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Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Revision of the Commission's Rules to Ensure Compatibility with Enhanced 911 Emergency Calling Systems. PS Docket No. 07-114 JOINT PETITION FOR EXTENSION OF COMMENT AND REPLY COMMENT DEADLINES The Industry Council for Emergency Response Technologies (iCERT),1 the National Association of State 9-1-1 Administrators ("NASNA"),2 NENA: The 9-1-1 Association ("NENA"),3 the Texas 9-1-1 Alliance,4 and the Texas Commission on State Emergency Communications5 (collectively, "Petitioners") hereby respectfully submit this request for an 1 iCERT the Industry Council for Emergency Response Technologies is the exclusive trade association championing commercial public safety response technology providers and related organizations. iCERT improves the public safety ecosystem through ensuring that the needs and views of commercial technology providers are recognized and accommodated by all levels of government, driving continuous technology improvements, education, and helping our members reach their organic and marketplace growth objectives. 2 NASNA represents state 911 programs in the field of emergency communications. NASNA provides state 911 leaders' unique expertise to national trade associations, public policymakers, the private sector, and emergency communications professionals at all levels of government as they address complex issues surrounding the evolution of emergency communications. 3 NENA: The 9-1-1 Association improves 9-1-1 through research, standards development, training, education, outreach, and advocacy. Our vision is a public made safer and more secure through universally-available state-of-the-art 9-1-1 systems and trained 9-1-1 professionals. NENA is the only professional organization solely focused on 9-1-1 policy, technology, operations, and education issues. 4 The Texas 9-1-1 Alliance is an interlocal cooperation entity composed of 26 Texas emergency communication districts with E9-1-1 service and related public safety responsibility for more than 63% of the population of Texas. These emergency communication districts were created pursuant to Texas Health and Safety Code Chapter 772 and are defined under Texas Health and Safety Code Section 771.001(3)(B). 5 The Texas Commission on State Emergency Communications ("CSEC") is a state agency created pursuant to Texas Health and Safety Code Chapter 771, and by statute is the state's authority on emergency communications. CSEC's membership includes representatives of the Texas 9-1-1 Entities and the general public, and CSEC directly oversees and administers the Texas state 9-1-1 program under which 9-1-1 service is provided in 206 of Texas' 254 counties, covering approximately two-thirds of the state's geography and one-fourth of the state's population. iCERT I NASNA I NENA I Texas 9-1-1 Alliance I CSEC January 30, 2020 PS 07-114 1

extension of the comment and reply comment deadlines in the above-captioned proceedings, currently set for February 18, 2020 and March 16, 2020, respectively.6 The Petitioners hereby request that comments be due no later than February 21, 2020, and that reply comments be due no later than March 20, 2020. A short extension of the aforementioned deadlines will serve the public interest by allowing time for crucial policy, technical, operational, and business conversations to take place during key stakeholder meetings scheduled during the comment and reply comment periods. The Commission's Fifth Further Notice of Proposed Rulemaking, released November 25, 2019, raises a number of important legal, technical, operational, and business questions pertaining to the feasibility of advanced vertical location, mapping, and addressing services for 9-1-1. Answers to some of these questions lie outside the traditional 9-1-1 ecosystem, requiring participation from companies and public safety entities with expertise in three-dimensional indoor mapping. In addition, the Commission's proposals require in-depth consideration of existing standards and the extent to which they require modification. The opportunity to develop the record is made even more challenging by three major events in the 9-1-1 policymaking space. First, NENA's NG9-1-1 Standards & Best Practices Conference ("SBP") occurred January 20-23, 2020. SBP brings together technical and operational experts from the 9-1-1 industry to create and refine best practices, guidelines, resources, and documents that enable Next Generation 9-1-1 services, systems, and operators to function effectively and foster interoperability. The collective 9-1-1 technical and operational 6 See Public Safety and Homeland Security Bureau Announces the Effective Date and Comment Cycle for the Vertical Location Accuracy (Z-Axis) Fifth Report and Order and Fifth Further Notice of Proposed Rulemaking, Wireless E911 Location Accuracy Requirements, PS Docket No. 07-114, (January 16, 2020) ("PN"), referencing Wireless E911 Location Accuracy Requirements, Fifth Report and Order and Fifth Further Notice of Proposed Rulemaking, FCC 19-124 (rel. Nov. 25, 2019) amended by Erratum (rel. Jan 15, 2020) ("FNPRM"). iCERT I NASNA I NENA I Texas 9-1-1 Alliance I CSEC January 30, 2020 PS 07-114 2

expertise at this event is unparalleled, and the discussions that take place will surely affect 9-1-1 stakeholders' contributions to the record. Secondly, NENA's 9-1-1 Goes to Washington ("GTW"), which brings hundreds of 9-1-1 professionals together with government leaders to address today's most pressing 9-1-1 and emergency communications policy issues, occurs February 12-15, 2020. Many of these 9-1-1 professionals plan to schedule Ex Parte meetings during GTW to discuss important topics in indoor location accuracy discussions which will undoubtedly contribute to the record and better inform the Commission and interested stakeholders. Both SBP and GTW provide a setting where various expert stakeholders can communicate with each other to find points of mutual agreement on issues like those contained in the current FNPRM. Lastly, the Alliance for Telecommunications Industry Solutions ("ATIS") Emergency Services Interconnection Forum ("ESIF")7 has its in-person meeting February 25th-26th, 2020. ESIF the ATIS group tasked with developing Next Generation 9-1-1 and location accuracy requirements and solutions, as well as resolving technical and operational issues to facilitate interconnection of emergency services networks with other networks provides an important forum for information exchanges on 9-1-1 location standards. These exchanges will help clarify more clearly which changes in 9-1-1 standards, such as the industry E2 interface and z-uncertainty, are necessary to accommodate the Commission's new requirements and proposals. The Petitioners recognize that requests to extend filing deadlines are not routinely granted. However, the Commission has previously found that an extension is warranted when it is necessary to ensure the Commission receives full and informed responses and that the affected See https://www.atis.org/0 lcommittforums/esif/ iCERT I NASNA I NENA I Texas 9-1-1 Alliance I CSEC January 30, 2020 PS 07-114 3

parties have a meaningful opportunity to develop a complete record for the Commission's consideration.8 The Petitioners here seek an extension of time to allow interested parties to analyze the complex and expansive issues raised in the FNPRM regarding the evolving indoor location accuracy ecosystem and the feasibility of large-scale indoor 3D mapping and addressing. The Petitioners welcome this discussion and believe it is of paramount importance for the Commission to develop a full and complete record in this proceeding. Under these circumstances, Petitioners believe that a brief extension of time is warranted. 8 E.g., Public Safety and Homeland Security Bureau, Order Granting Request for Extension of the Reply Comment Deadline, DA No. 15-299 (March 6, 2015) (In the Matters of 911 Governance and Accountability and Improving 911 Reliability, Docket Nos 14-193 & 13-75)). iCERT I NASNA I NENA I Texas 9-1-1 Alliance I CSEC January 30, 2020 PS 07-114 4

Respectfully submitted, INDUSTRY COUNCIL FOR EMERGENCY RESPONSE TECHNOLOGIES Kim Robert Scovill Executive Director 1 Radburn Lane Newark, DE 19711 202.503.9998 executivedirector@theindustrycouncil.org NATIONAL ASSOCIATION OF 9-1-1 STATE ADMINISTRATORS Harriet Rennie-Brown Executive Director 1105 Hill St., Traverse City, MI 49684 517-243-2075 harriet.rennie-brown@nasna911.org NENA: THE 9-1-1 ASSOCIATION Dan Henry Regulatory Counsel and Director of Government Affairs 1700 Diagonal Road Suite 500 Alexandria, VA 22314 dhenry@nena.org iCERT I NASNA I NENA I Texas 9-1-1 Alliance I CSEC January 30, 2020 PS 07-114 TEXAS 9-1-1 ALLIANCE Michael J. Tomsu Vinson & Elkins L.L.P. 2801 Via Fortuna, Suite 100 Austin, Texas 78746 512-542-8527 512-236-3211 (fax) mtomsu@velaw.com TEXAS COMMISSION ON STATE EMERGENCY COMMUNICATIONS Patrick Tyler General Counsel 333 Guadalupe Street, Suite 2-212 Austin, Texas 78701-3942 512-305-6915 512-305-6937 (fax) patrick.tyler@csec.texas.gov