Here at Polaris Wireless, our commitment to public safety includes engaging with other industry stakeholders such as wireless carriers, advocacy groups, technology vendors, and the Federal Communications Commission (FCC), where engineers meet lawyers and lobbyists to create regulation that serves a purpose, meets specific needs, and is achievable within established timeframes.
The regulation driving some of our innovation is the wireless enhanced 911 (E911) location accuracy rules, first adopted in 1996. These rules have been changed over the years as wireless carrier networks have evolved, devices have become ‘smarter’, there is increased use of mobile phones for 911, and location technologies have improved. We all know that our phones can find us with seemingly high accuracy, yet behind the scenes, location accuracy for E911 was lagging. This really came to light in the 2013 timeframe when the public safety community started noticing and voicing this disparity. After a couple of years of discussion, workshops, and debate, in 2015 the FCC adopted a Fourth Report and Order in the matter of Wireless E911 Location Accuracy Requirements.
This Report and Order mandated new indoor wireless E911 location accuracy requirements for both horizontal and vertical location. Because there was insufficient data to reasonably set a vertical, or z-axis, accuracy benchmark, the FCC asked the wireless industry to test technologies and make a recommendation. Polaris Wireless was one of two companies that participated in independent testing in early 2018, which led to quite a bit of public comments and ultimately to the FCC issuing a Fourth Further Notice of Proposed Rulemaking in March 2019 in which they proposed a z-axis requirement. We’re not done yet, though. These proposed rules are not yet final.
I’ll address the details and key discussion points in a future post. For now, I’d like to shed some light on the process for rulemaking since this is not widely known or understood by those not directly involved.
- The FCC issues a Public Notice seeking industry comment on topics of interest. It can issue multiple notices on any topic, requesting broad input, such as state of the market or technology, or it can request specific input.
- Then the FCC issues a Notice of Proposed Rulemaking (NPRM) or Further NPRM (FNPRM) where it outlines its proposal and highlights questions to be answered or issues to be clarified.
- Lastly the FCC issues a Report and Order with final rules.
Throughout this process, members of the industry, or anyone interested in the topic, can file comments within specified timeframes. Additionally, anyone can meet face to face with the FCC on these proceedings. These interactions, and all associated documents, are fully public, so that anyone wishing to educate themselves on the status of a given issue can access and read through what has been submitted. The FCC will consider all of this information when deciding on the final rules, so it is critical that key stakeholders participate.
All of the filings related to the current z-axis proceedings can be found on the FCC Electronic Comment Filing System here.
This is no trivial matter, so I do what I can to stay in touch with wireless carriers, public safety advocates, and other vendors. We have also filed comments and I have met with the FCC many times. While there are many different topics of discussion and debate, we have focused on providing awareness of what our high-accuracy, indoor, and 3D location technology can provide for the public safety community. I look forward to updating you on how Polaris Wireless has been participating in this process for Z-axis location.
