WASHINGTON-Thomas Sugrue, chief of the FCC’s Wireless Telecommunications Bureau, has begun preparing for the likelihood that many mobile-phone carriers will not meet upcoming deadlines governing location-based 911 wireless emergency service rules.
Meanwhile, Sugrue and his staff are mired in other prickly 911 policy issues dealing with 911 call-completion rules, implementing 911 legislation passed last year and 911-only phones that do not supply emergency dispatchers with call-back or location information.
911 compliance
Sugrue and the rest of the WTB staff have recently gotten an earful on whether there will be enhanced 911 phase II in the time frames set by the Federal Communications Commission.
Generally those arguments can be placed in the following categories: carriers say they can’t comply with deadlines; manufacturers say they will not have handsets ready to sell by the deadlines; location vendors claim to be ready and public-safety officials say carriers must be forced to act or they will sit on their hands.
“The points being raised in the [individual] presentations were rather different. Typically the party making the presentation says they are doing great things while everyone else isn’t,” said Sugrue. These presentations prompted Sugrue to call in two groups of the various parties on separate occasions to present their views in a round-table format.
When all is said and done, however, Sugrue can really only impact the behavior of one set of the parties involved in the E911 debate.
“I don’t mean to minimize the problem, but I do think that pessimism from the carriers is to be expected because, as they point out, they are the ones on the hook,” said Sugrue.
Carriers should not take this to mean that they can miss the deadlines inherent in the E911 mandates. Indeed, Sugrue said that carriers are not going to be able to wait until next year and then claim they can’t meet the deadline.
Carriers must tell the FCC by Oct. 1 which technology-handset, network, a combination or something else-they plan to use to deploy phase II and the status of the deployment of their technology choice.
Service providers choosing to implement network-based technology need a request from a public safety answering point before implementing 50 percent of their phase II solution within six months of the PSAP request and 100 percent within 18 months of the request.
Carriers that embrace a handset-based solution are required to begin selling phones with automatic-location-information (ALI) capability by March 1, 2001. The phones will be phased in until Dec. 31, 2004, when all subscribers must be equipped with ALI-capable mobile phones.
The Oct. 1 deadline is too soon, say carriers and manufacturers. There isn’t the time or the data available to make such an expensive decision. Indeed, one carrier, Verizon Wireless, while claiming it is preparing for the FCC’s mandates, would not discuss downsides to the different options.
BellSouth Corp. is concerned the deadline means that carriers will have to choose the more expensive network solution because the handset manufacturers will not be ready to start rolling out phones before March, and even then, network solutions are not developed enough for deployment.
“The FCC needs to consider delaying the requirements. We have done trials and we don’t see that either handset or the network technology [is at the point] where we can meet the FCC’s accuracy or penetration capabilities,” said Ben Almond, BellSouth federal regulatory vice president.
This piggybacks on what Motorola Inc. says it has been telling the FCC since before it revised the rules last November.
“Motorola has consistently been telling the FCC that their regulations were more than challenging but they chose to listen to other people,” said Mary E. Brooner, director of telecommunications strategy and regulation for Motorola Global Government Relations.
Joe Hanna, a member of the Association of Public-safety Communications Officials Inc., said on his own he has been talking with carriers to see if he can get an agreement to approach the FCC to change the rules that would allow carriers to order phones rather than actually sell phones.
Such a plan would get to the common circular argument from the carriers and manufacturers about the availability of location-enabled handsets. Carriers claim they will not be able to sell handsets before March because manufacturers have said they will not have them ready. Manufacturers say they can’t make handsets until a carrier orders them, notwithstanding FCC mandates that they be sold by a certain date.
These arguments come at the same time that location vendors say they will be ready.
Qualcomm Inc. said it shocked everyone when it presented a prototype phone enabled with global positioning system location technology.
“For our piece of it, we were glad that we could show everyone the handset that we had developed. Show them we had integrated GPS into the handset with one antenna,” said Jonas Neihardt, Qualcomm vice president for federal affairs.
However, Qualcomm no longer manufactures handsets, and the phone used in the demonstration uses Code Division Multiple Access technology-only one of four digital standards used by U.S. wireless carriers.
Qualcomm said it didn’t matter that the phone used CDMA technology. “The chip we showed is a CDMA chip and the phone we showed is a CDMA phone but there is no reason it can’t be deployed with other air interfaces,” said Neihardt.
Responding to manufacturer arguments that it could take as long as 18 months to develop a handset notwithstanding the existence of location technology, Qualcomm told the attendees that its Asian manufacturers could produce handsets within six months of chips being delivered.
Implementation problems
As complex and divisive an issue as phase II is, it is not the only 911 challenge for carriers, vendors, PSAPs and policy makers.
Various 911 stakeholders are debating before the FCC how best to deal with non-service initialized mobile phones. Such phones typically are old and deactivated, but are capable-indeed required by law-to make 911 calls. As such, the phones increasingly are donated to charitable organizations.
This has created a problem, according to public-safety advocates, because PSAPs contacted by people using 911-only mobile phones find it difficult to call back or locate callers.
Carriers, led by the Cellular Telecommunications Industry Association, largely favor education over a mandated technical solution.
A notable exception is SBC Wireless Inc. While SBC does not advocate regulatory intervention, it reiterated in reply comments that any FCC action should include education and the establishment of a universally recognized `non-service initialized’ mobile identification number to alert emergency dispatch operators of call-back limitations.
In the associations’s mobile-phone donation program, phones given away by CTIA members are network activated. The same is not always true for other donation programs.
A high-power public safety group-comprising APCO, the Texas Commission of State Emergency Communication Districts, the National Emergency Number Association and the National Association of State Nine-One-One Administrators-insist a technical solution is possible.
“While there is no information in the record on the costs to make this standard occur, this solution is neither `rocket science’ nor a service that carriers should not already provide,” said the public-safety coalition.
The Wireless Consumers Alliance said donated and commercially sold 911-only mobile phones “create a false sense of security and measures should be taken to make such phones as are reliable as possible and, at the same time, inform the users of the shortcomings of the wireless
systems.”
Secure Alert L.L.C., a commercial distributor of 911-only phones, again urged the FCC not to change existing 911 rules.
Another troublesome area is compliance with the FCC’s 911 call-completion rules. These rules are designed to improve processing of 911 wireless calls. While several manufacturers sought and received waivers of the Feb. 13 deadline, Samsung Electronics Co. Ltd. late last month entered into a consent decree with the FCC that includes a $50,000 voluntary contribution by the manufacturer to the U.S. Treasury to settle a call-processing compliance issue.
On yet another front, the industry is concerned the FCC may take a liberal approach to implementing legislation-making 911 the universal wireless emergency telephone number and giving carriers and vendors limited liability protection-passed by Congress last year.
The FCC is expected to shortly issue proposed rules for implementing the law that Congress passed last year.
