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FCC Seeks Comments on Proposed Framework for Next Generation 911 Deployment Provision
[September 16, 2014]

FCC Seeks Comments on Proposed Framework for Next Generation 911 Deployment Provision


(Targeted News Service Via Acquire Media NewsEdge) Targeted News Service WASHINGTON, Sept. 16 -- The Federal Communications Commission published the following proposed rule in the Federal Register: Facilitating the Deployment of Text to 911 and Other Next Generation 911 Applications; Framework for Next Generation 911 Deployment A Proposed Rule by the Federal Communications Commission on 09/16/2014 Publication Date: Tuesday, September 16, 2014 Agency: Federal Communications Commission Dates: Submit comments on or before October 16, 2014 and reply comments by November 17, 2014. Written comments on the Paperwork Reduction Act proposed information collection requirements must be submitted by the public, Office of Management and Budget (OMB), and other interested parties on or before November 17, 2014.



Comments Close: 11/17/2014 Entry Type: Proposed Rule Action: Notice of proposed rulemaking.

Document Citation: 79 FR 55413 Page: 55413 -55425 (13 pages) CFR: 47 CFR 20 Agency/Docket Numbers: PS Docket Nos. 11-153, 10-255 FCC 14-118 Document Number: 2014-21852 Shorter URL: https://federalregister.gov/a/2014-21852 Action Notice Of Proposed Rulemaking.


Summary In this Third Further Notice of Proposed Rulemaking (Third Further Notice), the Commission seeks comment on technical issues related to the provision of enhanced location information and support for roaming for texts to 911, as well as the capabilities of future texting services. Comments received will inform the Commission of the technological and business issues related to the provision of location and roaming support for text-to-911, and how text-to-911 may be applied to future texting services. If the proposals are adopted, they will enhance existing text-to-911 service and lead to improved emergency response.

DATES: Submit comments on or before October 16, 2014 and reply comments by November 17, 2014. Written comments on the Paperwork Reduction Act proposed information collection requirements must be submitted by the public, Office of Management and Budget (OMB), and other interested parties on or before November 17, 2014.

ADDRESSES: You may submit comments, identified by either PS Docket No. 10-255 or PS Docket No. 11-153, by any of the following methods: Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments.

Federal Communications Commission's Web site: http://fjallfoss.fcc.gov/ecfs2/. Follow the instructions for submitting comments.

People with Disabilities: Contact the FCC to request reasonable accommodations (accessible format documents, sign language interpreters, CART, etc.) by email: [email protected] or phone: (202) 418-0530 or TTY: (202) 418-0432.

For detailed instructions for submitting comments and additional information on the rulemaking process, see the SUPPLEMENTARY INFORMATION section of this document.

FOR FURTHER INFORMATION CONTACT: Dana Zelman of the Policy and Licensing Division of the Public Safety and Homeland Security Bureau, (202) 418-0546 or [email protected]. For additional information concerning the Paperwork Reduction Act information collection requirements contained in this document, contact Benish Shah, (202) 418-7866, or send an email to [email protected].

SUPPLEMENTARY INFORMATION: This is a summary of the Commission's Third Further Notice of Proposed Rulemaking in PS Docket Nos. 10-255 and 11-153, released on August 13, 2014. The full text of this document is available for public inspection during regular business hours in the FCC Reference Center, Room CY-A257, 445 12th Street SW., Washington, DC 20554, or online at http://www.fcc.gov/document/fcc-adopts-text-911-rules. The Second Report and Order that was adopted concurrently with the Third Further Notice is published elsewhere in this issue of the Federal Register. Parties wishing to file materials with a claim of confidentiality should follow the procedures set forth in section 0.459 of the Commission's rules. Confidential submissions may not be filed via ECFS but rather should be filed with the Secretary's Office following the procedures set forth in 47 CFR 0.459. Redacted versions of confidential submissions may be filed via ECFS.

Summary of the Third Further Notice of Proposed Rulemaking Introduction 1. In this Third Further Notice of Proposed Rulemaking (Third Further Notice), we affirm the Commission's commitment to ensuring access to emergency services for all Americans. The Commission's rules must evolve as legacy networks and services transition to next generation technologies, and as consumer expectations and needs evolve. Current trends in mobile wireless usage show the continued evolution from a predominantly voice-driven medium of communication to one based more on text and data transmissions. The need to provide text-to-911 service in a timely manner is made more pressing because many consumers believe text-to-911 is already an available service, because of the unique value of text-to-911 for the millions of Americans with hearing or speech disabilities, and because of the crucial role it can play in protecting life and property when making a voice call would be dangerous, impractical, or impossible due to transmission problems.

Background 2. In September 2011, the Commission released a Notice of Proposed Rulemaking (NPRM), 26 FCC Rcd 13615, which sought comment on a number of issues related to the deployment of Next Generation 911 (NG911), including how to implement text-to-911. In the NPRM, the Commission stated that sending text messages, photos, and video clips has become an everyday activity for mobile device users on 21st century broadband networks, and that adding non-voice capabilities to our 911 system will substantially improve emergency response, save lives, and reduce property damage, as well as expand access to emergency help, both for people with disabilities and for people in situations where placing a voice call to 911 could be difficult or dangerous.

3. In December 2012, AT&T, Sprint Nextel, T-Mobile, and Verizon Wireless entered into a voluntary agreement with the National Emergency Number Association (NENA) and APCO International (APCO) in which each of the four carriers agreed to be capable of providing text-to-911 service to requesting PSAPs by May 15, 2014 (Carrier-NENA-APCO Agreement). As part of the Carrier-NENA-APCO Agreement, the four major carriers committed to implementing text-to-911 service to a PSAP making a "valid" request of the carrier "within a reasonable amount of time," not to exceed six months. Carriers promised to meet these commitments "independent of their ability to recover these associated costs from state or local governments." The commitments specifically did not extend to customers roaming on a network.

4. Also in December 2012, the Commission released a Further Notice of Proposed Rulemaking (Further Notice), 27 FCC Rcd 15659, which proposed, inter alia, to require all CMRS providers, as well as interconnected text messaging providers, to support text messaging to 911 in all areas throughout the nation where PSAPs are capable of and prepared to receive the texts. The Commission defined interconnected text messaging applications as those using IP-based protocols to deliver text messages to a service provider and the service provider then delivers the text messages to destinations identified by a telephone number, using either IP-based or Short Message Service (SMS) protocols. The Further Notice noted the extent to which consumers had begun to gravitate toward IP-based messaging applications as their primary means of communicating by text, that consumers may reasonably come to expect these applications to also support text-to-911, and that consumer familiarity is critical in emergency situations where each second matters. To that end, the Further Notice sought to ensure consumers' access to text-to-911 capabilities on the full array of texting applications available today--regardless of provider or platform.

5. Recognizing that text-to-911 would not be rolled out uniformly across the country or across text messaging platforms, the Commission took steps to provide consumers with clarity regarding the availability of text-to-911. In May 2013, the Commission issued a Report and Order, 28 FCC Rcd 7556, requiring covered text providers to provide consumers attempting to send a text to 911 with an automatic bounce-back message when the service is unavailable. The Commission found a "clear benefit and present need" for persons who attempt to send text messages to 911 to know immediately if their text cannot be delivered to the proper authorities. The Commission noted specifically that, "[a]s these applications proliferate, consumers are likely to assume that they should be as capable of reaching 911 as any other telephone number." 6. In January 2014, we adopted a Policy Statement, 29 FCC Rcd 1547, stating that the Commission believes that every provider of a text messaging service that enables a consumer to send text messages using numbers from the North American Numbering Plan (NANP) should support text-to-911 capabilities. The Commission clarified that it intends to take a technologically neutral approach to any rules adopted for text-to-911 service, and it encouraged voluntary agreements to support text-to-911.

7. We also released a Second Further Notice of Proposed Rulemaking (Second Further Notice), 29 FCC Rcd 1547, seeking comment on technical issues for the implementation of text-to-911 service with respect to interconnected text providers, the provision of location information with texts to 911, and roaming support for text-to-911 service.

Third Further Notice of Proposed Rulemaking Enhanced Location 8. While we recognize that enhanced location information is not yet universally attainable for texts to 911 over either SMS or other messaging platforms protocols under development, we seek comment on the specific approaches and a likely timeframe for covered text providers to achieve the capability to provide enhanced location with text-to-911 communications. This additional functionality will enable PSAPs to dispatch first responders more directly and quickly to the scene of an emergency. We acknowledge the collaborative effort underlying CSRIC's report, CSRIC IV WG1, Final Report--Investigation into Location Improvements for Interim SMS (Text) to 9-1-1 (rel. June 19, 2014) (Enhanced Location Report), available at http://transition.fcc.gov/pshs/advisory/csric4/CSRIC_IV_WG-1_Task-1_Final_061814.pdf, and CSRIC's recommendation that the Commission "refrain from wireless E9-1-1 Phase II-like mandates" for SMS text to 911 service and instead encourage further development and implementation of more robust solutions. CSRIC's report, however, suggests that one CMRS provider can currently deliver enhanced location information, using a commercial location-based technology in support of SMS text-to-911. In light of our important public safety interest in delivering more accurate location information with texts to 911, and considering that enhanced location technologies already exist and that other standards development beyond the current J-STD-110 have been underway, we see no reason to delay the potentially life-saving delivery of enhanced location information.

9. We propose that, no later than two years of the effective date of the adoption of final rules on enhanced location, covered text providers must deliver enhanced location information (consisting of the best available location that covered text providers could obtain from any available location technology or combination of technologies, including device-based location) with texts to 911. We seek comment on whether solutions could be developed to provide enhanced location in this timeframe and, if not, what would be a suitable timeframe. Our ultimate location accuracy objective is to require covered text providers to deliver all communications with 911 with location information that is sufficiently granular to provide a "dispatchable address." 10. For purposes of a near-term requirement, we propose to use the term "enhanced location" to mean the best available location. We recognize that the granularity of the enhanced location may vary by text-to-911 session, according to the user's particular device capabilities and settings. In some instances, we would expect that the device would approximate the user's address, consistent with what a consumer could expect from commercial location-based services (cLBS) capabilities today. We believe an enhanced location requirement would provide substantial public safety benefits to consumers who need to reach 911 through text-capable communications. We seek comment on this assertion, particularly to the extent to which such improvements would result in tangible benefits with respect to the safety of life and property compared to the cost of meeting the proposed requirements.

11. Technical feasibility. The Policy Statement and Second Further Notice, 29 FCC Rcd 1547, indicated that "developing the capability to provide Phase II-comparable location information" with 911 text messages "would be part of the long-term evolution of text-to-911." The Second Further Notice requested comment on the provision of Phase II-equivalent location information with text-to-911 calls. In response, the majority of commenters indicate that delivery of enhanced location information is not possible at this time.

12. CSRIC's Enhanced Location Report assesses the capability to include enhanced location information for SMS text-to-911 services and addresses the limitations of the current standard, ATIS/TIA J-STD-110, underlying SMS text-to-911. In view of the differences between the SMS text platform and the CMRS network, CSRIC finds three key limitations contributing to the problem of delivering enhanced location information over SMS architecture: (1) The current standard does not include a specification for the emergency message interaction with the handset, such that an emergency text to 911 cannot enable location information by overriding user location privacy settings and GPS location capabilities enabled by the handset; (2) enhanced location information takes more time to generate than coarse location, such that relying on enhanced location to initially route an SMS text to 911 could delay the routing process up to 30 seconds; and (3) only some of the location platforms that are currently deployed have the technology necessary to generate enhanced location information. CSRIC's Enhanced Location Report concludes that "there is no solution for generating enhanced location in an SMS text to 9-1-1 session for any currently deployed systems that does not require user equipment (UE) changes, network changes, or both." 13. Although current text-to-911 deployments may not support enhanced location, CSRIC's report recommends several approaches that stakeholders could explore to provide enhanced location information during SMS text-to-911 sessions. In particular, CSRIC examines four approaches: (1) Network-based location; (2) handset-based approaches; (3) end-to-end text-to-911 with location embedded in the SMS message, and (4) a modified "embedded location" approach using a user-downloaded texting application. We seek comment on these different approaches, as described in the Enhanced Location Report, and whether they could support the delivery of enhanced location information with texts to 911 in a near-term timeframe. What challenges must be overcome and what are the costs associated with implementation of the different approaches? In what timeframe could these approaches be implemented? 14. We observe that using device-specific location appears to be technically feasible, given CSRIC's remark that handset-based location technology, "using cLBS methods, is currently being used by at least one U.S. CDMA carrier for network deployments supporting SMS text-to-9-1-1." We acknowledge CSRIC's findings that the delivery of more granular location information than coarse location continues to present challenges. For this reason, we believe that an enhanced location requirement that is premised upon the delivery of best available location, using any available location technology or combination of technologies, strikes a balance that promotes our important public safety objectives, while being practicable and reasonable within these potential limitations. We seek comment on how "best available" location information would be determined. Among multiple "available" locations, what would determine which available location information is "best?" What are the necessary conditions for a location technology to be considered "available," to the device, such that a covered text provider may use it for routing or providing additional location information? Are there any additional factors we should consider with respect to assessing what should be considered the "best available location" for a particular text-to-911 session? 15. In addition to the approaches examined by CSRIC, two commenters suggest that the delivery of some form of enhanced location information by CMRS providers is technically feasible in the near term. First, TruePosition contends that existing network-based U-TDOA location capabilities could be used to deliver location information, with "relatively minor development effort," for texts to 911. TruePosition asserts that, although "[t]he solutions produced by the voluntary Carrier-NENA-APCO agreement, and the J-STD-110 standard, do not currently define an interface protocol to retrieve sender/customer location information," those solutions provide a platform "to build a more permanent solution to the problem of identifying the location of the customer who has sent an emergency text message." We seek comment on the technical feasibility of TruePosition's proposed approach and whether it offers a path forward for providing enhanced location. Would the "silent SMS" approach be feasible for other location determination mechanisms other than U-TDOA, such as A-GPS? What standards development work would be necessary to implement such an approach? 16. Second, TCS asserts that what it characterizes as "updated Phase II compatible" location technology is readily available to CMRS providers as deployable cLBS platforms, and that such solutions can be deployed either by the user or the CMRS provider. According to TCS, these cLBS solutions support existing 2G and 3G systems, and are possible under the current J-STD-110. TCS's view appears to be consistent with CSRIC's reporting that the J-STD-110 architecture also "allows for routing based on a more accurate enhanced location," and that one U.S. CMRS provider is using "using cLBS methods." CSRIC observes, however, that while enhanced location may be possible where a cLBS platform is available, "based on a CMRS provider's existing network infrastructure, the availability to provide a cLBS platform can be limited or technically challenging." We seek comment on these particular implementation challenges, and whether it would be possible for covered text providers to deliver enhanced location information in this manner within a near-term timeframe.

17. Further, the comment record indicates that technical complexities exist for interconnected text providers to deliver enhanced location. For example, Microsoft submits that, for OTT applications, "the cell site location is not readily available" and that server-based implementation approaches would require testing of location accuracy information, as well as the creation of "standardized acquisition and transmission of that location information" through TCC gateways. Bandwidth contends that there is a need for location accuracy solutions that are consistent with both established technical standards supporting existing CMRS solutions and "a broad range of application-derived location solutions commonly used by today's OTT providers." TCS proposes that OTT providers leverage the existing J-STD-110 standard to require that "emergency text message requests re-use existing SMS APIs in the device, effectively changing the OTT text message interaction into an SMS message dialogue . . ." TCS submits that, although this approach "would require OTT text application software modifications," it "represents the shortest path to having support for emergency OTT text." We seek comment on the different approaches described by TCS, as well as any additional proposals that would resolve the technical issues of covered text providers in delivering enhanced location information.

18. Further Standards-Setting Work. Most commenters indicate that standards bodies and covered text providers will need more time to develop and implement the capability to deliver enhanced location information with texts to 911. Many of the commenters believe that, rather than investing further to modify the interim J-STD-110, the standards work should focus on a long-term approach that would incorporate the enhanced features and location capabilities that NG911 is expected to provide for more granular location information. For example, NENA supports a longer-term approach based on standards efforts that "would incorporate an integrated location standard which . . . would apply to both voice and text service providers." Additionally, CSRIC reports that modifying the J-STD-110 "would require substantial [3GPP] standards development work, requiring significant development costs and potentially lead to major operational impacts on existing network systems." We seek comment on the extent to which development of enhanced location solutions for the interim SMS standard would divert resources from NG911 solutions. We also seek comment on when the relevant standards work, referenced by the commenters, is likely to be completed, and whether covered text providers ultimately will be capable of providing dispatchable address information, consistent with the Commission's long-term goals.

19. We note that Verizon indicates there is "under development" standards work on the Global Text Telephony (GTT) standard. Verizon asserts that this effort focuses on providing capabilities for LTE networks "to include more precise caller location than cell site location by leveraging the same location solution currently under development for VoLTE." We seek comment on the current status of the GTT standards effort for the following potential capabilities: (1) Providing interoperability or interworking between text messaging platforms and E911 legacy and NG911 networks; and (2) enabling CMRS and other covered text providers to deliver granular location information to PSAPs as more CMRS providers implement LTE networks.

20. Further, the record indicates that LTE networks present the opportunity for providing enhanced location determination with text. We seek comment on what measures covered text providers would need to take to implement in LTE networks the ability to provide enhanced location. What would be the costs of implementing such capability? What should the Commission do to encourage the necessary standards work? 21. Similarly, we seek comment on the provision of enhanced location information with MMS-to-911 texts and for location determination of MMS callers. For purposes of providing enhanced location information, MMS-to-911 will need to be evaluated once ATIS develops such standard in which cost effectiveness of MMS is considered, as well as potential problems with receiving MMS at PSAPs. What is the status of standards work on MMS messaging to include enhanced location information? We also seek comment on what factors exist that could affect covered text providers' use of MMS to route texts to 911 with enhanced location information. Will the eventual sunset of SMS further our goal of providing dispatchable address information for communications to 911 on all text-capable media? We seek comment on the costs for covered text providers to develop, test, and implement the capability to provide enhanced location information using MMS.

22. Finally, the record reflects that the technological developments and standards-setting efforts on LTE networks, MMS, and multimedia message emergency services (MMES) have already commenced. With developments in the CMRS wireless industry to migrate to LTE networks already underway, and the continued evolution and growth of OTT text applications in response to consumer demand, we believe that a reasonable basis exists to anticipate that within the near future, standards bodies will be adopting or releasing standards that address the provision of enhanced location information for 911 text messages. We seek comment on this view.

23. Enhanced Location through the Use of Commercial Location-Based Services. cLBS may present a solution for covered text providers to deliver enhanced location information in the near term. In light of the significant potential that cLBS might offer, we seek comment on the technical, privacy, and security issues associated with using cLBS for text-to-911 enhanced location information. [1] CSRIC suggests that the use of cLBS platforms is limited and challenging. More specifically, CSRIC reports that, concerning cLBS support for A-GPS generated location information, "not all carriers have location platforms capable of providing A-GPS location fixes to support the [TCC]." 24. The record is mixed concerning capabilities for covered text providers to use cLBS platforms. T-Mobile urges that "[t]he Commission . . . ensure that any rules it adopts regarding SMS text-to-911 location information acknowledge the fundamental difference between Phase II E911 voice location estimates and cLBS-based enhanced location estimates," and that "those requirements must be grounded in the technical and economic limitations of the cLBS service." ATIS suggests that location information derived from cLBS may be a " `best available' location" and "not equivalent to the location information obtained for voice emergency calls." Similarly, CSRIC observes that CMRS providers do not exercise the same control over cLBS platforms as they do for E911 voice calls, and thus, "location estimates may or may not be as reliable or accurate" as E911 voice location technologies.

25. We seek further comment on how cLBS could be leveraged to provide enhanced location information for text-to-911 in the short term and more granular, dispatchable address information in the long term. While cLBS may deliver location information that is not equivalent to voice location, there are also many instances where cLBS could offer even more granular location than Phase II information provided with voice calls to 911. In fact, consumers today regularly use applications that leverage cLBS to pinpoint their location to a high level of precision. We recognize, however, that cLBS information may vary in quality and reliability. How likely is it that location information derived from cLBS will increase in reliability and accuracy over time? What additional standards work must be accomplished? What would be the costs for covered text providers to test and implement the capabilities that cLBS offer? 26. Privacy. Commenters submit that leveraging cLBS services for purposes of providing enhanced location information raises privacy concerns. For example, Verizon notes that, in order to deliver location information using cLBS, covered text providers may "need to maintain ongoing access to providers' and devices' commercial [LBS] capabilities," which "may require a user to turn off all the device's privacy settings with respect to all communications, not just 911-related communications." Sprint and other commenters observe that with cLBS, "a user is capable of disabling GPS location services on the device and there is currently no `override' that exists on most wireless handsets to enable GPS to function if a text message is directed to emergency services." CSRIC also reports that the capability to override privacy settings may not be possible, depending on the smartphone operating system and the device's equipment manufacturer.

27. We seek comment on what solutions need to be developed for cLBS platforms to address these privacy issues. What technological developments and standards work needs to occur to override privacy settings for SMS text-based applications over legacy networks in order for enhanced location to be acquired and transmitted consistently to PSAPs with texts to 911? How quickly could these modifications be made? We emphasize that any such override of a user's device settings should be limited to those instances where a user is sending a 911 text message, and for the sole purpose of delivering the 911 text message to the appropriate PSAP. [2] Similarly, in the long term, for advanced NG911-compatible networks, such as IP-based text over LTE networks, what technological developments and standards work by stakeholders must occur to enable overriding of privacy settings for emergency texts to 911? The record generally suggests that, at least for a certain subset of devices, covered text providers and OS providers routinely upgrade the firmware and OS software. Could any modifications to implement emergency overriding of privacy settings be accomplished in this manner? What are the specific costs that both firmware and software approaches would entail? 28. Finally, what measures can or should the Commission take to address Heywire's contention that OS providers and hardware manufacturers have been removing or disabling access to geo-location functions available to applications outside of the native pre-authorized applications? How many applications and what OS platforms have been affected by this? What coordination must occur to address the issue of privacy settings? 29. Security. The record further indicates that the technical and privacy issues in implementing enhanced location over cLBS also raise the issue of security. TCS contends that "application-managed location solutions place too much reliance on handset environment, configuration, and capability and are subject to security threats, including authentication and location spoofing." Motorola Mobility asserts that "[a]ny location privacy override solution for SMS to 911 must be thoroughly validated using elaborate regression testing," and that "[w]hile the [original equipment manufacturers] that develop smartphones could apply such rigorous testing to the system SMS [application], they have no control over the testing regimen applied to an OTT [application]." We seek comment on what solutions need to be developed for cLBS to enable enhanced location capability that is secure. What measures can the Commission take to promote secure enhanced location capability and guard against security risks such as location spoofing? What would the cost burdens be on covered text providers, OS providers, and other stakeholders? Should we task CSRIC with location issues further--particularly in the context of making recommendations for enabling the use of cLBS and addressing security concerns to provide enhanced location for texts-to-911? 30. Timeframe. Based on the CSRIC Enhanced Location Report and the record, we seek comment on the timeframe in which covered text providers could reasonably offer either enhanced location information or more granular location information sufficient to provide dispatchable address information for some or all text-to-911 users. Based on the record, if we wait for covered text providers to migrate from interim SMS solutions to 4G LTE solutions before including enhanced location, we may be looking at a time horizon of five years or more.

31. In light of the serious public safety implications, we seek comment on what can be accomplished to deliver enhanced location in a shorter timeframe. With respect to the timeframe to migrate to LTE, TruePosition contends it is "simply far too long to wait while tens of millions of wireless users are left without a Phase II-like location capability." We agree. While NENA asserts that a "Commission mandate for enhanced text location capabilities would, at this juncture, be premature," it notes that "multiple industry stakeholders have already begun developing solutions to enable more precise location capabilities. . . ." RWA suggests that its members will need "at least two years" to "be capable of achieving more precise location capabilities." Heywire adds that an "undertaking" to address OS providers and hardware manufacturers removing or disabling access to "geo-location functions" could take "at least two years," and that "until . . . a technical method" is found, "it would be impossible to establish a realistic timeframe. . . ." In light of these comments, and balanced against the significant public policy interest and statutory mandate to promote public safety, we believe that a two-year timeframe to provide enhanced location--from the adoption of final rules on this issue--should be reasonable. We seek comment on this view, as well as how the various factors, including privacy and security concerns, would impact the establishment of timeframes for covered text providers to deliver enhanced location information.

32. Confidence and Uncertainty. Finally, we seek comment on CSRIC's recommendation that "[a]lthough not all location platforms may be capable of delivering enhanced location information, when such information is available it should be delivered with uncertainty and confidence values." CSRIC recommends that the Commission "encourage appropriate standards development organizations to incorporate confidence and uncertainty values into existing standards for enhanced location when it can be provided." Is this a necessary component for the delivery of enhanced location with texts to 911? Additionally, CSRIC observes that only one Class of Service (CoS) designation is available under the interim J-STD-110 and recommends adding CoS values to assist PSAPs "in determining the best way to use additional resources to locate a caller in the event the location is not provided or the location that is verbally provided is inaccurate." We seek comment on CSRIC's recommendations and how these additional features would support the provision of enhanced location for texts to 911, and whether they would help PSAPs respond to texts to 911 by dispatching emergency resources more expeditiously.

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