Before working in public policy, I was a Silicon Valley technology developer. When they learn this, people often ask me if I’m frustrated by the slow pace of policy. I usually say speed is only desirable when you’re moving in the right direction, which tends to be the exception more often than the rule in Washington. A good example is the FCC’s proceedings on Wireless E911 (FCC PS Docket 07-114).

The problem here is providing 911 with the information they need to do their job, which they understand as dispatching the right emergency service (an ambulance, a fire truck, or a police car) to the right location, with a realistic expectation of what they’re going to find when they get there. The 911 system was designed for a world in which telephones were in fixed locations, and we don’t really live in that world any more.

So the FCC issued a set of rules in 2010 for mobile networks that aimed to provide 911 operators with an equivalent to the wired location information they knew how to handle. As is typical in the FCC’s stove-piped organization structure, these rules came from the Public Safety Bureau, which means they weren’t informed by a broad perspective about wireless technology developments outside the public safety domain. As the commercial sector is very keen to offer location-based services to consumers, this was a major oversight. But the FCC has statutory authority to enforce its vision of location services on carriers, so its narrow vision trumps the broader vision of innovators. The FCC has also obtained additional authority for itself beyond the Communications Act by attaching conditions to mergers, such as Verizon/Alltell, relating to Wireless E911.

Briefly, the FCC has established two sets of rules of location accuracy, one for “network based” location services and the other for “handset based” location. The rules establish benchmarks that require X percent of calls to provide accuracy within Y meters in Z years. The numbers are squishy because small carriers have a hard time complying and because newer technologies such as 3G and LTE do a better job of providing location than older ones, and the small carriers are always behind the big guys. One of the reasons small, rural carriers are cheaper than larger ones is that the services they offer don’t really measure up; not only do you compromise coverage and call quality when you use a marginal carrier, you compromise your safety as well. But most of us don’t call 911 on a regular basis – you might call once in your lifetime – so this is a compromise that many people are willing to make.

If we look at the problem of location generically, it does not stand to reason that carriers are the best place to look for it. Carriers run towers, but the typical tower covers 1000 users, and they can be spread out over several square miles. Carriers provide most phones, but that’s changing as the BYOD (bring your own device) movement gathers steam and wireless technology standardizes over LTE. It’s not very useful to know where the tower is, and triangulating to a more precise location isn’t always possible, especially in remote areas. When triangulation is possible, it takes time to get a fix, and the 911 system is unfortunately setup to get all the information they ever get during a short call. The current 911 system is designed around the limitations of the PSTN, and is only just beginning to evolve along wireless norms (long after the people have mainly moved from wired phones to cellular.) The Enhanced 911 system (E911) is the attempt to catch up.

If I were designing E911, I would create a system for smartphones that essentially commandeers the phone and uses it to provide emergency services not only with precise location but with location history, audio and video streams, and other situational information the phone may have to offer such as altitude, temperature, heart rate, and fitness indicators. My phone knows more about me than I do in many respects, because I run fitness apps on it that record not only my location but my location history, my blood pressure, my heart rate, my weight, and my body composition. It also knows, or can know, many other things that might be useful to a paramedic or the medical staff at a hospital.  All this really takes is an app on the phone, an app at the 911 PSAP that can talk to it, and another app for the first responder; all with appropriate authentication, of course.

Our phones are often in contact with, or in the range of, a number of wireless services that can or do provide location information. Not only are there two GPS networks in space, there are increasing numbers of Wi-Fi access points and cellular femto-cells capable of broadcasting programmed latitude and longitude and/or postal address; all they need is a standard format and some motivation.

It would be trivial to build a device that plugs into a wall socket and broadcasts location over Bluetooth. Your smartphone wouldn’t even have to connect with it, the lat/long or address could be encoded in device’s name or metadata.  There’s no reason that something like this couldn’t be built into cars, buses, and subways as well. The first in-car GPS navigator I had was a battery-powered device that attached to my Blackberry Curve by Bluetooth; it worked reasonably well, but building it into the car would have been better. The additional cost would be pennies. It’s reasonable to build location sensing into cars to make tow service calls more helpful; these calls are many times more common than calls to 911.

So how does the location picture change if we change the obligations?

Suppose we make the provision of location a primary responsibility of building owners, vehicle operators, and pedestrians rather than of networks? I wouldn’t let networks and handsets off the hook, but I would be willing to allow them to satisfy their obligation by gathering and transmitting location from one or more widely used third party location services, such as the ones I’ve mentioned, or by their own devices to the best of their innate ability (GPS receivers for example.)

This is to say that location information is much more easily provided by the features of the environment that are in fixed locations and close to the user than it is by mobile devices or networks. The salient feature of the old 911 system was the fixed location of the desktop phone. Lots of things have that property. The salient features of the smart phone are its ability to sense information close by – such as the sound waves emanating from the user’s vocal cords – and to transmit this information to a remote end point, such as 911 PSAP.

Having solved the location problem by returning it to the place where it belongs, I would then proceed to redesign the 911 system internally. Rather than answering a call, grabbing some information instantly and then dispatching a team, why shouldn’t 911 make a connection to the caller and to the smartphone’s sensors and then re-route this connection to the emergency vehicle? This way the team could get the additional information previously mentioned and know exactly what they were getting into.

One problem with re-thinking 911 and location along these lines is the FCC’s lack of authority to force compliance with location by the people who own Wi-Fi access points, cars, and buildings, but there are a couple of ways around this: it could condition the use of unlicensed spectrum on accurate location beaconing, which would cover just about everyone. At the end of the day, however, force shouldn’t be necessary as the standards bodies would be willing to define formats and require the information to be sent.

Location is the kind of thing that serves a much larger interest than 911, and broad-based standards serve first responder interests better than the arcane and proprietary systems that form its history. Public Safety finally realized this when Congress forced them to convert from their unique little systems to LTE for FirstNet. The next step in the evolution of emergency services is to leverage the capabilities that advancing, standards-based technologies provide to the citizen. Rather than complaining that the American teenager has better communications than they do, they should refocus in using their new systems more effectively. Ultimately, public safety is obligated to connect to the citizen using the tools that the citizen uses, not the other way around.

Sometimes it pays to shift your viewpoint.