Indoor-location technology is not ready for E911 use, argues TIA

Federal regulators should refrain from adopting new location accuracy rules until indoor-positioning technology is truly ready for prime time, according to the Telecommunications Industry Association (TIA), which represents manufacturers and suppliers of communications networks.

"Although TIA supports the development of improved location accuracy, many concerns remain regarding the impact of new requirements on innovation and whether technology is sufficiently developed to support the proposed mandate," said the organization in a filing regarding the FCC's ongoing proceeding on wireless E911 location-accuracy requirements. 

Location-accuracy requirements should be based on technology "the claims for which can be confirmed with verified data using commercially available products," TIA said.

The group stressed that indoor-location technologies are still quite nascent and may not be sufficiently developed to support an indoor location-accuracy requirement for determining a caller's location within 50 meters on a horizontal grid, as proposed by the FCC. If its proposed rules are adopted, the commission wants to require service providers to deliver that level of accuracy for 67 percent of 911 calls placed from indoor environments within two years and for 80 percent of indoor calls within five years.

Location accuracy using Wi-Fi technology could be aided by two evolving IEEE Wi-Fi standards--802.11mc and 802.11k/u--which are on track for Wi-Fi Alliance certification in 2015, TIA noted. But once those technologies are certified, there will still be a ramp-up period as those technologies are integrated into new commercial devices such as access points and mobile devices such as smartphones.

The association cited information provided earlier to the FCC by Cisco Systems, which stated that the 802.11mc file timing measurement protocol for use with 802.11ac Wi-Fi "will be capable of producing 10 feet of accuracy on a horizontal x/y axis 90 percent of the time although more accurate data is possible depending upon implementation and the use of  'angle of arrival' data."

The FCC also proposes to require mobile service providers to deliver z-axis, vertical location information within 3 meters of a caller's location for 67 percent and 80 percent of indoor wireless 911 calls within three years and five years of the effective date of adoption rules, respectively. This would help first responders determine what floor of a multi-story building a person is calling from. But TIA contends technology capable of satisfying those requirements is neither sufficiently developed nor readily available.

While advances have been made regarding indoor-location technology, which has numerous commercial applications for merchants pursuing location-based marketing, TIA suggested the market remains at a delicate stage of development.

"Placing additional compliance burdens on industry at this time, through further location accuracy regulations, will divert focus from developing new life-saving, advanced location accuracy techniques and instead place focus on regulatory compliance," TIA said.

Though stressing that it "strongly opposes" adoption of further location accuracy requirements for E911, TIA noted that if the FCC moves ahead to do so, it should ensure any new rules "adhere to technology neutral and results-based principles."

For more:                                                                                    
 - see this TIA release
- see this TIA filing (PDF)

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