24, 2013 Ex Parte
Letter at 1; CSRIC Indoor Location Test Bed Report at 55 (listing the following vendors who did not participate but
(continued….)
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indoor calls – after a reasonable period of time – would encourage CMRS providers to work with location
and device vendors to implement the advances being made in indoor location technology.
47.
As noted above, the CSRIC test bed examined the RF fingerprinting, A-GPS/AFLT, and
beacon technologies of Polaris, Qualcomm, and NextNav, respectively. Horizontal location accuracy
varied by technology and the representative environments – dense urban, urban, suburban, and rural. For
each environment, CSRIC evaluated the accuracy of each technology for 67 percent and 90 percent of the
total number of calls tested.101 While we acknowledge that the test bed results indicate that further
improvement is necessary, we are encouraged that, at least in suburban and rural environments, a 50-
meter (or less) search ring can already be produced by existing technology. Further, even if technology
currently cannot satisfy the proposed near-term 50-meter accuracy requirement in more challenging
indoor environments, the adoption of more stringent requirements for indoor location accuracy, together
with a reasonable implementation timeframe, would afford CMRS providers with sufficient time and
incentive to develop the necessary technology to enable compliance with the proposed requirement
regardless of the environment.
48.
We propose to combine the 50-meter accuracy requirement with a reliability threshold of
67 percent in two years and 80 percent in five years. With this requirement, the center point of the
uncertainty circle should fall within 50 meters of the true location 67 or 80 percent of the time, as
applicable, and must be delivered within 30 seconds.102 Thus, under the first two-year benchmark, up to
33 percent of calls may either have location outside the accuracy threshold or location data that arrives
after a delay of more than 30 seconds. We seek comment on whether the proposed two-stage reliability
thresholds of 67 and 80 percent would be useful to public safety entities and technically feasible for
CMRS providers to achieve. Under the current E911 requirements based on outdoor measurements,
CMRS providers using handset-based location technologies must satisfy a reliability requirement of 67
percent for 50 meters. We also note that CSRIC tested for location accuracy based on the reliability
percentages of 67 percent and 90 percent of the total number of calls tested.103 In proposing this two-
stage reliability requirement, we seek comment on whether a reliability metric of 67 percent is adequate
to meet the needs of public safety in the current environment. CSRIC considered that the public safety
entities need reliable, “consistent caller location information” for indoor locations;104 would a 67 percent
requirement provide sufficiently reliable indoor location information? We note that CSRIC’s analysis of
accuracy measurements versus reliability percentages indicates that an 80 percent reliability requirement
for indoor calls, while not achievable now, may be attainable with a 50-meter accuracy requirement in the
proposed near-term period.105 We seek comment on whether two-stage approach to adopting reliability
requirement would adequately address public safety needs, and seek comment on any alternative
approaches.
(Continued from previous page)
hopefully could in future test beds: TruePosition (UTDOA Positioning), CommScope (DAS Proximity-based
Positioning), CSR (AGNSS/WiFi/MEMS Sensor Hybrid Positioning), and Boeing BTL (LEO Iridium Satellite-
based Positioning)).
101 See CSRIC Indoor Location Test Bed Report at 26-27, Table 7.2-1, Summary Horizontal Accuracy Statistics in
All Environments.
102 While we propose that CMRS providers must identify a location fix within 30 seconds, we propose to allow
CMRS providers to exclude calls of 10 seconds or less, for which the CMRS provider is unable to obtain a location
fix, in assessing compliance with the 67 and 80 percent reliability thresholds. See infra Section IV.A.
103 See CSRIC Indoor Location Test Bed Report at 26-27, Table 7.2-1, Summary Horizontal Accuracy Statistics
(also testing for accuracy for 95 percent of the total number of calls).
104 See id. at 9.
105 See id. at 27, 29, and 32, Figs. 7.3-1, 7.3-3, and 7.3-5 (illustrating cumulative horizontal accuracy in dense urban,
urban, and suburban environments).
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49.
We also seek comment on whether the proposed two-stage reliability requirements are
feasible in light of the types of specific challenges that CMRS providers may confront in indoor
environments, such as the proliferation of signal boosters within buildings.106 We seek comment on the
extent to which these types of indoor-specific challenges may affect a providers’ ability to deliver
location information in compliance with our proposed reliability thresholds for indoor calls.
50.
At the same time, we recognize that certain in-building systems and access devices –
such as a DAS network – could be programmed to provide specific location information, including
building address and floor level information, for the origination of the indoor call.107 In addition to our
proposed 50-meter accuracy requirement, should we consider adopting an alternative indoor location
requirement that CMRS providers can satisfy by delivering a caller’s building address and floor
information? Such a requirement would be consistent with our long-term indoor location objective,
which is the delivery of “dispatchable address” information, including the caller’s building address, floor
level, and suite/room number.
51.
Further, we propose that the combined 50-meter accuracy and 67- and 80-percent
reliability requirements comprise the sole ring for testing indoor location accuracy. We seek comment on
this proposal. We note that, in the context of E911 location accuracy based on outdoor measurements,
our rules include a “dual search ring” system, with different reliability thresholds for 50-meter and 150-
meter accuracy.108 While a dual search ring requirement was a reasonable approach based on outdoor
measurements,109 a search ring larger than 50 meters is unlikely to yield sufficiently granular information
to prove useful to public safety in the context of locating a caller indoors.
52.
We also seek comment on the costs of imposing a 50-meter accuracy requirement (versus
some other benchmark), and a two-stage reliability requirement of 67 and 80 percent (or some other
reliability benchmark or dual ring system). We anticipate that a more precise horizontal 50-meter
accuracy requirement would come at a higher cost than a less precise accuracy requirement, but to what
extent? We seek comment on what any cost differential might be, and whether such costs could be
mitigated. For example, would a single 50-meter /67 or 80 percent requirement be more costly to CMRS
providers than a dual search ring? For example, would a 50-meter/67 percent, 150-meter/80-90 percent
requirement (similar to our existing Phase II E911 requirements based on outdoor measurements for
handset-based location solutions) serve to reduce costs?
53.
We seek comment on alternative approaches to implementing indoor location accuracy
and reliability requirements. For example, a potential alternative approach would be to extend the
existing E911 Phase II location accuracy requirements, which currently apply to outdoor measurements

106 See Amendment of Parts 1, 2, 22, 24, 27, 90 and 95 of the Commission’s Rules to Improve Wireless Coverage
Through the Use of Signal Boosters, WT Docket 10-4, Report and Order, 28 FCC Rcd 1663, 1665 ¶ 3 n. 1 (2013)
(Signal Booster Report and Order). In the Signal Booster Report and Order, the Commission defined a “signal
booster” as including all manner of amplifiers, repeaters, boosters, distributed antenna systems, and in-building
radiation systems that serve to amplify signals between a device and a wireless network. The Commission noted
that signal boosters can affect network-based E911 solutions in some instances, by introducing delay that alters the
measured time-of-arrival used by network-based E911 systems. Id. at ¶ 83.
107 See also infra Section III.C.1 (seeking comment on the potential for attaching specific address information to
small cells and DAS networks, and transmitting such information with wireless calls to 911 from indoors).
108 See 47 C.F.R. § 20.18(h)(2)(i), (ii) (applying to handset-based technologies and establishing 80 percent for the
initial benchmark and 90 percent for the last benchmark in 2019); for network-based technologies, the reliability
percentages are 67 and 90 percent but with less stringent accuracy standards. See 47 C.F.R. § 20.18(h)(1)(i), (ii).
109 In the past, the Commission has observed that a dual ring approach encourages the implementation of location
technologies that may not be accurate enough to satisfy a desired stringent standard but could provide beneficial
“backstop and adjunct capabilities.” See Third E911 Report and Order, 14 FCC Rcd at 17423 ¶ 77 (also including
network-based location technologies for rural environments).
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only, to indoor environments. While this approach would permit providers to simply apply existing
outdoor location accuracy requirements to indoor calls, such an approach could be inconsistent with the
Commission’s intent to progress towards more granular location data for all wireless calls to 911,110 and,
as discussed above, would be unlikely to result in a sufficiently narrow search ring to be of use to public
safety in indoor environments.111 Further, we think that a uniform indoor accuracy requirement,
independent from any existing outdoor location requirements, acknowledges that indoor environments are
distinct from outdoor environments. In the Indoor Location Test Bed Report, CSRIC recommended that
the Commission treat indoor location accuracy separately from outdoor location accuracy due to
differences in testing and technologies.112 We seek comment on this analysis and our proposed approach.
54.
We also invite 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 invite 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. We seek comment on whether there has been a market failure in the
provision of E911 information and, if not, whether the market could be relied upon to address indoor
location issues on its own, and within a reasonable period of time. Could voluntary commitments, in
conjunction with Commission monitoring of indoor location accuracy developments and actual
performance, be sufficient and effective in satisfying the public safety objectives of this proceeding? We
invite comment on the potential for voluntary commitments and other consensus-based proposals to
address these issues.
55.
Timeframe. In light of recent developments in wireless technology and usage trends, we
believe it is critical to address the gap in our existing E911 regulatory framework regarding indoor
location accuracy as quickly as possible. Accordingly, we propose a two-stage implementation timeframe
from the effective date of an order adopting indoor E911 location accuracy requirements and seek
comment on whether such a timeframe would be technically feasible and economically reasonable. We
recognize that the extent to which a provider is able to satisfy a specific accuracy or reliability
requirement will be linked to the timeframe allowed for implementation of such requirements.
56.
The record, to date, is divided regarding whether location accuracy technology is
sufficiently developed to support the near-term implementation of an indoor location accuracy
requirement.113 However, evidence in the record suggests that technology is sufficiently developed to
support the implementation of an indoor location accuracy requirement in the near term. For example,
CSRIC observed that the participating vendors are currently working on improvements to their location

110 We discuss the Commission’s intent to move towards more granular location information for outdoor calls
below. See infra Section IV.A.
111 The Commission has indicated that it will eliminate the larger 100/300-meter network-based accuracy standard
for outdoor measurements and will require providers to satisfy a 50-meter standard for all calls over time. See
Wireless E911 Location Accuracy Requirements, Third Report and Order, PS Docket No. 07-114, 26 FCC Rcd
10074, 10082 ¶ 19 (stating that “the network-based standard should sunset at an appropriate point after the end of
the eight-year implementation period, at which point all carriers would be obligated to meet the handset-based
location accuracy standard”) (E911 Location Accuracy Third Report and Order). See also 47 C.F.R. §
20.18(h)(1)(ii)(C) (the last location accuracy benchmark for network-based providers is Jan. 18, 2019).
112 See CSRIC Indoor Location Test Bed Report at 52 (noting that indoor testing may require different industry
accepted methods of testing, compared to outdoor methods).
113 Wireless providers, while indicating there has been considerable development in indoor location technologies,
nevertheless emphasize that “indoor location accuracy and vertical location are both areas where considerable work
remains” and “caution against trying to impose aggressive rules ahead of either consensus on standards for indoor
location accuracy or proven technologies.” See, e.g., AT&T Comments, PS Docket No. 07-114 (filed Sept. 25,
2013), at 6 (AT&T Workshop Comments).
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technologies that show promise toward achieving more precise accuracy performance.114 These results
also indicate that at least one indoor location technology is already close to achieving the indoor accuracy
requirement equivalent to the existing outdoor handset-based location requirement (50 meters for 67
percent of calls).115 The record and the CSRIC Indoor Location Test Bed Report indicate that other
vendors are actively working on advances in improving location technologies.116 In addition, recent
filings suggest that the technology is sufficiently developed to support a near-term indoor location
accuracy requirement.117
57.
We seek comment on whether a two-year timeframe is sufficient for CMRS providers to
satisfy the horizontal (x- and y-axis) component of the indoor location accuracy requirement discussed
above for 67 percent of indoor 911 calls. We believe that the significant public interest benefits of
providing indoor location as soon as possible, combined with the current pace of technological
developments, suggest that an expedited timeframe may be feasible and warranted. The CSRIC test bed
results, which tested three different technologies – all of which provided reasonably accurate indoor
measurements – and subsequent testing by others of their indoor location technology with similar
results,118 suggests that location technology, with further advancements, could satisfy our proposed
accuracy requirement within this timeframe. Furthermore, as described above, at least two of the indoor
location technologies tested in the CSRIC test bed are commercially available already, while TruePosition
asserts that its solution is already in use by two of the nationwide CMRS providers and “can easily be
paired with existing AGPS capabilities, used by many cell phone networks, in a hybrid solution.”119 We
seek comment on our analysis. In what timeframe could technologies meet the proposed 50-meter
requirement for 67 percent of all indoor calls? Is a five-year timeframe appropriate for technologies to
meet the proposed 50-meter requirement for 80 percent of all indoor calls? How long would standards
bodies need to develop any necessary standards? What else should the Commission consider with regard
to the proposed timeframes?
58.
We also seek comment on how any necessary network and handset upgrades would
impact the proposed timeline. How long would it take CMRS providers to deploy location accuracy
systems capable of meeting the proposed requirements throughout their networks? How long would
providers need to obtain the hardware necessary for upgrading handsets to work with newly deployed
location accuracy systems? How much time would be necessary for upgraded handsets to enter the

114 See, e.g., CSRIC Indoor Location Test Bed Report at 40–41 (discussing NextNav’s next generation system,
Polaris’s improvements to its “signature representation” technology to solve signal path problems on the upper
floors of buildings; and Qualcomm’s improvements to its 3G AFLT technology that will incorporate OTDOA
location technology in 4G LTE networks).
115 Id. at 35.
116 See TruePosition Wilmington Test Bed Results; NextNav Aug. 14, 2013 Ex Parte Letter; Cisco July 24, 2013 Ex
Parte
Letter at 1; CSRIC Indoor Location Test Bed Report at 55 (listing the following vendors who did not
participate but hopefully could in future test beds: TruePosition (UTDOA Positioning), CommScope (DAS
Proximity-based Positioning), CSR (AGNSS/WiFi/MEMS Sensor Hybrid Positioning), and Boeing BTL (LEO
Iridium Satellite-based Positioning).
117 In a recent ex parte, for example, NextNav states that “[a]ll four major wide-area location providers [have]
confirmed that their most advanced location technologies can be deployed and in commercial operation within two
years.” See Letter from Bruce A. Olcott, Counsel, NextNav, LLC, to Marlene H. Dortch, Secretary, FCC, PS
Docket No. 07-114 (filed Nov. 26, 2013) at 8 (NextNav Nov. 26, 2013 Ex Parte Letter).
118 See supra Section II.B. para. 17; see also Table 1.
119 TruePosition April 22, 2013 Ex Parte Letter at 2. While handset-based providers have traditionally been the
primary users of A-GPS, network-based providers have also been migrating in this direction. See Section IV.D
(discussing migration to handset-based location accuracy technologies); see also E911 Location Accuracy Third
Report and Order,
26 FCC Rcd at 10082 ¶ 18.
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marketplace to sufficiently penetrate the marketplace, such that providers could meet the proposed 67 and
80 percent reliability requirements?
59.
Some commenters suggest a longer implementation timeframe is necessary, but we
believe that the establishment of firm timeframes – together with a clear accuracy requirement – will
provide the regulatory certainty necessary120 for parties to dedicate resources to improving location
accuracy technology. Further, the extent and pace of recent advancements in indoor location technology
suggests that technical feasibility will not prove to be a barrier to implementation of a near-term, two-year
indoor location requirement of 50 meters for 67 percent of calls. Given that there are several different
indoor location technology solutions already deployed or under development, we think that a two-year
timeframe would allow for the development of technological alternatives and encourage competition
among location technology vendors, so that CMRS providers would have a choice of solutions to
implement. Two years would also allow time necessary to establish the indoor location accuracy test bed.
60.
We also seek comment on alternatives to using the effective date of rules as the trigger
for the timeline to comply with proposed indoor location accuracy requirements. For example, to address
potential uncertainty in the development of technology, should we consider initiating the compliance
timeline only after the test bed administrator certifies that a technology has met the proposed accuracy
standards in the test bed? Would any process be necessary or appropriate for opportunity for comment on
and Commission review of such a determination? If we used technology certification as the timeline
trigger, should we require availability of competitive technology options? Should we retain the two- and
five-year timelines proposed above or should they be shortened? Would linkage of the timeline to
technology certification reduce the incentive to invest in technological development or create incentives
to delay testing in the test bed? What other factors should we consider with regard to the impact of test
bed certification on proposed timelines?
61.
As another alternative, if the timeline is triggered by the adoption of rules, we seek
comment on whether the Commission should consider reevaluating the compliance timeline at some
interim point to evaluate the status of testing of location technology. For example, a year after the rules
go into effect, the Commission could require the test bed administrator to report to the Commission on the
results of technology testing, at which point the Commission could consider whether any adjustments to
the timeline are necessary based on how technologies have performed in the test bed. Such an approach
would enable the Commission to evaluate progress made during testing while retaining control over
implementation timeframes and ensuring that testing efforts proceed in a timely manner. We seek
comment on this alternative.
62.
We invite parties who disagree with this proposed timeframe to provide specific reasons
why more time is necessary, including the steps necessary to implement horizontal requirements and the
time necessary to satisfy each step. We also seek comment on whether there have been sufficient
advancements in location technology since the CSRIC test bed results. We also understand that
additional capital investment may be necessary to meet any new proposed indoor testing requirements.
We seek detailed and concrete data regarding the costs of implementing horizontal indoor location
accuracy requirements within a two-year timeframe. We also seek comment on alternative reliability
standards, as well as on whether we should phase in different reliability standards in conjunction with
staged implementation timeframes, or different requirements for specific types of mobile devices (e.g.,
only 4G-capable devices). Alternatively, would likely development timetables and cost considerations
warrant a longer implementation timeframe that would permit integration of the vertical location
capability proposed below on the same schedule?
63.
Facilitating Network Migrations and NG911 Transitions. Whether we adopt the
proposed requirements or another approach, we seek to encourage CMRS providers to invest in the near-
term as a pathway to achieving more precise indoor accuracy in the long term. We also believe that any

120 See supra Section III, para. 25 note 53.
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near-term indoor location accuracy requirements should take into account long-term E911 and NG911
objectives to avoid requiring significant investment in technologies that could become stranded. In our
view, a technology-neutral indoor accuracy requirement should allow CMRS providers flexibility to
adopt an indoor location accuracy solution that best fits with their long-term business and technology
plans.
64.
We seek comment on how best to structure a near-term requirement so that it will
promote our longer-term objectives. For instance, what approach would provide incentives to providers
to leverage existing investments in implementing technologies in the near-term to facilitate their efforts to
meet a long-term accuracy requirement? What effect if any would it have on their ability and incentive to
accelerate deployment of the vertical location accuracy goals discussed below? On the transition to
NG911? How would the adoption of a near-term 50-meter requirement affect the costs, deployment, and
operation of the network upgrades that providers currently are making to deploy 4G technologies? Would
the proposed near-term requirements have an adverse impact on current and future requirements work that
could also serve to achieve meeting a long-term accuracy requirement? In this regard, we note that
CSRIC concluded that more standards work will be required “to allow practical implementation of many
emerging location technologies for emergency services use.”121
2.

Vertical Location Information

65.
Background. While horizontal location information is a critical element to locating a 911
caller, a third dimension of location information – a vertical, or “z-axis” component – would greatly
enhance location accuracy. Vertical location information on a caller’s floor height would substantially
benefit first responders trying to locate callers in multi-story buildings.
66.
Locating 911 callers in a three-dimensional environment has been a longstanding goal of
the Commission. In 1994, prior to the adoption of its initial E911 rules, the Commission envisioned a
“Phase III” of E911 implementation, which would include a vertical location component.122 The
Commission observed that “location information consisting only of latitude and longitude may be
sufficient for radio transmitters operating outside of an urban environment,” but that “[e]ven greater
accuracy could be necessary in urban environments to determine the precise location of a caller within a
multi-story structure.”123 Indeed, from the beginning, the Commission has noted the need for z-axis
information for urban areas.
67.
Building on this initial inquiry, in 1996 the Commission proposed that “carriers should be
required to achieve the capabilities necessary to provide to PSAPs . . . information that locates a wireless
911 caller within a radius of 40 feet . . . using longitude, latitude, and vertical location data.”124 It also
sought comment on whether it would be appropriate to limit the applicability of vertical location
requirements to certain geographic areas125 and what additional costs would be imposed on providers in
order to support the provision of vertical location data.126

121 CSRIC Indoor Location Test Bed Report at 54. See also Cisco July 24, 2013 Ex Parte Letter at 1(concerning Wi-
Fi standards work and certification in 2015).
122 Revision of the Commission’s Rules to Ensure Compatibility with Enhanced 911 Emergency Calling Systems,
Notice of Proposed Rulemaking, 9 FCC Rcd 6170 at ¶ 51 (1994).
123 Id..
124 First E911 Report and Order, 11 FCC Rcd at 18743-44 ¶ 138.
125 Id. at 18744 ¶ 140 (seeking comment “whether it would be appropriate to limit a requirement for providing this
type of location information to certain geographic areas.”).
126 Id. at 18745 ¶ 141. Subsequently, the Commission focused its inquiry on horizontal location accuracy, as
described above. See [cross-reference earlier discussion]. At that time, indoor wireless coverage was neither as
prevalent nor as important, as landline phones were predominantly used indoors
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68.
The Commission most recently sought comment on the technical feasibility of
implementing vertical location accuracy requirements in its 2010 E911 Location Accuracy Further
Notice
.127 Specifically, the Commission sought comment on the state of industry development of z-axis
technology and the development of relevant standards; what existing technologies could integrate z-axis
components; how z-axis location data could be incorporated into the data already being delivered to
PSAPs; and in what timeframe it would be reasonable to require carriers to deliver z-axis information
with its location data.128
69.
In response to the E911 Location Accuracy Further Notice, most commenters submitted
that z-axis information would be extremely useful for first responders.129 At the time, however, most
commenters agreed that no technology with sufficiently developed z-axis location capabilities existed.130
Likewise, commenters stressed the unique challenges of providing vertical location as opposed to
horizontal location.131 Commenters also emphasized that PSAPs would face difficulties with interpreting
z-axis information and translating this data into a usable format for first responders.132 For example,
Polaris Wireless noted that because vertical location is best expressed in contextual form, “PSAP call
takers must be able to visualize vertical location information in computer-aided design (‘CAD’) or other
display formats in order to dispatch personnel to the correct place.”133 A number of commenters argued
that the Commission should establish a task force to conduct a more in-depth analysis of issues relating to
the delivery of usable z-axis location information.134 Some commenters suggested that the Commission

127 E911 Location Accuracy Further Notice, 25 FCC Rcd at 18966-67 ¶ 23.
128 Id.
129 See APCO Comments, PS Docket No. 07-114 (filed Jan. 19, 2011), at 5 (APCO Further Notice Comments);
AT&T Comments, PS Docket No. 07-114 (filed Jan. 19, 2011), at 12 (AT&T Further Notice Comments); Motorola
Comments, PS Docket No. 07-114 (filed Jan. 19, 2011), at 8 (Motorola Further Notice Comments); NENA
Comments (corrected), PS Docket No. 07-114 (filed Jan. 20, 2011), at 11 (NENA Further Notice Comments).
130 See, e.g., AT&T Further Notice Comments at 12; APCO Further Notice Comments at 5; ATIS Comments, PS
Docket No. 07-114 (filed Jan. 19, 2011), at 9 (ATIS Further Notice Comments); CTIA Comments, PS Docket No,
07-114 (filed Jan. 19, 2011), at 7 (CTIA Further Notice Comments); Motorola Further Notice Comments at 8;
Polaris Wireless Comments, PS Docket No. 07-114 (filed Jan. 19, 2011), at 8 (Polaris Further Notice Comments);
Sprint Nextel Comments, PS Docket No, 07-114 (filed Jan. 19, 2011), at 9 (Sprint Further Notice Comments); T-
Mobile USA, Inc. Comments, PS Docket No, 07-114 (filed Jan. 19, 2011), at 20 (T-Mobile Further Notice
Comments); TeleCommunications Systems, Inc. Comments, PS Docket No. 07-114 (filed Jan. 19, 2011), at 5 (TCS
Further Notice Comments); Texas 911 Alliance Comments, PS Docket No, 07-114 (filed Jan. 19, 2011) , at 16
(Texas 911 Further Notice Comments). Two commenters argued that the provision of z-axis information was
technically feasible in the near term. See CommLabs Comments, PS Docket No. 07-114 (filed Jan. 19, 2011), at 12
(CommLabs Further Notice Comments); Intrado Comments, PS Docket No. 07-114 (filed Jan. 19, 2011), at 4
(Intrado Further Notice Comments).
131 See Andrew, a Commscope Company Comments, PS Docket No. 07-114, (filed Jan. 18, 2011) at 6-7
(CommScope Further Notice Comments); AT&T Further Notice Comments at 12; Motorola Further Notice
Comments at 8-9; Polaris Further Notice Comments at 20.
132 See APCO Further Notice Comments at 5; ATIS Further Notice Comments at 9; Motorola Further Notice
Comments at 9; Polaris Further Notice Comments at 8; Sprint Further Notice Comments at 9; T-Mobile Further
Notice Comments at 21; Verizon and Verizon Wireless Comments, PS Docket No. 07-114 (filed Jan. 19, 2011), at
14 (Verizon Further Notice Comments); NENA Further Notice Comments at 12; Sprint Workshop Comments at 7.
133 Polaris Further Notice Comments at 8.
134 See, e.g., AT&T Further Notice Comments at 12; AT&T Reply Comments, PS Docket No. 07-114 (filed Feb. 18,
2011) , at 8 (AT&T Further Notice Reply Comments) (suggesting that the Commission postpone regulatory work on
z-axis and instead task an E911 Technical Advisory Group to explore further); CTIA Further Notice Comments at 7
(“A stakeholder group would prove useful when evaluating and making recommendations on topics like [z-axis] . .
.”); see also Polaris Further Notice Comments at 9; Motorola Reply Comments, PS Docket No. 07-114 (filed Feb.
18, 2011), at 5 (Motorola Further Notice Reply Comments).
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wait and impose a vertical location accuracy requirement in conjunction with a comprehensive rollout of
Next Generation 911.135 Most commenters agreed that there was still considerable work to be done to
develop vertical location technology and standards and that regulation was inappropriate at that time.136
70.
CSRIC II’s Working Group 4C (WG4C) was responsible for examining E911 and public
safety location technologies in use today, identifying current performance and limitations for use in next
generation public safety applications, examining emerging E911 public safety location technologies, and
recommending options to CSRIC for the improvement of E911 location accuracy timelines.137 Among
other findings, WG4C identified several challenges with providing a vertical location data, noting in
particular that “[c]urrent data formats for sending location to a PSAP do not support transmission of Z-
height, and therefore a change to the relevant standards is required.”138 Finally, WG4C recommended
that there be an in-depth analysis in the future of z-axis data and how it could be transmitted to PSAP
securely.139
71.
The Commission later tasked CSRIC II with additional investigation of location
accuracy140 Subsequently, as discussed above, in 2012-2013, CSRIC III’s WG3 conducted an indoor
location test bed to explore further currently available and future indoor location technologies.141
Although it did not specifically focus on technologies that could provide z-axis information, one

135 See CommScope Further Notice Comments at 7 (“it is not so much ‘altitude’ information that is useful as it is on
which “floor(s)” the caller is likely located. The NG911 architecture capability of delivering civic address form of
location . . . means that this “altitude” consideration may be better addressed in the context of NG911 rather than
conventional Phase II cellular E911, because the “floor” and building address can be explicitly communicated in the
NG911 architecture.”); NENA Further Notice Comments at 12 (“With PSAPs in the beginning stages of the
transition to NG9-1-1, it may be appropriate for the commission to address z-axis requirements in the context of a
deployed NG9-1-1 system.”).
136 See, e.g., APCO Further Notice Comments at 5; NENA Further Notice Comments at 11; ATIS Further Notice
Comments at 9; Motorola Further Notice Comments at 8; Polaris Further Notice Comments at 21; Sprint Further
Notice Comments at 9; Verizon Further Notice Comments at 13-14. But see Texas 911 Further Notice Comments at
16 (suggesting that requirements in at least some contexts – such as requiring femtocells to provide MSAG address
information – could mitigate some of the more difficult unresolved location accuracy issues); CommLabs Further
Notice Comments at 14 (“The Commission should [also] move forward with the adoption of a z-axis mandate in its
indoor location accuracy and testing rules.”).
137 E911 Location Accuracy Further Notice and NOI, 25 FCC Rcd at 18962 ¶ 12 (stating that “[o]ne of the Working
Groups within CSRIC, Group 4C - Technical Options for E911 Location Accuracy, is responsible for examining
E911 and public safety location technologies in use today, identifying current performance and limitations for use in
next generation public safety applications, examining emerging E911 public safety location technologies, and
recommending options to CSRIC for the improvement of E911 location accuracy timelines”). See also CSRIC II
Working Group 4C, Technical Options for E911 Location Accuracy Final Report, at 5 (March 14, 2011), available
at
http://transition.fcc.gov/pshs/docs/csric/CSRIC_4C_Comprehensive_Final_Report.pdf (last visited Feb. 3, 2014)
(Technical Options for E911 Location Final Report). CSRIC II spanned March 19, 2009 to March 19, 2011.
CSRIC III was chartered from March 18, 2011 to March 18, 2013.
138 Technical Options for E911 Location Final Report at 28. WG4C also acknowledged that at the time, “Phase II
deployments were not designed to provide accurate Z-height” and that “significant development would be required
for any Z-height compatible modifications or replacements.” Id.
139 Id. at 28.
140 See CSRIC, Working Group Descriptions, Working Group 4C, available at
http://transition.fcc.gov/pshs/advisory/csric/wg-descriptions.pdf (last visited Feb. 3, 2014). As mentioned
previously, the CSRIC II charter expired in March 2011, when it was superseded by CSRIC III. CSRIC II’s
Working Group 4A, CSRIC III’s Working Group 3, and CSRIC IV’s Working Group 4C were tasked with the same
function.
141 See CSRIC Indoor Location Test Bed Report.
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participating vendor, NextNav, tested its indoor location technology for vertical location accuracy in the
CSRIC test bed.142 NextNav provided vertical location accuracy within 2.9 meters and 4.8 meters for the
67th and 90th percentiles, respectively.143 NextNav’s second-generation technology was tested again in
2013 and demonstrated improvements on the results reported in the 2012 test bed, including z-axis
performance.144
72.
WG3 noted that “[p]ublic safety recognizes that additional work remains before
actionable altitude measurements can be broadly provided and utilized to aid first responders, including
standardization, commercial availability, and deployment of such technologies.”145 However, the record
indicates that other vendors have been developing this capability, suggesting that z-axis technology has
taken significant strides toward commercial viability since the Commission last considered it. For
example, several commenters noted the feasibility of indoor and vertical location and have strongly urged
the Commission to develop indoor location accuracy requirements.146
73.
Discussion. In light of advancements in indoor location technologies with vertical
capabilities, and the growing use of smartphones with features such as barometric pressure sensors, we
believe that vertical location technology has sufficiently matured to propose the near-term inclusion of z-
axis location information for wireless 911 calls placed from indoors. Specifically, we propose to require
CMRS providers to deliver z-axis location information within 3 meters of the caller’s location, for 67
percent and 80 percent of indoor wireless 911 calls within three years and five years of the effective date
of adoption of rules, respectively.147 By using a 3-meter measurement, we are effectively requiring floor

142 Id. at 36.
143 Id. at 39. To compare, an average floor height separation is 3 meters. Id. at 39. See also Council on Tall
Building and Urban Habitat, Height Calculator, available at
http://www.ctbuh.org/TallBuildings/HeightStatistics/HeightCalculator/tabid/1007/language/en-GB/Default.aspx
(last visited Feb.3, 2014) (Height Calculator) (assuming a standard floor-to-floor height of 3.9 meters in office
buildings, 3.1 meters in residential and hotel buildings, and 3.5 meters in mixed- or unknown use buildings).
144 NextNav Aug. 14, 2013 Ex Parte Letter at 1-2.
145 CSRIC Indoor Location Test Bed Report at 9.
146 See, e.g., NENA Workshop Comments at 3 (explaining that “as the recent CSRIC test bed results make clear,
technology exists and can be (or in some cases already is) deployed today that can much better meet the needs of the
public,” including with respect to vertical location) See also Letter, Bruce A. Olcott, Counsel to NextNav, to
Marlene Dortch, Secretary, FCC, PS Docket No. 07-114 (filed Nov. 13, 2013), at 3 (“Although NextNav was the
only vendor to demonstrate ‘floor level’ vertical location accuracy in the CSRIC test-bed, other location technology
vendors have developed vertical indoor location capabilities. The CSRIC LBS Report discussed several technologies
capable of providing vertical location accuracy including Observed Time Difference of Arrival technologies,
Distributed Access System proximity-based location technologies, and hybrid A-GPS technologies. Further, the
underlying approach to NextNav’s vertical location capabilities (the use of calibrated miniature pressure sensors in
handsets) is a technique numerous other vendors have noted can be supported by their systems as well.”) (footnotes
omitted); TruePosition Workshop Comments at 6 (“New pressure sensors are available for installation in wireless
phones which can be used to determine the altitude, or Z-axis. These pressure sensors have absolute and relative
errors which must be calibrated in order to provide an accurate altitude. Experimental calibration schemes have
shown promise on prototype systems.”); Mission Critical Partners, Inc. Comments, PS Docket No. 07-114 (filed
Sept. 25, 2013), at 2(Mission Critical Partners Workshop Comments) (“Submissions to the record in this proceeding
claim the potential for a technology that would provide a … possible z-axis accuracy of less than five meters
indoors. The benefits and improvements to the safety and capabilities of first responders that would utilize a
network with these location specifications would be immeasurable.”) (footnotes omitted).
147 The vertical location accuracy requirement would be a separate and independent requirement from the horizontal
location accuracy requirement discussed above. The vertical requirement would apply independently – and would
be measured and tested independently – from any horizontal location accuracy requirement.
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level information.148 A vertical search ring greater than 3 meters from the caller could lead to mistaken
floor identification.149 In response to the E911 Location Accuracy Further Notice, CommScope noted
that “vertical accuracy standard would need to be far more stringent than the current standards for the X-
Y (Latitude/Longitude) components to provide effective information for emergency location purposes.”150
We seek comment below on various aspects of our proposal.
74.
We think a 3-meter vertical location accuracy requirement is technically feasible.
Significantly, based on the test bed report and filings in the record to date, at least one vendor has
developed vertical location technology that already can locate callers to within 2.9 meters at the 90th
percentile,151 and others estimate having similar granular capabilities within three to five years.152 Below,
we seek comment on whether an initial deployment requirement of three years from the effective date of
our new rules would be achievable, including whether such a timeframe ensures that CMRS providers
have sufficient competitive choices of vendors and time to incorporate, test, and deploy their technology
of choice, and whether setting such a timetable would spur the advancement of vertical location solutions
already in development.
75.
We also seek comment on the potential costs associated with a vertical location
requirement. If a provider were to modify handsets to incorporate barometers in handsets, for example,
what would be the cost per handset? We seek comment on how best to structure a vertical location
accuracy requirement to mitigate potential costs to providers while still ensuring PSAPs obtain useful
vertical location information. We note that our proposed requirement is technology-neutral, and our
proposed approach affords providers with the flexibility to choose the most cost-effective means of
integrating vertical location technology into their networks.
76.
We also seek comment on whether PSAPs are ready to make use of z-axis location
information. In recent testimony before the Senate Commerce Committee, NENA stated that the existing
location databases have data fields capable of capturing other location elements, such as z-axis
readings. NENA opined that many PSAPs are prepared to accept an extended range of data, once the
provider has the capability to capture such data.153 We note that elevation and floor level information

148 The average floor height of a multi-story building floor is 3.1 meters in residential buildings, 3.9 meters in office
buildings, and 3.5 meters in mixed-use settings. See Height Calculator. By proposing a 3-meter requirement, first
responders would be able to determine the likely floor level of the 911 caller. As mentioned earlier, if there is
vertical location information on the caller of greater than 6.2 meters, then it is reasonable to assume multiple levels,
which are primarily indoor environments, and that the call is therefore originating from indoors.
149 We therefore intend to tighten these z-axis accuracy parameters for long-term implementation, as discussed
below in Section III.C.
150 CommScope Further Notice Comments at 6.
151 In the CSRIC test bed, NextNav was able to locate a caller’s vertical location within 3 meters more than 67
percent of the time in dense urban, urban, and rural morphologies. See CSRIC Indoor Location Test Bed Report at
36. NextNav conducted additional testing on the second generation of its location technology and reported
improvements in both horizontal and vertical location accuracy. It provided callers’ vertical location within 3.2
meters 80 percent of the time, across all morphologies. See NextNav Aug. 14, 2013 Ex Parte Letter at 3-11.
152 See Polaris Wireless, Inc. Comments, PS Docket No. 07-114 (filed Sept. 25, 2013), at 3 (Polaris Workshop
Comments) (estimating “that the vertical location accuracy performance of its system should achieve floor-level
precision across all indoor environments in the 3-5 year timeframe”). We discuss the appropriate implementation
timeframe for z-axis location capabilities in the discussion below.
153 See U.S. Senate Committee on Commerce, Science, and Transportation, Subcommittee on Communications,
Technology, and the Internet Hearing, “Locating 911 Callers in a Wireless World,” Jan. 16, 2014, available
at
http://www.commerce.senate.gov/public/index.cfm?p=Hearings&ContentRecord_id=c8765be1-6155-459f-8ca7-
7e9e557e84b5&ContentType_id=14f995b9-dfa5-407a-9d35-56cc7152a7ed&Group_id=b06c39af-e033-4cba-9221-
de668ca1978a (last visited Jan. 28, 2014) (E911 Location Accuracy Senate Hearing).
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have been an optional component of ALI standards for several years.154 Polaris Wireless, however, notes
that “PSAP call takers must be able to visualize vertical location information in computer-aided design
(‘CAD’) or other display formats in order to dispatch personnel to the correct place” and that “significant
challenges lie ahead in designing and upgrading public safety equipment, databases, and procedures in
preparing for future availability of vertical information.”155 In addition, NextNav states that “many
PSAPs are not presently prepared to fully utilize Z-axis data in the emergency dispatch process because
they do not have accurate mapping systems to convert Z-axis data into floor-level dispatchable
information.”156 To the extent that PSAPs must take additional measures to be capable of receiving z-axis
information, we seek comment on what steps must be taken and any corresponding costs, as well as the
timeframe in which these steps reasonably could be completed.
77.
Timeframe. We seek comment on a reasonable timeframe for provision of vertical (z-
axis) information. We recognize that the development of vertical location technology, the incorporation
of these capabilities into a sufficient number of consumer handsets, and the development of any necessary
industry standards, may take additional time. We therefore propose that CMRS providers must deliver z-
axis information for 67 percent of calls within a three-year timeframe and for 80 percent of calls within a
five-year timeframe. We seek comment on whether this would afford a sufficient implementation period.
We seek comment on any necessary developments that must take place in order for the delivery of z-axis
information would be feasible.
78.
Commenters should explain what the path to implementation of a z-axis requirement
would look like, including specific steps and corresponding timeframe estimates. We note that only one
vendor participating in CSRIC’s indoor location accuracy test bed provided location information with a z-
axis component.157 In this regard, CSRIC states that, “even the best location technologies tested have not
proven the ability to consistently identify the specific building and floor, which represents the required
performance to meet Public Safety’s expressed needs. This is not likely to change over the next 12-24
months.”158 Several commenters also argue that vertical location technology is not yet sufficiently
developed or widely enough available to reasonably require providers to support this capability at
present.159

154 NENA, Standard Data Formats for 9-1-1 Data Exchange & GIS Mapping, Version 9 (Mar. 28, 2011), at 86,
available at http://c.ymcdn.com/sites/www.nena.org/resource/collection/C74A8084-E3BD-405D-93C2-
48AFCFA5B490/NENA_02-010-v9_Data_Formats_for_ALI_MSAG_GIS.pdf (last visited Feb.3, 2014).
155 Polaris Workshop Comments at 8.
156 See Letter from Bruce A. Olcott, Counsel to NextNav, LLC, to Marlene H. Dortch, Secretary, FCC, PS Docket
No. 07-114 (filed Nov. 26, 2013), at 4 (NextNav Nov. 26, 2013 Ex Parte Letter), citing the remarks of John Snapp,
Senior Technical Officer and Vice President, Intrado, at FCC E911 Phase II Location Accuracy Workshop, at
minute 146, available at http://www.fcc.gov/events/workshop-e911-phase-ii-location-accuracy (last visited Dec. 20,
2013). NextNav notes that “[t]he question of how Z-axis information is ultimately implemented into PSAPs,
however, need not delay the adoption of vertical accuracy rules because such information can be useful to first
responders with or without accompanying mapping systems.” NextNav Nov. 26, 2013 Ex Parte Letter at 5
157 See CSRIC Indoor Location Test Bed Report at 36, 39.
158 See id. at 54-55.
159 See, e.g., AT&T Workshop Comments at 6 (stating that “considerable work remains” with respect to vertical
location accuracy data, and that while A-GPS can provide an estimate of above-sea-level altitude, “there is still a lot
of variability in this data and, without the appropriate context about the environment, that data will be all but useless
to public safety”); CTIA Workshop Comments at 9 (“[E]ven the best location technologies tested have not proven
the ability to consistently identify the specific building and floor, which represents the required performance to meet
Public Safety's expressed needs.”) (citing CSRIC Indoor Location Test Bed Report at 54-55); TruePosition
Workshop Comments at 6 (stating that “[c]urrent technologies do not yet support the Z-axis”); T-Mobile Workshop
Comments at 31 (stating that “[n]o currently available technology can provide accurate vertical location”).
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79.
At the same time, however, based on the CSRIC test bed results and on filings in the
record to date, at least one vendor has developed vertical location technology that already can locate
callers to a more granular degree than what we propose here,160 and others estimate having similar
granular capabilities within three to five years.161 In addition, nearly all smartphones are now equipped
with sensors that can determine speed, compass direction, and movement.162 Thus, many devices can
now gauge direction, turns, speed, and height above sea level, and thereby generate a three-dimensional
view of the user’s location.163 We believe that this trend will continue.164 We seek comment on these
developments, and how these trends should affect the ability of CMRS providers to provide z-axis
information for 67 percent of calls within three years and 80 percent of calls within five years. As
discussed above, we also seek comment on whether test bed certification should serve as a triggering date
rather than the effective date of the adoption of rules.165 Alternatively, if the timeline is triggered by the
adoption of rules, should the Commission consider reevaluating the compliance timeline at some interim
point to evaluate the status of testing of location technology?
80.
Finally, we seek comment on the timeframe in which a significant fraction of PSAPs
would be capable of receiving and processing z-axis information, and how that should impact the
timeframe in which a z-axis requirement could reasonably be imposed on CMRS providers, or whether
PSAPs are ready to accept z-axis information today.166 In addition, we seek comment on any technical,
operational, manufacturing, or other issues that may impact CMRS providers’ ability to implement the
proposed requirement in the near future.
3.

Implementation Issues

a.

Compliance Testing for Indoor Location Accuracy Requirements

81.
Background. As noted above, our current Phase II location accuracy rules contain no
requirement for testing compliance with the standards or for reporting the results thereof. Despite the
acknowledged difficulties with indoor testing, the International Association of Chiefs of Police suggested
that the Commission nevertheless formulate a testing regime that requires periodic indoor testing to verify

160 NextNav was able to locate a caller’s vertical location within 3 meters more than 67 percent of the time. See
CSRIC Indoor Location Test Bed Report
at 42. NextNav conducted additional testing on the second generation of
its location technology and reported improvements in both horizontal and vertical location accuracy. See Letter
from Bruce A. Olcott, Counsel, NextNav, LLC, to Marlene H. Dortch, Secretary, FCC, PS Docket No. 07-114 (filed
Aug. 14, 2013) at 3-11 (NextNav Aug. 14, 2013 Ex Parte Letter).
161 See Polaris Workshop Comments at 3 (estimating that its vertical location accuracy performance “should achieve
floor-level precision across all indoor environments in the 3-5 year timeframe”).
162 Lawson, Stephen, “Ten Ways your Smartphone Knows Where You Are,” PC WORLD, Apr. 6, 2012, available at
http://www.pcworld.com/article/253354/ten_ways_your_smartphone_knows_where_you_are.html (last visited Feb.
3, 2014).
163 The measurement of turns is distinct from compass direction. For example, if a device makes a 180-degree turn,
this could mean from north to south or east to west. To further illustrate, one vertical location experiment used the
frequency of 180-degree turns made by the device to count the landings between and at floor heights to estimate the
device’s vertical location. See Schulzrinne, et al., “Improving the Vertical Accuracy of Indoor Positioning for
Emergency Communication,” Columbia University Computer Science Technical Reports (Oct. 30, 2012) at 4,
available at http://academiccommons.columbia.edu/catalog/ac:154021 (last visited Feb. 3, 2014) (Vertical Accuracy
Technical Report
).
164 See, e.g., Clarke, Peter, “MEMS in Mobiles to be $6B Market,” EE TIMES, July 30, 2013, available at
http://www.eetimes.com/document.asp?doc_id=1319091 (last visited Feb. 3, 2014).
165 See supra Section III.B.1 at paras. 60-61.
166 See supra Section III.B.2 at paras. 70-71 (seeking comment on PSAP readiness to use z-axis information).
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compliance.167 NENA agreed that it “is incumbent upon the Commission to establish a testing regime
under which such technologies can be evaluated with an eye toward improving access to accurate indoor
location information for the public and the public safety community.”168 APCO concurred, stating that
“[c]ompliance testing [including indoor testing] must also be repeated within a reasonable time frame.”169
Location technology vendors also supported indoor location testing.170 Many commenters also urged the
Commission to consider the standard developed by ATIS (ATIS-0500013), in collaboration with public
safety entities, to assess the performance of indoor wireless location technologies.171
82.
As discussed above, the Commission referred the indoor testing issue to CSRIC for
further development of technical recommendations.172 In response, WG3 developed a test bed, in
conjunction with ATIS/ESIF, to “determine actual performance levels in various real-world conditions,
representative of indoor environments across the country.”173 The test bed used the San Francisco Bay
area, which provided “a sufficient diversity of points in close enough proximity” to allow a single team to
be deployed, rather than multiple teams to different geographic regions.174 In each morphology (or broad
wireless use environment), WG3 identified a number of buildings of different sizes and types and selected
test points in each building to represent the range of conditions encountered within that structure. The
number of test points in a given building depended on its size and complexity. At each test point, a
statistically significant number of independent test calls were placed.175
83.
The test bed participants selected a third-party testing house through a competitive RFI
process.176 According to WG3, the capability and credibility of this test house were key factors in the
success of the test bed.177 Only summary data was made available to all other parties.178 An oversight
committee composed of a group of stakeholder interests was included, so that all stakeholders’ views
received a hearing and due weight.179 Participating vendors and wireless operators jointly funded the

167 See IACP Second Further Notice Comments at 1.
168 See NENA Second Further Notice Comments at 14.
169 See APCO Further Notice Comments at 4.
170 See TruePosition Reply Comments, PS Docket No. 07-114 (filed Nov. 2, 2011), at 11 (TruePosition Second
Further Notice Reply Comments); Commlabs Second Further Notice Comments at 17.
171 See, e.g., APCO Second Further Notice Comments at 8; CTIA Second Further Notice Comments at 3;
SouthernLINC Second Further Notice Reply Comments at 10; Qualcomm Second Further Notice Comments at 11.
See also
“Approaches to Wireless E9-1-1 Indoor Location Performance Testing,” ATIS Technical Report
0500013. This ATIS standard, as well as other ATIS standards discussed in this proceeding, will be available for
review and download on the ATIS website during the pendency of the period for filing comments. See
http://www.atis.org/fcc/locationaccuracy.asp (last visited Feb. 14, 2014). Paper copies will also be available for
review (but not photocopying) at Commission headquarters upon request by contacting Dana Zelman at 202-418-
0546 or dana.zelman@fcc.gov. To request materials in accessible formats for people with disabilities (braille, large
print, electronic flies, audio format), send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental
Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (TTY).
172 See supra Section II.B; see also E911 Location Accuracy Second Further Notice, 26 FCC Rcd at 10104 ¶ 88.
173 See CSRIC LBS Report at 57.
174 See CSRIC Indoor Location Test Bed Report at 11.
175 See id. at 12.
176 See id. at 11.
177 See id. at 47.
178 See id. at 46; 11-12. WG3 noted that protecting proprietary information was a key to making the test work. See
CSRIC Indoor Location Test Bed Report
at 46.
179 See id. at 48.
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testing process to ensure no one party had excessive influence over the testing process.180
84.
Discussion. We believe that 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 propose 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. Specifically, we propose a rule requiring CMRS providers to participate in an
independently administered test bed program that is representative of real-life call scenarios and that
includes, but is not limited to, the following testing components:
 Testing in representative indoor environments based on standards adopted by an industry
standards body group;
 Testing for the following performance attributes: location accuracy, latency (Time to First Fix),
and reliability (yield)181;
 Requiring 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.
As an alternative, however, we also propose that CMRS providers may use other testing methods that
may better suit their particular business plans or practices. In order to maintain the same level of test
result reliability, however, CMRS providers must demonstrate that their alternative methodology and
testing procedures are at least equivalent to the testing methodology and procedural standards used in the
independently administered indoor location accuracy test bed. In using alternative testing methods,
CMRS providers would need to provide the same information about the location technologies’
effectiveness, and also show that the indoor location technology used in the test bed is the same
technology deployed in their network.
85.
Certification under either the proposed test bed or an alternative test methodology (of
equivalent reliability) would provide a safe harbor to demonstrate that the CMRS provider meets the
indoor location accuracy requirement Under our safe harbor proposal, a technology that meets the
location requirements in the test bed, upon certification by the CMRS provider that it 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. We seek comment on the practical effect of this safe harbor. What
factual showing would be necessary to overcome the presumption of compliance? If a compliance issue
arises that overcomes the presumption, should we afford the provider an opportunity to resolve the issue
before considering initiation of enforcement action? If the provider can demonstrate that it is using best
efforts to meet the accuracy requirements, but is prevented from doing so by circumstances beyond its
control, should we limit the scope of potential enforcement activity? We seek comment on these issues.
(i)

Test Bed Methodology

86.
We propose that CMRS providers may demonstrate compliance with indoor location
accuracy requirements by participating in an independently administered test bed program. Certification
by the test bed administrator would provide CMRS providers a “safe harbor” that they meet any indoor
accuracy requirements we may adopt in this proceeding. As part of the test bed participation, CMRS

180 See id. at 11.
181 As discussed earlier, we propose to require CMRS providers to meet a 67/80 percent reliability standard for
indoor calls. In the indoor location test bed, CSRIC measured “yield” as the number of calls that delivered location
information as compared to the number of completed calls. In the discussion below, we propose a definition for
yield for the purpose of determining whether a technology, as tested in the test bed, meets our proposed reliability
standard.
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providers must show that the indoor location technology used in the test bed is the same technology
deployed in their networks, with similar parameters, such as beacon or cell tower density and topology.
We believe that such an independently administered program would provide an objective platform for
testing the accuracy of the provider’s chosen indoor location technology in a variety of representative
indoor environments and building types, without requiring ubiquitous in-building testing, and that such an
approach would mitigate the potential costs of compliance testing.
87.
Based on the record and the methodology used by WG3 for its test bed, we propose
certain minimal test bed requirements. Specifically, the test bed must (1) include testing in representative
indoor environments; (2) test for certain performance attributes (discussed in greater detail below); 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. We discuss each of these proposed
requirements below. We also seek comment on which aspects of the testing process – administrative,
technical, and operational – should be set forth in our rules and which are better left to the discretion of
the test bed administrator.
88.
Representative Environment. First, we propose that the test bed should reflect, to the
extent possible, a representative sampling of the different real world environments in which CMRS
providers will be required to deliver indoor location information. We seek comment on whether, by
doing so, the test bed could provide reliable information about how location technologies perform in
different circumstances, without necessitating ubiquitous testing in real-world environments. Both WG3
and commenters note that the industry standards body group, ATIS, has adopted indoor testing standards
incorporating representative test environments rather than ubiquitous testing.182 The CSRIC WG3 test
bed used dense urban, urban, suburban and rural morphologies, as defined by the ATIS-0500013
standard.183 We seek comment on whether these morphologies are sufficiently representative and
inclusive of the variety of indoor environments in which wireless 911 calls are made, or whether there are
different environments that should be included.
89.
Performance Attributes. We propose that any location accuracy test bed must evaluate a
CMRS provider’s choice of location accuracy technology in light of several key performance
requirements: location accuracy, latency (TTFF), and reliability (yield). For purposes of determining
compliance with the location accuracy and TTFF requirements, we propose to follow the methodology
used by WG3 in its test bed. For location accuracy, the CSRIC test bed computed “the error in estimating
the location of the device under test … by comparing each vendor’s reported horizontal position … to the
surveyed ground truth position of the test location (determined through a precise land survey).”184
Further, “[e]ach test call (or equivalent) was assumed to be independent from prior calls and accuracy was
based on the first location delivered by the vendor after ‘call initiation.’”185 With regard to latency, the
CSRIC test bed calculated TTFF by “establishing the precise time for call initiation (or an equivalent
initiation event if the vendor’s test configuration did not support the placement of an emulated emergency

182 See CSRIC Indoor Location Test Bed Report at 11, 12. See also ATIS Second Further Notice Comments at 6
(“This industry standard recommends the testing of representative samples of indoor environments”); Commlabs
Reply Comments, PS Docket 07-114 at 7 (filed Nov. 2, 2011) (“Alliance for Telecommunications Industry
Solutions … recommended in its comments that, rather than require wide scale indoor testing, verification should be
conducted through “testing of representative samples of indoor environments”) (Commlabs Second Further Notice
Reply Comments).
183 See CSRIC LBS Report at 57; CSRIC Indoor Location Test Bed Report at 12.
184 CSRIC Indoor Location Test Bed Report at 14.
185 Id. at 14.
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test call).”186 More specifically, we propose to measure latency “from the time the user presses SEND
after dialing 9-1-1, to the time the location fix appears at the [location information center].”187
90.
We propose that providers measure yield in the test bed for purposes of testing whether a
location technology satisfies that proposed reliability requirement. 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.”188 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 WG3 encountered in testing indoor locations,
we propose a modified definition of yield for purposes of determining compliance with the proposed 67
and 80 percent reliability requirements in the test bed. We therefore suggest that the yield percentage 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. We propose to exclude calls that are dropped or otherwise disconnected in 10 seconds or less,
for which providers do not get a Phase II fix, from calculation of the yield percentage (both the
denominator and numerator).189 We seek comment on this proposed calculation of yield.
91.
For purposes of assessing yield, we propose that CMRS providers should satisfy the 67
and 80 percent reliability requirements 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. We believe
this approach is consistent with our proposal that providers must satisfy the location accuracy requirement
at the PSAP- or county-level. We seek comment on this approach.
92.
Finally, we seek comment on whether the foregoing metrics are sufficient for assessing
each performance requirement and our proposed indoor location requirements as a whole. What other
performance requirements, if any, should we require to determine compliance with our proposed location
accuracy requirements?
93.
Testing to Emulate Actual Network Deployment. We propose that a CMRS provider must
show both (1) that the indoor location technology used for purposes of its compliance testing is the same
technology that will be deployed in its network, and (2) that this technology is being tested as it will
actually be deployed in the CMRS provider’s network. The CSRIC test bed tested both commercially
available technologies as well as new and emerging technologies. Accordingly, two of the three
participating vendors could not test their technology as it would be deployed in a provider’s network to
provide an end-to-end E911 location solution.190 For this reason, technical performance in the test bed

186 Id. at 14. We note that, in its location-based services report, CSRIC states that “[t]he ideal definition [for TTFF]
would be to measure from the time the user presses SEND after dialing 9-1-1, to the time the location fix appears at
the MPC.” See CSRIC LBS Report at 8.
187 CSRIC LBS Report at 8.
188 CSRIC Indoor Location Test Bed Report at 14.
189 Several commenters indicate that TTFF is presently often less than 30 seconds. See, e.g., Letter from Nneka
Chiazor, Executive Director, Federal Regulatory Affairs. Verizon, to Marlene H. Dortch, Secretary, FCC, PS Docket
No. 07-114 (filed Dec. 19, 2013), at 1 (Verizon has taken “steps … to improve the location information delivered to
PSAPs,” such as “[m]aking caller location information available within an average of 12-15 seconds, and within 25
seconds for 99 percent of all calls for which the information is available”); TruePosition Comments, PS Docket No.
07-114 (filed Aug. 6, 2013), at 22 (test results demonstrate that AGPS/UTDOA and Terrestrial Beacons solutions
exceeded the FCC’s current outdoor requirements for network-based positioning solutions … with UTDOA
producing an overall average TTFF of approximately four (4) seconds and Terrestrial beacons producing an overall
average TTFF of approximately 27 seconds”).
190 Qualcomm’s AGPS/AFLT technology was tested fully in the wireless network. See CSRIC Indoor Location Test
Bed Report
at 25. However, CSRIC tested Polaris’ RF pattern matching technology “off-line” because “the Polaris
(continued….)
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was necessarily different than what could be achieved in an actual production implementation.191 We
seek comment on our proposal to require testing of the indoor location technology to be used as it will
actually be deployed in CMRS provider’s network. Moreover, we seek comment on the feasibility of
establishing a test bed that addresses our concerns that any compliance test bed provide a close simulation
of real-world indoor calling scenarios. Are there factors such as beacon or cell tower density and
topology that may cause the test bed results to differ materially from performance for actual 911 calls
outside the test bed? Should the test bed be constrained to a small geographic area, similar to the CSRIC
IV example, or should the selection of test points change periodically or cover a larger geographic area?
94.
Test Bed Approach. In order to accommodate a technology-neutral approach and to
encourage advancements in indoor location technology, as well as to avoid the costs of unnecessary
testing requirements in a given situation, we think it appropriate to allow for some flexibility in
compliance testing procedures. For this reason, we propose allowing the indoor test bed administrator
sufficient discretion to determine the actual test approaches to be used, e.g., the number of test points,
number of test calls, and the best combination of devices to test simultaneously per technology.192 We
seek comment on this proposal.
95.
Test Bed Administration. WG3 indicated that a competent and reliable administration is
necessary in order to establish and operate an effective test bed.193 There are multiple administrative
issues inherent in setting up any test bed for purposes of compliance testing, including (1) selecting an
independent test bed administrator; (2) establishing a test bed funding mechanism; (3) finding an
acceptable third-party test house or houses; (4) establishing and maintaining the test bed, including
maintenance of any data and data confidentiality, and (5) establishing and administering a certification
process for CMRS providers to demonstrate compliance with the Commission’s indoor location accuracy
requirements. We seek comment on these views and on whether there are any other such administration
issues that we should consider.
96.
The Commission recently renewed the CSRIC charter for an additional two years,194
asking CSRIC IV WG1 to examine many of the foregoing issues.195 Its report on these issues is due in
(Continued from previous page)
position computing platforms were not integrated into the AT&T or T-Mobile networks serving the Bay Area.” See
CSRIC Indoor Location Test Bed Report
at 25. CSRIC also did not test NextNav’s beacon location technology in a
wireless provider network because it was not commercially available at the time. Instead, it was tested by use of
standalone receivers that received the beacon signals in order to compute their location. See CSRIC Indoor Location
Test Bed Report
at 24, 41, and 54.
191 See CSRIC Indoor Location Test Bed Report at 54 (CSRIC reported, “[i]n some cases determination of the
position estimate (position calculation function) for test bed effort was computed in non-real time, using non-
standardized signaling methods independent of the wireless carrier network [leading to d]ifferences in technical
performance resulting from these deviations, relative to an actual production implementation.”).
192 See CSRIC Indoor Location Test Bed Report at 12-13.
193 See id. at 48 (“oversight was necessary … to sponsor the [test bed] activity and handle the logistics of getting the
work done”). See also 2013 CSRIC III Location-Based Services Report at 60 (“a test bed management structure
with contractual authority that extends beyond [CSRIC] cycles will encourage ongoing technology development”).
194 See FCC Announces Membership of the Communications Security, Reliability, and Interoperability Council,
Public Notice, 28 FCC Rcd 6904 (rel. May 16, 2013) (announcing that the Commission renewed the CSRIC charter
through Mar. 18, 2015).
195 See CSRIC IV Working Group Leadership and Descriptions at 2 (“Working Group 1 – NG911, Tasking 3”),
available at http://www.fcc.gov/pshs/advisory/csric4/wg_descriptions.pdf (last visited Feb. 3, 2014) (Under the
charter, CSRIC IV WG1 will: “[E]xamine the requirements to establish a permanent entity to design, develop, and
manage an ongoing public test bed for indoor location technologies that can provide the FCC with regular
comprehensive, unbiased and actionable data on the efficacy of location technologies. The Working Group will
consider chartering requirements, including prerequisites for impartial test bed administration and maintenance of
(continued….)
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June 2014.196 While CSRIC IV WG1 is not considering requirements for the establishment and
administration of an ongoing test bed for the specific purpose of assessing compliance with location
accuracy requirements, we expect that its recommendations will be informative. As such, we direct the
Bureau to seek further comment on them in this proceeding. These comments should address whether the
test bed being developed by CSRIC IV WG1 would be sufficient for the purpose of compliance testing
for indoor location accuracy.
97.
We also note that the test bed CSRIC IV WG1 is developing would not include a
certification component. Is such a certification requirement necessary or appropriate? Are there other
Commission compliance regimes (such as for equipment authorizations pursuant to part 2 of our rules)
that may serve as appropriate models? We seek comment on how any compliance certification process
should work for the indoor location accuracy compliance test bed. We also ask commenters to provide us
with cost estimates for the certification component of the indoor location accuracy compliance test bed.
(ii)

Alternative Testing Methods

98.
As an alternative to the test bed method outlined above, we propose to allow CMRS
providers to demonstrate compliance with our indoor location accuracy requirements through alternative
means. We believe this would serve the public interest by allowing CMRS providers the flexibility to test
their indoor location accuracy solution in a manner that suits their particular business needs while, at the
same time, maintaining the same level of test result reliability. We also propose that CMRS providers
could combine resources to develop their own test methodology. We propose, however, that CMRS
providers choosing an alternative approach must demonstrate in any certification requirement that their
methodology and testing procedures are at least equivalent to the rigor and standards used in the
independent location accuracy test bed approach discussed above. Thus, they would have to provide the
same information about the technologies’ effectiveness and also show that the indoor location technology
used in the test bed is the same technology deployed in their network.
99.
What is the feasibility of allowing CMRS providers to develop such an alternative
mechanism for testing indoor location accuracy? For example, how should the Commission determine
whether CMRS providers choosing to forego the test bed have demonstrated that their methodology and
testing procedures are at least equivalent to the rigor and standards used in the test bed approach
discussed above? Should we require providers electing to use an alternative testing approach to file their
proposed approach with the Commission in advance, in order to allow us to review their proposed
methodology? What further requirements, if any, are appropriate and necessary to ensure that a provider
using an alternative testing approach is satisfying our accuracy requirements? Finally, should the
Commission leave it to the industry to determine whether and how to establish any jointly used program
in order to save costs?
(iii)

Test Frequency

100.
We seek comment regarding the extent to which CMRS providers should be required to
re-test the accuracy of their indoor location technologies. For example, as CMRS providers make
material upgrades to their networks and handsets to incorporate new or updated system and location
technologies, further testing might be appropriate to show that the system continues to satisfy any indoor
(Continued from previous page)
data confidentiality; types of entities that could assume the role as test bed administrators; technical requirements;
scope and scale of necessary facilities and locations; permanent or contracted human resources to manage the test
bed; start-up and ongoing cost requirements to maintain the test bed on an ongoing basis; and other considerations
necessary to establishing an independent testing administrator.”).
196 See CSRIC, Working Group #1: NG911 (Dec. 4, 2013), available at
http://transition.fcc.gov/bureaus/pshs/advisory/csric4/CSRIC_IV_WG1_STATUS_120413.pdf (last visited Feb. 3,
2014).
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location accuracy requirements.197 What types of changes would be substantive enough to warrant re-
testing? Alternatively, should we require periodic re-testing, regardless of whether a provider has made
any significant updates to its network?198 We also seek comment on any alternative methods that might
best ensure that indoor location technologies continue to comply with our requirements.
(iv)

Confidentiality of Test Results

101.
Under the WG3 test bed regime, all parties agreed that raw results would be made
available only to the vendors whose technology was to be tested, participating wireless providers, and the
third-party testing house.199 In order to protect vendors’ proprietary information, only summary data was
made available to all other parties.200 Should these restrictions be carried forward to the proposed indoor
location accuracy test regime? Or should some or all test data also be made available to the Commission,
or to requesting PSAPs and other 911 authorities? We note that APCO states that “test results need to be
shared with relevant PSAPs,” and that “PSAPs may also want to conduct independent tests to verify
accuracy data.”201 Moreover, given the extent to which mobile wireless communications services are
becoming increasingly central to the day-to-day lives of Americans, should this data also be available, at
least to some extent, to the public? Can and should the Commission’s location accuracy requirements and
enforcement of compliance therewith preempt any state or local determinations to the contrary, absent
agreements between CMRS providers and PSAPs for more stringent requirements?
(v)

Cost/Benefit Analysis

102.
We also seek comment on the costs and benefits of all of our proposed compliance
testing measures, as well as on additional ways to reduce the costs of compliance testing, without
adversely impacting the reliability and accuracy of the test results. CSRIC reported that the 2013 test bed
cost approximately $240,000.202 We anticipate that the costs of the proposed indoor test bed program
may exceed that amount for several reasons. CSRIC noted that its test bed costs were for only the limited
San Francisco Bay area, tested with a limited number of test points.203 If a single test bed remains
sufficient for determining compliance with our indoor location accuracy requirements, we anticipate that
costs will not increase substantially in this regard. However, larger or additional test beds may be
necessary for purposes of compliance testing, which would increase costs. A larger number of test points
and the participation of more CMRS providers and location technology vendors could also increase
costs.204 Further, CSRIC noted that, in some instances, the test bed process did not include testing “the
end-to-end E911 solution as it would be deployed in a carrier’s network,”205 which may increase costs.
103.
Nevertheless, we believe that the broader test bed approach proposed here, based on

197 See CSRIC LBS Report at 60 (“Location technologies continue to evolve and new technologies continue to
emerge. … New technologies, or significant updates to existing technologies, will require future rounds of test bed
characterization.”).
198 See also infra Section IV.G (on outdoor periodic testing).
199 See CSRIC Indoor Location Test Bed Report at 12.
200 See Presentation by CSRIC WG3, Indoor Location Accuracy – Test Bed Framework (Sept. 12, 2012), at 6,
available at http://transition.fcc.gov/pshs/advisory/csric3/3-WG%20Presentation%209-12-12.pdf (last visited Feb.
19, 2014) (noting agreement reached among test bed participants that CMRS providers could only view raw results
if they signed a nondisclosure agreement); see also CSRIC Indoor Location Test Bed Report at 12.
201 See APCO Further Notice Comments at 4.
202 See CSRIC Indoor Location Test Bed Report at 52.
203 Id.
204 Id.
205 Id. at 54.
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testing in representative environments, is likely to cost significantly less than ubiquitous in-building
testing. Both the record and CSRIC’s report indicate that ubiquitous in-building testing is likely to be
both costly and impractical due to security and permission issues that make it difficult to access private
buildings.206 Based on CSRIC’s recommendation to test in representative environments and on initial
CMRS industry comments supporting CSRIC’s and standards body processes,207 we find that, by
avoiding the need for ubiquitous testing, our proposed test bed process would significantly lower costs.
Moreover, it would reduce the costs of participation by CMRS providers, by providing them the
opportunity to share costs for the test bed. We also propose that CMRS providers may choose an
alternative testing means. This may afford a way for CMRS providers to test their indoor location
technology in a more cost-effective manner, depending upon their particular business plans. We seek
specific cost data, where available, and comment on all of the foregoing, and any other, factors related to
the implementation costs of an indoor location accuracy compliance test bed.
b.

Applicability of Indoor Location Accuracy Requirements

104.
We propose to apply the indoor location accuracy requirements on a nationwide-basis,
across all geographic areas. As noted earlier, one of our key objectives is to make indoor location as
widely available as is technologically and economically feasible. While we recognize that certain indoor
environments are more likely to present challenges in identifying a caller’s location, other indoor
environments may not present greater challenges than outdoor environments. Based on the CSRIC test
bed results, as well as additional information regarding the ability of location-based technologies to
perform indoors, we believe that existing location-based technology is sufficient to identify a caller’s
location in a number of indoor environments already, and that providers might be capable of satisfying
indoor location requirements nationwide within a reasonable period of time.208 CMRS providers also
confirm that A-GPS technology works well in most indoor locations,209 and U.S. Census data suggests
that the majority of indoor environments are likely to be the types of structures that are suitable for A-
GPS location-based solutions.210 A 2011 peer-reviewed journal article, which presented the results of a
study evaluating the ability of GPS- and A-GPS-enabled mobile phones to identify reference locations
with known coordinates in an indoor two-story structure, found that “whenever a valid GPS position fix

206 See supra Section II.A.; CSRIC Indoor Location Test Bed Report at 49-50, 52.
207 See supra Section II.B.
208 The CSRIC test bed study indicates more generally that “[o]utstanding GPS performance, almost as good as
outdoors, can be achieved inside single story homes.” CSRIC Indoor Location Test Bed Report at 31. The report
further notes that “[a]lmost as good performance is achieved inside the upper floor of relatively small building with
composite or tile roof material.” Id.
209 See, e.g., Letter from John Nakahata, Counsel to T-Mobile USA, Inc., to Marlene H. Dortch, Secretary, FCC
(filed Nov. 16, 2013), at 1 (“If three quarters of wireless 911 calls are placed from indoors, … then at least two-
thirds of all of T-Mobile’s indoor UMTS 911 calls of more than 30 seconds in length are getting position fixes based
on A-GPS”); Letter from Nneka Ezenwa Chiazor, Executive Director, Federal Regulatory Affairs, Verizon, to
Marlene H. Dortch, Secretary, FCC (filed Nov. 14, 2013), at 2, n. 7 (“Phase II … was available for … 93 percent of
[Verizon] indoor calls,” citing King County, Washington data). See also Letter, George Rice, Jr., Executive
Director, iCERT, to Marlene H. Dortch, Secretary, FCC (filed Sept. 25, 2013), at 5 (“data provided by Verizon
Wireless demonstrates a high Phase II yield (91-95%) for all wireless 9-1-1 calls including those from indoor
locations”).
210 A recent study released by the United States Census Bureau indicates that during the years 2009-2011
approximately 61 percent of all housing units in the United States were single-family, detached homes. See Mazur,
Christopher, “Physical Characteristics of Housing: 2009-11” (Apr. 2013), available at
http://www.census.gov/prod/2013pubs/acsbr11-20.pdf (last visited Feb. 3, 2014) (Census Bureau Housing Study).
Another 5.8 percent were single-family homes attached to other structures, usually other homes. Id. at 1. During
the same period, units in buildings with two to four apartments comprised 9.1 percent of housing inventory, while
mobile homes constituted another 6.5 percent. Id.
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was obtained, the maximum positional error never exceeded 100 [meters], even when considering the
indoor tests.211 We anticipate that additional improvements in location technologies since that time,
together with advancements that will take place over the new few years, will reduce this potential for
error even further. For example, additional global navigation satellite systems are being deployed or
activated, such as GLONASS, Galileo and Compass.
105.
Given the ability of A-GPS to perform well across a large number of indoor
environments, together with the fact that the majority of CMRS providers are already using handset-
based, A-GPS solutions,212 we believe that only a limited number of environments would require
additional infrastructure in order for CMRS providers to comply with our proposed indoor accuracy
requirements. We therefore believe that indoor location across all areas is technologically feasible, as
well as economically reasonable. We seek comment on this analysis.
106.
Alternatively, we ask whether we should apply our proposed indoor location accuracy
requirement in a more targeted fashion, and if so, how? For example, would it be more effective to phase
in application of the indoor location accuracy requirements, by first focusing on areas throughout the
nation with the largest volume of indoor calls? If so, should we limit the application of our horizontal
indoor location accuracy requirements to urban areas? The Census Bureau defines “urban” as “[c]ore
census block groups or blocks that have a population density of at least 1,000 people per square mile (386
per square kilometer) and surrounding census blocks that have an overall density of at least 500 people
per square mile (193 per square kilometer).”213 ATIS also provides definitions of “urban” and “dense
urban” areas.214 We seek comment on whether the Census Bureau or ATIS definitions would provide a
useful basis for defining and focusing the application of indoor location requirements.

211 See P. A. Zandbergen and S. J. Barbeau, “Positional Accuracy of Assisted GPS Data from High-Sensitivity GPS-
enabled Mobile Phones,” 64 Journal of Navigation 3, pp. 381-399 (July 2011), at 381, 397. The study evaluated the
ability of the GPS-enabled phones to determine location in a two-story residential structure consisting mostly of
wood and concrete stucco. See id. at 387, 393. The authors note, however, “only a limited set of indoor conditions
were evaluated, reducing the general reliability of the results for indoor positioning. Further research into the
performance of A-GPS under indoor conditions would be very relevant given the FCC requirements for the
performance of mobile phones.” Id. at 398.
212 Verizon Wireless, Sprint, and U.S. Cellular operate on CDMA networks and use handset-based location
technology. AT&T and T-Mobile have historically operated on GSM networks and have used network-based
location technology. However, AT&T announced in 2012 its plans to discontinue service on its 2G/GSM networks,
and it has stated that it is making “a steady migration toward AGPS,” a handset-based location technology.
Furthermore, as of Jan. 31, 2014, “AT&T will be considered a handset-based carrier and will measure compliance
based on the location accuracy associated with handset-based technologies.” See Letter from Joseph P. Marx,
Assistant Vice President, AT&T Services, Inc. to Marlene Dortch, Secretary, FCC (filed Jan. 31, 2014), at 1 (AT&T
Jan. 31, 2014 Ex Parte Letter). See also infra notes 430, 467; Letter from Jamie Tan, Director, Federal Regulatory,
AT&T, to Marlene Dortch, Secretary, FCC, PS Docket No. 07-114 (filed Sept. 9, 2013) at 12 (AT&T Sept. 9, 2013
Ex Parte Letter). T-Mobile stated that it “used U-TDOA for its 2G GSM network (later adding A-GPS capability
for A-GPS-capable handsets), and it migrated to A-GPS for its UMTS/HSPA+ network.” See Letter from John
Nakahata, Counsel to T-Mobile USA, Inc., to Marlene H. Dortch, Secretary, FCC (filed Sept. 25, 2013), at 1.
213 See Urban Criteria for the 2010 Census, 76 Fed. Reg. 53030, 53039 (Aug. 24, 2011), available at
http://www.census.gov/geo/reference/pdfs/fedreg/fedregv76n164.pdf (last visited Feb. 3, 2014) (Urban Criteria
Census 2010).
214 ATIS defines “urban” as an area with “[h]igh population density where multi-story apartment and office
buildings are observed, and with “[h]igh [cell] site concentration due to capacity requirements and high signal
penetration margins are encountered.” See ATIS, Define Topologies & Data Collection Methodology Technical
Report (ATIS-0500011) (2007), at 1 (ATIS Define Topology Report). ATIS defines “dense urban” as areas that are
“typically downtown environments in larger urbanized cities,” where “[u]rban canyons are commonly encountered,”
and “[v]ery high cell site concentration is also observed.” Id.
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107.
As another alternative, we seek comment on whether we should allow certain exclusions
from the indoor location requirements. For example, should we exclude certain geographic areas from
the indoor location requirements and if so, what areas should be excluded and why? What other potential
distinctions might be appropriate? Should, for example, different considerations apply in with respect to
vertical accuracy? Rather than establishing exclusions, should any exclusions be reported on a case-by-
case basis? Our current E911 regulatory framework currently allows providers to file reports noting
certain exclusions, such as areas with dense forestation.215 We also seek comment on how compliance
based on one or more test beds, as discussed above, would affect the definition of areas to exclude. We
also seek comment on whether we should establish any exceptions for smaller wireless providers and, if
so, why. Rather than excluding certain areas from indoor location requirements, would it be more
appropriate to apply a different accuracy threshold (for example, 100 meters instead of 50 meters) in
certain indoor environments?216
108.
As noted above, we anticipate that the z-axis requirement should be applied co-
extensively, in the same geographic areas, with any x- and y-axis indoor requirements. In the alternative,
we seek comment on whether we should apply the z-axis requirement to only a subset of those
environments where we apply the horizontal indoor location requirement, or otherwise apply the z-axis
requirement in a manner that is independent from the application of horizontal indoor location
requirements.
109.
Finally, we seek comment on any other alternative approaches that would enable us to
focus the application of indoor location requirements in the most effective and cost-efficient way
possible. We recognize that the implementation of any indoor location accuracy requirements will
impose costs on CMRS providers, and seek comment on the ways in which any implementation
requirements could be designed to mitigate those costs to the extent possible, without sacrificing our
important public safety objectives. We seek detailed comment on the costs associated with each of the
proposed alternatives. We also seek comment on how we these different approaches may affect smaller
CMRS providers and whether there are particular measures we should take to minimize the potential
burdens on these smaller providers.
c.

County/PSAP-Level Measurements; Enforcement Tied to PSAP
Readiness

110.
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-based or PSAP-based geographic
level.217 We propose to adopt this standard here, and require CMRS providers to satisfy the proposed
indoor location accuracy requirements on a PSAP-level or county-level basis. This geographic
requirement has been in place since 2010,218 and we believe that it continues to provide a sufficient
degree of accuracy to PSAPs in most cases.219 We also believe that extending this requirement to indoor
location accuracy requirements would be most efficient and cost-effective for CMRS providers, by
allowing them to choose which requirement best meets their needs based on individualized factors like

215 See 47 C.F.R. § 20.18(h) (1)(vi) (permitting exclusions for counties or portions of counties where triangulation is
not technically possible); 20.18(h)(2)(iii) (permitting exclusions for heavily forested areas). .
216 See 47 C.F.R. §20.18(h)(i).
217 See 47 C.F.R. §20.18(h).
218 E911 Location Accuracy Second Report and Order, 25 FCC Rcd at 18913-20 ¶¶ 12-29.
219 As noted in the E911 Location Accuracy Second Report and Order, the county-based compliance standard
conforms to PSAPs’ recent consolidation efforts to mirror county boundaries. Id. at 18915 ¶ 16. Moreover, where
PSAP service areas either exceed or are smaller than county boundaries, allowing a PSAP service area-based
compliance standard allows the reported accuracy to match the exact boundary of the PSAP’s service area. Id. at ¶
17.
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natural and network topographies.220 We recognize, 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
proposed above.221 We seek comment on this proposal.
111.
We intend that CMRS providers’ investment in and deployment of improved indoor
location capabilities are targeted towards those PSAPs or counties that are capable of utilizing this
location information. In this regard, PSAPs would be entitled to seek Commission enforcement of these
requirements within their jurisdictions,222 but as a precondition 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.223 In this manner, we also intend to ensure
we receive consistent and reliable E911 call tracking data, based on all available E911 information, in
connection with any claims for enforcement action. We note that the accurate and reliable delivery of
E911 location information depends upon the willingness and readiness of PSAPs and CMRS providers to
work together. We seek comment on this proposal.
d.

Liability Protection

112.
Background. In general, liability protection for provision of 911 service is governed by
state law and has traditionally been applied only to 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.224
113.
Discussion. We recognize that adequate liability protection is needed for CMRS
providers to proceed with implementation of the indoor location accuracy requirements. The recent NET
911 Act and Next Generation 9-1-1 Advancement Act have significantly expanded the scope of this
liability protection, and we believe this provides sufficient liability protection for CMRS providers.
Nevertheless, we seek 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. Do CMRS providers have sufficient liability protection under current laws to implement our
proposed indoor location accuracy requirements, or is additional protection still necessary or desirable?
Have there been instances where this liability protection has proven to be insufficient?

220 Id. at 18916 ¶ 18.
221 See supra Section III.B.3.a.i.
222 PSAPs that seek enforcement may be required to provide a showing to overcome the proposed safe harbor
described in para. 85, supra.
223 See infra Section IV.E., para. 167 (discussing providers’ delivery of E911 location information to its location
information center and the need for PSAPs to “pull” or bid for this information).
224 In 2008, Congress enacted the New and Emerging Technologies 911 Improvement Act (NET 911 Act), which
provides that a “wireless carrier, IP-enabled voice service provider, or other emergency communications provider …
shall have” the same liability protection as a local exchange provider under federal and state law. 47 U.S.C. § 615a.
In February 2012, Congress further extended state liability protection to providers of NG911 service in the Next
Generation 9-1-1 Advancement Act of 2012, enacted as subtitle E of the Middle Class Tax Relief and Job Creation
Act of 2012, Pub. L. No. 112-96, 126 Stat 156, 237-45. The Next Generation 9-1-1 Advancement Act of 2012
provides that “[a] provider or user of Next Generation 9-1-1 services…shall have immunity and protection from
liability under Federal and State law [to the extent provided under section 4 of the Wireless Communications and
Public Safety Act of 1999],” with respect to “the release of subscriber information related to emergency calls or
emergency services,” “the use or provision of 9-1-1 services, E9-1-1 services, or Next Generation 9-1-1 services,”
and “other matters related to 9-1-1 services, E9-1-1 services, or Next Generation 9-1-1 services.” 47 U.S.C. § 1472.
In addition, Section 6503 of the Act amends the National Telecommunications and Information Administration
Organization Act to define “emergency call” as “any real-time communication with a public safety answering point
or other emergency management or response agency,” including communication “through voice, text, or video and
related data.” 47 U.S.C. § 942(e)(4).
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114.
More specifically, we seek comment on liability concerns that may be raised in
conjunction with the possible adverse effect on indoor location accuracy from signal boosters.225 At the
time of the Signal Booster Report and Order, the Commission noted that its “existing E911 location
accuracy requirements do not apply to calls placed indoors, where we expect the vast majority of
[multiple dwelling unit] calls will be placed.”226 Because we now propose to apply location accuracy
requirements to indoor calls, we seek comment regarding any liability concerns with regard to the
operation of signal boosters, and in satisfying our proposed indoor location accuracy requirements.
CMRS providers commenting in the Signal Booster Report and Order were especially concerned about
liability for location accuracy when those capabilities are affected by signal booster use.227 Have these
liability concerns abated in any way, in light of technological developments that might improve location
accuracy or based on liability protection afforded by existing laws? If not, what position, if any, could
and should the Commission take regarding potential liability for interference with location accuracy
technology from signal booster use, whether in the multiple dwelling unit context or otherwise?
e.

Waiver Process

115.
We seek comment on whether we should adopt a specific waiver process for CMRS
providers who seek relief from our indoor location accuracy requirements. As discussed above, we seek
to adopt cost-efficient, technology-neutral rules that are easy to understand and administer. In doing so,
we intend to allow CMRS providers flexibility to comply with any indoor location accuracy requirements
in a manner that suits their particular business plans and technology choices. At the same time, however,
we recognize that there may be instances where a provider may require limited relief. In general, the
Commission’s rules may be waived for good cause shown.228 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 these implementation issues were more precisely identified. 229
116.
We seek comment on whether our existing waiver processes are sufficient for purposes of
any indoor location accuracy requirements, or whether we should adopt a waiver process that is specific
to indoor location accuracy. In the event that commenters believe a specific waiver process would serve
the public interest, we seek comment on how such a specific waiver process would be implemented.
Furthermore, should we establish criteria for a streamlined process for waiver relief? For example, under
one potential approach, providers who believe they cannot comply with a particular indoor location
accuracy benchmark, despite their good faith efforts, may submit a certification to this effect six months
prior to the applicable benchmark. The certification must include an alternative timeframe for satisfying
the benchmark, as well as an explanation of how they will achieve compliance within this alternative
timeframe. In the event a provider submits such a certification, and provided the certification is not false
and the alternative timeframe is not unreasonable, should we defer enforcement action during the
pendency of the alternative timeframe? What additional criteria, if any, might be warranted to justify a
waiver or extension of time to satisfy an indoor location accuracy benchmark? We seek comment on how
best to structure a waiver process that ensures providers take their obligation to satisfy indoor location
accuracy requirements seriously, while at the same time acknowledging that unforeseeable circumstances
might arise that would justify limited relief.

225 See supra Section III.B.1. (discussing the potential effects of signal boosters on location accuracy).
226 Signal Booster Report and Order, 28 FCC Rcd at 1696 ¶ 90 n. 206.
227 Id. at 1696 ¶ 92.
228 See 47 C.F.R. §1.3.
229 See Revision of the Commission’s Rules to Ensure Compatibility with Enhanced 911 Emergency Calling
Systems, CC Docket No. 94-102, Report and Order and Further Notice of Proposed Rulemaking, 11 FCC Rcd
18676, 18710 ¶ 66, 18718 ¶ 84 (1996) (E911 First Report and Order).
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C.

Long-Term Indoor E911 Location Accuracy Requirements

117.
In developing a framework for E911 location accuracy, we seek comment on how any
potential near-term requirements would operate in a NG911 environment, as well as how these
requirements could facilitate the Commission’s long-term location accuracy objectives. The accuracy
requirements discussed above only provide for a “rough” approximation of a wireless 911 caller’s
location. The proposed requirements for horizontal location within 50 meters and z-axis information
within 3 meters could still result in building misidentification, and are insufficiently granular to provide
room or apartment-level location. We agree with commenters who assert that public safety would be best
served through the delivery of a dispatchable address.230 Commscope, however, notes that delivering
location information in the form of a civic address may be better addressed in the context of NG911,
because NG911 architecture allows for the explicit communication of floor and building address
information, rather than conventional Phase II E911.231
118.
Over the long term, we seek comment on how to formulate requirements that would
require sufficiently granular location information to provide PSAPs with “dispatchable” address
information, which would include a building address as well as specific floor and suite/room number
information for indoor calls. We seek comment on this goal, including its costs and benefits. We also
seek comment on what technologies might facilitate the delivery of dispatchable address information, and
within what timeframe. We also seek comment on what future location-based solutions and NG911
technologies may make the provision of dispatchable address information easier. In the following
sections, we seek comment on ways in which we can take steps towards achieving our long-term indoor
location objectives.
1.

Leveraging Indoor Network Access Technologies

119.
We seek comment on ways in which we can take steps towards achieving our long-term
indoor location objectives by leveraging measures that CMRS providers are already taking to expand and
enhance their networks. For instance, to account for technical difficulties of urban and indoor
environment, CMRS providers are already deploying both small cells and DAS to improve and expand
their network coverage and speed.232 In its report on leveraging location-based services for E911

230 For example, Intrado notes that “[f]or obvious reasons, the physical address of the 911 caller is still the most
effective information for rendering emergency assistance to those inside a structure,” and urges the Commission to
require carriers to provide a “dispatchable address” for wireless callers. Intrado Further Notice Comments at 3-4.
231 CommScope Further Notice Comments at 7.
232 See, e.g., PR Newswire, “Verizon Wireless Activates DAS System In Empire State Plaza,” Sept. 16, 2013,
available at http://www.prnewswire.com/news-releases/verizon-wireless-activates-das-system-in-empire-state-
plaza-223946991.html (last visited Feb. 3, 2014); DeGrasse, Martha, “Small cells: Carriers focus on handoffs to
legacy networks,” RCR WIRELESS, Nov. 21, 2013, available at
http://www.rcrwireless.com/article/20131121/heterogeneous-networks-2/small-cells-carriers-focus-on-handoff-to-
legacy-networks/ (last visited Feb. 3, 2014); AT&T, “Small Cells, Big Steps,” available at
http://www.att.com/Common/about_us/pdf/small_cell.pdf (last visited Feb. 3, 2014) (“by 2015, AT&T plans to
deploy 40,000 small cells in the network”). For our purposes here, we use the term “small cell” to refer to picocells
and microcells. A picocell has a limited range of connectivity and is often employed to provide coverage over an
area such as a single floor of a building or an airport terminal. A microcell offers a larger deployment footprint,
such as a residential neighborhood or an entire airport. See E911 Location Accuracy Further Notice and NOI, 25
FCC Rcd at 18973 ¶ 40. A DAS is “[a] network of spatially separated antenna nodes connected to a common source
via transport medium that provides wireless service within a geographic area or structure.” DAS Forum, “In-
Building Enterprise DAS for Wireless Infrastructure 2011,” available at http://www.thedasforum.org/wp-
content/uploads/2011/10/PPT-InBuilding-Enterprise-DAS-for-Wireless-Infrastructure-2011.pdf (last visited Feb. 3,
2014). DAS are often deployed across entire building wings, floors, and concourses. CSRIC LBS Report at 47
(describing CommScope’s GeoLENs System, which utilizes DAS). Though the Commission sought comment on
femtocells in the Location Accuracy Further Notice, we intend to exclude these from this discussion, as well as
signal boosters specifically designed for “out of the box” consumer use. See http://wireless.fcc.gov/signal-
(continued….)
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purposes, CSRIC noted that “[a]s cell sizes shrink, the location of the serving cell itself may suffice for a
position estimate for both E9-1-1 call routing and first responder dispatch [because] the base station itself
can be a Phase II positioning technology.”233
120.
Providing specific location information through small cells and DAS may be able to save
critical time during an emergency. We seek comment on whether small cells and DAS could be
leveraged to provide critical location information for public safety entities responding to emergencies
located indoors, and if so, how. In particular, we seek comment on whether, as part of a long-term indoor
location solution, CMRS providers should be subject to a requirement to program all small cell and
geographically identifiable DAS extensions of their CMRS networks with address information at the time
of installation and/or prior to the commencement of commercial service using the small cell or DAS.234
We also ask whether wireless providers should also program existing small cell and DAS deployments
with location information whenever those sites and system are upgraded or replaced.
121.
We seek comment on the technical feasibility of programming both small cells and DAS
with location information, as well as the feasibility of installing A-GPS chips within small cell nodes and
DAS antennae.235 We note that Navanu, a location technology vendor, submits that its technology
incorporates a passive RF analyzer that can also be “embedded within … a DAS system … or any
wireless broadband access point” and “can isolate a signal from a mobile device and map [the device]
location.”236 Can CMRS providers currently configure small cells, DAS, and industrial signal boosters to
provide this information? If not, what additional developments must be made? Would additional work
be necessary to develop industry standards? We also seek comment on whether configuring DAS and
industrial signal boosters to identify the address of the building from which the 911 call originated might
compensate for any potential adverse effect on determining location information through network-based
methods that otherwise might arise from the use of signal boosters and DAS.237 Finally, we seek
comment on whether CMRS providers could retroactively program existing small cells, DAS, and
industrial signal boosters to contain specific address information.
122.
We seek comment on the potential costs to CMRS providers to program small cell nodes
with dispatchable address information. We also seek comment on the potential costs of configuring DAS
to perform the same function. We believe that leveraging actions that CMRS providers are already
undertaking should lower the potential costs for providers to achieve more granular location information
that is consistent with our long-term E911 objectives.
123.
We also seek comment on what steps, if any, PSAPs would need to take to incorporate
and use this additional information. Could existing information fields be used to display additional
(Continued from previous page)
boosters/index.html (describing different types of signal boosters use and current Commission requirements
governing their use). Consumer Signal Boosters are devices that are marketed and sold to the general public for
their personal use to improve wireless coverage in limited areas such as homes and vehicles. See 47 C.F.R. §§ 20.3,
20.21(a).
233 See CSRIC LBS Report at 10; see also Remarks of Timothy Lorello, Senior Vice President/Chief Marketing
Officer of TCS, FCC E911 Phase II Location Accuracy Workshop, at minutes 212, 241, available at
http://www.fcc.gov/events/workshop-e911-phase-ii-location-accuracy (last visited Feb. 3, 2014).
234 Again, we would envision that any potential requirements would apply only to small cell and DAS network
extensions that are installed at the behest of the CMRS provider, though a third party may install the device.
235 See also E911 Location Accuracy Further Notice, 25 FCC Rcd at 18973 ¶ 41.
236 See Navanu Feb. 11, 2013 Ex Parte Letter at 2 (also submitting that an RF analyzer can reside within a small
cell). According to Navanu, the capability currently is in early development but has minimal costs because it does
not demand new requirements for site deployments. See id. (asserting that the costs “can range from a few dollars to
somewhere under fifty dollars, depending on the small cell’s design”).
237 See notes 160 and 339-341 for further discussion of how signal boosters can impact location accuracy.
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address information, like floor and apartment number? If not, what additional upgrades would be
necessary to PSAP equipment? What modifications to PSAP operating procedures would be necessary to
accommodate any additional information from small cell deployments?
2.

Differentiating Between Indoor and Outdoor Calls

124.
CMRS providers generally have indicated that it is not possible to differentiate between
indoor and outdoor calls to 911.238 We seek comment on whether technology has evolved such that
CMRS providers are able now, or will be able in the foreseeable future, to determine whether a call
originates from indoors and make this information available to PSAPs. If not, what additional
technological advancements need to take place in order to differentiate between calls that originate
indoors versus outdoors? In what timeframe would these advancements likely take place?
125.
We suggest that one way in which indoor and outdoor calls could be differentiated is by
using location information provided by small cell and DAS infrastructure. If dispatchable address
information from a small cell or DAS node is available to the PSAP, this information would include the
floor and suite/room number, thereby signifying the call originated indoors. Similarly, to the extent that
providers convey z-axis information that indicates that a call originated above a certain height above
ground, it could be reasonable to infer that a wireless call originated indoors. Furthermore, consistent
with the observations in the CSRIC LBS Report, CMRS providers may be able to use certain commercial
location-based services on a device to provide a reasonable estimate of the device’s location and whether
the device is located indoors. We seek comment on these methods, as well as on any other ways that
CMRS providers could use to determine whether a call originates from indoors. In addition, what costs
would be associated with developing this capability? What steps would CMRS providers have to take, if
any, to make information on whether a call originated from indoors available in its location information
center?
126.
We also seek comment on whether identifying a wireless 911 call as originating indoors
versus outdoors, by itself, would be useful information to public safety entities. Would it be sufficient to
provide public safety entities with more granular location information, which presumably would identify
whether a call originated indoors within a certain search radius? We also seek comment on whether
existing PSAP equipment could readily make use of this information. What costs could be associated
with a PSAP’s ability to use this kind of information?
3.

Leveraging Commercial Location-Based Services, Emerging Technologies,
and other Sources of Location Information

127.
Commercial location-based services (LBS) are applications that CMRS providers load, or
consumers download, onto their phones, and are independent of any solutions that CMRS providers might
be required to adopt to comply with our location accuracy requirements. Such applications, which
typically combine GPS and Wi-Fi, are currently implemented in all major commercial mobile operating
systems. In its E911 Location Accuracy Second Further Notice, the Commission noted that these
commercial LBS “could potentially permit service providers and applications developers to provide
PSAPs with more accurate 911 location information,”239 and sought comment on whether it should
encourage mobile service providers to enable the use of commercial LBS for emergency purposes.240 It
also sought comment on the value of operational benchmarks to assist consumers in evaluating the ability
of carriers to provide precise location information for emergency purposes based on the location-based

238 See, e.g., AT&T Workshop Comments at 2-3 (“To this point, it should be noted that AT&T Mobility – and
presumably other wireless carriers – does not and cannot maintain call data on the origin of the call; that is, whether
calls originate indoors or outdoors.”); T-Mobile Workshop Comments at 16 (submitting that it “has no way to know
and track when a wireless 911 call is made from an indoor location”).
239 E911 Location Accuracy Second Further Notice, 26 FCC Rcd at 10101 ¶ 79.
240 Id.
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capabilities of devices.241 The Commission tasked WG3 with investigating how commercial location-
based services might be leveraged for indoor wireless E911 service.242
128.
In response to the E911 Location Accuracy Second Further Notice, numerous
commenters supported investigation by CSRIC of the use of commercial LBS by public safety,243 though
some commenters suggested that further study beyond the CSRIC report – then pending – would be
necessary.244 CTIA and AT&T urged the Commission to allow the industry to come up with best
practices for using location-based services.245 Several commenters noted that industry standards work
would be necessary before commercial LBS would be a viable option for 911 purposes.246
129.
Several commenters cautioned against using commercial LBS.247 Verizon stated that
certain commercial LBS technologies “potentially could serve as a supplement to A-GPS, particularly for
indoor areas,”248 but noted that “[n]ot all customers subscribe to commercial LBS, and even those who do
may not have the service turned on at the moment they make a 911 call” and that currently, “not all
handsets will support commercial LBS applications.”249 VON Coalition also argued that “[neither Wi-Fi
positioning or commercial LBSs] can guarantee accurate location data.”250 TCS also noted that “[t]he use
of commercial [LBS] can be inhibited by regulatory and funding conditions” and suggested that questions
of funding also be referred to CSRIC.251
130.
WG3’s final report in March 2013 investigated commercial LBS and emerging location
technologies for indoor wireless E911 use, and made recommendations on how they could be best
leveraged for E911 purposes.252 While the report concluded that few of these technologies are presently
available for indoor E911 use, it found that “good progress is being made” in addressing challenges to

241 Id.
242 Id. (“CSRIC should be directed to explore and make recommendations on methodologies for leveraging
commercial location-based services for 911 location determination. CSRIC should also suggest whether it is
feasible or appropriate for the Commission to adopt operational benchmarks that will allow consumers to evaluate
carriers’ ability to provide accurate location information.”).
243 APCO Second Further Notice Comments at 8; CenturyLink Comments, PS Docket No. 07-114 (filed Oct. 3,
2011) at 6 (CenturyLink Second Further Notice Comments); MetroPCS Comments, PS Docket No. 07-114 (filed
Oct. 3, 2011) at 15 (MetroPCS Second Further Notice Comments).
244 AT&T Second Further Notice Comments at 6-7 (suggesting that further investigation of commercial LBS be
referred to the E911 Technical Advisory Group (ETAG)); Verizon Second Further Notice Comments at 19- 20
(believes that Commission should seek further comment after CSRIC issued its report); T-Mobile Second Further
Notice Comments at 6-7 (though supportive of CSRIC’s efforts, generally thinks that commercial LBS is not a
viable solution for 911 purposes); TIA Comments, PS Docket No. 07-114 (filed Oct. 3, 2011), at 3, 7 (suggesting
that ETAG is the best forum for these issues to be discussed) (TIA Second Further Notice Comments);
SouthernLINC Second Further Notice Reply Comments at 6-8.
245 CTIA Second Further Notice Comments at 7, 9; AT&T Second Further Notice Comments at iii.
246 Verizon Second Further Notice Comments at 20; SouthernLINC Second Further Notice Reply Comments at 7.
247 Verizon Second Further Notice Comments at 19, 20; VON Coalition Comments, PS Docket No. 07-114 (filed
Oct. 3, 2011), at 10 (VON Coalition Second Further Notice Comments); TCS Second Further Notice Comments at
11.
248 Verizon Second Further Notice Comments at 19.
249 Id. at 20.
250 VON Coalition Second Further Notice Coalition Comments at 10.
251 TCS Second Further Notice Comments at 11.
252 See CSRIC LBS Report.
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such use.253 At the same time, the CSRIC LBS Report highlights several concerns with regard to
leveraging commercial LBS for 911.254 The CSRIC LBS Report recommends further evaluation of
LBS.255
131.
Since the Commission last sought comment on leveraging commercial LBS for 911
purposes, considerable developments have been made.256 Industry bodies have already created wireless
E911 standards that support a range of technologies that can provide indoor location information.257
Moreover, there is increasing commercial interest in developing LBS, particularly services that rely on
indoor location, for a range of different applications.258 Indeed, indoor location technology has become
such a large market that it is bigger than its outdoor counterpart, if commercial buildings are included.259
132.
Indoor location solutions are also being developed that use Wi-Fi and similar in-building
technology to locate calls. Cisco’s technology, for example, uses RF fingerprinting to determine location
over a Wi-Fi network using signal strength and time of arrival lateration techniques.260 Cisco indicates
that, with respect to indoor environments, “location data today is generally available in enterprise [Wi-Fi]

253 See id. at 56. In addition to the three technologies tested in the CSRIC test bed, discussed above, the CSRIC LBS
Report
also noted the potential for such other technologies as Wi-Fi, See id. at 20-28 (discussing Assisted Global
Navigation Satellite System (A-GNSS); id. at 29-30 (Observed Time Difference of Arrival (O-TDOA); id. at 35-42
(LEO Satellite-Based Positioning); and id. at 42-47 (Uplink Time Difference of Arrival (U-TDOA) for LTE).
254 Particularly, CSRIC notes that commercial LBS “have not been subjected to mandated accuracy levels and
rigorous compliance testing and evaluation to ensure that database integrity and peak accuracy levels are
maintained.” CSRIC LBS Report at 17. CSRIC further notes that commercial LBS are problematic because “not all
customers subscribe to [commercial location based services], and even those who do may not have the service or
their location privacy setting turned on at the moment they make a 9-1-1 call,” and because the user equipment must
be able to handle simultaneous voice and data. Id.
255 Id. at 2.
256 See id. at 56 (stating that there is continual development in this field). See also NENA Workshop Comments at 3
(noting improvements in time to first fix and satellite- and ground-based positioning systems and significant and
rapid increase in the deployment and use of LBS); Polaris Wireless Workshop Comments at 3 (forecasting
substantial improvements in indoor location accuracy, both horizontally and vertically).
257 See CSRIC LBS Report at 15. The predominant standard is J-STD-036, developed by the Telecommunications
Industry Association and the Alliance for Telecommunications Industry Solutions. Id. The report notes, however,
that further standards may need to be developed for over-the-top (OTT) technologies. Id. at 16.
258 See “Location-based Services – An Overview of Opportunities and Other Considerations,” Report, Wireless
Telecommunication Bureau, FCC (rel. May 2012), at 10, available at http://www.fcc.gov/document/location-based-
services-report (last visited Feb. 5, 2014) (Location-Based Services Report). See also Gross, Doug, “The Growing
Push to Track Your Location Indoors,” CNN, Mar. 26, 2013 available at
http://www.cnn.com/2013/03/25/tech/mobile/apple-indoor-gps (last visited Feb. 5, 2014) (Growing Push Article)
(noting that “a new move in mobile tech is seeing startups who want to help you find the store you’re looking for in
the mall, turn around when you’re getting farther from your terminal at the airport or figure out where your friends
are in an expansive convention hall.”). Analyst firm ABI Research predicts that by 2017, the indoor location
technology market will reach $5 billion in revenues, and represent over 200,000 installations of infrastructure
equipment, including Wi-Fi hotspots and Bluetooth antennas, and over 800 million branded applications downloads.
See also
Carle, Christian, “Indoor Location: The Mobile Revolution Starts Now,” INVESTVINE (June 6, 2013),
available at http://investvine.com/indoor-location-the-mobile-revolution-starts-now/ (last visited Feb. 19, 2014)
(Indoor Location Mobile Revolution Article).
259 See Indoor Location Mobile Revolution Article.
260 See Cisco, “Unified Wireless Location Services,” available at
http://www.cisco.com/en/US/docs/solutions/Enterprise/Mobility/emob41dg/ch13Loca.html (last visited Feb. 5,
2014).
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networks and is technologically feasible in residential Wi-Fi networks.”261 At the same time, however,
Cisco acknowledges that “significant work remains” on generating civic addresses (including floor
numbers) and location data for Wi-Fi enabled devices that are not authenticated to the Wi-Fi access
points.”262 Also, Cisco noted that current standards efforts should be ready for Wi-Fi Alliance
certification some time in 2015.263 Cisco indicated that implementation of Wi-Fi protocols will provide
“10 feet of accuracy on a horizontal x/y axis 90% of the time.”264
133.
Location-based technologies are also already being rolled out in conjunction with
consumer application and device offerings. Indeed, commercial location technologies, typically
combining GPS and Wi-Fi, currently are implemented in all major commercial mobile operating
systems,265 with multiple independent Wi-Fi access location databases, maintained by Google, Apple, and
Skyhook, among others.266 The use of Bluetooth beacon technology is also potentially attractive for
indoor location although, at present, such technology is less developed than that for Wi-Fi.267 At a recent
consumer electronics trade show and the 2014 Super Bowl, Bluetooth low energy (LE) beacons were
demonstrated.268 Moreover, essentially all smartphones now sold have Wi-Fi and Bluetooth network

261 Letter from Mary L. Brown, Director, Cisco Government Affairs, Cisco Systems, Inc., to Marlene H. Dortch,
Secretary, FCC, PS Docket No. 07-114 (filed June 5, 2013), at 1 (Cisco June 5, 2013 Ex Parte Letter). Cisco states
that while significant work remains to be done, “location accuracy of 5 meters, and even … 1 meter, is achievable.”
Id. at 1-2.
262 Id.at 1-2.
263 Id.at 1.
264 Id. (referring to “the 802.11mc Fie Timing Measurement protocol over the 802.11ac (80MHz) physical layer.”
Cisco also asserts that “more accurate data is possible depending upon implementation and the use of ‘angle of
arrival’ data.”).
265 See, e.g., “Android Location,” available at http://developer.android.com/reference/android/location/package-
summary.html (last visited Feb. 5, 2014) (listing GPS functions as part of Android location services); “iOS 6:
Understanding Location Services,” available at http://support.apple.com/kb/HT5467 (last visited Feb. 5, 2014);
“Turning on and querying Location Services on the device,” available at
http://docs.blackberry.com/en/developers/deliverables/17954/Turning_on_querying_Location_Services_1222726_1
1.jsp (last visited Feb. 5, 2014); Windows Phone, “Location and My Privacy FAQ,” available at
http://www.windowsphone.com/en-us/how-to/wp7/web/location-and-my-privacy (last visited Feb. 5, 2014).
266 See, e.g., Google, Configure access points with Google Location Service, available at
https://support.google.com/maps/answer/1725632?hl=en (last visited Feb. 5, 2014) (“Google, as a location service
provider, uses publicly broadcast Wi-Fi data from wireless access points, as well as GPS and cell tower data.”); Cox,
John, “Apple Leverages Wi-Fi location with latest acquisition,” NETWORK WORLD, Mar. 25, 2013, available at
http://www.networkworld.com/news/2013/032513-apple-wifislam-268054.html (last visited Feb. 5, 2014) (“Apple
has bought a small software startup that lets smartphones and tablets pinpoint their location indoors using nearby
Wi-Fi signals.”) (Apple-WiFiSLAM Article); Skyhook, Coverage Area, available at
http://www.skyhookwireless.com/location-technology/coverage.php (last visited Feb. 5, 2014) (“To pinpoint
location, Skyhook uses a massive reference network comprised of the known locations of over 700 million Wi-Fi
access points and cellular towers.”).
267 See CSRIC LBS Report at 34-35 (noting that “Bluetooth is a nearly standard feature on all current cell phones and
smart phones” and that it is “ideally suited to create low cost beacons that could be deployed indoors to determine
location.”)
268 See Business Wire, “CEA Announces iBeacon Scavenger Hunt at 2014 International CES, Jan. 2, 2014, available
at
http://www.businesswire.com/news/home/20140102005966/en/CEA-Announces-iBeacon-Scavenger-Hunt-2014-
International (last visited Feb. 5, 2014); Wingfield, Nick, “Another Super Bowl Ad Fest, This Time on the
Cellphone,” N.Y. TIMES, Jan. 30, 2014 at A1, available at http://www.nytimes.com/2014/01/31/technology/For-
Super-Bowl-Personalized-Phone-Alerts.html (last visited Feb. 5, 2014).
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interfaces.269 As noted earlier, these capabilities also provide a means of determining indoor location.270
In fact, indoor location applications are now mainstream for iPhone and Android devices, which together
cover about 80 percent of the smartphone market.271
134.
Furthermore, almost all smartphones sold today are equipped with multiple sensors that
can determine acceleration, magnetic fields (compass direction) and movement (gyroscope), which also
provide a means of determining the operating environment.272 In addition, a number of large mobile
device vendors have started to include barometric pressure sensors in their devices, which can calculate z-
axis information.273 In light of the fact that 61 percent of CMRS subscribers owned a smartphone as of
May 2013,274 the majority of wireless subscribers already have access to some form of indoor location-

269 See, e.g., Galbraith, Craig, “Number of Wi-Fi Access Points Growing Quickly,” BILLING AND OSS WORLD, Sept.
6, 2013, available at http://www.billingworld.com/news/2013/09/number-of-wi-fi-access-points-growing-
quickly.aspx (last visited Feb. 5, 2014) (“Virtually all new smartphones now have Wi-Fi connectivity as standard”);
CSRIC LBS Report at 34 (Bluetooth is nearly a standard feature on all current cell phones and smart phones). See
also, e.g.,
Apple, iPhone Tech Specs, available at http://www.apple.com/iphone/specs.html (last visited Feb. 5,
2014); Android, Developers, Connectivity, available at
http://developer.android.com/guide/topics/connectivity/bluetooth.html (last visited Feb. 5, 2014).
270 See Cisco June 5, 2013 Ex Parte Letter at 1-2. See also Skyhook, “Submit a Wi-Fi Access Point,” available at
http://www.skyhookwireless.com/howitworks/submit_ap.php (last visited Feb. 5, 2014) (“Skyhook's location
technology leverages Wi-Fi access point information to accurately determine location information in dense urban
areas or indoor environments.”); Apple-WiFiSLAM Article (Apple acquires company that uses Wi-Fi signals to
determine indoor location); Costa, Tony, “Indoor Venues are the Next Frontier for Location-Based Services,”
FORBES, Jan. 23, 2013, available at http://www.forbes.com/sites/forrester/2013/01/23/indoor-venues-are-the-next-
frontier-for-location-based-services/ (last visited Feb. 5, 2014) (“Apple, Broadcom, Google, Microsoft, Nokia, and
Qualcomm … are extending the capabilities of their platforms and products to enable indoor positioning.”); Google,
“A New Frontier for Google Maps: Mapping the Indoors,” Nov. 29, 2011,
http://googleblog.blogspot.com/2011/11/new-frontier-for-google-maps-mapping.html (last visited Feb. 5, 2014)
(“Google Maps for Android enables you to figure out where you are and see where you might want to go when
you’re indoors.”).
271 See Indoor Location Mobile Revolution Article (“The fusion of multiple technologies, such as Wi-Fi, Bluetooth
Low Energy and GPS, along with specific ones already integrated in smartphones (accelerometer, magnetometer,
gyroscope, and pressure sensor acting as an altimeter) allowed [the overcoming of] the main technical barriers that
prevented indoor location to be successful in the market.”).
272 For example, an iPhone 5 comes with the following sensors: three-axis gyro, accelerometer, proximity sensor,
ambient light sensor, and compass; a Samsung Galaxy SIII comes with an accelerometer, RGB light, digital
compass, proximity, gyro, and barometer. See Tolentino, Melissa, “Compared: iPhone 5 vs. Samsung Galaxy SIII
and Note II,” SILICON ANGLE, Sept. 2012, available at http://siliconangle.com/blog/2012/09/13/compared-iphone-5-
vs-samsung-galaxy-siii-and-note-ii/ (last visited Feb. 3, 2014). See also Ravindranath, Lenin, et al., “Improving
Wireless Network Performance Using Sensor Hints,” in Proceedings of the 8th USENIX conference on Networked
systems design and implementation at 1, 9 (2011), available at http://nms.csail.mit.edu/papers/wesp-nsdi11-final.pdf
(last visited Feb. 3, 2014) (“Commodity smartphones and tablet devices come equipped with a variety of sensors,
including GPS, accelerometers, magnetic compasses, and gyroscopes, which can provide hints about the device’s
mobility state and its operating environment.”). See also Growing Push Article (“WiFiSlam … is one of several
startups that are marrying traditional GPS coordinates with smartphone tools like accelerometers and compasses to
get more precise coordinates.”).
273 See Happich, Julien, Samsung Leads the Adoption of Pressure Sensors in Smartphones, for Floor-Accurate
Indoor Geolocation,” EE TIMES EUROPE, Mar. 21, 2013, available at http://www.electronics-
eetimes.com/en/samsung-leads-the-adoption-of-pressure-sensors-in-smartphones-for-floor-accurate-indoor-
geolocation.html?cmp_id=7&news_id=222916211 (last visited Jan. 28, 2014).
274 See Smith, Aaron, “Smartphone Ownership 2013,” Pew Internet & American Life Project, June 5, 2013,
available at http://pewinternet.org/Reports/2013/Smartphone-Ownership-2013/Findings.aspx (last visited Feb. 14,
2014).
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based technology. Moreover, the performance reached by such indoor location technologies has now
surpassed GPS for the outdoors, with an average accuracy of a few square feet compared to several tens
of square feet for GPS.275 We seek comment on these developments and on how they may relate to
potential location accuracy requirements.
135.
Recent data shows that adults are increasingly using location-based services and data
networks.276 We seek comment on how providers could use commercial LBS to provide or enhance E911
location information, assuming CMRS providers can obtain usable location information from commercial
LBS applications. To what extent can CMRS providers access and provide this supplemental
information, where available, to the location information center for retrieval by the PSAP, now or in the
foreseeable future? Could smart phones be programmed in such a manner that, when the phone initiates a
voice call to 911, a separate and additional query within the handset is made for information on the
device’s last known location, with all location information then being sent to the provider’s location
information center? Moreover, what technical and operational challenges, if any, do PSAPs face in
receiving location accuracy information from LBS services, and in what timeframe could they be
addressed? What are the associated costs, if any, to meeting those challenges?
136.
What privacy concerns, if any, might be implicated by sharing location information
obtained through commercial LBS with CMRS providers, in order to enhance the accuracy of E911
location information? Many commercially deployed location information systems have privacy settings
to restrict the amount of information shared by a smartphone user. CSRIC noted, however, that despite
user privacy controls over location data, “for 9-1-1 calls, GPS or other location methods are activated
regardless of the user’s privacy setting.”277 CSRIC added that “[i]t is therefore imperative that any new
location technology . . . adhere to the same privacy principles,” and that “location technology cannot be
downloaded in the form of an application, which would be subject to the user’s privacy settings.”278
Could location software application programming interfaces (APIs)279 be more tightly integrated into the
user equipment’s lower level services, such that location capabilities remained activated despite user
privacy settings or create a separate privacy setting for “911-only” restricted-use location data, or would it
be necessary to require that smartphone users affirmatively “opt in” to permit the disclosure of this
information? What other privacy issues should the Commission take into account?
137.
We recognize that commercial LBS may present trade-offs. For example, location
information from LBS applications on the phone may be inaccurate and untimely, as the user could have
terminated any active location-based services session well before that user dials 911. Furthermore,
continuously maintaining active sessions with location-based applications could have practical
implications for users, including a negative effect on the battery life of a user’s device and increased data
usage fees.280 Nevertheless, given the increasing usage of commercial LBS and the importance of

275 See Indoor Location Mobile Revolution Article. See also NexGen Comments Workshop at 3 (“Since almost any
calibrated altimeter will be more accurate in reading altitude than GPS, the incorporation of altimeter technology
into cell phones will provide more accurate z-axis location information than will a GPS provided reading in this
state in the evolution of GPS technology.”).
276 See Zickhur, Kathryn, “Location-Based Services,” Pew Research Center Internet & American Life Project, Jun.
5, 2013, at 4, available at http://pewinternet.org/~/media//Files/Reports/2013/PIP_Location-
based%20services%202013.pdf (last visited Feb. 6, 2014) (noting that 74 percent of adult smartphone owners have
used location-based services at least once, which works out to roughly 45 percent of all American adults).
277 CSRIC LBS Report at 19.
278 Id.
279 An application programming interface is a set of software instructions on how software components should
interact with each other.
280 See, e.g., Apple, Guidelines for Extending iPhone Battery life, available at
http://www.apple.com/batteries/iphone.html (last visited Feb. 14, 2014) (noting that “[a]pps that actively use
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determining a 911 caller’s location, we believe it should be considered as a potential resource for E911
purposes.
138.
Institutional and Enterprise-based Location Systems. We also seek comment on how
institutional and enterprise location systems could be leveraged to provide location data for E911. For
example, Cisco Systems has demonstrated possible use cases for its location technologies for hotels,
hospitals, higher education campuses, and large enterprise settings.281 Cisco indicates that it “will be
capable of producing 10 feet of accuracy on a horizontal X/Y axis 90% of the time although more
accurate data is possible depending upon implementation and the use of ‘angle of arrival’ data.”282 Cisco
also states “the client can query the network for its own location for use in applications such as
emergency services,” but that “the architecture that would allow the delivery of location data to a [PSAP]
is still being studied by industry.”283 Furthermore, in 2013, Guardly released its Indoor Positioning
System, a subscription-based mobile security system for businesses, school campuses, apartment
buildings and parking garages which Guardly states can provide “the building name, floor, and room
number of the wireless caller in less than 5 seconds” to emergency and/or security personnel.284
139.
Because of the numerous commercial and operational incentives for location technology
in these settings, we anticipate that the number of deployed institutional and enterprise-based location
systems will increase in the near future. We seek comment on whether location information from these
systems could be provided to CMRS providers and, ultimately, made available to public safety entities
together with other E911 location information. Cisco states that per existing standards, “the client can
query the network for its own location for use in applications such as emergency services,” but that “the
architecture that would allow the delivery of location data to a [PSAP] is still being studied by
industry.”285 Today many such location systems can only interact with – and therefore provide emergency
location information for – devices that have Wi-Fi or Bluetooth capabilities. Do any indoor location
systems already make this information available to CMRS providers, and if so, what are they? What
modifications to Wi-Fi hotspots, location beacons, or devices with location information would be
necessary to enable the transmission of location information to CMRS providers?
140.
Smart Building Technology. Indoor location positioning is in high demand for
commercial uses, and major industry stakeholders are investing in the development of indoor positioning
technologies for applications in retail, health, gaming, entertainment, and advertising.286 Many of these
systems are designed to assist smartphone users in finding specific locations and estimating walking
time,287 as well as to assist retailers with precise marketing and advertising based on a customer’s
(Continued from previous page)
location services, such as Maps, may reduce battery life.”); Casti, Taylor, “9 Apps Draining Your Phone’s Battery,”
MASHABLE, Sept. 21, 2013, available at http://mashable.com/2013/09/21/battery-draining-app/ (last visited Dec. 19,
2013) (recommending users to “[k]eep location services off until you need it” in order to save battery life.).
281 See Cisco July 24, 2013 Ex Parte Letter at 1.
282 Id.
283 Id.at 2.
284 See Guardly, Indoor Positioning System, https://www.guardly.com/technology/indoor-positioning-system (last
visited Feb. 3, 2014).
285 Cisco July 24, 2013 Ex Parte Letter at 2.
286 See, e.g., Lessin, Jessica, “Apple Acquires Indoor Location Company WifiSLAM,” WALL STREET JOURNAL,
Mar. 23, 2013, available at http://blogs.wsj.com/digits/2013/03/23/apple-acquires-indoor-location-company-
wifislam/ (last visited Feb. 3, 2014); Schutzberg, Adena, “Ten Things You Need to Know About Indoor
Positioning,” DIRECTIONS MAGAZINE, May 6, 2013, available at http://www.directionsmag.com/articles/10-things-
you-need-to-know-about-indoor-positioning/324602 (last visited Feb. 3, 2014).
287 See, e.g., Nokia Indoor Navigation demonstration, available at
http://www.youtube.com/watch?v=S2GALFBrtXk&feature=youtu.be (last visited Feb. 14, 2014); IndoorLBS.com,
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movement.288 Though some “smart building” technology is already commercially available, its
deployment has been largely limited to public settings, given the cost of the necessary in-building
supporting infrastructure. Nevertheless, some residential “smart building” technologies are available
today, which could potentially be registered with dispatchable address information, including Wi-Fi-
enabled home security systems, door locks, and thermostats.289 We seek comment on how Bluetooth or
Wi-Fi-enabled locks, thermostats, smoke detectors, lighted exit signs, security systems and other
residential “smart building” technologies could be registered with dispatchable address information and,
if so, how it could be achieved.

IV.

IMPROVING THE DELIVERY OF PHASE II LOCATION INFORMATION

141.
In the following sections, we seek comment on measures to ensure that PSAPs receive
Phase II information in a swift and consistent format. We also seek comment on whether CMRS
providers should differentiate between the type of location technology used to generate a location fix.
Further, we seek comment on whether recent technological developments, including the proliferation of
GPS-enabled smartphones capable of providing more granular location information, warrants
strengthening our current E911 Phase II requirements to provide location information within 50 meters
for all wireless 911 calls. We also propose periodic Phase II call tracking requirements, measures to
facilitate the swift resolution of PSAP Phase II concerns, and compliance testing requirements to ensure
that we can monitor and ensure compliance with our E911 rules. 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, and that this information is provided in a way that is clear and useful.

A.

Time to First Fix (TTFF)

142.
Background. The Commission’s current E911 location accuracy rules do not require
CMRS providers to test for and meet a specific Time to First Fix (TTFF). In the E911 Location Accuracy
Third Report and Order
, the Commission tasked CSRIC with the “making recommendations concerning
cost-effective and specific approaches to testing requirements, methodologies, and implementation
timeframes,” including appropriate updates to OET Bulletin 71.290 In response, CSRIC WG3 noted that,
while the OET Bulletin No. 71 “suggests an acceptable time limit [Time to First Fix] for delivering the
location estimate of 30 seconds,” the OET guideline is “generally accepted as the de facto standard for
maximum latency in E9-1-1 location delivery.”291
143.
The record shows that with current location technologies, there is a trade-off between the
accuracy of the location information and the time to complete a location fix.292 This trade-off depends in
(Continued from previous page)
“Indoor Navigation Demos,” available at http://www.indoorlbs.com/p/indoor-navigation-systems.html (last visited
Feb. 3, 2014).
288 Clifford, Stephanie, and Hardy, Quentin, “Attention, Shoppers: Store Is Tracking Your Cell,” N.Y. TIMES, July
14, 2013, at A1, available at http://www.nytimes.com/2013/07/15/business/attention-shopper-stores-are-tracking-
your-cell.html?pagewanted=all&_r=0 (last visited Feb. 3, 2014).
289 See, e.g., August Smart Locks, http://www.august.com/ (last visited Feb. 4, 2014); Sargent Locks,
http://www.sargentlock.com/products/product_landing.php?item_id=1589 (last visited Feb. 4, 2014); Lockitron,
https://lockitron.com/preorder (last visited Feb. 4, 2014). Nest Thermostats allows the owner to adjust their home
thermostat using a smart phone or other device. See Meet the Nest Account and Nest Mobile App, available at
https://nest.com/blog/2011/11/10/meet-the-nest-account-and-nest-mobile-app/ (last visited Feb. 3, 2014).
290 See E911 Location Accuracy Third Report and Order, 26 FCC Rcd 10089 ¶ 37. See also OET Bulletin No. 71.
The Commission indicated that it would seek comment on CSRIC’s recommendations prior to implementing
specific testing requirements and procedures. See id. at 10089 ¶ 37.
291 See CSRIC Outdoor Location Accuracy Report at 12.
292 See infra, Section IV.C. (describing the trade-off between accuracy and latency). See also NENA Workshop
Comments at 3 (asserting that “existing network-based and network-assisted location technologies can provide very
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part on the location technology a carrier employs. For instance, the time for A-GPS technologies to
generate a location fix is typically longer than the time needed for network-based location solutions.293
TruePosition asserts that “[the] failure to accurately and timely locate all E-911 calls is the direct result of
the wireless carriers’ decision to move toward reliance on handset-based [A-GPS] technology as their
primary E-911 location technology … [and] the use of low-cost, inferior ‘fall-back’ technology when [A-
GPS] fails.”294 TruePosition adds that “[A-GPS] takes time to report an accurate location, typically at
least 30 seconds, and has difficulty performing in … environments such as urban areas where very high
volumes of 911 calls routinely occur.”295 However, while CMRS providers using A-GPS technologies
acknowledge that the time to generate an initial location fix based on GPS satellite signals may take
longer than five seconds,296 they submit that, generally, they can deliver Phase II location fixes within 12-
15 seconds.297
144.
Discussion. We propose that, as part of our existing Phase II E911 requirements as well
as our proposed indoor requirements,298 CMRS providers must deliver E911 location information, with
the specified degree of accuracy,299 within a maximum period of 30 seconds to the location information
center.300 We believe this proposal is consistent with the record, both in terms of addressing a need for
the Commission to take action regarding latency, as well as what is technically feasible. Public safety
(Continued from previous page)
fast first fixes, which are valuable to public safety, even if they are subject to larger uncertainties than final GNSS
[satellite] fixes.”).
293 See infra, Section IV.C at para. 154 (concerning the trade-off between accuracy and latency).
294 TruePosition Workshop Reply Comments at 1.
295 Id.
296 See Letter from Nneka Chiazor, Executive Director, Federal Regulatory Affairs, Verizon, to Marlene H. Dortch,
Secretary, FCC, PS Docket No. 07-114 (filed Sept. 11, 2013), at 5 (stating that its “A-GPS solution first attempts to
generate a location fix exclusively using GPS satellites, in which case a very precise Phase II fix can be obtained in
as little as 5 seconds.”) (Verizon Sept. 11, 2013 Ex Parte Letter).
297 See Verizon Sept. 11, 2013 Ex Parte Letter at 5 (submitting that a “pure GPS-based location fix often will be
available with the PSAP’s initial bid, but because Verizon Wireless’ average time to deliver a Phase II fix to the
MPC is around 12-15 seconds, in most cases the PSAP will often receive the ‘Phase I’ cell site/sector location first
with the voice call, and thus will need to ‘re-bid’ to obtain … Phase II location.] See also Letter from Allison M.
Jones, Counsel-Legal/Government Affairs, Sprint Corporation, to Marlene H. Dortch, Secretary, FCC, PS Docket
No. 07-114 (filed Sept. 30, 2013), at Attachment at 21 (stating that “Phase II location information calculation at the
PDE generally takes 15-20 seconds, but could take up to 30 seconds or more, and will not be available to the PSAP
until it is calculated.”).
298 See supra, Section III.B.3.a. i (proposing, for indoor accuracy testing, key performance attributes, including a
TTFF of a maximum 30 seconds to deliver location information meeting a horizontal accuracy standard of 50
meters).
299 See 47 C.F.R. § 20.18(h)(1)-(2) (for the currently specified accuracy standards for outdoor measurements only).
300 See supra, Section II.C para. 21 note 47 (using the term “location information center” to refer to either the MPC
or GMLC, depending on the carrier and type of network). Once the CMRS provider generates the location fix, it is
transmitted to the location information center, where it is available for retrieval by PSAPs through their initial
bidding or re-bidding process. See, e,g., Verizon Sept. 11, 2013 Ex Parte Letter, at 5 (stating that “the fix . . . is
transmitted to the third party vendor’s [Location Information Center] for retrieval by the PSAP via a bid to [the
PSAP’s] ALI Database, which, in turn, accesses the MPC”). See also Sprint Workshop Comments at 2-3
(describing the process for wireless carriers to transmit the Phase II location information to the MPC and then
PSAPs bidding to receive Phase II information or rebidding to update or verify the initial Phase II bid location
information); AT&T Sept. 9, 2013 Ex Parte Letter, Attachment B, at 2 (concerning the delivery of Phase II location
information to the GMLC and the bidding by a PSAP).
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commenters call for improvements in TTFF.301 Similarly, Mission Critical Partners emphasizes that
“[a]ny improvements to the yield, accuracy, and time to first fix (TTFF) of locations would be welcomed
by PSAPs nationwide.”302 The E911 Location Accuracy Workshop also shed light on the need for CMRS
providers to deliver Phase II location fixes with a level of accuracy and within a short time frame, e.g. 30
seconds, in order to be useful to PSAPs, depending on the re-bidding practices of each jurisdiction.303
145.
The record evidences trends and technological developments that may reduce the time in
which CMRS providers can obtain and transmit location fixes. First, as CSRIC notes and as discussed
above, there are ongoing developments in hybrid location technologies.304 As CMRS providers refine and
deploy hybrid technologies to achieve better location accuracy indoors, is it technically feasible for
providers to leverage those hybrid deployments for wireless 911 calls from outdoor environments to
achieve improved yield and TTFF? On the one hand, the record indicates that implementing hybrid or
“fall-back” location technologies may result in longer TTFFs and less accuracy. TruePosition asserts that
in challenging environments, whether outdoors or indoors, fall-back technologies are unlikely to deliver
Phase II compliant information as quickly as PSAPs need it.305 Typically, however, providers using A-
GPS have built their networks to deliver a location fix using hybrid location or “fall-back” technologies
only if their systems cannot obtain an A-GPS fix within a TTFF of 30 seconds.306 For example, Verizon
indicates that it has taken “steps … to improve the location information delivered to PSAPs,” such as
“[m]aking caller location information available within an average of 12-15 seconds, and within 25
seconds for 99 percent of all calls for which the information is available.”307 Will hybrid technologies,
complemented by beacon technologies, DAS networks, and small cells, make it possible to achieve
improvements in TTFF in challenging environments?
146.
The second major factor that is likely to improve the delivery of location information is
the migration by CMRS providers to 4G VoLTE networks, which the record indicates can achieve swifter
times to first fix.308 Consequently, we seek comment on how the migration to 4G VoLTE might affect a
requirement for the specific TTFF level that we propose as well as timetables for compliance.309

301 See NENA Workshop Comments, at 2-3 (concerning possible impact of indoor wireless calls on TTFF). See also
E911 Phase II Workshop webcast, morning session, at http://www.fcc.gov/events/workshop-e911-phase-ii-location-
accuracy.
302 Mission Critical Partners Workshop Comments at 1.
303 See E911 Phase II Location Accuracy Workshop webcast, afternoon session, available at
http://www.fcc.gov/events/workshop-e911-phase-ii-location-accuracy. See also Letter from Bruce A. Olcott,
Counsel for NexNav, LLC to Marlene H. Dortch, Secretary, FCC, PS Docket No. 07-114 (filed Dec. 23, 2013) at 3
(noting that at the workshop, public safety representatives said a view that “30 seconds is often too long to assist
911 operators because, rather than wait 30 seconds for Phase II location information, operators often spend the . . .
initial portion of an E911 call orally eliciting location information . . . .”).
304 See CSRIC Indoor Location Test Bed Report at 41 (detailing a hybrid solution by Qualcomm); see id. at 43
(detailing NextNav’s hybrid solution).
305 See TruePosition Workshop Comments at 2 (asserting that, in such cases, the information is not Phase II
equivalent and that Round Trip Time technology “will never deliver . . . more than Phase I-type information”).
306 See infra, Section IV.C (describing when a fall-back location mode is triggered). Providers using handset-based
location technologies, as well as providers using network-based technologies but deploying A-GPS capable
handsets, fall back to hybrid location fixes if a Phase II fix cannot be delivered to their respective location
information centers within a TTFF of 30 seconds.
307 See Verizon Dec. 19, 2013 Ex Parte Letter at 1 (emphasis in original) (referring to the improvements in the
context of “enhancing the A-GPS location accuracy solution for VoLTE in ways . . . , including coupling location
data from additional satellite systems (GLONASS) and OTDOA with GPS data.”).
308 See T-Mobile Workshop Comments at 19 (“[F]or pre-LTE radio access network technologies, any ‘hybrid’ of
location technologies must be run sequentially. This means that ‘fallback’ technologies (with less accuracy but
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147.
Further, we recognize that wireless 911 calls may terminate after a short period of time,
before CMRS providers’ networks can generate a location fix. Therefore, we propose to exclude wireless
911 calls that are dropped or disconnected in 10 seconds or less, and in which CMRS networks have not
yet delivered a location fix to the location information center, for purposes of determining compliance.
We seek comment on whether 10 seconds is the right cut-off for an exclusion for short calls.
Alternatively, should we base the exclusion on some other timeframe (e.g., should we instead exclude
calls shorter than 15 seconds, 20 seconds, or 30 seconds)? If we were to adopt an exclusion for short
calls, are there other measures to provide the best available information, even if the location information
is not a full Phase II fix? For instance, should CMRS providers share with PSAPs Class of Service (COS)
information, e.g., whether the location fix is Phase I- or Phase II-compliant, in order to alert PSAPs of
information that might not be Phase II-compliant but may be helpful in the emergency?310 For example,
the record indicates that with wider deployment of micro-cells, Phase I may be more helpful than PSAPs
have recently viewed it.311
148.
Additionally, we propose that, based on the outdoor testing procedures recommended by
WG3, CMRS providers should implement periodic testing procedures to ensure that they meet a TTFF
requirement.312 We seek comment on both the costs of implementing a 30-second TTFF, as well as for
compliance testing. We would expect providers to measure and test for such compliance with the
proposed TTFF at the appropriate point in their E911 networks. The record shows that CMRS providers
already test for and collect data on yield and TTFF.313 We seek comment on whether this would mitigate
any potential costs of compliance testing. We recognize that WG3 found that costs for testing can be
(Continued from previous page)
higher yield) run after a primary technology has been tried and failed. . . . This will change with LTE, for which the
industry standards allow multiple location technologies to be run simultaneously.”). See also E911 Phase II
Workshop webcast, morning session, at http://www.fcc.gov/events/workshop-e911-phase-ii-location-accuracy. See
also
T-Mobile Workshop Comments at 12 (submitting that the running of fall-back technologies “after a primary
technology has been tried” will be resolved “once LTE networks are rolled out, which allow multiple location
technologies to run concurrently”); Verizon Workshop Comments at 6 ( “911 calls from VoLTE handsets will
utilize Observed Time Difference of Arrival (‘OTDOA’) instead of AFLT as the network-based fallback location
technique,” and that OTDOA should outperform AFLT “due to higher LTE bandwidth . . . and more advanced
processing.”).
309 Concerning a potential timeframe for such requirements, with the imminent deployment by major providers of
4G VoLTE, it is reasonable to expect that 4G VoLTE will be widely deployed before the sunset of the network-
based standards. See infra, Section IV.D. (seeking further comment on revision of Commission’s existing E911
rules for outdoor calls).
310 See infra, Section IV.G (on confidential treatment of sharing testing results for periodic outdoor testing). Such
COS results could be aggregated and shared over a period of time with those PSAPs who do not collect it. Cf.
Sprint Workshop Comments at 4 (“The initial bid or call-set up that occurs on Sprint’s network will normally
include Phase I level data and this is typically provided to PSAPs in the Class of Service designation.”).
311 See e.g., Verizon Workshop Comments at 7 (“[I]ndoor small cell deployments . . . with a very small coverage
area, have the potential to provide very accurate location information via the equivalent of a ‘Phase I’ location fix.”)
(citing Qualcomm Aug. 2013 Ex Parte Letter, Attachment at 10-11); NextNav Workshop Comments at 14-15
(“[C]all routing on Phase I information may significantly narrow the performance differences noted by the
CalNENA report and the various carrier responses. . . . Such operational issues are arguably best resolved by a
cooperative effort of PSAPs and carriers to improve their procedures through automated rebidding and reduced time
intervals to provide Phase II information.”).
312 See infra, Section IV.G (on periodic outdoor testing).
313 See T-Mobile Workshop Comments at 21 (stating that it generates daily reports on data from its GMLC); Sprint
Workshop Comments at 5-6, n.8 (concerning Phase II data delivered to its MPC with respect to E911 service to five
California PSAPs); AT&T Sept. 9, 2013 Ex Parte Letter, Attachment B, at 2-3.
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high.314 We seek comment on whether this magnitude of costs is accurate. How would the cost ranges in
WG3’s data be affected by the transition to 4G VoLTE networks? Would the cost of TTFF
improvements likely be incorporated into the 4G network upgrades and the roll-out of 4G VoLTE?
Would costs decrease after providers have fully deployed such networks? Additionally, what would the
cost burdens be for the regional and smaller CMRS carriers who are also planning to migrate to 4G
VoLTE networks using A-GPS technologies, to meet and test for the proposed TTFF of 30 seconds?315
149.
Alternatively, we seek comment on whether voluntary efforts are sufficient to improve
latency, such that it is unnecessary to impose any additional regulations at this time. For instance, would
more frequent coordination between CMRS providers and PSAPs be sufficient to address concerns
regarding TTFF performance levels, without regulatory metric or testing requirements for TTFF?

B.

Confidence and Uncertainty Data

150.
Background. Our current rules require CMRS providers presently subject to the
Commission’s E911 requirements to provide confidence and uncertainty (C/U) data on a per-call basis
upon PSAP request.316 C/U data reflects the level of confidence that a specific 911 caller is within a
specified distance of the location that the carrier provides. Confidence data is expressed as a percentage,
indicating the statistical probability that the caller is within the area defined by the “uncertainty”
statistical estimate, while uncertainty is expressed as a radius in meters around the reported position.317
151.
The Commission has held that “[o]nce a [wireless service provider] has established
baseline confidence and uncertainty levels in a county, ongoing accuracy shall be monitored based on the
trending of uncertainty data and additional testing shall not be required.”318 However, WG3 subsequently
indicated that “uncertainty estimates on a call-by-call basis are not a reliable substitute for empirical
location accuracy testing.”319 Nevertheless, it also stated that “[u]ncertainty estimates . . . can indicate a

314 For instance, WG3 notes that the deployment of field test resources can range from $250 to $1000 per cell site,
and that, for testing systems with the capability to monitor Key Performance Indicators (KPIs) (such as latency with
respect to TTFF), the annual costs “to maintain reporting and data storage” range from $500,000 to $1,500,000 for a
large network. CSRIC Outdoor Location Accuracy Report at 27.
315 See CSRIC Outdoor Location Accuracy Report at 27 (also informing that some vendors have a per PSAP costing
structure that might charge from $50,000 to $150,000 per PSAP, regardless of the number of cell sites tested).
316 See 47 C.F.R. § 20.18(h)(3) (providing that “all carriers subject to this section shall be required to provide
confidence and uncertainty data on a per-call basis upon the request of a PSAP,” and that “[a]ll entities responsible
for transporting confidence and uncertainty between wireless carriers and PSAPs, including LECs, CLECs, owners
of E911 networks, and emergency service providers (collectively, System Service Providers (SSPs)) must
implement any modifications that will enable the transmission of confidence and uncertainty data provided by
wireless carriers to the requesting PSAP”).
317 See Public Safety and Homeland Security Bureau Reminds CMRS Providers of the January 18, 2013 Deadline
for Meeting the First Benchmark of the Commission’s Updated E911 Location Accuracy Rules, Public Notice, 28
FCC Rcd 253, 255 n.14 (PSHSB Jan. 16, 2013) (PSHSB E911 First Benchmark Notice) (citing E911 Location
Accuracy Second Report and Order
, 25 FCC Rcd at 18928-30 ¶¶ 50-55). The uncertainty estimate is expressed in
meters. For example, the E911 Phase II location information that CMRS providers provide to PSAPs is
accompanied by a 90 percent/35 meter “C/U score,” reflecting 90 percent confidence that the caller is within 35
meters of the estimated location. See E911 Location Accuracy Second Report and Order, 25 FCC Rcd at 18928-30
¶¶ 51-53.
318 See E911 Location Accuracy Second Report and Order, 25 FCC Rcd at 18928 ¶ 51.
319 CSRIC Outdoor Location Accuracy Report at 22.
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trend that may reflect continued proper system operation or system problems.”320 WG3 also has noted the
importance of C/U data in the testing context.321
152.
Public safety entities have indicated that C/U data play a meaningful role in assessing the
quality of the location information that accompanies a wireless 911 call. According to APCO, “many
PSAPs find [confidence and uncertainty] information to be invaluable in evaluating the location data
received with 9-1-1 calls.”322 NENA further explains that a “position reported with high confidence …
allow[s] responders to narrow the field of search and thus reduce the required search time and the number
of responders required and thereby the cost of responding to a given call”323 According to Intrado, “X/Y
[coordinates] should never be used alone,” but should always be combined with uncertainty
measurements.324
153.
The record also suggests, however, that C/U data is not always perceived as useful by
PSAPs. Following the Commission’s recent E911 Location Accuracy workshop, NextNav indicated that
“[w]orkshop participants acknowledged that the value of confidence and uncertainty information to
PSAPs has in the past been uncertain.”325 T-Mobile also indicated that “[c]onfidence level is suppressed
(not submitted to the PSAP) – per public safety request.”326 The record suggests that, to the extent public
safety entities do not request or use C/U data, it may be due to the variable way in which such information
is generated or presented. NENA explains:
Different location technologies in use today generate differing forms of confidence
and uncertainty measurements which can cause interpretation issues in PSAPs. This
in turn can affect real-time decision-making on caller location and response methods.
. . . Such differences complicate the training of call takers and the day-to-day
operation of PSAPs, impose unnecessary costs on local public safety agencies, and
can reduce the speed and efficiency with which response services are delivered.327
WG3 acknowledges that “disparate service providers and technologies report confidence and uncertainty
values differently,”328 but that “[u]ncertainty trending is still useful within a single service provider and
single technology environment.”329
154.
Given this lack of uniformity in the delivery of C/U data, NENA states that it is “critical
that the Commission establish a uniform standard for the delivery of such information to PSAPs and for

320 Id. at 22.
321 See id. at 39 (“in the context of location system testing in general (not only indoors) the results provide an
indication of how well a location system under test is performing in a certain environment”).
322 See APCO Further Notice Comments at 3.
323 See NENA Further Notice Comments at 5.
324 See Intrado Location Accuracy Workshop Presentation (Nov. 18, 2013) at 6, available at
http://transition.fcc.gov/bureaus/pshs/911/Phase%202/Workshop_11_2013/Intrado_Snapp_Nov2013.pdf (last
visited Feb. 18, 2014) (Intrado Workshop Presentation).
325 See NextNav Nov. 26, 2013 Ex Parte Letter at 7. NextNav further stated that “[s]ome carriers may collect but, at
the request of public safety, not transmit confidence level information to the PSAP.” Id.
326 See T-Mobile Location Accuracy Workshop Presentation (Nov. 18, 2013) at 3, available at
http://transition.fcc.gov/bureaus/pshs/911/Phase%202/Workshop_11_2013/T_Mobile_Nov2013_FINAL.pdf (last
visited Jan. 29, 2014) (T-Mobile Workshop Presentation).
327 See NENA Further Notice Comments at 6.
328 CSRIC Outdoor Location Accuracy Report at 22.
329 Id.
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the meaning of the data delivered.”330 NextNav suggests that “the Commission may wish to follow the
guidance of the ATIS Emergency Services Interconnection Forum (‘ESIF’), which recommends 90
percent be used as a standard required confidence level.”331 T-Mobile likewise indicates that this “90%
confidence level is recommended by ESIF and public safety.”332
155.
Discussion. We believe that C/U data is a critical component in helping PSAPs
understand the quality of the location information they receive from providers, whether the 911 calls are
made indoors or outdoors.333 We seek to develop a better understanding of why C/U data is not always
utilized by PSAPs. What are the problems PSAPs have encountered with its use? How could C/U data
be provided in a more helpful fashion?
156.
We also seek comment on NextNav’s suggestion to incorporate ESIF’s recommended 90
percent confidence level as a requirement.334 Is it important that all CMRS providers subject to
Commission’s E911 requirements use the same confidence level when calculating C/U data? If a
standard confidence level is desirable across Phase II data, is 90 percent the correct level? Why or why
not? Moreover, if not, should the Commission nevertheless still require CMRS providers to use the same
confidence level? If so, what should that level be and why? What potential costs would be associated
with implementing this requirement? In the event we establish a uniform confidence level, should CMRS
providers be required to demonstrate compliance with that confidence level to the FCC, and if so, how?
157.
We seek comment regarding the format in which C/U data is provided to the PSAPs.
What are the various formats in which this data is presently provided? Is the fact that horizontal
uncertainty is expressed either as a circle or an ellipse problematic?335 Should the Commission require
that C/U data be provided in a standard, uniform format? If so, what should that format be? What are the
potential costs involved in standardizing C/U data for all stakeholders involved? What additional
measures, if any, should the Commission could take to increase the usefulness of C/U data for PSAPs?
158.
Finally, we anticipate that any requirements we adopt regarding standardization of the
delivery and format of C/U data would apply in conjunction with the delivery of both indoor and outdoor
location information. Is there any reason why the format of C/U requirements should differ for indoor
versus outdoor calls? We seek comment on this issue as well.

C.

Identifying the Type of Technology Used to Deliver the E911 Location Fix

159.
Background. Typically, when a wireless caller initiates a call to 911, CMRS providers
first attempt to locate the caller using A-GPS.336 However, GPS signals may be blocked in certain

330 See NENA Further Notice Comments at 6.
331 See NextNav Nov. 26, 2013 Ex Parte Letter at 7.
332 See T-Mobile Workshop Presentation at 3.
333 Our current rules require providers to furnish C/U data on per-call basis upon the request of a PSAP. These
requirements would extend to any proposed indoor location accuracy requirements. In any case, as a practical
matter, because providers and PSAPs do not distinguish between wireless 911 calls that originate indoors versus
outdoors, providers must, by necessity, provide C/U data for all calls.
334 See NextNav Nov. 26, 2013 Ex Parte Letter at 7.
335 See Sprint Location Accuracy Workshop Presentation (Nov. 18, 2013) at 9, available at
http://transition.fcc.gov/bureaus/pshs/911/Phase%202/Workshop_11_2013/Sprint_No2013_FINAL.pdf (last visited
Feb. 18, 2014) (Sprint Workshop Presentation).
336 See Verizon Sept. 11, 2013 Ex Parte Letter at 5 (describing Verizon Wireless’s A-GPS solution, which firsts
attempts to generate location based on GPS only, then a hybrid of GPS and AFLT, and then a pure AFLT attempt);
Letter from John Nakahata, Counsel to T-Mobile USA, Inc., to Marlene H. Dortch, Secretary, FCC, PS Docket No.
07-114 (filed Sept. 27, 2013) at 1 (“For 911 calls placed using A-GPS capable handsets (the substantial majority of
T-Mobile 911 calls), T-Mobile first attempts to obtain an A-GPS fix.”) (T-Mobile Sept. 27, 2013 Ex Parte Letter);
TruePosition Workshop Reply Comments at 4 (stating that “the primary technology currently relied upon by the
(continued….)
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environments, compromising the accuracy and reliability of GPS technology.337 In the event that A-GPS
fails to provide a sufficiently accurate location fix within the 30 second timeframe recommended in OET
Bulletin 71,338 CMRS providers then rely on “fall-back” technologies, which provide location information
that may be less accurate.339 The record shows that providers using network-based location solutions also
first attempt to locate callers with GPS-capable handsets using A-GPS, but then “fall back” if necessary to
a hybrid of A-GPS and Round Trip Time (RTT), which calculates the distance between the handset and
the nearest base station, and subsequently, will attempt a location fix using RTT only.340
160.
Each location technology presents a trade-off between accuracy and latency. For
example, though A-GPS can locate wireless 911 callers within 10-20 meters, it is dependent on whether
the device can reach four or more satellites,341 and it often takes 30 seconds or more to generate a precise
location, though shorter times are possible.342 On the other hand, a location fix via RTT may provide
location information within a short period of time, but is significantly less accurate.343
161.
Discussion. To ensure that PSAPs can understand and make educated assessments
regarding the quality of Phase II location information, we seek comment on whether to require CMRS
providers to identify the technology used to determine a location fix and to provide this information to
PSAPs that have the capability to receive this information. We seek comment regarding the technical
feasibility of determining the type of technology used to identify a caller’s location on a call-by-call basis.
What potential costs might a provider incur to implement a requirement that it differentiate between the
types of technology used to provide a location fix?
162.
We also seek comment on the usefulness of this additional information to PSAPs, and
whether the benefits of this information would exceed any potential costs that might be necessary to make
use of this information. If PSAPs were aware of the type of location fix received, would they be able to
assess whether it is necessary to re-bid for better location information? To what extent would C/U data
(Continued from previous page)
carriers for the vast majority of their customers to calculate a Phase II compliant location” is AGPS); TruePosition
Location Accuracy Workshop Presentation (Nov. 18, 2013) at 2, available at
http://transition.fcc.gov/bureaus/pshs/911/Phase%202/Workshop_11_2013/TruePosition%20FCC%20briefing%201
1-18-2013.pdf (last visited Dec. 19, 2013) (noting that “[c]arriers have come to rely on AGPS for primary E-911
location”) (TruePosition Workshop Presentation).
337 Some CMRS providers report an A-GPS failure rate of approximately 20 percent, much of which results from
location attempts for wireless callers who are indoors. See AT&T Workshop Comments at 4; Verizon Workshop
Comments at 4. See also TruePosition Workshop Reply Comments at 8.
338 OET Bulletin No. 71 at 4 (“An acceptable time limit for such testing [of location accuracy] is 30 seconds after the
call is sent.”).
339 For example, a handset-based provider may attempt to generate Phase II location information by using, in order:
(1) A-GPS, when four or more satellites are within view of the device; (2) a hybrid of A-GPS and Advanced
Forward Link Trilateration (AFLT), which combines GPS information from available satellites (fewer than four)
with cell-tower AFLT; and (3) AFLT by itself. Verizon Sept. 11, 2013 Ex Parte Letter at 5. TruePosition also notes
that “fall-back technologies currently employed by the wireless carriers do not meet the FCC Phase II accuracy
requirements.” TruePosition Workshop Reply Comments at 9.
340 T-Mobile Sept. 27, 2013 Ex Parte Letter at 1; AT&T Sept. 9, 2013 Ex Parte Letter at 9 (noting its use of RTT as
fallback technology); TruePosition Workshop Reply Comments at 9.
341 TruePosition Workshop Presentation at 2 (noting that GPS signals are often compromised in indoor
environments, resulting in fallback location fixes which can be highly inaccurate).
342 Verizon Sept. 11, 2013Ex Parte Letter at 5 (noting that a precise Phase II fix via GPS can take up to 30 seconds
but in most instances is generated within 12-15 seconds but can be generated in as few as 5 seconds).
343 See T-Mobile Workshop Comments at 12 (describing RTT as a “medium accuracy solution”); TruePosition
Workshop Comments at 2 (asserting that RTT “will never deliver anything more than Phase I-type information”).
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already reflect sufficient information on this score, since that data would generally reflect discounted
certainty? Could existing information fields be used to display information on the type of location fix
that? If not, would it be possible to add an information field to the PSAP console with a software update,
or would more substantial upgrades of hardware or CPE be necessary? Could CPE be programmed to
automatically rebid if it receives Phase II location information from a fall-back technology? We seek
comment on whether and to what extent PSAPs might need to reconfigure their call-taking processes and
console displays in order to make use of this information, and whether the benefits of receiving this
information would outweigh any costs that might be entailed.

D.

Updating the E911 Phase II Requirements Based on Outdoor Measurements

163.
Background. Among other actions, in 2010 the Commission required CMRS providers to
satisfy location accuracy requirements over an eight-year implementation period, ending in 2019, with
interim benchmarks.344 At that time, certain CMRS providers exclusively used network-based location
technology to identify Phase II location.345 Accordingly, the Commission established E911 requirements
and exclusions specific to network-based providers, and provided a path by which these providers would
eventually migrate to handset-based technologies.346 The Commission agreed with T-Mobile that “[a]s
carriers transition to A-GPS, they will also transition from network-based accuracy standards to handset-
based standards, moving toward a de facto unified standard.”347 Because it had recently adopted the
existing E911 benchmarks, however, the Commission decided in the E911 Location Accuracy Third
Report and Order
that it was premature to seek comment on a sunset date,348 but tentatively concluded
“that the network-based standard should sunset at an appropriate point after the end of the eight-year
implementation period.”349
164.
Discussion. We seek comment on whether there have been sufficient advancements in
technology and a sufficient number of handsets with A-GPS capabilities in the consumer subscriber base
to warrant modification of our existing Phase II requirements as they apply to outdoor calls. We note that
CMRS providers are increasingly turning to handset-based technologies, namely A-GPS, to provide E911
Phase II information, which would support a more granular location accuracy requirement. When the
current rules were adopted, the CMRS providers that used network-based location technology on their
GSM networks had already begun to migrate to 4G and LTE networks, using handset-based location
technologies.350 These CMRS providers have continued to migrate away from networks requiring
network-based location technology.351 We also note that nearly all handsets are now GPS-enabled.352

344 See E911 Location Accuracy Second Report and Order, 25 FCC Rcd at 18947, Appendix C.
345 See id. at 18920 ¶ 30 (noting that “network-based providers will be unable to meet the new proposed county-level
accuracy standards in all areas relying solely upon current network-based technology solutions”).
346 Id. at 18920, 18927-28 ¶¶ 29, 48-49.
347 Id. at 10082 ¶ 18.
348 Id. at 10081 ¶ 16.
349 Id. at 10083 ¶ 21.
350 Id. at 10081 ¶ 17 (“the record in this proceeding clearly signals that the wireless industry is engaged in a broad
migration away from the dichotomy between network- and handset-based approaches to location accuracy. Current
handset-based carriers are increasingly combining A-GPS technologies with refinements based on location
determinations using network-based technologies.”).
351 See, e.g., Letter from Jamie Tan, Director, Federal Regulatory, AT&T, to Marlene Dortch, Secretary, FCC, PS
Docket No. 07-114 (filed Jan. 31, 2014), at 1 (as of Jan. 31, 2014, AT&T considers itself a handset-based carrier)
(AT&T Jan. 31, 2014 Ex Parte Letter); AT&T Sept. 9, 2013 Ex Parte Letter, Attachment A at 9 and Attachment B
at 2 (noting, respectively, a “steady migration toward AGPS” and describing how AT&T began deploying AGPS
throughout its networks partially in response to criticisms from public safety about poor E911 performance).
Additionally, in 2012, AT&T announced that it would fully discontinue service on its 2G/GSM networks by January
(continued….)
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165.
The record suggests that the migration to handset-based technologies can provide more
accurate location fixes.353 In response to the E911 Phase II Location Accuracy Workshop, King County
submits that “[i]n particular, the wireless carriers that use a network-based location technology that have
recently added [A-GPS] location technology to their Phase II solutions have shown dramatic
improvement in accuracy since 2005.”354 AT&T adds that the migration to A-GPS has resulted in
“increased accuracy in the Phase II location information provided, especially in rural areas where the
number and location of cell sites made trilateration-based location data less reliable,” as well as in lower
costs.355 On the other hand, TruePosition contends that “[t]here is no direct relationship between a
carrier’s transition from 2G to 3G or 4G network technology and . . . the E911 location accuracy that the
same carrier can deliver.”356 In any case, the record indicates that CMRS providers and technology
vendors have been working steadily to improve A-GPS performance.357
166.
In particular, and in light of any recent improvements or advancements in A-GPS
technology, we seek comment on whether all CMRS providers reasonably could comply with a 50-meter
accuracy/67 percent reliability requirement within two years, such that we could adopt a unitary
requirement for both indoor and outdoor calls. Establishing such a unitary requirement for all calls would
help standardize the information afforded to public safety entities while raising the level of accuracy
(Continued from previous page)
2017. See AT&T SEC Form 10-Q (Nov. 2, 2012) at 21, available at
http://www.sec.gov/Archives/edgar/data/732717/000073271712000088/q3_10q.htm (last visited Feb. 5, 2014). See
also
Fitchard, Kevin, “AT&T Starts Replacing 2G with HSPA in NYC,” GIGAOM (May 23, 2012), available at
http://gigaom.com/2012/05/23/att-starts-replacing-2g-with-hspa-in-nyc/ (last visited Jan. 24, 2014); Fitchard, Kevin,
“T-Mobile Pounds the First Nail in 2G’s Coffin,” GIGAOM (Feb. 23, 2012), available at
http://gigaom.com/2012/02/23/t-mobile-pounds-the-first-nail-in-2gs-coffin/ (last visited Jan. 24, 2014).
352 See Lendino, Jamie, “How to Find the Right GPS App for Your Phone,” PC Mag (May 29, 2012), available at
http://www.pcmag.com/article2/0,2817,2363154,00.asp (last visited Jan. 27, 2014); E911 Location Accuracy Second
Further Notice
, 26 FCC Rcd at 10083 ¶ 21 (stating that, in 2010, “almost all 2G and 3G handsets shipped by
manufacturers were equipped with GPS-chips”); Zandbergen, Paul, “Accuracy of iPhone Locations: A Comparison
of Assisted GPS, WiFi and Cellular Positioning,” 13 Transactions in GIS s1 (2009), pp. 5-26, at 6, available at
http://www.paulzandbergen.com/PUBLICATIONS_files/Zandbergen_TGIS_2009.pdf (last visited Jan. 29, 2014)
(Zandbergen Article) (noting that, in 2009, “[m]ost newer model cell phones are GPS-enabled.”); Berg Insight,
“GPS and Mobile Handsets,” (2009) available at http://www.berginsight.com/ReportPDF/ProductSheet/bi-gps4-
ps.pdf (last visited Jan. 24, 2014) (estimating that GPS sales would reach about 960 million, or 60 percent of total
handset shipments, in 2014).
353 T-Mobile Workshop Comments at 11, 17 (noting that “accuracy is much higher and uncertainty is lower when A-
GPS produces a location estimate,” and “A-GPS results are typically highly accurate”); AT&T Sept. 9, 2013 Ex
Parte
Letter, Attachment B at 2 (describing AT&T’s switch to AGPS “because of [its] greater accuracy”).
354 King County Workshop Comments, at 5.
355 AT&T Workshop Comments at 5; see also iCERT Workshop Comments at 4.
356 TruePosition Workshop Comments at 3. TruePosition asserts that “[t]he variable is the location technology that
the carrier chooses,” and that “the fall-off associated with increased latency and indoor inaccuracy” results from
certain providers’ decision to transition from UTDOA for GSM to A-GPS. Id. at 3. UMTS is an acronym for
Universal Mobile Telecommunications System – “a third generation mobile cellular system for networks based on
the GSM standard” but using “wideband code division multiple access (W-CDMA) . . . technology to offer greater
spectral efficiency and bandwidth . . . .” See
http://en.wikipedia.org/wiki/Universal_Mobile_Telecommunications_System (last visited Oct. 24, 2013).
357 See Qualcomm Second Further Notice Comments at 8-9 (noting Qualcomm’s efforts in 2011 to enhance A-GPS
and AGNSS technology); Verizon Workshop Comments at 1-4, citing Qualcomm Aug. 15, 2013 Ex Parte Letter at
4-5 (stating that Verizon has been working to improve GPS chipset sensitivity and to update its network databases to
generate more accurate fixes using hybrid and AFLT ); T-Mobile Workshop Comments at 11 (stating that “A-GPS’
ability to obtain a fix indoors has been improving over time, with technology and algorithmic advances in both the
handset and network components.”).
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across all calls, both indoors and outdoors. Would it be feasible for all CMRS providers to comply with a
50-meter accuracy/67 percent reliability (single search ring) requirement in two years? Or is there a
benefit in continuing to allow a dual search ring requirement? In the event we were to sunset network-
based requirements in two years and require a 50-meter accuracy requirement (with either an 80 percent
or 67 percent reliability requirement), should we adopt any exceptions for certain providers who might be
adversely affected, such as smaller or rural CMRS providers, or allow them a longer implementation
timeframe? Alternatively, would our existing waiver process be sufficient?

E.

Monitoring E911 Phase II Call Tracking Data

167.
Background. According to APCO, “Phase II information sometimes lacks sufficient
accuracy to ensure a rapid and efficient emergency response.”358 As discussed earlier in this Third Further
Notice
, CALNENA filed E911 call tracking data with the Commission that suggests there may be a
decline in the percentage of wireless 911 calls that include Phase II location information.359 In addition,
several other state and local public safety entities filed similar E911 call tracking data, also suggesting a
potential decline in the percentage of wireless calls that include Phase II location information.360 As noted
above, however, various providers responded that CALNENA’s reports mischaracterized the E911 data,
and suggest that PSAPs are not rebidding to obtain, or “pull” the location data.361
168.
The record provides insight on PSAPs’ ability to collect and monitor Phase II
performance data. For example, APCO notes that PSAP monitoring of Phase II data can be very costly
depending on the method utilized,362 and “many smaller PSAPs may not have the expertise or the funding
to compile detailed statistics concerning performance.”363 In another example, NENA comments that “all
analytical systems deployed by 9-1-1 authorities lack visibility into the internal process of carrier
networks, in many cases, to those of the 9-1-1 system service providers on which the PSAPs and
authorities depend.”364 Consequently, the same data may be subject to different interpretations.365
Alternatively, CalOES states that California PSAPs are able to monitor Phase II performance on an
individualized basis, because there is “a statewide enterprise call tracking management information
system to collect, analyze, and monitor various call performance measure.”366
169.
Discussion. We seek comment on whether the Commission should require providers to
periodically report E911 Phase II call tracking information, similar to the call data provided in

358 APCO Workshop Comments at 3.
359 See CALNENA Ex Parte Letter; see also supra Section II.C.
360 NENA Workshop Comments at 2 (stating that “NENA’s members report having noticed a decrease in the
fraction of wireless call for which Phase II location data is available early in the call.”) (emphasis in original). But
see
King County Workshop Comments at 8 (stating that “the percentage of wireless 911 calls with Phase II location
has remained fairly constant over the past five years.”). Phase II 911 Call Tracking Data submitted by certain states
and public safety entities to the Commission is available at http://www.fcc.gov/encyclopedia/phase-2-data-sets.
361 See AT&T Workshop Comments at 4; Sprint Workshop Comments at 6; T-Mobile Workshop Comments at 24;
Verizon Sept. 11, 2013 Ex Parte Letter at 2.
362 APCO Workshop Comments at 4.
363 Id.
364 NENA Workshop Comments at 2 (emphasis in original).
365 Id. (noting that AT&T capably explains this discrepancy). According to AT&T, the difference in their
interpretation of data and CALNENA’s interpretation of data can be explained as a difference of vantage points. See
AT&T Sept. 9, 2013 Ex Parte Letter, Attachment B at 2.
366 CalOES Workshop Comments at 2.
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conjunction with the recently held E911 Location Accuracy Workshop.367 Would such a requirement help
promote the delivery of Phase II E911 information? In the event we were to require periodic reporting of
Phase II E911 call tracking data, 368 we seek to implement a requirement that provides meaningful data
while minimizing the potential burden on providers. We seek comment regarding the scope of
information required in the reports. What information should be provided in Phase II call tracking
reports? How frequently should providers be required to report Phase II E911 call tracking data? We
also seek comment on any alternative measures that could ensure that providers are delivering Phase II
E911 information. Could we rely instead on periodic certifications of compliance with Commission
requirements based on the test bed or alternative measurements described above? Are there other ways
that the Commission could monitor Phase II E911 data without imposing a requirement on CMRS
providers?
170.
We realize that a reporting requirement would impose a cost on providers. We seek
comment on the estimated costs of such a requirement. Could existing call monitoring mechanisms be
leveraged for this purpose? We also seek estimates regarding how these costs might vary, depending on
the nature of the reporting obligations and the size of the representative sample of the provider’s coverage
area that is subject to these requirements.

F.

Monitoring and Facilitating Resolution of E911 Compliance Concerns

171.
Our objective in proposing indoor location accuracy requirements, as well as testing
metrics and reporting requirements, is to ensure that public safety providers have consistent and reliable
access to accurate location information on a call-by-call basis, as well as for the Commission and public
safety entities to have sufficient information to monitor E911 performance more generally. Filings
submitted in conjunction with the E911 Location Accuracy workshop, as well as statements made at the
workshop itself, indicate there have been instances in which public safety believes it is receiving
inadequate location information and where the Commission can help foster a dialogue between CMRS
providers and public safety entities to help address PSAP concerns and promote a better understanding of
E911 practices.369 We seek comment on whether we should establish a separate process by which PSAPs
or state 911 administrators could file an informal complaint specific to the provision of a CMRS
provider’s E911 service, and if so, how the complaint procedure should be structured in light of our
existing informal complaint process.370 We propose that, in connection with the filing of any informal
complaint, PSAPs 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.
172.
We also recognize that public safety organizations such as NENA or APCO might be
well-suited to monitor and facilitate resolution of PSAP concerns. We seek comment on additional
measures the Commission could take to help facilitate discussion and the swift resolution of public safety
concerns, whether it is through establishment of an informal Commission process or through continued
coordination with public safety organizations such as NENA or APCO.

367 A webcast of the E911 Location Accuracy Workshop is available at http://www.fcc.gov/events/workshop-e911-
phase-ii-location-accuracy (last visited Feb. 19, 2014). See also Public Safety and Homeland Security Bureau
Announces Availability of Webcast and Additional Materials from November 18, 2013 Workshop on E911 Phase II
Location Accuracy, Public Notice, PS Docket No. 07-114, DA 13-2226 (rel. Nov. 20, 2013).
368 See infra, Section IV.G.
369 As discussed above, the workshop highlighted the need for PSAPs to re-bid, in order to obtain Phase II location
information and provided additional information regarding the latency issues inherent in producing a first location
fix using A-GPS. See supra Section IV.A. A webcast of the E911 Phase II Location Accuracy Workshop is
available at http://www.fcc.gov/events/workshop-e911-phase-ii-location-accuracy (last visited Jan. 23, 2014).
370 See 47 C.F.R. § 1.716.
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G.

Periodic Outdoor Compliance Testing and Reporting

173.
Background. In the 2010 E911 Location Accuracy Second Report and Order, the
Commission held that “[o]nce a wireless service provider has established baseline confidence and
uncertainty levels in a county or PSAP service area, ongoing accuracy shall be monitored based on the
trending of uncertainty data and additional testing shall not be required.”371 In the 2011 E911 Location
Accuracy Third Report and Order
, however, the Commission found that periodic testing “is important to
ensure that test data does not become obsolete as a result of environmental changes and network
reconfiguration.”372 The Commission tasked CSRIC with the “making recommendations concerning cost-
effective and specific approaches to testing requirements, methodologies, and implementation timeframes
. . , including appropriate updates to OET Bulletin 71, issued in 2000.373
174.
The Commission stated that it will require CMRS providers to test outdoor location
accuracy compliance on a periodic basis and make the results available to the Commission, PSAPs within
their service areas, and state 911 offices in the states or territories in which they operate, subject to
confidentiality safeguards.374 However, the Commission also stated that specific testing requirements and
procedures would not become mandatory until the Commission sought comment on CSRIC’s
recommendations.
175.
CSRIC’s Outdoor Location Accuracy Report examined several issues concerning testing
methodologies and procedures and concluded that technical reports issued by ATIS since the publication
of OET Bulletin No. 71 provided more useful, updated methods for CMRS providers to conduct initial
and periodic testing.375 Based on the ATIS technical reports, CSRIC Working Group 3 (WG3) made
several recommendations for both initial testing376 and periodic testing.377
176.
Further, WG3 found that several standards adopted by ATIS since the issuance of OET
Bulletin No. 71 “generally provide more current and relevant procedures and guidelines than are available

371 See E911 Location Accuracy Second Report and Order, 25 FCC Rcd at 18928 ¶ 51.
372 See E911 Location Accuracy Third Report and Order, 26 FCC Rcd 10088 ¶ 36.
373 See id. at 10089 ¶ 37. See also OET Bulletin No. 71, available at
http://transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet71/oet71.pdf. The Commission
indicated that it would seek comment on CSRIC’s recommendations prior to implementing specific testing
requirements and procedures. See E911 Location Accuracy Third Report and Order, 26 FCC Rcd at10089 ¶ 37.
The Commission also noted that disclosure of such test results would enable it “to monitor trends in location
accuracy and thereby ensure that its regulations are appropriately tailored to enhance location accuracy without
imposing unnecessary costs or administrative burdens.” Id. at 10088 ¶ 36.
374 Id.. at 10088 ¶ 34.
375 See CSRIC Outdoor Location Accuracy Report at 15; ATIS-0500001, High Level Requirements for Accuracy
Testing Methodologies (2011) (finding that ATIS-0500001 “focuses on providing a set of minimum technical
requirements for testing location accuracy of a typical network deployment of positioning technologies for wireless
E9-1-1 services in order to assess FCC compliance.”); CSRIC Outdoor Location Accuracy Report at 16 (describing
ATIS 0500010, Maintenance Testing (ATIS Maintenance Testing Report (2006) as “a useful technical foundation
for maintenance testing . . . .”). See also CSRIC Outdoor Location Accuracy Report at 16, 24-25.
376 See id. at 24. More recently, ATIS has stated that “[i]nitial compliance at the county- or PSAP-level needs to be
established through empirical data collection methods that include ground truth and actual error measurements
pursuant to the Commission’s rules.” See Letter, Thomas Goode, General Counsel, ATIS, to Jeffrey Goldthorp,
Chief, Communications Systems Analysis Division, Public Safety and Homeland Security Bureau, FCC, PS Docket
07-114 (filed Apr. 12, 2012), at 2 (ATIS Apr. 12, 2012 Ex Parte Letter).
377 See id. at 24-25 (recommending that periodic testing include the following alternative testing methods: predictive
testing, incremental testing, reduced empirical data sample size, key performance indicator (KPI) monitoring, testing
in representative environments, and empirical spot-checking).
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in OET 71.”378 WG3 made several recommendations for performance and maintenance testing, including
“key performance indicators” (KPIs) that CMRS providers would “routinely monitor and archive” to
assess system performance and determine “when further testing and system improvements are needed at
the local level.”379 WG3further indicated that, while the costs for empirical testing can be expensive,380
alternative techniques, such as monitoring KPIs, are more cost-efficient.381
177.
The comments received in response to the workshop show that both public safety entities
and CMRS providers agree that higher Phase II yield levels are desirable in order to ensure that public
safety entities receive the benefits of Phase II location information. Further, the E911 Location Accuracy
Workshop showed that yield can be a useful tool for assessing how well a particular location technology
performs in various challenging environments.382
178.
Discussion. Consistent with the Commission’s reasons and conclusions in the E911
Location Accuracy Third Report and Order, we believe that periodic testing is necessary as providers
upgrade their networks and migrate to handset-based technologies.383 We seek comment on the
recommendations in WG3’s report. We also invite industry and public safety stakeholders to submit a
consensus proposal that addresses WG3’s recommendations, and that provides a technically feasible path
forward for periodic compliance testing and reporting. The CSRIC Outdoor Location Accuracy Report
identifies a suite of five ATIS technical reports,384 and we seek comment on whether these reports
collectively represent the best practices for outdoor location accuracy.385 The CSRIC Outdoor Location

378 See id. at 4. See also ATIS Technical Report 0500001- High Level Requirements for Accuracy Testing
Methodologies (July 2004); ATIS Technical Report 0500010- Maintenance Testing (Feb. 2007).
379 See id. at 5; 22-23 (reporting that “[a]verage local latency values for a given location technology are typically
well-behaved and don’t normally vary significantly . . . “ but noting that “[i]ncreases in average latency can serve as
a trigger for investigation”). Network latency affects the time in which a carrier can generate and deliver a location
fix to the MPC/GMLC of the carrier. WG3’s KPIs also include uncertainty estimate trends. See id. at 22.
380 See id. at 26 (stating that “[e]mpirical testing methods are highly reliable, but not necessarily cost effective if
applied repeatedly at a PSAP or county level”).
381 See id. at 10.
382 See APCO Workshop Comments at 4 (submitting that “yield’ is extremely important as it would provide a more
useful evaluation of the location information that is provided for all wireless calls to 9-1-1” and that “accuracy
performance testing should include a consideration of ‘yield’”); NENA Workshop Comments at 3 (also stating that
“the Commission’s current rules … largely leave the question of what qualifies as a valid Phase II fix up to the
discretion of each carrier.”); T-Mobile Workshop Comments at 17 (stating that “[i]ndoor environments tend to
reduce yield” and that various factors, like the “length of the 911 call[,]” and “the specific nature of the indoor
environment, including the amount of RF attenuation and level of multipath (RF reflections)” can adversely affect
the yield level). See generally T-Mobile Workshop Comments at 21 (noting that T-Mobile “generates other KPI
[Key Performance Indicator] reports from other systems to look at specific E911 parameters like yield . . . ”).
383 See E911 Location Accuracy Third Report and Order, 26 FCC Rcd at 10088 ¶ 34 (stating that “requiring CMRS
providers to periodically test their outdoor location accuracy… is important to ensure that…location accuracy
requirements are being met”; and that “[t]he lack of available data has also made it difficult to assess the effects of
emerging technologies on location accuracy results….”).
384 See CSRIC Outdoor Location Accuracy Report at 4 (ATIS Technical Report numbers 0500001 (High Level
Requirements for Accuracy Testing Methodologies), 0500009 (High Level Requirements for End-to-End Functional
Testing), 0500011 (Define Topologies & Data Collection Methodology), 0500010 (Maintenance Testing), and
0500013 (Approaches to Wireless Indoor Location).
385 This ATIS standard, as well as other ATIS standards discussed in this proceeding, will be available for review
and download on the ATIS website during the pendency of the period for filing comments. See
http://www.atis.org/fcc/locationaccuracy.asp (last visited Feb. 14, 2014). Paper copies will also be available for
review (but not photocopying) at Commission headquarters upon request by contacting Dana Zelman at 202-418-
(continued….)
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Accuracy Report also identifies several alternative testing concepts developed in ATIS-05000010 to
provide a useful technical foundation for maintenance testing.386 The record demonstrates that providers
already have processes in place that are capable of testing for yield and TTFF.387 Should the Commission
consider any other alternative testing concepts not included in ATIS-05000010? To the extent we adopt a
rule specifying that a particular ATIS technical standard, methodology, or suite of ATIS technical
standards should be used by CMRS providers for purposes of periodic maintenance testing of outdoor
location accuracy, we propose to accommodate future updates of that standard by delegating rulemaking
authority to the Chief of the Public Safety and Homeland Security Bureau. We seek comment on this
approach.
179.
In addition, WG3 recommends that “[a]lternative testing methods replace full compliance
testing every” 24 months.388 We seek comment on whether 24 months is an appropriate timeframe for
conducting periodic tests. We also invite comment on what enforcement mechanisms would be
appropriate to ensure compliance with any required timeframe for periodic testing.
180.
Finally, we recognize that our current rules allow the monitoring of ongoing accuracy
based on the trending of uncertainty data.389 We propose to remove this provision, in light of our
proposed periodic testing requirement. As NENA has noted, confidence and uncertainty trends are not
sufficient proxies for location accuracy testing because “[r]eported confidence and uncertainty data are
themselves subject to systemic error.”390 We seek comment on this proposal.
181.
Reporting Requirements and Confidentiality Safeguards. We recognize that imposing
reporting requirements may implicate CMRS providers’ proprietary information.391 Accordingly, we seek
comment on what safeguards should be implemented to ensure that confidential information is protected.
Under the CSRIC indoor test bed regime, all parties agreed that raw results would be made available only
to the vendors whose technology was to be tested, participating wireless providers, and the third-party
testing house; only summary data was made available to other parties.392 Would it be sufficient for
CMRS providers to report only summary data to the Commission, PSAPs within their service areas, and
state 911 offices in the states or territories in which they operate, in order to demonstrate compliance with
the Commission’s requirements? If so, what data should be included in the summary? We seek comment
on whether public safety’s need for improvements in yield and TTFF components supports the inclusion
of specific reporting metrics, such as those that WG3 described in its Outdoor Location Accuracy
Report
.393 Given the extent to which mobile wireless communications services are becoming increasingly
(Continued from previous page)
0546 or dana.zelman@fcc.gov. To request materials in accessible formats for people with disabilities (braille, large
print, electronic flies, audio format), send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental
Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (TTY).
386 See CSRIC Outdoor Location Accuracy Report at 20-21.
387 See T-Mobile Workshop Comments at 21 (concerning the generation of daily reports from its GMLC and that of
other [KPI] reports from other systems, which look at specific E911 and location technology parameters, such as
yield and uncertainty estimate trends”). See also Verizon Ex Parte (filed Sept. 11, 2013) at 5 (submitting that “in
Verizon Wireless’s experience the caller’s location is calculated within 12-15 seconds on average”).
388 See CSRIC Outdoor Location Accuracy Report at 25.
389 See 47 C.F.R. § 20.18(h)(3).
390 See NENA Reply to T-Mobile Ex Partes, PS Docket No. 07-114, WC Docket No. 05-196 (filed July 5, 2011), at
2 (NENA Reply to T-Mobile).
391 E911 Location Accuracy Third Report and Order, 26 FCC Rcd 10088 ¶ 36.
392 See CSRIC Indoor Location Test Bed Report at12.
393 See CSRIC Outdoor Location Accuracy Report at 27 (observing that performance testing systems afford the
capability to monitor KPIs, including yield and latency).
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central to the day-to-day lives of Americans, should this data also be available, at least to some extent, to
the public?394 If so, what data would be useful to the public? For instance, would public disclosure of
location accuracy test results provide consumers with a reasonable “yardstick” regarding competing
providers’ abilities to provide Phase II location information in the counties or PSAP service areas where
they are likely to make a wireless 911 call?395 Finally, should the confidentiality safeguards in this regard
mirror those that we might adopt in relation to the indoor location accuracy compliance testing
requirement?396

H.

Roaming Issues

182.
In the 2007 E911 Location Accuracy Notice and the 2010 E911 Location Accuracy
Further Notice and NOI, the Commission sought comment on location accuracy while roaming.397 The
Commission expressed concern that “a wireless caller whose carrier employs one type of location
technology may not be provided Phase II service at all when roaming on the network of another carrier
that relies on a different technology, or when there is no roaming agreement between carriers using
compatible technologies.”398 In 2011, CSRIC II’s Working Group 4C similarly noted that “[t]he ability to
support Phase II location for roamers may be limited in some carriers’ networks.”399
183.
We seek comment on whether the provision of Phase II information for roamers
continues to be a concern, or whether this concern has been addressed by the evolution of location
technology since the Commission last examined this issue. In comments responding to the E911
Location Accuracy Further Notice and NOI
, NENA noted that “carriers are now migrating to network-
assisted GNSS positioning solutions, though not all carriers have yet adopted this technology,” and asked
the Commission to “seek input from carriers on how best to ensure that E9-1-1 calls in a roaming
environment are completed.”400 AT&T indicated that “at least in the case of GSM carriers, there is no
clear problem in locating roamers that requires a regulatory solution,” and stated that it “can support
locating roaming handsets as long as the handsets support compatible spectrum.’”401 Verizon similarly
stated that it can provide Phase II location for all Code Division Multiple Access (CDMA) roamers using
location-capable handsets “in the same manner as for our subscribers.”402 However, Verizon also noted
that it is unable to provide Phase II location capability to customers using handsets that are not location-
capable (i.e., without a GPS chip) or that use a different air interface.403

394 See, e.g., Improving the Resiliency of Mobile Wireless Communications Networks; Reliability and Continuity of
Communications Networks, Including Broadband Technologies, PS Docket 13-239; PS Docket 11-60, Notice of
Proposed Rulemaking
, FCC 13-125 at paras. 13-14 (rel. Sept. 27, 2013) (Resiliency of Mobile Wireless
Communications Networks NPRM
) (discussing benefits of public disclosure of data on the resiliency of mobile
wireless networks, including increasing competitive pressure to encourage providers to significantly harden their
networks).
395 See Resiliency of Mobile Wireless Communications Networks NPRM, FCC 13-125, at ¶¶. 1-2.
396 See supra, Section III.B.3.a.iv.
397 See E911 Location Accuracy Notice, 22 FCC Rcd at 10615 ¶ 17; E911 Location Accuracy Further Notice and
NOI
, 25 FCC Rcd at 18967 ¶ 24.
398 See id..
399 See Technical Options for E911 Location Final Report at 21.
400 NENA Further Notice Comments at 13-14.
401 AT&T Further Notice Reply Comments at i, 8.
402 Verizon Further Notice Comments at 14.
403 Id.
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184.
The record suggests that in most cases, handset-based carriers and network-based carriers
can support Phase II location for roamers on their networks because roamers typically use compatible
technologies. In addition, potential incompatibility in location technology used by roamers may be
reduced further as both handset and network-based carriers migrate to A-GPS and move forward with the
planned implementation of VoLTE. We seek comment on this analysis. Notwithstanding these
technology trends, are there circumstances in which accurate location of roamers could continue to be
hindered by technological incompatibilities? Could implementation of our indoor location proposals
create any challenges in the roaming context that the Commission should address?

V.

CONCLUSION

185.
By this Third Further Notice, we seek comment on proposed measures to ensure the
delivery of more accurate Phase II location information. In proposing an indoor location regulatory
framework, as well as measures to ensure that our existing E911 requirements continue to keep pace with
technological developments and changing consumer and public safety needs, we intend to ensure that all
wireless calls to 911 receive the support they need in times of an emergency.

VI.

PROCEDURAL MATTERS

A.

Ex Parte

Presentations

186.
The proceedings initiated by this Third Further Notice shall be treated as “permit-but-
disclose” proceedings in accordance with the Commission’s ex parte rules.404 Persons making ex parte
presentations must file a copy of any written presentation or a memorandum summarizing any oral
presentation within two business days after the presentation (unless a different deadline applicable to the
Sunshine period applies). Persons making oral ex parte presentations are reminded that memoranda
summarizing the presentation must: (1) list all persons attending or otherwise participating in the meeting
at which the ex parte presentation was made; and (2) summarize all data presented and arguments made
during the presentation. If the presentation consisted in whole or in part of the presentation of data or
arguments already reflected in the presenter’s written comments, memoranda, or other filings in the
proceeding, the presenter may provide citations to such data or arguments in his or her prior comments,
memoranda, or other filings (specifying the relevant page and/or paragraph numbers where such data or
arguments can be found) in lieu of summarizing them in the memorandum. Documents shown or given
to Commission staff during ex parte meetings are deemed to be written ex parte presentations and must
be filed consistent with rule 1.1206(b). In proceedings governed by rule 1.49(f) or for which the
Commission has made available a method of electronic filing, written ex parte presentations and
memoranda summarizing oral ex parte presentations, and all attachments thereto, must be filed through
the electronic comment filing system available for that proceeding, and must be filed in their native
format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in this proceeding should familiarize
themselves with the Commission’s ex parte rules.

B.

Comment Filing Procedures

187.
Pursuant to sections 1.415 and 1.419 of the Commission’s rules, 47 CFR §§ 1.415, 1.419,
interested parties may file comments and reply comments in response to this Third Further Notice of
Proposed Rulemaking
on or before the dates indicated on the first page of this document. Comments may
be filed using the Commission’s Electronic Comment Filing System (ECFS). See Electronic Filing of
Documents in Rulemaking Proceedings
, 63 FR 24121 (1998).

Electronic Filers: Comments may be filed electronically using the Internet by accessing the
ECFS: http://fjallfoss.fcc.gov/ecfs2/.

404 47 C.F.R. §§ 1.1200 et seq.
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Paper Filers: Parties that choose to file by paper must file an original and one copy of each filing.
If more than one docket or rulemaking number appears in the caption of this proceeding, filers
must submit two additional copies for each additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission’s
Secretary, Office of the Secretary, Federal Communications Commission.

All hand-delivered or messenger-delivered paper filings for the Commission’s Secretary
must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325,
Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries
must be held together with rubber bands or fasteners. Any envelopes and boxes must be
disposed of before entering the building.

Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.

U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th
Street, SW, Washington DC 20554.

C.

Accessible Formats

188.
To request materials in accessible formats for people with disabilities (braille, large print,
electronic files, audio format), send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental
Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (TTY).

D.

Regulatory Flexibility Analysis

189.
As required by the Regulatory Flexibility Act of 1980, see 5 U.S.C. § 604, the
Commission has prepared an Initial Regulatory Flexibility Analysis (IRFA) of the possible significant
economic impact on small entities of the policies and rules addressed in this document. The IRFA is set
forth in Appendix B. Written public comments are requested in the IRFA. These comments must be
filed in accordance with the same filing deadlines as comments filed in response to this Third Further
Notice of Proposed Rulemaking
as set forth on the first page of this document, and have a separate and
distinct heading designating them as responses to the IRFA.

E.

Paperwork Reduction Analysis

190.
This Third Further Notice of Proposed Rulemaking 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 PRA. In addition, pursuant to the Small Business Paperwork Relief Act of
2002,405 we seek specific comment on how we might “further reduce the information collection burden for
small business concerns with fewer than 25 employees.”406

VII.

ORDERING CLAUSES

191.
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, Pub. L. No. 106-81, 47 U.S.C. §§ 615 note, 615, 615a, 615b; and Section 106

405 Pub. L. No. 107-198.
406 44 U.S.C. § 3506(c)(4).
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of the Twenty-First Century Communications and Video Accessibility Act of 2010, Pub. L. No. 111-260,
47 U.S.C. § 615c, that this Third Further Notice of Proposed Rulemaking is hereby ADOPTED.
192.
IT IS FURTHER ORDERED that the Commission’s Consumer and Governmental
Affairs Bureau, Reference Information Center, SHALL SEND a copy of this Third Further Notice of
Proposed Rulemaking
, including the Initial Regulatory Flexibility Analysis, to the Chief Counsel for
Advocacy of the Small Business Administration.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
Secretary
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APPENDIX A

Commonly Used Abbreviations for Organizations/Entities

Name of Organization/Entity

Abbreviation/Short Name

Andrew, a Commscope Company, Inc.
CommScope
Association of Public-Safety Communications Officials- International APCO
AT&T Services, Inc.
AT&T
Alliance for Telecommunications Industry Solutions
ATIS
The Boeing Company
Boeing
California Chapter of the National Emergency Number Association
CALNENA
California Office of Emergency Services
CalOES
Commlabs, Inc.
Commlabs
Congressional Fire Services Institute
CFSI
CTIA – The Wireless Association
CTIA
International Association of Chiefs of Police
IACP
International Association of Fire Chiefs
IAFC
Industry Council For Emergency Response Technologies
iCERT
Intrado, Inc.
Intrado
King County, Washington – E911
King County Comments
MetroPCS Communications, Inc.
MetroPCS
Metropolitan Emergency Service Board Of Minnesota
Metropolitan Emergency Service
Board
Mission Critical Partners, Inc.
Mission Critical Partners
Motorola Solutions, Inc.
Motorola
National Emergency Number Association
NENA
NexGen Global Technologies, LLC
NexGen
NextNav, LLC (formally CommLabs, Inc.)
NextNav
Oakland County Office of the Sheriff
Oakland County
Polaris Wireless, Inc.
Polaris
Qualcomm, Inc.
Qualcomm
Southern Communications Services, Inc.
SouthernLINC
Sprint Nextel Corporation
Sprint Nextel
T-Mobile- USA, Inc.
T-Mobile
TeleCommunications Systems, Inc.
TCS
Telecommunications for the Deaf and Hard of Hearing, Inc.
TDI
Texas 911 Alliance
Texas 911
TruePosition, Inc.
TruePosition
Verizon and Verizon Wireless Corporation
Verizon
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APPENDIX B

Initial Regulatory Flexibility Analysis

1.
As required by the Regulatory Flexibility Act of 1980, as amended (RFA),1 the
Commission has prepared this present Initial Regulatory Flexibility Analysis (IRFA) of the possible
significant economic impact of the proposals described in the attached Third Further Notice of Proposed
Rulemaking
(Third Further Notice) on small entities. Written public comments are requested on this
IRFA. Comments must be identified as responses to the IRFA and must be filed by the deadlines for
comments in the Third Further Notice. The Commission will send a copy of the Third Further Notice of
Proposed Rulemaking
, including this IRFA, to the Chief Counsel for Advocacy of the Small Business
Administration (SBA).2 In addition, the Third Further Notice and IRFA (or summaries thereof) will be
published in the Federal Register.3

A.

Need for, and Objectives of, the Proposed Rules

2.
In this Third Further Notice, we propose rules that would update and expand the
Commission’s wireless Enhance 911 (E911) location accuracy requirements to include indoor
environments and to reflect patterns in modern wireless usage and advancements in location-based
technology. Specifically, we propose that all CMRS providers subject to Section 20.18(a) of the
Commission’s rules must provide the caller’s horizontal (x- and y-axis) location within 50 meters and
vertical (z-axis) data within 3 meters for 67 percent of 911 calls placed from indoor environments, within
two and three years of the effective date of the rules, respectively. Within five years of the effective date
of the rules, all CMRS providers subject to Section 20.18(a) of the Commission’s rules must provide the
caller’s horizontal (x- and y-axis) location within 50 meters and vertical (z-axis) data within 3 meters for
80 percent of 911 calls placed from indoor environments. All CMRS providers would be required to
meet these indoor requirements at either the county or PSAP geographic level. Over a longer period (to
be determined), indoor requirements would be strengthened to provide for delivery of “dispatchable”
indoor location, i.e., room-level identification. We propose that compliance with any indoor location
requirements would be measured through testing in an independently administered test bed program, or
through alternative testing mechanisms of equivalent reliability. Public Safety Answering Points (PSAPs)
would be entitled to seek Commission enforcement of these requirements, provided they have
implemented re-bid policies that are designed to obtain all 911 location information made available to
them by CMRS providers. We also seek comment on whether we should adopt a specific waiver process
for those providers who seek relief from our indoor location accuracy requirements.
3.
Additionally, we seek comment on whether to implement various measures for modifying
our existing E911 rules for indoor and outdoor 911 calls. Specifically, we seek comment on whether to
adopt a metric for time to first location fix (in order to count towards compliance of the location accuracy
requirements, a location fix must be generated within 30 seconds). We note that our proposal would
exclude short calls (i.e., calls lasting 10 seconds or less) that may not provide sufficient time to generate a
fix. We also seek comment on whether to standardize the content and delivery of confidence/uncertainty
data generated for wireless 911 calls. We seek comment on whether CMRS providers should inform
PSAPs of the specific location technology used to generate location information for each call. We also
seek comment on whether to require CMRS providers to inform PSAPs of their specific location
technology, accelerate the currently established timeframe for establishing a unitary compliance
requirement for measuring location accuracy for outdoor calls, and require CMRS providers to track and

1 See 5 U.S.C. § 603. The RFA, see 5 U.S.C. § 601 – 612, has been amended by the Small Business Regulatory
Enforcement Fairness Act of 1996 (SBREFA), Pub. L. No. 104-121, Title II, 110 Stat. 857 (1996).
2 See 5 U.S.C. § 603(a).
3 See 5 U.S.C. § 603(a).
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periodically report aggregate data on E911 performance. We also seek comment on whether to establish
a process by which PSAPs can report concerns regarding the provision of E911 services and whether
CMRS providers should be required to conduct periodic compliance testing for indoor and outdoor calls.
4.
In proposing an indoor location regulatory framework, as well as measures to ensure that
our existing E911 requirements continue to keep pace with technological developments and changing
consumer and public safety needs, we emphasize that our ultimate objective is that all Americans –
whether they are calling from urban or rural areas, from indoors or outdoors – receive the support they
need in times of an emergency. Recent data reveals that overall wireless usage has increased significantly
since the Commission’s adoption of E911 location accuracy rules, and further, that the majority of 911
calls also are now placed from wireless phones. Additionally, current trends indicate that a significant
percentage of Americans resides in urban areas where there are high concentrations of multi-story
buildings. Therefore, improvements to indoor location accuracy have become increasingly important. At
the same time, we seek comment on whether our proposals in this notice are the best way to achieve this
objective, and we encourage industry, public safety entities, and other stakeholders to work
collaboratively to develop alternative proposals for our consideration.

B.

Legal Basis

5.
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, Pub. L. No. 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, Pub. L. No. 111-260, 47 U.S.C. § 615c.

C.

Description and Estimate of the Number of Small Entities to Which the Proposed
Rules Would Apply

6.
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.4 The RFA generally defines the
term “small entity” as having the same meaning as the terms “small business,” “small organization,” and
“small governmental jurisdiction.”5 In addition, the term “small business” has the same meaning as the
term “small business concern” under the Small Business Act.6 A small business 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).7
7.
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.8 First, nationwide,
there are a total of approximately 27.9 million small businesses, according to the SBA.9 In addition, a

4 5 U.S.C. §§ 603(b)(3), 604(a)(3).
5 5 U.S.C. § 601(6).
6 5 U.S.C. § 601(3) (incorporating by reference the definition of “small business concern” in the Small Business Act,
15 U.S.C. § 632). Pursuant to 5 U.S.C. § 601(3), the statutory definition of a small business applies “unless an
agency, after consultation with the Office of Advocacy of the Small Business Administration and after opportunity
for public comment, establishes one or more definitions of such terms which are appropriate to the activities of the
agency and publishes such definitions(s) in the Federal Register.”
7 15 U.S.C. § 632.
8 See 5 U.S.C. §§ 601(3)–(6).
9See SBA, Office of Advocacy, available at http://www.sba.gov/sites/default/files/FAQ_Sept_2012.pdf (last viewed
Jan. 31, 2014).
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“small organization” is generally “any not-for-profit enterprise which is independently owned and
operated and is not dominant in its field.”10 Nationwide, as of 2007, there were approximately 1,621,315
small organizations.11 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.”12 Census Bureau data for 2011 indicate that there were 89,476 local
governmental jurisdictions in the United States.13 We estimate that, of this total, as many as 88,506
entities may qualify as “small governmental jurisdictions.”14 Thus, we estimate that most governmental
jurisdictions are small.
1.

Telecommunications Service Entities

a. Wireless Telecommunications Service Providers
8.
Pursuant to 47 C.F.R. § 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.”
9.
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.
10.
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.15 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.16 For this category, census data for 2007 show that there were 11,163

10 5 U.S.C. § 601(4).
11 INDEPENDENT SECTOR, THE NEW NONPROFIT ALMANAC & DESK REFERENCE (2010).
12 5 U.S.C. § 601(5).
13 U.S. CENSUS BUREAU, STATISTICAL ABSTRACT OF THE UNITED STATES: 2011, Table 427 (2007).
14 The 2007 U.S Census data for small governmental organizations are not presented based on the size of the
population in each such organization. There were 89, 476 small governmental organizations in 2007. If we assume
that county, municipal, township and school district organizations are more likely than larger governmental
organizations to have populations of 50,000 or less, , the total of these organizations is 52,125. If we make the same
assumption about special districts, and also assume that special districts are different from county, municipal,
township, and school districts, in 2007 there were 37,381 special districts. Therefore, of the 89,476 small
governmental organizations documented in 2007, as many as 89,506 may be considered small under the applicable
standard. This data may overestimate the number of such organizations that has a population of 50,000 or less. U.S.
CENSUS BUREAU, STATISTICAL ABSTRACT OF THE UNITED STATES 2011, Tables 427, 426 (Data cited therein are
from 2007).
15 U.S. Census Bureau, North American Industry Classification System, Definition of “Wireless
Telecommunications Carriers (except Satellite),” NAICS code 517210, available at http://www.census.gov/cgi-
bin/sssd/naics/naicsrch?code=517210&search=2007%20NAICS%20Search (last viewed Jan. 31, 2013).
16 See id. See also 13 C.F.R. § 121.201, NAICS code 517210.
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establishments that operated for the entire year.17 Of this total, 10,791 establishments had employment of
999 or fewer employees and 372 had employment of 1000 employees or more.18 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.19 In addition, the SBA has developed a small business size standard for wireless firms within the
two broad economic census categories of “Paging” and “Cellular and Other Wireless
Telecommunications.” Under both categories, the SBA deems a wireless business to be small if it has
1,500 or fewer employees. For the census category of Paging, Census Bureau data for 2002 show that
there were 807 firms in this category that operated for the entire year. Of this total, 804 firms had
employment of 999 or fewer employees, and three firms had employment of 1,000 employees or more.
Thus, under this category and associated small business size standard, the majority of firms can be
considered small. For the census category of Cellular and Other Wireless Telecommunications, Census
Bureau data for 2002 show that there were 1,397 firms in this category that operated for the entire year.
Of this total, 1,378 firms had employment of 999 or fewer employees, and 19 firms had employment of
1,000 employees or more. Thus, under this second category and size standard, the majority of firms can,
again, be considered small.
11.
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.20 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.21 Of these 1,307 carriers, an estimated 1,006 have
1,500 or fewer employees and 301 have more than 1,500 employees.22 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.23
12.
A 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.24 Census

17 U.S. Census Bureau, Subject Series: Information, Table 5, “Establishment and Firm Size: Employment Size of
Firms for the United States: 2007 NAICS Code 517210” (issued Nov. 2010), available at
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ECN_2007_US_51SSSZ2&prod
Type=table (last viewed Jan. 31, 2014).
18 Id. Available census data do not provide a more precise estimate of the number of firms that have employment of
1,500 or fewer employees; the largest category provided is for firms with “100 employees or more.”
19 Id.
20 13 C.F.R. § 121.201, NAICS code 517110.
21 See Trends in Telephone Service, Federal Communications Commission, Wireline Competition Bureau, Industry
Analysis and Technology Division at Table 5.3 (Sept. 2010) (Trends in Telephone Service).
22 See id.
23 See http://factfinder.census.gov/servlet/IBQTable?_bm=y&-fds_name=EC0700A1&-geo_id=&-_skip=600&;-
ds_name=EC0751SSSZ5&-_lang=en.
24 13 C.F.R. § 121.201, NAICS code 517110.
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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.25 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.26 Of these 1,442 carriers, an estimated
1,256 have 1,500 or fewer employees and 186 have more than 1,500 employees.27 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.28 In addition, 72 carriers have reported that they are Other Local Service Providers.29
Of the 72, seventy have 1,500 or fewer employees and two have more than 1,500 employees.30
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.
13.
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.31 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.32 These small business size
standards, in the context of broadband PCS auctions, have been approved by the SBA.33 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.34 On April 15, 1999, the Commission
completed the reauction of 347 C-, D-, E-, and F-Block licenses in Auction No. 22.35 Of the 57 winning
bidders in that auction, 48 claimed small business status and won 277 licenses.

25 See http://factfinder.census.gov/servlet/IBQTable?_bm=y&-fds_name=EC0700A1&-geo_id=&-_skip=600&;-
ds_name=EC0751SSSZ5&-_lang=en.
26 See Trends in Telephone Service at Table 5.3.
27 See id.
28 See id.
29 See id.
30 See id.
31 See Amendment of Parts 20 and 24 of the Commission’s Rules – Broadband PCS Competitive Bidding and the
Commercial Mobile Radio Service Spectrum Cap; Amendment of the Commission’s Cellular/PCS Cross-Ownership
Rule; WT Docket No. 96-59, GN Docket No. 90-314, Report and Order, 11 FCC Rcd 7824, 7850–52, paras. 57–60
(1996) (PCS Report and Order); see also 47 C.F.R. § 24.720(b).
32 See PCS Report and Order, 11 FCC Rcd at 7852 ¶ 60.
33 See See Letter from Aida Alvarez, Administrator, Small Business Administration, to Amy Zoslov, Chief,
Auctions and Industry Analysis Division, Wireless Telecommunications Bureau, Federal Communications
Commission (Dec. 2, 1998) (Alvarez Letter 1998).
34 See Broadband PCS, D, E and F Block Auction Closes, Public Notice, Doc. No. 89838 (rel. Jan. 14, 1997).
35 See C, D, E, and F Block Broadband PCS Auction Closes, Public Notice, 14 FCC Rcd 6688 (WTB 1999). Before
Auction No. 22, the Commission established a very small standard for the C Block to match the standard used for F
Block. Amendment of the Commission’s Rules Regarding Installment Payment Financing for Personal
(continued….)
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14.
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.36 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.37
On May 21, 2007, the Commission completed an auction of 33 licenses in the A, C, and F Blocks in
Auction No. 71.38 Of the 12 winning bidders in that auction, five claimed small business status and won
18 licenses.39 On August 20, 2008, the Commission completed the auction of 20 C-, D-, E-, and F-Block
Broadband PCS licenses in Auction No. 78.40 Of the eight winning bidders for Broadband PCS licenses
in that auction, six claimed small business status and won 14 licenses.41
15.
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.42 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.43
16.
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 has 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.44 In 2006, the Commission conducted its first auction of AWS-1 licenses.45 In that initial AWS-
(Continued from previous page)
Communications Services (PCS) Licensees, WT Docket No. 97-82, Fourth Report and Order, 13 FCC Rcd 15743,
15768, ¶ 46 (1998).
36 See C and F Block Broadband PCS Auction Closes; Winning Bidders Announced, Public Notice, 16 FCC Rcd
2339 (WTB 2001).
37 See Broadband PCS Spectrum Auction Closes; Winning Bidders Announced for Auction No. 58, Public Notice,
20 FCC Rcd 3703 (WTB 2005).
38 See Auction of Broadband PCS Spectrum Licenses Closes; Winning Bidders Announced for Auction No. 71,
Public Notice, 22 FCC Rcd 9247 (WTB 2007).
39 Id.
40 See Auction of AWS-1 and Broadband PCS Licenses Closes; Winning Bidders Announced for Auction 78, Public
Notice
, 23 FCC Rcd 12749 (WTB 2008).
41 Id.
42 Amendment of the Commission’s Rules to Establish New Personal Communications Services, Narrowband PCS,
GEN Docket No. 90-314, ET Docket No. 92-100, PP Docket No. 93-253, Second Report and Order and Second
Further Notice of Proposed Rulemaking
, 15 FCC Rcd 10456 (2000).
43 See Alvarez Letter 1998.
44 See Service Rules for Advanced Wireless Services in the 1.7 GHz and 2.1 GHz Bands, Report and Order, 18 FCC
Rcd 25162, App. B (2003), modified by Service Rules for Advanced Wireless Services In the 1.7 GHz and 2.1 GHz
Bands, Order on Reconsideration, 20 FCC Rcd 14058, App. C (2005).
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1 auction, 31 winning bidders identified themselves as very small businesses.46 Twenty-six of the
winning bidders identified themselves as small businesses.47 In a subsequent 2008 auction, the
Commission offered 35 AWS-1 licenses.48 Four winning bidders identified themselves as very small
businesses, and three of the winning bidders identified themselves as a small business.49For 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 not yet adopted size standards for the AWS-2 or AWS-3
bands but has proposed to treat both AWS-2 and AWS-3 similarly 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.50
17.
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.51 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.
18.
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.52 The SBA has approved these definitions.53 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.
(Continued from previous page)
45 See Auction of Advanced Wireless Services Licenses Scheduled for June 29, 2006; Notice and Filing
Requirements, Minimum Opening Bids, Upfront Payments and Other Procedures for Auction No. 66, AU Docket
No. 06-30, Public Notice, 21 FCC Rcd 4562 (2006) (Auction 66 Procedures Public Notice).
46 See “Auction of Advanced Wireless Services Licenses Closes; Winning Bidders Announced for Auction No. 66,”
Public Notice, 21 FCC Rcd 10,521 (2006) (Auction 66 Closing Public Notice).
47 See id.
48 See AWS-1 and Broadband PCS Procedures Public Notice, 23 FCC Rcd at 7499. Auction 78 also included an
auction of broadband PCS licenses.
49 See Auction of AWS-1 and Broadband PCS Licenses Closes, Winning Bidders Announced for Auction 78, Down
Payments Due September 9, 2008, FCC Forms 601 and 602 Due September 9, 2008, Final Payments Due
September 23, 2008, Ten-Day Petition to Deny Period, Public Notice, 23 FCC Rcd 12749 (2008).
50 Service Rules for Advanced Wireless Services in the 1915–1920 MHz, 1995–2000 MHz, 2020–2025 MHz and
2175–2180 MHz Bands et al., Notice of Proposed Rulemaking, 19 FCC Rcd 19263, App. B (2005); Service Rules
for Advanced Wireless Services in the 2155–2175 MHz Band, Notice of Proposed Rulemaking, 22 FCC Rcd 17035,
App. (2007); Service Rules for Advanced Wireless Services in the 2155-2175 MHz Band, Further Notice of
Proposed Rulemaking
, 23 FCC Rcd 9859, App. B (2008).
51 NAICS Code 51210.
52 Amendment of the Commission’s Rules to Establish Part 27, the Wireless Communications Service (WCS),
Report and Order, 12 FCC Rcd 10785, 10879 ¶ 194 (1997).
53 See Alvarez Letter 1998.
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19.
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.54 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.55 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.56 SBA approval of these
definitions is not required.57 An auction of 52 Major Economic Area (MEA) licenses commenced on
September 6, 2000, and closed on September 21, 2000.58 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.59
20.
Upper 700 MHz Band Licenses. In the 700 MHz Second Report and Order, the
Commission revised its rules regarding Upper 700 MHz licenses.60 On January 24, 2008, the
Commission commenced Auction 73 in which several licenses in the Upper 700 MHz band were
available for licensing: 12 Regional Economic Area Grouping licenses in the C Block, and one
nationwide license in the D Block.61 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.
21.
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.62 The Commission defined a “small business” as an entity that,

54 Service Rules for the 746-764 MHz Bands, and Revisions to Part 27 of the Commission’s Rules, Second Report
and Order
, 15 FCC Rcd 5299 (2000). Service rules were amended in 2007, but no changes were made to small
business size categories. See Service Rules for the 698-746, 747-762 and 777-792 MHz Bands, WT Docket No. 06-
150, Revision of the Commission’s Rules to Ensure Compatibility with Enhanced 911 Emergency Calling Systems,
CC Docket No. 94-102, Section 68.4(a) of the Commission’s Rules Governing Hearing Aid-Compatible
Telephones, WT Docket No. 01-309, Biennial Regulatory Review – Amendment of Parts 1, 22, 24, 27, and 90 to
Streamline and Harmonize Various Rules Affecting Wireless Radio Services, WT Docket 03-264, Former Nextel
Communications, Inc. Upper 700 MHz Guard Band Licenses and Revisions to Part 27 of the Commission’s Rules,
WT Docket No. 06-169, Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700
MHz Band, PS Docket No. 06-229, Development of Operational, Technical and Spectrum Requirements for
Meeting Federal, State and Local Public Safety Communications Requirements Through the Year 2010, WT Docket
No. 96-86, Report and Order and Further Notice of Proposed Rulemaking, 22 FCC Rcd 8064 (2007).
55 Id. at 5343 ¶ 108.
56 Id.
57 Id. at 5343 ¶ 108 n.246 (for the 746-764 MHz and 776-704 MHz bands, the Commission is exempt from 15
U.S.C. § 632, which requires Federal agencies to obtain Small Business Administration approval before adopting
small business size standards).
58 See 700 MHz Guard Bands Auction Closes: Winning Bidders Announced, Public Notice, 15 FCC Rcd 18026
(WTB 2000).
59 See 700 MHz Guard Bands Auction Closes: Winning Bidders Announced, Public Notice, 16 FCC Rcd 4590
(WTB 2001).
60 700 MHz Second Report and Order, 22 FCC Rcd 15289.
61 See Auction of 700 MHz Band Licenses Closes, Public Notice, 23 FCC Rcd 4572 (WTB 2008).
62 See Reallocation and Service Rules for the 698–746 MHz Spectrum Band (Television Channels 52–59), Report
and Order
, 17 FCC Rcd 1022 (2002) (Channels 5259 Report and Order).
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together with its affiliates and controlling principals, has average gross revenues not exceeding $40
million for the preceding three years.63 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.64 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.65 The SBA approved these small size
standards.66 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.67 A second auction
commenced on May 28, 2003, closed on June 13, 2003, and included 256 licenses.68 Seventeen winning
bidders claimed small or very small business status, and nine winning bidders claimed entrepreneur
status.69 In 2005, the Commission completed an auction of 5 licenses in the Lower 700 MHz band. All
three winning bidders claimed small business status.
22.
In 2007, the Commission reexamined its rules governing the 700 MHz band in the 700
MHz Second Report and Order.70 An auction of A, B and E block 700 MHz licenses was held in 2008.71
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).
23.
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.72 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.73 Census data
for 2007, which supersede data contained in the 2002 Census, show that there were 1,383 firms that
operated that year.74 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.

63 See id., 17 FCC Rcd at 1087–88 ¶ 172.
64 See id.
65 See id., 17 FCC Rcd at 1088 ¶ 173.
66 See Alvarez Letter 1998.
67 See Lower 700 MHz Band Auction Closes, Public Notice, 17 FCC Rcd 17272 (2002).
68 See Lower 700 MHz Band Auction Closes, Public Notice, 18 FCC Rcd 11873 (2003).
69 See id.
70 700 MHz Second Report and Order, Second Report and Order, 22 FCC Rcd 15,289, 15,359 n.434 (2007).
71 See Auction of 700 MHz Band Licenses Closes, Public Notice, 23 FCC Rcd 4572 (2008).
72 This service is governed by Subpart I of Part 22 of the Commission’s Rules. See 47 C.F.R. §§ 22.1001-22.1037,
NAICS code 517210.
73 13 C.F.R. § 121.201, NAICS code 517210.
74 2007 Economic Census Report Employment Size of Firms, at NAICS Code 517210.
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24.
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).75 Under the SBA
small business size standard, a business is small if it has 1,500 or fewer employees.76 According to
Trends in Telephone Service data, 413 carriers reported that they were engaged in wireless telephony.77
Of these, an estimated 261 have 1,500 or fewer employees and 152 have more than 1,500 employees.78
Therefore, more than half of these entities can be considered small.
25.
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.”79 For this category, Census Bureau data for 2007 show that there were a total of 2,623
firms that operated for the entire year.80 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

26.
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.81 Thus, under this size standard, the majority of firms can be considered small.
27.
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

75 13 C.F.R. § 121.201, NAICS code 517210.
76 Id.
77 TRENDS IN TELEPHONE SERVICE, tbl. 5.3.
78 Id.
79 See http://www.census.gov/cgi-bin/sssd/naics/naicsrch?code=517919&search=2007%20NAICS%20Search.(last
viewed Jan. 31, 2014).
80 See
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ECN_2007_US_51SSSZ1&prod
Type=table (last viewed Jan. 31, 2014).
81 The NAICS Code for this service 334220. See 13 C.F.R 121/201. See also
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ECN_2007_US_00A1&prodTyp
e=table (last viewed Jan. 31, 2014).
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a phase change, magnetic, optical, or magnetic/optical media.”82 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.83 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

28.
The Third Further Notice proposes a regulatory framework to require delivery of
accurate location information to PSAPs for wireless 911 calls placed from indoors. Our proposal includes
both near- and long-term components. In the near term, the Commission proposes that CMRS providers
subject to Section 20.18 of the Commission’s rules provide horizontal location information within 50
meters for 67 percent of 911 calls placed from indoor environments within two years of the effective date
of the rules and provide vertical location information within 3 meters for 67 percent of 911 calls placed
from indoor environments within three years. Within five years of the effective date of the rules, the
Commission proposes that all CMRS providers subject to Section 20.18(a) of the Commission’s rules
must provide the caller’s horizontal (x- and y-axis) location within 50 meters and vertical (z-axis) data
within 3 meters for 80 percent of 911 calls placed from indoor environments. These standards would
apply nationwide. For the long term, we propose to develop more granular indoor location accuracy
standards, consistent with the evolving capabilities of indoor location technology and increased
deployment of in-building communications infrastructure that would provide for delivery to PSAPs of in-
building location information at the room or office/suite level. Additionally, the Third Further Notice
proposes that CMRS providers demonstrate compliance with indoor location accuracy requirements
through a test bed or through other testing methods, provided that the methodologies are equivalent to the
test bed approach. The Third Further Notice seeks comments on whether CMRS providers should certify
compliance with the indoor location accuracy requirements.
29.
The Third Further Notice also addresses several ways to improve the delivery of Phase II
location information. The Third Further Notice proposes to require CMRS providers to deliver location
information within 30 seconds to the location information center (but with a provision to exclude short
calls of 10 seconds or less that may not provide sufficient time to generate a location fix) and identify the
technology used to determine a location fix and to provide this information to the PSAP. The Third
Further Notice
seeks comment on whether the Commission should standardize the content and process
for delivery of confidence and uncertainty data generated for each wireless 911 call. Additionally, the
Third Further Notice seeks comment on whether it would be feasible to expedite the timeframe for
implementing a unitary location accuracy standard for outdoor calls. The Third Further Notice also seeks
comment on whether CMRS providers should track and periodically report information regarding the
percentage of wireless calls to 911 that include E911 Phase II information, and conduct periodic
compliance testing for both indoor and outdoor calls. The Third Further Notice also seeks comment on
whether CMRS providers should track and periodically report E911 call information also seeks comment
on what safeguards should be implemented to ensure that CMRS providers’ confidential information is
protected in relation to reporting requirements. The Third Further Notice also seeks comment on whether
to adopt a process by which PSAPs or state 911 administrators could raise complaints or concerns
regarding the provision of E911 service. Many of the foregoing requirements will likely require the use
of professionals for compliance, e.g. engineers and attorneys.

82 U.S. Census Bureau, 2007 Economic Census, Industry Series: Manufacturing, “Semiconductor and Related
Device Manufacturing,” NAICS code 334413.
83 See http://factfinder.census.gov/servlet/IBQTable?_bm=y&-geo_id=&-_skip=300&-ds_name=EC0731I1&;-
_lang=en.
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E.

Steps Taken to Minimize Significant Economic Impact on Small Entities, and
Significant Alternatives Considered

30.
The RFA requires an agency to describe any significant, specifically small business
alternatives that it has considered in reaching its proposed 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 or reporting requirements under the rule for
small entities; (3) the use of performance, rather than design, standards; and (4) and exemption from
coverage of the rule, or any part thereof, for small entities.”84
31.
The Third Further Notice analyzes a variety of possible means of implementing various
near- and long-term E911 location accuracy requirements, without imposing undue costs or regulatory
burdens. The Third Further Notice recognizes that the implementation of any indoor location accuracy
requirements will impose costs on CMRS providers and seeks comment on the ways in which any
implementation requirements could be designed to mitigate those costs to the extent possible, without
sacrificing important public safety objectives. The Third Further Notice seeks comment on how we
different approaches may affect smaller CMRS providers and whether there are particular measures the
Commission should take to minimize the potential burdens on these smaller providers. The Third Further
Notice
seeks comment on a wide range of questions that will enable the Commission to weigh the costs
and benefits of its proposals, including whether to establish any exceptions for smaller wireless providers.
The Third Further Notice suggests that costs of compliance are likely to be mitigated by the fact that
providers are already undertaking various indoor location technology research and development efforts
for their own commercial, non-911 related purposes.
32.
The Third Further Notice proposes to offer CMRS providers flexibility in implementing
the indoor location requirements. For example, the Third Further Notice proposes to allow CMRS
providers to implement whatever location technology it chooses, and foresees that providers may
implement different solutions to determine a caller’s indoor location, each of which may present unique
costs. The Third Further Notice seeks comment on the technical feasibility and specific challenges of its
various proposals. The Third Further Notice also seeks comment on whether, in order to increase
flexibility for CMRS providers, the Commission should adopt a specific waiver process for those
providers who seek relief from our indoor location accuracy requirements. In addition, the Third Further
Notice
seeks comment on any other alternative approaches that would enable the Commission to focus the
application of indoor location requirements in the most effective and cost-efficient way possible, and
asking for possible voluntary approaches agreed upon between CMRS providers and public safety as an
alternative to regulation. These or other alternatives in the comment record can help to reduce the
compliance burden on small businesses.
33.
The Third Further Notice also seeks comment on various Phase II E911 delivery issues.
For example, the Third Further Notice seeks comment on requiring CMRS providers to satisfy a unitary
E911 location accuracy standard (for outdoor calls) within an expedited timeframe. In doing so, the Third
Further Notice
seeks comment on how expediting the timeframe towards more granular location accuracy
standards may affect smaller CMRS providers, and specifically seeks comment on the implementation
timeframe, as well as the sufficiency of the Commission’s existing waiver process to provide relief.
34.
The Third Further Notice also invites industry and public safety stakeholders to
collaborate to identify alternative proposals for improving indoor location accuracy, including a
consensus-based, voluntary proposal to address the public safety goals detailed in this proceeding.
Finally, the proposals in the Third Further Notice do not become effective until after the Commission
seeks comment and adopts an order implementing them. We seek comment on the effect of the various

84 5 U.S.C. §§ 603(c)(1)-(c)(4).
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proposals described in the Third Further Notice, as summarized above, will have on small entities, and on
what effect alternative rules would have on those entities.

F.

Federal Rules that May Duplicate, Overlap, or Conflict with the Proposed Rules

35.
None.
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APPENDIX C

Proposed Rules

Part 20 of the Code of Federal Regulations is amended 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) to remove paragraph (h)(3) and redesignating
paragraph (h)(4) as paragraph (h)(3).
3.
Section 20.18 is amended by redesignating paragraphs (i) through (n) as paragraphs (m) through
(q) and adding new paragraphs (i) through (k) and new paragraph (m) as follows:
*
*
*
*
*
(i) Indoor Location Accuracy for 911 and testing requirements. CMRS providers subject to this section
must provide to the designated Public Safety Answering Point the location of 911 wireless calls, based on
indoor measurements, within 50 meters (by longitude and latitude) no later than two years from [the
effective date of the adoption of this rule], and, within 3 meters (vertical height) no later than three years
from [the effective date of the adoption of this rule], for 67 percent of all such calls. No later than five
years from the [effective date of the adoption of this rule], CMRS providers must comply with the 50
meter (by longitude and latitude) accuracy requirement and the 3 meter (vertical height) accuracy
requirement, for 80 percent of all such calls. CMRS providers shall satisfy these indoor location accuracy
standards on a PSAP-level or county-level basis, and may demonstrate compliance by either:
(1) Participating in an independently administered test bed program that includes a sampling of
different environments that is representative of real-life indoor call scenarios, employs the
same technology or technologies actually employed in their networks, and relies on tests of
how the technology or technologies will actually be so employed; or
(2) Using alternative testing methods, provided that CMRS providers demonstrate that their
methodology and testing procedures are at least equivalent to the testing methodology and
procedure standards used in the independently administered indoor location accuracy test bed
under paragraph (i)(1) of this section.
(j) Latency (Time to First Fix). For purposes of measuring compliance with the outdoor location accuracy
standards of paragraph (h) and the indoor location accuracy standard of paragraph (i), a call will be
deemed to satisfy the standard only if it provides the specified degree of location accuracy within a
maximum period of 30 seconds (“Time to First Fix”), as measured at the location information center of
the E911 network. For such purposes, CMRS providers may exclude 911 calls of a duration of 10
seconds or less.
(k) Confidence and uncertainty data: 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)
information confidence and uncertainty information (C/U data) on a per-call basis upon the request of a
PSAP. Such C/U data shall specify (1) the caller’s location within a specified confidence level, and (2)
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the radius in meters from the reported position at that same confidence level. All entities responsible for
transporting confidence and uncertainty between wireless carriers and PSAPs, including LECs, CLECs,
owners of E911 networks, and emergency service providers, must enable the transmission of confidence
and uncertainty data provided by wireless carriers to the requesting PSAP.
(l) Reports on Phase II plans. *
*
*
(m) Conditions for enhanced 911 services—(1) Generally. The requirements set forth in paragraphs (d)
through (k) 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.
*
*
*
*
*
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STATEMENT OF

CHAIRMAN THOMAS E. WHEELER

Re:
Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114
One of the Commission’s most important responsibilities is to preserve certain core values even
as technology advances and the way that consumers use that technology evolves. Nowhere is that
imperative more clear than in the arena of public safety.
Our E911 location accuracy rules were written when wireless phones were a secondary means of
communication, and were mostly used outside. Today, more and more consumers use wireless phones as
their primary means of communication, and more and more 911 calls are coming from wireless phones,
from indoors.
The numbers make this trend very plain, but the stories really bring the issue home. Earlier this
week, I met with folks from local PSAPs who told me their stories about why this is so important. They
talked about how, during the Navy Yard shootings, people were calling 911 from inside the building – not
using their office phones; using their mobile phones. Another story involved a person whose iPad had
been stolen – the location information delivered to the PSAP was off by almost 3 miles, but the
information provided using the iPad’s location app provided pinpoint accuracy.
Our rules need to reflect the new realities of the always-connected mobile world. A lot of good
work already has been done on this issue. In particular, through the CSRIC, FCC staff worked with
wireless providers and technology vendors to establish a test bed to determine the state of location
technology. What we learned has given us confidence that further advances in technology should enable
us to locate callers indoors with the same degree of accuracy as outdoors. The Notice we adopt today
builds on that experience by proposing an accuracy threshold for indoor locations that is just as effective
as the threshold for outdoor locations, and an aggressive but reachable timeline for achieving that
threshold.
Another important development is the ability to find a caller on the so-called “Z-axis” – that is,
not just knowing what building the caller is in, but also what floor. This technology is relatively new, but
it’s already being installed in many handsets for commercial services. The proposals we adopt today seek
to leverage that innovation to make sure that information is available to public safety.
Of course, as the saying goes, it takes two to tango. Providers will deliver the information, but it
will mean little if PSAPs and state and local governments do not take the necessary steps on their part.
This item asks important questions about what steps the FCC can take to encourage PSAPS to continue
moving forward, but state and local governments must also step up to ensure that PSAPs have sufficient
funding to deploy the necessary technologies and, ultimately, make the migration to NG911.
The item also proposes changes to our rules to address some of the challenges and issues raised
by the data that was submitted to the FCC last year by the California chapter of the National Emergency
Number Association.
Finally, this item also asks some very important questions about the opportunities new
technologies enable in the longer term. Technologies that already exist and are already widely deployed
should be able to provide granular location information. For example, can we leverage Wi-Fi or other
small cell technologies to locate not just the building a caller is in, but the room? Today, for instance,
stores in the mall know when you enter because they bounce a Wi-Fi signal off your mobile handset.
Our job is to ensure that as network providers and their customers upgrade to new technologies,
there is no downgrade in reliability, availability, or public safety. Today’s item takes the next steps to
ensure that our rules continue to evolve along with technology and changing consumer habits.
Thank you to everyone in the Public Safety Bureau for their work on this item.
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STATEMENT OF

COMMISSIONER MIGNON L. CLYBURN

Re:
Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114
Improving emergency response times has been a primary goal for 9-1-1 services, since 1967,
when President Lyndon Johnson first encouraged the FCC to collaborate with the wire line industry in the
development of a nation-wide emergency number. Consumers have made it clear that improving
response times for 9-1-1 calls from wireless phones must also be a national priority. As today’s item
notes, the number of American households that are wireless only has grown from roughly 16 percent, in
2007, to 39 percent. And, for those living below the poverty line, that number has risen to 54 percent.
At our November 2013 workshop on location accuracy, we listened with unease about call
centers in certain areas of the country not receiving the information they needed to dispatch help to those
in need because mobile calls pose more challenges to first responders than wire line calls. Citizens
understandably expect and believe that their mobile handsets – especially those smartphones with location
based services – provide them with the same capacity to get help as their wire line phones. But all too
often, this is simply not the case and the results can be heartbreaking.
Last month, at a Senate hearing on location accuracy, a witness testified that in Horry County,
South Carolina, where you can find sixty miles of sun and fun, on and near Myrtle Beach, along with
millions of other visitors each year, how 50% of their 9-1-1 callers cannot provide dispatchers with
meaningful location information. And, with estimates as high as 80 percent of emergency calls being
placed from cellular phones, it should come as no surprise that we have also been hearing pleas for
location standards when wireless 9-1-1 calls are made from indoors. Location services must improve, as
quickly as possible, and the Commission’s response time to that end should also be swift.
We must ensure that our public safety obligations keep pace with consumer demand and technology
shifts and I commend Chairman Wheeler for bringing forth a comprehensive Further Notice just three
months after the November workshop. The item includes creative rule proposals and asks a wide range of
technical questions designed to improve the timeliness and accuracy of all wireless location information.
It also proposes, for the first time, location accuracy standards for wireless 9-1-1 calls from indoor
locations. I am pleased that we seek comment on testing compliance with all of these standards and on
requiring carriers to send location information within 30 seconds from the time the mobile consumer
makes her 9-1-1 call.
Also noteworthy are the detailed questions about how developments in roaming, Wi-Fi, location
based services and emerging technologies could impact the delivery of location information. We need to
make sure our location accuracy standards account for future innovations in mobile services. The Further
Notice also properly seeks comment on the abilities of PSAPs to access the location data that wireless
providers send.
I understand some members of the wireless industry are bristling because the Commission is
proposing to enhance the location accuracy rules at a pace that is seen as a bit aggressive. But today’s
item asks the wireless industry, the public safety entities, and others to work collaboratively toward
developing alternative proposals for our consideration. And allow me to point out that one of the
hallmarks of leadership in this industry is that it has, on many occasions, exceeded our expectations. We
have already heard from those, who concur, that it is time for the industry to adopt indoor location
standards, and today, I wish to commend those entities. It would be great to see other examples of this
kind of leadership, and for the wireless industry to actually move ahead of schedule, in implementing all
the proposed location accuracy rules that our nation so desperately expects and needs.
I thank Admiral Simpson, and the dedicated staff, of the Public Safety Homeland Security
Bureau, for their good work on this Further Notice, and for the presentation this morning.
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STATEMENT OF

COMMISSIONER JESSICA ROSENWORCEL

Re:
Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114
During my time at the Commission, I have made it a priority to visit public safety officials and
talk about communications technologies where they work. So over the course of a year or so, I visited
one 911 call center every month. That means I have seen public safety officials at work from Alaska to
Arkansas, California to Colorado, Vermont to Virginia—and a whole lot of places in-between.
In every visit, I get the privilege of meeting emergency call operators and watching them work.
They always amaze. Because when crises mount, they answer calls with steely calm and help ensure that
help is on the way.
In every visit, I also hear one refrain: the number of wireless calls to 911 is skyrocketing. The
data bear this out. Today, more than 70 percent of 911 calls are from wireless phones. That is more than
400,000 calls across the country every day. And this number is only going to grow. Today, for roughly 2
in 5 households, their wireless phone in their only phone. In some places, that number is even higher. In
Idaho, for instance, more than half of all households no longer have a landline phone. In Mississippi, one
half of adults live in wireless-only households. Closer to home, the numbers are similar right here for the
District of Columbia.
The way we connect and call is changing. So is the way we reach out for help at our moment of
greatest need. But our rules that provide first responders with information about where we are when we
call 911 are stranded in calling practices of the last century.
So today, under our rules, if you call 911 from a wired phone, first responders know where you
are and where to send help.
If you call 911 from a wireless phone outdoors, the Commission has standards that help ensure
first responders can locate you and send assistance.
But if you call 911 from a wireless phone indoors, you should cross your fingers and hope and
pray, because no location accuracy standards apply.
This is an unacceptable gap in our policies. But today we do something about it. On the heels of
a hearing on this issue led by Senator Mark Pryor, we start a rulemaking to narrow this gap and fix this
problem. He has been a champion on this issue and I thank him for it. To be sure, our proposals are
aggressive. But I think we can fix this problem if all stakeholders work together. I am encouraged that
carriers have told me they intend to work with public safety officials and the Commission to find
technologies that work. For my part, I will be watching closely.
Finally, I want to note that this is important to me. I have traveled far and wide and witnessed
this problem and I have spoken and written about it at length. So I am really pleased that the Chairman
made it a priority to put it before the Commission and put it on the agenda today. I want to thank him for
making public safety a priority. I look forward to working with my colleagues—and icons in the public
safety community like Steve Souder—to improve our policies and make us all more safe. Because one
thing is certain—when you call 911—you want first responders to find you.
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STATEMENT OF

COMMISSIONER AJIT PAI

APPROVING IN PART AND CONCURRING IN PART

Re:
Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114
It is one of the most elementary questions one can ask, yet it has been a challenging one for
technology alone to answer: Where are you? The answer to this question is vital during an emergency.
For this reason, there is tremendous value in transmitting accurate location data to emergency responders
whenever someone dials 911. By knowing the location of someone in need, 911 dispatchers can send
first responders immediately to the scene. Without it, police officers, firefighters, and emergency medical
technicians may spend precious seconds, minutes, or even hours searching for a caller. And that is true
whether a call is made indoors or outside.
I saw the promise of accurate indoor location technology for myself in the summer of 2012 inside
a large Silicon Valley hotel. As I rode the elevator from floor to floor on that July afternoon, the
prototype device tracked me fairly well. Had I needed to call 911, transmitting that information could
have made all the difference.
I therefore support today’s decision to commence a rulemaking proceeding to examine whether
the Commission should adopt indoor location accuracy requirements. I also believe that we should enact
rules in this area that are both aggressive and achievable. Unfortunately, I am skeptical that the
timeframes proposed in today’s item are realistic. As a result, I am voting to approve in part and concur
in part.
Concerned about the feasibility of the timeframes proposed in this item, my office asked
Commission staff and stakeholders for a step-by-step timeline that would show how it would be possible
for a carrier to meet the timeframes contained in our proposed rules. But to date, no one has been able to
produce such a timeline. It appears that today’s proposal takes its inspiration from Field of Dreams: “If
you build it, he will come.” Only in this case, the mantra is: “If we mandate it, they will comply.”
This is unfortunate. The Commission’s rules should be more than aspirational. Our rulemaking
process is not a feel-good exercise. It imposes legally binding obligations on regulated entities. It is
unfair to saddle them with obligations that cannot be met. And such rules don’t help the American people
either. Indeed, they can be counterproductive since they stand a good chance of sparking litigation or
paralyzing the industry with fear of taking any action if there is no clear path to compliance.
Americans recently have witnessed several instances where unrealistic mandates were imposed
on businesses and had to be delayed. In order to prevent history from repeating itself, I would like to
highlight two specific suggestions teed up in today’s item for enabling carriers to comply with any
location accuracy rules. First, the trigger for compliance should not be the effective date of the rules we
ultimately adopt. Instead, the clock should start running when our Communications Security, Reliability
and Interoperability Council (CSRIC) certifies that a technology vendor has demonstrated through an
independently administered test bed program that a solution meets the horizontal and vertical location
accuracy benchmarks set forth in those rules. To me, this is a matter of common sense. Carriers cannot
begin to deploy a technology solution that does not yet exist. And the public should not be led to rely on
a promise that cannot be kept.
Second, carriers should not be subject to enforcement action if they prove they are making their
best efforts to deploy a technology that has been certified by CSRIC as complying with the Commission’s
location accuracy standards. Creating such a safe harbor would incentivize every vendor to partake in the
CSRIC process. After all, the first to get CSRIC certification would have a leg up on competitors in
getting its technology deployed in the field. This race to certification, in turn, would have the
serendipitous effect of getting an independently verified technology out in the field further and faster.
This will save lives.
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We also need to have this safety valve because we do not know how long it will take for carriers
to deploy a compliant technology nationwide or whether a compliant technology will work in every single
county in the United States. Deploying a compliant technology across the whole country will be a
daunting and time-consuming task. Judging from our experience with Phase II, which the FCC mandated
in 1996 but will not be fully implemented until 2019, I am skeptical that this deployment can be
completed in two to three years.
The item indicates, for example, that CMRS carriers are increasingly turning to handset-based
solutions for providing location information. But what would that entail here? First, the technology in
question will need to go through the standards process. Second, device manufacturers will need to
incorporate it into handsets. Third, consumers then will need to replace their old handsets with new ones.
Experience with the deployment of AGPS-capable handsets has taught us that this is a cycle that will take
many years to complete—and that’s if everything goes smoothly. While I wish that we could click our
heels together three times and watch the technology magically deploy itself on a nationwide basis, we’re
not in Oz (or Kansas, for that matter).
One other aspect of the proposed rules is worth mentioning. Today’s item proposes that accurate
location information must be transmitted to a Public Safety Answering Point within 30 seconds. At the
same time, however, it also proposes to exclude from compliance determinations only calls lasting 10
seconds or less. So what is given with one hand would be taken away by the other. If a call lasts for
twenty seconds, then a carrier will be penalized for failing to transmit accurate location information
within those twenty seconds even though the rule ostensibly provides the carrier with thirty seconds to do
so. This does not make sense. Whatever time period we end up choosing, whether it be 10 seconds, 20
seconds, or 30 seconds, we should have one consistent measure of how long carriers have to provide
location accuracy information.
Finally, there’s another critical aspect of the location accuracy problem worth thinking about.
Last month, I began an inquiry into the state of 911 availability in establishments, such as hotels, motels,
office buildings, and schools, that use multiline telephone systems (MLTS). Location accuracy matters
with MLTS systems as well. A recent tragedy in Utah illustrates why.
On January 22, Randy Palmer suffered a heart attack while shopping at a Midvale, Utah auto
parts store. An employee promptly called 911. But the call went to the wrong dispatch center because
the store’s phone system indicated that the call was being placed from the company’s Salt Lake City
office. First responders were consequently sent to the wrong location and took about 15 minutes to arrive
in Midvale. Unfortunately, Mr. Palmer passed away. His widow put it well when she said: “People need
to know what happened and I don’t want something like this to happen to someone else. My husband
was the most important person in my life [and] in my daughter’s life. The [extra] minutes absolutely cost
him his life.” To me, the lesson is this: As we design indoor location accuracy requirements, we must
not forget about MLTS location accuracy.
I would like to thank the staff of the Public Safety and Homeland Security Bureau for their hard
work on these issues and my colleagues for agreeing to incorporate some of my suggestions into this
item. I look forward to working together in the months to come to hasten the day when that vexing
question—where are you?—becomes an academic one when it comes to emergency calling.
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STATEMENT OF

COMMISSIONER MICHAEL O’RIELLY

APPROVING IN PART AND CONCURRING IN PART

Re:
Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114
As more Americans rely exclusively on mobile phones, we must ensure that first responders can
quickly and accurately locate wireless callers that dial 911 in an emergency. For this reason, I am
supportive of issuing today’s notice.
Going forward, however, we should avoid imposing location accuracy rules that are too far ahead
of available technology. Aspirational goals are laudable, but they cannot be the basis for regulation. Any
requirements that develop from this proceeding must be truly feasible as judged by experts operating in
the field.
The deadlines we impose must also be realistic. I am concerned that the proposed timelines for
implementing indoor location accuracy requirements do not meet this objective. Many steps are needed
to deploy these new technologies. Vendors will have to test their technology and go through the
standards setting process. Location systems will have to be built. Hardware will have to be added to
handsets. New handsets will have to be introduced to consumers and achieve sufficient market
penetration. This all takes time.
In fact, the record suggests that, after a system-wide deployment of new technology, it can take
approximately four years for upgraded handsets to comprise 67 percent—and approximately five years to
comprise 80 percent—of the total phones on a wireless provider’s network.1 We must ask whether it is
possible, within two, three or even five years, for wireless providers to meet the proposed location
accuracy requirements for 67 or 80 percent of all indoor calls to 911 when the necessary handsets may not
even make up 67 or 80 percent of the total phones in the marketplace.
We learned these important lessons with the Phase II location accuracy rulemaking. There, the
Commission established requirements and deadlines based on representations of emerging, as opposed to
proven, technologies. It is fair to say that implementation did not go smoothly. A year after these rules
were adopted, the Commission had to modify its benchmarks to “provide carriers with a reasonable
prospect of meeting the [Phase II] accuracy and reliability requirements.”2 Despite this relief, the
Commission still had to issue approximately 40 waivers, extensions or stays and a dozen enforcement
actions.3
For these reasons, I regret that I must concur to the proposed deadlines in the notice. I look
forward to engaging with stakeholders regarding timeframes in which it is feasible to meet the proposed
indoor location accuracy requirements. One idea is basing the effective date of any rules on a successful
demonstration, in a test bed, that there is technology available that meets the location accuracy
requirements, but there may be others. We want to ensure that industry is capable of implementing any
rules both timely and successfully so that this information is available for first responders.
Separately, I am pleased that the notice raises important questions about privacy. I hope the
Commission will examine the privacy implications of advanced technologies and government access to

1 Letter from Joseph P. Marx, Assistant Vice President, AT&T Services Inc., to Marlene H. Dortch, Secretary, FCC,
Attachment, at 4 (Jan. 31, 2014).
2 Letter from Brian M. Josef, CTIA-The Wireless Association, to Marlene H. Dortch, Secretary, Federal
Communications Commission, at 1 (Feb, 14, 2014) (citing Revision of the Commission’s Rules to Ensure
Compatibility with Enhanced 911 Emergency Calling Systems
, Fourth Memorandum Opinion and Order, 15 FCC
Rcd 17442 ¶ 23 (2000)).
3 Id. at 2.
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consumers’ location information. We need to be extremely careful with such data as technology evolves
to better pinpoint a user’s location for use in emergencies. We are entering a world where the
Commission may require the ability to identify a person’s location within 3 meters vertically—which is
basically at floor level—and 50 meters horizontally. Law-abiding Americans should not have to worry
about being tracked by law enforcement or other government entities in non-emergency circumstances.
Finally, I appreciate hearing from Steve Souder, the Director of the Department of Public Safety
Communications for Fairfax County, Virginia and thank him for joining us here today. His perspective is
helpful to our process and I applaud his service. I would, however, like to take this opportunity to echo
the comments made by Chairman Wheeler at our last Open Meeting. Just as we look to require providers
of technology to improve their public safety offerings, we need Public Safety Answering Points (PSAPs)
to modernize their capabilities as well.
I thank the Chairman for including a number of my edits and the dedicated staff of the Public
Safety and Homeland Security Bureau for all of their hard work on this notice. I also thank my colleague
Commissioner Rosenworcel for her work on this issue.
95

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