FCC Will Require Location-Based Wireless 911 Routing

The FCC is poised to require Commercial Mobile Radio Service (CMRS) providers to implement location-based routing for all 911 calls.  The Report and Order (Order) in Docket 18-64 is expected to be approved at the Commission’s January 25, 2024, meeting.  The agency explains its reasoning.

Americans expect that every 911 call will be answered by the public safety answering point (PSAP) that has the ability to promptly dispatch aid to the caller’s location. Wireless 911 calls are typically 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 routed to the wrong PSAP because the
receiving cell site is not in the same jurisdiction as the 911 caller.  This, in turn, means that the PSAP must transfer the 911 call, which consumes time and resources and ultimately delays the arrival of first responders. With location-based routing, more precise information about the location of the wireless caller’s device can be used to route 911 calls to the appropriate PSAP…The record indicates that implementing location-based routing nationwide will reduce by millions the number of wireless 911 calls that would otherwise be routed to an inappropriate PSAP and need to be transferred. This improved routing for 911 will reduce emergency response times and save lives.  (FCC Fact Sheet, Docket 18-64, released January 4, 2024).

In the Order, the Commission mandates the following new requirements.

All CMRS providers must:

  • Deploy location-based routing technology nationwide for wireless voice calls and real-time text (RTT) communications to 911 originating on their Internet Protocol (IP)-based networks (i.e., 4G LTE, 5G, and subsequent generations of IP-based networks).
  • Use location-based routing to route wireless 911 voice calls and RTT communications to 911 originating on their IP-based networks when location information available to the CMRS provider’s network at time of routing is ascertainable within a radius of 165 meters (about 541.34 ft) at a confidence level of at least 90 percent.
  • In the absence of these conditions, CMRS providers must use alternative routing methods based on “best available” location information, which may include but is not limited to device-based or tower-based location information confidence level of at least 90 percent.

Implement location-based routing within six months and non-nationwide providers to implement location-based routing within twenty-four months of the effective date of the Order.  For RTT communications to 911, the Order would require all CMRS providers to implement location-based routing within 24 months.

Within 60 days of the applicable compliance deadlines certify and submit evidence of compliance with location-based routing requirements.  At that time, CMRS providers also must submit one-time live call data reporting on the routing methodologies for calls in live call areas, and they must certify the privacy of location information used for location-
based routing.

The Commission defers consideration of proposals to require CMRS providers and covered text providers to implement location-based routing for Short Message Service (SMS) texts to 911.

It also defers consideration of proposals concerning IP-formatted delivery of wireless 911 voice calls, texts, and associated routing information to Next Generation 911 (NG911) networks to its pending NG911 transition Docket No. 21-479.

The FCC asserts that the implementation of location-based routing has potential annual benefits of over $173 billion in terms of reduced mortality and reduced call transfer burdens to PSAPs.  It also forecasts that the new rules will cost the industry a collected cost of $215 million.  Thus, the benefits far outweigh the industry costs.

While some wireless providers requested the Commission to allow them to implement location-based routing on a PSAP-by-PSAP basis, they have been overruled by public health authorities pushing for the new requirements.  This Report and Order is almost surely a done deal, so be ready for it!