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LECs OUTLINE RANGE OF COST RECOVERY METHODS FOR WIRELESS E911

SBC told FCC it had invested “tens of millions of dollars” to be able to provide Enhanced 911 Phase 2 capability. Similar filings outlining progress on interconnections needed for E911 deployment also were made by Alltel, BellSouth, Qwest, Sprint and Verizon in response to request by Wireless Bureau Chief Thomas Sugrue last month that they make that information publicly available. Public safety groups and several wireless carriers have cited LEC cooperation as “missing link” in some E911 deployment situations, which also depend on public safety readiness and wireless carrier deployments. Some concerns have centered on progress of LECs in upgrading automatic location information (ALI) databases needed to support Phase 2. ALI consists of more specific latitude and longitude information under Phase 2 that’s provided to emergency dispatchers when wireless caller dials 911. LECs outlined range of methods to recover costs of Phase 2 upgrades from public safety agencies and wireless carriers, including tariffs, interconnection agreements and existing contracts.

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SBC said any necessary database upgrades would be completed by Sept. 30 and interface would be available for testing with wireless carriers, public safety answering points (PSAPs) or 3rd-party vendors around Oct. 1. SBC estimated its interface would be ready for “live” E911 Phase 2 service to consumers around Nov. 1, with specific cutover dates to be negotiated between SBC and customer. Company said that “depending on state law,” it could “lawfully provide” service with existence and approval of permanent tariff, interim tariff or individual case-specific contract in case of retail offerings for PSAPs. For carrier-to- carrier offerings with wireless operators, SBC said it could provide service with interconnection agreement or, in certain states, tariff. As for recovery of costs from PSAPs, SBC said: (1) Ameritech Ill. filed temporary tariff Aug. 1 that runs for 90 days, allowing SBC to meet certain wireless 911 service requests while working with Ill. Commerce Commission and PSAPs on “outstanding issues.” (2) Southern New England Telephone in Conn. and Ameritech Ind. will rely on existing contracts. (3) SBC plans to file tariffs in Ark., Cal., Mich., Mo., Nev., Ohio, Okla., Tex. and Wis. by mid-Oct. In recovering E911 costs for wireless carriers, SBC said “predominant form” of cost-recovery was through interconnection agreements, although many states gave mobile carriers ability to purchase from tariffs. Tariffs involving wireless carrier cost-recovery will be filed in Conn., Ind. and Mich. by Sept. 30, SBC said, and in Ark., Kan., Mo., Nev., Okla. and Tex., by mid-Oct. “Interconnect agreements do not need to be amended to reflect wireless 911,” SBC said.

BellSouth said any costs needed to upgrade ALI database to make sure it could receive latitude and longitude information and translate it into format that PSAP could accept would be recovered from PSAPs under BellSouth general subscriber services tariff for extended ALI under what company called “one-time, nonrecurring charge.” Costs associated with interface device and accompanying software will be recovered from wireless carriers through interface agreement, BellSouth said. Both wireless carrier interface agreement and agreements involving how routers to ALI databases are being revised, it said. Revised agreements are expected to be finalized by Sept. 16, company said.

Sprint told FCC it had national ALI database that it expected to upgrade by Oct. 15. That database has been tested with 3rd-party vendors Intrado and TCS and will be made available for testing “with any wireless carrier, PSAP or third-party vendor” operating in Sprint’s local territories by mid-Oct. It told FCC that necessary database upgrades were continuing and would be completed by Oct. 15, when Phase 2 wireless data elements could be delivered to PSAP. Sprint said it hadn’t determined whether there would be new charges for connectivity to wireless carrier databases. “Sprint is in the process of identifying wireless costs and their recovery,” it said. “A decision has not been made regarding passthrough charges when Sprint is the host database provider.” Sprint said it continued to examine requirements to provide Phase 2 wireless service and expected its first tariff covering Phase 2 wireless charges to be submitted by end of Sept. “Sprint does not anticipate charging wireless carriers,” filing said.

Qwest told FCC it had taken position that software upgrades to ALI database were responsibility of PSAP and hardware upgrades to connect to ALI database were domain of mobile positioning center provider or wireless carrier. Qwest said interface it had chosen to pass Phase 2 information along to PSAPs, based on E2 Plus protocol, would be available for PSAPs, 3rd-party vendors and wireless carriers by mid-Sept. It said hardware upgrades were completed in 2nd quarter for its database. “Qwest has determined that 35% of the E2 Plus costs are software and 65% are hardware and will be seeking cost recovery from the respective entities according to that allocation,” filing said. Costs of software portion of E2 Plus upgrade, as well as costs to troubleshoot change for public safety agencies, will be recovered through new product offering to PSAPs, Qwest said. Unless state PUC requests otherwise, product will be offered through pricing on individual basis, Qwest said. Hardware part of costs of that upgrade will be priced through interconnection agreements with wireless carriers, it said.

Verizon said it now supported wireless E911 implementation for 2,000 PSAPs. “With the limited exception of 11 grandfathered systems that cannot be upgraded, all other Verizon-operated databases have been upgraded and all interfaces are ready now for testing and launch of E911 Phase 2 service,” company said. “Verizon is ready to handle all PSAP wireless requests for the service.”