Beyond the Reporting Deadline: Shifting Focus to Monitoring and Enforcement of Emergency Caller Location Accuracy and Reliability

Today, 5 March 2024, marks the deadline for EU Member States to report to the European Commission on criteria adopted at national level for the accuracy and reliability of caller location information for emergency communications from landlines and mobile phones. With the box now ticked on this reporting obligation, the focus shifts to the monitoring and enforcement of these crucial standards.

In September 2023, EENA published a recommendation on emergency caller location information criteria for mobile-originated emergency communications. The recommendation is that Member States should lay down an initial set of criteria for the accuracy and reliability of caller location information that requires a “horizontal accuracy estimate of 50m for 80% of all mobile-originated emergency communications”. Setting the criteria is an obligation under Directive (EU) 2018/1972 as supplemented by Commission Delegated Regulation (EU) 2023/444.

The rationale for EENA’s recommendation was to initiate discussions on the need for European coordination on laying down these criteria in a harmonised way. This is to avoid a fragmented regulatory regime across Europe and to strive for continuous improvement in location accuracy and reliability. Fragmentation would not be in the interests of handset providers, electronic communications network and service providers or indeed individual EU citizens, whose personal safety might be better protected in one Member State when compared to another.

Several Member States, including Bulgaria, Croatia, Greece and Ireland, have taken EENA’s recommendation into account in national level public consultations on setting the criteria.

Why Mobile Caller Location Matters

The majority of emergency communications in Europe originate on a mobile device, including from roaming end-users travelling between Member States. 78% of emergency communications in 2021 were placed from mobile phones with the rate varying significantly across Member States, from 42% in Luxembourg and 63% in Germany to 96% in Cyprus and 99% in Czech Republic. The importance of accurate and reliable location for mobile callers cannot be understated when it comes to ensuring a swift and timely intervention.

In this blogpost, we will focus on international best practice approaches taken in the United States (US), Norway and Canada to monitor and enforce caller location criteria for emergency communications made using a mobile phone. The US and Norway have set criteria that are in line with EENA’s recommendation while Canada is moving swiftly in the same direction. It is hoped that these approaches will provide Member State authorities with food for thought to inform their own monitoring and enforcement programmes.

United States – Harnessing testing and reporting for effective regulatory oversight

The Federal Communications Commission (FCC) has continuously revised and approved the E911 framework to require delivery of accurate location information to PSAPs for mobile originated calls to 911. The FCC’s Sixth Report and Order sets out the current requirements. Mobile Network Operators (MNOs) providing services nationwide must achieve a 50-metre horizontal accuracy (X/Y axis location within 50 metres) or provide dispatchable location for 80% of all 911 calls made from a mobile phone. In addition,  there is a requirement to position handsets within a floor-level vertical accuracy of 3 metres (Z axis location) for 80% of all mobile emergency calls.

The FCC monitors compliance with these criteria through a variety of methods, including:

• Performance testing: The FCC conducts periodic testing of MNOs’ E911 location capabilities. This testing involves collecting location data from a sample of 911 calls and comparing it to the caller’s actual location. The FCC uses this data to assess the performance of different MNOs in meeting the accuracy and reliability criteria.
• Test Beds: MNOs participate in “Test Beds” that are carried out by an independent company established by the Cellular Telephone Industries Association (CTIA). To replicate a real-world environment for these tests, they are conducted in cities across the US which are representative of a selection of different morphologies (dense urban, urban, suburban, rural) using a variety of handsets. This Test Bed concept actually originated with the FCC’s Fourth Report and Order in 2015 which revolved around indoor location accuracy for 911 calls. The most recent testbeds have focused mainly on vertical location.
• MNO reporting: MNOs are required to report to the FCC, on a quarterly basis, with their E911 location performance data. This includes information on the number of calls, the percentage of calls with accurate location data, and the average accuracy of location data. Reports must be submitted to the FCC using this template. Copies of these reports must also be sent to NENA, NASNA and APCO. Reports from MNOs may be treated confidentially upon request. In addition to submitting quarterly live data on E911 call performance, PSAPs can also request live call data from MNOs and seek FCC enforcement of the requirements within their jurisdictions.
• Industry surveys: The FCC conducts surveys of industry experts to gather information about the state of E911 location services. This information is used to inform the FCC’s rulemaking and enforcement activities.
• Complaints: The FCC also investigates complaints from consumers about the accuracy and reliability of 911 location data. If a complaint is substantiated, the FCC may take enforcement action against the MNO.

The FCC can and does fine MNOs if they fail to meet any of their mandated obligations including failure to release E911 data in a “timely manner”.

Norway – Drive testing for better accuracy and reliability

Emergency caller location information in Norway must have a maximum margin of error of 50 metres for a minimum of 80% of emergency communications. This requirement is set out in Norway’s Electronic Communications Regulation section 6-2ª (in Norwegian).

The Norwegian Communications Authority (Nkom) is responsible for ensuring that MNOs comply with the accuracy and reliability criteria set out in the regulation. To achieve this, Nkom has carried out a drive testing programme.

The drive testing was conducted in 2021, 2022 and 2023. 280 emergency calls were made to the three Norwegian emergency numbers  (110, 112 and 113) from different geographic locations in Norway (representing different morphologies) using a variety of devices connected to all mobile networks. In addition, Nkom tested emergency calls from selected smart watches. The testing programme was carried out in cooperation with the emergency services and covered the following test scenarios:

• Positioning of the calling handset
• Transfer of the subscriber telephone number to the emergency services
• The transfer of the subscriber’s registered name and address to the emergency services (there are no anonymous subscriptions in Norway and operators must provide sufficient identity checks.)
• Correct routing of the call to the most appropriate PSAP
• The PSAPs call answering speed

PSAPs were on standby to receive calls from the test devices. When a call was received the call taker provided the most accurate position they received. The Nkom testing team compared this information with the actual location from which they made the call. The difference between the reported position and the actual position was recorded for each call.

If an MNO fails to meet the required accuracy and reliability standards, Nkom can issue warnings, impose fines, or require corrective actions. These actions could involve improving network infrastructure, enhancing location techniques, or implementing stricter internal control measures. Nkom publishes regular reports on emergency caller location accuracy, including performance data from each MNO and details of any enforcement actions taken. This transparency promotes accountability and encourages continuous improvement.

The tests carried out have revealed regulatory breaches and technical vulnerabilities both on the originating and terminating side of the emergency communications supply chain. Several actions were taken in the aftermath of the drive tests, all with the aim of optimising and improving the emergency communication service. The report from the last tests is available (in Norwegian) here.

Canada – Reporting obligations and technology adoption to improve location accuracy and reliability performance

In Canada, reporting obligations are regulated by the Canadian Radio-television and Telecommunications Commission (CRTC). MNOs are required to submit annual reports to the CRTC detailing their compliance with emergency services obligations, including the accuracy and reliability of caller location information. These reports may include performance metrics, improvements made, and challenges faced in providing accurate location information. MNOs are expected to continuously improve their location accuracy technologies and practices. This includes adopting new standards and technologies as they become available and as mandated by the CRTC.

Informed by these annual reports and other inputs such as technological advancements and changes in the emergency services ecosystem, the CRTC regularly reviews and updates caller location requirements. In 2003, the CRTC mandated the transmission of Phase I location (essentially the caller’s telephone number and Cell-ID) to PSAPs and, in 2009, Phase 2 location (specifically latitude and longitude) was mandated. Phase 2 also imposed certain confidence and uncertainty levels.

The latest location accuracy and reliability targets for the current reporting period are:

Handset-derived location (utilising AML) is due to be turned on in Canada by end of April 2024 and it is expected that the accuracy criteria set out in the table above will be made more stringent as a result thereby approaching EENA’s recommended criteria.

In addition, MNOs must describe in detail to the CRTC the process in place to quickly identify and correct cell site/sector misconfigurations, along with associated timelines and communications to stakeholders, and to provide this information annually as part of the wireless location accuracy reporting. This reporting requirement started in period 10 (1 January 2023 to 31 December 2023) and was introduced due to the impact of misconfigured cell site/sectors in the accuracy of location data provided with 9-1-1 calls. It was also introduced based on the argument that the implementation of 5G would bring thousands of new cell sites/sectors thereby increasing the potential for misconfigurations.

MNOs are also required to work collaboratively with PSAPs to ensure that location information is transmitted effectively and accurately.

Adapting best practices for monitoring and enforcement for the European context

The approaches adopted in the US, Norway and Canada offer valuable insights through their diverse approaches. The FCC utilises performance testing, test beds, MNO reporting, and industry surveys, while Nkom leverages drive testing programs and transparency through public reports. Canada has similar reporting obligations and, notably, has reporting obligations on cell site/sector misconfigurations.

Some may consider the act of reporting on the criteria to the European Commission as a final milestone. This step does not represent the conclusion of our efforts but the initial step on a path of continuous evaluation, adaptation, and enhancement of caller location information criteria. By adapting our strategies, leveraging the latest technology and fostering collaboration, we can create a culture of continuous improvement. Monitoring and enforcement activities are an essential component of this.

In the months ahead, EENA will engage with all stakeholders on monitoring and enforcement of caller location criteria. The matter will be discussed during the EENA Conference in Valencia (24-26 April, 2024) and may be the topic for an EENA webinar later in the year.

Striving for continuous improvement in location accuracy and reliability will enhance public safety across the continent and will ultimately lead to more lives saved.