FCC Seeks to Refresh Record on Location-Based Routing for Wireless 911 Calls Comments due July 11, 2022 Reply Comments due July 25, 2022

The Federal Communications Commission (“FCC” or “Commission”) has issued a Public Notice seeking to refresh the record on location-based routing for wireless 911 calls in light of technological improvements and industry implementation of location routing technologies since the 2018 Notice of Inquiry on Location-Based Routing for Wireless 911 Calls. The FCC seeks comment on a number of matters related to the feasibility of location-based routing rather than cell site based routing, as a means of reducing the incidence of misrouted wireless calls to 911, specifically cell sector-misroutes, and improving emergency response times.

The FCC seeks comment on developments in location-based routing that have occurred since 2018, the extent of the problem with cell sector-based misroutes, the interdependency between location-based routing technologies and NG911, the status of current location-based routing technologies (including the five technologies identified by CSRIC V),1 the feasibility of implementing location-based routing for text-to-911, security or privacy concerns of location-based routing, and means for improving 911 routing. In particular for small carriers, the Commission inquires about the extent to which they have implemented location-based routing solutions, and whether there are specific considerations needed with respect to implementing location-based routing for 911 calls.

Please contact Robin Tuttle at [email protected] or Greg Whiteaker at [email protected] if you have question about the future of location-based routing for 911 calls, or if you would like to participate in refreshing the record.

[1] The five methods of location-based routing identified by CSRIC V include: (1) holding 911 calls until Phase II location data becomes available; (2) an interim or quick fix method that would hold calls at a wireless MSC or the PSAP gateway for up to six seconds to allow the wireless carrier time to deliver X/Y coordinates; (3) registered or provisioned civic address for certain devices; (4) device-based hybrid location; and (5) wireless 911 location accuracy emerging technologies.