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SBC Comments on FCC's Wireless E911 Location Accuracy NPRM - PS Docket No. 07-114

Filed July 3, 2025

Executive Summary

The Safer Buildings Coalition has filed comprehensive comments in PS Docket No. 07-114 (6th FNPRM on Wireless E911 Location Accuracy). SBC's comments address both emergency location accuracy improvements and indoor wireless coverage gaps that are a critical consideration for quickly and accurately locating those who need help. Under the banner of "9-1-1 Inside," SBC advocates that the ability to call for help and be accurately located should not depend on where someone happens to be standing when an emergency occurs.

SBC's comments recognize that indoor emergency communications face two distinct challenges: wireless "dead zones" where 911 calls cannot be made due to coverage gaps, and when calls are possible, difficulty accurately locating callers inside buildings. To address location accuracy, the comments support device-based hybrid solutions as enhancements to existing network approaches and Height Above Ground Level (AGL) as a beneficial addition to Height Above Ellipsoid (HAE) measurements. The comments also propose creation of a National Indoor Wireless Coverage Map to improve understanding and awareness of the scope of poor indoor coverage - which would primarily help address coverage gaps and secondarily support location accuracy improvements.

The recommendations emphasize market-driven solutions that leverage existing smartphone technology and private sector data collection, aligning with regulatory efficiency priorities by building on current infrastructure rather than requiring new government programs.

The Context: Indoor Emergency Location Challenges

"The Other Digital Divide: The One That Starts at the Building Wall"

While America has made tremendous progress connecting rural areas through evidence-based broadband policy and the National Broadband Map, indoor emergency communications represent a distinct challenge. The primary concern is wireless "dead zones" inside buildings where no connectivity exists at all, making 911 calls impossible due to coverage gaps. When emergency communications are possible, current location systems work well outdoors but face limitations inside buildings where emergency responders often cannot locate callers quickly enough during critical incidents.

Technology Opportunities for Enhancement

Modern smartphones contain sophisticated sensors that could enhance location accuracy when integrated with existing network-based approaches:

  • Barometric pressure sensors for elevation measurement
  • Accelerometers and gyroscopes for indoor positioning
  • Wi-Fi and Bluetooth beacons for location refinement
  • Integration with existing GPS/GNSS capabilities

These device-based capabilities represent opportunities for incremental improvements that complement current network infrastructure investments rather than requiring wholesale replacement of existing systems.

Evidence-Based Policy Opportunity

Unlike outdoor broadband coverage, no comprehensive data exists regarding indoor wireless coverage quality. This represents an opportunity to apply the successful National Broadband Map model to indoor emergency communications, using existing market data to identify coverage gaps and guide targeted improvements.

Benefits of SBC's Recommendations

Enhanced Emergency Response:

  • Improved Location Precision: Device-based enhancements could provide more reliable ±3-meter vertical accuracy
  • Enhanced Vertical Accuracy: Adding AGL to existing HAE requirements offers the potential for significant improvement in vertical location accuracy
  • Building Integration: Coordination with existing building safety infrastructure maximizes current investments
  • Technology-Neutral Standards: Performance requirements that encourage innovation while maintaining baseline reliability

Smart Policy Innovation:

  • Evidence-Based Approach: Proposed indoor coverage map follows successful National Broadband Map precedent
  • Market Data Utilization: Uses existing carrier coverage models and crowdsourced data without new regulatory requirements
  • Targeted Solutions: Identifies specific buildings needing attention rather than broad mandates
  • Private Sector Implementation: Leverages commercial mapping and data analysis capabilities

Regulatory Efficiency Benefits:

  • Builds on Existing Infrastructure: Enhances current HAE systems rather than replacing them
  • Market-Driven Innovation: Encourages carrier-OEM coordination and voluntary improvements
  • Reduces Regulatory Burden: Uses existing data collection rather than new reporting requirements
  • Cost-Effective Implementation: Leverages smartphone capabilities already in devices

Technology Integration:

  • Incremental Enhancement: Device-based solutions complement existing network approaches
  • Industry Collaboration: Supports coordination between carriers and device manufacturers
  • PSAP Compatibility: Solutions designed to work with existing 911 infrastructure and NG911 architecture
  • Flexible Implementation: Multiple pathways for achieving improved location accuracy

Frequently Asked Questions

Q: How do device-based solutions work with existing location technology?

A: Device-based approaches are designed to enhance, not replace, existing network-based location systems. Modern smartphones contain sensors that can provide additional location data to improve overall accuracy while building on current infrastructure investments.

Q: What is Height Above Ground Level (AGL) and how does it relate to current systems?

A: AGL provides operational elevation information that complements existing Height Above Ellipsoid (HAE) measurements. AGL helps emergency responders calculate floor levels and position equipment effectively. Multiple implementation approaches exist, including direct device measurement and HAE-to-AGL conversion, allowing flexibility while preserving current system investments.

Q: Where can I read SBC's complete comments?

A: The complete comments are available through the FCC's Electronic Comment Filing System at FCC Filing Status using filing ID 10703192295348. Comments can also be accessed by searching PS Docket No. 07-114.

Q: What is the proposed indoor coverage map?

A: SBC proposes a National Indoor Wireless Coverage Map that would identify buildings where 911 calling capability may be compromised. The map would use existing data from carrier coverage models, crowdsourced applications, and building assessments - requiring no new data collection mandates while enabling targeted improvements where most needed.

Q: How does this align with regulatory efficiency priorities?

A: The recommendations leverage existing market data and smartphone capabilities rather than creating new regulatory requirements. The approach follows the successful National Broadband Map model, using private sector data collection to enable smart, targeted policy rather than broad mandates.

Q: Will this require new infrastructure investment?

A: The proposals are designed to leverage existing smartphone technology and current network infrastructure. Device-based enhancements use capabilities already present in most modern phones, while the coverage mapping utilizes data already collected by industry.

Q: How would building location information be implemented?

A: SBC supports a graduated approach with interim milestones that make meaningful progress while allowing time for technical development. This includes enhanced floor-level identification, building entrance information, and voluntary integration with existing building safety systems.

Q: What about compatibility with current 911 systems?

A: All recommendations emphasize compatibility with existing Public Safety Answering Points (PSAPs) and alignment with NG911 standards. Location data would be delivered in formats that current 911 centers can receive and process without requiring costly system upgrades.

Filing Information

Date Filed: July 3, 2025

FCC Proceeding: PS Docket No. 07-114 (6th FNPRM on Wireless E911 Location Accuracy)

Submittal ID: 10703192295348

Current Status: DISSEMINATED (publicly available in FCC database)

Comment Period Status: Reply comment period closed July 7, 2025 - proceeding now under FCC consideration

Check Filing: FCC Filing Status

Download Full Comments: SBC Comments PS Docket No. 07-114 (PDF)

Filed Document Title: Comments of Safer Buildings Coalition PS Docket No. 07-114

Proceeding Background: Sixth Further Notice of Proposed Rulemaking on Wireless E911 Location Accuracy Requirements

Next Steps: Awaiting further FCC action - not currently scheduled for August 7, 2025 Open Meeting agenda

How to Follow: Monitor www.fcc.gov for FCC announcements regarding PS Docket No. 07-114

About the Safer Buildings Coalition

SBC is an independent 501(c)(4) non-profit organization and the recognized thought leader on policies and technologies that ensure effective in-building communications for public safety personnel and the communities they serve. SBC authored the Complete ERCES Handbook, a foundational reference for the NICET Public Safety In-Building Communications (IB-PSC) Certification Program. SBC's "9-1-1 Inside" initiative advocates that emergency location capability should not depend on where someone happens to be standing when they call for help.

Contact Information

John Foley, Managing Director
Safer Buildings Coalition
[email protected]
(610) 291-3856
www.saferbuildings.org