by Gary Allen

This forum was intended as the rather routine presentation of information from various stakeholders in wireless E911, including NENA committees, the Cellular Telephone and Internet Association (CTIA) and the Federal Communications Commission (FCC). However, it was the presentations by the latter two groups that provided the most interesting counterplay, even though the two participants didn't directly face one another in debate.

Ron Whinery, chair of NENA's wireless committee, emphasized that all of NENA's committees working on wireless E911 issues need additional expertise and assistance. He pointed out that the committee began six months ago with just 30 members, and now has a membership of 140. Yet the issues remain huge. He asked anyone from the PSAP or commercial side of the industry to join and committee and help make wireless E911 a reality.

But it was Kathryn Condello of the CTIA who provided the most interesting commentary on the regulatory history of wireless E911. Her recollections were pointed, and she frequently sounded bitter about being on the regulatory end of the FCC's big stick, while PSAPs have no deadlines or implementation requirements. She noted that she was speaking from prepared text, but her remarks were so frequently "off the wall" that it was hard to believe she selected her words before coming to speak in front of a 911 group.

In essence, Condello turned the focus on implementation of Phase I and II back to the PSAPs, and definitely away from the wireless carriers. She frequently stated that the wireless carriers were ready, and questioned whether PSAPs had done their share to get the technology "on the road."

Condello said that CTIA joined NENA and the Association of Public Safety Communications Officials (APCO) six years ago to come up with an deployment approach for Phase I and II wireless E911. The wireless industry "rolled up its sleeves" and helped to develop the technology, "which does not exist anywhere else on earth." She said the FCC then adopted a "very aggressive" schedule for wireless E911, "a schedule that, frankly, kinda put, you know, the wireline industry, which doesn't have a long history, to shame." Not only that, but the FCC expanded the scope of the its original wireless E911 ruling from PCS systems to cellular and MRA operators such as Nextel.

She said there are five essential parties for the "successful resolution" of wireless E911: wireless carriers, wireless suppliers, PSAPs, PSAP suppliers, the FCC. "This is not going to be the place where we're really going to talk about what our differences have been," Condello told the audience. "But I do want to point three key elements that have been factors in the deployment of Phase I and Phase II."

She said the FCC and PSAPs agreed on the issue of how to handle uninitialized phones. "From our perspective, and it's still a very difficult--let me be frank--impossible, technical issue to re-connect or verify an emergency call, or re-connect a call to an uninitialized phone," Condello said. "Nevertheless, that's the rule."

On another matter, Condello said the CTIA didn't agree with PSAPs on the cost-recovery issue. She termed it a "fundamental shift in cost-recovery rules which the wireless industry perceived as adding additional implementation costs to us. You and we didn't really agree. Nonetheless, those are the rules."

Lastly, Condello said "one of the most critical actions that's affecting us right now," is that over time, the regulators, "continually shifted the location accuracy requirement, so that, while you can piss and moan, and complain or be proactive about what the accuracy standards are, fundamentally there's not been a stable platform for the vendors, either our vendors or PSAP vendors."

Regardless what the issues were or the outcome was, "to a certain extent--hell, to a great extent--the regulatory process, each one, and each decision, has taken about a year or more to resolve, each disputed issue, which froze each individual party's position, which impacted technology deployment, which impacted technology development, which impacted technology decisions by the carriers and the PSAPs and their suppliers, and delayed deployment planning while the process went on," Condello said.

What Now?

Now, in 2001 and "mid-way through delivering on our joint commitment," every wireless switch in the country is in compliance, Condello said. She added that the FCC made it clear, in Congressional testimony just two weeks ago, that wireless carriers "will not be relieved of their obligation to deploy E911."

"So where does that leave us?" Condello asked. "October 1st is less than 100 days away," she said, "The wireless industry is under enforceable mandate, and as a regulated industry we will do what we have to do to meet our obligation." So Condello said she wanted to focus more on, "What can we do, so that we can work better together to insure the public safety community will be as ready to deliver on the carrier agreements as the carriers have to be ready."

She said is an important topic for the top six national wireless carriers because, "To us, the concept of a 'soft launch' of Phase II E911 services is really had to imagine," Condello said. She foresees a "train wreck" ahead as Phase II is deployed in some counties, but not in others. Wireless phone users will have their expectations raised by the service in their home area, only to find out that an adjacent county doesn't have Phase II service.

Condello said, "We know the issues associated with our joint deployment are immense, and we do not undermine or underestimate them. But, face it. Our fates are inextricably linked together."

She added that, "The wireless industry is going to invest billions --billions width a "b"-- of dollars to upgrade its networks and handsets. The nation's 120 million wireless subscribers already pay an estimated $700 million a year in 911 surcharges, intending to support PSAP deployment of Phase I and Phase II."

She continued, "These realities create a common challenge that is only solvable together."

Further, "We are concerned that, as we start to deploy Phase II technology, attention will start to shift to the PSAP, in particular PSAPs that don't have the ability to provide the functionality of converting the latitude and longitude into Phase II capabilities," Condello said.

The wireless industry is entering into binding agreements, with penalties for non-compliance, to provide Phase II. "The question again to you," Condello told the NENA audience, "how can the PSAP community make a similar commitment to keep in step with our deployment, and to insure at the very least that the Phase I safety net is in place throughout the country."

She said the CTIA understands that PSAPs are neither regulated nor required to implement Phase II under a deadline. "But if the wireless industry commits to this enforceable delivery of E911 capability, we hope, we trust, we think you should...rate a similar level of commitment." This is issue CTIA expects the consumer public will want answered in the near future.

Condello then noted the surcharges being collected by PSAPs across the country for 911 services, which she estimated at $700 million a year. She acknowledged that the surcharges haven't enabled PSAPs to implement Phase I or II service. "The millions of dollars collected from consumers must be put to work immediately," she said. "You need to have access to it, and you need to get it, so you can do what you need to do to deliver your end of the commitment as well."

She continued," We must work together to avoid the potential for massive confusion and dissatisfaction" that could result from customers who purchased a phone believing they would receive Phase II service.

Condello then turned to the issue of negotiating contracts between PSAPs and the wireless carriers that service its area. She pointed out there are some 6,800 PSAPs, potentially resulting in a total of 61,000 separate contracts to be written up, negotiated and signed. Condello urged PSAPs to consider state-level contracts that would greatly simplify the process. "Our organizations and members must work together to develop coordinated, rational implementation plans in each of the states." She said that CTIA believes that state-level implementations are the key to a rapid deployment.

She said she put these forward because they are the ones that will impact public safety the most. "And you are our public safety partners in this endeavor, and what impacts you, ultimately impacts us."

She finished by saying, "The CTIA wants to reinforce again that we're sticking with you in making the promise of (the FCC's Phase I/II rules) a life-enhancing reality."

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