T-Mobile USA asked FCC to review Wireless Bureau decision that dismissed carrier’s request to modify its Enhanced 911 Phase 2 waiver. In application for review, T- Mobile said bureau’s order addressed only one of 3 requested changes in its E-911 implementation plan. In Dec., Bureau referred compliance by Cingular and T-Mobile with E-911 Phase 2 requirements to Enforcement Bureau for possible action. Both companies had asked separately for extensions of handset deployment dates for Enhanced Observed Time Difference of Arrival (E-OTD) technology. They sought interim benchmarks beyond what FCC granted in Oct. 2001 waivers for Phase 2 rollout. In Dec. 2001, T-Mobile told FCC it didn’t expect to meet Dec. 31, 2002, date for implementing E-OTD solution for all valid requests from public safety answering points (PSAPs) pending as of June 30. Bureau order issued last month said because T-Mobile told agency it couldn’t meet proposed date that had been part of its amended Phase 2 waiver request, it no longer was appropriate to address requested changes in E-911 waiver. But in filing Mon., T-Mobile said Bureau had addressed only its request for Dec. 31, 2002, deadline to implement E-OTD solution for pending PSAP requests. It said order didn’t directly touch on other parts of its request, including limited change in its network software solution (NSS) deployment deadline and E-OTD handset benchmarks. T-Mobile’s Phase 2 implementation plan for E-911 includes rollout of network-based NSS solution that would cover all network users, regardless of PSAP request, and would be accurate within 1,000 m. Second part involves introducing E-OTD-capable handsets combined with network upgrades to better pinpoint caller’s location. T- Mobile said bureau’s basis for dismissal, which was that carrier said it would meet Dec. 31 E-OTD rollout deadline, “has no bearing on the other portions of the request.” It said it met proposed deadline changes in its NSS deployment and E-OTD handset rollout. “The Bureau’s failure to address 2 of the 3 requested modifications clearly is prejudicial procedural error warranting reversal and the Commission’s review,” T-Mobile said. Carrier said its amended waiver request didn’t receive “hard look” required by past FCC cases. “It received ‘no look,'” it said.
Qwest told FCC that despite “good-faith efforts” to move Enhanced 911 Phase 2 rollouts forward, T-Mobile USA had tried to “blame” it for problems in providing wireless 911 service to certain public safety answering points (PSAPs) by end of 2002. Issue of ILEC readiness for Phase 2 deployment of E911 has been cited in past by some carriers and public safety groups as “missing link” for E911 rollouts. In Fri. filing at FCC, Qwest took issue with Dec. 10 letters from T-Mobile to PSAPs in its 14-state region. Qwest said T-Mobile informed PSAPs it wouldn’t be able to offer Phase 1 E911 services to them because Qwest had refused to provide those services over connection capable of handling Phase 2 location identification information. Qwest said T-Mobile painted “overall inaccurate picture.” It said it had advised T- Mobile to consider digital solution called noncall associated signaling to support wireless 911 deployments. Instead, filing said T-Mobile opted for use of analog-based technology called CellTrace, which was used to roll out Phase 1 E911 in Ariz., Iowa and Colo. “It was T-Mobile’s subsequent change in its deployment strategy for Phase 1 services from its original decision to proceed with an analog approach to one now involving digital technology that has in large part created the current difficulties in T-Mobile’s deployments,” Qwest said. In letter to Wireless Bureau Acting Policy Div. Chief Blaise Scinto, Qwest took issue with change in T- Mobile’s deployment strategy for Phase 1 E911 data. Qwest said while it technically was possible to deliver automatic location identification data on interface technology selected by T-Mobile, system identified information as Phase 2, not Phase 1, data. It said it became clear that E2 Plus interface wasn’t well-suited for Phase 1 deployments. “Qwest advised T-Mobile that, if T-Mobile continued to want to deliver Phase 1 data over an interface designed for Phase 2 delivery, it should make changes to correct the inaccurate characterization of the data,” Qwest said. It said T-Mobile hadn’t made those changes. Phase 1 of E911 rules requires carriers to supply 911 dispatchers location of cell site or base station receiving emergency call. Phase 2 requires more specific automatic location information. Robert Calaff, T- Mobile corporate counsel in Washington, told us Mon. that carrier was “perplexed that Qwest seems to be the only major LEC that can’t figure out how to do what we are trying to do here, which is to deliver Phase 1 information over the E2 interface.” Position of T-Mobile is that issue “is solely within Qwest’s capability and control because the problem that is potentially surfacing now is one that relates to the presentation of the location information that T-Mobile is delivering to the LEC.” That presentation capability is part of E2 interface itself and is programmed by Qwest and its 911 database vendor Intrado, Calaff said. “We are doubly perplexed because that is within T-Mobile’s control to solve,” he said.
FCC Wireless Bureau sought comments on Sprint PCS request for 6-month extension of deadline for ensuring that new digital handsets were local-capable by Dec. 31, 2002, under Enhanced 911 rules. Sprint Dec. 20 filed request to move deadline to June 30 to achieve 100% activation goal. Comments are due Jan. 24, replies Feb. 3. Sprint told FCC that extension of deadline was justified because of impact of recent communications market downturn and resulting loss of subscribers and negative growth rates that it had seen. Bureau said in notice late Fri. that Sprint contended that in current economic climate, location-capable phones were at competitive disadvantage because they were more expensive than other models. Sprint also told FCC it didn’t believe it could advertise benefits of E911 Phase 2-capable phones until more public safety answering points could process Phase 2 location data. Carrier said FCC already had given longer extensions to other companies using same technology. Sprint said it expected that all of phones it sold to distributors would be location-capable by March 31, but said it would take more time for distributors to sell out their remaining inventory that wasn’t compliant.
FCC Wireless Bureau late Fri. referred compliance by Cingular Wireless and T-Mobile USA with Enhanced 911 Phase 2 requirements to Enforcement Bureau for possible action. Cingular and T-Mobile separately had asked FCC in petitions for reconsideration to extend handset deployment dates for Enhanced-Observed Time Difference of Arrival (E-OTD) technology. Carriers requested interim benchmarks beyond what FCC had granted in Oct. 2001 waivers for Phase 2 rollout. Cingular this fall had told FCC that because of uncertainties over ability of E-OTD to satisfy Oct. 1, 2003, deadline for accuracy, it had suspended E-OTD infrastructure shipments. E-OTD is hybrid handset-network solution for locating wireless 911 callers. Ability of wireless carriers to roll out E-OTD technology in GSM portions of their networks has come under fire from public safety groups. In case of T-Mobile, last Dec. it had asked FCC to modify its E911 Phase 2 waiver, outlining proposed new deployment schedule for E-OTD. In report at FCC in Oct., T-Mobile said it didn’t expect it could meet Dec. 31, 2002, benchmark for implementing E-OTD for all valid requests from public safety answering points pending as of June 30, 2002. That proposed target had been part of T-Mobile’s request at FCC to amend its E911 Phase 2 waiver. Because T-Mobile informed agency it couldn’t meet proposed date, “we find it no longer appropriate to address T-Mobile’s amended request for limited modification,” bureau said in order, dismissing request as moot. “We refer issues regarding T-Mobile’s compliance with its Phase 2 obligations under its existing compliance plan to the Enforcement Bureau for possible enforcement action,” order said. In case of Cingular, in Nov. it filed petition for reconsideration of FCC order that had granted waiver request for additional compliance time for E911 Phase 2, including dates by which it had to begin selling certain levels of E-OTD capable handsets. While that petition proposed extended deployment dates, Oct. 2002 filing cautioned that it had halted E-OTD shipments beyond what already had been deployed and was exploring alternatives. In order, Wireless Bureau said it treated as “severable request” part of Cingular’s reconsideration petition that proposed revised handset rollout dates. Other issues remain pending before FCC, order said. In filing Fri., Cingular confirmed that it had decided not to deploy E-OTD in favor of True- Position network-based solution called Uplink Time Difference of Arrival (U-TDOA). Cingular said it had completed trial of U-TDOA in Wilmington, Del., in Oct., including 17 sites that covered 20 square miles. Data showed that 67% of calls were located within 47.1 m and 95% within 112.2 m, within FCC accuracy requirements for network-based Phase 2 solutions.
FCC opened inquiry Wed. into making additional spectrum available for unlicensed devices, including TV broadcast spectrum. Office of Engineering & Technology Chief Edmond Thomas cited Wi-Fi as example of kinds of technology that used cognitive, frequency-agile radios to share such spectrum with incumbents. FCC Chmn. Powell stressed item would balance how to use existing spectrum efficiently while not interfering with incumbents. Comr. Martin voiced concerns about unlicensed applications in current broadcast spectrum, particularly because inquiry comes during DTV transition.
AT&T Wireless told FCC recent report on Enhanced 911 by former Office of Engineering & Technology Chief Dale Hatfield underscored inadequate attention paid to “wireline technical issues.” Last month, Hatfield released results of inquiry on wireless E911, pointing to “seriously antiquated” wireline infrastructure for emergency calls. Comment period on report closed Fri. AT&T Wireless said report showed wireline technical issues still needing work included timing of upgrades and how ILECs planned to recover E911 costs. Company said FCC should “take steps to ensure that the responsibilities of standards-setting bodies are clarified and that there is better specification of E911 implementation standards.” Carrier said there was no industry consensus on delivery of “location reliability” information, meaning “there is little understanding of how to interpret this information and the degree to which PSAPs should rely on it.” That means individual public safety entities are deciding independently whether such confidence factors should be delivered to public safety answering points (PSAPs). AT&T Wireless said any steps FCC took as result of report should recognize investment carriers had made in responding to E911 Phase 2 requests from PSAPs. Rural Cellular Corp. (RCC) said it was encountering rural carrier difficulties outlined in report in meeting existing accuracy standards in E911 rules. Carrier said its rural base stations weren’t densely spaced and typically were linear in their layout. While that provided good coverage to small population centers, it didn’t accommodate triangulation techniques needed to pinpoint physical location of E911 caller, RCC said. “Not only is triangulation more difficult to accomplish with fewer cells, but the percentage-based accuracy requirements are very difficult for a rural carrier to meet,” it said. Nextel described progress it had made in several markets in rolling out Assisted-GPS (A-GPS) capability in its iDEN market. Nextel said it was experiencing “extensive end-to-end connectivity problems” related to: (1) Trunking between LEC’s regional automatic location identification (ALI) database and PSAP. (2) Configuration of LEC’s selective routers and ALI databases. (3) Interface between Intrado’s wireless national ALI database and LEC’s infrastructure. Like other carriers, Nextel stressed need for flexibility in E911 rules. It agreed with point in Hatfield report that carriers with low customer turnover rates could be penalized under rules because they could be forced to absorb costs to replace obsolete handsets if enough customers didn’t naturally leave their system. Sprint said it agreed with Hatfield conclusion that FCC should stay focused on implementation of Phase 2 services and resist pressure to place new obligations on carriers. Hatfield report said creation of National 911 Program Office in proposed Dept. of Homeland Security would be helpful, but might come too late if ultimately implemented. “As a practical matter, Phase 2 service may be largely deployed by the time a new federal agency could take action,” Sprint said. It still may be helpful to smaller, underfunded jurisdictions that would request Phase 2 service at later date, carrier said.
Sprint PCS told FCC differences with BellSouth over responsibility for costs to upgrade databases needed for Enhanced 911 Phase 2 rollouts had been resolved. FCC Wireless Bureau weighed in last week on dispute between LECs and carriers over responsibility for costs of changing automatic location information (ALI) databases used by public safety answering points (PSAPs) to locate 911 callers (CD Nov 4 p5). Sprint said hurdles to Phase 2 testing and implementation, and particular issues in deployment of Spartanburg-Greenville, S.C., markets, appeared to have been resolved. Sprint said that in informal e-mail and phone exchanges, BellSouth indicated it would allow Sprint to provide Phase 2 service under interconnection provisions of general subscribers services tariff. Sprint told FCC its understanding was that BellSouth didn’t plan to require new contracts with wireless carriers for ALI upgrades. “Although BellSouth may file revised tariffs to address the responsibility of PSAPs for ALI costs, Sprint understands that BellSouth does not intend to delay implementation of Phase 2 services while these tariffs are being prepared,” filing said. Before Wireless Bureau’s letter laying out FCC position, BellSouth had argued that Commission precedent supported recovering certain network upgrade costs for E911 Phase 2 from carriers. But Sprint PCS and Verizon Wireless had contended that FCC precedent indicated costs associated with such upgrades were purview of PSAPs. Bureau stipulated that in absence of agreement to contrary, ALI database upgrade costs lay with public safety entities, not wireless carriers.
FCC Wireless Bureau weighed in last week on side of mobile operators in dispute between LECs and carriers over responsibility for costs to upgrade databases needed for Enhanced 911 Phase 2 rollouts. ILECs typically provide needed changes in automatic location information (ALI) databases used by public safety answering points (PSAPs) to locate 911 callers. In recent filings, BellSouth argued FCC precedent supported recovering certain network upgrade costs for E911 Phase 2 from carriers. BS proposed recovering costs for E2 interface, which it will install to upgrade its database, via usage-based charge assessed on wireless carriers. E2 interface is used to send query from ALI database to mobile positioning center maintained by wireless carriers, requesting transmission of location information back to ALI database. But Sprint PCS and Verizon Wireless said FCC precedent indicated costs associated with such upgrades were purview of PSAPs. In Oct. 28 letter, Wireless Bureau Chief Thomas Sugrue said absent agreement among companies to contrary, FCC decisions on Phase 2 were that responsibility for ALI database upgrade costs lay with public safety entities, not wireless carriers. He said FCC view was that rollout of E911 remained purview of “cooperative joint efforts and good-faith negotiations” among all those parties. But he said FCC had directed Wireless Bureau, “in the event of an impasse in such negotiations that is delaying the deployment of wireless E911 services” to help resolve disagreements. Such impasse appeared to have been reached that’s holding back planned Phase 2 test in Spartanburg/Greenville, S.C. “It appears likely that failure to address this dispute promptly will result in delays in other Phase 2 tests and deployments,” Sugrue said. Past FCC order issued in response to request for clarification from King County, Wash., made clear that proper demarcation point for allocating costs between wireless operators and PSAPs was input to 911 selective router that ILEC maintained. Costs that order said were responsibility of PSAPs included ALI database, Sugrue said. His letter said E2 interface that was focus of current dispute was software upgrade to ALI database. “As such, costs associated with implementing the interface are the responsibility of the PSAP” under FCC decisions concerning King County, he said. BellSouth had argued FCC didn’t intend that PSAPs be responsible for E2 functionality because it went beyond existing 911 system to retrieve location information from mobile positioning center of wireless carrier. But in his letter, Sugrue said King County decisions stipulated demarcation point, with wireless carriers bearing E911 costs up to that point and PSAPs handling costs beyond it. “Aside from being inconsistent with the language of the King County decisions, BellSouth’s approach would fundamentally undercut the Commission’s purpose in setting a ‘bright line’ demarcation point,” letter said.
FCC clarified that 911 call-forwarding rule didn’t preclude wireless carriers from blocking fraudulent 911 calls from nonservice initialized phones under state and local law enforcement procedures. Commission said its determination to require forwarding of all wireless 911 calls without regard to caller’s service subscription status was intended to enable authentic emergency calls, not fraudulent or abusive calls. It said where public safety answering point (PSAP) had identified handset that was transmitting fraudulent 911 calls and made request to wireless carrier to block 911 calls from that handset in accordance with state and local laws, carrier’s compliance didn’t violate Sec. 20.18(b). FCC Comr. Martin said: “Harassing 911 calls from noninitialized phones are a significant problem for PSAPs, causing a disruption of emergency telephone services and a waste of public safety resources… This public notice should put an end to… confusion and make clear that PSAPs and carriers may block harassing 911 calls.”
Despite funding uncertainty for fiscal 2003, National Communications System (NCS) still plans to begin national rollout of initial operating capability of wireless priority service by year-end, Govt. Emergency Telephone Service (GETS) Dir. John Graves said Wed. He told Telecom Service Priority (TSP) Oversight Committee meeting at NCS hq in Arlington, Va., that 2003 capability for service designed to give priority to national security personnel and responders in emergencies still was on track because $208 million set aside to get program running was “any-year” money. Uncertainty involves $73 million sought by Bush Administration after Sept. 11 attacks that House and Senate conferees recently zeroed out of defense appropriations bill (CD Oct 15 p1). For initial capability, NCS is close to signing contract with T-Mobile USA and with Cingular Wireless, Graves said.