# Wireless E911 Location Accuracy Requirements > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/fr%3A2025-06865 ## Record - **Collection:** Federal Register - **Document type:** Proposed Rule - **Published:** May 7, 2025 - **Citation:** 90 FR 19374 ## Text FEDERAL COMMUNICATIONS COMMISSION 47 CFR Part 9 [PS Docket No. 07-114; FR ID 290080] Wireless E911 Location Accuracy Requirements AGENCY: Federal Communications Commission. ACTION: Proposed rule. SUMMARY: In this document, the Federal Communications Commission (the FCC or Commission) proposes rules to strengthen wireless 911 location accuracy rules and to put more actionable location information in the hands of Public Safety Answering Points (PSAPs) and first responders. DATES: Comments are due on or before June 6, 2025, and reply comments are due on or before July 7, 2025. ADDRESSES: You may submit comments, identified by PS Docket No. 07-114, by any of the following methods: • Electronic Filers: Comments may be filed electronically using the internet by accessing the ECFS: https://www.fcc.gov/ecfs. • Paper Filers: Parties who choose to file by paper must file an original and one copy of each filing. Filings can be sent by hand or messenger delivery, by commercial courier, or by the U.S. Postal Service. All filings must be addressed to the Secretary, Federal Communications Commission. Hand-delivered or messenger-delivered paper filings for the Commission's Secretary are accepted between 8 a.m. and 4 p.m. by the FCC's mailing contractor at 9050 Junction Drive, Annapolis Junction, MD 20701. All hand deliveries must be held together with rubber bands or fasteners. Any envelopes and boxes must be disposed of before entering the building. Commercial courier deliveries (any deliveries not by the U.S. Postal Service) must be sent to 9050 Junction Drive, Annapolis Junction, MD 20701. Filings sent by U.S. Postal Service First-Class Mail, Priority Mail, and Priority Mail Express must be sent to 45 L Street NE, Washington, DC 20554. People with Disabilities. To request materials in accessible formats for people with disabilities (braille, large print, electronic files, audio format), send an email to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau at 202-418-0530. FOR FURTHER INFORMATION CONTACT: Thomas Eng, Engineer, Policy and Licensing Division, Public Safety and Homeland Security Bureau, (202) 418-0019, Thomas.Eng@fcc.gov, or Brenda Boykin, Deputy Chief, Policy and Licensing Division, Public Safety and Homeland Security Bureau, (202) 418-2062, Brenda.Boykin@fcc.gov. SUPPLEMENTARY INFORMATION: This is a summary of the Commission's Sixth Further Notice of Proposed Rulemaking ( FNPRM ), FCC 25-22, in PS Docket No. 07-114, adopted on March 27, 2025, and released on March 28, 2025. The full text of this document is available at https://www.fcc.gov/document/fcc-proposes-improvements-wireless-e911-location-accuracy-rules. Pursuant to §§ 1.415 and 1.419 of the Commission's rules, 47 CFR 1.415, 1.419, interested parties may file comments and reply comments on or before the dates indicated on the first page of this document. Comments may be filed using the Commission's Electronic Comment Filing System (ECFS). See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998), https://www.govinfo.gov/content/pkg/FR-1998-05-01/pdf/98-10310.pdf. The Commission will treat this proceeding as a “permit-but-disclose” proceeding in accordance with the Commission's ex parte rules. Persons making ex parte presentations must file a copy of any written presentation or a memorandum summarizing any oral presentation within two business days after the presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all persons attending or otherwise participating in the meeting at which the ex parte presentation was made, and (2) summarize all data presented and arguments made during the presentation. If the presentation consisted in whole or in part of the presentation of data or arguments already reflected in the presenter's written comments, memoranda, or other filings in the proceeding, the presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them in the memorandum. Documents shown or given to Commission staff during ex parte meetings are deemed to be written ex parte presentations and must be filed consistent with rule § 1.1206(b). In proceedings governed by rule § 1.49(f) or for which the Commission has made available a method of electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations, and all attachments thereto, must be filed through the electronic comment filing system available for that proceeding, and must be filed in their native format ( e.g., .doc, .xml, .ppt, searchable .pdf). Participants in this proceeding should familiarize themselves with the Commission's ex parte rules. Synopsis Background In the FNPRM, we propose to strengthen our wireless 911 location accuracy rules to put more actionable location information in the hands of Public Safety Answering Points (PSAPs) and first responders. In the FNPRM, we propose to focus our approach on making the information available to PSAPs more valuable and directly applicable to incident response. Better location information from the outset of a 911 call translates to time saved during a response, and that time saved translates to lives saved. From the handsets in consumers' hands, to the provider networks and technologies used to derive and deliver location data to the PSAPs, to the equipment and systems used by the PSAPs, our goal is to encourage cooperation and collaboration among all parties involved to achieve the ultimate goal of better location accuracy, delivered as quickly and reliably as possible, to every PSAP nationwide. In 2015, the Commission adopted comprehensive location accuracy rules requiring CMRS (Commercial Mobile Radio Service) providers to provide either (1) coordinate-based (horizontal and vertical) location information or (2) dispatchable location information, with wireless 911 calls. 1 In the Fourth Report and Order and subsequent orders in this proceeding, the Commission established minimum horizontal and vertical accuracy requirements and a timetable for their implementation, and required that technologies used to meet minimum accuracy thresholds be validated by testing in an independent test bed. Since 2015, these requirements have led to significant improvements in the accuracy and actionability of caller location information delivered to PSAPs with wireless 911 calls. However, progress has fallen short in some areas. First, while CMRS providers have tested z-axis technologies in the test bed and are now using these technologies to deliver z-axis information to PSAPs, experience to date indicates that the z-axis information PSAPs are receiving with individual calls is frequently not actionable due to lack of precision and/or the information being delivered in a format that is not easily usable. 2 Second, issues have arisen about the transparency of the industry test bed process and whether current testing methodologies used to validate z-axis technologies adequately model real-world conditions. Third, while the Commission's rules require CMRS providers to deliver dispatchable location—public safety's preferred solution—whenever technically feasible, the number of wireless 911 calls currently being delivered with dispatchable location is very small compared to the number of calls delivered with coordinate-based location information. 3 While coordinate-based location information remains acceptable when providing dispatchable location is not technically feasible, we seek comment on how industry, handset manufacturers, carriers, and public safety can work collaboratively toward improvement, and how we can continue to increase the amount of dispatchable location being derived and delivered to PSAPs. 1 Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114, Fourth Report and Order, 30 FCC Rcd 1259 (2015), 80 FR 11806 (Mar. 4, 2015) ( Fourth Report and Order ), corrected by Erratum (PSHSB Mar. 3, 2015). 2 Letter from Jeffrey S. Cohen, Chief Counsel, Association of Public-Safety Communications Officials International, Inc. (APCO), to Marlene Dortch, Secretary, FCC, PS Docket No. 07-114 et al., at 2 (filed Jan. 31, 2024) (APCO Jan. 31, 2024 Ex Parte ) (“The Commission's rules require wireless carriers to provide a height estimate for 9-1-1 callers expressed as a `height above ellipsoid' . . . . Few 9-1-1 emergency communications centers (ECCs) have the resources to even explore how to make use of HAE-based vertical information . . . .”); see also Letter from Jeffrey S. Cohen, Chief Counsel, APCO, to Marlene Dortch, Secretary, FCC, PS Docket No. 07-114 and WC Docket No. 18-336, at 1 (filed Sept. 6, 2022) (APCO Sept. 6, 2022 Ex Parte ) (“APCO reiterated that ECCs need actionable location information in the form of dispatchable location as compared to z-axis information provided as a height above ellipsoid.”); Letter from Jeffrey S. Cohen, Chief Counsel, Mark S. Reddish, Senior Counsel, and Alison P. Venable, Government Relations Counsel, APCO, to Marlene Dortch, Secretary, FCC, PS Docket No. 07-114 et al., at 2 (filed May 20, 2024) (APCO May 20, 2024 Ex Parte ). 3 APCO Jan. 31, 2024 Ex Parte at 2; Letter from Jeffrey S. Cohen, Chief Counsel, APCO, to Marlene Dortch, Secretary, FCC, PS Docket Nos. 07-114, 21-479, and 18-64, at 1 (filed Sept. 22, 2023) (“[T]he Commission [should] explore additional avenues for ensuring that emergency communications centers receive actionable location information in the form of dispatchable location.”); APCO Sept. 6, 2022 Ex Parte at 1. To advance the goal of putting more actionable information in the hands of PSAPs and first responders, we seek comment on a number of different proposals. Specifically, in the FNPRM, we propose to strengthen our vertical location (z-axis) accuracy requirements and to require CMRS providers to deliver z-axis information to PSAPs in more actionable formats. In addition, we seek comment on mechanisms to increase the number of wireless 911 calls for which the CMRS provider delivers dispatchable location information ( i.e., street address plus in-building identification of the caller's office, apartment, or room number), rather than coordinate-based information, to the PSAP. 4 We also seek comment on some additional proposals that we believe would improve location accuracy, such as strengthening the existing testing and compliance framework, revising live call reporting requirements, developing a centralized online complaint portal for location accuracy problems, and improving horizontal (x,y) location accuracy for wireless calls and location accuracy for text-to-911. Finally, we seek comment on whether certain of our legacy wireless location accuracy rules have become outdated and should be eliminated, and we also propose to eliminate certain obsolete information collection requirements associated with our 911 location accuracy rules. We believe the measures proposed in the FNPRM will improve the performance of vertical and dispatchable location technologies, provide more actionable information to PSAPs, and reduce emergency response times. 5 4 We note that, while seeking comment exploring how dispatchable location can be provided more often, we are not proposing to phase out x/y/z location as a location accuracy option. 5 APCO states that “further Commission action is needed to explore ways to (1) improve the transparency and reliability of testing to verify that HAE-based z-axis estimates meet the Commission's +/−3 meter metric and ensure testing is conducted of currently in use and potential dispatchable location solutions available through carriers' own products and services as well as by third party location solutions providers, (2) make carrier reports more uniform and informative to better understand and compare dispatchable location methods in use, (3) explore the role of mobile device manufacturers and mobile operating system developers in contributing to dispatchable location solutions, and (4) provide more robust and accountable requirements for carriers to deploy methods, several of which are likely feasible today, to provide dispatchable location as soon and as frequently as possible.” Letter from Jeffrey S. Cohen, Chief Counsel, and Alison P. Venable, Government Relations Counsel, APCO, to Marlene Dortch, Secretary, FCC, PS Docket No. 07-114 et al., at 2 (filed Nov. 1, 2024). • Vertical Location. We propose to strengthen the existing rules with respect to z-axis location by requiring CMRS providers that deploy z-axis technology to deliver z-axis information to PSAPs measured in Height Above Ground Level (AGL), which is likely to be more actionable than the currently required Height Above Ellipsoid (HAE). In addition, we seek comment on requiring CMRS providers to provide floor level estimates. • Testing and Compliance Framework. We propose to strengthen the test bed validation process and require greater transparency and accountability with respect to test results. Specifically, we propose that testing and validation meet the following requirements in order for test results to be considered valid for compliance purposes: ○ We propose to require that validation of a vertical location technology in the industry test bed must demonstrate compliance of that technology with accuracy standards in each morphology. Thus, CMRS providers would not be allowed to base compliance certifications on aggregating or averaging test bed results across morphologies based on live call data or other factors. ○ We propose to provide non-nationwide CMRS providers and major public safety organizations (National Emergency Number Association (NENA), Association of Public-Safety Communications Officials International, Inc. (APCO), and National Association of State 911 Administrators (NASNA)) with expanded access to test bed data and results on request. We further propose to allow NENA, APCO, and NASNA to challenge the validation of particular technologies in the test bed. • Dispatchable Location. We seek comment on mechanisms to increase the number of wireless 911 calls that convey dispatchable location and to ensure that CMRS providers use dispatchable location technologies to their maximum potential as they become available. In that connection, we seek to refresh the record on the current state of dispatchable location solutions and initiatives to develop new and enhanced solutions. • Live Call Reports. We propose to require CMRS providers' live call data reports to include information on the specific technologies used to provide dispatchable location and on the morphologies for live calls providing dispatchable location. • Complaint Portal. We seek comment on requiring CMRS providers to develop a centralized, online complaint portal that PSAPs could use to report location accuracy problems to CMRS providers before seeking FCC enforcement. • Horizontal Location Accuracy. We seek comment on improving horizontal (x,y) location accuracy for wireless 911 calls. • Mobile Text. We seek comment on improving location accuracy for text-to-911 (mobile text). • Eliminating Certain Existing Regulations. We seek comment on whether to eliminate existing E911 Phase II rules, and we also propose to eliminate certain other obsolete or superseded 911 location accuracy rules in 47 CFR 9.10. In the Fourth Report and Order, the Commission adopted comprehensive 911 location accuracy rules that for the first time required CMRS providers to provide vertical as well as horizontal location information with wireless 911 calls. The primary purpose of these rules was to enable PSAPs and first responders to use the information to pinpoint the location of wireless 911 callers inside multi-story buildings, including floor level and, ideally, apartment, office, or room number. 6 In order to focus provision of vertical location in areas with the highest concentration of multi-story buildings, the Commission required nationwide CMRS providers to deploy vertical location capability in each of the top 25 Cellular Market Areas (CMAs) by April 3, 2021, and in each of the top 50 CMAs by April 3, 2023. 7 6 Fourth Report and Order, 30 FCC Rcd at 1319, paragraph 162 (stating that “by providing a z-axis metric as a backstop to dispatchable location for identifying floor level of 911 calls from multi-story buildings, we ensure that vertical location accuracy is achieved within the timeframe laid out by the Roadmap”). 7 Id. at 1261-62, paragraph 6; see also 47 CFR 9.10(i)(2)(ii)(C), (D). The Commission afforded non-nationwide CMRS providers an additional year to comply with these requirements. See 47 CFR 9.10(i)(2)(ii)(F). The Commission established two alternative ways for CMRS providers to provide this information to PSAPs. The first was to deploy technology that would provide “dispatchable location” with wireless 911 calls, which the Commission defined as “[a] location delivered to the PSAP by the CMRS provider with a 911 call that consists of the street address of the calling party, plus additional information such as suite, apartment or similar information necessary to adequately identify the location of the calling party.” 8 The Commission envisioned that CMRS providers would develop dispatchable location capability by building a national location database of in-building beacons and hotspots known as the National Emergency Address Database (NEAD). 9 8 Fourth Report and Order, 30 FCC Rcd at 1360, Appx. D; accord 47 CFR 9.10(i)(1)(i). 9 Fourth Report and Order, 30 FCC Rcd at 1279, paragraph 55. A commitment to build the NEAD was a component of the “Roadmap” agreement between the major wireless providers and national public safety organizations that preceded the Fourth Report and Order. See Letter from John Wright, APCO, Charles W. McKee, Sprint, Joan Marsh, AT&T, Kathleen O'Brien Ham, T-Mobile, Christy Williams, NENA, and Kathleen Grillo, Verizon, to Marlene H. Dortch, Secretary, FCC, PS Docket No. 07-114 (filed Nov. 18, 2014), Attach. A, “Roadmap for Improving E911 Location Accuracy,” https://www.fcc.gov/ecfs/document/60000983188/1. The second alternative was to deploy z-axis technology that met a Commission-approved accuracy metric. However, the Commission deferred adoption of a z-axis metric pending further testing, directing the nationwide CMRS providers to conduct testing in the industry test bed and submit a proposed z-axis accuracy metric to the Commission for approval by August 2018. 10 Following testing of z-axis technologies in the test bed (Stage Z), in August 2018, CTIA submitted the Stage Z test report and proposed a z-axis accuracy metric to the Commission of plus or minus 5 meters relative to the handset for 80% of calls. Following public comment on the industry proposal, 11 the Commission proposed 12 and in the Fifth Report and Order adopted a more stringent metric of plus or minus 3 meters for 80% of calls made from “z-axis capable” devices. 13 The Commission also required CMRS providers to deliver z-axis information to PSAPs measured in HAE and to provide floor level information if the CMRS provider had such information available. 14 Finally, the Commission reaffirmed the April 2021 and April 2023 deadlines for meeting these requirements in the top 25 and top 50 CMAs, respectively, as previously established in the Fourth Report and Order. 15 10 Fourth Report and Order, 30 FCC Rcd at 1302-04, paragraphs 112 through 114, 116. 11 Public Safety and Homeland Security Bureau Seeks Comment on Vertical (Z-Axis) Accuracy Metric Proposed by the Nationwide Wireless Carriers, PS Docket No. 07-114, Public Notice, 33 FCC Rcd 8616, 8617 (PSHSB 2018), https://www.fcc.gov/ecfs/document/0910993124543/1. 12 Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114, Fourth Further Notice of Proposed Rulemaking, 34 FCC Rcd 1650, 1654, paragraph 11 (2019), 84 FR 13211 (Apr. 4, 2019) ( Fourth FNPRM ). 13 Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114, Fifth Report and Order and Fifth Further Notice of Proposed Rulemaking, 34 FCC Rcd 11592, 11593, 11604-05, paragraphs 2, 24 through 25 (2019), 85 FR 2660 (Jan. 16, 2020) ( Fifth Report and Order ), 85 FR 2683 (Jan. 16, 2020) ( Fifth FNPRM ); see also 47 CFR 9.10(i)(2)(ii)(H). 14 Fifth Report and Order, 34 FCC Rcd at 11608, 11610-11, paragraphs 32, 37; see also 47 CFR 9.10(i)(2)(ii)(H). HAE is a global standard for vertical location that measures altitude between the wireless device that makes the 911 call and a globally defined (WGS-84) reference ellipsoid. Fifth Report and Order, 34 FCC Rcd at 11608, paragraph 32 n.134. 15 Fifth Report and Order, 34 FCC Rcd at 11596, paragraph 9. In the companion Fifth FNPRM, the Commission sought comment on whether to establish a long-term timeline for migrating to a more stringent z-axis metric than 3 meters, and ultimately whether to require CMRS providers to deliver floor level information in conjunction with wireless indoor 911 calls. 16 The Commission also proposed to expand the options for demonstrating deployment of z-axis or dispatchable location capability. 17 With respect to dispatchable location, the Commission sought comment on alternatives to the NEAD, noting reports that the nationwide CMRS providers were facing challenges in establishing the NEAD. 18 Shortly after release of the Fifth Report and Order, the nationwide CMRS providers announced that they had ceased work on the NEAD due to challenges with testing and lack of third-party participation, and that the NEAD would not be available to support dispatchable location. 19 16 Id. at 11619, paragraph 61. To continue to improve the z-axis metric, the Commission sought comment on whether enhancements are needed to the vertical location accuracy testing process. Id. at 11620, paragraph 65. 17 Id. at 11619, 11622-25, 11632-33, paragraphs 61, 71 through 78, Appx. B. 18 Id. at 11625-26, paragraph 80. 19 See Letter from Thomas C. Power, Secretary, and Thomas K. Sawanobori, Vice President, NEAD, LLC, to Marlene H. Dortch, Secretary, FCC, PS Docket No. 07-114, at 1 (Feb. 14, 2020) ( NEAD Feb. 14 2020 Termination Letter ) (informing the Commission that the NEAD Platform “has ceased operation and is no longer available to support wireless providers' provision of dispatchable location information”). In the July 2020 Sixth Report and Order, the Commission rejected proposals by T-Mobile, Verizon, and AT&T to weaken the 3-meter vertical location accuracy standard or to extend the previously established deadlines for implementing it. 20 The Commission also afforded nationwide CMRS providers the option of meeting the April 2021 and April 2023 deadlines by deploying handset-based z-axis technology that could be used throughout the provider's nationwide footprint. 21 With respect to choosing between coordinate-based and dispatchable location, which had previously been left to the provider's discretion, the Commission adopted a binding preference for dispatchable location by requiring CMRS providers to provide dispatchable location with wireless E911 calls if it is technically feasible and cost effective for them to do so. 22 Finally, the Commission added a requirement for nationwide CMRS providers to deploy z-axis location technology or dispatchable location nationwide by April 2025. 23 20 Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114, Sixth Report and Order and Order on Reconsideration, 35 FCC Rcd 7752 (2020), 85 FR 53234 (Aug. 28, 2020) ( Sixth Report and Order ), corrected by Erratum (PSHSB Aug. 28, 2020) and Second Erratum (PSHSB Oct. 29, 2020). 21 Sixth Report and Order, 35 FCC Rcd at 7759, paragraph 18; see also 47 CFR 9.10(i)(2)(ii)(I)( 2 ). 22 Sixth Report and Order, 35 FCC Rcd at 7775-76, paragraphs 51 through 53; see also 47 CFR 9.10(i)(2)(ii)(G) (“By January 6, 2022: All CMRS providers shall provide dispatchable location with wireless E911 calls if it is technically feasible for them to do so.”). 23 Sixth Report and Order, 35 FCC Rcd at 7763, paragraph 25. CTIA and APCO filed petitions for reconsideration of the Sixth Report and Order. 24 CTIA argued that the COVID-19 pandemic had impeded any ability to validate whether z-axis location solutions could meet the Commission's vertical location accuracy requirements. APCO urged the Commission to require CMRS providers to deliver dispatchable location for a minimum percentage of 911 calls—an alternative that the Commission had previously rejected—rather than tie the Commission's dispatchable location benchmark to the number of address reference points in a location database. 25 In January 2021, the Commission dismissed the petitions as procedurally defective and, as an alternative and independent ground for resolving the issues raised, denied the petitions on the merits. 26 Regarding dispatchable location requirements, the Commission upheld the existing rules but stated that it would monitor progress towards deployable dispatchable location technologies and exercise future oversight if necessary. 27 24 Petition of CTIA for Reconsideration, PS Docket No. 07-114 (filed Sept. 28, 2020), https://www.fcc.gov/ecfs/search/search-filings/filing/1092835868478; Petition of APCO International for Reconsideration, PS Docket No. 07-114 (filed Sept. 23, 2020), https://www.fcc.gov/ecfs/search/search-filings/filing/109232735502601 (APCO Petition for Reconsideration). 25 APCO Petition for Reconsideration at 3 (“Rather than basing compliance on the number of reference points in a database, the better approach would be to establish a specific minimum percentage of calls that must be delivered with a dispatchable location.”). 26 Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114, Order on Reconsideration, 36 FCC Rcd 570, 576, 579, paragraphs 16 through 17, 25 (2021), 86 FR 8714 (Feb. 9, 2021) ( Order on Reconsideration ). 27 Id. at 592, paragraph 48; see Sixth Report and Order, 35 FCC Rcd at 7782-83, paragraph 71. Following release of the Sixth Report and Order, CTIA informed the Commission that the next round of testing of z-axis location technologies (Stage Zb), originally scheduled to start in September 2020, was being postponed due to the impact of COVID-19 and that testing would not resume until it could be “safely and effectively accomplished within buildings in the test cities.” 28 In February 2021, AT&T, T-Mobile, and Verizon sought a waiver of the April 2021 compliance deadline, “based in part on challenges with testing z-axis solutions due to the COVID-19 pandemic.” 29 The Enforcement Bureau conducted an inquiry into these providers' compliance with the Commission's vertical location benchmarks. After the investigation was concluded, the Enforcement Bureau entered into consent decrees with all three providers requiring each company to immediately start providing wireless 911 callers'z-axis location information to PSAPs nationwide, to implement a compliance plan that included specific testing, to report periodically on dispatchable location and floor level information technologies, and to pay a $100,000 settlement amount. In addition, the consent decrees gave each company until April 3, 2022, to meet the z-axis requirements that would have been applicable on April 3, 2021. 30 From December 2021 through May 2022, the test bed conducted testing of z-axis technologies in Stage Zb, after which CTIA submitted a summary to the Commission. 31 On June 2, 2022, the three providers certified that they had met the 3-meter metric requirements as of April 3, 2022, as required by the consent decrees. 28 Letter from Scott K. Bergmann, Senior Vice President, Regulatory Affairs, and Thomas K. Sawanobori, Senior Vice President & Chief Technology Officer, CTIA, to Marlene H. Dortch, Secretary, FCC, PS Docket No. 07-114, at 3 (filed Aug. 21, 2020); accord id. at 1; see also Letter from Paul Margie, Counsel for Apple Inc., to Marlene H. Dortch, Secretary, FCC, PS Docket No. 07-114, at 2 (filed Nov. 3, 2020) (stating that due to the pandemic, the z-axis location capabilities of Apple's Hybridized Emergency Location (HELO) vertical location solution “may not be suitable for external testing prior to the end of Q1 2021”). 29 Petition of AT&T for Waiver, PS Docket No. 07-114 (filed Feb. 12, 2021), https://www.fcc.gov/ecfs/document/10212237290677/1; Petition of T-Mobile for Limited Waiver, PS Docket No. 07-114 (filed Feb. 12, 2021), https://www.fcc.gov/ecfs/document/1021374367479/1; Petition of Verizon for Waiver, PS Docket No. 07-114 (filed Feb. 12, 2021), https://www.fcc.gov/ecfs/document/10213853309676/1 (Verizon Petition for Waiver). 30 T-Mobile USA, Inc., Order and Consent Decree, 36 FCC Rcd 9074, 9078-80, paragraph 11 (EB 2021), https://www.fcc.gov/document/fcc-settles-t-mobile-over-911-vertical-location-accuracy-rules; Cellco Partnership d/b/a Verizon Wireless, Order and Consent Decree, 36 FCC Rcd 9084, 9088-90, paragraph 11 (EB 2021), https://www.fcc.gov/document/fcc-settles-verizon-over-911-vertical-location-accuracy-rules; AT&T Services, Inc., Order and Consent Decree, 36 FCC Rcd 9094, 9098-100, paragraph 11 (EB 2021), https://www.fcc.gov/document/fcc-settles-att-over-911-vertical-location-accuracy-rules; see also Press Release, FCC, FCC Secures Life-Saving Commitment from Wireless Carriers to Deliver 911 Vertical Location Information Nationwide within Seven Days (June 3, 2021), https://www.fcc.gov/document/fcc-secures-911-vertical-location-commitments-wireless-carriers. 31 The providers submitted the Stage Zb summary under a request for confidentiality. See Letter from Scott K. Bergmann, Senior Vice President of Regulatory Affairs, CTIA et al., to Marlene H. Dortch, Secretary, FCC, PS Docket No. 07-114, at 3, 5 (filed June 2, 2022), https://www.fcc.gov/ecfs/search/search-filings/filing/10602197662551 (Stage Zb Cover Letter). On November 21, 2024, the Commission's Enforcement Bureau entered into a consent decree with DISH Wireless L.L.C. (DISH) with respect to its obligation to deploy vertical location technology for wireless 911 calls in each of the top 25 CMAs where it launched 5G Voice over New Radio (VoNR) service. 32 In the consent decree, DISH admitted that on January 24, 2023, it launched VoNR service in two top 25 CMAs without deploying vertical location technology and that it subsequently “continued to launch VoNR service in top 25 CMAs and top 50 CMAs without deploying vertical location technology.” 33 Under the terms of the consent decree, DISH agreed to pay a civil penalty of $100,000, and the Enforcement Bureau agreed to terminate the investigation of this matter. 34 32 DISH Wireless L.L.C., Order and Consent Decree, DA 24-1139, 2024 WL 4880017, at * 1, paragraph 1 (EB Nov. 21, 2024), https://www.fcc.gov/document/fcc-and-dish-settle-dispatchable-location-investigation-100000 . 33 Id. at * 3, paragraph 4. The consent decree notes that on April 5, 2024, DISH certified that it was in compliance with the Commission's vertical location accuracy requirements in each of the top 50 CMAs where it provided VoNR wireless services. Id. 34 Id. at * 4-6, paragraphs 10, 11, 13. Discussion In the FNPRM, we propose to build on recent technological developments and standardization efforts that will enable CMRS providers to convey more actionable vertical location information with wireless 911 calls. Specifically, we propose to require CMRS providers to convey z-axis coordinates in AGL in addition to HAE. We also seek comment on requiring CMRS providers to provide floor level estimates. In addition, we seek comment on potential mechanisms to increase the number of wireless 911 calls that convey dispatchable location (street address, plus additional information to locate the 911 caller) and on collaborative approaches among all parties in the call and location delivery process that might be explored to facilitate an increase in dispatchable location usage. We also propose to strengthen our wireless location accuracy testing, compliance, and reporting requirements. We seek comment on improving location accuracy for mobile texts and on the benefits and costs associated with our proposals. Finally, we seek comment on whether certain of our legacy wireless location accuracy rules have become outdated and should be eliminated, and we also propose to eliminate certain obsolete information collection requirements associated with our 911 location accuracy rules. Since the Commission adopted the z-axis location accuracy standard in 2019, wireless location technologies continue to progress. The speed and accuracy of E911 location have improved significantly through integration of device-based hybrid (DBH) location technologies into most mobile handsets. DBH uses “a combination of technologies and sensors—including satellite GPS [Global Positioning System] and crowd-sourced Wi-Fi measurements—that can supplement wireless providers' existing 9-1-1 network and device-assisted information to produce a higher-accuracy location, particularly indoors.” Both Google and Apple have developed DBH applications optimized for emergency calls: Google's Android Emergency Location Service (ELS) supports 911 location in most Android devices, 35 and Apple's Hybridized Emergency Location (HELO) supports 911 location in most iOS devices. 36 According to live 911 call data reports submitted by CMRS providers, DBH technology has replaced assisted GPS (A-GPS) as the primary wireless 911 location technology and is used by CMRS providers for approximately 80% of wireless 911 calls. 37 35 Android, Emergency Location Service, https://www.android.com/safety/emergency-help/emergency-location-service/ (last visited Feb. 4, 2025) (describing ELS as “a tool available on Android devices that allows first responders to locate emergency callers and texters faster and with greater accuracy, using a combination of GPS, cell, Wi-Fi and sensor data”). 36 Press Release, Apple, Apple's iOS 12 securely and automatically shares emergency location with 911 (June 18, 2018), https://www.apple.com/newsroom/2018/06/apple-ios-12-securely-and-automatically-shares-emergency-location-with-911/ (stating that “Apple launched HELO (Hybridized Emergency Location) in 2015, which estimates a mobile 911 caller's location using cell towers and on-device data sources like GPS and Wi-Fi Access Points”). 37 Pursuant to Commission rules, CMRS providers collect and report aggregate data on the location technologies used for live 911 calls in six representative test cities. 47 CFR 9.10(i)(3). While the live call data submitted by each provider are confidential, aggregated call data from the three nationwide carriers show that the percentage of 911 calls in which DBH is used has risen from 17% in 2017 to 80% in 2022. In another significant development, a NENA working group has drafted consensus requirements and guidelines for operationalizing z-axis information in the PSAP to support the display of 3D location data for E911 and Next Generation 911. 38 Although the NENA requirements document has not yet turned into a formal standard, it can help expedite standards development and provide guidelines for transmission of vertical location information by CMRS providers and other entities in the location information delivery chain. It can also help to provide practical guidance for intake, processing, and display of z-axis information in the PSAP. To illustrate, the NENA requirements document includes guidance on converting altitude to floor levels, generating 3D volumes for buildings at low or no cost, available enterprise services, and consensus standards for operationalizing z-axis information ( e.g., configuring Automatic Location Identification (ALI) and provisioning 3D geographic information system (GIS) datasets). 39 38 NENA, NENA Requirements for 3D Location Data for E9-1-1 and NG9-1-1 (June 10, 2022), https://cdn.ymaws.com/www.nena.org/resource/resmgr/standards/nena-req-003.1-2022_3d_gis_w.pdf (NENA 3D Location Requirements). 39 Id. at 3. NENA's 3D Location Requirements document references the following five objectives. 1. To provide a technical and regulatory background for 3D 9-1-1 locations. 2. To establish uniform language in reference to z-axis within the 9-1-1 community for terms “altitude,” “height,” and “elevation” (as they are currently used interchangeably across specifications). 3. To provide practical guidance for operationalizing 3D location, such as how the Automatic Location Identification (ALI) should be configured and provisioning of 3D GIS datasets (including Digital Elevation Models [DEM] and 3D structures). 4. To provide requirements for future standards development for 3D location, such as how uncertainty should be conveyed for certain civic address elements. 5. To provide baseline requirements for implementations and enhancements. Id. As part of our overarching 911 agenda, and in light of increasing standardization, we seek to strengthen our wireless location accuracy rules to provide PSAPs and first responders with actionable information in the live 911 call environment. A. Improving Actionability of Z-Axis Information Under the current rules, CMRS providers providing coordinate-based location information to PSAPs with wireless 911 calls must deliver the z-axis component in Height Above Ellipsoid (HAE). 40 In addition, CMRS providers must provide floor level information when it is available. 41 We propose to make the z-axis information delivered to PSAPs and first responders with 911 calls more understandable and actionable by requiring CMRS providers to convert HAE values to Height Above Ground Level (AGL) and to provide both the HAE and AGL values with each call. We seek comment on data sources that can be leveraged to generate floor level information and whether to require CMRS providers to provide a floor level estimate with all calls. We also seek comment on how PSAPs use the vertical location information that is being provided today. Have PSAPs found the information to be useful, and have they observed any limitations in the accuracy of such information? To what extent do PSAPs use NENA 3D location guidelines or other mechanisms to operationalize the information? 40 47 CFR 9.10(i)(2)(ii)(H). 41 Id. 1. Converting HAE to AGL When the Commission mandated use of HAE in the Fifth Report and Order, the record reflected general consensus around using HAE as the baseline for measuring vertical location. 42 The Commission also acknowledged that HAE values would need to be translated to other formats to be actionable, but declined to require CMRS providers to perform the translation, concluding that “translation mechanisms can be developed using HAE as a baseline reference, and that for the time being we should afford industry and public safety flexibility to develop solutions that are cost-effective for both sides.” 43 42 Fifth Report and Order, 34 FCC Rcd at 11608, paragraph 33. 43 Id. at 11611, paragraph 38 (footnote omitted). Since the Fifth Report and Order, there has been significant progress in the development of data sources and translation tools that CMRS providers could use to translate HAE to AGL for the z-axis location of individual wireless 911 calls. As noted above, NENA has developed guidelines for operationalizing z-axis information. NENA suggests that HAE to AGL conversion can be performed by subtracting the terrain height, also expressed with respect to the WGS84 ellipsoid, at the horizontal location corresponding to the HAE. RapidSOS and GeoComm have partnered to convert z-axis information into actionable data, including height above ground and floor level, and 3D visualization of a caller's location in a building. In 2021, FirstNet unveiled z-axis capability using NextNav's Pinnacle vertical positioning service as part of its FirstNet Enhanced Location Services (FirstNet ELS) and provides z-axis data in Height Above Terrain (HAT) to indicate the relative altitude or vertical location of first responders. Digital terrain height information is typically available at various resolutions and costs. Currently, the U.S. Geological Survey (USGS) provides digital terrain maps at 10m by 10m resolution nationwide at no cost. 44 44 The United States Geological Survey provides a free topological map of the United States at a 1/3 arc-second DEM on its website. United States Geological Survey, The National Map (TNM) Datasets, https://apps.nationalmap.gov/datasets/ (last visited Feb. 4, 2025). One-third arc-second is equivalent to a resolution of “approximately 10 meters north/south, but variable east/west due to convergence of meridians with latitude.” United States Geological Survey, About 3DEP Products & Services, https://www.usgs.gov/3d-elevation-program/about-3dep-products-services (last visited Feb. 4, 2025). Given the availability of HAE-to-AGL translation tools, we propose to require CMRS providers to convert HAE values for individual 911 calls to AGL and to deliver both the HAE and the AGL values to the PSAP. We also propose to require CMRS providers to provide floor level information in addition to z-axis location information, if floor level information is available to them. This proposal is consistent with the existing requirement for providing z-axis information in HAE, which also requires provision of floor level information “[w]here available to the CMRS provider.” 45 While we do not propose to require floor level information at this time, we continue to believe that such information will be helpful to PSAPs and that CMRS providers should deliver it to the PSAP if it is available. We seek comment on these proposals. 45 See 47 CFR 9.10(i)(2)(ii)(H). AGL may be obtained by subtracting the terrain height at any horizontal (x/y) location from the corresponding HAE value, provided that both terrain height and HAE are expressed with respect to the same reference frame. 46 Providing AGL means that PSAPs receive a vertical location measurement relative to ground level for the x/y location of the call, which we tentatively conclude would be more actionable than the raw HAE value alone. 47 Receiving both the HAE and AGL values would enable the PSAP to check the accuracy of the HAE-to-AGL translation. We seek comment on this proposal. Would receiving AGL z-axis information benefit PSAPs and first responders? How much more actionable would the information be than HAE alone? Would it facilitate the ability of first responders to estimate floor level or integrate vertical location information into 3D mapping tools? If AGL is indeed more actionable than HAE, are there any benefits or costs to continuing to provide HAE values as well? 46 NENA 3D Location Requirements at 15, n.6 (“A reference frame, or geodetic datum, is ‘an abstract coordinate system with a reference surface (such as sea level) that serves to provide known locations to begin surveys and create maps.’ ”). 47 APCO Jan. 31, 2024 Ex Parte at 2 (“The Commission's rules require wireless carriers to provide a height estimate for 9-1-1 callers expressed as a `height above ellipsoid' . . . . Few 9-1-1 emergency communications centers (ECCs) have the resources to even explore how to make use of HAE-based vertical information (assuming this information is indeed accurate), which would require at a minimum substantial costs and resources including detailed building plans.”). We believe it is reasonable to require CMRS providers to provide AGL as part of the information delivered to PSAPs. In a 2020 ex parte filing in this proceeding, NENA noted that “the future of public safety-grade 3D mapping is surprisingly close and surprisingly feasible.” 48 At that time, NENA noted that “[i]t is close enough, in fact, that the Commission could reasonably require CMRS providers to sponsor large-scale, ‘entry-level’ Above Ground Level (AGL) conversion solutions for public safety. These solutions (presented as supplemental data alongside elevation in Height Above Ellipsoid [HAE]) would be understood by public safety to be a reliable stepping stone to more local, highly accurate vertical data.” Since then, the availability of terrain databases and HAE-to-AGL translation tools appears to provide a low-cost, scalable mechanism for CMRS providers to translate HAE to AGL. In addition, APCO contends that it is cost prohibitive for most PSAPs to perform the conversion to HAE on their own. We believe that requiring CMRS providers to deliver AGL to PSAPs would be a more efficient and cost-effective approach than placing the translation burden on thousands of individual PSAPs, as industry commenters have advocated. We seek comment on this view. Are the above-mentioned tools and computations viable for use in computing AGL data? To what degree are location technology vendors and GIS providers already performing these computations for 911 calls or capable of doing so? Where in the 911 call flow does conversion from HAE to AGL occur? How is the resulting AGL location information currently being used? What are the costs of such an approach? 48 Letter from Daniel Henry, Regulatory Counsel and Director of Government Affairs, NENA, to Marlene Dortch, Secretary, FCC, PS Docket No. 07-114, at 3 (filed Apr. 16, 2020) (NENA Apr. 16, 2020 Ex Parte ). We seek comment on the requisite level of Digital Terrain Model (DTM) resolution necessary to accurately convert from HAE to AGL, the means of achieving such resolution, and the associated costs. We also seek comment on how to ensure that AGL measurements provided to PSAPs meet the same or comparable confidence and uncertainty thresholds as the underlying HAE measurements from which they are derived. Because HAE conversion to AGL requires reliable terrain data and an accurate horizontal location fix, it may yield a different uncertainty value than HAE. Would conversion from HAE to AGL introduce any errors in the accuracy of the z-axis information that could impact emergency response and, if so, to what degree? 49 What technical standards are available for providers to determine the level of error, if any, introduced by the HAE to AGL conversion? Would technical standards need to be developed for this purpose? For purposes of determining AGL uncertainty, we propose to apply the Commission's prior determination that 90% is the appropriate confidence value. 50 Assuming a confidence value of at least 90%, how will uncertainty associated with the AGL value be calculated? For example, what uncertainty value will be generated by HAE conversion to AGL using the USGS 10m by 10m terrain data map, and by how much will the uncertainty value differ from the HAE uncertainty value? What uncertainty threshold needs to be achieved for PSAPs to consider an AGL measurement actionable? 49 See, e.g., NENA 3D Location Requirements at 83-84 (noting also that “transformations SHOULD only be used for internal processes and the results SHOULD NOT be passed to a downstream entity”). 50 In the Fifth Report and Order, the Commission required CMRS providers to provide vertical confidence and uncertainty data on a per call basis to requesting PSAPs. As with horizontal confidence and uncertainty data, the Commission explained, CMRS providers must report vertical confidence and uncertainty data using a confidence level of 90%, i.e., they must identify the range above and below the estimated z-axis position within which there is a 90% probability of finding the caller's true vertical location. 47 CFR 9.10(j)(1), (4). With respect to timing, we propose to require nationwide CMRS providers that deploy z-axis technology to deliver z-axis information in AGL within 12 months after the effective date of final rules, and we propose to require non-nationwide CMRS providers to deliver AGL within 24 months. As noted in the discussion above, technical feasibility appears well established, and therefore it appears deployment of this feature within a year of the effective date of our final rules should be reasonable. Based on the available information, we believe that the ability to convert HAE to AGL exists today, that PSAPs can readily receive the data and, as noted by previous commenters, that it would be reasonable to require CMRS providers to provide AGL conversion services. 51 We seek comment on this proposed timeline. Does it provide sufficient time for CMRS providers to develop and deploy the tools they need to provide z-axis information in AGL? Is the timeline sufficient for PSAPs to develop the capability to receive and use information in AGL? If the proposed timeline is not sufficient for either CMRS providers or PSAPs, what would be the appropriate time period and why? 51 See, e.g., NENA Apr. 16, 2020 Ex Parte (indicating that such a requirement might have been feasible as far back as 2020). 2. Providing Floor Level Estimates In the Fifth FNPRM, the Commission sought comment on whether to require CMRS providers to provide floor level information to PSAPs, either by converting HAE to a precise floor level or determining floor level independently of HAE. 52 In the Sixth Report and Order, the Commission deferred action on this issue in light of continued disagreement over the feasibility, costs, and timeframes associated with converting HAE to floor level. 53 We seek to refresh the record on this issue. Has there been progress since the Sixth Report and Order in developing mechanisms for calculating floor level, either by converting HAE to floor level or by other means? If PSAPs receive AGL in addition to HAE, could AGL be used to provide a reliable floor level estimate, by either using digital building maps or assuming a uniform building structure and floor spacing ( e.g., 3m per floor)? We seek comment on the ability of PSAPs to access digital building maps, which have the potential to provide highly accurate floor level information, depending on resolution, availability, and cost. What is the current availability of digital building maps, what is the cost of obtaining such maps for 911 location purposes, and what mechanisms exist to keep building map information current? Alternatively, using uniform building structure and spacing models to estimate floor level would be considerably less costly than using digital building maps, but also would yield less accurate information. We seek comment on whether such an approach would be sufficient to meet public safety requirements for actionable information. 52 Fifth Report and Order, 34 FCC Rcd at 11621-22, paragraphs 66 through 69. 53 Sixth Report and Order, 35 FCC Rcd at 7781-83, paragraphs 70 through 71. We also seek comment on the role that third-party vendors play in providing floor level information to PSAPs. As noted above, some third-party vendors are providing precise location information directly to PSAPs, with some claiming to provide AGL and floor level as well as HAE. 54 These vendors use a combination approach of multiple sensors already available in smart devices and the resultant data provided by the handset location vendors, along with crowd sourcing, via the increasing availability of “mesh like” networks of data points. 55 To what degree does the information provided to PSAPs by third-party vendors meet their needs for actionable location information, including floor level? Are floor level estimates validated against other information sources to ensure accuracy and, if so, what is the process for doing so? Are cloud services utilized for these capabilities and, if so, to what extent? What proportion of PSAPs currently relies on vendors to convert HAE to AGL or to generate floor level estimates? What is the cost to PSAPs to procure these services? If we required CMRS providers to provide floor level to PSAPs, would this reduce the cost burden on PSAPs? 54 See, e.g., GeoComm, GeoComm and RapidSOS Empower Emergency Communications Centers to Convert Raw Z-axis Location Data into Dispatchable Locations (Oct. 24, 2023), https://www.geocomm.com/rapidsos-dispatchable-locations/ . GeoComm notes that this feature is “[c]urrently available for 9-1-1 calls from Android-based devices.” Id. 55 See, e.g., Tom Sawanobori, The Wireless Industry's Commitment to 9-1-1 Location Accuracy (March 31, 2021), https://www.ctia.org/news/blog-the-wireless-industrys-commitment-to-9-1-1-location-accuracy (“Device-based hybrid solutions use a combination of technologies and sensors—including satellite GPS and crowd-sourced Wi-Fi measurements—along with wireless providers' other 9-1-1 network and device information, to produce a higher-accuracy location.”). B. Strengthening the Wireless 911 Location Accuracy Testing and Compliance Framework In the Fourth Report and Order, the Commission required independent testing of all technologies used to meet indoor location accuracy requirements, and directed industry to establish an independently administered test bed for this purpose. 56 The Commission established baseline requirements in order for test results derived from the test bed to be considered valid for compliance purposes. 57 In particular, the Commission specified that the test bed should “reflect a representative sampling of the different real-world environments in which CMRS providers will be required to deliver indoor location information,” and required all technologies to be tested in four morphologies: dense urban, urban, suburban, and rural. 58 The Commission further required location technologies to be tested in the same manner that they are deployed on provider networks. 59 The Commission established that CMRS providers could rely on test bed results to create a presumption of compliance with the Commission's location accuracy requirements when tested technologies were used in live 911 calls on the provider's network. 60 However, the Commission did not require CMRS providers to make the details of test results public, relying on the test administrators' certification as sufficient notification that a technology “meets our key performance indicators.” 61 56 Fourth Report and Order, 30 FCC Rcd at 1307-09, paragraphs 126 through 132; see also 47 CFR 9.10(i)(3)(i). 57 Fourth Report and Order, 30 FCC Rcd at 1307, paragraph 127. Specifically, the Commission stated that “the test bed must (1) include testing in representative indoor environments; (2) test for certain performance attributes (known as key performance indicators, or KPIs); and (3) require CMRS providers to show that the indoor location technology used for purposes of its compliance testing is the same technology (or technologies) that it is deploying in its network, and is being tested as it will actually be deployed in the network.” Id. 58 Id. at 1307, paragraph 128. 59 Id. at 1308, paragraph 130. 60 Id. at 1313, paragraph 147. 61 Id. at 1308, paragraph 131. Since the establishment of the test bed, it has been used to test the capabilities of horizontal and vertical location technologies used by CMRS providers. The first testing of vertical location technology in the test bed occurred in Stage Z, conducted in 2018, which provided information that contributed to the Commission's adoption of the ±3-meter accuracy metric. 62 Following adoption of the metric, the test bed conducted further vertical location testing in Stage Za from September 2019 to February 2020, and in Stage Zb from December 2021 to May 2022. Stage Za tested the z-axis performance of Google's Android ELS. 63 In Stage Zb, both ELS and Apple's HELO technologies were tested. 64 62 Fourth FNPRM, 34 FCC Rcd at 1651-52, 1654, paragraphs 4, 11. 63 Sixth Report and Order, 35 FCC Rcd at 7755-56, paragraph 9; Letter from Thomas K. Sawanobori, Senior Vice President & Chief Technology Officer, CTIA, and Scott K. Bergmann, Senior Vice President, Regulatory Affairs, CTIA, to Marlene H. Dortch, Secretary, FCC, PS Docket No. 07-114 (filed Apr. 29, 2020). 64 Stage Zb Cover Letter at 1 (reporting that Stage Zb testing validated that DBH z-axis location technology solutions, Google's ELS and Apple's HELO, together achieve ±3-meter accuracy for at least 80% of wireless 911 calls). The Stage Zb test results provided the basis for the June 2022 certifications by the three nationwide CMRS providers that as of April 3, 2022, they had achieved compliance with the ±3-meter location accuracy standard as required by the Commission's rules and the 2021 consent decrees. However, the underlying test reports and test data were not made public because they were submitted to the Commission subject to a request for confidential treatment to protect proprietary and commercially sensitive information. 65 This is consistent with prior test bed reports, which have similarly been submitted subject to requests for confidentiality. 65 Stage Zb Cover Letter at 6 (Attachment redacted). CTIA submitted two Stage Zb reports, one on testing of ELS (Google) and one on testing of HELO (Apple). CTIA requested confidential treatment of both reports to protect information submitted by Google and Apple regarding the “specifics of ELS's and HELO's respective performance, that is not publicly available and is protected against disclosure in the normal course of business.” Id. In addition, CTIA requested confidentiality for the Stage Zb Test Summary, noting that it contained “morphology-based 9-1-1 call data information from the nationwide wireless providers (AT&T Mobility, T-Mobile USA, and Verizon) that is proprietary and commercially sensitive and not publicly available.” Id. The purpose of the test bed program is to provide a reliable mechanism for validating the performance of indoor location technologies without the need for each provider to conduct indoor testing in all locations where a technology is actually deployed, which would be impractical and highly burdensome. 66 In establishing the test bed approach, the Commission found it to be “the most practical and cost-effective method for testing compliance with indoor location accuracy requirements.” 67 Following the 2015 Fourth Report and Order, CTIA and the nationwide CMRS providers worked with APCO, NENA, and other stakeholders to establish the test bed, based on the framework recommended in 2014 by the Communications Security, Reliability, and Interoperability Council (CSRIC), with testing following guidelines developed in 2017 by the Alliance for Telecommunications Industry Solutions' (ATIS) Emergency Services Interconnection Forum (ESIF) and input from other stakeholders. 68 However, in the multiple years since the test bed was established, some public safety organizations have raised questions about whether the test bed and compliance certification process for validating vertical location technologies provides adequate assurance of real-world performance. In addition, parties have advocated for greater transparency in the test bed process and have sought expanded access to test results and underlying test data. As discussed below, we propose to make certain modifications to the wireless location accuracy testing and compliance framework to address these issues. 66 Fifth Report and Order, 34 FCC Rcd at 11613, paragraph 45. 67 Fourth Report and Order, 30 FCC Rcd at 1305, paragraph 121. 68 See, e.g., Fifth Report and Order, 34 FCC Rcd at 11602-03, paragraph 19 & nn.83-85; CSRIC IV Working Group 1, Final Report: Specification for Indoor Location Accuracy Test Bed (June 2014), https://transition.fcc.gov/pshs/advisory/csric4/CSRIC_IV_WG-1_Subgroup3_061814.pdf; Report on Stage Z, 911 Location Technologies Test Bed, LLC, at 3-4, 12-14 (2018), https://api.ctia.org/wp-content/uploads/2018/08/911-Location-Test-Bed-Stage-Z-Report-Final.pdf; ATIS, Test Bed and Monitoring Regions Definition and Methodology, ATIS-0500031.v002 (approved Feb. 13, 2017) ( ATIS-0500031.v002 ). 1. Requiring Validation on a Per-Morphology Basis As noted above, the nationwide CMRS providers based their compliance certifications on the Stage Zb test results submitted by CTIA. These test results were derived from “aggregated and anonymized” data “to generate z-axis performance metrics for the DBH technology solutions deployed in each of the nationwide wireless providers' networks, consistent with ATIS standards and reporting under the Commission's live 9-1-1 call data rules.” According to CTIA, “[t]he results of Stage Zb validate that ELS's and HELO's DBH z-axis location technology solutions together achieve the FCC's ±3-meter accuracy metric for at least 80 percent of wireless 9-1-1 calls.” In relying on the Stage Zb test data to support their compliance certifications, the nationwide carriers, following the ATIS standards, averaged test results across morphologies based on the percentage of live calls that originated in each morphology. 69 Because live call data show that the preponderance of 911 calls originate from suburban areas, this methodology effectively discounted Stage Zb results for urban and dense urban morphologies, where vertical location technology is most useful. While such aggregation may be allowable under our current rules, it raises questions about whether such aggregated test data accurately reflect the real-world performance of the technologies being tested. Testing of z-axis technologies in the test bed identifies the percentage of test calls in each morphology that generated a location fix of ±3 meters. 70 Live call data, on the other hand, identifies the relative number of live 911 calls in each morphology for which a given z-axis technology was used to provide vertical location. 71 Thus, live call data provides no information regarding the actual performance of z-axis technologies in the live environment, either across morphologies or within any individual morphology. 72 69 CTIA notes that “[t]he Test Bed performed the Stage Zb testing in accordance with ATIS standards and Commission rules.” Stage Zb Cover Letter at 4 & n.4 (citing ATIS, Unified X/Y and Z Indoor Test Methodology, ATIS 0500040 (approved Jan. 13, 2020) and 47 CFR 9.10(i)(3)(i)(A) through (D)). ATIS 0500040 states that “the critical statistics are those obtained for each morphology, aggregated across the various test regions. These per-morphology metrics are subsequently entered into the live call weighting process, as defined in ATIS-0500031.v002 [Ref 1], Clause 8, for regulatory compliance purposes.” 70 The rules require CMRS providers to “measure yield separately for each individual indoor location morphology (dense urban, urban, suburban, and rural) in the test bed, and based upon the specific type of location technology that the provider intends to deploy in real-world areas represented by that particular morphology.” 47 CFR 9.10(i)(3)(i)(D). 71 Public Safety and Homeland Security Bureau Provides Guidance to CMRS Providers Regarding Upcoming E911 Indoor Location Accuracy Reporting Requirements, PS Docket No. 07-114, Public Notice, 32 FCC Rcd 5584-85 (PSHSB 2017) (revising the instruction for entering “yield” in live call reports). 72 We note that in 2000, the Commission's Office of Engineering and Technology and, subsequently in 2012, the third CSRIC (CSRIC III) recognized the possible use of weighting based on 911 call densities as a valid testing input to demonstrate compliance with the overall performance metrics required under the Commission's 911 location accuracy rules. FCC Office of Engineering and Technology, OET Bulletin No. 71, Guidelines for Testing and Verifying the Accuracy of Wireless E911 Location Systems, at 6-7 (Apr. 12, 2000), https://transition.fcc.gov/oet/info/documents/bulletins/oet71/oet71.pdf; CSRIC III, Working Group 3, E9-1-1 Location Accuracy, Final Report—Outdoor Location Accuracy, at 12 (Mar. 14, 2012), https://transition.fcc.gov/bureaus/pshs/advisory/csric3/CSRIC-III-WG3-Final-Report.pdf. To address these issues, we propose to modify our rules to require that validation of a technology in the industry test bed must demonstrate compliance of that technology with the 3-meter metric in each morphology. Thus, we would no longer allow CMRS providers to base compliance certifications on aggregating or averaging test bed results across morphologies. By eliminating averaging across morphologies, we would provide greater certainty that vertical location technologies that have been tested in the test bed will provide the requisite accuracy level when used with 911 calls in each of the four morphologies. We also propose to exclude the use of live call data in the validation of vertical location technologies. Live call data does not demonstrate performance, either on a per-technology or a per-morphology basis. In addition, live call data does not distinguish between indoor and outdoor calls, and thus does not provide a basis for determining compliance with indoor vertical location requirements. 73 73 The 2015 Fourth Report and Order stated that live call data, when coupled with test bed performance data for each positioning source method, “will then determine the degree to which that method can be counted towards the required location accuracy thresholds each time that positioning source method is used.” Fourth Report and Order, 30 FCC Rcd at 1311, paragraph 139. In 2017, ATIS published guidance that enables wireless providers to demonstrate compliance with the Commission's rules and suggests weighting test results based on “the proportion of live indoor wireless 911 calls in each corresponding morphology” to come up with a single number for compliance purposes. ATIS-0500031.v002 at 5. We seek comment on these proposals. Should the number or percentage of total 911 test calls required for validation of a technology be the same for each morphology? For example, should the number or percentage be lower for a morphology that has fewer tall buildings, such as rural or suburban, while maintaining the same level of confidence ( e.g., 90%) in the test results? Are there circumstances where it would be appropriate to allow CMRS providers to average test data across morphologies for compliance purposes? Similarly, are there circumstances where we should allow consideration of live call data or other factors in determining compliance on a per-morphology basis? How should we define a technology for purposes of these requirements? For example, should ELS and HELO be defined as separate technologies? Should CMRS providers be allowed to average or combine the performance of different technologies within a morphology ( e.g., ELS and HELO) in support of a compliance showing? 74 Should we allow weighted averaging based on the percentage of handsets equipped with each technology in the provider's subscriber base? Should CMRS providers be allowed to certify their compliance based on an average of the handset distribution of multiple providers? How should non-nationwide CMRS providers that do not conduct their own testing in the test bed use the test bed data to certify their compliance with the proposed testing and validation requirements? 75 Should non-nationwide CMRS providers be allowed to use performance data from the test bed in a different manner from nationwide CMRS providers to certify their compliance with our proposed testing and validation requirements? 74 As noted, CTIA states that “Stage Zb[ ] test results from the two DBH location technology solutions [HELO and ELS] were aggregated and anonymized to generate z-axis performance metrics for the DBH technology solutions deployed in each of the nationwide wireless providers' networks, consistent with ATIS standards and reporting under the Commission's live 9-1-1 call data rules.” Stage Zb Cover Letter at 5 (citing ATIS Test Bed Monitoring Regions Definition and Methodology, ATIS 00500031v.002 (Feb. 2017) and 47 CFR 9.10(i)(3)(ii)(C)). 75 See infra for discussion of proposals to increase the transparency of the test bed process for non-nationwide CMRS providers and other stakeholders. We propose to apply these requirements for testing and validation of technologies in the test bed to all testing of new technologies in the test bed once the rules become effective. In addition, we propose that by 24 months after the effective date of the final rules, nationwide CMRS providers must deploy on a nationwide basis either dispatchable location or z-axis technology that has been validated in accordance with the new test bed and validation requirements. We propose that non-nationwide CMRS providers would have an additional 12 months to meet these requirements by deploying either dispatchable location or z-axis technology throughout their network footprint. If we modify testing and validation procedures as proposed, we anticipate that some z-axis technologies that were previously validated in the test bed may have to be re-tested under the new requirements, including the requirement that validation of a technology in the test bed must demonstrate compliance of that technology with the 3-meter metric in each morphology. CMRS providers may also need time to determine how to deploy technologies or combinations of technologies in a way that complies with the revised rules. Are the timeframes we propose for this appropriate? If not, what would be appropriate timeframes to allow for re-testing, certification, and deployment? Is additional testing and standardization necessary to determine whether any revisions to our accuracy benchmarks are required due to these new requirements? If so, how much time is needed to complete such additional testing or modifications to standards? We seek comment on the potential costs of any re-testing. Do most deployed and validated z-axis technologies already meet this proposed per-morphology standard? Should we establish interim milestones as well as final compliance deadlines? In the Fourth Report and Order, the Commission required the test bed administrator to “make available to [non-nationwide CMRS providers] the same data available to participating CMRS providers and under the same confidentiality requirements.” 76 The Commission noted that the purpose of this requirement was to “enable such CMRS providers to determine whether to deploy that technology in their own networks” and to “obviate[ ] the need for individual testing by those providers.” 77 The test bed administrator has defined procedures and established a fee structure for non-nationwide CMRS providers to follow to obtain access to test results. However, there are no deadlines for providing non-nationwide CMRS providers with access to test data and no explanation of the costs that the fees are intended to recover. In addition, location accuracy test data and the reports generated by the industry test bed are currently subject to confidentiality protections, and we require only summary information to be provided to most third parties. 78 We recognize that some confidentiality protection of test data and reports is appropriate to enable vendors who submit to testing to protect proprietary and competitively sensitive information. However, the restrictions applicable to test bed information have resulted in virtually no information being available to PSAPs or the public. 79 In addition, while APCO and NENA have access to some test bed information as members of the Test Bed's Technical Advisory Committee, and some test reports have been disclosed to APCO, NENA, and NASNA, disclosure is subject to highly restrictive non-disclosure agreements that limit the ability of these organizations to disseminate or take action based on the information. 76 Fourth Report and Order, 30 FCC Rcd at 1309, paragraph 132; see also Wireless E911 Location Accuracy Requirements; The 911 Location Technologies Test Bed, LLC Request for Confidential Treatment, PS Docket No. 07-114, Order, 35 FCC Rcd 6486, 6488-89, paragraphs 5 through 6 (2020) ( Stage Za Report Confidentiality Order ) (granting confidential treatment of the Stage Za Report, in part because the test results are “indisputably commercial information”). 77 Id. 78 Fourth Report and Order, 30 FCC Rcd at 1308, paragraph 131 (“[R]aw test results would be made available only to the vendors whose technology was to be tested, to the participating CMRS providers, and to the third-party testing house. In order to protect vendors' proprietary information, only summary data was made available to all other parties. At this time, we will not require CMRS providers to make public the details of test results for technologies that have been certified by the independent test bed administrator.”); see also Stage Za Report Confidentiality Order, 35 FCC Rcd at 6486-87, paragraphs 1 through 2. 79 See, e.g., APCO May 20, 2024 Ex Parte at 2 (stating that “[f]urther Commission action is needed to improve the transparency and reliability of testing to evaluate location technologies and to provide stronger requirements for carriers to deploy methods, several of which are feasible today, to derive dispatchable location”). We seek to promote greater transparency and accountability in the test process by creating a standard process for sharing test bed data and procedures with stakeholders. Specifically, we propose that upon request from a non-nationwide CMRS provider, NENA, APCO, or NASNA, the test bed administrator must provide the requesting party the same data available to CMRS providers participating in the test bed, including unaggregated test bed results by wireless location technology provider, morphology, and technology, as well as other relevant information sought by the requesting party (such as information on the test bed process, including any significant changes to the test bed process). We propose that this obligation would include providing the requesting party with test bed data, as well as the full report on the test bed results. In addition, we propose that the test bed administrator must make this information available to the requesting party on a timely basis not to exceed 30 days, at no cost, and subject to the same confidentiality requirements as those for the nationwide CMRS providers. We seek comment on these proposals. Should these entities be required to pay fees to obtain access to test data and, if so, are guidelines or conditions needed to eliminate unnecessary costs? Is 30 days an appropriate limit on the time for responding to a request? We also seek comment on whether the test bed administrator should be required to negotiate a standardized agreement with requesting non-nationwide CMRS providers and public safety entities that would provide for access to test bed information on a timely basis and on reasonable terms. In that connection, we seek comment on what would constitute reasonable terms for such an agreement. We also seek comment on narrowing the scope of confidentiality over the test bed validation process and the extent to which the test bed administrator, CMRS providers, technology providers, or others should be able to claim confidentiality with respect to test results or test bed procedures. Given the critical public importance of providing accurate location with 911 calls, should we create a presumption that test bed reports are to be made public? How can the Commission's rules help the test bed strike a balance between protecting and safeguarding non-public information ( e.g., proprietary business information) in ways that promote vendor participation in the test bed, while also promoting greater transparency and accountability for non-nationwide CMRS providers and public safety stakeholders in the test process? 3. Location Testing Challenge Process The current rules provide a means for PSAPs to resolve real-world performance issues after a tested location technology has been deployed by a CMRS provider. However, our rules do not provide a mechanism for stakeholders to challenge the validation of a technology in the test bed before it is deployed. We propose to amend the rules to provide for greater transparency in the test bed, including a process for challenging the validation of location technologies in the test bed. Specifically, we propose that APCO, NENA, or NASNA may submit to the Commission a challenge to the validation of a particular technology under the test bed provisions in the rules. 80 We also propose that such challenges must be limited to whether the process for validating a particular technology has met the requirements of the rules and that such challenges must be made prior to 60 days after the CMRS provider's certification. Is 60 days after a CMRS provider's certification an appropriate final deadline for submitting such a challenge? Should we require particular information to support a challenge? We seek comment on when to allow such challenges, e.g., while testing is underway, after the test bed administrator has validated a particular technology, after a CMRS provider certifies compliance with the rules, and the proposed scope of such challenges. We also seek comment on whether to allow additional parties besides APCO, NENA, and NASNA ( e.g., individual PSAPs) to bring such challenges. In addition, we seek comment on whether the Public Safety and Homeland Security Bureau should address challenges to the test bed validation process to ensure compliance with our rules if the parties cannot resolve the matter, including seeking public comment on contested technology validation. To what extent would Public Safety and Homeland Security Bureau involvement, or the challenge process as a whole, unreasonably delay technology deployments necessary to advance our public safety objectives in this proceeding? Should there be limits, such as time frames, on such a challenge process to expedite it and ease the burden on the parties involved? If so, what should those limits be? Would the existence of a challenge process discourage parties from participating in the test bed process? 80 See 47 CFR 9.10(i)(3)(i) (requirements for “Indoor location accuracy test bed”). C. Increasing the Provision of Dispatchable Location With Wireless 911 Calls Throughout this proceeding, the Commission has recognized the importance of dispatchable location to public safety, and has sought to encourage the development of dispatchable location solutions that would reliably identify the precise location of in-building wireless 911 callers. In the Fourth Report and Order, the Commission noted that as part of the “Roadmap” agreement between public safety and the major wireless providers, the wireless industry had committed to build the NEAD, a national database of in-building access points that would be leveraged to support dispatchable location. Although the Commission did not require wireless providers to build or use the NEAD, it modeled its rules so that wireless providers could use the NEAD as a mechanism for complying with wireless location accuracy requirements. 81 81 The Commission's 2015 rules specified that “[i]n each CMA where dispatchable location is used: nationwide CMRS providers must ensure that the [National Emergency Address Database] is populated with a sufficient number of total dispatchable location reference points to equal 25 percent of the CMA population.” 47 CFR 20.18(i)(2)(ii)(C)( 1 ) (2015 version; also later renumbered to § 9.10); see Fourth Report and Order, 30 FCC Rcd at 1361, Appx. A (containing 2015 version of rule). In the Sixth Report and Order, following the discontinuance of the NEAD, the Commission modified its rules to encourage the development of alternatives to the NEAD to support dispatchable location. The Commission noted that the record reflected a diverse array of technological approaches that could be used to provide dispatchable location, including reverse geocoding, device contextual information, indoor mapping, 5G home voice products, 911 calls using Voice over Wi-Fi, and DBH. 82 Given the early development of these solutions, however, the Commission declined to adopt minimum percentage thresholds for dispatchable location for 911 calls, finding that such particularized requirements went beyond what was technically feasible and cost-effective at the time. 83 In addition, the Commission declined to specify confidence and uncertainty values when conveying dispatchable location, citing the need for standards work in this area. 84 However, the Commission adopted the requirement that “[a]ll CMRS providers shall provide dispatchable location with wireless E911 calls if it is technically feasible for them to do so.” 85 This rule mirrors the dispatchable location requirement that the Commission adopted in the 2019 Kari's Law/RAY BAUM'S Act Report and Order for 911 calls originated on non-CMRS platforms, including multi-line telephone systems (MLTS), interconnected VoIP, Telecommunications Relay Services (TRS), and fixed telephony. 86 82 Sixth Report and Order, 35 FCC Rcd at 7773, paragraph 49 & n.139. 83 Id. at 7776, paragraph 53. 84 Id. at 7778, paragraph 61. 85 47 CFR 9.10(i)(2)(ii)(G); Sixth Report and Order, 35 FCC Rcd at 7792, Appx. A. 86 Implementing Kari's Law and Section 506 of RAY BAUM'S Act; Inquiry Concerning 911 Access, Routing, and Location in Enterprise Communications Systems; Amending the Definition of Interconnected VoIP Service in Section 9.3 of the Commission's Rules, PS Docket Nos. 18-261 and 17-239, GN Docket No. 11-117, Report and Order, 34 FCC Rcd 6607, 6733-34, Appx. A (2019), 84 FR 66716 (Dec. 5, 2019) ( Kari's Law/RAY BAUM'S Act Report and Order ), corrected by Erratum, 34 FCC Rcd 11073 (PSHSB 2019), also corrected by Second Erratum, 37 FCC Rcd 10274 (PSHSB 2022); 47 CFR 9.16. We seek comment on the degree to which the current dispatchable location requirements for CMRS providers have, or have not, been effective in facilitating the development of dispatchable location solutions. According to live call data reported by the nationwide CMRS providers for 2023 and part of 2024, CMRS providers are delivering some live wireless 911 calls with dispatchable location. 87 We seek comment on specific technologies that CMRS providers are using to deliver dispatchable location with these calls. How do CMRS providers validate the street address and other in-building location information delivered with such calls? Do the CMRS providers apply confidence and uncertainty thresholds to ensure against inaccuracies or errors in the validation process? When conveying dispatchable location with wireless 911 calls, do CMRS providers also convey coordinate-based (x/y/z) information and, if so, do they use the geodetic information and confidence and uncertainty data to validate the accuracy of the dispatchable location? When dispatchable location information is available, how often do PSAPs use this information to support emergency response, and how do they use it? 87 Total aggregated dispatchable location call totals from the 2023 and 2024 (partial) quarterly reports submitted by the nationwide CMRS providers amount to 310,542. We note that the individual carrier data are confidential. We also seek comment on how to increase the availability and use of dispatchable location for wireless 911 calls. The live call data reported by the nationwide CMRS providers indicate that dispatchable location calls represent only about 0.9%; of total wireless 911 calls. 88 To what extent are these percentages attributable to factors beyond the carriers' control? Given this very low percentage, what steps, if any, are CMRS providers taking to increase their use of dispatchable location? Are there technically feasible solutions that could support provision of dispatchable location for a larger percentage of calls than current levels? Should we require CMRS providers to develop plans and timelines for expanding the use of dispatchable location when 911 calls on their networks originate in indoor environments provisioned with Wi-Fi access points, femtocells, or Internet of Things (IoT) devices, the location of which can be identified and mapped for geolocation purposes? Should we establish benchmarks or timelines for providing dispatchable location with wireless 911 calls? Should we establish benchmarks or timelines only for providing dispatchable location in particular environments that are likely to have such infrastructure that can be identified and mapped for geolocation purposes, e.g., individual residences, multi-story office buildings, apartment buildings, hotels, conference centers, or other environments? If we establish timelines or benchmarks, should we provide additional time for non-nationwide CMRS providers? 88 The total percentage of live 911 calls with dispatchable location relative to z-axis information from the 2023 and 2024 (partial) quarterly reports submitted by the nationwide CMRS providers is 0.89%. We invite commenters to identify incentives for CMRS providers to expedite their efforts to find solutions for generating and conveying dispatchable location for higher percentages of wireless 911 calls. What is the current state of deployment of in-building infrastructure that is or could be programmed with street address and floor level information? Regarding access points, we seek comment on the accuracy of programming access points with street address and floor level. What percentage of wireless traffic is offloaded from CMRS networks to indoor infrastructure, such as Wi-Fi and femtocells, and what percentage of wireless 911 calls on CMRS networks present as Wi-Fi calls? Are there circumstances where the Wi-Fi network could provide dispatchable location information that is more precise and reliable than the location information provided for the call over the cellular network? Do CMRS providers currently use or plan to use location information from indoor infrastructure in combination with geodetic (x/y/z) coordinates? What are the timelines for planned use of in-building infrastructure to provide dispatchable location? In that connection, we seek comment on how combining location technologies and device sensors can supplement CMRS providers' existing 911 network and device-assisted information for generating dispatchable location. We also seek to refresh the record on the current and future feasibility of leveraging the specific technologies that the Sixth Report and Order and other sources have identified as having the potential to support dispatchable location, e.g., reverse geocoding, commercial location-based services (cLBS), Voice over Wi-Fi, and small cells. 89 In the Sixth Report and Order, the Commission concluded that it was premature to adopt dispatchable location benchmarks or timelines based on these technologies. 90 Is that still the case? We seek comment on the potential for each of these technologies, individually and in combination with others, to support dispatchable location. 89 See, e.g., Sixth Report and Order, 35 FCC Rcd at 7773, paragraph 49 & n.139. 90 See, e.g., id. at 7757, 7776, paragraphs 12, 53. Reverse Geocoding. Reverse geocoding refers to the process of using geodetic information to generate a civic address and other location information such as floor level and room number. 91 We seek comment on whether reverse geocoding represents a technically feasible solution for generating dispatchable location and floor level estimates. Is accurate reverse geocoding widely available and reliable? What data sources are required for reverse geocoding, and how readily available are they? How accurate are these data sources? Has horizontal (x/y) location accuracy achieved sufficient granularity and confidence/uncertainty levels to support reliable reverse geocoding of civic addresses with minimal risk of error? As between the CMRS provider and the PSAP, who should perform these conversions, and why? What are the costs associated with this process for CMRS providers and PSAPs? Who should incur these costs? 91 See, e.g., NENA 3D Location Requirements at 12-17. As described by NENA, reverse geocoding matches horizontal (x/y) coordinates to an address database to obtain a civic address, then uses z-axis information (in HAE) to estimate AGL, and then uses AGL to estimate the caller's floor level (FL). NENA explains, “Geodetic location is fundamental to location in 9-1-1 because it provides a means for representing a position estimate. Devices, often with the cooperation of network elements, can estimate their position. This position estimate is expressed using a standard geodetic reference, as coordinates within the reference. For emergency services to correctly identify the appropriate responding agency and for responders to locate the caller, a high-quality location estimated in 3D space is essential. Geodetic location expressed as standardized coordinates allows 9-1-1 networks and elements inside and outside those networks to exchange and process location information without conversion.” NENA 3D Location Requirements at 16. Commercial Location-Based Services. As a general matter, commercial location-based services (cLBS) use a variety of techniques to find a wireless 911 caller's location. For example, new technologies based on the IEEE 802.11mc (Wi-Fi Round Trip Time or Wi-Fi RTT) standard may enable smartphones to measure the distance to nearby Wi-Fi access points and determine their indoor location without having to connect to the access point. Have CMRS providers been successful at leveraging commercial location-based services for 911 use? Could CMRS providers use such technologies to generate and convey dispatchable location for wireless 911 calls and, if so, under what conditions? Are there commercial benefits from deploying such technologies that would support improved indoor location accuracy? Voice over Wi-Fi (Wi-Fi Calling). The potential to deliver 911 calls over Wi-Fi has been the subject of continued study since the Sixth Report and Order. In 2021, the Public Safety and Homeland Security Bureau submitted a report to Congress on the technical feasibility of using Wi-Fi access points to support 911 calling. 92 In March 2023, CSRIC issued a report on 911 service over Wi-Fi that included discussion of location determination for Wi-Fi 911 calls. 93 The report noted that Wi-Fi caller location continues to be heavily reliant on the user's registered location, which may not identify the caller's actual location at the time of the call. CSRIC noted, however, that “[t]he broad availability of DBH location technologies combined with the deployment of location-based routing has led to improvements in location information for 911 over Wi-Fi over supporting networks, reducing the reliance upon a user-inputted Registered Location and associated challenges.” 94 92 FCC, Report to Congress: Study on Emergency 911 Access to Wi-Fi Access Points and Spectrum for Unlicensed Devices When Mobile Service Is Unavailable (PSHSB Mar. 23, 2021), https://www.fcc.gov/document/report-congress-911-over-wi-fi (Report to Congress on Emergency 911 Access to Wi-Fi). 93 Communications Security, Reliability, and Interoperability Council (CSRIC) VIII, Report on 911 Service Over Wi-Fi at 48-49 (2023), https://www.fcc.gov/CSRICReports. 94 Id. at 49. In light of these developments, we seek comment on the current technical feasibility of CMRS providers using Voice over Wi-Fi (also referred to as VoWi-Fi or Wi-Fi calling) to deliver wireless 911 calls with accurate and reliable dispatchable location. What Wi-Fi 911 calls, if any, do CMRS providers currently deliver to PSAPs with dispatchable location? How is the caller's location validated at the time of the call, particularly if it is not the same as the caller's registered location? Do CMRS providers corroborate Voice over Wi-Fi calls with geodetic information before transmitting to PSAPs? Do CMRS providers transmit geodetic information with such wireless 911 calls and, if so, do they convey confidence and uncertainty data? Small Cells. CMRS providers already deploy various indoor coverage and network capacity expansion solutions, such as residential femtocells, enterprise microcells, and distributed antenna systems, that can be sources for generating dispatchable location. 95 Because these devices typically are deployed at known locations and have a relatively small coverage footprint, we seek comment on whether associating a caller to a small cell could be used in some environments to derive a dispatchable location for the caller. How widely are small cell 96 solutions available today? Are they used to generate dispatchable location or other location information in support of wireless 911 calls? How is location information provided by the small cell verified? What are the main issues for using these types of solutions to generate dispatchable location? For instance, if a femtocell is moved from its initial location, would the network detect this and require an update to the femtocell location and prompt the end user? 95 See Fourth Report and Order, 30 FCC Rcd at 1275-76, paragraph 46 (stating that “the feasibility of dispatchable location is linked to the proliferation of indoor, infrastructure-based technologies, including small cell technology, distributed antenna systems (DAS), Wi-Fi access points, beacons, commercial location-based services (cLBS), institutional and enterprise location systems, and smart building technology”). See, e.g., Verizon Petition for Waiver at 9 (stating that Verizon has begun delivering dispatchable location to PSAPs for 911 calls from certain devices when the information can be determined reliably, including certain 911 calls using Voice over Wi-Fi and indoor Distributed Antenna System (DAS) configurations); AT&T, AT&T Microcell ® Terms of Service https://www.att.com/legal/terms.microcellterms.html (last visited Feb. 4, 2025) (“911 calls placed over your MicroCell will be routed to the emergency response center responsible for sending first responders ( i.e., police, medical assistance or fire) to your location based on the address you provide in your online registration.”). 96 The Small Cell Forum has defined a small cell as “a low-cost radio access point with low radio frequency (RF) power output, footprint and range. It can be deployed indoors or outdoors, and in licensed, shared or unlicensed spectrum.” Small Cell Forum, About small cells, https://www.smallcellforum.org/small-cells/ (last visited Feb. 4, 2025). Types of small cells include femtocells, picocells, and microcells—broadly increasing in size from femtocells (the smallest) to microcells (the largest). See, e.g., FCC, Small Wireless Facilities: An Introduction to 5G Infrastructure and the Streamlined Section 106 Review of Small Wireless Facilities at 11 (Sept. 13, 2022), https://www.fcc.gov/sites/default/files/workshop-09132022-session-3.pdf (FCC Environmental Compliance Workshop presentation); Press Release, Small Cell Forum, Femto Forum Becomes Small Cell Forum as Femtocell Technology Extends Beyond the Home (Feb. 15, 2012), https://www.smallcellforum.org/press-releases/femto-forum-becomes-small-cell-forum-femtocell-technology-extends-beyond-home/. Location Databases. While CMRS providers are no longer pursuing the NEAD, the potential remains for providers to create or rely on other address or location databases to obtain or generate dispatchable location information. We seek comment on whether CMRS providers have created in-house address databases or have access to third-party databases that support 911 caller location. How reliable and accurate are these databases? If the databases contain access point information, how are access point locations verified, both initially and if the access point location changes? Are there any existing standards for creating such databases and validating addresses? Are CMRS providers sharing, or do they intend to share, the information in these databases with each other? Smart Building/In-building Technologies. We seek comment on whether the evolution and deployment of “smart building” technology could lead to dispatchable location information being more readily available. To what degree are buildings equipped with IoT sensors and data-capable devices capable of collecting, storing, and transmitting location-specific data that could be used to support dispatchable location for wireless calls from within the building? Could cloud computing and indoor mapping applications be leveraged to support expansion of smart building capabilities into the public safety realm? Can smart building sensors, devices, and networks be configured in such a way that a mobile device originating a 911 call could interact with them and derive relevant location information? Are there infrastructure requirements to make this a viable approach? What would anticipated incremental costs be? Would hardware or software modification be required to handsets, or would the fact that most wireless sensors are already configured to communicate via Bluetooth and Wi-Fi be a mitigating factor? 5G Networks. We seek comment on whether 5G networks have the potential to deliver more precise location information that could support dispatchable location. Do technology providers envision the ability to leverage on-device capabilities and analytics with 5G capabilities to create a more precise location determination environment? 97 Do these 5G-based improvements include positioning accuracy by combining 5G measurements, Global Navigation Satellite Systems (GNSS), multi-path profiles, sensor inputs, and Artificial Intelligence-assisted RF sensing using Wi-Fi as it currently exists today? We understand that this is heavily dependent on the broader deployment of 5G and on the implementation of updated and advanced capabilities as defined by 3GPP. However, since public statements continue to be made touting these benefits, 98 we believe there is value in discussing what specific capabilities are either already deployed, or anticipated to become available in the near future that support achieving dispatchable location. What is the current state of 5G capabilities on this front? What is the roadmap for the implementation of these advanced capabilities? Even absent the use of Artificial Intelligence, will the deployment of 5G networks result in greater location accuracy, including vertical location? 97 See, e.g., Letter from Jeffrey S. Cohen, Chief Counsel, APCO International, to Marlene H. Dortch, Secretary, FCC, PS Docket No. 07-114, at 2 (filed July 10, 2020) (“With increasing news of carriers deploying in-home and in-office 5G-based fixed wireless products, the carriers could similarly provide dispatchable location associated with these technologies.”). 98 See, e.g., Verizon Comments, PS Docket No. 07-114, at 8 (rec. Feb. 21, 2020) (Verizon Comments) (“Verizon already plans to incorporate dispatchable location capabilities into 5G home voice products.”). Other Stakeholders. As noted, we understand that it is critical to foster cooperation and collaboration among multiple stakeholders in the process of generating and delivering 911 calls and actionable location information. Those parties include not only the CMRS providers and PSAPs, but also third parties, including cable and internet service providers (ISPs), original equipment manufacturers (OEMs), and vendors. We seek comment on the role and responsibilities of these third parties in facilitating CMRS providers' compliance with any standards that we may adopt for conveying dispatchable location. In this proceeding, commenters have noted that CMRS providers, cable companies, ISPs, device manufacturers, and operating system providers have a role to play in improving location information for 911 but that challenges to achieving industry coordination remain. 99 What companies own or control these capabilities or systems ( e.g., database vendors, equipment manufacturers, Wi-Fi access point aggregators, indoor small cells owners or managers, IoT sensor and data-capable device owners or managers)? To what extent do wireless providers have access or visibility to information sources owned, controlled, or managed by these entities? How would access to such information sources enable CMRS providers to obtain or generate dispatchable location? We seek comment on the extent to which applying standards or requirements to parties other than CMRS providers would increase the availability and use of dispatchable location solutions. Do databases or other information sources owned, maintained, or controlled by service providers and other entities have the capability to support location validation with sufficient reliability to meet public safety requirements for accurately identifying the caller's location? How should we engage or require cable companies, ISPs, OEMs, vendors, or other entities in finding solutions to providing validated street address and floor level information for wireless 911 calls? Do these parties have concerns over authentication protocols, privacy, and security that would need to be addressed? What measures would be needed to help ensure that location data generated by or with the assistance of third parties are transmitted and configured to enable compatibility and interoperability with CMRS providers and the 911 system? 99 See, e.g., Verizon Comments at 2 (“Third party providers of those services and products all have their own business and policy priorities that may not always coincide with one another, or with service providers' E911 compliance demands.”); NCTA Reply, PS Docket No. 07-114, at 10-13 (filed June 18, 2019) (stating that “customer Wi-Fi access point data is commercially sensitive information, and NCTA's members are troubled by the potential for disclosure or other misuse of their customers' Wi-Fi access point information for competitive purposes”). See also Report to Congress on Emergency 911 Access to Wi-Fi at 15, paragraph 35 (noting that “[t]he record reflects that the complex and competitive nature of today's communications ecosystem impacts 911 service over Wi-Fi access points and spectrum for unlicensed devices,” and noting that NCTA had stated that “ `[a]ll providers likely would need to agree to support every transmission and compression protocol, or all providers would need to agree on one standard' ”). We invite CMRS providers, Apple, and Google to provide a status update on their efforts to improve wireless 911 location accuracy using DBH. As noted above, live call data reports in the six ATIS test cities reflect that DBH is used for 80% of wireless 911 calls. We seek comment on whether there have been developments in DBH since 2022 that might impact the regulatory proposals in the FNPRM. Specifically, we seek comment on the status of DBH solutions ( i.e., ELS and HELO), whether individually or combined, and whether these technologies are improving dispatchable location. In addition, we seek comment on plans for using DBH and other technologies ( e.g., barometric pressure sensors) to help first responders and PSAPs find 911 callers in multi-story buildings. Confidence and Uncertainty. We seek updated comment on establishing confidence and uncertainty values associated with dispatchable location. In the Fifth FNPRM, the Commission sought input on how to account for uncertainty in dispatchable location data for a broad range of emerging solutions, whether we should extend confidence and uncertainty requirements to alternative dispatchable location mechanisms and, if so, what the required confidence and uncertainty percentage should be. 100 In the Sixth Report and Order, the Commission deferred consideration of this issue to a future proceeding but encouraged carriers, public safety organizations, and other interested parties to create standards for conveying uncertainty for dispatchable location in a manner that is more useful for first responders. 101 As an interim measure, the Commission revised § 9.10(j)(4) of the rules “to make explicit that when CMRS providers provide dispatchable location or floor level information in addition to z-axis information, they must provide confidence and uncertainty data for the z-axis location.” 102 Accordingly, we seek to refresh the record on the state of standards work for conveying confidence and uncertainty values associated with dispatchable location. 100 Fifth Report and Order, 34 FCC Rcd at 11625, paragraph 79. 101 Sixth Report and Order, 35 FCC Rcd at 7778, paragraph 61 (“Although several commenters suggest that confidence and uncertainty values could be developed for dispatchable location, the record indicates that no standard currently exists, and additional work is needed to develop a standardized approach. We therefore defer consideration of this issue to a future proceeding. We also encourage carriers, public safety organizations, and other interested parties to create standards for conveying uncertainty for dispatchable location in a manner that is more useful for first responders.”). 102 Id. at 7778, paragraph 62. D. Live Call Reporting and Enforcement 1. Live Call Data Reports We propose to modify our live call data reporting rules to require CMRS providers to report the specific technologies they use to provide dispatchable location with live 911 wireless calls and to report these data for each morphology. The reporting template for live call data currently requires providers to identify whether they provide dispatchable location with live 911 calls, but it does not require them to identify the specific technology (or combination of technologies) used to provide dispatchable location. 103 We believe that additional information would be helpful in evaluating the deployment of dispatchable location solutions. We propose to revise the rules to require information on the location technology or technologies used for each 911 call providing dispatchable location, such as Wi-Fi calling or femtocells. 104 This would make the reporting for live calls providing dispatchable location consistent with the reporting for live calls conveying geodetic z-axis information. 105 We additionally seek comment on whether we should require CMRS providers to provide data not only for each category of location technology used in live call reports ( e.g., DBH) but also for specific technologies within a category ( e.g., HELO, ELS). Would such requirements be more burdensome than beneficial? Would the annual reporting requirement discussed below be a more appropriate means of collecting this information? We seek comment on all of these issues. 103 See Public Safety and Homeland Security Bureau Provides Updated Guidance to CMRS Providers Regarding Reporting of 911 Live Call Data: Revised Template Provides for Reporting of Vertical Location Technology Used in Live 911 Calls, PS Docket No. 07-114, Public Notice, 36 FCC Rcd 9193, 9195, Appx. (PSHSB 2021) ( Template Public Notice ), https://www.fcc.gov/document/pshsb-provides-updated-template-911-live-call-data-reports. 104 Wi-Fi calling is a voice service that allows users to place and receive calls over a wireless internet connection, as opposed to using a cellular signal. See Apple, Make a call with Wi-Fi Calling (Dec. 8, 2023), https://support.apple.com/en-us/HT203032. A femtocell is a small, low-power cellular base station designed for use in a residence or small business. It connects to an internet service provider's network through broadband and, unlike Wi-Fi calling, operates on licensed frequency bands. In most cases, consumers must purchase a femtocell from their mobile network operator. See Hussain Kanchwala, What Is a Femtocell and What Does It Do? (Oct. 19, 2023, https://www.scienceabc.com/innovation/what-are-femtocells.html. 105 For example, for live calls delivering z-axis information, the reporting template requires providers to “enter each position technology or combination of technologies used to determine z-axis coordinates ( e.g., DBH, barometric sensor-based technology, etc.).” Template Public Notice, 36 FCC Rcd at 9195, Appx. (setting similar requirement for live calls delivering x/y-axis information). 2. Complaint Portal Our current rules provide that PSAPs may seek Commission enforcement of location accuracy requirements within their geographic service area, “but only so long as they have implemented policies that are designed to obtain all location information made available by CMRS providers when initiating and delivering 911 calls to the PSAP.” 106 In addition, prior to seeking Commission enforcement, “a PSAP must provide the CMRS provider with [30] days written notice, and the CMRS provider shall have an opportunity to address the issue informally. If the issue has not been addressed to the PSAP's satisfaction within 90 days, the PSAP may seek enforcement relief.” 107 106 See 47 CFR 9.10(i)(2)(iv). 107 See id. While the existing rules provide a mechanism for PSAPs and CMRS providers to resolve 911 location performance issues at the local level, we believe transparency and accountability would be enhanced by establishing a centralized clearinghouse for PSAPs to notify CMRS providers of complaints. The Commission established such a mechanism in the 800 MHz rebanding proceeding, requiring CMRS providers to establish and maintain an online portal for public safety to provide notice of interference complaints. 108 Notification in the 800 MHz portal also initiated the timeline for CMRS providers to address complaints before Commission enforcement action could be initiated. 109 We seek comment on whether we should require CMRS providers to establish a similar centralized, online complaint portal that PSAPs could use to report location accuracy problems to CMRS providers before seeking FCC enforcement. How should such a complaint portal function? For example, upon receipt of a complaint in the portal, should CMRS providers have a time limit for attempting to resolve it ( e.g., 90 days, as provided by existing rules)? What would be the costs associated with such a complaint mechanism? 108 See 800 MHz Interference Notification, Public Safety 800MHz Interference Notification Site, https://prod.publicsafety800mhzinterference.com/sign-in (last visited Feb. 4, 2025). 109 See 47 CFR 90.674. E. Improving Accuracy of Horizontal Location Information We seek to refresh the record on improving the accuracy of horizontal location accuracy information for wireless 911 calls. In January 2015, the Commission adopted horizontal location accuracy standards for 911 as part of the Fourth Report and Order. 110 In particular, the Commission required all CMRS providers to provide (1) dispatchable location, or (2) x/y location within 50 meters, for the following percentages of wireless 911 calls within the following timeframes, measured from the effective date of the rules adopted in the Fourth Report and Order: 110 Fourth Report and Order, 30 FCC Rcd 1259; 47 CFR 9.10(i)(2)(i). • Within 2 years: 40 percent of all wireless 911 calls. • Within 3 years: 50 percent of all wireless 911 calls. • Within 5 years: 70 percent of all wireless 911 calls. • Within 6 years: 80 percent of all wireless 911 calls. 111 111 Fourth Report and Order, 30 FCC Rcd at 1261, 1287, 1361, paragraphs 6, 74, Appx. D; 47 CFR 9.10(i)(2)(i). The rules allow non-nationwide CMRS providers (regional, small, and rural carriers) to extend the five- and six-year deadlines based on the timing of Voice over Long Term Evolution (VoLTE) deployment in their networks. 112 112 Fourth Report and Order, 30 FCC Rcd at 1261, 1287, 1361, paragraphs 6, 74, Appx. D; 47 CFR 9.10(i)(2)(i). The record in this proceeding underscores the importance of accurate and reliable horizontal location information for first responders and in particular the effect that inaccurate horizontal location can have on the accuracy of vertical location information. NENA has commented that vertical location accuracy and floor level estimations would benefit greatly from increased accuracy in the horizontal plane and that the Commission's existing rules for horizontal uncertainty “could easily place the caller on the right floor but in a building across the street.” Similarly, the International Association of Fire Chiefs (IAFC) has pointed out that “[w]hile a ± 50-meter horizontal metric may provide enough information for a PSAP to provide a dispatchable address, it can also lead to responders arriving at an incorrect building location.” And the Texas 9-1-1 Entities have stated that “the horizontal and vertical information must work together in order for public safety entities to be able to convert x-, y-, and z-axis information to the floor level of the correct building.” 113 113 Texas 9-1-1 Entities Comments, PS Docket No. 07-114, at 6 (rec. Feb. 21, 2020) (emphasis omitted); see also NextNav, LLC (NextNav) Comments, PS Docket No. 07-114, at 23 (rec. Feb. 21, 2020) (stating that “the preexisting requirement for 50 meter horizontal accuracy cannot guarantee that the information provided will always identify the correct building”); Environmental Systems Research Institute, Inc. (Esri) Reply, PS Docket No. 07-114, at 3 (rec. Mar. 20, 2020) (Esri Reply) (discussing the current limits of horizontal accuracy of 50 meters and stating that “[l]imited horizontal accuracy could not only result in improperly identifying the horizontal location of a caller, but—when coupled with less-than-accurate vertical information—could result in first responders reporting to the wrong building”). It has been a decade since the Commission's horizontal location accuracy rules were adopted, and location technologies have advanced considerably since 2015. We seek comment on what progress has been made since 2015 to develop and deploy technological solutions that provide more accurate horizontal location information for wireless calls to 911. What percentage of wireless 911 calls provide horizontal location information that is more accurate than the Commission's requirement, and how accurate is the information provided? What specific technologies are available to provide improved horizontal location accuracy? T-Mobile has noted the potential of DBH technology for providing more accurate horizontal location information. CTIA similarly has noted that device-based solutions such as Google's ELS and Apple's HELO “continue to emerge, and . . . earlier achieved more granular horizontal location for wireless 9-1-1 calls, particularly indoors.” What are the capabilities of DBH solutions such as ELS and HELO for improving horizontal location accuracy, and how widely available are these technologies? Are there other technologies besides DBH that could be used for improving horizontal location accuracy, either alone or in combination with DBH? Does the use of non-U.S. satellite signals ( e.g., signals from the European Union's Global Navigation Satellite System (GNSS), known as Galileo), in conjunction with the existing 911 system, improve indoor horizontal location accuracy? 114 Does the transition to Next Generation 911 have an impact on indoor horizontal location accuracy and, if so, what is that impact? 115 114 See, e.g., Wireless E911 Location Accuracy Requirements; AT&T Services, Inc. Request for Authorization and Waiver, PS Docket No. 07-114, Order, 35 FCC Rcd 8805 (2020). 115 See, e.g., 47 CFR part 9, subpart J; Facilitating Implementation of Next Generation 911 Services (NG911); Location-Based Routing for Wireless 911 Calls, PS Docket Nos. 21-479 and 18-64, Report and Order, FCC 24-78, 2024 WL 3507091 (July 19, 2024), 89 FR 78066 (Oct. 17, 2024), corrected by Erratum, 2024 WL 3507091 (Sept. 5, 2024) and Second Erratum, 2024 WL 3507091 (Oct. 1, 2024). If it is technically feasible to strengthen the horizontal location accuracy requirements, what changes do commenters recommend? Is a smaller radius than 50 meters feasible and, if so, what specific radius do commenters support? What percentage of wireless calls should be required to meet this level of accuracy and within what time frame? What testing and validation in the test bed should be required to demonstrate compliance with any new horizontal location accuracy requirements? Would the current testing and validation processes in the test bed need to be modified accordingly and, if so, how? Should there be separate requirements for non-nationwide providers and, if so, what should these requirements be? We also seek comment on the costs and benefits of any suggested changes to the existing horizontal location accuracy requirements. In addition, we seek comment on whether there are any other engineering or other issues that the Commission should consider with regard to improving horizontal location accuracy. F. Mobile Text Location Accuracy We seek to refresh the record on improving location accuracy for mobile texts. The Commission's 2014 Second Report and Order on text-to-911 required covered text providers, which include CMRS providers, to obtain location information sufficient to route text messages to the appropriate PSAP. 116 However, the Commission did not require text providers to convey additional location information to PSAPs at that time. The Commission also noted the possibility that Short Message Service (SMS) text-to-911 would be an interim solution and that CMRS providers might eventually seek to migrate customers away from SMS. 117 116 Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications; Framework for Next Generation 911 Deployment, PS Docket Nos. 11-153 and 10-255, Second Report and Order and Third Further Notice of Proposed Rulemaking, 29 FCC Rcd 9851, paragraph 10 (2014), 79 FR 55367 (Sept. 16, 2014) ( Text-to-911 Second Report and Order ), 79 FR 55413 (Sept. 16, 2014) ( Text-to-911 Third NPRM ), corrected by Erratum (PSHSB Aug. 22, 2014); see also 47 CFR 9.10(q)(10)(v). 117 Text-to-911 Second Report and Order, 29 FCC Rcd at 9867-68, paragraph 44; see also FCC, Interim Text to 9-1-1 Working Group: Co-chairs: Brian Daly, AT&T and Gregg Vanderheiden, TRACE (Sept. 14, 2012), https://docs.fcc.gov/public/attachments/DOC-316315A1.pdf (selecting SMS as the default texting solution because it was a standard-based solution and could be rapidly deployed to provide nationwide access to 911 during the transition to NG911). In the 2019 Report and Order implementing Kari's Law and RAY BAUM'S Act, the Commission noted that covered text providers, including CMRS providers, were starting to transition mobile wireless text services from SMS to more robust IP-enabled platforms, such as real-time text (RTT). 118 The Commission noted that these IP-enabled platforms were capable of providing location information with 911 texts using some of the same location methodologies that were used to support IP-based voice services. 119 In addition, the Commission noted the potential to use the DBH location capabilities of mobile handsets ( e.g., HELO and ELS) to generate location information, which could then be sent via text to the PSAP. 120 118 Kari's Law/RAY BAUM'S Act Report and Order, 34 FCC Rcd at 6690, paragraphs 217 through 218. 119 Id. at 6690, paragraph 218; see also AT&T Comments, PS Docket Nos. 18-261 and 17-239, at 11 (rec. Dec. 10, 2018) (AT&T KL/RBA Comments) (stating that because real-time text includes a voice component, it can access specific caller location updates—and deliver them to the PSAP); Verizon Comments, PS Docket Nos. 18-261 and 17-239, at 7 (rec. Dec. 10, 2018) (Verizon KL/RBA Comments) (“The transition to IP-enabled LTE networks, and global text telephony (GTT) ( i.e., real-time text or [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/fr%3A2025-06865. Public record. Not legal advice.