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Federal Communications Commission
445 12th St., SW
Washington, D.C. 20554
News media information 202 / 418-0500
Fax-On-Demand 202 / 418-2830
Internet: http://www.fcc.gov
TTY: 202/418-2555

DA 00-1875
Released: August 16, 2000


(CC Docket No. 94-102)

Comment Date: September 18, 2000
Reply Comment Date: October 11, 2000

In this Public Notice, the Wireless Telecommunications Bureau (Bureau) seeks comment on a request filed by the King County, Washington E-911 Program Office for assistance in resolving a conflict related to the implementation of wireless Phase I Enhanced 911 (E911) service in the State of Washington.1 The King County Request states that King County and several other counties in Washington State have ordered Phase I service from wireless carriers operating in the State and that the Public Safety Answering Points (PSAPs) in these counties are capable of receiving and utilizing Phase I information over their existing E911 networks. According to the request, some carriers have agreed to implement Phase I service only if King County and the several other requesting counties pay for some or all of certain network and data base components associated with the delivery of the Phase I service. King County requests that the Bureau clarify whether the funding of certain of the network and data base components of Phase I service, and the interface of these components to the existing E911 system, are the responsibility of the wireless carriers or the PSAPs.

On December 8, 1999, the Commission released the Second Memorandum Opinion and Order in CC Docket No. 94-102.2 In that Order, the Commission eliminated the requirement that a cost recovery mechanism be in place for a carrier before the carrier is obligated to provide E911 service. The Commission also concluded that a carrier's obligation to provide E911 service pursuant to a PSAP request is contingent upon the carrier receiving a valid request from a PSAP that is capable of receiving and utilizing the data elements associated with the service, and a mechanism for recovering the PSAP's costs of the E911 service is in place.

To assist us in addressing the King County Request, we seek comment on the following issues relating to the implementation of Phase I E911 service:

  • Whether a clearly defined demarcation point exists in the E911 network3 that separates the responsibilities of carriers and PSAPs for providing the various components or upgrades needed to implement Phase I technologies? Commenters should identify particular components and/or upgrades with the party responsible for the upgrade (i.e., wireless carrier, local exchange carrier (LEC), or PSAP), along with the justification or rationale for their position.

  • Whether the appropriate demarcation point between wireless carrier, LEC, and PSAP responsibility to provide the various components or upgrades needed to implement Phase I will vary according to the technology employed to deliver those services?

  • Whether there is a rationale or precedent, based on the implementation of wireline E911 networks, for a particular division of costs among carriers and PSAPs in the implementation of wireless Phase I technologies? What is the division of costs between LECs and PSAPs in the provision of wireline E911 networks? Although the Commission has not imposed special obligations on LECs in implementing wireless E911, whether certain costs associated with Phase I technologies should be borne or shared by LECs?

This is a "permit but disclose" proceeding pursuant to §1.1206 of the Commission's Rules.4 Presentations to or from Commission decision-making personnel are permissible provided that ex parte presentations are disclosed pursuant to 47 C.F.R. §1.1206(b).

Parties interested in filing comments may do so on or before September 18, 2000 and reply comments are due on or before October 11, 2000. To file formally, parties must submit an original and four copies to the office of the Secretary, Federal Communications Commission, 445 12th Street, S.W., TW-A325, Washington, D.C. 20554. In addition, parties must submit one copy to E. Wendy Austrie, Policy Division, Wireless Telecommunications Bureau, Federal Communications Commission, Room 3-B101, 445 12th Street, S.W., Washington, D.C. 20554. Copies of the King County Request may be obtained from the following docket: CC Docket No. 94-102. Comments and reply comments will be available for public inspection during regular business hours in the FCC Public Reference Room, Room CY-A257, 445 12th Street, S.W., Washington, D.C. 20554.

For further information concerning this proceeding, contact E. Wendy Austrie, Policy Division, Wireless Telecommunications Bureau at (202) 418-1310.

- FCC -

1. Letter from Marlys Davis, E-911 Program Manager, King County E-911 Program Office, Department of Information and Administrative Services, to Thomas J. Sugrue, Chief, Wireless Telecommunications Bureau, FCC, dated May 25, 2000 ("King County Request").

2. In the Matter of Revision of the Commission's Rules To Ensure Compatibility with Enhanced 911 Emergency Calling Systems, Second Memorandum Opinion and Order, FCC 99-352, 14 FCC Rcd 20,850 (1999).

3. For the purposes of this Public Notice, we consider the E911 network to include all facilities and equipment beyond the wireless carrier’s switch necessary to transmit wireless 911 calls to PSAPs.

4. 47 C.F.R. §1.1206.