Wireless carriers are backing request to FCC that seeks clarifica...

for PSAPs that FCC had created. Cingular Wireless also has filed petition for reconsideration, challenging overall decision by Commission on PSAP readiness and citing procedural and substantive grounds. Richardson, Tex., originally asked FCC to better define what constituted valid PSAP request for E911 service. Oct. decision by FCC now under challenge had said that PSAP submitted valid E911 request: (1) If any upgrades needed on PSAP network would be completed within 6 months of request. (2) If PSAP had made “timely request” to LEC for trunking and other facilities needed for E911 data to be transmitted. Assn. of Public-Safety Communications Officials-International (APCO), National Emergency Number Assn. and National Assn. of State Nine One One Administrators told FCC in comments that they disagreed with changes Sprint sought on LEC readiness part of order. Sprint said PSAPs should be required to document that necessary LEC upgrades will be completed within 6 months of E911 data request or LECs should publish their Phase 2 database upgrade schedule. “Such a LEC publication requirement should not, however, alter the basic obligation of carriers to respond to a PSAP request, so long as the PSAP can document that a database upgrade request has been submitted to the relevant LEC.” But CTIA said it agreed with Sprint petition to ensure PSAP request for Phase 2 E911 service was granted after PSAP verifies it was ready to use information. “Requiring wireless carriers to deliver Phase 2 services when the PSAP will not be capable of utilizing the data within the 6-month implementation period is a waste of resources,” CTIA wrote. Group said “despite the best intentions of the PSAPs,” they have record of not being able to receive and use Phase 1 data even if mechanism is in place for recovering costs of system upgrades. Even in states where PSAPs have access to state funding for preparing for E911 compliance, “it is anticipated that a majority of states have or will raid funds dedicated to wireless 911 to cover budget deficits,” CTIA said. To make sure carriers have protection from spending “unnecessary resources” and that PSAPs will be ready to use E911 data, CTIA said FCC should give wireless operators more time for installation when PSAP “fails to substantiate Phase 2 readiness.” CTIA agreed with Sprint proposal that Phase 2 service only can become operational when automatic identification location database capabilities needed from LECs have been upgraded for Phase 2. Nextel also filed comments siding with Sprint, saying valid PSAP request for E911 has to demonstrate technical upgrades by wireless carrier, PSAP and LEC. “If any prong is not in place, Phase 2 E911 cannot be deployed,” Nextel wrote. VoiceStream also stressed in comments that FCC can’t assume that because PSAP has requested database upgrade from LEC, that system will be in place in 6 months.