Federal Communications Commission	"FCC  XX-XXX"


STATEMENT OF
COMMISSIONER MICHAEL O’RIELLY

Re: 	Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114.

The Commission’s location accuracy rules require wireless providers to deploy either dispatchable addresses or z-axis metric solutions so that first responders have the best information possible to find a person in need within a multi-story building.  Throughout this proceeding, I have expressed that our vertical location accuracy requirements must be based on proven technologies, that deadlines must be realistic, and that our rules must be technology neutral.  Today’s notice proposes a z-axis approach that looks to strike that right balance.

While the wireless industry initially advocated for a five-meter z-axis metric, it recognized that the public safety community was not in agreement and, to provide certainty, is willing to test a three-meter metric in the established test bed.  Currently, two vendors appear capable of providing vertical location accuracy results within three meters in some scenarios with a consistency that would comply with our rules.  Early test bed results, however, do not support a two-meter z-axis metric, which was supported by some in the record.  I plan on following this issue closely and will want to see that there is solid evidence to ensure that the metric the Commission eventually picks is feasible in the applicable timeframes. 

Further, I applaud the efforts of the wireless industry to perfect technologies capable of providing accurate vertical location.  Besides z-axis technologies, the industry continues to work on the database to make dispatchable location—or providing an address along with floor, apartment or suite number—a reality.  Device manufacturers are also working on technologies to provide accurate location information.  I reiterate my firm belief that we must promote technological neutrality and that wireless providers should have a choice of solutions and vendors that they can utilize to meet our rules.

In light of recent press reports, I will also restate my concern that location accuracy information should not be used in any way to infringe on the rights of American citizens.  This location accuracy proceeding is about providing first responders with life-saving information, not a vehicle to aggregate location information that can be provided to others.  This data should not be made available for use by government agencies to locate, monitor, or take actions that are harmful to Americans.  
  
Finally, I appreciate the questions added by the new Office of Economics and Analytics to facilitate a more thorough cost-benefit analysis.  I am very pleased that, although there is discussion of the Commission’s past use of the flawed value of a statistical life standard, the item seeks to elicit data on the various z-axis options presented in the record so that we can do an appropriate cost-benefit analysis to inform the Commission’s decision making.

I approve.

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