Achieving E911 Compliance with CTIA Location Testing

The E911 Mandate is More Than Just a Requirement

The Federal Communications Commission (FCC) mandates that all mobile phones must provide precise location data when a user places an Enhanced 911 (E911) call. This location data must meet strict accuracy thresholds and be delivered reliably, whether the call is made from a city block or a remote rural home.

The motivation behind this regulation is clear: emergency services can't afford to guess where a caller is. Reaching the right location with better accuracy can reduce response times and potentially save lives. But achieving that level of accuracy is far from trivial; it requires devices to integrate complex positioning technologies like A-GNSS (Assisted GPS), cellular triangulation, and Wi-Fi-based positioning.

To ensure consistency and reliability, the Cellular Telecommunications and Internet Association (CTIA) developed a rigorous OTA testing and certification program based on the FCC mandates. Their test plans for Wireless Device OTA Performance outline the comprehensive procedures, lab configurations, and test cases needed to validate location performance across technologies like A-GNSS, LTE, 5G, and Wi-Fi.

With the current unstable global situation and vulnerabilities in traditional GPS signals that can be jammed easily by bad actors, FCC put out its Sixth Further Notice of Proposed Rulemaking for E911 earlier this year (March 6, 2025). One of the main requests is to use more GNSS technologies to improve accuracy and reliability, e.g., GPS L5 band and Galileo (European satellite system), which are the new GNSS technologies that are included in the current CTIA test plan.

Why CTIA Location Testing Is Mandatory for E911 Compliance

For anyone designing or testing wireless devices for the U.S. market, it is crucial to understand why CTIA-mandated location testing is essential, and how test solutions like the Spirent 8100 system are vital in achieving that compliance. Wireless carriers in the US tend to rely on a device chipset's compliance to CTIA test plans to ensure the device performs well over-the-air (OTA) and achieves the recommended location accuracy. However, carriers will be penalized if devices on their network don't meet location accuracy requirements.

CTIA certification focuses on end-to-end OTA performance, which evaluates how the complete device behaves in real-world conditions, rather than just validating chip-level functionality. OTA testing in the lab measures performance of the GNSS antenna in an anechoic chamber to mimic real world by emulating 4G, 5G, and GNSS and also considers many other factors like the position of the device, RF circuitry, impact of the hand/head, cross talk, etc.

The certification process also includes specific conformance test plans for location technologies such as A-GPS L1, A-GPS L5, and Galileo E1. A device's location accuracy can be greatly improved by leveraging multiple satellite constellations (such as using Galileo and GPS), which are especially important in urban canyons or deep indoor scenarios. Because of this comprehensive scope, CTIA certification has become the gold standard recognized by carriers, test labs, and government regulators for determining location readiness and compliance.

E911 compliance isn't optional. It's enforced by the FCC, monitored by CTIA, and driven by carrier mandates. Devices that fail to comply can be rejected from networks, incur regulatory fines for the operators, or, most critically, fail users when it matters most.

The Latest Mandate from CTIA

In a major regulatory development, CTIA mandated OTA location testing for 5G devices as of October 31, 2024. This move reflects a broader industry shift toward mainstream carrier adoption of 5G, enforcing devices on their network be tested for 5G.

Why It's Critical Right Now

5G was introduced in 2018. However, the majority of the carriers relied on LTE predominantly until 2024, when 5G SA networks began to roll out. As a result, CTIA started to mandate testing 5G devices for location performance, which has triggered a significant market shift.

Moreover, CTIA is set to release a new version of the test plan in December 2025. Customers need a solution that can evolve with these plans and Spirent 8100 is already aligned with the upcoming specifications.

Who Needs to do CTIA Location Testing?

• Device Manufacturers: To ensure their handsets are accepted by carriers and can be sold in the U.S.

• Chipset Makers: To validate modem and GNSS functionality before integration into devices.

• Test Labs: Serve as authorized CTIA labs to validate device conformance.

Spirent 8100 Helps to Certify Compliance

The Spirent 8100 Location Test System is an industry leading, fully integrated system that emulates the entire wireless network environment-from GNSS satellites, 4G/5G networks, and Wi-Fi. It provides a controlled lab environment that precisely mimics the complexities of real-world conditions.

Key Features:

• End-to-End Location Testing: Supports LTE, 5G FR1 NSA/SA and A-GNSS systems.

• OTA Conformance: Fully aligned with CTIA and related specs.

• GNSS Integration: Leverages best-in-class simulation from Spirent's own GSS solutions.

• Network Emulation: Uses Spirent Landslide and other solutions to model RAN and core networks.

• Modular Design: Integrates multiple Spirent and third-party components into one cohesive testbed.

• Lab-Based Reproducibility: Eliminates the unpredictability of field testing by recreating real-world scenarios in a lab chamber (anechoic or reverberation).

The real power lies in the software orchestration layer that binds together components from different vendors and Spirent's own solutions - including satellite simulators, Wi-Fi emulators, and cellular core simulators.

This allows the Spirent 8100 to:

• Implement test plans quickly with pre-configured test packs, including CTIA requirements

• Automate complex test sequences

• Integrate with certified anechoic chambers

• Perform full conformance validation with minimal user interaction

Conclusion: The De Facto Standard

E911 compliance isn't optional. It's enforced by the FCC, monitored by CTIA, and driven by carrier mandates. Devices that fail to comply can be rejected from networks, incur regulatory fines for the operators, or, most critically, fail users when it matters most.

Spirent 8100 is the industry's most trusted, complete, and compliant solution for location testing. It is used by every major OEM, trusted by every Tier 1 carrier, and embedded in the workflows of certified test labs worldwide.

Whether you're developing a next-gen smartphone or testing modems for drones, if your product needs to pass CTIA's OTA location tests, the path leads through 8100.

Are you ready for the CTIA mandate? Spirent is. Learn more about Spirent 8100.