Small Carriers Warn of Costs, Timing Concerns on Location-Based Routing Mandate
Groups representing small carriers warned of timing problems and financial hardships for their members from proposed rules to more precisely route wireless 911 calls and texts to public safety answering points through location-based routing (LBR), in comments on an NPRM commissioners approved 4-0 in December (see 2212210047). But public safety groups urged the FCC to act as soon as possible. The commission proposed to require nationwide providers to deploy LBR within six months from the effective date of final rules, while smaller carriers would get 18 months.
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Chairwoman Jessica Rosenworcel said in December that as many as 23 million wireless calls per year may be routed to the wrong PSAP using legacy 911 systems. “We can fix this, and we should,” she said.
The proposed requirements will be “extremely expensive and time consuming for small wireless carriers,” the Rural Wireless Association said in proceeding 18-64. The NPRM projects the implementation costs at $366,600 per provider for labor alone, RWA said: “While such a cost may be relatively easily absorbed by a Verizon or T-Mobile, it would be the equivalent of a financial earthquake” for RWA members. Smaller carriers “have customer bases that are less than 10,000 rather than north of 100 million, and therefore cannot pass on such costs to their customers without causing financial hardship to the rural customers they serve.”
The Competitive Carriers Association said the 18 months proposed isn’t enough time for smaller carriers. CCA noted the largest providers took four years to get ready to start LBR. An LBR mandate would require “a carefully orchestrated series of changes that affects the wireless carriers’ device inventory, transport networks, and several aspects of the core network systems,” CCA said. “With unlimited time and money,” carriers can eventually deploy LBR to any PSAP, the group said: “The problem is that location-based routing will be economically and practically infeasible in the eighteen months that the Commission proposes to allow for wireless carriers to implement it.”
“Rather than imposing rigid rules, Commission policy should provide flexibility for wireless providers to implement LBR in the manner that meets their unique network and handset configurations and is coordinated with public safety,” CTIA said. The group agreed with arguments about giving small carriers more time: “The nationwide wireless providers have already deployed or are actively working to deploy LBR on their networks. … The Commission has consistently provided non-nationwide providers with more time than nationwide wireless providers to meet 9-1-1 obligations, and it should do so here.”
APCO urged a mandate rather than voluntary agreements to implement LBR. Proposed timelines are “acceptable,” though shorter would be better because “some service providers are already providing location-based routing for voice calls and texts,” APCO said. For non-nationwide providers, “APCO would prefer alignment with the nationwide providers’ timeframe, rather than granting an additional year for compliance, unless the record demonstrates that additional time is warranted.”
APCO urged adoption of accuracy metrics and said it's open-minded on what metric to adopt “so long as it strikes an appropriate balance between how often the device’s location will be known quickly and accurately enough to use location-based routing rather than cell-sector based routing, and how effective the use of location-based routing will be at delivering the call.”
The National Emergency Number Association “strongly supports” requiring carriers to implement LBR. “Providers have demonstrated in their own arguments that their location-based routing systems are technically feasible and are voluntarily operating today,” NENA said: “The Commission has proposed sufficient compromises to avoid undue burden on the wireless industry, such as a later implementation date for non-nationwide … providers.”
Major carriers said they're already moving forward on LBR. T-Mobile said it implemented LBR in 2020. “However, the technologies used to provide the service are continuing to evolve,” the carrier said, noting the continuing work of groups like ATIS’ Emergency Services Interconnection Forum. “It is prudent to allow LBR to continue to mature before considering specific metrics or mandates,” T-Mobile said.
AT&T noted it completed rollout of LBR on its network in June and uses it to deliver 911 calls and texts “to nearly all PSAPs nationwide.” Rules should be “flexible and forward-looking” and “leverage existing resources, including ongoing standards processes and existing databases -- to make the transition to location-based routing as smooth and efficient as possible," AT&T said.
Verizon expects to have LBR available for requesting PSAPs starting at the end of March. “The time it takes between a PSAP’s request for LBR, and its use in live 911 calls, will depend on several factors,” Verizon noted: “These include the availability of accurate PSAP jurisdictional shape files and the number of sites within the PSAP’s boundary that need to be enabled with LBR. … Instead of a blanket flash-cut nationwide implementation deadline, implementation should be based on PSAP requests, with a compliance date of at least 6 months after the … request and subject to mutually agreed-to alternative timetables.”