Working Group #3 E911 Location Accuracy March 22, 2012 Stephen J. Wisely and Richard Craig, Co-Chair’s

Participants 2 First NameLast NameOrganization MichaelAndersonEricsson FirdausAryanaTelecommunication Systems, Inc. WayneBallantyneMotorola Mobility, Inc. AndrewBeckCommScope JebBenedictCenturyLink DonnaBethea- Murphy Iridium BillBuchholtzTexas 911 Alliance RichardCraigVerizon Wireless MarlysDavisKing County E9-1-1 Program Office KhaledDessoukyTechnoCom Corporation ThomasDombrowskyWiley Rein LLP ChrisFischer NORCOM JeannaGreenSprint RogerHixsonNENA RyanJensenT-Mobile MarteKinderTime Warner Cable SandraLottCenturyLink MikeLoushineTelcordia WG 3 Outdoor Location Accuracy Subgroup consists of the following members: First NameLast NameOrganization BarryMartinBoeing KathrynMartinAccess Partnership KathyMcMahonAPCO International MartinMoodyMetro Emergency Services Board JimNixonT-Mobile GaryParsons NextNav LLC GaneshPattabiranan NextNav LLC GustavoPavonTrue Position, Inc. RaghavendhraRaoAT&T ChuckRonshagenCassidian Communications BrettSchneiderBexar Metro Network District DeWayneSennettATIS NormanShawPolaris Wireless, Inc. SusanSherwoodVerizon Wireless JohnSnappIntrado, Inc. DorothySpears-DeanVirginia Information Technologies Agency BillTortorielloUS Cellular GregTuretzkyCSR Technology Inc. BruceWilsonQualcomm Inc. StephenWiselyAPCO International KarenWong State of California Richard Deh-MinWuNokia Siemens Networks

Participants 3 Outdoor Location Accuracy Subgroup Co-Leaders Jeanna M Green- Sprint Brett Schneider – Bexar Metro District Working Group Document Editors: Jeanna Green – Sprint Kathy McMahon – APCO International Working Group 3 had: 2 Face to Face meetings 40 Plus Conference Calls Working Group 3 had: 40 Members 36 Organizations, companies, associations and public safety centers represented

Outdoor Accuracy Testing Due 3/2012 Indoor Accuracy Testing Due 6/12 Impact of Commercial LBS Technologies Due 3/ Work Group 3 Areas of Focus

Address questions referred to CSRIC in PS Docket no , Wireless E9-1-1 Location Accuracy Requirements. Develop approaches to outdoor location accuracy testing criteria, procedures, and timeframes that are reasonable & cost- effective, considering alternatives to current FCC OET Bulletin 71. Develop recommendations concerning the feasibility of flexible testing criteria & methodologies & gather detailed costs data for the methods. 5 Outdoor Report Areas of Focus

 Consensus opinion is that OET 71 continues to be a valuable high-level guideline and framework for evaluating compliance for enhanced location accuracy testing.  OET 71 acknowledged within its framework, that testing and verification practices would evolve over time - indeed that has been the case.  Since the Bulletin was originally issued, the Alliance for Telecommunications Industry Solutions (ATIS) Emergency Services Interconnection Forum (ESIF) has produced five (5) standards documents and each of these was reviewed by WG3 (Section 4). 6

 As a consequence of our review of ATIS materials, we suggest the following ATIS Technical Reports, as augmented by recommendations in Section 5 of our report, be recognized and used by stakeholders as best practices for outdoor location accuracy:  ATIS Technical Report – High Level Requirements for Accuracy Testing Methodologies  ATIS Technical Report – High Level Requirements for End-to-End Functional Testing.  ATIS Technical Report – Define Topologies & Data Collection Methodology.  ATIS Technical Report – Maintenance Testing  ATIS Technical Report – Approaches To Wireless Indoor Location Performance Testing* (*referred to in Section 4.7 so as to address concepts that are also relevant to outdoor accuracy) 7

 Our consensus is that ATIS generally provides more current and relevant procedures and guidelines than are available in OET 71.  Although there are many valid approaches to location accuracy performance, some of them provide a more cost-effective way to achieve and maintain location accuracy within the wireless service provider’s (WSP’s) network.  In Section 5 of our report, we supplement the information available in ATIS by providing some alternative methodologies for location accuracy testing 8

 The WG concurs that ATIS provides both:  best practices for conducting Empirical accuracy testing, and  appropriate guidelines and accepted procedures for use of the predictive testing methodology, as well as proper safeguards in utilizing predictive testing  We recommend that the FCC promote and support further development and guidance on the various alternative testing methodologies, as defined within this WG3 report, be documented within ATIS

 The current FCC rules, established in the 2 nd R & O, do not clearly mandate a specific Phase 2 yield requirement; rather they establish specific “Phase 2 location accuracy” standards spread over four defined benchmarks at the county-level.  Although the WG members generally worked in concert to provide overall objectivity and worked toward best practice resolutions, ‘yield’ is a subject that we could not find consensus on, and was a continuous point of disagreement. 10

 Phase 2 yield may be defined as the ratio of successful acquisition of Phase 2 locations over the total number of valid location requests.  The subject of location system performance and yield means numerous things to different stakeholders. In an effort to provide visibility into the debate over yield, we have provided highlights from the discussion within Section 7 of this report.  No consensus recommendations with regard to yield are contained in this report. 11