NENA Comments on Z-Axis Report & Order and Further Notice of Proposed Rulemaking

The Federal Communications Commission (FCC) recently published a draft Report & Order and Further Notice of Proposed Rulemaking that, if adopted at the commission’s November 19 meeting, will significantly improve 9-1-1’s ability to locate callers in multi-story buildings. These rules and proposals are a great step forward for 9-1-1 and for everyone who relies on public safety responders. The rules will help ensure that the telecom industry keeps the promises it made to the public in their 2015 Z-Axis Roadmap, and the FNPRM’s proposals tee up further proceedings on related issues we will face as we move forward.

Here’s a quick summary of the draft.

The R&O will:

1. Set the z-axis metric. The R&O will set a z-axis accuracy metric of ±3 meters for 80% of wireless 9-1-1 calls from all z-axis capable handsets, that is, any handsets that can communicate their vertical location without a hardware upgrade.

2. Set z-axis deployment benchmarks. Nationwide carriers will be required to deploy z-axis technology that meets this metric in the top 25 Cellular Market Areas (CMAs) by April 3, 2021 and in the top 50 CMAs by April 3, 2023.

3. Require validation of z-axis accuracy. Carriers will have to validate through testing that their z-axis technology meets the metric through the same method we use for validating x- and y-axis location accuracy.

4. Harmonize confidence requirements. Z-axis location information will now have to conform to the same confidence requirements as x-and y-axis information (90%).

5. Extend privacy protections for NEAD data. The FCC’s existing privacy and security protections for data from the National Emergency Address Database (NEAD) will now extend to any 9-1-1 geolocation data stored by a wireless carrier.

The FNPRM seeks comment on:

1. Benchmarks after 2023. Should the FCC require even more precise location accuracy metrics after 2023?

2. Floor level. Should carriers have to report a 9-1-1 caller’s specific floor level, and if so, how?

3. Tweaking deployment requirements. Instead of requiring that 80% of a CMA’s population be covered by z-axis technology, should the FCC instead require that 80% of a CMA’s buildings over a certain height be covered? Should the FCC measure compliance on a CMA-by-CMA basis at all, or should it use another delineation?

4. Non-NEAD DL services. Should carriers be allowed to use dispatchable location solutions other than the NEAD? 

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