NENA Comments on Z-Axis Report & Order and Further Notice of Proposed Rulemaking
Thursday, October 31, 2019
Posted by: Chris Nussman
Earlier this week, the Federal Communications Commission (FCC) published a draft Report & Order and Further Notice of Proposed Rulemaking that, if adopted at the commission’s November 19 meeting, will significantly improve 9-1-1’s ability to locate callers in multi-story buildings. These rules and proposals are a great step forward for 9-1-1 and for everyone who relies on public safety responders. The rules will help ensure that the telecom industry keeps the promises it made to the public in their 2015 Z-Axis Roadmap, and the FNPRM’s proposals tee up further proceedings on related issues we will face as we move forward.
First, here’s a quick summary of the draft.
The R&O will:
1) Set the z-axis metric. The R&O will set a z-axis accuracy metric of ±3 meters for 80% of wireless 9-1-1 calls from all z-axis capable handsets, that is, any handsets that can communicate their vertical location without a hardware upgrade.
2) Set z-axis deployment benchmarks. Nationwide carriers will be required to deploy z-axis technology that meets this metric in the top 25 Cellular Market Areas (CMAs) by April 3, 2021 and in the top 50 CMAs by April 3, 2023.
3) Require validation of z-axis accuracy. Carriers will have to validate through testing that their z-axis technology meets the metric through the same method we use for validating x- and y-axis location accuracy.
4) Harmonize confidence requirements. Z-axis location information will now have to conform to the same confidence requirements as x-and y-axis information (90%).
5) Extend privacy protections for NEAD data. The FCC’s existing privacy and security protections for data from the National Emergency Address Database (NEAD) will now extend to any 9-1-1 geolocation data stored by a wireless carrier.
The FNPRM seeks comment on:
1) Benchmarks after 2023. Should the FCC require even more precise location accuracy metrics after 2023?
2) Floor level. Should carriers have to report a 9-1-1 caller’s specific floor level, and if so, how?
3) Tweaking deployment requirements. Instead of requiring that 80% of an CMA’s population be covered by z-axis technology, should the FCC instead require that 80% of a CMA’s buildings over a certain height be covered? Should the FCC measure compliance on a CMA-by-CMA basis at all, or should it use another delineation?
4) Non-NEAD DL services. Should carriers be allowed to use dispatchable location solutions other than the NEAD?
With that said, let’s unpack things a bit from NENA’s perspective.
We’re pleased with the ±3m standard, and we’re not alone.
It’s safe to say that public safety stands behind the FCC’s draft rules. A number of public safety organizations commented in this proceeding — and almost all of them agreed on the major points. The Boulder Regional Emergency Telephone Service Authority (BRETSA), International Association of Fire Chiefs (IAFC), the International Association of Fire Fighters (IAFF), the National Association of State EMS Officials (NASEMSO), the National Public Safety Telecommunications Council (NPSTC), the National Sheriffs Association, and the Texas 911 Entities all called for ±3m vertical location accuracy metric.
Why we chose the ±3m metric.
The ±3m vertical accuracy requirement for 80% of calls is great for public safety because it strikes a balance between what we can feasibly do now and what we need to save lives. Anything less accurate than ±3 meters and we’re looking at an uncertainty range of at least three floors in an average building. Asking for anything more accurate would push the wireless carriers beyond the boundaries of current location solutions. We’re excited because we believe that undistorted, accurate x/y/z-axis information will open up a new world of dispatchable location solutions for public safety, promoting technology-neutral innovation in indoor location accuracy, mapping, and addressing.
Why we didn’t ask for a floor-level location mandate.
The short answer is: It can’t be done reliably. Ever been in an office that featured a two-floor atrium, where half of the offices were part of a loft, or maybe a Floor 7 1/2?
The problem for 9-1-1 is that nobody has a dataset of all the various layouts in existing office buildings. We don’t have a database of all the multistory lobbies or split-level office units, nor a database that accounts for buildings that are built into an incline and have two distinct “ground floors” (FCC staff know all about this). To require wireless carriers to provide this information would either be viewed as impossible, or would result in a hasty mathematical solution — just divide the height above ground level of the call by 4.3 meters (the average height of a floor). Maybe it’ll be right, maybe it won’t; but hey, at least we’ll have a floor level!
Jokes aside, public safety needs data to be accurate before it’s actionable.
And if we’re talking about what the wireless carrier provides to the 9-1-1 network, we can work taking accurate information and making it actionable — but we can’t go the opposite direction.
Why we didn’t ask for “dispatchable location.”
Similar to floor level, public safety’s problem has always been that no one has complete, accurate, nationwide datasets of indoor addresses. Hotels may have relatively predictable guest room numbering schemes, but — as anyone who has ever been to a conference center or resort can tell you — expo-hall naming schemes can be literally anything. Confusing and unconventional addressing schemes afflict office buildings, as well: Floor plans may feature a mixture of cubicles and offices and may have 5- or 6-character alphanumeric addresses, which even employees may be unfamiliar with. The situation often gets worse in hoteling situations, where employees fly into HQ to spend a few days each month attending in-person meetings and are generally unfamiliar with the campus layout. You get the idea here.
If the FCC requires that wireless carriers deliver a “dispatchable location,” what happens when that location is wrong? Will the door to kick down be the wrong one? What happens if the location is correct, but it’s presented to the telecommunicator as Office G-1475b. Is that right next to G-1575b, or is it a floor above that?
In the future, we may have nationwide 3D maps for all buildings — maps that contain addresses and wayfinding information, structured in a way that responders can navigate quickly and seamlessly. To achieve that, we first need accurate x/y/z information. Only then will the market move forward to create robust, reliable maps and address databases.
The 3D mapping “innovation greenfield.”
The core of our request to the FCC was for 3D location, delivered in a standards-compliant, x/y/z format. The x/y/z format is critically important for us because we envision a future in which 9-1-1 has 3D maps of every multistory building in its jurisdiction. Those 3D maps could come from well-known players in the GIS world — NENA partners like Esri, GeoComm, and others — or they could come from commercial mapping giants like Google or Microsoft. Even small startups could get in on the action, making use of innovative mapping technologies, to beat more established competitors in the market. As long as vendors adhere to standards like NENA’s Next Generation 9-1-1 i3 family of standards, experienced incumbents and innovative startups can compete head-to-head on the merits of their products, keeping costs down for public safety, and innovation high.
As you can likely gather, setting z-axis metrics for location accuracy is just a first step in a long journey toward seamless 9-1-1 indoor location and response. We need to determine the best method for making sure z-axis and dispatchable location solutions are deployed to places and people that need them most. We need to determine whether the FCC’s location accuracy requirements need to be narrowed beyond the 2023 benchmarks. We need to determine how best to best map multi-story buildings, both old and new. We need to determine how to identify “dispatchable location”s and operationalize that information so field responders know exactly where to go. And we need to figure out how to do all of this inexpensively — so any PSAP that needs this important technology can get it. The FCC’s FNPRM smartly tees up a lot of these important questions, and we’re looking forward to working on them together with public safety, industry, and the Commission.