DA 03-1771

May 23, 2003

**PARTIES INTERESTED IN PERFORMING AS A CELLULAR SID ADMINISTRATOR MUST
SIGN A MEMORANDUM OF UNDERSTANDING BY JUNE 9, 2003**

On November 7, 2002, the Commercial Wireless Division (Division) began
the process of transitioning the administration of Cellular System
Identification Numbers (SIDs) from the FCC to the private sector. By
this Public Notice, the Division is asking parties interested in being
recognized as a Cellular SID Administrator to complete the attached
Memorandum of Understanding (MOU) and file it with the Commission by
June 9, 2003. [^1]

On March 25, 2003, the Division released its proposed general Guidelines
to be used by all recognized Cellular SID Administrators and asked the
industry to provide comments.[^2] The Division received comments from
four organizations.[^3] After careful consideration of the comments
received, we believe that the Guidelines released in March,[^4]
including the use of multiple Cellular SID Administrators, is the right
direction for transitioning the responsibility of Cellular SID
administration from the FCC to the private sector. The refinement and
further development of the Guidelines, as well as the actual
administration process, should be the responsibility of the entities who
are recognized to perform Cellular SID Administration and who are
knowledgeable of the needs of the Cellular industry.

After the Division receives the completed MOUs from parties interested
in performing as a Cellular SID Administrator, another Public Notice
will be released identifying the Administrators and asking the
Administrators to work together to develop the SID administration
process including: developing and maintaining the database, defining the
process for a cellular licensee to request a SID, coordinating
assignments among multiple administrators, developing any industry
oversight that might be required, and revising the Guidelines to
incorporate the administration process and revising other sections, as
appropriate, to meet the needs of the cellular industry. This future
Public Notice will ask the Administrators to provide the Division,
within forty-five (45) days, a basic outline of their plan and a time
frame for implementation and transition to the private sector. **Until
announced by Public Notice, the FCC will continue to perform the
administration process for Cellular SIDs.**

Parties interested in becoming a Cellular SID Administrator must
complete the attached MOU by **June 9**, **2003**. All filings should
refer to WT Docket No. 01-108 and reference *Cellular SID
Administration*. The MOU may be filed electronically via the
Commission's Electronic Comment Filing System (ECFS) or by paper, as
explained below.

-   **If filed by ECFS**, comments shall be sent as an electronic file
    via the Internet to http://www.fcc.gov/cgb/ecfs/. Only one copy of
    an electronic submission must be filed through ECFS. In completing
    the transmittal screen, parties should include their full name,
    Postal Service mailing address, and the applicable docket number, WT
    01-108. Parties may also submit an electronic comment by Internet
    e-mail. To get filing instructions for e-mail comments, parties
    should send an e-mail to ecfs@fcc.gov, and should include the
    following words in the body of the message, "get form." A sample
    form and directions will be sent in reply. See the "**NOTE**" below
    for an additional filing requirement.

-   **If filed by paper**, an original and four copies of each filing
    must be filed by hand or messenger delivery, by commercial overnight
    courier, or by first-class or overnight U.S. Postal Service
    mail.[^5] The Commission's contractor, Vistronix, Inc., will receive
    hand-delivered or messenger-delivered paper filings for the
    Commission's Secretary at 236 Massachusetts Avenue, N.E., Suite 110,
    Washington, D.C. 20002.[^6] The filing hours at this location are
    8:00 a.m. to 7:00 p.m. All hand deliveries must be held together
    with rubber bands or fasteners. Any envelopes must be disposed of
    before entering the building. Commercial overnight mail (other than
    U.S. Postal Service Express Mail and Priority Mail) must be sent to
    9300 East Hampton Drive, Capitol Heights, MD 20743. U.S. Postal
    Service first-class mail, Express Mail, and Priority Mail should be
    addressed to 445 12th Street, SW, Washington, D.C. 20554. All
    filings must be addressed to the Commission's Secretary, Office of
    the Secretary, Federal Communications Commission. See the "**NOTE**"
    below for an additional filing requirement.

**NOTE**: **Regardless of the filing method used, electronic or paper,
all parties interested in becoming a Cellular SID Administrator must
also send a paper copy of the signed MOU addressed to the Commission's
Secretary, Office of the Secretary, Federal Communications Commission,
with a cover letter directed to the [attention of Denise
Walter]{.underline}, Room 4-B421, Commercial Wireless Division, Wireless
Telecommunications Bureau.** **This filing should be accompanied by a
self-addressed stamped envelope**.

A copy of the MOU must also be delivered electronically, by e-mail or
facsimile, or if delivered as paper copy, by hand or messenger delivery,
by commercial overnight courier, or by first-class or overnight U.S.
Postal Service mail (according to the procedures set forth above for
paper filings) to the Commission's duplicating contractor, Qualex
International, at qualexint@aol.com or (202) 863-2898 (facsimile).

The completed MOUs are available for public inspection and copying in
the FCC's Reference Center, 445 12^th^ Street, SW, Room CY-A257,
Washington, DC 20554. Copies of the MOUs may also be obtained from the
Commission's duplicating contractor, Qualex International, Portals II,
445 12th Street, SW, Room CY-B402, Washington, DC, 20554, telephone
(202) 863-2893, facsimile (202) 863-2898, or e-mail at
<qualexint@aol.com>. The request is also available electronically
through ECFS, which may be accessed on the Commission's Internet website
at http://www.fcc.gov/e-file/ecfs.html by entering the Docket Number of
this proceeding, WT Docket No. 01-108.

For further information, contact Denise Walter, Commercial Wireless
Division, Wireless Telecommunications Bureau, at 202-418-0620 or
denise.walter@fcc.gov.

MEMORANDUM OF UNDERSTANDING

Between

Federal Communications Commission

and

**\[SID Administrator\]**

**REGARDING THE ADMINISTRATION OF CELLULAR SYSTEM IDENTIFICATION NUMBERS
(SIDs)**

1\. PARTIES. The parties to this Memorandum of Understanding (MOU or
Agreement) are the Federal Communications Commission (FCC) and **\[SID
Administrator\].**

2\. AUTHORITY. The authority to enter into this agreement was delegated
to the Wireless Telecommunications Bureau by the Commission.[^7]

3**.** PUPROSE. The purpose of the MOU is to provide a means for **\[SID
Administrator\]** to administer the process of assigning System
Identification Numbers (SIDs) to cellular licensees.

4\. RESPONSIBLITIES. The responsibilities of a Cellular SID
Administrator are outlined in a separate document entitled *Guidelines
for Cellular SID Administrators* (Guidelines) which is included as
*Attachment A* of this MOU.

5\. POINTS OF CONTACT. For purposes of this Agreement, the point of
contact for the FCC is the Wireless Telecommunications Bureau,
Commercial Wireless Division, 202-418-0620. The point of contact for
**\[SID Administrator\]** is **\[Name of Contact\]**.

6\. LIMITATION ON ASSIGNMENT OR TRANSFER. This Agreement may not be
sold, assigned or transferred to any party without the prior written
approval of the FCC. In addition, **\[SID Administrator\]** agrees to
report to the FCC, within **sixty (60) days** of its concurrence, any
matters that could reasonably be expected to impair its ability to
perform the duties authorized under this Agreement, including, but not
limited to, a filing for bankruptcy or any legal or administrative
proceeding that may bear upon **\[SID Administrator's\]** ability to
perform the duties authorized under this Agreement.

7\. OTHER PROVISIONS. Nothing in this Agreement is intended to conflict
with current law or regulation or directives of the FCC. If a term of
this Agreement is inconsistent with such authority, then that term shall
be invalid, but remaining terms and conditions of this Agreement remain
in full force and effect.

8\. EFFECTIVE DATE. The terms of this Agreement will become effective on
the date of the last signature subscribed below.

9\. MODIFICATION. This Agreement and the Guidelines constitute the
entire Agreement of the parties. The FCC may initiate changes to the
Agreement and the Guidelines by providing at least 30 days written
notice to SID Administrators. Any changes to the Agreement requested by
the SID Administrator must be mutually agreed to in writing by both
parties to the Agreement. The process to modify the Guidelines is
described in Section 8.0 of the Guidelines.

10\. TERMINATION. This Agreement is effective until terminated. Either
party may terminate this Agreement by providing sixty (60) days notice
to the other party. This Agreement may also be terminated by the FCC for
cause at any time, if after notice of breach and a sixty (60) day period
to cure the breach, the breach remains uncured. A breach is a failure of
**\[SID Administrator\]** to perform any of the responsibilities under
Section 4 of this Agreement outlined in the *Guidelines for Cellular SID
Administrators*. Notifications required by this paragraph must be
provided by Certified Mail -- Return Receipt Requested and commence the
day the Certified Mail is received by the other party. Within 30 days of
termination of this Agreement for any reason, **\[SID Administrator\]**
shall provide the FCC with a current and complete database of all
cellular licensees and their SIDs.

11\. APPROVAL. In accordance with the forgoing, the parties have
indicated their approval of this Agreement as of the dates written
below.

**FEDERAL COMMUNICATIONS SID Administrator**

**COMMISSION**

By: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ By:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Date: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Date:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

**ATTACHMENT A**

**Guidelines for Cellular SID Administrators**

**May 22, 2003**

1.0 PURPOSE AND SCOPE

This document contains guidelines for the FCC-recognized Administrators
for Cellular System Identifier Numbers (SIDs) within the United States.

1.1 Since the early 1980's, Cellular SIDs have been assigned by the FCC
and have been a required element of the FCC authorization.

1.2 In August 2002, the Commission adopted an Order to eliminate SIDs
from being a required element of the license and to transition the
administration of SIDs to the private sector.

2.0 CELLULAR SID FUNCTION

2.1 System Identification Numbers, or SIDs, are numeric identifiers
assigned to cellular systems. SIDs are transmitted by the cellular
system so that the cellular mobile stations can determine whether the
system through which they are communicating is a system to which they
subscribe, or whether they are considered by the system to be roamers.

3.0 ASSUMPTIONS AND CONSTRAINTS

These guidelines are based on the following assumptions and constraints:

3.1 These guidelines should provide the greatest latitude to those
providing cellular services while permitting the effective and efficient
management of a finite resource.

3.2 The Cellular SID Administrators initially recognized by the FCC are
responsible for developing an efficient process for administering
Cellular SIDs in a multiple Administrator environment. The process will
be reviewed by the FCC and then incorporated in these Guidelines under
Section 7.0.

3.3 A Cellular Carrier can request a SID from any one of the
FCC-recognized Cellular SID Administrators.

3.4 New Cellular SID Administrators can be recognized by the FCC by
filing a letter of intent and certifying they will comply with the
guidelines and then signing a Memorandum of Understanding with the
Wireless Telecommunications Bureau.

4.0 ASSIGNMENT PRINCIPLES

The assignment principles defined below allow cellular systems the
greatest possible latitude in providing seamless roaming capabilities.

4.1 Information requested from applicants for Cellular SID numbers will
be kept uniform and kept to a minimum.

4.2 Maintain the current practice of assigning odd number SIDs to
Channel Block "A" licensees and even number SIDs to Channel Block "B"
licensees.

4.3 The assignment of a Cellular SID number does not imply ownership of
the Cellular SID number.

4.4 If a license experiences a transfer of control or assignment of
authorization, the authorized use of the Cellular SID remains with the
license.

4.5 A request to use a SID assigned to another carrier must be
accompanied by a notice stating that the authorized SID user concurs
with the request

5.0 RESPONSIBILITIES OF CELLULAR SID ADMINISTRATORS

These general guidelines will be used by the Cellular SID Administrators
in reviewing and processing requests for a SID. A Cellular SID
Administrator will:

5.1 Assign a Cellular SID number to any FCC licensed cellular carrier
who submits the appropriate request for a SID assignment.

5.2 Assign SID numbers in a fair, timely and impartial manner to any
applicant that meets the criteria for assignment (see 5.1).

5.3 Assign SID numbers on a first come, first served basis from the
available pool.

5.4 Request the minimum information necessary to make a SID assignment.

5.5 Assign the number of SIDs requested based on industry practices.

5.6 Treat sensitive information received from applicants as proprietary
and confidential, and not to be shared with non-administrator personnel.

5.7 Ensure that fees charged for services are fair and reasonable.

5.8 Provide the Public with access to a complete listing of assigned
SIDs updated annually.

6.0 RIGHTS AND RESPONSIBILITIES OF CELLULAR SID APPLICANTS AND ASSIGNEES

Entities requesting a Cellular SID assignment shall:

6.1 Keep administrative information current with an Administrator.

6.2 Have the right to request a SID from any one of the recognized
Cellular SID Administrators

6.3 Comply with all applicable regulations.

7.0 CELLULAR SID ASSIGNMENT PROCEDURES

7.1 \[Reserved for the SID assignment procedures, including the
coordination of SID assignments in a multi-administrator environment.
Procedures will be developed by the initial FCC-recognized Cellular SID
Administrators.\]

8.0 MAINTENANCE OF GUIDELINES

8.1 Cellular SID Administrators may request modifications to the
Guidelines by sending their request to the FCC. Requests to modify the
Guidelines should be based on a consensus agreement of all SID
Administrators.

8.2 The FCC may initiate changes to the Guidelines by providing the
Administrators with at least 30 days written notice.

[^1]: To complete the Memorandum of Understanding, download the MOU into
    a word document and replace the 8 instances of \[SID Administrator\]
    with the name of the organization. Also enter the contact person
    under *Points of Contact*, Section 5, and sign and date the MOU.

[^2]: *See* Commercial Wireless Division Seeks Comments on Its Proposed
    Guidelines for Cellular SID Administrators, *Public Notice,* DA
    03-864, rel. March 25, 2003.

[^3]: Comments were received from Telcordia Technologies, CIBERNET, the
    Alliance for Telecommunications Industry Solutions (ATIS), and NECA
    Services, Inc. In general, the comments expressed some concern with
    the Division allowing multiple SID Administrators as opposed to one
    designated Administrator. The comments also offered a few
    suggestions for expanding the proposed Guidelines.

[^4]: The Division made minor changes to Sections 5 and 8.

[^5]: Please note that we continue to experience delays in receiving
    U.S. Postal Service mail.

[^6]: *See* FCC Announces a New Filing Location for Paper Documents and
    a New Fax Number for General Correspondence, *Public Notice,* 16 FCC
    Rcd 22,165 (2001).

[^7]: *See* In the Matter of Year 2000 Biennial Regulatory Review --
    Amendment of Part 22 of the Commission's Rules to Modify or
    Eliminate Outdated Rules Affecting the Cellular Radiotelephone
    Service and other Commercial Mobile Radio Services, WT Docket No.
    01-108, *Report and Order*, 17 FCC Rcd 18401 (2002).