Federal Communications Commission "FCC XX-XXX" STATEMENT OF COMMISSIONER MICHAEL O’RIELLY Re: Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114. This is the sixth z-axis-related item that I have voted on since joining the Commission. I apologize in advance to those who may experience a bit of déjà vu as you hear my words today. In all seriousness, I continue to be fully supportive of our ultimate goal: providing first responders the pin-point location information they need to find and provide aid to Americans in peril. These professionals are there to assist us in the worst of times, when every second counts, and the location data provided to them is crucial, especially in urban centers. From manufacturers and wireless providers to fire departments and localities, to all of the associations representing the various interested parties, there is a common goal to develop a solution to provide the best information as quickly as possible. But, ultimately, the location provided must absolutely be correct and reliable if we are going to reach this goal. While equipment and wireless providers are making great strides with z-axis technologies, the technology still is not commercially deployed and proven. Promising results have been achieved in a test bed environment, but there are no real-world operations yet. And while meeting deadlines and benchmarks is still a work in progress, nonetheless, today we double down and require z-axis nationwide availability by 2025, as if the ultimate remedy requires just one more mandate. We now have wireless providers and manufacturers expressing concerns about the direction in which we are headed. We cannot just dismiss the merits of their arguments by attacking their motives or hiding behind Commission procedure. These are the very companies that we are going to rely on to make this technology work, and they seem to have serious doubts. The handset-based solutions that will facilitate nationwide deployment are currently less accurate than the network-based systems this Commission has been considering for years. I am concerned that the Phase II history is repeating itself, heading us towards a deluge of waivers. And, the handset-based technology may not be ready in time to meet the earliest deadlines, forcing providers to switch z-axis solutions midstream. That seems neither effective nor cost-efficient, and we know who will end up paying for this: the American consumer. One way or another, these costs will be passed on in the form of higher bills or reduced functionality. And, of course, our cost-benefit analysis never considered such duplication of efforts. In fact, the CBA relies on the same old, tired, and inaccurate analysis we have used for years. Thankfully, today’s item does provide more flexibility, such as allowing providers to comply by deploying z-axis technology on handsets, covering 80 percent of a Cellular Market Area’s multi-story buildings, and providing dispatchable location – which is still the ultimate goal – without the National Emergency Address Database, or NEAD. Further, I am pleased that we have withheld from making other premature rule changes. The goal should be to get what is already required actually working and helping people before shifting the goalposts any further. I approve, with the same reservations I have had since 2014. 2