Before the
Federal Communications Commission
Washington, DC 20554

In The Matter Of
Wireless E911 Location Accuracy Requirements

)
)
) PS Docket No. 07-114
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)

COMMENTS OF INTRADO
Intrado Inc. and Intrado Communications Inc. (together, “Intrado”) respectfully submit
the following comments in connection with Public Notice DA 14-1680 released November 20,
2014 by the Federal Communications Commission (“FCC” or “Commission”). 1
Intrado commends the Commission for encouraging voluntary industry solutions that
would make the wireless user community and the general public safer through improvements to
location accuracy.2 The recently released “Roadmap”3 is the direct result of the Commission’s
request that stakeholders work on a consensus approach to improving wireless location
accuracy.4
The Roadmap holds the promise of facilitating what stakeholders, as well as the
Commission, agree is the best result for public safety: “. . . the delivery of a dispatchable

1

P.S. Docket No. 07-114, 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, Released November 20, 2014.
2

Wireless E911 Location Accuracy Requirements, Third Further Notice of Proposed Rulemaking, 29 FCC Rcd
2374, ¶ 6 (“NPRM”) (“[W]e encourage industry public safety entities, and other stakeholders to work
collaboratively to develop alternative proposals for our consideration.); id.¶ 26 (“[W]e invite relevant stakeholders –
including public safety and industry – to propose a consensus approach”).
3

APCO, NENA, Carrier Cover Letter Roadmap for Improving E911 Location Accuracy filed 11/18/2014
http://apps.fcc.gov/ecfs/document/view?id=60000986637
4

NPRM ¶ 26.

1

 address.”5 To introduce wireless carrier-delivered, dispatchable addresses to the public safety
lexicon, the Roadmap encompasses a bold new paradigm: “indoor” (address) and “outdoor” (X
and Y coordinates) locations. It does so, in part, because even the best outdoor technologies
currently available, when applied to indoor location, can only provide a 50-meter search radius.
For most urban environments, this represents one or more multi-story buildings on a city block,
and for indoor location, this is not acceptable, particularly in the long term.
By adopting a technology-neutral approach that encourages carriers to leverage existing
commercial location-based service technologies, the Roadmap will facilitate real improvements
in the delivery of useable emergency location information for both indoor and outdoor wireless
911 calls. Yet, the Roadmap does not abandon efforts to continue improving location solutions
based on the use of x, y coordinates. In combination these initiatives render criticism of the
Roadmap, at a minimum, premature.
The Roadmap identifies concrete initiatives that will be undertaken to promote improved
location accuracy using such technologies. This includes near-term deadlines to improve
location accuracy for both outdoor and indoor calls while dispatchable location solutions are
being developed, as well as longer term initiatives that will be implemented if dispatchable
location solutions do not develop as quickly as expected or desired. The Roadmap identifies
enforceable metrics that wireless service providers must satisfy regardless of whether or not
these particular initiatives - or the specific technologies identified for use - prove fruitful.
Finally, the Roadmap goes beyond a voluntary agreement among the carriers and public safety,
and asks the Commission to codify certain of its provisions in order to provide greater assurance
that the objectives of the Roadmap will be met.

5

NPRM ¶ 117.

2

 As significant as the Roadmap is, it could not detail every technical or process issue and
work remains for all parties.6 For example, public safety, carriers and the vendor community
need to reach consensus on address validation, and an appropriate dispatchable address standard
for fixed-location wireless customers is needed. Important dialogs with cable / broadband, the
alarm industry and other in-home technology providers could be initiated as a way to increase
the density of indoor beacon technology (e.g., a beacon in cable TV boxes or smoke alarms).
Exploration of new and novel “crowd sourcing” location techniques should be encouraged.
Approaches to vertical (Z-axis) information need to be explored including, but not limited to, use
of barometric pressure (as identified in the Roadmap).
Intrado believes that the Roadmap is what it professes to be: a realistic, effective,
sustainable, initial framework that lays the foundation for continuous improvement of 911
location accuracy. Intrado looks forward to working with the Commission, the public safety and
carrier communities and other stakeholders to implement the Roadmap and further advance 911
location technology and services.

December 15, 2014

Respectfully submitted,
Intrado Inc. and Intrado Communications Inc.

/s/ Craig W. Donaldson
Craig W. Donaldson
Senior Vice President
Regulatory & Government Affairs
1601 Dry Creek Drive
Longmont, CO 80503
720-494-5800

6

Workgroups have already been announced to continue the evolution of the Roadmap.

3