July 16, 2020
The National Public Safety Telecommunications Council (NPSTC) expresses its support for the Sixth Report and Order and its adherence to the vertical location accuracy requirement that was previously adopted by the Commission mandating that wireless carriers provide z-axis location information to public safety that is accurate within +/- 3 meters for at least 80% of calls to 911. The public safety community has clearly indicated that 3 meter accuracy is the minimum threshold necessary to reliably locate wireless callers in distress. Further, the provision of 3 meter accuracy for anything less than 80% of calls from z-axis capable handsets would be insufficiently accurate to be useful as actionable information to support first responders in the field. Given the importance of highly accurate vertical location information, NPSTC also urges the Commission in the future to take further steps to ensure that there are continual improvements in vertical location accuracy. For example, NPSTC strongly supported tightening the vertical metric to 2 meters, or even 1 meter if possible, in the relatively near future. As NPSTC has previously observed, at least one location technology vendor has already demonstrated accuracy of better than 2 meters, indicating that the timeframe required for tightening the requirement may not be lengthy.
Also, NPSTC urges the Commission to take further steps to require the wireless industry to identify and implement location technologies that reliably provide the correct floor level, or even floor label, for the vast majority of wireless calls to public safety answering points. We do applaud the Commission for requiring floor or address information whenever that information is available. The provision of the correct floor information, potentially coupled with the identity of the exact door to knock down, would vastly improve the resources that are available to emergency first responders.