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APCO-Petition for Clarification 911 Wireless Location Accuracy

FCC PS Docket No. 07-114 Wireless 911 Location Accuracy

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Friday, February 7, 2020

APCO has filed a Petition for Clarification, requesting that the Federal Communications Commission (FCC) provide clarity on the location information wireless carriers must provide with 9-1-1 calls made from indoor locations.

Last November, the FCC established rules that will require carriers to provide an estimate of the caller’s altitude information – such as “149 meters height above ellipsoid” (a technical measure of altitude that differs from height above ground level or sea level) – and in some cases the floor level – “5th floor.”  

With this Petition, APCO asks for the FCC to clarify several aspects of the rules so that emergency communications centers can raise appropriate concerns with the carriers and FCC in the event that carriers are not meeting the 9-1-1 location accuracy requirements. 


The Association of Public-Safety Communications Officials-International, Inc. (APCO)1 submits this Petition for Clarification in response to the Federal Communications Commission’s (Commission) Fifth Report and Order regarding wireless E9-1-1 location accuracy requirements.2 I.

Introduction and Summary

APCO seeks clarification of the Commission’s Fifth Report and Order regarding wireless E9-1-1 location accuracy requirements. APCO’s intent is to clarify the rules, within the framework of the Order as adopted, so that wireless carriers provide the 9-1-1 location information expected for the benefit of public safety on the timeline established by the Commission. Emergency communications centers (ECCs) will be in the best position to know if carriers are providing z-axis information that complies with the metric, but clarification is needed so that, in the event of non-compliance, ECCs can raise appropriate concerns with the carriers and Commission.

As described in this Petition, several aspects of the Order require clarification. For example, which phones should consumers expect to provide vertical location information with 9- 1-1 calls? How do carriers ensure that they have deployed z-axis technology in a manner that will achieve the accuracy demonstrated in the test bed? What additional z-axis technology testing is required, given that the testing described in CTIA’s Stage Z Test Report was not sufficient to demonstrate compliance with the z-axis metric? When must carriers provide floor level information in addition to the altitude of a 9-1-1 caller? APCO respectfully requests swift action by the Commission to ensure there is no risk of delay to the location accuracy benchmarks. "


1 Founded in 1935, APCO is the nation’s oldest and largest organization of public safety communications professionals. APCO is a non-profit association with over 35,000 members, primarily consisting of state and local government employees who manage and operate public safety communications systems – including 9-1-1 Emergency Communications Centers (ECCs), emergency operations centers, radio networks, and information technology – for law enforcement, fire, emergency medical, and other public safety agencies.

2 Wireless E911 Location Accuracy Requirements, Fifth Report and Order and Fifth Further Notice of Proposed Rulemaking, FCC 19-124 (rel. Nov. 25, 2019) amended by Erratum (rel. Jan 15, 2020) (“Z-Axis Order”).

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