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iCERT Supports NENA, NASNA, Texas 911 Alliance, CSEC Request for Extension to File Comments

FCC PS Docket No 07-114 (Wireless 911 Location Accuracy - Z-Axis)

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January 30, 20202 Washington, D.C.

NOTE: While it supports this filing, iCERT's support is not an endorsement of any of the Parties' filings in this pleading. Many iCERT members have filed thoughtful Comments and Replies in this FCC Docket reflecting a variety of positions on the regulatory and technical issues addressed therein. iCERT, itself, has not filed a separate Comment or Reply in this matter, and is not committing to file a position in the future.

The Industry Council for Emergency Response Technologies (iCERT),[1] the National Association of State 9-1-1 Administrators (“NASNA”),[2] NENA: The 9-1-1 Association (“NENA”),[3] the Texas 9-1-1 Alliance,[4] and the Texas Commission on State Emergency Communications[5] (collectively, “Petitioners”) hereby respectfully submit this request for an extension of the comment and reply comment deadlines in the above-captioned proceedings, currently set for February 18, 2020 and March 16, 2020, respectively.[6] The Petitioners hereby request that comments be due no later than February 21, 2020, and that reply comments be due no later than March 20, 2020. A short extension of the aforementioned deadlines will serve the public interest by allowing time for crucial policy, technical, operational, and business conversations to take place during key stakeholder meetings scheduled during the comment and reply comment periods.

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The Petitioners recognize that requests to extend filing deadlines are not routinely granted. However, the Commission has previously found that an extension is warranted when it is necessary to ensure the Commission receives full and informed responses and that the affected parties have a meaningful opportunity to develop a complete record for the Commission’s consideration.[7] The Petitioners here seek an extension of time to allow interested parties to analyze the complex and expansive issues raised in the FNPRM regarding the evolving indoor location accuracy ecosystem and the feasibility of large-scale indoor 3D mapping and addressing. The Petitioners welcome this discussion and believe it is of paramount importance for the Commission to develop a full and complete record in this proceeding. Under these circumstances, Petitioners believe that a brief extension of time is warranted. Document Document


Date: Tuesday, February 4, 2020 Subject: Wireless E911 comment extension order

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The Public Safety and Homeland Security Bureau grants the joint request for extension of the comment cycle in the wireless E911 proceeding. See


Policy and Licensing Division

Public Safety and Homeland Security Bureau

Federal Communications Commission


[1] iCERT — the Industry Council for Emergency Response Technologies — is the exclusive trade association championing commercial public safety response technology providers and related organizations. iCERT improves the public safety ecosystem through ensuring that the needs and views of commercial technology providers are recognized and accommodated by all levels of government, driving continuous technology improvements, education, and helping our members reach their organic and marketplace growth objectives.

[2] NASNA represents state 911 programs in the field of emergency communications. NASNA provides state 911 leaders’ unique expertise to national trade associations, public policymakers, the private sector, and emergency communications professionals at all levels of government as they address complex issues surrounding the evolution of emergency communications.

[3] NENA: The 9-1-1 Association improves 9-1-1 through research, standards development, training, education, outreach, and advocacy. Our vision is a public made safer and more secure through universally-available state-of-the-art 9-1-1 systems and trained 9-1-1 professionals. NENA is the only professional organization solely focused on 9-1-1 policy, technology, operations, and education issues.

[4] The Texas 9-1-1 Alliance is an interlocal cooperation entity composed of 26 Texas emergency communication districts with E9-1-1 service and related public safety responsibility for more than 63% of the population of Texas. These emergency communication districts were created pursuant to Texas Health and Safety Code Chapter 772 and are defined under Texas Health and Safety Code Section 771.001(3)(B).

[5] The Texas Commission on State Emergency Communications ("CSEC") is a state agency created pursuant to Texas Health and Safety Code Chapter 771, and by statute is the state's authority on emergency communications. CSEC's membership includes representatives of the Texas 9-1-1 Entities and the general public, and CSEC directly oversees and administers the Texas state 9-1-1 program under which 9-1-1 service is provided in 206 of Texas' 254 counties, covering approximately two-thirds of the state's geography and one-fourth of the state's population.

[6] See Public Safety and Homeland Security Bureau Announces the Effective Date and Comment Cycle for the Vertical Location Accuracy (Z-Axis) Fifth Report and Order and Fifth Further Notice of Proposed Rulemaking, Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114, (January 16, 2020) (“PN”), referencing 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) (“FNPRM”).

[7] E.g., Public Safety and Homeland Security Bureau, Order Granting Request for Extension of the Reply Comment Deadline, DA No. 15-299 (March 6, 2015) (In the Matters of 911 Governance and Accountability and Improving 911 Reliability, Docket Nos 14-193 & 13-75)).

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