By: Andy Regitsky
In 2018, the FCC released a Notice of Inquiry in Docket 18-64 after it recognized that there was a problem routing certain wireless 911 calls.
When 911 service was first introduced, all 911 calls originated from wireline networks, and wireline providers used the fixed location of the calling telephone to route 911 calls to the nearest PSAP [Public Safety Answering Point]. With the deployment of the first generation of cellular service, wireless 911 calls could originate from any location served by the wireless network, and the caller could move locations during the call. To enable timely routing of wireless 911 calls, CMRS providers typically programmed their networks to use the location of the first cell tower receiving the call to determine the nearest PSAP and route the call accordingly. This became the basis for routing of wireless Enhanced 911 (E911) calls (legacy E911 routing). (FCC Notice of Proposed Rulemaking draft, Docket 18-64, at para. 6).
In legacy E911 routing, because the location of the cell tower may be some distance from the caller’s location, CMRS providers may route a wireless 911 call to a PSAP other than the one designated by the relevant state or local 911 authority to receive calls from the actual location of the caller. Currently, most wireless 911 calls are routed through the cell site (tower) where the call is received and are sent to the PSAP associated with that cell site. Sometimes, however, the 911 call is routed to the wrong PSAP because the receiving cell site is not in the same jurisdiction as the 911 caller. When this occurs, the PSAP must transfer the 911 call which consumes time and resources, and ultimately delays the arrival of first responders.
The record indicates that misroutes are frequent where legacy E911 routing is used. The 9-1-1 Association (NENA) estimates that 23 million calls using legacy E911 routing are misrouted annually. Other parties estimate that approximately 11-12% of legacy E911 calls are misrouted, and the percentage of misrouted calls can vary between and even within jurisdictions. For example, the Fayetteville (Arkansas) Police Department reports that 30% of the 911 calls its jurisdiction receives are misrouted from neighboring jurisdictions. Intrado estimates that Palm Beach County, Florida, experiences misrouted calls at a rate as high as 20-50% along PSAP boundaries. (Id., at para. 7).
Obviously, the way to avoid this is through mandatory location-based routing of the call. On June 9, 2022, the Commission released a Public Notice that updated the record in this proceeding. According to wireless providers, location-based routing appears to now be technologically feasible, and it is already being implemented by AT&T and T-Mobile. Therefore, on December 21, 2022, the FCC intends to issue a Notice of Proposed Rulemaking in which it will propose to require Commercial Mobile Radio Service (CMRS) and covered text providers to do the following:
Deploy technology that supports location-based routing on their Internet Protocol (IP)-based networks, but not for calls originating on circuit-switched time division multiplexed (TDM) networks.
Use location-based routing to route all 911 voice calls and texts originating on their IP-based networks when caller location information meets certain proposed baseline requirements for accuracy and timeliness.
Use the best available location information (which could be longitude/latitude of the cell tower) to route 911 voice calls and texts from IP-based networks when accurate caller location information does not meet the proposed baseline requirements.
Deliver 911 calls, texts, and associated routing information in IP format upon request of 911 authorities who have established the capability to accept NG911-compatible IP-based 911 communications. Nationwide CMRS providers and covered text providers would be subject to this requirement six months from the effective date of final rules on location-based routing or within six months of a valid request for IP-based service from a local or state public safety authority, whichever is later. Non-nationwide CMRS providers would have an additional six months to comply with this requirement.
Nationwide CMRS providers would have six months from the effective date of final rules to meet these location routing requirements. Non-nationwide CMRS providers would have an additional year (i.e., eighteen months from the effective date of final rules) to meet the same requirements.
Covered text providers would have eighteen months from the effective date of final rules to meet these requirements.
Industry comments on these proposals will be due 30 days after the Notice appears in the Federal Register.
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