Public safety groups opposed request by small wireless carriers t...

Communications Officials International (APCO) urged FCC last week to grant such relief on case-by-case basis. Tier 3 carriers seeking relief are smallest operators, with fewer than 500,000 subscribers. Several have proposed Commission forbear from enforcement action against Tier 3 carriers that couldn’t achieve precise caller location accuracy levels set out in FCC rules. “Plainly, the evidence of rural difficulties does not support the broad forbearance requested,” APCO filing said. “For that matter, there is no attempt to define ‘rural.’ Altogether, these gaps and ambiguities threaten to open floodgates that would wash away the Phase 2 regulations.” Public safety groups said petition “raises the specter” that Phase 2 deployment would “become so expensive as to make personal wireless service unaffordable to rural consumers.” That prospect is no less desirable than public safety agencies’ consuming hours or days looking for callers who can’t be found in emergencies, APCO said. “Throughout the petition runs the assumption that refined location determinations are less important in rural areas than in urban or suburban locales,” it said. “The assumption is unfounded. Each urban, suburban or rural environment presents a set of location challenges unique to the time and circumstances of the single call.” Verizon Wireless told FCC there wasn’t legal or policy justification for applying different technical and reliability standards for E-911 accuracy based on carrier size. CTIA told FCC it supported relief sought by Tier 3 carriers and said it was seeking forbearance for all carriers operating in rural areas, not just smallest operators. It reiterated some of same concerns raised by small carriers, including high cost of adding base stations in rural areas for network-based Phase 2 solutions for analog and TDMA systems. “Granting limited forbearance to all carriers operating in rural areas will provide sufficient time to determine appropriate Phase 2 technologies for those areas, while avoiding repeated investment in unsuitable technologies that may lead to subscriber rate increases or even discontinuance of service where cost recovery among a very small subscriber base is economically unfeasible,” CTIA said.