Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of: Wireless E911 Location Accuracy Requirements ) ) ) ) PS Docket No. 07-114 ) ) ) COMMENTS OF MOTOROLA MOBILITY LLC Motorola Mobility LLC (“Motorola Mobility”) hereby responds to the Commission’s Public Notice seeking comment on the location accuracy “Roadmap” submitted by the Association of Public-Safety Communications Officers (“APCO”), the National Emergency Numbering Association (“NENA”), AT&T, Sprint, T-Mobile USA, and Verizon Wireless.1 Motorola Mobility supports the Roadmap, which sets out aggressive, but achievable, benchmarks that will drive location technology development and bring substantial improvement to 911 location performance—consistent with the themes of comments received in response to the Commission’s Location Accuracy Third Further Notice.2 To realize the benefits of the Roadmap, however, all stakeholders—including carriers, public safety, and manufacturers— must be fully involved in the development, testing, and implementation of new location technologies. 1 Public Safety and Homeland Security Bureau Seeks Comment in the E911 Location Accuracy Proceeding on the Location Accuracy “Roadmap” Submitted by APCO, NENA, and the Four National Wireless Carriers, PS Docket No. 07-114, Public Notice, DA 14-1680 (rel. Nov. 20, 2014) (“Public Notice”); see also “Roadmap for Improving E911 Location Accuracy” (“Roadmap”) attached to Letter from APCO, NENA, AT&T Mobility, Sprint, T-Mobile USA, and Verizon to Marlene H. Dortch, PS Docket No. 07-114 (Nov. 18, 2014). 2 Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114, Third Further Notice of Proposed Rulemaking, 29 FCC Rcd 2374 (2014) (“Location Accuracy Third Further Notice”). Motorola Mobility supports efforts to improve the reliability and accuracy of automatic location information for all wireless 911 calls. In addition to incorporating advanced location technologies into its own devices, Motorola Mobility has participated actively on the Commission’s Communications Security, Reliability, and Interoperability Councils (“CSRICs”), including CSRIC III Working Group 3, which conducted the Indoor Location Accuracy Test Bed, and CSRIC IV Working Group 1, which examined location accuracy and testing for Voiceover-LTE networks (“VoLTE”). As Motorola Mobility has explained previously, the work of the CSRIC has “underscored that the technologies essential to supporting accurate indoor location information are only in the early stages of development.”3 Motorola Mobility further stressed that any new 911 location accuracy obligations should incorporate realistic deadlines developed based on solid evidence about the feasibility and availability of indoor location technologies, collected through comprehensive real-world testing.4 The Roadmap is the product of positive collaboration between the public and private sectors and further evidences the wireless industry’s commitment to leveraging new technologies to provide first responders with a “dispatchable location” for 911 calls placed indoors. The Roadmap sets clear, aggressive benchmarks for all wireless calls, including calls delivered utilizing VoLTE technology that will translate into real improvements in 911 location accuracy and the effectiveness of public safety response.5 Significantly, the Roadmap includes language endorsed by the signatories for inclusion in the Commission’s rules,6 making the carriers’ 3 Comments of Motorola Mobility LLC at 2, PS Docket No. 07-114 (filed May 12, 2014) (“Motorola Mobility Comments”). 4 Id., 2-3. 5 See Roadmap at 7-8. 6 Id. at 13. 2 commitments enforceable. Motorola Mobility supports the implementation of the Roadmap, which will be invaluable to achieving the Commission’s objective of ensuring “delivery of more timely, accurate, and actionable location information for all 911 calls.”7 The Roadmap identifies and responds to the need for further technology development in the area of indoor location accuracy, as highlighted by various industry commenters in response to the Third Further Notice.8 For example, the Roadmap correctly articulates the need for separate work streams on implementation solutions for providing a dispatchable location, improvement of horizontal location information, and development of basic standards for delivery and use of vertical location information.9 The record in this proceeding demonstrates “that delivering vertical location information presents unique challenges that are far different from those associated with providing horizontal information, and the technology development necessary to overcome these challenges is still in the early phases.”10 As such, the Roadmap correctly prioritizes delivery of dispatchable location data while also emphasizing longer-term development of standards and feasible candidate technologies for delivering vertical location information. The Roadmap contemplates the creation of a test bed to “facilitate the testing of 9-1-1 location technologies,” which “will be operated in a technology neutral manner.”11 Motorola 7 Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114, Third Further Notice of Proposed Rulemaking, 29 FCC Rcd 2374, ¶ 4 (2014) (“Location Accuracy Third Further Notice”). 8 See Reply Comments of Motorola Mobility LLC at 3, PS Docket No. 07-114 (filed July 14, 2014) (“Motorola Mobility Reply Comments”). 9 Roadmap at 4-7, 10. 10 Motorola Mobility Reply Comments at 9. See also id., 13-14, Appendix 1; Comments of T-Mobile USA, Inc. at 13-14, PS Docket No. 07-114 (filed May 12, 2014). 11 Roadmap at 3. 3 Mobility agrees that comprehensive testing of location accuracy technologies is critical to identifying technologies that may be deployed in the field for E911 use. Indeed, Motorola Mobility endorsed further testing prior to the adoption of any new location accuracy obligations, to ensure that decision-making is based on reliable results about the latest technology.12 For example, the CSRIC III test bed exemplified “effective multi-stakeholder cooperation between wireless operators, equipment manufacturers, location technology providers, and public safety, which leveraged commercial standards to develop a reproducible process that delivered comprehensive and unbiased results.”13 By linking implementation of new obligations to certification of technologies through a similar multi-stakeholder test bed process, the Roadmap should ensure that network operators are able to adopt location solutions that best meet the needs of public safety and consumers who public safety seeks to protect. The Roadmap suggests that the next test bed should be managed by a non-governmental entity, such as the Alliance for Telecommunications Industry Solutions (“ATIS”).14 Although CSRIC-supervised testing also is an option,15 Motorola Mobility supports the testing approach outlined in the Roadmap, so long as any test bed is designed and executed in an open process enabling full participation by manufacturers, in addition to carriers and other affected parties. As Motorola Mobility has previously explained, an effective E911 location solution requires that any new technology not only be accurate but also be commercially available and viable for inclusion in consumer devices and networks.16 To this end, the Roadmap correctly recognizes 12 Motorola Mobility Comments at 4-6. 13 Id. at 4, 6. 14 Roadmap at 3. 15 Motorola Mobility Comments at 4. 16 Id. at 6-12. 4 that handset design and development will be a key component to deploying enhanced location accuracy.17 Therefore, test procedures and device prototypes being tested need to be practically realizable in handsets. The manufacturing community must be actively included not only in technology development, but also in all phases of test bed implementation. In the past, such participation has proven beneficial as it was due to manufacturer involvement in the CSRIC III test bed that unrealistic assumptions about antenna gain were corrected and test procedures were modified to eliminate background processes that add excessive current drain. In conclusion, Motorola Mobility supports the Roadmap, which evidences a continued industry-public safety partnership in mutual service of the public interest. Adoption of the Roadmap would result in challenging but achievable commitments to technology development and solutions deployment that would benefit the public. While substantial work remains to be done, the Roadmap represents an important step in realizing the benefits of improved reliability and accuracy of automatic location information for all wireless 911 calls. Respectfully submitted, /s/ Charles Eger Charles Eger Senior Director, Global Regulatory and Issue Management Motorola Mobility LLC 1455 Pennsylvania Ave., N.W. Suite 400 Washington, D.C. 20004 December 15, 2014 17 Roadmap at 5. 5