9/11/01 deadline

September 6, 2001

Richard Mathias
Illinois Commerce Commission
527 East Capitol Avenue
P. O. Box 19280
Springfield, IL 62794-9280

RE: Wireless 9-1-1

Dear Chairman:

I write on behalf of the membership of the Illinois Chapter of the National Emergency Number Association (INENA) to express our concern over the failure of the wireless carriers to meet the deadline of September 11, 2001 imposed by Commission rules for the provision of wireless 9-1-1 at the Phase 0 level.

As you know, the wireless carriers are mandated by the FCC to provide Phase I wireless 9-1-1 within 180 days of receiving notice from a public safety answering point (PSAP) in this state that the PSAP can accept these calls. Phase I 9-1-1 wireless service provides the public safety community and the residents of the State of Illinois with a call back number for the cell caller and some basic location (cell site) information. Phase 0 service only provides the ability to have direct voice communication with the cell caller. The wireless carriers have not only failed to meet the deadline for the provision of Phase I wireless service in many instances, they are now seeking extensions of the time to provide Phase 0 service, the most basic 9-1-1 service.

As a consequence of the wireless carriers’ failure to meet their deadlines, residents of many parts of the state, will continue to receive 9-1-1 service through Conor Communications, a private company. Inherent in the use of Conor Communications are delays necessitated by call transfers, inexperienced and untrained 9-1-1 operators and the inability to provide emergency medical information. The Illinois Wireless Emergency Telephone System Act does not authorize private communication centers as part of the State’s 9-1-1 system and it is our belief that after September 11, 2001, Conor Communications will be operating illegally.

While we recognize that public safety is the paramount concern of the 9-1-1 system and that, because of the wireless carriers’ failure to provide the mandated service, Conor Communications must continue to operate in those areas where the carriers cannot route cellular 9-1-1 calls to the proper PSAP, we strongly urge the Commission to apply all available pressure to the wireless carriers and to move toward the deletion of Conor Communications from the 9-1-1system. We also urge the Commission to adopt a firm deadline of thirty (30) days for this to be accomplished.

We understand that the Commission is concerned about the liability that might arise from the discontinuation of the Conor service, but you must also be concerned for the on-going liabilities created by Conor’s presence in the 9-1-1 system.

The blame for the failure to provide the residents of our State with wireless 9-1-1 service must be laid squarely at the feet of the wireless carriers. We, of the State’s 9-1-1 community, stand ready to assist the Commission in any way possible to resolve this failure and thank you in advance for your cooperation and assistance.


President INENA