FCC Adopts E911 Vertical Location Accuracy Metric (Z-Axis)
In 2015, the Federal Communications Commission (“FCC” or “Commission”) adopted rules for improving E911 wireless location accuracy, including vertical location requirements by requiring CMRS providers to provide either dispatchable location using the National Emergency Address Database (“NEAD”) or vertical (z-axis) location information in compliance with a yet-to-be determined FCC approved metric. Following industry testing and proposals for a z-axis accuracy metric, the Commission sought comment on a proposed z-axis metric. In the 2019 Fifth Report and Order, the FCC adopted the vertical location accuracy metric (z-axis) summarized below. The FCC also is seeking further comment on whether to adopt more stringent standards in the future and whether to expand the vertical location accuracy requirements.
Z-Axis Requirement Applies to Nationwide and Non-Nationwide CMRS Providers in Top 25 and Top 50 CMAs
Nationwide CMRS providers must deploy either dispatchable location or the z-axis accuracy metric for wireless E911 calls in the top 25 CMAs by April 3, 2021, and in the top 50 CMAs by April 3, 2023. Non-nationwide CMRS providers serving the top 25 and top 50 CMAs have an additional year to meet the wireless E911 vertical location accuracy benchmarks, specifically until April 3, 2022 and April 3, 2024 respectively. The Order adopting these new requirements becomes effective on March 16, 2020.
Metrics, Capable Devices, Format, and Qualifications
The vertical location accuracy metric is 3-meters above or below the handset for 80% of all wireless E911 calls. This standard applies to all handsets that have the capability to support vertical location, regardless of technology. Devices that can be modified by firmware or a software upgrade are considered z-axis capable, but not devices that would require a hardware upgrade. The z-axis information must be reported as Height Above Ellipsoid (HAE). Providers may only use 911 call z-axis information for 911 purposes with certain exceptions.
Information Provided to PSAPs
CMRS providers must provide vertical confidence and uncertainty data on a per call basis to requesting PSAPs using a confidence level of 90%, and floor level information where available. There is no requirement to translate HAE to other formats when delivering to PSAPs, but again, if providers have reliable information about a caller’s floor level then they should provide it.
Reporting to FCC and Public Safety Organizations
Live call data reporting now includes z-axis data, and floor level information where available. If providers are using z-axis technology for vertical location, they must certify by the compliance deadlines that the technology is deployed consistent with the manner in which it was tested in the test bed.
Further Comment Sought
The FCC is seeking further comment on: (1) whether to establish a long-term timeline for a more stringent z-axis metric, specifically 2 meters; (2) whether to require CMRS providers to deliver floor level information, requiring conversion from the z-axis; (3) expansion of options for demonstrating deployment of z-axis or dispatchable location capability beyond population-based CMA coverage, such as urban and dense urban areas where multi-story buildings are concentrated and through deploying z-axis capable handsets nationwide; (4) a timeline for affording new z-axis deployment options to non-nationwide CMRS providers; (5) costs and benefits of possible nationwide deployment of z-axis technology, resulting in a nationwide x, y, and z location accuracy standard; and (6) allowing CMRS providers to demonstrate dispatchable location deployment by means other than NEAD reference points.
Consolidation of 911 Rules in Part 9
In a related matter, the FCC’s E911 indoor location accuracy rules, including the vertical location accuracy requirements, which were previously located in FCC Rule Section 20.18, have been consolidated with all of the FCC’s 911 rules into Part 9 of the FCC Rules. The E911 location accuracy rules are now FCC Rule Section 9.10. The consolidation of 911 was adopted without substantive changes to the existing rules in the FCC’s Order implementing Kari’s Law and Section 506 of the Ray Baum Act in August 2019.
If you have questions about the vertical location accuracy requirements, please contact Greg Whiteaker at [email protected] or Robin Tuttle at [email protected].
