Wireless 911 Location Accuracy Requirements, PS Docket No. 07-114

Ms. Marlene H. Dortch


Federal Communications Commission

445 12th Street, SW

Washington, D.C. 20554

December 18, 2014

RE: Wireless 911 Location Accuracy Requirements, PS Docket No. 07-114

On behalf of the National Asian Peace Officers Association (NAPOA) and our Executive Board, I would like to thank you for this opportunity to provide our comments on the Wireless E9-1-1 Location Accuracy Requirements. 

Following a review of the Requirements document, it is apparent that the public would be better served through the implementation of a precise, dispatchable address-based network to assist first-responders in a critical emergency.  To this end, the Association of Public-Safety Communications Officials (APCO) International, the National Emergency Number Association (NENA) and the four national wireless carriers, including: AT&T Mobility, Sprint, T-Mobile USA and Verizon, joined collectively to announce a plan to improve wireless 911 call location accuracy. 

NAPOA recommends consideration of this initiative for the following reasons:

Necessary to save lives – In an emergency, either medical or police related, time is a critical factor.  Public safety rests on the ability of first-responders to arrive at the scene of an accident or police emergency in a timely manner;

State-of-the-art technology – The technology exists today to develop and implement viable solutions that enable dispatch centers to locate callers using mobile devices and cellular phones;

Consensus approach – Participation by public safety and major wireless services providers (WSPs) including: AT&T, Sprint, T-Mobile and Verizon, illustrates the importance of this initiative and the unified approach necessary to accomplish this objective; and,

Solution is practical, feasible and realistic – The Roadmap introduced through this initiative establishes a series of timelines to determine whether the location solutions meet the requirements as outlined, based on currently existing and deployed 911 location technologies.

NAPOA feels that an enhanced location-based system to accurately identify the location of wireless-based callers is long overdue and that implementation of such a system would serve the critical needs of all first-responders. 

NAPOA serves as the voice of over 3,000 Asian American and Pacific Islander (AAPI) law enforcement officers and agents in over 20 local chapters across the country.  The mission of NAPOA is to promote diversity within the law enforcement community and open doors for advancement through leadership training, education and mentorship.

If you have any questions, please do not hesitate to call me at (973) 997-1000, or via email at: tgmasters71@gmail.com.


Thomas Masters

Thomas Masters

Executive Director

National Asian Peace Officers’ Association