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A Joint Facilitated Meeting at the NENA Annual Conference Setting: As described by the FCC, their wireless 9-1-1 rules “. . . seek to improve the reliability of wireless 9-1-1 services and to provide emergency services personnel with location information that will enable them to locate and provide assistance to wireless 9-1-1 callers much more quickly.” Under those rules, and upon a PSAP request, wireless carriers are required to provide wireless ALI level of service as part of Phase II E911 implementation beginning October 1, 2001. That implementation must occur within one of two separate accuracy requirements and deployment schedules associated with the two types of technology that exist todayi.e., network and handset-based solutions. A carrier must deploy a solution that complies with these standards, based presumably upon technology choice, testing, and other service related factorsall of which are of interest to the public safety community. Approved deviation from FCC rules procedurally requires a waiver. As clarified in the Commissions Fourth Memorandum Opinion and Order, “the Commissions rules may be waived for good cause shown,” but only “if special circumstances warrant a deviation from the general rule, and such a deviation will serve the public interest.” By practice, waivers must meet the following tests:
So far, several wireless carriers have filed requests for waivers, including VoiceStream Wireless Corporation, Nextel Partners, Inc., and AT&T Wireless Services, Inc.one of which, VoiceStream, has been granted. The other two are procedurally in review, and it is anticipated that other companies will be filing similar requests. Most of the other filed waiver requests beyond the three mentioned above, take one of the three as their model. These petitions are based largely upon individual company analysis and testing of available technology, in different settings, the results of which are just now being disclosed. It is essential that the public safety organizations (APCO, NENA and NASNA) thoroughly and effectively review these requests, with the intent to minimize their need, and foster timely and aggressive deployment. As described below, this joint project is designed to support that goal.
Project Overview: The project is a joint APCO/NENA/NASNA (also referred to as PS Associations) effort (referred to as “the Program” hereafter) to solicit comments from experts for the purpose of formulating a more enlightened FCC and regulatory policy regarding wireless company (WC) waiver requests FCC wireless rules as described above. Specifically, the PS Associations will solicit comments (anonymously if desired) from experts in the field, including but not limited to:
During a three-week public comment period, comments will be solicited through a variety of means including association websites, list serves and direct mail. Comments will be based upon existing waiver requests, associated testing results, other testing that has occurred, and the state of technology that exists today, in light of the articulated tests for waivers. The comment period will culminate in a one-hour (or longer) facilitated discussion at the NENA Annual Conference on the afternoon of Wednesday, June 27, 2001, with the intent of consolidating and summarizing the comments provided. The PS Associations will use the information gathered and distilled to help formulate their collective broader regulatory policy responses to the WC requests for waivers.
Program Specifics:
Forward: The facilitated/led meeting at the NENA Annual Conference will culminate in a set of distilled findings and conclusions. While it is understood that some issues will be unresolved, the process and discussion, if effective, should illuminate several key assumptions relative to the waiver requests. Specifically, some of the issues that will be illuminated would be:
Success Defined: The Program will be successful if the joint PS Association response to the FCC is based on more information and understanding of the underlying state of technology, and a deeper understanding of the underlying facts offered in support of carrier waiver requests. This process is not a substitute for a longer-range program on behalf of Project Locate, and NENAs collaboration with Project Locate. Those programs and that work will continue to focus on the foregoing issues well beyond the Forum Event at the NENA Conference.
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