In continued exchange between public safety community and CTIA on thorny Enhanced 911 issues, CTIA Pres. Tom Wheeler wrote to 2 groups this week, elaborating on remaining challenges to implementation of Phase 2 before Oct. 1 deadline. Letter is follow-up to strongly worded July 2 missive by CTIA to Assn. of Public Safety Communications Officials (APCO) and National Emergency Number Assn. (NENA), from which some wireless carriers had distanced themselves. Wheeler wrote July 17 to NENA and APCO that he wants to “continue our dialogue” on joint E911 challenges. “The purpose of my previous letter was to inquire of your organizations how you intend to establish equivalent deliverable expectations for your members,” Wheeler wrote. Wheeler cited assertion by groups that public safety answering points (PSAPs) not ready to roll out Phase 2 of E911 today will be ready within 6 months after they submit Phase 2 request to particular wireless carrier. “With all due respect, that is exactly the heart of the problem I was trying to raise in my earlier correspondence,” Wheeler said. “With carrier-enabled handsets or networks available, consumers will expect location capability whether or not a particular PSAP has determined it wants to make a Phase 2 request.” Wheeler said wireless carriers will know whether they buy E911-capable handset or have local wireless network that supports this location-specific capability. “The only way they will have equivalent knowledge that the information being transmitted can be used for their safety is for all of America’s PSAPs to step up and commit to a parallel implementation schedule,” Wheeler said. He noted that “major problems” still must be worked out concerning Phase One capabilities for E911. “Since Phase One is a technical precursor to Phase 2, should not those problems get worked out before Phase 2 makes things even more difficult,” Wheeler asked in detailed 7-page letter. Wheeler said that point of his previous correspondence was to seek similar commitment by PSAPs to deal with these issues in manner in which solutions are binding on every PSAP. Structure is needed, for example, on whether location-specific information will be processed by PSAPs using SS-7 protocol or IP format, Wheeler said. “The regulatory process is imposing uniform requirements on wireless carriers, what will be the equivalent solution for your members,” Wheeler said.

FCC Wireless Bureau turned down request by Cingular Wireless that certain materials in its waiver request for Phase 2 of Enhanced 911 be kept confidential. Cingular sought confidential treatment for its Phase 2 trial results, deployment timeline for network-based Phase 2 location technologies and deployment cost estimates. Bureau said Cingular hadn’t met procedural requirements for requesting confidentiality. “Even if the materials could be deemed confidential, however, we find that the public interest requires that these materials be made available for public inspection,” bureau said in order released Tues.

FCC Wireless Bureau asked for comment on PCS One request for waiver of Enhanced 911 (E911) Phase 2 deadline. Waiver request filed June 20 proposed that carrier deploy hybrid system using network software solution and handset-based technology called Enhanced Observed Time Difference of Arrival for its GSM networks. Like several carriers with E911 waiver requests pending, PCS One petition mirrored earlier VoiceStream request that was granted by Commission Sept. 8. PCS One serves eastern Pa. and is owned equally by Voicestream and D&E Communications, 2 companies that have several cooperative arrangements and are integrated technically, PCS One said. It said geographic proximity of PCS One network to VoiceStream systems using same technology and technical integration of systems on regional basis were reasons FCC should grant waiver subject to same conditions as VoiceStream. Comments are due July 26, replies Aug. 6.

FCC Wireless Bureau asked comment on request for waiver of Enhanced 911 Phase 2 deadline by Corr Wireless Communications, which is among several carriers with waiver petitions pending. Corr is seeking temporary waiver of FCC Phase 2 rules to allow it to deploy network solution on graduated implementation timeline. Corr said FCC’s 6-month implementation deadline for network-based solutions had been triggered by public safety answering point request in its service area. Corr, rural carrier with fewer than 21,000 subscribers, said network solution was expensive and graduated implementation was needed to ease economic burden. Corr told FCC it wouldn’t have revenue to cover high costs of implementing network solution and that its customer base was too small to raise rates to cover those costs. Corr proposed it immediately install switch-related infrastructure needed for Phase 2 and provide service to top 35% of cell sites of any requesting PSAP within 9 months of receiving request. Comments are due July 26, replies Aug. 6.

In update to FCC on its Enhanced 911 Phase 2 progress, VoiceStream said it planned to deploy Ericsson network equipment for Enhanced Observed Time Difference (EOTD) of Arrival handsets in Washington in Dec. VoiceStream said it planned to take commercial shipments of 2 EOTD handsets by Oct. 1 “However, VoiceStream will only be able to deploy its EOTD solution in a limited fashion this year,” company told FCC last week in ex parte filing. “This is due primarily to delays in the provision of EOTD network equipment by Nortel and Ericsson.” Deployment of Nokia network equipment will start in Oct. in Houston, and Nortel equipment rollout will commence in Denco, Tex., around same time. VoiceStream last fall received conditional waiver from FCC for Phase 2 of E911 (CD Sept 11 p1). Among conditions, VoiceStream must deploy network solution providing baseline location information accuracy of 1,000 m for 67% of all calls by Dec. 31, 2001. Handset solution can be deployed along later timeline, with 100% compliance of all sets sold by March 31, 2002. Network solution is on track for deployment at end of 2001 at those accuracy levels “or better,” VoiceStream said. Company attached recent letters from equipment carriers indicating all elements of their Phase 2 solution weren’t expected to be ready by Oct. 1 deadline for Phase 2. “Despite diligent development efforts, the earliest potential compliance deadline of Oct. 1, 2001, unfortunately will not permit Nortel Networks to make the entire tested, deployable core wireless technology [for Phase 2] available at that time,” Nortel said in letter to VoiceStream.

Location-based technology for wireless handsets isn’t likely to be widespread for consumers until 2002, despite FCC deadline of Oct. for Phase 2 of Enhanced 911, Cahners In-Stat Group said. Research firm estimated revenue of location-based wireless services could grow to more than $13 billion in 2005 from current $37 million. It also projected cost of deploying such technology could range from “hundreds of millions” to more than $1 billion. Several carriers, including AT&T Wireless, Cingular and Nextel, have waiver petitions for Phase 2 of E911 pending before Commission.

FCC Wireless Bureau requested comments on Cingular Wireless’s Phase 2 Enhanced 911 waiver request. Cingular had asked Commission for waiver to allow it to roll out hybrid network and handset-based technology called Enhanced Observed Time Difference of Arrival in its GSM network and switch-based technology similar to Mobile Assisted Network Location System for its TDMA network. Cingular is seeking waiver of Oct. 1 deployment deadline and relaxation of accuracy requirements on temporary basis (CD July 10 p5). Comments are due July 31, replies Aug. 10.

FCC Wireless Bureau is seeking comment on what criteria public safety answering points (PSAPs) should meet at time of request for Enhanced 911 Phase 2 service. Bureau requested feedback on what would demonstrate “sufficient steps” to ensure it could receive and use E911 data before wireless carrier delivers service. In April, FCC sought comments on petition by Richardson, Tex., that sought Commission clarification of process by which PSAPs make requests for Phase 2 E911 service. City contended request for service was valid when carrier was informed that necessary equipment upgrades for Phase 2 service would be finalized before delivery of that service and when adequate cost recovery mechanism for upgrades was in place. Wireless carriers have opposed petition, arguing that PSAPs already must be able to receive and use E911 data as condition of “valid” E911 request. Wireless Bureau said it sought comments on “identifiable, measurable criteria” that could “reasonably predict for the Commission, carrier and PSAP whether a PSAP will be ready to receive and utilize Phase 2 information within 6 months of a request.” Among factors that could demonstrate that, it said, were: (1) Whether necessary funding was available. (2) Whether there were purchase orders with vendors that would install necessary upgrades within 6 months. (3) Whether arrangements had been made with LECs to supply services such as trunking. Among other questions is whether PSAP must show it has “state of the art” mapping capability instead of less sophisticated plotting mechanism. Comments are due July 25, replies Aug. 1.

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.

Broad cross-section of wireless carriers and consumer groups urged FCC to implement transition period before eliminating requirements that cellular operators provide analog service. Recommendations came in comments to Commission this week on notice of proposed rulemaking (NPRM) in which agency asked whether it should do away with or modify requirements for cellular carriers that dated back to 1981, including whether AMPS-type (Advanced Mobile Phone Systems) service requirement should be kept in place. Sprint PCS, Qwest and Verizon Wireless were among carriers advocating 5-year transition period before AMPS requirement was shelved. Factors cited by carriers advocating phase-out period include: (1) Large number of subscribers still using analog service. (2) Dominance of AMPS technology for roaming. (3) Importance of AMPS for linking customers to 911 services. (4) Reliance of new telematics systems such as General Motors OnStar system on analog networks. (5) Extent to which current digital technologies weren’t compatible with text-telephone systems (TTY) for subscribers with hearing disabilities.