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Leading Public Safety Orgs React with Anger, Offer Alternatives to Secret Carrier Deal on 9-1-1 Location

Date: 2014-11-19
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Secret Deal Lacks "Consensus" and Garners Strong Opposition From Law Enforcement, Fire Fighters, EMS, Deaf/Hard of Hearing Groups Including Former President of NENA and California NENA President

 

More than a dozen of the nation's leading public safety advocates and organizations reacted with anger and alternative approaches to a carrier-backed proposal announced on Friday that would replace the FCC's proposed public safety rules for wireless 9-1-1 location accuracy with a "best efforts" approach that delays implementation and weakens or eliminates many of the safety requirements of the FCC's proposed rules.

Public safety leaders unfurl a banner at the Federal Communications Commission's workshop on wireless 9-1-1 location accuracy on September 9, 2013 (PRNewsFoto/Find Me 911 Coalition)

 

The deal was negotiated in secret by the major wireless carriers and ratified by the executives of two groups, the Association of Public-Safety Communications Officials (APCO), and the National Emergency Number Association (NENA), without the involvement of major stakeholder organizations representing police, fire, EMS, public safety, consumers, seniors, victims, or the deaf/hard-of-hearing.  Individuals and organizations submitting joint comments in opposition to all or part of the deal included:

  • R. Craig Whittington, former NENA President, 2009-2010
  • Danita Crombach, President of the California state chapter of NENA
  • National Association of Sheriffs'
  • International Association of Chiefs of Police
  • International Association of Fire Chiefs
  • National Association of State Emergency Medical Services Officials
  • Emergency Medical Services Medical Directors Association of California
  • Alliance of Retired Americans
  • Telecommunications for the Deaf and Hard of Hearing
  • Deaf Seniors of America
  • Association of Late-Deafened Adults
  • Deaf and Hard of Hearing Consumer Advocacy Network
  • California Coalition of Agencies Serving the Deaf and Hard of Hearing
  • National Association of the Deaf
  • American Association of the Deaf-Blind
  • Cerebral Palsy and Deaf Organization

In addition, Nathan Lee, whose wife Denise Amber Lee was kidnapped and killed despite connecting with 9-1-1 for several minutes while captive, submitted a petition to the FCC signed by more than 120,000 emergency responders and concerned citizens urging the FCC to proceed with its original rule as drafted.

"This is absolutely not a consensus agreement, as it only appears to be supported by a handful of APCO and NENA execs, not their peers in the 9-1-1 and public safety community," said Jamie Barnett, Director of the Find Me 911 Coalition and former Chief of the FCC's Public Safety and Homeland Security Bureau. "The terms of this so-called deal are a travesty for public safety and a tragedy for consumers. The carrier proposal delays implementation of robust accuracy requirements for years longer than the FCC's proposed rule, offers no vertical accuracy standard or timeline, and abandons millions of users of existing 3G or 4G phones by focusing only on future handset design."

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"The only thing saved by this rule is carrier cash," continued Barnett. "The carriers' wireless service is a cash cow, but this highlights their refusal to make the necessary investments in the nation's 911 system to save lives. Given the lack of any meaningful commitment to fix a problem caused by the carriers, this proposal should be rejected in favor of the robust rule proposed by the agency."

Among the concerns about the deal raised by public safety advocates:

  • The carrier approach depends entirely on new and untested technologies, including a hypothetical new database and system connecting Wifi and Bluetooth locations to physical addresses. Even if validated, the design, testing, and implementation of any such technologies would take years – or decades – longer than accuracy requirements of the FCC's proposed rule.
  • While the deal announcement frequently uses the phrase "dispatchable addresses," the terms of the deal only require the use of "heightened location accuracy technologies" (HLAT) that locate callers within 50 meters, the same horizontal accuracy standard as the FCC's proposed rule.
  • The implementation timeline for those HLAT technologies in the carrier proposal is dramatically weaker than the FCC's proposed rule, with only 40 percent of wireless calls covered after two years vs. the FCC's proposed 67 percent requirement after two years.
  • In years five and six, the carrier proposal switches its compliance measurement from share of all calls to share of VoLTE calls only. As VoLTE phones have not yet been widely adopted, this likely will lead to a major drop in location accuracy.
  • Even under the optimistic and unlikely assumption that 50% of all calls will come from VoLTE phones in year five, the carrier proposal would only require an overall accuracy rate (within 50 meters) of 37.5 percent, less than half of the FCC's proposed 80 percent coverage in year five.
  • The carrier plan would offer no support for the millions of users of 3G and 4G phones without a special, as-yet nonexistent, chipset. Thus, under the best-case scenario, no users of existing phones will ever be covered under the proposed carrier approach, leaving older phone users without enhanced 911 locations.
  • There is no vertical accuracy requirement or timeline in the carrier proposal, only a three-year commitment to undertake an "assessment" of vertical status after three years and some level of undefined coverage in major markets by year six. The FCC proposal, by contrast, requires 3-meter vertical accuracy for 67% of calls by year three.

In a joint letter submitted by former NENA President R. Craig Whittington, CALNENA President Danita Crombach, Angelo Salvucci of the EMS Directors Association of California, Richard Fiesta of the Alliance for Retired Americans, Claude Stout of Telecommunications for the Deaf and the heads of half a dozen other organizations representing the deaf and hard of hearing, the groups said:

"Despite the important roles our organizations play in representing public safety professionals, seniors, and deaf/hard of hearing Americans, we have been shut out of this process. Rather than working with other relevant stakeholders in an open and inclusive manner, the carriers have ignored any requests from our organizations to be involved, so we must share our deep concerns about the proposal openly. ... This plan is a blatant attempt by the carriers to delay, distract and dilute any proceedings that would impose real accuracy requirements that include FCC oversight and regulation. We urge you to dismiss it and adopt the strong and effective rule that the Commission has put forward."

In another joint letter and alternative plan proposed by the Association of Chiefs of Police, the International Association of Fire Chiefs, the National Association of State Emergency Medical Services Officials, and the National Sheriffs' Association, they said:

"We were not consulted on these negotiations and were not provided any details of the discussions until October 29, 2014. Our organizations are disappointed that we were not consulted earlier, because we represent the leadership of the frontline first responders who are called upon to respond to 9-1-1 emergencies every day. ... We also have concerns that many of the provisions in the roadmap must be worked out after the agreement has been finalized. For example, the roadmap depends on technology that has never been tested. It is disconcerting that the burden for providing lifesaving call information is relying on untested technology solutions."

Copies of the documents filed by organizations in opposition to the carrier plan and offering alternate approaches can be found at http://apps.fcc.gov/ecfs/proceeding/view?name=07-114.

About the Find Me 911 Coalition
Find Me 911 is an effort supported by more than 200,000 individuals, as well as national and local organizations. The individuals and organizations represent a broad range of 9-1-1 telecommunicators and first responders – emergency medical services personnel, fire fighters and police.  Find Me 911 seeks to ensure that the Federal Communications Commission (FCC) move forward quickly to establish a reasonable, measurable level of location accuracy for emergency calls made indoors, enabling first responders to locate emergency calls from wireless phones from all locations rapidly and efficiently.

[Note: See an opposing view here]

- People, Places & Things/9-1-1magazine.com (via Find Me 911), 11/17/14

 

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