Federal Communications Commission	FCC 19-20


STATEMENT OF
COMMISSIONER GEOFFREY STARKS

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

We depend on the 911 system sending help when and where we need it.  That call is made thousands of times every day throughout the country, and we all rely on help being just three digits away.  The first responders who answer the calls are lifesavers – in the truest sense.  We owe them our gratitude and I thank them for everything they do.  The same goes for the people who answer our 911 calls.  They are highly-trained specialists who spend their days connecting people like you and me with help on our worst days.
Imagine someone in a skyscraper calling 911.  First responders rush to help.  They arrive at the building within minutes, but they are two floors below.  They are ready and equipped, and close – but not close enough.  It is essential that help arrives in the right place, and on the right floor.
Ensuring that first responders know what floor to go to when callers make indoor 911 calls within multistory buildings is no easy task.  This FNPRM gets us one step closer to incorporating this capability into the nation’s 911 system and I support that goal.  There are things in this FNPRM that I support – primarily getting z-axis location accuracy requirements off of the drawing board, out of the test environment, and into first-responder’s tool kits so it can start to save lives.  But let me be clear – I don’t see this FNPRM providing the final element of the Commission’s indoor location accuracy regime. 
The wireless industry has worked hard to provide vertical location or “z-axis” capability, which is the ability of wireless networks to locate handsets within a few feet of their actual vertical location.  Increasing vertical location accuracy will give first responders the tools they will need to find you on the right floor if you call for help in a tall building.  But people need solutions that get help to them.  Not close to them – but directly to them.    
While a 3-meter z-axis metric, as this FNPRM proposes, will get first responders close, it still leaves about a 10-foot margin of error, which can send first responders to the floor above or below you.  I’m concurring in part because this FNPRM does not set out a clear path or propose a plan to get to a greater level of accuracy than 3-meters.  Only floor level accuracy will give first responders the right tools to go to the right floor, the first time, every time.  We need a plan to get there and that plan has to get it done as quickly as possible.  The days where first responders don’t know what floor of a tall building a call for help is coming from must become history.  
I had several other concerns about this FNPRM, as it was originally drafted.  The first is whether the vertical location technology described in the FNPRM will work for consumers who use the Commission’s Lifeline program.  The FNPRM describes barometric pressure sensor technology, used in most higher-end mobile handsets manufactured since 2016, that can provide information about the handset’s altitude.  
This technology can be lifesaving if your phone has it.  But, do Lifeline phones have it?  The lifesaving technology we are asking about in this FNPRM needs to be available to everyone everywhere.  911’s most advanced features can’t have an asterisk that says: “this won’t save you if you use Lifeline.”  The FNPRM before us includes questions that I called for about this concern.
My other concern has to with data privacy and security.  The rules on which this FNPRM seeks comment allow carriers to comply with vertical location accuracy requirements in two ways, through z-axis technology, as this FNPRM addresses, or through delivery of “dispatchable location information” which is essentially the caller’s address and floor or suite number if they are in a tall building.  Carriers have developed technology to obtain dispatchable location information using wireless networks that users’ phones connect to when a 911 call is made.  
Recognizing the high degree of location accuracy that this technology delivers, however, the Commission adopted rules specifically limiting use of data from the National Emergency Address Database, or NEAD, to 911 calls.  The Commission also required industry to develop a privacy and security plan for this data.
I’m glad that this FNPRM now asks important questions about the appropriate treatment of similarly situated z-axis data and whether rules like those the Commission adopted for NEAD data should apply.  We need to build protections in to make sure that consumer’s sensitive location data is not misused, like we have been reading about in the news.  I appreciate my colleagues agreeing with me that these questions should be included.  
We all hope never to need to call 911 for our loved ones or ourselves.  But we know it happens.  And when a 911 call comes from inside a tall building, first responders need to know what floor to go to.  Today’s FNPRM moves us closer to making that a reality.  
I’d like to thank the dedicated staff of PSHSB for your tireless work on this issue and on this FNPRM.  You are helping to save lives.

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