Public safety groups opposed request by small wireless carriers to FCC to forbear from applying certain Enhanced 911 Phase 2 accuracy requirements. National Emergency Number Assn., National Assn. of State Nine One One Administrators and Assn. of Public Safety 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.

FCC Wireless Bureau extended deadline for comments and replies on its further rulemaking on possible revisions in its enhanced 911 rules. New deadline for comments is Feb. 18, replies March 11.

Bad power module in piece of essential equipment at Verizon switching center in N.Y.C. impaired phone service to more than 100,000 customers in Manhattan for 2 hours Jan. 24. Power supply module for piece of equipment that connected local switch to other switches failed at 1:30 p.m. in Verizon office on E. 30th St. Customers in 10-block radius around Verizon office found they could call only 911 or other customers served by same switch, but calls from or to other parts of city couldn’t go through. Problem was corrected by 3:30 p.m. when faulty power supply module was replaced, Verizon said.

Motorola told FCC it supported OnStar request for clarification that telematics systems embedded in vehicles that communicated with emergency call centers weren’t considered “handsets” under Enhanced 911 rules. Point of clarification sought is that embedded telematics systems aren’t covered by E-911 obligations and activation timetables under Phase 2 for licensed wireless carriers. “The telematics safety and security services systems are well established, their performance is well known and there is no demonstrated need to disrupt or impose new regulatory burdens on their operations,” Motorola said. FCC rules define location-capable handsets as “portable or mobile phones” that have special location-determining hardware or software used to pinpoint E-911 calls. Embedded telematics systems use standalone GPS, while handset-based Phase 2 solutions use network-assisted GPS handset solutions.

Rural carriers urged FCC Wireless Bureau to grant temporary relief to smallest wireless carriers for Enhanced 911 Phase 2 location accuracy standards. Several groups filed comments Fri. at Commission in support of petition for forbearance from E-911 accuracy standards imposed on smallest (Tier 3) wireless carriers. They are nonnationwide and had fewer than 500,000 subscribers as of year-end 2001. Rural Cellular Assn. (RCA) supported proposal that FCC forbear from enforcement action against Tier 3 carriers that couldn’t achieve precise caller location accuracy levels set out in FCC rules. RCA said small rural carriers had difficulty recovering costs for network upgrades needed to increase location accuracy capability. Such carriers have smaller subscriber base over which to spread such increased costs and have customer base that’s “particularly resistant to price hikes and surcharges,” it wrote. RCA said: “The carriers cannot afford to add base stations solely to assist triangulation methods for location accuracy, nor can they economically provide new Phase 2-capable handsets free to subscribers.” RCA said leasing and zoning challenges also made it difficult to construct additional base station capacity and handsets weren’t available for analog and TDMA systems used in rural areas. Group backed proposal by coalition that FCC forbear from enforcing existing accuracy standards in rural markets. It said that in rural areas, accuracy standard “can be significantly lower” than for urban markets and emergency callers still had good chance of pinpointing 911 caller’s location. NTCA also backed proposal, saying forbearance request “represents a reasonable solution to an expensive and ongoing E-911 deployment issue.” Point of petition is that FCC “temporarily relax” accuracy standards for smallest carriers while holding all carriers to strict implementation deadlines. Under petition, carriers still would have to comply with most E-911 responsibilities. NTCA said they would have to install Phase 2 technical solutions within 6 months of public safety answering point request or by Sept. 1, whichever was later. “The forbearance would merely permit Tier 3 carriers to deploy network-based Phase 2 solutions from existing transmitting facilities, utilizing existing cell site antenna configurations,” NTCA said. “Carriers choosing handset technology would not be required to do further enhancements to the available handset- based configuration to increase accuracy levels.” FCC’s competition goals may be protected if rural carriers can implement E-911 solutions that are “technically and economically achievable,” NTCA said. “The current rules may force rural carriers out of the wireless business altogether.”

ITU Study Group is to meet for first time today (Tues.) in Geneva to hash out ultra-wideband (UWB) policy issues, including definitions and operational and technical characteristics. In flurry of last-min. contributions last week, Canada and several European countries submitted proposals, some of which used emissions limits in FCC’s Feb. 14 UWB order as starting point. In other cases, companies such as Ericsson, Nortel and Qualcomm submitted similar data on interference concerns as they had been teed up at Commission.

Cingular Wireless told FCC that it had met consent decree stipulation on Enhanced 911 deployment by rolling out Phase 2 location technology at more than 2,000 cell sites by end of 2002. Consent decree on E-911 Phase 2 had required carrier to implement Phase 2 services at minimum of 2,000 cell sites. Cingular said it had completed end-to-end testing and had begun to provide location information to public safety answering points (PSAPs) from 1,683 cell sites. While it said it had exceeded minimum requirement, PSAPs serving 784 sites weren’t able to engage in end-to-end testing of Phase 2 technology by Dec. 31 deadline. Those 911 call centers had agreed to complete end-to-end testing by that date but weren’t able to “due to unforeseen circumstances.” Once those tests are complete, Cingular said, it will be able to provide location information under Phase 2. Carrier reminded FCC of recent order in which agency said it didn’t intend to impose liability on carrier for missing such benchmark when PSAP couldn’t receive Phase 2 information as of particular deadline. Cingular said it would start providing Phase 2 service to those PSAPs within 90 days of receiving notification that they could do end-to- end testing.

FCC Wireless Bureau requested comments on separate requests by 2 small, rural wireless carriers for more time to provide nationwide roaming support for customers with ported or pooled numbers. Under FCC rules, covered wireless carriers that operate in top 100 Metropolitan Statistical Areas must offer local number portability (LNP) by Nov. 24. LNP allows customers to take their numbers with them when they switch providers. Those carriers also had to take part in thousand-block number pooling by Nov. 24, 2002. All covered wireless carriers also had to support nationwide roaming by users with ported or pooled numbers by Nov. 24, 2002. Bureau said public notice was meant to ensure that if subscriber with ported or pooled number roamed onto another carrier’s network, user still would be able to make and receive calls. Comments are due Feb. 13, replies Feb. 27. Requests at FCC are from: (1) Pine Belt PCS, which said it couldn’t meet Nov. 24, 2002, deadline for supporting roaming by customers with pooled or ported numbers. Carrier asked for one-year extension because it had received indications from lender that it could obtain financing to cover costs of upgrading its equipment. Pine Belt also asked for waiver or temporary extension of FCC rule that carriers deliver valid call-back numbers to public safety answering points in areas where they provided Phase 1 Enhanced 911 service. (2) Kodiak Wireless, which sought extension of roaming deadline to July 1, 2003. It said it had been burdened by costs of providing roaming support because of its limited resources.

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.