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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 01-894
Released: April 6, 2001

CC DOCKET NO. 94-102

Comments Due: May 7, 2001

Reply Comments Due: May 21, 2001

Under the Federal Communications Commission's (Commission's) rules, wireless carriers are required to begin deploying the capability to identify the precise location of wireless 911 calls beginning on October 1, 2001, provided certain conditions are met.1 This capability is called Phase II Automatic Location Identification (ALI). The Phase II rules establish deployment schedules and set accuracy and reliability requirements for location technologies that might used, specifically for handset-based and network-based ALI technologies.2

In a filing made on April 4, 2001, AT&T Wireless Services, Inc. (AT&T) requests a waiver of the Phase II rules to permit it to deploy a hybrid network and handset-based technology called Enhanced Observed Time Difference of Arrival (E-OTD) throughout its planned Global System for Mobile Communications (GSM) air interface network and a technology called Mobile-Assisted Network Location System (MNLS) for its current Time Division Multiple Access (TDMA) network. According to AT&T, it has announced plans to overlay a GSM platform on its TDMA network, which will give the network higher speed data capabilities and offer AT&T's customers a wider array of mobile devices, expediting the provision of the next generation of advanced wireless services to customers. AT&T claims, however, that rolling out this new interface will seriously complicate its efforts to comply with the Phase II rules.

To accomplish the GSM rollout and Phase II implementation, AT&T indicates that it intends to deploy E-OTD, the same technology to be used by VoiceStream Wireless Corporation (VoiceStream) under a waiver granted by the Commission last year.3 AT&T claims that it faces circumstances similar to VoiceStream and that, while E-OTD ultimately will meet and even exceed the Commission's accuracy requirements, AT&T requires a temporary waiver of the Commission's accuracy rules for handset-based location technologies.

For its existing TDMA network, AT&T asserts that MNLS, which is a network-overlay solution, will bring E911 Phase II service to its customers in the shortest possible timeframe, with initial deployment by the end of 2001 and complete system-wide deployment by the end of the first quarter of 2002. AT&T claims that MNLS has a number of advantages over other solutions it investigated, including the fact that it will work with all TDMA handsets. Although MNLS will not satisfy the Commission's location accuracy requirement for network-based solutions (100 meters for 67 percent of calls/ 300 meters for 95 percent of calls), AT&T states that it will provide a level of accuracy comparable to that demonstrated by other network-based solutions that AT&T has tested. AT&T asserts that MNLS will provide location accuracy of approximately 250 meters for 67 percent of calls and 750 meters for 95 percent of calls.

We seek comment on this waiver request. Parties interested in filing comments may do on or before May 7, 2001 and reply comments on or before May 21, 2001.

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).

Comments may be filed using the Commission’s Electronic Comment Filing System (ECFS) or by filing paper copies. Comments filed through the ECFS can be sent as an electronic file via the Internet to http://www.fcc.gov/e-file/ecfs.html. In completing the transmittal screen, commenters should include their full name, Postal Service mailing address, and the docket number of this proceeding. Parties that choose to file by paper must file an original and four copies of each filing with the Office of the Secretary, Federal Communications Commission, 445 12th Street, S.W., Washington, D.C. 20554, and a diskette copy with the Commission’s copy contractor International Transcription Service, Inc. (ITS), Room CY-B400, Federal Communications Commission, 445 12th Street, S.W., Washington, D.C. 20554. The filing should include the docket number of this proceeding: CC Docket No. 94-102. Filings and comments are also available for inspection and copying during regular business hours in the Reference Information Center, Federal Communications Commission, Court Yard Level, Room CY-A257, 445 12th Street, S.W., Washington, D.C. or may be purchased from ITS.

For further information concerning this proceeding, contact Dan Grosh or Patrick Forster, Policy Division, Wireless Telecommunications Bureau, at (202) 418-1310.

1 47 C.F.R. §20.18.

2 47 C.F.R. §20.18(f)-(h).

3 Revision of the Commission's Rules To Ensure Compatibility with Enhanced 911 Emergency Calling Systems, CC Docket No. 94-102, Fourth Memorandum Opinion and Order, 15 FCC Rcd 17,442 (2000), recon. pending.

4 47 C.F.R. § 1.1206.