1STATEMENT OF 
COMMISSIONER MIGNON L. CLYBURN
Re: Location-Based Routing For Wireless 911 Calls, PS Docket No. 18-64.
Any delay in 911 call response time can mean the difference between life and death.  When seeking 
the assistance of first responders, no explanation for delay could ever bring comfort to a victim’s family or 
friends.  There is little wonder why many ask, “if Uber and Lyft can locate me within seconds, then why is it 
so difficult for police and other public safety officials?”  Of the 80 percent of the 240 million mobile phone 
calls to 911 each year, it is estimated that as many as 10,000 lives could be saved each year, if the 911 
emergency dispatching system were able to reach callers just one minute faster. 
One way to speed up response times, is to integrate new location technologies into our emergency 
communications networks.  In order for location-based routing to be effective in delivering the 911 call to 
the appropriate PSAP, or Public Safety Answering Point, the location needs to be calculated in five seconds 
or less, with a fairly high degree of accuracy.  
Legacy location technologies such as GPS, are not capable of providing a location determination 
within five seconds.  Twenty to 30 seconds is more likely.  As a result, wireless 911 calls continue to be 
routed based on cell tower location, because the tower location is known immediately.  That means the call 
is more likely to be routed to the PSAP nearest the cell tower, instead of the one nearest to the actual 
location of the emergency.
Fortunately, a report that the Communications Security, Reliability, and Interoperability Council 
(CSRIC) issued in September 2016, found that new technologies may be able to provide more precise 
location data, than the tower location within the necessary five-second window.  It is my hope that today’s 
Notice of Inquiry (NOI) will incentivize the public safety, commercial communications, and technology 
communities to work together and help us, to expeditiously develop a solution.  Time is of the essence.  
My thanks to the Public Safety & Homeland Security Bureau for this truly important work.