Mike Rigert

Mike Rigert

Story Vault

By Mike Rigert

Take your pick of the many tragic individual anecdotes but the problem remains the same.

On Jan. 17, 2008, Denise Amber Lee, 21, a wife and mother of two young boys, was abducted from her home.1 Lee made a desperate call to 9-1-1 from her abductor’s car using her abductor’s cellphone. Four other 9-1-1 calls—including one in which an eyewitness provided police with an exact location as the crime unfolded before her in real time—were also made on Lee’s behalf.2 And though police quickly traced Lee’s 9-1-1 call to the suspect’s cellphone, they could not locate her. Lee was brutally murdered. Two days later her body, with a single gunshot wound to the head, was found in a shallow grave in a remote, swampy area near Toledo Blade, Fla.3

Fast-forward to June 16, 2013, when Joann Hillman-Payne, an EMT with the New York City Fire Department, took a 9-1-1 cellphone call from Mary Thomas.4 But because Thomas was suffering from a stroke, Hillman-Payne could not understand Thomas’ badly slurred speech. Rescuers struggled to locate the patient as Hillman-Payne continued a nearly eight-hour phone conversation with Thomas to reassure her and try to keep her conscious. Though first responders ultimately found and transported her to a nearby hospital, part of the confusion in locating Thomas, a housekeeper, was that she calling from an Upper Manhattan high-rise apartment that she was working in, and thus the location information—the physical address of the cell tower—was woefully inaccurate.

The current inability of Public Safety Answering Points (PSAPs) to accurately locate 9-1-1 cellphone callers indoors and vertically in multi-story buildings has been called “a serious public safety problem” by Danita Crombach, a communications manager at the Ventura (Calif.) County Sheriff’s Office call center.5 Because available technology doesn’t allow GPS signals from cell towers to penetrate most structures, callers dialing 9-1-1, who, for a variety of reasons may not be able to verbally provide their location (e.g., lost or unfamiliar with location; hearing impaired; can’t speak due to having a stroke or other medical condition; don’t speak English; experiencing a domestic violence situation), may or may not be located by first responders.

In an increasingly mobile phone-based society in which cellphone use is skyrocketing, the FCC estimates that upward of 76 percent of 9-1-1 calls now come from wireless phones rather than landlines. If identifying a 9-1-1 cellphone location wasn’t problematic enough (more about that later), finding the caller is severely compromised when he or she cannot verbally give the calltaker a current address for a variety of reasons.

Though daunting, the problem is far from unsolvable. A handful of technologies are currently being evaluated that may allow cellphone carriers to provide PSAPs not only with more accurate latitude and longitude coordinates (x- and y-axis), but also with the vital z-axis (vertical) that would enable call centers to locate callers vertically inside skyscrapers and other tall structures.

Moreover, the FCC has heard the outcry from both the public and the U.S. public safety community. On Feb. 20, the commission introduced proposed rules that would require cellphone carriers to provide horizontal indoor location of a caller to within 50 meters (164 feet) for 67 percent of 9-1-1 calls within two years (80 percent within five years) of the rules’ adoption.6 Within three years of the rules’ adoption, cellphone carriers would be required to provide vertical indoor location (z-axis) within 3 meters (roughly 10 feet) of the caller for 67 percent of calls, and for 80 percent of cellphone calls within five years.

Yet the burden would not only be upon cellphone carriers. To allow the improved caller location function, PSAPs would be required to update their communications systems and infrastructure to receive the more accurate location data from cellphone providers.

In the absence of a crystal ball to know if the FCC will adopt the proposed rules, we can delve further into the problem of 9-1-1 cellphone caller location accuracy, its causes and impacts, the first-hand experiences and perspectives of emergency dispatch professionals and their supporters, and at the pending regulations themselves.

The problem

In 1997, an FCC ruling set several deadlines and reporting dates for cellphone carriers implementing wireless 9-1-1 or wireless Enhanced 9-1-1 (E9-1-1) services.7 The basic rules require providers to transmit all 9-1-1 calls to a PSAP regardless of whether the caller subscribes to the provider’s service or not.

Phase I E9-1-1 rules require cellphone carriers to provide PSAPs with the phone number of the originator of a 9-1-1 call and location of the cell tower transmitting the call within six minutes.

Phase II E9-1-1 rules specify that by 2012, cellphone carriers must provide emergency responders with x- and y-axis coordinates accurate to 50 to 300 meters (164 feet to 984 feet) of a 9-1-1 caller, depending on the technology used.

However, both Phase I and Phase II E9-1-1 rules apply to outdoor use only despite industry estimates that at least 50 percent of wireless 9-1-1 calls originate from indoors. And beginning in 2011, cellphone carriers could file with the FCC a list of counties or portions of counties that they opt to exclude from the location accuracy requirements for technical reasons (i.e., rural areas with limited or no cellphone coverage) that might hamper locating a caller.

But just because a PSAP is Phase II capable doesn’t mean the communication center is getting accurate or reliable Phase II caller site data. For a prime example, look no further than Crombach, who is also president of California’s chapter of the National Emergency Number Association (CALNENA). In her Aug. 12, 2013, letter to the FCC detailing the alarming caller location problem and expressing support for new 9-1-1 location accuracy rules, she states that Ventura County 911 (which serves nearly one million residents) has been receiving Phase II location data for years. However, in 2011 she and other officials began noticing “a significant decrease in the percentage of wireless 9-1-1 calls that delivered Phase II location information.”

Without the Phase II data, dispatchers are unable to locate 9-1-1 callers in need, particularly if they are unable to verbalize their current address.

“In Ventura County, the problem is urgent,” Crombach said. “Of the 87,000 wireless calls we received over the past 18 months, over one-half did not have Phase II location information delivered with the call as required by FCC regulations.”

And the Phase II problem is not isolated to Ventura County 911. PSAPs throughout the state have told her that they are experiencing the same decline in wireless 9-1-1 accuracy as the Phase II data they used to receive is no longer delivered with the call. Statistical reports from around the state indicate the phenomenon is widespread, Crombach said, including in San Francisco, San Jose, Pasadena, Bakersfield, and Ventura County.

“According to the California State 9-1-1 Office, of the 1,589,580 wireless 9-1-1 calls received statewide in March 2013, more than 55 percent did not have Phase II location information delivered with the call,” Crombach said.

One cellphone carrier’s delivery of Phase II location information in Ventura County dropped from the 90th percentile in 2008 to less than 35 percent at the end of 2012, she states in her letter. Even the best performing provider delivered accurate location information to the PSAP on only 64 percent of calls in December 2012.

Crombach suspects that since the problem is much worse in urban areas, the carriers’ assisted global positioning system (AGPS) technology “may be a significant factor” as GPS signals typically cannot go through structures and urban “canyons” created by high-rise buildings.

“This data drives home the risk we are facing today as a large and growing percentage of those callers have their location unavailable to dispatchers and emergency responders,” Crombach said. “Now is the time for action on existing rule compliance and on establishing indoor accuracy requirements before more lives are put at risk.”

Jamie Barnett is director of the Find Me 911 Coalition (www.findme911.org), an effort of more than 200,000 individuals comprised primarily of local and national public safety organizations dedicated to bring about improvements to emergency caller location. He said a key catalyst to the group’s founding was the news out of California from Crombach. The organization estimates that upward of 60 to 80 million wireless 9-1-1 calls per year are not being accurately located.8 He said just getting the FCC to initiate the proposed indoor caller location rules was “a tremendous victory.”

“Millions of Americans each year rely on their mobile phones to place emergency calls to 9-1-1, not realizing that if they place that call from many indoor locations there is no ability to determine their location and there is (currently) no FCC requirement that wireless carriers be able to do so,” Barnett said.

The survey

In the spring of 2014, Find Me 911 commissioned a survey among 1,014 PSAP managers and employees representing 880 individual PSAPs from all 50 states, or approximately 15 percent of all PSAPs.9

Barnett said one of the most illuminating finds was that 82 percent of 9-1-1 personnel surveyed have little confidence in the location data provided to their PSAPs by wireless carriers. It also showed that 54 percent said the latitude and longitude (Phase II) data provided by carriers is “regularly” inaccurate, and that 97 percent of 9-1-1 call centers have received a wireless 9-1-1 call within the last year from a caller who could not tell the dispatcher his or her location.

“The results are truly staggering,” Barnett said. “It’s time to move past Phase I and Phase II and improve our indoor wireless caller capabilities. It’s solvable and the technology does exist. … Not only are we not finding people but we’re misdirecting valuable first responder assets.”

In seeking the professional opinion of people “on the front lines,” the survey was formulated to complement FCC’s questions so that results could be submitted as part of public comment to the proposed rules, Barnett said.

But perhaps the most powerful, and at the same time disturbing, realization to come out of the survey’s results were respondents’ 200 personal stories describing the challenges associated with locating wireless callers. The following are some examples (responses are excerpted and edited by Find Me 911 for grammar and spelling):

•“Received a 9-1-1 from a cellphone with an open line. It was a female that sounded as if she had her mouth gagged. She was getting beat [and] even her dog was being hurt. The lat/long came to an abandoned building in St. Louis City … Could not pinpoint her location, and her phone died. She was never found.” —Missouri 9-1-1 employee

•“We had a caller call in [and] all we could hear was what sounded like a struggle to breathe and loud music in the background. He called from his cell phone, however there was no Phase II, only Phase I where it shows only a triangle of area that he could be calling from. … The subject was eventually found and he had been murdered by having his throat cut.” —Texas 9-1-1 employee

•“We had a caller with Lou Gehrig’s disease. He called 9-1-1 for an ambulance but was unable to speak, and the 9-1-1 information would not zone in on his location. … [The] caller was in physical distress, but we would have never found him based on the 9-1-1 info.” —California 9-1-1 employee

•“A call was received from a young child indicating that her mother was unresponsive. It took nearly 45 minutes to ascertain the correct address and even then the location provided by Phase II rebidding put the location of the caller to only within a 1,000-yard radius. —New Hampshire 9-1-1 employee

“This survey, and the powerful personal stories of 9-1-1 employees from around the country, removes any doubt about the life-and-death urgency of the FCC’s rulemaking on this issue,” Barnett said.

The proposed rules

The FCC offered two public comment periods following publication of the proposal in February; the second and final period closed mid-July 2014.

As one might imagine, the pending regulations have been met with their share of proponents and detractors, including members of the FCC.

FCC Commission Chairman Thomas Wheeler cited a disconnect between the rules and the realities of the always-connected mobile world, a perspective he gained when visiting with staff at PSAPs urging the advance of 9-1-1 caller location capability.10 For example, dispatchers spoke to him about the Sept. 15, 2013, Washington Navy Yard shooting during which a lone gunman fatally shot 12 people and injured three others. A significant number of employees used their cellphones to dial 9-1-1 rather than their office phones. He also mentioned an anecdote about a stolen iPad in which the location information delivered to a PSAP for the caller reporting the theft was “off by almost three miles,” while the data provided to the device’s location app “provided pinpoint accuracy.”

Similarly, Commissioner Jessica Rosenworcel delineated the stark contrast in accurate location information options for the public when dialing 9-1-1 from a mobile phone.

“If you call 9-1-1 from a wireless phone outdoors, the commission has standards that help ensure first responders can locate you and send assistance,” she said. “But if you call 9-1-1 from a wireless phone indoors, you should cross your fingers and hope and pray, because no location accuracy standards apply.”

Commissioner Ajit Pai said the FCC should approve rules that are both “aggressive and achievable.” “Unfortunately, I am skeptical that the time frames (two and five years for indoor vertical) proposed in today’s item are realistic. … The commission’s rules should be more than inspirational.”

Pai added that the date of compliance should not be the effective date of the rules’ adoption but rather when the FCC’s Communications Security, Reliability, and Interoperability Council (CSRIC) certifies that a technology vendor has demonstrated through an independently administered test program that a solution meets the horizontal and vertical location accuracy benchmarks for those rules.

“Judging from our experience with Phase II, which the FCC mandated in 1996 but will not be fully implemented until 2019, I am skeptical that this deployment can be completed in two to three years (for the first phase of proposed indoor location),” Pai said.

Barnett countered that the technologies for indoor, vertical location do exist and said the time frames suggested in the FCC’s proposed rules are manageable. He said it’s entirely feasible for PSAPs that aren’t Phase II capable to be up to speed within two years.

“More rural areas with fewer cell towers linked to a network’s systems are not as accurate with Phase II location,” Barnett said. “That’s where GPS, in tandem with triangulation of cell towers, works best.”

He said that’s why it’s really going to take a combination of technologies for improved 9-1-1 wireless caller location to operate at the highest levels.

Possible technology candidates for z-axis location information that are fully operational or under development, according to Find Me 911, include:

Uplink Time Difference of Arrival (U-TDOA), which computes location by measuring the time it takes cellphone transmissions to reach multiple cell towers.

Advanced Forward Link Trilateration (AFLT), which computes location by measuring the time it takes multiple cell tower transmissions to reach the cellphone.

RF pattern matching, which computes location by measuring the power levels received by the handset from multiple cell towers.

Terrestrial beacon transmitters, which compute location by measuring the time it takes signals to arrive at the handset from multiple beacons.

Digital television signals, which compute location by measuring the time it takes multiple cell tower transmissions to reach the cellphone.

Observed Time Difference of Arrival (O-TDOA), which computes location by measuring the time it takes signals to arrive at the handset from multiple digital TV transmitters.

“Improvements to 9-1-1 caller location in public safety will lead to saving lives,” Barnett said. “I hope the FCC will adopt the rules soon, maybe as early as October.”

Meeting the objective

Mark Rector, a member of Priority Dispatch Corp.’s Implementations Department, said it’s been his experience in the industry that FCC rules often take more than the allotted time to get all parties involved onboard. Another issue from the public safety side is cost-related; FCC regulations are essentially unfunded mandates. But generally, he said, involved parties and organizations tend to take proactive steps and make a good faith effort to comply with rules, particularly when public safety is an issue.

“There’s a collegial patience factor, but nonetheless, a commitment to carriers and public safety to make (improved indoor location) happen,” Rector said.

Still, he understands Commissioner Pai’s call for cooler heads to prevail on the commission when it comes to setting more reasonable time frames for implementing the proposed rules and also the requisite technology development.

“It’s going to be an enormous challenge, in my opinion, to drill down to satisfactory technology capable of finding a cellphone in the basement corner of a massive industrial warehouse that covers four acres, or a bathroom of a 25-story office complex,” Rector said. “That’s going to be interesting.”

The key, he said, will be getting realistic input from all stakeholders and then incorporating that into the rules in order to get the maximum cooperation and collaboration out of PSAPs, cellphone carriers, technology research and design providers, etc.

“Let’s have a reasonably achievable goal with a plan on how to get there,” Rector said. “What’s good for this is that Phase II is well underway, and the indoor, vertical location efforts can piggyback on its solutions and ride the coattails of that. Find Me 911 is very fortunate in that the work has begun.”


1O’Neill, Ann. “Woman’s frantic 911 call helps convict her killer.” CNN.com. 2009; Aug. 28. http://images.cnn.com/2009/CRIME/08/28/florida.murder.kidnap.911/index.html (accessed June 9, 2014).

2Denise Amber Lee Foundation. “Our Story.” http://www.deniseamberlee.org (accessed June 9, 2014).

3Herald-Tribune. “Denise Amber Lee shot and tossed in a shallow grave.” 2008; Jan. 20. http://www.heraldtribune.com/article/20080120/BREAKING/82183926?template... (accessed June 9, 2014).

4Briquelet, Kate. “Hero EMT dispatcher helps pinpoint lost stroke victim in EIGHT-HOUR phone call marathon.” New York Post. 2012; June 16. http://nypost.com/2013/06/16/hero-emt-dispatcher-helps-pinpoint-lost-str... (accessed June 9, 2014).

5Crombach, Danita. “CALNENA Letter to the FCC.” The California Chapter of the National Emergency Number Association (CALNENA). 2013; Aug. 12. http://www.calnena.org/communications/To-FCC-08-12-2013/CALNENA-Letter-t... (accessed June 9, 2014).

6Federal Register. “Wireless E911 Location Accuracy Requirements; Proposed Rule. Introduction and Executive Summary.” 2014; March 28. http://www.gpo.gov/fdsys/pkg/FR-2014-03-28/pdf/2014-06618.pdf (accessed June 9, 2014).

7Federal Communications Commission. “Enhanced 9-1-1—Wireless Services.” http://transition.fcc.gov/pshs/services/911-services/enhanced911/Welcome... (accessed June 9, 2014).

8Findme911.org. “Wireless E-911: A Crisis in Location Data.” http://findme911.org/resources/wireless-e-911-a-crisis-in-location-data/ (accessed June 9, 2014).

9Findme911.org. “FIND ME 911 News: Survey of 9-1-1 Dispatchers Finds Many Indoor Callers Cannot be Located.” http://findme911.org/news/survey-of-9-1-1-dispatchers-finds-many-indoor-... (accessed June 9, 2014).

10FCC. “Proposes new indoor requirements and revisions to existing E911 rules.” http://www.fcc.gov/document/proposes-new-indoor-requirements-and-revisio... (accessed June 9, 2014).