An amended FCC report to Congress on deployment of E911 Phase II ...
An amended FCC report to Congress on deployment of E911 Phase II services by Tier III service providers (CD April 7 p6) contains “2 factual statements” that “understate and reflect poorly on the efforts made by Tier III carriers…
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to deploy E911 Phase II service in a timely manner,” Rural Cellular Assn. (RCA) told the Commission in an ex parte Wed. First, RCA said, there are only about 166 separately owned Tier III service providers, not 390, as the Commission stated. “We assume the [FCC’s] source for the number of Tier III licensees was probably the Commission’s Universal Licensing System,” which “contains the names of many companies that are closely affiliated with one another,” RCA said: “There are a comparatively small number of separately owned Tier III carriers providing service in the United States and that number continues to decrease as consolidation in the industry continues.” The Commission’s report also said only 10 Tier III licensees are “providing Phase II service to at least one PSAP.” But RCA said “no fewer than 24” Tier III carriers provide Phase II data used by PSAPs to locate E911 callers. “That is a significantly different number in view of information reported by the National Emergency Number Association that only about 40% of PSAPs nationwide are capable of receiving Phase II data,” RCA said. That percentage is “considerably lower in rural areas, where most Tier III carriers operate,” it said. RCA also said it expects more waiver requests to be filed by rural wireless service providers, which can’t meet a deadline for deployment of Phase II services. “When a good faith and commercially reasonable effort has been made by the carrier,” the FCC should grant the requested relief, RCA said.