Background: NENA and Wireless Phase II Implementation
This report on Phase II Technology Plans is the first installment of a planned series of reports on wireless enhanced 9-1-1 emergency calling. The NENA Wireless Phase II Matrix that accompanies the report will be updated in three stages, as more and more technology plans are available on the FCC web site. Please return to the Matrix for updates for carriers. When the Matrix contains all of the wireless carriers, it will be marked final.
Since 1994, when the FCC first opened a rulemaking on wireless enhanced 9-1-1, NENA’s technical subcommittees on network, database and CPE, among others, have been working to prepare for the advent of automatic number identification (ANI), automatic location information (ALI) and selective routing for emergency calls from mobile phones. In 2000, NENA formed a specific committee, the NENA Wireless Committee, to address the regulatory, technical, political and operational impediments to wireless integration.
Through the formation of this committee, NENA supports and has adopted a proactive posture regarding the complex task of implementing wireless location technology across North America.
As an association, NENA has expressed an unqualified viewpoint that wireless implementation should happen within the originally prescribed FCC deadlines. The reality of wireless implementation, however, makes it clear that the process has been a slow one. NENA has charged its Wireless Committee to address this issue, and to adopt an enlightened and informed approach to promoting this process in an expeditious manner that serves the public’s interests, and the public safety community.
November 9 Technology Plans: Assessing Phase II Progress
November 9, 2000, wireless carriers were required to file their technology plans with the FCC. NENA views these filings as an important barometer of how the wireless industry is moving towards Phase II location capability for America’s 9-1-1 service.
Plans that contain a high degree of detail generally indicate that a given wireless carrier has made substantial efforts to comply with the E9-1-1 rules of FCC docket 94-102. Conversely, technology plans with little detail, or plans that indicate little activity suggest that the wireless carrier has not made significant efforts to comply with the time frames of 94-102.
The Public Interest
Given the critical value of automatic location of wireless 9-1-1 callers, there is an important public safety interest in the readiness of wireless carriers to meet their obligations under the E9-1-1 rules. NENA, NASNA, APCO, and other leading public safety agencies and organizations are actively engaged in educational and promotional efforts to raise the readiness of public safety agencies for wireless implementation. These efforts will increase the likelihood that public safety will largely be prepared for wireless implementation within the time frames outlined in the current FCC Rules.
In this regard, the November 9, 2000 filings represent an important benchmark in measuring the readiness of wireless carriers to meet the October 1, 2001 service levels prescribed by the FCC’s Third Report and Order. (For more information regarding the deadlines for achieving Phase II capability for handset and network solutions see: Fourth Memorandum Opinion and Order in the Matter of Revision of the Commission’s Rules to Ensure Compatibility with Enhanced 911 Emergency Calling Systems [FCC 00-326, CC Docket No. 94-102, 9/11/00] at http://www.fcc.gov/e911.)
Handset vs. Network
What do the plans tell us? Most filed plans either foreshadow, or explicitly state, that the time-frame of October 1, 2001 is in jeopardy. The most pessimistic projections are from wireless carriers who have chosen the handset solution. Many plans note that equipment manufacturers are currently unable to manufacture an ALI-capable handset in a manner, and under a time schedule, consistent with the FCC rules.
The plans were required to contain a series of important information specifically requested by the FCC: Public Notice, “Wireless Telecommunications Bureau Provides Guidance on Carrier Reports on Implementation of Wireless E911 Phase II Automatic Location Identification,” CC Docket No. 94-102 9/14/00 www.fcc.gov/e911. Wireless carrier plans that contain little or no detail are indicative of a company that has not seriously addressed its responsibilities under the FCC’s E9-1-1 rules at Section 20.18 of Chapter 47, Code of Federal Regulations.
The Questions of the Matrix
In reviewing the specific requirement of the technology plans, NENA categorized the specific sections of the plans according to the seven-part requirements in the September 14 Public Notice. The following is a summary of the specific FCC language, followed by the legend for the NENA Matrix for each plan component.
Important Note: The elements of this report contain the analysis of the National Emergency Number Association expressed for the sole benefit and education of its membership. Nothing in this report shall be deemed to be other than the opinions and views of the National Emergency Number Association.
FCC Requirement One:
1. Type of Technology: Identification of the Phase II location technology(ies) that the carrier plans to deploy across its service territory, e.g., network-only, handset-only, hybrid or a combination thereof. Please also include a complete description of the technology(ies) that is/are chosen and the name of the corresponding vendor or vendors. Indicate what technology will be used in each individual area of the carrier’s service territory.
NENA Matrix Legend, Column One:
Network: The plan indicated the network location method would be utilized for Phase II.
Handset: The plan indicated handset technology would be utilized.
Not Identified: The plan was graded as “not identified” if the plan failed to clearly state handset or network solutions would be utilized.
Hybrid: The plan indicated a combination of both network and handset methods would be used.
FCC Requirement Two:
2. Testing and Verification: A description of the testing method used, or to be used, to determine the accuracy of the ALI solution(s) selected, and a description of the results of tests already conducted. Note: The Commission provided guidelines for determining accuracy of ALI solutions in OET Bulletin No. 71, issued April 12, 2000. (Copies of this bulletin can be downloaded from the Commission’s web site, at http://www.fcc.gov/oet/info/documents/bulletins/.)
NENA Matrix Legend, Column Two:
Planned: Plans that failed to demonstrate that the wireless carrier had tested location technology before the filing date were graded as “planned.” Many of the respondents indicated a future planned test. Others wholly omitted specific comments on this plan element.
Partial: Plans that indicated that technology tests were conducted prior to the plan were graded as having performed partial tests.
Substantial: Plans that evidenced a substantial and good faith effort of testing prior to the required filing were graded as performing substantial testing.
FCC Requirement Three:
3. Implementation Details and Schedule: A complete description of the carrier’s strategy and schedule for the installation of the hardware and software needed to implement its chosen technology (handset-based, network-based or hybrid systems). For example, indicate whether both hardware and software changes will be necessary and fully describe the precise nature of the changes. In addition, please provide the roll-out schedule for the installation of the ALI technology(ies).
NENA Matrix Legend, Column Three:
This requirement was graded solely on the date provided for the rollout of ALI technology(ies).Quarter xxxx: For wireless carriers using handset technology, the schedule column reflects the quarter or date when the carrier projects to meet the FCC penetration requirements for new handsets.
Undetermined: The plan indicates uncertainty as to when the wireless carrier can comply with the FCC rules for Phase II.
None: The plan fails to address the roll-out projection of the carrier.
FCC Requirement Four:
4. PSAP Interface: A description of hardware and software changes necessary to transmit Phase II data to PSAPs and the carrier’s strategy and schedule for the installation and/or modification of such hardware or software changes.
NENA Matrix Legend, Column Four:
Detailed: Plans that provided a detailed strategy for interfacing with the PSAP were graded as detailed.
Nondetailed: Plans that provided little or no specific actions or strategies for PSAP interfacing were graded as non-detailed.
None: Plans that failed to address this specific plan requirement were marked none.
FCC Requirement Five:
5. Existing Handsets: A description of the carrier’s strategy and schedule for the upgrade and/or replacement of existing customer handsets, if applicable.
NENA Matrix Legend, Column Five:
This plan component asks wireless carriers to indicate their plan and projection for replacing all legacy phones, at or near the 100% replacement level. For network location, legacy phones are not deemed to be an issue, as network upgrades will serve legacy phones by most assessments. For handset methods, the requirement under the FCC rules is 4th Quarter 2005.The dates given or lack of dates were noted in this column.
FCC Requirement Six:
6. Location of Non-Compatible Handsets: A description of the best efforts that carriers employing a handset-based or hybrid system will make to accommodate handsets that are incompatible with the carrier’s ALI system, e.g., handsets that do not have ALI capability, or handsets that are ALI-capable, but are not compatible with the carrier’s particular handset-based or hybrid system.
NENA Matrix Legend, Column Six:
Network Coverage Provided: The location of roaming callers in network-solution regions is deemed to locate legacy roamers, or non-compatible roamers. NENA notes differences in solutions may result in some network solutions being unable to serve various handset technologies. For simplicity, however, if a network location was indicated, this provision was deemed to have the capability to serve roaming and “non-compatible” handsets.
Best Efforts / Other: For most carriers utilizing handset location, some variation of “best efforts” or other descriptor was noted.
Accessing and printing the NENA Wireless Phase II Matrix
Having read the above information defining the sections of the NENA Wireless Phase II Matrix, you are now ready to download the Matrix itself. It is in Adobe PDF format; click here for Adobe PDF Instructions. Printing the legend you have just read may help you in reading the Matrix. Click here to download the NENA Wireless Phase II Matrix (65k; Adobe PDF).