Cingular Wireless asked FCC for waiver of Phase 2 Enhanced 911 (E911) Oct. 1 deployment deadline and relaxation of accuracy requirements on temporary basis. Carrier contended waiver was needed because solutions it planned for location information technology didn’t now meet Phase 2 accuracy requirements and couldn’t be deployed by upcoming deadlines. Cingular wants waiver that would let it deploy Enhanced Observed Time Difference (E-OTD) technology for its GSM networks and switch-based location technology on TDMA networks. As for E-OTD, Cingular said that this was “only viable option” for its GSM network, and other GSM carriers planned similar systems. E-OTD at outset won’t meet FCC’s handset-based accuracy standards but Cingular said accuracy would improve as software was refined. At start, technology will supply accuracy within 100 m of caller location 67% of time and 300 m 95% of time. Cingular said “industry consensus appears to be forming that E-OTD handsets will satisfy the Commission’s accuracy requirements by October 1, 2003.” Phase 2 rules require accuracy of position enabled-handsets within 50 m 67% of time and within 150 m for 95% of calls by Oct. 1. Cingular is proposing to deploy E-OTD as part of 25% of all handsets sold by Dec. 31, 40% by March 31, 2002, ratcheting up to 100% by Sept. 30, 2002. Carrier is proposing “safety net” location solution similar to network software solution that was part of VoiceStream waiver granted by FCC. VoiceStream solution provides that GSM subscribers without E-OTD handsets could be located within radial accuracy of 1,000 m for 67% of calls. “This will ensure that location information is available for the embedded GSM base,” Cingular said. Carrier is migrating its network from TDMA to GSM, but no existing solution will meet Phase 2 requirements, it said. It proposes rolling out switch-based technology for TDMA that can locate callers within 250 m for 67% of calls and 750 m for 95% of calls. Other carriers that have waiver requests pending before FCC include AT&T Wireless, Carolina PCS I, Nextel. Only large carriers without waiver proposals are Sprint PCS and Verizon Wireless. Cingular said it was selecting vendor for its switch- based Phase 2 solution and then would begin building required databases. First databases are designed to be areas where public safety answering point (PSAP) has submitted E911 request that is at least 6 months old.
Public safety officials fired off angry letter to CTIA Pres. Tom Wheeler, saying they agree with his call for better cooperation on Enhanced 911 but were troubled by “tone and substance” of June 24 letters from Wheeler. Wheeler urged better cooperation in letters to Assn. of Public-Safety Communications Officials (APCO) and National Emergency Number Assn. (NENA) and urged public safety answering points (PSAPs) to make binding commitments on rolling out wireless E911 technology, although they remain unregulated by FCC. In part, Wheeler called for uniform implementation plan across more than 6,800 PSAPs and deployment of necessary upgrades. “We disagree with, and are frankly offended by, CTIA’s apparent effort to deflect criticism of carriers by suggesting that there needs to be a ‘binding and enforceable commitment’ by the PSAP community to make wireless E911 a reality,” public safety groups wrote to Wheeler. Letter was signed by APCO Pres. Lyle Gallagher, NENA Pres. Sharon Counterman and National Assn. of State Nine One One Administrators Evelyn Bailey. Letter ticked off incentives that PSAPs have to implement E911 that are centered around saving lives. “We are also deeply troubled by your implication that PSAPs and local governments have misappropriated the 911 fees collected through wireless telephone bills by failing to use those funds for wireless E911 upgrades,” letter said. “You appear to assume that implementing wireless E911 is the only expense that PSAPs incur and the only purpose for which 911 fees should be expended.” Letter notes that PSAPs respond to about 120,000 wireless 911 calls each day, task that is complicated by fact that dozens of calls can be received concerning same emergency. Public safety groups also contend that FCC policy changes haven’t contributed to slow carrier compliance because wireless operators have known about basic E911 requirements since 1996. In addition, groups questioned CTIA assertion that every wireless switch in U.S. is Phase 1 compliant, asking why some carriers haven’t provided Phase 1 service despite valid PSAP requests.
U.S. Appeals Court, D.C., handed decisive win to FCC Fri., upholding agency decision to remove carrier cost-recovery requirement as precondition to provision of Enhanced 911 service. To turn around slow rollout of E911 services, FCC had stripped away condition that wireless carriers didn’t have to meet E911 Phase 1 and Phase 2 requirements until guaranteed state or local govt. funding was in place. Action was driven by concern that cost-recovery requirement was slowing E911 deployment and that wireless carriers could recover such costs from subscribers because they weren’t rate-regulated. Rural carriers, including U.S. Cellular Corp., challenged FCC decision, based in part on concern that they had less dense subscriber base to pass on such costs to customers. In unanimous ruling written by Judge David Tatel, court concluded eliminating carrier cost recovery requirement “merely imposes the cost of E911 service on its beneficiaries.” Washington attorney Thomas Van Wazer, who argued case for U.S. Cellular, said carrier was “strongly” considering appeal to full 9-member D.C. Circuit.
FCC Wireless Bureau seeks comment on petition from Nextel, Qwest Wireless, Verizon Wireless and VoiceStream Wireless asking it to reconsider its May 7 letter saying wireless carriers were responsible for costs of all hardware and software components for 911 selective routers. Letter said Public Safety Answering Points (PSAPs) must pay for maintaining and upgrading E911 components including selective router, trunks between 911 selective router and PSAP, Automatic Location Identification database and PSAP customer-premises equipment. Companies said Bureau exceeded its authority because it wrote letter without notice and comment period. Petitioners also said decision ignored wireless carrier comments and said Bureau erroneously assumed E911 network didn’t include carrier’s mobile switching center to 911 selective router trunkline and discriminated against wireless carriers. Comments are due July 30, replies Aug. 14.
There should be more coordination between public safety answering points (PSAPs) and wireless industry, CTIA said in June 24 letters to National Emergency Number Assn. and Assn. of Public- Safety Communications Officials. Letter urged PSAPs to make binding commitments on rollout of wireless E911 technology, even though they aren’t regulated by FCC. “If we are to succeed in delivering enhanced wireless 911 services to the American public, it will require our mutual cooperation,” CTIA Pres. Thomas Wheeler said in letter.
Members of House Telecom Subcommittee voiced concern Thurs. that wireless carriers and 911 call centers wouldn’t meet Oct. 1 deadline for deploying Phase 2 of Enhanced 911 location capabilities. Ranking Democrat Markey (Mass.) warned “industry should not seek -- nor should the Commission grant -- waivers to rules merely for business convenience.” He cited what he called “manana” syndrome among carriers on implementing E911. “But when it comes to 3G, they want spectrum today. They stipulate that it’s a national priority.” Markey said he backed industry’s quest for more 3G spectrum, but said he would “like to see the same alacrity and aggressiveness” on public safety offerings linked to E911. Hearing focused on thorny implementation issues that face wireless industry less than 4 months before Phase 2 deadline, including equipment availability and readiness of public safety answering points.
Nextel, Qwest Wireless, Verizon Wireless and VoiceStream asked FCC Wireless Bureau last week to reconsider recent conclusion that mobile carriers were responsible for certain costs of Enhanced 911 wireline network. Bureau clarified last month where line was to be drawn for dividing costs of E911 Phase 1 network and database components (CD May 9 p6). In letter to King County, Wash., E911 program, Bureau Chief Thomas Sugrue said proper demarcation point for funding between carriers and public safety answering points (PSAPs) was input to 911 selective routers that ILECs maintain. Those routers receive 911 calls from LEC central offices and send them to specific PSAP that serves area of emergency caller. Four wireless carriers that filed petition said appropriate demarcation point for ascertaining PSAP costs was mobile switching center of wireless carrier. “At a minimum, the bureau is obliged to reconsider its conclusions because it did not consider and address highly relevant facts and arguments submitted by commenters in response to the bureau’s solicitation of public input on the King County request,” carriers said. They are arguing that bureau decision: (1) Was beyond scope of its delegated authority. (2) Wasn’t supported in FCC rules and record. (3) Constituted rulemaking for which “the full Commission must provide notice and comment.” Carriers contend numerous industry entities had sought demarcation point at mobile switching center. “Indeed, it appears from the letter that the bureau chose to ignore altogether the many filings opposed to the King County request,” carriers said. Among points raised in comments that carriers said bureau ignored were regulatory requirements that assign financial responsibility to PSAPs for transporting and processing data once carrier has made E911 Phase 1 data available at mobile switching center. In other areas, carriers said bureau could not wipe out meaning of FCC rules through interpretations. Bureau made “new policy choice” of who should bear costs of E911 wireline network, departing from previous decisions on how joint costs should be shared between carriers and PSAPs, petition said.
FCC asked for comments in Further Notice of Proposed Rulemaking on issue of nonservice initialized wireless phones used to make 911 calls. FCC seeks feedback on whether such phones should have capability so public safety answering points (PSAPs) could call back emergency caller, even though those phones didn’t have dialable number. In some cases, such phones were used to provide service by carrier but have been reissued under donor programs such as domestic violence protection. In other cases, handsets are newly manufactured 911-only phones that can’t receive incoming calls. Public safety entities had asked FCC to take another look at callback issue because noninitialized phones didn’t have dialable callback number for emergency response or in some cases didn’t provide accurate location information. In further notice, Commission seeks comments on possible technical solutions to callback issue. It tentatively concluded that all carrier-donated handsets should be labeled and initialized on limited basis so PSAP could return emergency call. It also proposed that said all newly manufactured 911-only handsets be labeled and provide for PSAP return calls. Wireless carriers have argued that no viable technical solution has been identified for allowing PSAPs to return calls, and developing one could divert resources from implementing Enhanced 911 mandates. But public safety entities have disagreed, saying solution exists or could easily be devised. Comments are due July 9, replies Aug. 8. Notice also seeks comments on how often such calls occur and whether variation could be used of temporary local directory numbers, which are used now for roaming calls.
Assn. of Public-Safety Communications Officials-International (APCO) applauded FCC Wireless Bureau decision last week concerning how certain Enhanced 911 expenses are to be divided between wireless carriers and public safety answering points. Bureau clarified where line is to be drawn for allocating costs of E911 Phase 1 network and database components in letter to King County, Wash., E911 program (CD May 9 p6). Letter stipulated proper demarcation point was input to 911 selective routers that ILECs maintain. “The FCC’s decision will single-handedly cut untold red tape from the process of implementing wireless enhanced 9-1-1 throughout the nation,” said APCO Pres. Lyle Gallagher. APCO pointed out that bureau decision sides with recommendations made by APCO, National Emergency Number Assn., National Assn. of State 911 Administrators.
FCC Wireless Bureau released separate orders Thurs. that require Nextel and AT&T Wireless, which have requested Enhanced 911 Phase 2 implementation waivers, to provide more information related to Phase 2 location technology testing. Nextel in Nov. had asked Commission for waiver of implementation of E911 Phase 2 services in advance of Oct. 1 deadline for making certain location-based information was available to public safety answering points. Nextel had sought waiver of implementation deadline to deploy its handset-based assisted GPS technology. Carrier has told FCC that field trials had shown that technology was only accurate E911 Phase 2 technology available to it. FCC order said Nextel didn’t describe field trials it had carried out, including results. Order sets out questions it wants answered as part of agency’s “ongoing evaluation” of readiness of E911 technologies. Information FCC is seeking includes: (1) List of all tests and studies of E911 Phase 2 location technologies Nextel conducted, including field testing, lab trials, feasibility studies to ascertain whether certain technologies complied with FCC requirements. (2) Results of tests and studies, including accuracy and reliability levels demonstrated in each test. (3) Current and expected availability of each location technology solution tested. (4) Publicly announced plans by Nextel to change air interface standards to CDMA from existing iDEN standard and how those changes would affect E911 Phase 2 deployment. Bureau said it would make that information available to public. Wireless Bureau is seeking similar information from AT&T Wireless, which also has waiver request pending. In separate order on AT&T, bureau also denied carrier’s request that certain information on tests and field evaluations be kept confidential. Bureau said AT&T didn’t meet procedural requirements for confidentiality and didn’t demonstrate by “preponderance of the evidence that the materials in question were entitled to confidential treatment.” Information sought from AT&T Wireless included data supporting its selection of mobile-assisted network location system technology for Phase 2 for its TDMA network. Other details carrier is ordered to provide include: (1) Information on what Phase 2 location technology solution AT&T plans to use for analog wireless phones and test results. (2) “Further information” on planned rollout of GSM network, including timeline, planned discontinuance of service on TDMA network, how GSM network would comply with Phase 2.