publicSafety

E911 Filing

August 25, 2008 8:46 PM

The Honorable Kevin Martin
Chairman
Federal Communications Commission
445 12th Street, S.W.
Washington, DC 20554

Re: PS Docket 07-114

Dear Chairman Martin:

The Association of Public-Safety Communications Officials, International (APCO), the National Emergency Number Association (NENA), and AT&T Mobility (AT&T) submit this letter to propose improved compliance measurements for the Commission's wireless E911 location accuracy rules governing network-based technologies. APCO, NENA and AT&T have worked together to develop technologically feasible compliance measurements that improve the ability of providers to locate customers making calls to 9-1-1 from wireless phones.

This letter outlines these proposed compliance measurements for carriers using network-based technologies. As referenced in APCO and NENA's July 14, 2008 letter to Chief Derek Poarch, these proposed rules would measure wireless 9-1-1 location accuracy at the county level, but the undersigned parties also recognize that it is not technically feasible for carriers to meet the current accuracy standard in all counties using location accuracy technology currently available. Accordingly, the undersigned parties agree that any location accuracy rules that the Commission adopts for carriers that employ network-based solutions must be limited to the metrics and schedules set out here. These proposed compliance measurements will ensure that over time the wireless industry will continue to improve accuracy levels as technology develops.

As 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, carriers who employ network-based location solutions may be expected to deploy handset-based solutions as an overlay to existing network-based solutions in order to meet the more stringent county-level requirements set forth below. To encourage the improvements in location accuracy that may be achieved using both network and handset based solutions, this proposal provides that network-based carriers may elect to use a system of blended reporting for their accuracy measurements, as defined below. Carriers also may elect to report accuracy in any county based solely on the handset-based accuracy standards. The specifics of the proposal are as follows:

Accuracy Standards for Network-Based Location Solution Carriers:

67%/100M: 67 percent of all calls, measured at the county level, shall be located within 100 meters in each county by the end of year 5, in accordance with the interim benchmarks below; and
90%/300M: 90 percent of all calls, measured at the county level, shall be located within 300 meters in 85 percent of all counties by the end of year 8, in accordance with the interim benchmarks below.

Applicability of Accuracy Standards: The county-level location accuracy standards will be applicable to those counties, on an individual basis, for which a network-based carrier has deployed Phase II in at least one cell site located within a county's boundary. Compliance with the 67 percent standard and compliance with the 90 percent standard in a given county shall be measured and reported independently (i.e. the list of compliant counties for the 67 percent standard may be different than for the 90 percent standard).

Blended Reporting: Accuracy data from both a network-based solution and a handset-based solution may be blended to meet the network-based standard. Such blending shall be based on weighting accuracy data in the ratio of aGPS handsets to non-aGPS handsets in the carrier's subscriber base. The weighting ratio shall be applied to the accuracy data from each solution and measured against the network-based standards.

Example of blended reporting at 60% penetration of aGPS devices in the network:

Metric Network-based Average Handset-based Average Blended Result
67%/100M 120M 40M 72M
90%/300M 400M 100M 220M

The blended results are derived by combining 40% of the network-based average with 60% of the handset-based average to produce a blended average for the county.

Network-Based Solution Compliance Benchmarks

67%/100M NETWORK-BASED ACCURACY STANDARD

End of Year 1: Carriers shall comply in 60% of counties, which counties shall cover at least 70% of the POPs covered by the carrier, network-wide. Compliance will be measured on a per county basis using existing network-based accuracy data.

End of Year 3: Carriers shall comply in 70% of counties, which counties shall cover at least 80% of the POPs covered by the carrier, network-wide. Compliance will be measured on a per county basis, using, at the carrier's election, either: (i) network-based accuracy data; or (ii) blended reporting.

End of Year 5: Carriers shall comply in 100% of counties. Compliance will be measured on a per county basis, using, at the carrier's election, either: (i) network-based accuracy data; (ii) blended reporting; or (iii) subject to the following caveat, solely handset-based accuracy data (at handset-based accuracy standards).

A carrier may rely solely on handset-based accuracy data in any county if at least 95% of its subscribers, network-wide, use an aGPS handset, or if it offers subscribers in that county who do not have an aGPS device an aGPS handset at no cost to the subscriber.

90%/300M NETWORK-BASED ACCURACY STANDARD

End of Year 3: Carriers shall comply in 60% of counties, which counties shall cover at least 70% of the POPs covered by the carrier, network-wide. Compliance will be measured on a per county basis using, at the carrier's election, either: (i) network-based accuracy data; or (ii) blended reporting.

End of Year 5: Carriers shall comply in 70% of counties, which counties shall cover at least 80% of the POPs covered by the carrier, network-wide. Compliance will be measured on a per county basis using, at the carrier's election, either: (i) network-based accuracy data; or (ii) blended reporting.

End of Year 8: Carriers shall comply in 85% of counties. Compliance will be measured on a per county basis using, at the carrier's election, either: (i) network-based accuracy data; (ii) blended reporting; or (iii) subject to the caveat above, solely handset-based accuracy data (at handset-based accuracy standards).

ETAG: An ETAG (E911 Technical Advisory Group) shall be established to work with the E911 community to address open issues within this framework (e.g., updated outdoor and indoor accuracy measurement methodologies, tactics for improving accuracy performance in challenged areas, testing of emerging technology claims, E911 responsibilities in an open-access environment, the development of hybrid network-AGPS technologies, etc.).

Confidence and Uncertainty: Confidence and uncertainty data shall be provided on a per call basis upon PSAP request. This requirement shall begin at the end of Year 2, to allow testing to establish baseline confidence and uncertainty levels at the county level. Once a carrier 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.

Sincerely,

Brian Fontes
CEO
NENA

Robert M. Gurss
Director, Legal & Gov't Affairs
APCO

Robert W. Quinn, Jr.
SVP - Federal Regulatory
AT&T