On March 28, 2025, the FCC released a Sixth Further Notice of Proposed Rulemaking (FNPRM) seeking comment on proposals aimed at enhancing emergency response capabilities by refining vertical (z-axis) location data provided with 911 calls, and through other updates to the FCC’s 911 location accuracy rules. The FNPRM was adopted at the March Open Meeting.
The FNPRM seeks comment on the following proposals:
- Enhancing Z-Axis Location Accuracy:
- Proposes to require wireless carriers that deploy z-axis technology to deliver z-axis location to PSAPs measured in Height Above Ground Level (AGL) instead of Height Above Ellipsoid (HAE) for more actionable vertical location data.
- Proposes to require the provision of floor level estimates to improve first responders’ ability to locate callers in multi-story buildings.
- Proposes 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 the final rules and to require non-nationwide CMRS providers to deliver AGL within 24 months.
- Improving Wireless 911 Location Accuracy Testing and Compliance:
- Proposes 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: dense urban, urban, suburban, and rural environments.
- Proposes to expand access to test data for non-nationwide CMRS providers and public safety organizations like APCO and NENA upon request.
- Proposes to introduce a challenge process allowing public safety groups to contest test results.
- Proposes to require that nationwide CMRS providers deploy either dispatchable location or validated z-axis technology nationwide within 24 months of the rule’s effective date, while non-nationwide providers would have an additional 12 months to comply within their network footprint.
- Increasing Dispatchable Location Data:
- Seeks comment ways to provide validated street addresses with room and apartment numbers instead of only coordinate-based (x/y/z) data.
- Seeks comment on ways to increase the percentage of 911 calls delivering dispatchable location information.
- Seeks to refresh the record on the current state of dispatchable location solutions and initiatives to develop new and enhanced solutions.
- Live Call Reporting and Enforcement:
- Proposes to require CMRS providers to include more details in live call data reports, such as the technologies used for dispatchable location.
- Explores the creation of a centralized online complaint portal for 911 authorities to report location accuracy problems.
- Enhancing Horizontal Location Accuracy and Text-to-911 Services:
- Seeks comment on ways to improve x/y location accuracy for 911 calls.
- Seeks comment on ways to improve location accuracy for text-to-911, which currently lacks precise location data.
- Eliminating Outdated Rules:
- Seeks comment on removing legacy E911 Phase II rules, which have been replaced by more advanced location accuracy requirements.
- Seeks comment on whether to eliminate obsolete reporting and compliance requirements that no longer align with current 911 technology and operational needs.
- Proposes to review and streamline outdated regulatory obligations to reduce unnecessary burdens on wireless providers while maintaining public safety standards.
The following notable changes were made from the draft item:
- ¶ 16 – The FCC added a request for comment on how Public Safety Answering Points (PSAPs) currently use vertical 911 location information and to what extent they use National Emergency Number Association (NENA) 3D location guidelines.
- ¶¶ 21-22 – The FCC added requests for comment on (1) whether conversion from Height Above Ellipsoid (HAE) to Height Above Ground Level (AGL) would introduce location accuracy errors, and (2) whether there are existing technical standards to address these potential errors, and if not, would they need to be developed.
- ¶ 33 – The FCC clarified that it is asking about both the “number or” percentage of total 911 test calls required for validation of a technology.
- ¶ 34 – The FCC added questions about additional standardization and testing requirements.
- ¶ 34 – The FCC added a request for comment on how its rules can balance safeguarding test bed data for non-nationwide CMRS providers and public safety stakeholders while also promoting transparency.
- ¶ 53 – The FCC added several questions about whether “CMRS providers, cable companies, ISPs, device manufacturers, and operating system providers have a role to play in improving location information for 911.”
- ¶ 63 – The FCC added request for comment on which testing and validation procedures should be required to ensure compliance with any new horizontal location accuracy requirements.
Comments are due 30 days after publication in the Federal Register, and reply comments are due 60 days after publication.
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