- EXPERIENCING THE PROBLEM EVERY DAY--PSAP
Managers across the country recite episode after episode of delayed and
even denied emergency response due to the absence of accurate location
data from wireless 9-1-1 callers.
- DISRUPTION OF SERVICE--Citizens
die, suffer longer, damage is more severe and disruption of normal public
services all result from the emergency call that cannot be accurately and
quickly located.
- CREATING ADDITIONAL RISK TO RESPONDERS
AND THE PUBLIC--The dispatch of traditional First Responders to the
wrong location creates additional risk to these public servants as well as
the general public they encounter while enroute.
- PUBLIC SAFETY NEEDS TO UNDERSTAND WHAT
WE ARE GETTING IN TERMS OF ACCURACY IN OUR COMMUNITY IN ORDER TO SERVE THE
PUBLIC--While the FCC accuracy parameters are not currently applicable
at the PSAP level, using them as a reference allowed a point of comparison
for the consistency and usefulness of location data delivered on E911
calls to the selected PSAPs. How these systems actually performed was an
important learning experience that had not been widely available. At the PSAP, the recognition of the
degree of deviation associated with wireless location data has impact on
call processing as well as dispatch capability. The degree of deviation
must be understood per WSP in order to establish and assess actual
capability within any service area.
- MOTIVATION TO ACHIEVE BETTER IS NEEDED--For
any meaningful, comprehensive effort to be made al the parties must have
strong motivation to act and maintain the relationship as well as the
progress toward valid goals. The topic of wireless accuracy has been
reviewed in multiple forums, usually with the same stakeholders, and the
results have yet to offer the average wireless caller any assurance that
public safety will have any credible information about their location, if
they cannot provide it amidst the emergency event.
- PUBLIC SAFETY HAS A DUTY TO RESPOND--Public
Safety Answering Points cannot abandon the duty to respond or the duty to
seek improvement in the manner with which emergency calls arrive at the
first place people call during an emergency. Public safety has always
understood the even in the absence of other call detail, the location
information for effective dispatch purposes is most critical.
- DON’T MAKE IT WORSE--The
technology choice for seeking to
access prompt response and assistance should NOT create further crisis by
failing to deliver location data at least as good as the current
parameters per type of solution.
- MORE DISCUSSION WILL CONTINUE TO BE
NON PRODUCTIVE--It is eleven years after 94-102. What will more
“talking” about the issues produce?
- APCO
has participated within the Emergency Services Interconnection Forum
(ESIF) of the Alliance
for Telecommunication Industry Solutions (ATIS) for the past five years.
- APCO
participated in general sessions and subcommittees seeking to devise
industry standards on topics from testing methodology for accuracy to the
maintenance testing processes post deployment. Despite a number of
discussions, the industry continued to rely upon a FCC Consent Decree to
justify their right to test across a national footprint, using weighting
and averaging of results to declare compliance with the existing accuracy
requirements.
- APCO
participated with many others in the FCC sponsored, NRIC VII process.
Specifically, without much surprise these same issues arose again in that
forum.
- For
any meaningful, comprehensive effort to be made al the parties must have
strong motivation to act and maintain the relationship as well as the
progress toward valid goals. The topic of wireless accuracy has been
reviewed in multiple forums, usually with the same stakeholders, and the
results have yet to offer the average wireless caller any assurance that
public safety will have any credible information about their location, if
they cannot provide it amidst the emergency event.
- APCO
respectfully submits that FCC Docket 94-102 has enjoyed considerable
debate, discussion and industry attempts to modify it original intent as
well as everyday application to handling emergency calls to 911 via
wireless devices.
- NEED CLEAR INSTRUCTION FROM FCC--The
FCC is being asked to provide clear instruction through its independent
regulatory role to the wireless carriers that location data delivered to
the PSAP should improve to at least the parameters already defined by the
FCC in earlier proceeding on this docket.
- SOLUTIONS ARE NOT SWIFT OR EASY BUT
MUST BEGIN TO IMPROVE WITH AN ESTABLISHED TIMELINE IN SIGHT--APCO and
public safety in general understand that this is not likely to be an easy
or rapid improvement. However, at present there is no FCC rule that
provides neither incentive nor timeline to reach the desired goal. The
language of the Consent Decree remains the prevailing influence and is
relied heavily upon by the wireless carriers, regardless of the
stakeholder meetings, joint sessions, and improvement committees etc that
entertain the question.
- HOW IS ACCURACY COMPLIANCE REPORTED
AND DOES IT MEAN ANYTHING?--It
is also important to begin the inquiry of just how did the wireless
carriers declare their compliance with the existing parameters in the
countless quarterly reports filed with the FCC over the past few years.
- PUBLIC PERCEPTION IS THAT WE WILL KNOW
WHERE THEY ARE--The public belief that the ability to speak to a call
taker guarantees that useful location information is always present for
dispatch purposes is not reality.
- LOCATION IS MOST IMPORTANT ELEMENT IN
CALL INFORMATION--Public safety has always understood the even in the
absence of other call detail, the location information for effective
dispatch purposes is most critical.
- PUBLIC SAFETY NEEDS TO KNOW WHAT IS BEING DELIVERED
LOCALLY FOR EFFECTIVE RESPONSE--Local
efforts to assess the performance of current and developing systems are
critical to better understanding the wireless location data delivered to
PSAPs.
- OBTAINING THE BEST INFORMATION
RELATIVE TO LOCATION IS ESSENTIAL TO A SUCCESSFUL 911 RESPONSE--The
prompt and effective dispatch of appropriate emergency services to any
reported event is dependent upon obtaining the best location information
possible from the caller. This essential element of competent dispatching
must occur regardless of the technology type used to access the universal
emergency number, 911.
- OPERATIONAL EXPENSES INCREASE AND
HOMELAND SECURITY IS COMPROMISED WITH LESS THAN USABLE LOCATION
INFORMATION--Many wireless 911 calls are made by concerned citizens
reporting traffic accidents, crimes, or other emergencies. Prompt delivery
of these and other wireless 911 calls to public safety organizations
benefits the public-at-large by promoting safety of life and property. In
addition, recent U.S. Department of Homeland Security (DHS) grants to the
American Trucking Association (ATA) have sought to expand the
“surveillance and awareness” capability of these informed users of the
national highway system by reporting suspicious persons and activity
through wireless access to 911. Unfortunately, not every wireless 911
caller can adequately describe the location of the event, often leading to
delayed responses and in rare cases, no response at all. The impact upon public safety agencies
searching for such an ill-defined location results in loss of time,
unavailability of emergency responders for other calls, as well as
increased operational expense.
- PUBLIC EXPECTATIONS FOR SERVICE NOT
BEING MET--There has been and continues to be a clear public
expectation that the PSAP, as well as response agencies, will have
consistent and accurate wireless location data delivered with all wireless
E911 calls to the PSAP. The
consumers of wireless service have embraced the convenience of service
equivalency for voice communication and have made assumptions, many of
which are incorrect, about the capability of these devices to deliver
wireless location data that can effectively assist the PSAP in the
dispatch of emergency services amidst a crisis event.
- IMPROVEMENTS WILL HAVE TO BE MADE--To
some originally deployed systems, retuning of equipment, perhaps even
additional tower sites and upgrades to improve the quality of location
data delivered will need to be made. This at least to the consumer can be
perceived to be a normal cost of doing business when one determines that
the technology and services sold will seek service equivalency and
connection to the emergency service providers’ basic systems.
- RESOURCE ALLOCATION RELIES ON LOCATION
INFORMATION--Many callers are able to speak and upon interview by the
call taker, general location information can often be determined; however,
in the instances the caller cannot speak, or is too young or impaired to
speak clearly and effectively, meaningful information about their location
is absent. In these cases, the
usefulness of the wireless data associated with the calls becomes the
critical means to assess which resources are to be dispatched.
- LONGER PROCESSING TIME DUE TO POOR
LOCATION INFORMATION EQUALS INEFFICIENT RESPONSE AND WASTED TAX DOLLARS--Every
consumer should know that calls without adequate location data for
dispatch purposes will take longer to process, leading to an extended
response time from initial contact with the PSAP and, in some cases, no
response until another source of location information is provided. It is clear to PSAPs across the country
that callers expect the PSAP to “know my location” during a crisis. Indeed, there is little time during the
call for help for the call taker to explain accuracy compliance and
testing issues.
- RISK
TO PUBIC INCREASES--Public
safety resources that may be dispatched to events with uncertain location
information are essentially out-of-service during the time of the response
and search for the reported event. The resultant loss of availability for
other reported emergencies, turnkey costs of such responses, and general
risk to public safety practitioners in response mode are collateral
consequences of less-than-useful and inconsistent location data.
- PUBLIC UTILIZING WIRELESS DEVICES ON
SAME LEVEL AS WIRELINE AND EXPECTS NO DIFFERENCE IN SERVICE--The public
has an expectation that wireless E911 will perform the same as enhanced
wire line 911; therefore, effective wireless Phase II deployment should
include both the service equivalency of access (voice) and the service
equivalency of location information (data) to PSAPs. Meeting this public expectation is
recognized as a challenge however improvements of system performance at
the PSAP level are possible and should be required.
- MANAGING EXPECTATIONS
CRITICAL/ASSESSING ACCURACY
FALLS TO LOCAL
GOVERNMENT--Managing the expectations of PSAP staff, First Responders
and the Public regarding the actual performance capability of wireless
E911 systems as deployed across the nation will continue to require local
action and assessment. At a minimum, every PSAP should seek to determine
the actual performance of the current systems and assist consumers within
the service area, to best utilize their wireless E911 access in times of
crisis. The cost to test PSAP by PSAP is high; however, local
agencies, in an effort to process calls for service in the most expedient
and effective manner possible, find themselves in a situation which may
require them to expend significant funds out of their already constrained
public safety budgets in order to assess the usefulness of the data they
receive on wireless calls. The vast majority of PSAPs often have no means
to assess and make adjustments for what should be known as the location
accuracy deviation per PSAP based on credible performance testing.
- EFFECTIVE RESPONSE AND STANDARD OF
CARE--In times of crisis, the wireless telephone caller is at that
moment a customer of both the WSP and the PSAP that receives the call. In
the critical moments of determining location, assessing severity, and
assigning call codes and priority, there is little to be gained from
trying to educate the caller at this point of contact, that their wireless
telephone does not work exactly the same as their home wire line telephone.
During those seconds, the PSAP has the burden of meeting the expectation
of the caller in crisis. This responsibility means sending the right
resources to the right location, now.
- PUBLIC EDUCATION ON SYSTEM LIMITATIONS
IS ESSENTIAL--There has been and continues to be a clear public
expectation that the PSAP, as well as traditional first responders, will
actually have consistent and accurate wireless location data delivered
with all wireless 911 calls to the PSAP.
This expectation exceeds the performance of many systems as
deployed. Public education with the
goal of better managing the expectation of current service must be
developed and distributed widely.
Managing the expectations of first responders, as well as PSAP
staff, must also be expanded and call management processes that have general
applicability rather than provider specific interpretations must also be
adopted.
- IMROVEMENTS
SHOULD BE ENCOURAGED--While
the need for continued evolution and investment in location technology to
support public safety is recognized and acknowledged, interim improvements
in today’s deployed systems also have benefits and are encouraged.
- WE
CANNOT IGORE OUR DUTY--The
challenge to provide useful location information to the PSAP for effective
response to nearly half of the estimated 200 million 911 calls made
annually cannot be ignored. On
behalf of every caller in crisis, it is incumbent upon all public safety
and wireless community stakeholders, supported by appropriate regulatory
and legislative action, to continue the collaborative effort to maximize
the usefulness and consistency of wireless location data provided to the
PSAP.
- CLARIFICATION IS REQUIRED--The FCC
is being asked to provide clear instruction through its independent
regulatory role to the wireless carriers that location data delivered to
the PSAP should improve to at least the parameters already defined by the
FCC in earlier proceeding on this docket.
- ESTABLISHING TIMELINES FOR
IMPROVEMENTS GETS US STARTED IN THE RIGHT DIRECTION--At present there
is no FCC rule that provides neither incentive nor timeline to reach the
desired goal.
- AGGRESSIVE AND THOROUGH ENFORCEMENT
CALLED FOR--Support for Commissioner Copps belief that “after
developing revised location
accuracy and accuracy reporting standards, aggressive and thorough enforcement
will continue to be important – just as enforcement has been important in
getting us this far.
- SUPPORT
FOR CHAIRMAN MARTIN’S VISION--Public safety must provide significant and broad based support
the Chairman Martin in these efforts to resolve this critical issue in the
interest of public safety and every wireless 911 caller – everyday!