No Objections Voiced at FCC So Far on Location-Based Routing NPRM

All has been quiet on the FCC’s proposed NPRM on location based routing (LBR) to public safety points, set for a vote Wednesday (see 2211300072). Industry officials said they expect the FCC to approve the NPRM largely as circulated by Chairwoman Jessica Rosenworcel, especially since there has been no lobbying.

Carriers are waiting to weigh in as part of the comment cycle and will have more to say then, said a lawyer with carrier clients. Major wireless and public safety groups declined to comment before the commissioner vote. All four commissioners voted to approve an LBR record refresh in June (see 2206080040). The FCC earlier sought comment in a 2018 notice of inquiry (see 1806290047).

“Nationwide implementation of location-based routing will significantly reduce misrouted 911 calls and texts and the delays associated with transferring misrouted 911 calls and texts from one PSAP to another,” says the draft NPRM: “For the millions of wireless 911 callers seeking emergency assistance each year, improving call routing will reduce emergency response times and save lives.” The NPRM notes the nation’s three largest carriers, AT&T, T-Mobile, and Verizon, “now indicate that they have deployed or plan to deploy location-based routing to varying extents on their networks.”

The NPRM proposes requiring carriers to “deploy technology that supports location-based routing on their Internet Protocol (IP)-based networks (i.e., 4G, 5G, and subsequent generations of IP-based networks)” and to “use location-based routing to route all 911 voice calls originating on their IP-based networks when caller location information available during origination of the 911 call meets certain requirements for accuracy and timeliness.” The NPRM proposes similar requirements for texts to 911. It also proposes “baseline requirements with respect to the accuracy and timeliness of location information” used for LBR.

In comments on the record refresh, public safety groups urged the FCC to push for more use of LBR (see 2207120065). T-Mobile said industry should address the issue voluntarily without the need for new FCC rules. AT&T and T-Mobile said implementation must be done carefully and will take time.

Comments filed “indicate that nationwide location-based routing is now feasible and has the potential to provide significant public safety benefits by reducing the number of misrouted calls to 911,” the draft said: “Commenters confirm that continued reliance on cell tower-based routing results in a considerable number of 911 calls being misrouted and that this is a significant problem for public safety.”

The draft notes that by one estimate “nationwide implementation of location-based routing would reduce misrouted wireless 911 calls by 85% from 23 million to 3.45 million per year” and “other commenters agree that implementation of location-based routing can significantly mitigate misroutes and, as a result, save lives and property.” It says that as of July “T-Mobile was offering location-based routing to 770 PSAPs, while AT&T has implemented location-based routing throughout its network and is using it to deliver 911 calls and texts to nearly all PSAPs nationwide.”