December 15, 2014 Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: PS Docket No. 07Ͳ114, Wireless E9Ͳ1Ͳ1 Location Accuracy Requirements Dear Ms. Dortch: The Congressional Fire Services Institute and the International Association of Fire Fighters respectfully submit comments in response to the Federal Communication Commission’s November 20, 2014 Public Notice seeking comment on the voluntary roadmap submitted by the Association of PublicͲSafety Communications Officials International, the National Emergency Number Association, and representatives of the Cellular Telephone Industry Association. As we have indicated in previous filings, CFSI and the IAFF support the Commission’s current proposal to improve wireless location accuracy. We do not find anything in the roadmap to change our support for the rules as proposed, and again urge the Commission to quickly proceed with their adoption. Of greatest concern, the roadmap fails to include any measurable or enforceable results for either improving indoor location accuracy or for the delivery of “dispatchable address.” The Commission’s proposal contains technologyͲneutral accuracy measurements for indoor location within reasonable timeframes and validated through independent testbeds. It allows the carriers total flexibility in the technology choices they make, provided they demonstrate minimum accuracy achievement. The measurement targets presented in the roadmap, however, are of almost no value in evaluating indoor location and dispatchable address performance, since they blend indoor results with those from outdoor 9Ͳ1Ͳ1, which factually has very high yield and accuracy. Furthermore, the majority of the technologies proposed in the roadmap lack measurable, realͲworld testing results and require adoption by thirdͲparties. Even if affirmative testing results were forthcoming, neither the Commission nor the carriers have the authority to compel the private sector or individual consumers to adopt such technologies, resulting in highly variable coverage. Lastly, the roadmap also lacks any meaningful implementation of vertical location capability. The significance of rapid delivery of location information, including vertical, should not be undervalued or underestimated. In July, IAFF Local 798, the San Francisco Fire Department, and the City of San Francisco Department of Emergency Management Division of Emergency Communications conducted realͲworld dispatch tests in multistory urban structures. These tests provided a clear and measurable validation of the Commission's conclusion that dispatch with vertical location information significantly improves emergency response. The time difference between an emergency dispatch to a precise location versus an indefinite search area is enormous, and too often may be the difference between life and death. Our tests clearly indicate that vertical location alone can provide a substantial improvement in search effectiveness in multistory structures, even without a floor number or a dispatchable address. The roadmap’s intention to simply study unͲcalibrated barometric pressure sensors over the next three years is unacceptable, particularly given the widespread and inexpensive availability of barometric pressure sensors in existing smartphones and the proven altitude accuracy achievable through ambient weather calibration. In conclusion, we strongly disagree that the carriers’ roadmap can be used as a replacement for the proposed rules, although we believe it is a worthy voluntary effort that should be encouraged and elements incorporated once positive performance has been demonstrated. Adoption of the roadmap would delay measurable improvements in 911 location accuracy, placing emergency responders, as well as the public, at risk. The Commission’s proposed rules have been subject to robust comment and have been nearly unanimously lauded by the public safety community. We again urge the Commission to reject the carriers’ proposal and proceed expeditiously with its proposed rules. Thank you for your attention to this critical public safety matter and your continued commitment to improving the communications needs of our nation’s frontline emergency responders. Sincerely, $ Dr. William F. Jenaway President Congressional Fire Services Institute Harold A. Schaitberger General President International Association of Fire Fighters