CFA and other advocacy organizations respectfully respond to the FCC’s request for comments regarding the location accuracy “roadmap” submitted by the Association of Public Safety Communications Officials (“APCO”), the National Emergency Number Association (“NENA”), and the four national wireless carriers. The roadmap raises significant privacy related concerns that are not adequately addressed in the roadmap itself. In light of these newly raised concerns, privacy advocates urge the Commission to pass regulations that require commercial mobile radio service (“CMRS”) carriers and others to treat mobile 911 location information and National Emergency Address Database (“NEAD”) as protected information, to require that representatives of consumer privacy organizations be allowed to participate fully in the further development of improved E911 location accuracy, and to ensure that any final agreement(s) will be subject to further notice and comment.