Verizon Wireless floated plan to FCC for proposed change that it ...

that carrier wouldn’t be in violation of such deadlines in cases in which public safety answering point (PSAP) couldn’t yet receive and use more detailed Phase 2 location data because LEC or PSAP hadn’t completed necessary upgrades to their facilities. Verizon said in Aug. 19 filing that action was “urgently needed” due to Dec. 31 deadline for filling certain valid E911 Phase 2 requests by PSAPs. Last fall, FCC issued order in response to request for clarification by Richardson, Tex., about what constituted “valid” PSAP request for E911 service. FCC said such requests were valid if any upgrades needed on PSAP network would be completed within 6 months of request and if PSAP had made “timely request” to LEC for trunking and other facilities needed for E911 data to be transmitted in first place. Verizon said its request would meet order’s goal of requiring licensees to begin Phase 2 deployment “in advance of actual PSAP readiness.” It touched on what had been more frequent E911 theme of carriers -- that LEC readiness was growing problem in terms of E911 readiness. Verizon said that since Richardson order was handed down in Oct., certain LECs had failed to upgrade their automatic location information (ALI) databases in timely way to pass those data to PSAPs, meaning Verizon hadn’t been able to provide “Phase 2 service to many PSAPs in the 6-month time frames” set out in its E911 Phase 2 waiver. Despite “best efforts” of public safety agencies and wireless carriers, Verizon Wireless said: “Phase 2 implementation cannot be completed without upgraded facilities and services provisioned by PSAPs from LECs and their own vendors.” It urged FCC to amend rules so carriers wouldn’t be deemed noncompliant for failing to meet E911 deadline if PSAP couldn’t receive or use Phase 2 data by deadline. Verizon sought 90 days to complete its work and testing after PSAP becomes ready. “In particular, no such violation should occur where such incapability is due to the LEC’s inability or unwillingness to provision facilities/service for the PSAP or is due to delays in upgrading the PSAP’s” on-site equipment, Verizon Wireless said. It said problem was that once it completed changes such as network upgrades for Phase 2 service, providing such E911 data required LEC to upgrade its ALI database. Only then could PSAP and wireless carrier take final steps to complete Phase 2 service, Verizon said. In many areas where it needs LEC service for that process, it said needed upgrades either weren’t complete or wouldn’t be finished until regulatory approval of tariff or PSAP acceptance of contract, “which may take months.” In case of SBC, Verizon said it had completed ALI database upgrades in some markets where carrier had Phase 2 requests, but had “failed to do so in most markets.” Verizon charged that SBC had turned down request to meet last month, saying it instead planned to file wholesale tariffs or negotiate interconnection agreements changes in its region. “To date, BellSouth has thus far offered merely to test its Phase 2 upgrades and only in South Carolina,” Verizon Wireless said. It said it hadn’t been able to move ahead to test Phase 2 service with BellSouth, delaying Phase 2 rollout in markets such as Orlando, Miami, Atlanta, New Orleans. Verizon said Qwest had said it should be able to deploy Phase 2 upgrades in its territory in Sept. as long as needed tariffs were accepted. Carrier said in several states in Qwest territory, tariff wouldn’t be filed until Sept.