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AT&T WIRELESS SEEKS E911 WAIVER FROM FCC RELATED TO GSM PLANS

AT&T Wireless became latest carrier last week to seek waiver of FCC’s location accuracy requirements for Enhanced 911 Phase 2, seeking time to deploy handset-based technology through its GSM network and network-based solution for its TDMA customers. AT&T said its request was similar to conditional waiver for hybrid handset- and network-based solutions that agency granted to VoiceStream last fall. Request came at time that Cingular Wireless also appeared to be entertaining similar waiver request at FCC, although spokesman said Fri. that carrier hadn’t yet made decision. Groups representing public safety answering points that field 911 calls have objected to such waivers, raising concerns whether Commission’s upcoming deadline for E911 Phase 2 would be met.

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FCC Wireless Bureau opened comment period for AT&T request Fri., with comments due May 7 and replies May 21. AT&T Wireless is seeking waiver that would allow it to deploy hybrid network and handset-based technology called Enhanced Observed Time Difference (E-OTD) in its GSM network and network location system for its TDMA system. Phase 2 of E911 requires carriers to pinpoint location of emergency caller within more precise parameters than first phase, including locating 67% of position-enabled handsets within 50 m of caller’s location by Oct. 1. “AT&T claims that it faces circumstances similar to VoiceStream and that, while E-OTD ultimately will meet and even exceed the Commission’s accuracy requirements, AT&T requires a temporary waiver of the Commission’s accuracy rules for handset-based location technologies,” FCC said. AT&T told Commission that network-overlay solution for its existing TDMA network would bring E911 Phase 2 service to customers in shortest time frame, with initial deployment by end of year and systemwide deployment by first quarter of 2002. AT&T said that solution wouldn’t satisfy FCC location accuracy requirement for network-based solutions of 100 m for 67% of calls and 300 m for 95% of calls. However, it said its proposed system would provide accuracy level comparable with other network-based technologies it had tested. AT&T said its solution would provide location accuracy of 250 m for 67% of calls and 750 m for 95%.

Assn. of Public-Safety Communications Officials-International (APCO) was studying details of AT&T Wireless request Fri., said Washington attorney Robert Gurss, counsel to APCO. “Generally we are very troubled by any request to extend the deadline,” he said. “We're certainly very concerned that other carriers might take similar steps and seek extensions. For the whole E911 process, every month it gets delayed is another month that PSAPs go without the ability to locate callers.” For handset-based solutions, delay creates more time for handsets without E911 Phase 2 capability to be sold on market, he said. “We are very anxious to get the process moving,” he said. Request from large carrier such as AT&T Wireless is “deeply troubling,” he said.

AT&T told FCC hybrid solution worked best for E911 Phase 2 based on plans announced last fall with Japan’s NTT DoCoMo to develop next-generation wireless services in U.S. For AT&T Wireless, that means that to usher in high-speed data services, it planned to overlay GSM/General Packet Radio Services platform on its existing TDMA network. Hybrid handset- and network-based E- OTD solution is needed for GSM network, similar to conditional waiver that VoiceStream received last year from FCC for hybrid solution. “In contrast to VoiceStream, however, AT&T has the unique opportunity to make E-OTD available in its GSM network upon deployment of the GSM air interface,” AT&T Wireless said. It said it was working with its GSM vendors to require contractually that GSM infrastructure be E-OTD equipped when installed and that GSM handsets sold to its subscribers be location-capable. Although E- OTD eventually will exceed FCC’s location accuracy mandates, carrier said it needs “temporary waiver” of accuracy rules for handset-based technologies.

Cingular told FCC in ex parte filing last week that it also was mulling use of E-OTD handsets for its GSM markets and was monitoring field trial results for that technology. Carrier said it was examining performance of those handsets in mobile environment, such as when subscriber was driving in car. “Cingular is still reviewing Phase 2 options for its TDMA markets with a final decision expected before late spring,” carrier said. Cingular said it was considering potential waiver petition for Phase 2, “for instance, if E-OTD handsets are not available during the fourth quarter of 2001.”

Separately, Wireless Bureau said Fri. it would seek comments through April 23 on petition filed Thurs. by Richardson, Tex. City wants FCC to clarify process by which public safety answering point (PSAP) requests Phase 2 E911 service from wireless carriers. Richardson essentially wants confirmation that PSAP makes valid request for this service by informing carrier that necessary equipment upgrades for Phase 2 service will be finalized before delivery of service by carrier and by having adequate cost- recovery mechanism in place to upgrade equipment so it can receive more specific location information. City contends that carrier that receives such request must deliver Phase 2 service within 6 months or by Oct. 1, whichever is later, so that service can be available after PSAP upgrades its equipment. Request for clarification stems from city’s request to VoiceStream last month. City said carrier responded that its request was invalid because PSAP wasn’t currently capable of receiving and using Phase 2 data, even though city told VoiceStream that by time data actually were delivered its equipment would be ready. Question is one of timing, with Richardson telling FCC that VoiceStream believes carriers don’t have to bring Phase 2 service to PSAP until latter has completed its equipment upgrades. City wants FCC to spell out that carrier must do work needed to bring Phase 2 to PSAP at same time as PSAP is completing its upgrades.

Despite waiver request, AT&T Wireless still received kudos last week from APCO for carrier’s decision last month on cost- recovery mechanisms related to Phase 2. APCO praised company’s decision to stop charging PSAPs for E911-related upgrades. AT&T Wireless told FCC recently it no longer would charge PSAPs for costs of upgrading LEC facilities for delivering E911 calls. Policy change took effect March 1 and applies to costs of upgrading LEC facilities for delivering E911 calls from mobile switching center to LEC’s selective router. “AT&T Wireless will now assume responsibility for these costs,” carrier told Commission.

“We're certain that the transition to Phase 2 will be smoother in areas served by AT&T as a result of their proactive initiative regarding Phase 1,” APCO Pres. Lyle Gallagher said. He said last week that he hoped other carriers would follow AT&T’s lead. AT&T Wireless (AWS) told FCC Wireless Bureau Chief Thomas Sugrue last month that it had previously collected 1 cent per subscriber per month from each PSAP that had requested Phase 1 service in jurisdictions in which cost-recovery mechanisms were implemented. “This new nationwide policy is a departure from the position AWS took” in past, company told bureau. “AWS has adopted the new policy in an effort to expedite Phase 1 deployment, which has, in some cases, been delayed as a result of the parties’ inability to reach agreement on this issue.”

Meanwhile, as counterbalance to waiver requests, vendors such as Qualcomm have pointed out that GPS-enabled chip sets are being sent to manufacturers in volume. Issue is “chicken-and-egg” problem because other vendors have indicated they can’t begin shipping in volume until they receive carriers’ orders and carriers have said they can’t move ahead in earnest with deployment until equipment is available, source said. Qualcomm’s position location technology went online in Japan last week and GPS-enabled phones will be available in U.S. in time to meet FCC mandate, said Jonas Neihardt, head of Qualcomm Washington office. “We were able to achieve this because we made it a priority and if other companies make it a priority they can achieve it too,” he said.