FOOTNOTES

This section will contain the footnotes referenced in the main document above.

…call handling capabilities …
One of the benefits of enhanced 911 systems is engineered network capacity that provides a very high level of service, but does predictably block calls by choking based on calling pattern experience. This prevents a visible single event from monopolizing the system. Wireless systems not interfaced provide no such controls and can easily overwhelm a PSAP with calls about a known incident.

…statute…
1994 Legislative Session, HB 2601 mandated ANI by January 1, 1995. The bill also established a county optional wireless Tax with a maximum rate of $0.25 per month. The agreement that led to the legislation was that the 25 cent rate would be equitable with the wireline tax if the wireless companies did not bill for the implementation of ANI

…customer tariffs …
The FCC was silent on the responsibilities of the LECs to provide assistance or connectivity for the necessary interfaces between the wireless carriers and the enhanced 911 systems. Wireless carriers have been serviced as interexchange carriers by the LECs, which typically limits the types of interconnections to high capacity multi-path trunks, which may be inappropriate for 911 purposes.

…system manager …
The ruling refers to the PSAP requesting the delivery of ANI. However, that is not practical where service boundaries do not approximate cell boundaries. In Washington the counties are mandated to provide E911 so they are the logical point of request.

…market competitive …
An interesting and market realistic, option to handle the cost recovery issue would be for the FCC to include enhanced 911 network services in the basic service definition within the universal service rules as has been suggested by Washington State. That would allow a uniform nationwide upgrade of 911 to accommodate both new wirleline technologies as well as the wireless location technologies. The inconsistencies of local funding would cease to be an issue for the carriers while allowing those funding mechanisms to be managed locally to address specific 911 support requirements.

…additional costs …
The counties in Washington are permitted to collect $0.25 per month per wireless subscriber to equalize the contribution toward operations with that of wireline customers where about one-half of the $0.50 per month is returned to the wireline companies in the form of E911 service fees. The wireless companies agreed to not request reimbursement until ALI was implemented.