FCC Extends Comment Dates on Wireless E911 Z Axis R&O and FNPRM
Updated: Feb 26
On Monday, November 25, 2019, the Commission released the Fifth Report and Order and Fifth Further Notice of Proposed Rulemaking (“R&O” and “FNPRM”) in the Wireless E911 Location Accuracy Requirements proceeding, which was adopted in the November Open Meeting (PS Docket No. 07-114). The R&O adopts a vertical location accuracy metric, or “z-axis”, for wireless E911 calls of plus or minus 3 meters and geographic requirements for the top Cellular Market Areas (“CMAs”). The FNPRM proposes and seeks comment on additional measures to improve E911 location accuracy, including long-term timelines and demonstration requirements.
The adopted R&O and FNPRM included several clarifications and additions from the previously circulated draft item. Specifically, the adopted item clarifies its definition of “z-axis capable” devices and adds additional context from the record to support the adopted 3-meter metric. The R&O also requires that, where available, providers must provide floor level information with their associated confidence and uncertainty data and live call data reporting. The adopted R&O additionally expands the privacy and security provisions regarding 911 call information, requiring CMRS providers to certify that neither they nor any third parties or vendors they rely on are using or storing data for non-911 purposes, and adds that 911 data may be used for non-911 data purposes with prior express consent. The FNPRM seeks additional comment on the feasibility of a 2-meter metric, floor level reporting for emergency communications, dispatchable location data, and other approaches to z-axis deployment.
On January 16, 2020, the Commission published the Fifth Report and Order and Further Notice of Proposed Rulemaking in the Federal Register therefore establishing the following effective date and comment dates:
The R&O is effective March 16, 2020. As noted in the Federal Register, compliance will not be required for Sections 9.10(i)(2)(ii)(C) and (D) (April 2021 and April 2023 3-meter metric benchmark compliance deadlines), (i)(4)(v) (required z-axis use certification), (j)(4) (providing confidence and uncertainty data, and where available, floor level information) until the Commission publishes a document in the Federal Register announcing the compliance date.
Comments on the FNRPM are due February 18, 2020.
Reply comments are due March 16, 2020.
On Tuesday, February 4, 2020, the Commission released an Order granting a Joint Petition for Extension of Comment and Reply Comment Deadlines (“Joint Petition”) filed on behalf of several public safety entities, requesting a short extension of the comment deadlines.
The Order grants the Joint Petition’s request to extend the deadline for comments in this proceeding until February 21, 2020, and reply comments until March 20, 2020. Petitioners cite to filing challenges with “three major events in the 911 policymaking space” and the need to fully analyze the issues regarding indoor location accuracy and indoor 3D mapping and addressing. The Commission accordingly finds good cause to extend these deadlines to ensure a robust and complete record in this proceeding.
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