FCC Seeks Feasibility of Location-Based Routing of Wireless 911 Calls

By: Andrew Regitsky

With today’s technology, when Americans make a 911 call over a wireline telephone, the call will be directed to, and answered by, a public safety answering point (PSAP) that can immediately dispatch aid to the caller’s location. The same scenario doesn’t always work when 911 calls are made on wireless phones and can have dangerous consequences.

That is because most wireless 911 calls are routed through the cell site (tower) where the call is received and are sent to the PSAP associated with that cell site. Sometimes, however, the 911 call is sent to the wrong PSAP because the cell site where the call was received is not in the same jurisdiction as the 911 caller. Each time a wireless 911 call is routed to one PSAP and must be transferred to another, the call transfer process consumes time and resources, and the process ultimately delays the ability of first responders to reach the scene of the emergency. (Draft of Docket 18-64 Fact Sheet, released May 18, 2022.)
The goal of the industry is to ensure location-based routing technology always works on 911 wireless calls. Such technology would allow carriers to route wireless 911 calls based on location information from the handset, rather than the location of the cell tower.

The FCC first began working with the industry on this issue in 2018, when it released a Notice of Inquiry in Docket 18-64 requesting comment on the feasibility of always using location-based routing to reduce the number of wireless 911 calls that are routed to an inappropriate PSAP. It found that technology was not advanced enough. Things may have changed.

According to the Commission, the technology has improved over the last four years and “there have been several publicly announced advancements in location-based routing technology and some implementation of location-based routing on wireless networks.” Therefore, it may now be feasible to route wireless 911 calls directly to the correct PSAP based on more precise information about the caller’s location.

The Commission gave the following examples of these improvements:

In 2018, CTIA announced that the nationwide wireless carriers planned to add device-based hybrid (DBH) location technologies to their networks to improve 911 location accuracy.

In 2019 Apple Inc. stated that it had made DBH location technology available on certain device models that would support carrier implementation of location-based routing.

In 2020, T-Mobile launched location-based routing on its network in Texas and Washington state.

Finally, in 2022, AT&T announced a plan for a nationwide rollout of location-based routing on its network.

In response to these improvements, on May 18, 2022, the Commission released a draft of a Public Notice in Docket 18-64 that will be voted on (and approved) at its June 8, 2022, meeting. The Public Notice seeks to update the record for location-based wireless 911 calls and asks for industry input on the following issues:

Parties are invited to provide the latest information on improvements to location-based routing technologies and deployment of such technologies in wireless carrier networks since the 2018 Notice of Inquiry.

The Notice requests updated information on the frequency of 911 call misroutes and developments in technology, operations, or industry standards to address the problem of misroutes.

The Commission seeks comments on the feasibility of using location-based routing technologies for text-to-911.

It asks for information on any interdependencies of location-based routing and Next Generation 911 (NG911) to optimize emergency response.

The Notice seeks comments on how the Commission can facilitate improved wireless routing and promote location-based routing of 911 calls.

Assuming the Public Notice is approved by the Commission on June 8, 2022, industry comments will be due 30 days after its release. Reply comments will be due 45 days after its release.