Wireless carriers asked FCC Tues. to clarify that LEC delays in providing network upgrades for Enhanced 911 services “constitute a defense to any enforcement actions taken against a wireless carrier for failure to meet Phase 2 deadlines.” In filing, wireless carriers and CTIA reiterated concerns that many LECs who provided automatic location information (ALI) databases still weren’t ready to provide Phase 2 services. ALI consists of more-specific latitude and longitude information under Phase 2 that’s handed off to emergency dispatchers when wireless subscriber dials 911. Among other concerns, CTIA said, some LECs now want to charge wireless carriers for ALI services, which it said violated FCC’s order in King County (Wash.) case. That decision had affirmed that 911 selective router maintained by ILECs was dividing line for E911 implementation costs between wireless carriers and public safety answering points (PSAPs). Carriers want FCC to issue directive that ALI database costs are to be allocated to PSAPs and requires LECs to finish upgrading databases “without delay.” Presentation at FCC was made by AT&T Wireless, Cingular Wireless, CTIA, Dobson Cellular, Intrada, Nextel, Sprint PCS, T-Mobile USA, Verizon Wireless, Western Wireless. Carriers said they wanted FCC to change rules to spell out that wireless carriers would begin delivering Phase 2 information within 6 months of PSAP request or within 120 days after PSAP was capable of receiving or using Phase 2 data, whichever was later. Presentation said LEC delays were affecting carriers’ ability to meet upcoming Phase 2 deadlines. “Although wireless carriers have spent countless hours and spent millions of dollars in an effort to meet the Phase 2 deadlines, LEC delays and charges will likely cause many wireless carriers to miss Phase 2 implementation deadlines,” filing said.
BellSouth (BS) told FCC it concluded that certain costs involving network upgrades to let wireless carriers deliver latitude and longitude of E911 caller’s location should be recovered from mobile operators. BS defended its allocation of upgrade costs among wireless carriers, operators of mobile position centers and public safety answering points (PSAPs) to allow E911 Phase 2 service as being in line with “Commission precedent.” BellSouth said in recent ex parte meeting at FCC it also covered whether there were legal barriers to it providing PSAPs with information beyond anything required under Phase 2 rules. CTIA also touched on LEC readiness issue in Sept. 12 letter to FCC in which it endorsed Verizon Wireless plan. That proposal would have FCC stipulate that carrier wouldn’t be in violation of Phase 2 deadline when PSAP couldn’t yet receive and use more detailed location information because PSAP itself or LEC hadn’t completed necessary network upgrades. Under existing FCC rules, PSAP request for Phase 2 service is “valid” if PSAP can show it has ordered necessary equipment and has vendor commitments to have it installed and operational within 6 months. CTIA Gen. Counsel Michael Altschul told FCC that often PSAP request wouldn’t lead to Phase 2 readiness within 6 months because: (1) PSAPs are required to receive commitments for suppliers only that gear will be operational within 6 months, but that often doesn’t preclude vendor from failing to deliver necessary equipment. (2) LECs often are unable or unwilling to provide necessary facilities or upgrades of automatic location information databases in 6 months after PSAP request for Phase 2 service. Altschul said some LECS had refused to make certain services available without tariff but “often make no effort to file such tariffs in an expeditious manner, placing CMRS carriers in a ‘Catch- 22’ situation where it is impossible to test Phase 2 equipment or provide Phase 2 information to PSAPs at the end of the 6-month deadline.”
Sprint PCS told FCC that recent round of filings on providing Enhanced 911 Phase 2 capability showed LECs hadn’t completed required network upgrades by June 30, delay that has disrupted E911 deployment schedules for wireless operators. “The Commission should act expeditiously to correct this situation,” Sprint said. Carrier said Commission had ordered Sprint and other operators to complete installation of all valid Phase 2 requests that were issued by June 30 by year-end. Delay by LECs in upgrading their automatic location information (ALI) databases needed to support Phase 2 “has negatively impacted Sprint Phase 2 deployment activity and continues to do so,” filing said. LECs late last month had responded to request by FCC Wireless Bureau Chief Thomas Sugrue to provide update on progress they had made on interconnections needed for E911 deployment. Public safety groups and some wireless carriers have pointed to readiness of LECs to provide their piece of E911 Phase 2 implementation as missing link in deployment lags, although LECs last month described extent to which they had put network and cost recovery components in place. Sprint said it agreed with most of Verizon Wireless plan floated to FCC recently on proposed change in that area. Verizon proposal would have FCC stipulate that carrier wouldn’t be in violation of Phase 2 deadlines in cases in which public safety answering point couldn’t yet receive and use more detailed location information because LEC or PSAP hadn’t completed necessary network upgrades. Sprint suggested several changes in Verizon’s plan. “This rule modification does not address the current scheduling crisis created by the LEC delay in deployment of Phase 2 systems,” Sprint said. If LECs complete proposed tariff filings and deployment schedules for database changes in Sept.-Oct. time frame, wireless carriers will be hit by glut of new, valid Phase 2 requests on which to act, Sprint said. Under Verizon proposal, those requests, which had been scheduled to roll out over 14-month period, could need to be deployed in as little as 90 days, carrier said. “Sprint’s deployment schedule cannot be compressed to this extent,” it said. “Accordingly, the new rule should be applied prospectively.”
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.
SBC told FCC it wasn’t trying to delay implementation of Enhanced 911 Phase 2, but was moving ahead to ensure that Phase 2 “can proceed without delay.” In Aug. 20 filing, SBC disputed several concerns raised by Sprint to FCC last week, particularly that SBC wanted to delay Phase 2 implementation in Mich. until Jan. 2003 when effective Phase 2 tariff would be in place. SBC told agency that Sprint took out of context its June 5 letter to Oakland County, Mich., Sheriff’s Dept. Sprint had cited letter in which SBC suggested that public safety groups meet with wireless carriers in state to negotiate commitment not to pursue implementation of FCC decision on cost recovery until alternative source of funding for LEC 911 service provider costs had been found. SBC countered in FCC filing that letter cited by Sprint was just part of discussion between SBC Ameritech and Mich. PSAP (Public Safety Answering Point) Tariff Task Force on issues related to Phase 2 cost recovery, not Phase 2 implementation. SBC said task force approached it and asked it to delay tariff filing for Phase 2 cost recovery because group wanted to jointly approach state lawmakers to amend state 911 law. Existing statute lets wireless carriers charge callers 52 cents, of which 25 cents is used by wireless carriers to recover 911-related costs. However, SBC said law didn’t let wireline carriers recover their costs from 911 fund, meaning SBC Ameritech Mich. had to recover costs from PSAPs through state tariff. SBC had proposed to task force that it delay filing proposed tariff if certain conditions were met, including having agreement of wireless carriers. SBC told FCC that task force rejected offer, so it planned to file proposed cost recovery tariff with Mich. PSC by late Sept. “SBC is unaware of any aspect of the Phase 2 scheme devised by the Commission that would deny SBC Ameritech the right to recover its costs associated with implementing that plan,” filing said. Sprint provided details last week to FCC about SBC’s discussions in Mich. and proposed interface agreement created by BellSouth related to E911. Sprint said FCC Wireless Bureau had sought more detailed information as part of follow-up to carrier’s quarterly E911 implementation report. Sprint had told Commission that documents showed that some providers of automatic location information databases planned to circumvent FCC decision on cost recovery and create additional hurdles to Phase 2 rollout.
Verizon Wireless floated plan to FCC for proposed change that it said would help to alleviate problem that has been standing in way of its meeting Enhanced 911 Phase 2 deadline of Dec. 31. Verizon asked Commission to stipulate 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.
Back-and-forth continues at FCC over role of LECs in providing Enhanced 911 services, with Sprint providing Wireless Bureau this week with documents it requested on arrangements with SBC and BellSouth. Sprint said that as part of its quarterly E911 implementation report filed earlier this month, bureau had sought copies of proposed interface agreement created by BellSouth and letter issued by SBC in June, both of which Sprint mentioned in its report. Sprint argued documents showed some providers of automatic location information (ALI) databases planned to “circumvent the FCC’s decisions on cost recovery and create additional roadblocks to Phase 2 implementation.” Wireless Bureau recently directed several large ILECs to make publicly available information related to interconnections needed for E911 deployment, with answers due Aug. 28. Sprint PCS in past has raised concerns at FCC on what it had said was lack of progress among LECs in upgrading 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 subscriber dials 911. Of 2 documents, Sprint told FCC: (1) SBC suggested in June 5 letter to Oakland County, Mich., Sheriff’s Dept. that public safety groups meet with wireless carriers in state “to negotiate a commitment not to pursue implementation of FCC’s King County opinion” until alternative funding source for LEC 911 service provider costs had been found. FCC’s King County decision in late July affirmed that 911 selective router maintained by ILECs was dividing line for E911 implementation costs between wireless carriers and public safety answering points. In letter, SBC proposed delay in filing its proposed wireless 911 tariff for Mich. until Jan. 2003. It also said it couldn’t provide Phase 2 service in Mich. without tariff addressing those costs. (2) Proposed BellSouth Phase 2 interface agreement suggested wireless carriers be charged 63 cents per data dip to cover cost of upgrading BellSouth ALI database. That would mean wireless carrier would pay 63 cents for initial transmission of latitude and longitude. Sprint told BellSouth in July 24 letter that it objected to that charge because it was counter to FCC’s decision on appropriate parties that must pay for ALI database upgrades.
FCC Wireless Bureau Chief Thomas Sugrue asked AT&T Wireless, Verizon Wireless and VoiceStream to provide information on what steps they were taking to reduce problem of unintentional 911 calls. In separate letters Wed., Sugrue said those calls could occur when preprogrammed 911 buttons on wireless phones were pressed accidentally and emergency dispatcher was dialed automatically. “Although preprogrammed 911 keys were initially considered to be a useful public safety feature for wireless phones, the number of unintentional calls and the burden they place on PSAP [public safety answering point] officials suggests that more harm than good has been brought about by this feature,” Sugrue wrote. National Emergency Numbering Assn. (NENA) has estimated that significant percentage of wireless 911 calls are unintentional. Problem, Sugrue wrote, is that typical PSAP practice is to remain on line to try to ascertain whether call is intentional. If E911 Phase 2 location capability is in place, dispatcher also may have to send emergency services to caller’s location if it can’t be determined over phone whether call was inadvertent. NENA sent letter to several wireless carriers in Dec. asking for information on what each had done or was willing to do to control problem and outlined several solutions for carriers and PSAPs to address together. “We support NENA’s efforts to address the unintentional calls problem and would urge that all wireless carriers, to the extent they have not done so already, take steps to eliminate the problem,” Sugrue wrote. He told each carrier that it hadn’t responded to NENA or provided information on what steps were needed to tackle problem. Sugrue asked for replies within 15 days of company’s receiving letter on information including: (1) Whether carrier had “communicated to its handset manufacturers its desire that mobile phones not be preprogrammed to dial 911 by pushing a single button on the keypad.” (2) Whether it had instructed its employees to deactivate auto-dial 911 feature if it came preprogrammed on certain phones. (3) Whether it provided subscribers with information on problem of unintentional 911 calls for existing and new handsets. (4) Whether it itemized 911 calls on customers’ bills to highlight problem. NENA raised such issues as possible solutions in its Dec. 12 letter to carriers.
Assn. of Public Safety Communications Officials (APCO) and National Emergency Number Assn. (NENA) wrote to FCC Chmn. Powell on group’s continuing concerns about pace of Enhanced 911 rollout, citing LEC upgrades as “the last remaining hurdle in many instances.” FCC Wireless Bureau Chief Thomas Sugrue recently directed largest ILECs to make publicly available certain information on interconnections needed for E911 deployment by Aug. 28. APCO and NENA also told Powell: “We urge the Commission to take affirmative action regarding carriers that are clinging to questionable location technologies and, as a result, are falling well short of implementation deadlines and accuracy requirements.” APCO and NENA said “most troubling problems” that remained for E911 implementation included failure of many LECs to cooperate with public safety answering points and wireless carriers or to provide on-time upgrades to their automatic location information (ALI) databases. Groups recently lauded Wireless Bureau letter to LECs asking for detailed information on their E911 deployment. “However, we believe that the Commission will need to consider taking further action, including adoption of provisions requiring LECs to proceed in a timely manner to provide necessary elements of Phase 2 operation,” groups said. They also urged Commission to take “a hard look” at Phase 2 rollout of E911 by GSM carriers using Enhanced Observed Time Difference (E-OTD) of Arrival technology. APCO said it still had petition of reconsideration pending on agency’s grant 2 years ago of waiver to VoiceStream Wireless. That waiver had extended certain Phase 2 implementation deadlines for carrier and allowed use of E-OTD technology. APCO and NENA raised concerns about implementation progress of VoiceStream, Cingular and AT&T Wireless. They said Cingular and AT&T Wireless recently submitted reports to FCC “indicating major E-OTD test failures, raising further questions regarding its deployment schedule and ultimate accuracy levels.” APCO and NENA called on FCC to resolve its petition for reconsideration and “to require VoiceStream to consider alternative technologies as possible replacements for E-OTD.”
FCC Wireless Bureau Chief Thomas Sugrue directed ILECs to make publicly available certain information related to interconnections needed for Enhanced 911 deployment by Aug. 28. Assn. of Public-Safety Communications Officials and other public safety groups have referred to LEC cooperation as “missing link” in some E911 deployment situations. ILECs’ provision of facilities and equipment needed to receive and use E911 data elements also is part of E911 technical inquiry being led by former Office of Engineering & Technology Chief Dale Hatfield. Sprint PCS also has raised concerns at Commission on what it has characterized as lack of progress among LECs in upgrading automatic location information databases needed to support Phase 2. “The Commission has found that ILECs have an obligation to provide nondiscriminatory access to and interconnection with their networks for the provision of 911 and E911 services to wireless callers,” Sugrue said in July 29 letter. Letter was sent to Sprint, BellSouth, Qwest, Verizon, SBC, Alltel. “To date, the Commission has not imposed on any ILECs any special obligations in connection with wireless E911, but has committed to monitoring their role in E911 implementation to determine whether additional obligations are necessary,” Sugrue said. He said ILECs were “integrally involved” in provision of E911 capability, with upgrades to ILEC services and facilities often required to enable LEC to pass E911 information from wireless carrier to public safety answering point (PSAP). “In light of the role played by ILECs in E911 deployment, we have concluded that certain information from ILECs should be made publicly available,” Sugrue said. He asked ILECs to provide information including location of each automatic location information (ALI) database, all PSAPs that it served, type of interface that had been or would be installed to pass along E911 Phase 2 information. Bureau also is seeking information on dates by which necessary database upgrades will be completed, interface that will be available for testing with wireless carriers, PSAPs or 3rd party vendors and interface that will be available for launch of live E911 Phase 2 service to subscribers. Bureau wants information on type of data that each ALI database will be able to receive and format in which company expects to receive data. “Identify the manner in which your company expects wireless carriers, public safety entities and/or 3rd party vendors to interconnect with the ALI databases and selective routers your company operates,” Sugrue said. He requested ILEC information explaining how costs of facility upgrades needed to support wireless E911 would be recovered, such as whether it would be through contracts or tariffs.