Posted by Mark O'Connor | Jul 23, 2020 | 0 Comments


On July 19, 2020, the FCC approved an Order regarding wireless E911 vertical location data that that wireless carriers must provide to public safety answering points (PSAPs) in order for emergency responders to locate E911 callers living and working in multi-story buildings. While providing some additional implementation flexibility for wireless carriers, the FCC also affirmed key deadlines and set new nationwide deadlines.

Entities Impacted

The Order will impact many sectors of the telecom market, including wireless carriers; cell phone manufacturers; wireless technology vendors; government emergency response teams; building owners and managers; and residential and business tenants of multi-story buildings.

Overview of the FCC's Order

The Order affirms and clarifies existing requirements that commercial wireless carriers deploy an E911 dispatchable location (street address, and apartment suite number or similar information) or a vertical “z-axis” technology solution. 

The FCC affirmed that nationwide CMRS providers (Verizon Wireless, AT&T, and T-Mobile) choosing to deploy z-axis location technology must comply with a vertical accuracy metric of plus or minus 3 meters for 80% of wireless E911 calls. These providers must deploy that technology by April 2021 in the top 25 Cellular Market Areas (CMAs), by April 2023 in the top 50 CMAs, and by April 2025 nationwide. Non-nationwide carriers must provide vertical location data throughout their service areas by April 2026.

The Commission also amended and clarified other vertical location requirements. First, the Order allows nationwide wireless carriers the option to use z-axis technology that covers 80% of the buildings exceeding three stories in a CMA, rather than requiring a z-axis solution that covers 80% of the CMA population. Second, wireless carriers may choose to meet the z-axis requirements using a handset-based technology solution. Third, wireless carriers are no longer required to use the National Emergency Address Database when designing dispatchable location information solutions. Fourth, and consistent with the 2018 RAY BAUM'S Act, beginning on January 6, 2022, wireless carriers must provide the dispatchable location of the wireless caller (i.e., street address plus additional information such as floor level) when it is technically feasible and cost-effective to do so.

About the Author

Mark O'Connor

Mark O'Connor, Member Contact: Telephone: 202-552-5121 Email: [email protected] Mr. O'Connor represents clients in the telecommunications industry on a broad range of transactional and regulatory matters before the FCC, state PUCs, and federal courts.  With over 25 years of telecommunicati...


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