The FCC Docket 94-102, Telecom Act of 96 and You

by Russ Russell

1996 has been an extraordinary year in terms of changes in the lawsaffecting telecommunications and 9-1-1: a real paradigm shift. Focusingon 9-1-1, the FCC CC Docket 94-102 requires wireless carriers to providelocation information on their 9-1-1 callers; and the TelecommunicationsAct of 1996 requires number portability as part of allowing telephone servicecompetition at the local level.

These changes will require significant planning and some expense bytelephone companies and 9-1-1 districts (i.e., city, county, or other governmentjurisdiction that orders 9-1-1 services for the population for which theyhave public safety responsibility). The following is an overview for yourunderstanding and planning.

FCC CC Docket 94-102

FCC CC Docket 94-102 requires location information on wireless 9-1-1callers to be generated and provided to the appropriate Public Safety AnsweringPoint (PSAP). The wireless companies to whom the rules apply (i.e., “coveredcarriers”) are defined by the FCC as “cellular, broadband PersonalCommunications Services (PCS) and certain Specialized Mobile Radio (SMR)licenses.” But note that the requirements imposed upon the coveredcarriers apply only if a carrier receives a request for E9-1-1 servicefrom the administrator of a PSAP that has made the investment which isnecessary to allow it to receive and use the data: The 9-1-1 district isin control of the schedule. However, for Phase I, a covered carrier mayrequest a waiver if it or its telephone company (telco) is not capableof transmitting Automatic Number Identification (ANI) to the PSAP. Thecarrier’s obligation to provide Phase I wireless 9-1-1 ANI does not ariseuntil the 9-1-1 district has made the investment to use the data and hasrequested that ANIs be transmitted by the carriers.

There are two phases of the requirements as follows:

Phase I – Requires the wireless carrier to relay the caller’s ANI andlocation of the base station or the cell site receiving a 9-1-1 call tothe PSAP through the use of “pseudo-ANI” (pANI). The caller’sANI identifies the calling mobile unit; the pANI identifies the cell siteor cell site sector, which in turn provides information on the radio coveragearea from which the 9-1-1 call was initiated. The call is direct-trunkedto a selective router where the pANI is used to look up routing codes toroute the call to the PSAP that is responsible for the majority of theterritory in that sector’s radio coverage.

Since standard CAMA-type trunking cannot provide two ANI data streams,this requires that the wireless carrier must use either Feature Group Dor Signalling System #7 or ISDN connectivity to the selective router. Sincefewer than half the selective routers (i.e., 9-1-1 tandems) are capableof Signalling System #7 or ISDN connection, there will be some negotiationamong telephone companies, 9-1-1 districts and wireless carriers as tohow the upgrading of selective routers will be funded. There are effortsin many states to apply 9-1-1 surcharges to wireless subscribers as a newsource of revenue.

Since most current PSAP display equipment will handle only one ANI datastream, this will require upgrading the PSAP equipment.

Provided to PSAP by FCC Phase I: The caller’s telephone number and ageneral location (accurate to somewhere between a few and several squaremiles) of the caller.

Impact on 9-1-1 Districts: There will be additional funding to be raisedand disbursed to the covered carriers and the telephone companies. ThePSAPs must be upgraded to handle the dual ANIs. A liaison must be establishedamong the 9-1-1 district, the telcos and the covered carriers for planningand ongoing support.

Impact on telephone companies: If a telco is a secondary in the 9-1-1district, then the impact is minor, perhaps being to provide trunking froma Mobile Switching Center to a meeting point with the lead telco. The leadtelco will plan the trunking to its selective router and will provide thattrunking in its franchise area (and possibly outside that area if it offerslong distance service). The lead telco will usually be the one with theselective routing service and thus must plan to accept Feature Group “D,”or Signalling System 7, or ISDN connections at its selective router.

Impact on covered carriers: They should plan near-term meetings withrepresentatives of the 9-1-1 districts from which a subscriber may placea 9-1-1 call. The covered carrier should prepare coverage maps that maybe overlaid on the 9-1-1 district jurisdictions to determine which PSAPshould receive the calls from which cell site sector. (They may requestnon-disclosure.) Rather than resist the requirement, they should look atit as a revenue and service opportunity, making their wireless servicemore valuable and an incentive for new subscribers. By planning with the9-1-1 carriers and the telcos they can ensure that budget, revenue andother constraints can be met.

Action Recommendation: The 9-1-1 districts will have to take the leadon implementing 9-1-1 by contacting their telephone companies and the coveredcarriers in their jurisdiction. They should invite representatives to ameeting to review the requirements and listen to concerns. From there,a standing committee should be established to work for funding the coveredcarrier’s investment as well as the other costs. Technical and projectplanners from all concerned parties should work together on a friendly,we-all-win-something, approach to enact Phase I by March 1998.

Phase II – The covered carriers must achieve the ability to identifythe latitude and longitude of a mobile unit making a 9-1-1 call withina radius of no more than 125 meters (410 feet) in 67 percent of all cases.This information will be transmitted to the PSAP where it will be displayed.

Not required in the FCC rules, but inferred by many are: (1) The locationinformation will be used by the selective router for routing the call tothe correct PSAP, and (2) The PSAP will have a map-display capability toshow the calling party’s location on a street grid. It makes good senseto have these capabilities to take full advantage of the latitude and longitudeinformation. The Phase I capabilities remain in place to provide the callingparty’s number and as a backup selective routing capability.

The telecommunications requirements now go beyond Feature Group “D”capability, requiring either Signalling System #7 or ISDN connectivityfrom the location determining technology (LDT) through the selective routerto the PSAP.

The LDT will be a radio location technology based on the use of antennasthat may or may not be co-located with the wireless carrier’s towers orbased on the Global Positioning System. The lat/long data will be mergedwith the wireless call either at the MSC or at the selective router. Inother words, the ability to locate the call does not require the locatingequipment to be installed with the covered carrier’s equipment.

The impact on 9-1-1 Districts, covered carriers and telcos are verysimilar to those listed in Phase I. The only change is that new PSAPs shouldestablish the ability to transfer map information with their ALI when callsare passed from one PSAP to another. This ability should also be plannedby telcos in selective router to selective router transfers.

The Number Portability Issue

The Telecommunications Act of 1996 requires that local exchange carriers(LECs, i.e., the telephone companies that previously had a monopoly ina geographic area) must allow alternate or competitive LECs (ALECs or CLECs– the terms are synonymous, i.e., telephone companies that plan to entera LEC’s area and provide services to some of that LEC’s subscribers) topurchase telecommunications services at wholesale prices for resellingto end users. This affects 9-1-1 because that ALEC and the LEC must jointlyensure that the subscriber’s 9-1-1 call reaches the PSAP and that the ANIretrieves the correct Automatic Location Identification (ALI) record.

A major change aspect concerns “number portability,” wherethe subscriber keeps his old (i.e., the one he had from the LEC) telephonenumber when signing up with the ALEC. This results in two ANIs being associatedwith the subscriber: (1) the “ported number” – the old LEC numberthat the customer still thinks is his telephone number, and (2) the ALEC’snumber that is used throughout the network to route and bill the subscriber.The ALEC’s number is the ANI that is sent to the PSAP — so now you canimagine the confusion when the PSAP telecommunicator sees a telephone numberand asks the calling party to verify it only to hear “That’s not mynumber! Where did you get that from? My number is [the ported number].”

Thus, there is a need to provide both telephone numbers in the ALI recordand educate the telecommunicators when they see a “ported number”record that the ANI displayed is not what the caller thinks is his number,but that the number will be in the comments section — at least until weestablish a specific field for that ported number. One aspect that doesnot require revision is that the address information will be properly displayed,but it will be the ALEC’s responsibility to provide that to the lead telcoso that it will be added to the 9-1-1 district’s ALI record data base.

ALEC Connectivity to 9-1-1 Networks

When an ALEC plans to offer telephone service in an area, it must planconnection of its central office switch(es) to the selective router(s)serving PSAPs responsible for the addresses of its subscribers. This entailsthree major considerations.

The first requirement is to select the preferred PSAP to handle callsfrom any particular subscriber. This is determined by a representativeof the ALEC meeting with a representative of the 9-1-1 district to selectand assign Emergency Service Numbers (ESNs) to each address. The assignmentcan be done at the Master Street Address Guide (MSAG) level, but may requirethe current MSAG to be updated with addresses unique to the ALEC.

Second, ALECs differ from LECs in that it is likely that an ALEC switchwill cover several times the geographic area that is covered by a LEC’sswitch. This makes it likely that the ALEC switch may have to trunk tomore than one selective router and have some selective routing capabilityitself. For example, if subscriber “A” lives in county “A,”which is served by selective router “A,” then the ALEC switchmust establish a minimum of a pair of dedicated 9-1-1 trunks to selectiverouter “A” and be able to know that 9-1-1 calls from subscriber”A” must be routed over that trunk group. If subscriber “B”lives in county “B,” which is served by selective router “B,”then the ALEC switch must establish a minimum of a pair of dedicated 9-1-1trunks to selective router “B.” Similarly, the ALEC switch mustknow to route 9-1-1 calls from subscriber “B” to selective router”B.” (The ALEC will learn which selective router handles whichsubscriber in the first requirement process stated above.)

The third requirement is to establish default routing. Default routingis the assignment of a 9-1-1 call route when no ANI is provided. The intentionis to route on the basis of the trunk group from which the call arrived,causing it to automatically route to the PSAP that is responsible for thelargest percentage of subscribers that could call over that trunk group.The concern is that some subscribers will almost always be routed to thewrong PSAP, but this cannot be helped. ALECs and 9-1-1 districts shouldapproach the default routing assignments as being better than no assignmentat all.

There are some other aspects of change with the new laws, but, in myview, these are the most important. LEC, ALEC and 9-1-1 district managersshould spend some time becoming familiar with both. Are we having fun,or is this roller coaster going a little fast?

Robert “Russ” Russell is the Senior Product Manager – 9-1-1for GTE Telephone Operations, having been involved almost continuouslyin 9-1-1 since developing and implementing the first GTE stand-alone 9-1-1system in 1986. He has written many tariffs and contributed to state legislationsover the years, and is considered to be a “subject matter expert”in the industry. His current emphasis is preparing GTE to meet the FCCCC Docket 94-102 and Telecommunications Act of 1996 requirements as theyaffect 9-1-1. He holds an MBA from Indiana University at Bloomington, IN;a BBA from Chaminade University in Honolulu, HI; and an AA in ElectronicSystem Technology from Los Angeles Community College.



Caller’s ANI: The 10-digit (Area Code + Exchange Code + Line Number)set of in-band multifrequency tones that identify the caller’s telephonenumber. There may be more digits passed if the caller is roaming on a foreignmobile radio. ANI is Automatic Number Identification.

pseudo-ANI: ANI as North American Number Plan (NANP) telephone numberassigned to the cell site or cell site sector that receives the mobilecall and will be forwarded to the 9-1-1 network upon receipt of a 9-1-1call. It is “pseudo” in that it is not a telephone number thatcan be called. It must be an assigned NANP number to avoid duplicate ALIrecords.

Number Portability: The ability of users of telecommunications servicesto retain, at the same location, their existing numbers without impairmentof quality, reliability or convenience when switching from one carrierto another (service provider portability).