APCO’s Regulatory Priorities for 2023

By APCO’s Government Relations Office.

The following is a list of APCO’s regulatory priorities for the coming year. As a general matter, APCO’s advocacy is driven by the best interests of our public safety members. That means we’re often arguing for a regulatory approach that: avoids shifting costs from service providers to ECCs; ensures that information being delivered to ECCs will best serve the operational needs of 9-1-1 professionals; and when it comes to spectrum, protects public safety users from interference and new costs.

Click each topic below to learn about recent developments and where things stand.  

1. Ensure wireless 9-1-1 calls are routed to the correct 9-1-1 center.

What’s the issue?

Traditionally, wireless 9‑1-1 calls have been routed to an emergency communications center (ECC) based on the cell tower sector that handles the call. This method of routing often results in a call being sent to an ECC that does not serve the caller’s actual location. These “misroutes” delay emergency response and waste ECC resources. In recent years, advances in location technology have created an opportunity to route wireless 9-1-1 calls more accurately, using “location-based routing,” which means using the location of the device making the call to route the call to the appropriate ECC. Some wireless carriers have even taken steps to implement location-based routing voluntarily.

In January, the FCC sought comment on proposed rules that would require wireless carriers to implement location-based routing nationwide. At the time of this writing the FCC was still reviewing public comments on its proposal.

What needs to be done?

APCO has urged the FCC to require carriers to provide location-based routing. We have pushed back on suggestions that 9‑1‑1 authorities should be responsible for enabling location-based routing or bear some costs, and explained that location‑based routing is not, and need not be, dependent on the deployment of pre‑NG9‑1‑1 technologies such as Emergency Services IP Networks or ESInets. Given that some carriers are voluntarily providing location‑based routing without placing additional costs on ECCs, and regardless of the technology an ECC has in place, we are hopeful to see positive action from the FCC soon.

2. Improve 9-1-1 outage reporting, reliability, and resiliency.

What’s the issue?

In the past year, the FCC has taken several steps to enhance network resiliency and reliability. Chairwoman Rosenworcel and Commissioner Carr visited areas where public safety communications had been impacted by natural disasters, and in May 2022 Commissioner Carr participated in an APCO webinar and shared a proposal to improve emergency communications resiliency. In July 2022, with APCO’s support, the FCC adopted new rules regarding arrangements among the major wireless carriers to increase coordination and information sharing during emergencies. For example, the new rules require all wireless service providers to execute roaming agreements with each other and to share resources in emergency situations.

In November 2022, the FCC took additional steps to address the timeliness, format, and content of outage notifications so that they provide actionable information for ECCs. APCO has been highlighting ECCs’ need for timely, actionable information about outages impacting 9-1-1 for several years. There are some basic regulatory requirements for notifications, but it’s all too common that ECCs don’t receive the timely information they need (if at all) for their situational awareness. APCO has been advocating that the FCC adopt rules to require timely notifications for outages that impact ECC operations but may not trigger the FCC’s presently very high thresholds. APCO has also urged that service providers provide outage information in a graphical format, much like how electric utilities and other service providers do today. Further, service providers should be required to provide a two-way contact database so that ECCs are promptly contacted or have the information they need to report outages they discover. To address some of these issues, the FCC’s Public Safety and Homeland Security Bureau will obtain information on the number of outages that go unreported under the current thresholds and consider modifying the thresholds. The Bureau will also collect information on the feasibility and utility of incorporating graphical information like outage maps into the notifications.

What needs to be done?

APCO will continue highlighting ECCs’ needs for mitigating outages and stands ready to support the Public Safety and Homeland Security Bureau’s further work. We will also continue pressing the FCC to hold the wireless carriers to their commitment to develop and maintain a secure, two-way contact database that would make it easier for carriers and ECCs to contact each other about known or suspected outages.

3. Improve location accuracy for wireless calls to 9-1-1.

What’s the issue?

9-1-1 professionals require actionable location information for 9-1-1 calls, and obtaining an accurate location is especially challenging for calls made indoors. Ideally, ECCs would know the caller’s “dispatchable location,” meaning the street address, plus (if applicable) the floor level and apartment/suite number.

The FCC’s rules require wireless carriers to provide dispatchable location when feasible, and carriers are also providing “z-axis” location to comply with a separate rule on vertical location information. Z-axis is generally viewed as an alternative to dispatchable location information because, when combined with the x/y coordinate information carriers have been providing for years, having the z-axis theoretically makes it possible to identify a caller’s location indoors.

APCO has consistently expressed a strong preference for dispatchable location information, which is feasible today, because it’s more actionable for ECCs than z-axis information. Carriers are delivering z-axis information as a “Height Above Ellipsoid (HAE),” which is not the same as height above ground or sea level. Setting aside the issue of whether z-axis estimates are accurate (which is a major issue), for HAE to be used to identify a specific location, specialized software and 3D maps will need to be developed. This will be technically challenging, time-consuming, and costly. It isn’t fair to expect ECCs to spend years and significant resources trying to make HAE work when it’s the wireless carriers’ responsibility to provide a caller’s location. Indeed, APCO has challenged the notion promoted by some that the responsibility (and costs) for developing ways to make use of HAE should be shifted from wireless carriers to the public safety community.

What needs to be done?

We’re seeking more transparency about the steps wireless carriers have taken to provide dispatchable location information, and considering the additional steps they can and should be taking. For example, wireless carriers should leverage a variety of technologies, such as “5G Home” offerings, to increase their ability to provide dispatchable location information. APCO also has insight into the carriers’ location technology test bed, and we are working to ensure the test results accurately represent real world performance. We’re hopeful that, by working with the FCC, we’ll develop an effective approach to increasing transparency and putting the right incentives in place for carriers and other stakeholders to improve 9-1-1 location accuracy.

4. Revise the rules for the 4.9 GHz band to enhance public safety use.

What’s the issue?

Historically, the 4.9 GHz band has been dedicated to public safety for broadband communications. For many years, APCO, among other public safety groups, has been asking the FCC to make reasonable rule changes to enable public safety to make increased use of this band.

In January 2023, the FCC adopted new rules that incorporate several of APCO’s recommendations to promote innovative technological approaches to the band. Importantly, the FCC reconfirmed the 4.9 GHz band as a dedicated public safety band and adopted a requirement for frequency coordination. The FCC also created a framework in which a band manager will be able to coordinate use of excess spectrum by non-public safety entities so long as public safety users are protected and maintain priority and preemption rights.

What needs to be done?

As part of the January 2023 rule change, the FCC sought input on how to increase and protect public safety use of the band, spur innovation, improve coordination, and drive down costs. There are a number of complex questions to address concerning how to enable spectrum sharing without sacrificing the reliability of the band for public safety users. APCO is examining these issues closely and will engage with the FCC to find a path forward to optimize this spectrum for public safety users.

5. Protect public safety users of the 6 GHz band from harmful interference.

What’s the issue?

Public safety agencies throughout the country make extensive use of the 6 GHz spectrum band for emergency dispatching, first responder radio communications, and connectivity with other jurisdictions. In 2020, despite significant technical debate and public safety concerns, the FCC changed the 6 GHz rules to expand unlicensed (ex – Wi-Fi) use of the band, effectively permitting hundreds of millions of potentially interfering new devices to share this band. These devices are not licensed, and thus not easily trackable, and are expected to be just as ubiquitous as the Wi-Fi routers presently found throughout homes and businesses.

APCO didn’t fundamentally oppose spectrum sharing as a concept, but reasonably asked the FCC to 1) ensure that real-world tests are conducted to inform the rules and measures for preventing/mitigating interference, and 2) require mechanisms to rapidly detect, identify, and eliminate any interference. The FCC did not adopt these suggestions.

Since the FCC adopted its order, new information has come to light that raises concerns that public safety operations will be subject to harmful interference. Accordingly, APCO and others submitted formal requests to the FCC to stop authorizing new unlicensed devices and to re-evaluate how to share the spectrum while protecting public safety from interference.

In the past year the FCC has continued to move forward with its new 6 GHz framework. Many “low power” Wi-Fi devices were approved and have entered the stream of commerce already, and the FCC is working through a process to permit “standard power” devices that will operate under the control of soon-to-be-established Automated Frequency Coordination (AFC) systems.

What needs to be done?

APCO is working with other stakeholders to urge the FCC to address our interference concerns. APCO has also put out a Technical Bulletin for current 6 GHz operators concerning steps they must take now to prepare for expected interference. APCO will remain in contact with public safety users of the spectrum and continue urging the FCC to act before it’s too late.


About the TabletopX Blog

A “Tabletop Exercise,” often shortened as “TTX,” is a discussion-based exercise frequently used by emergency planners. Led by a facilitator using a planned scenario, TTX participants describe the actions they would take, and the processes and procedures they would follow. The facilitator notes the players’ contributions and ensures that exercise objectives are met. Following the exercise, the facilitator typically develops an after-action report and conducts a debrief discussion during which players and observers have an opportunity to share their thoughts, observations, and recommendations from the exercise without assigning fault or blame.

Many of the attributes of a TTX are the same we seek to promote in the discussion generated from our blog posts. The goal is to capitalize on the shared experiences and expertise of all the participants to identify best practices, as well as areas for improvement, and thus achieve as successful a response to an emergency as possible.

TabletopX blog posts are written by APCO’s Government Relations team and special guests.