DA 01-1628

Released: July 11, 2001

**WTB SEEKS COMMENT ON WIRELESS E911 PHASE II WAIVER REQUEST FILED BY
CINGULAR WIRELESS, LLC**

**CC DOCKET NO. 94-102**

# Comments Due: July 31, 2001

# Reply Comments Due: August 10, 2001

The Federal Communications Commission\'s (Commission\'s) rules require
wireless carriers to begin to deploy the capability to identify the
precise location of wireless 911 calls beginning on October 1, 2001,
provided that 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 both handset-based and network-based ALI
technologies.[^2]

On July 6, 2001, Cingular Wireless LLC (Cingular) requested 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 Global System for Mobile Communications
(GSM) air interface network and a switch-based technology, similar to
Mobile-Assisted Network Location System (MNLS), for its Time Division
Multiple Access (TDMA) network.[^3] According to Cingular, a waiver is
necessary because these solutions do not currently meet Phase II
accuracy requirements and cannot be deployed prior to the Phase II
implementation deadlines.[^4]

With respect to its GSM networks, Cingular indicates that E-OTD, the
same technology to be used by VoiceStream Wireless Corporation
(VoiceStream) under a waiver granted by the Commission last year,[^5]
ultimately will meet the Commission\'s accuracy requirements, but
initially, the technology will provide location accuracy of
approximately 100 meters for 67 percent of calls and 300 meters for 95
percent of calls.[^6] Cingular expects the accuracy of its E-OTD
solution to improve to meet the more stringent handset accuracy
requirements by October 1, 2003.

For its TDMA network, Cingular asserts that a switch-based solution will
cover its entire TDMA customer base immediately upon deployment and can
be deployed more quickly and economically than any other solution. [^7]
Although a switch-based technology 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), Cingular
states that it will provide a level of accuracy comparable to that
demonstrated by other full network solutions that Cingular has tested.
Cingular asserts that its switch-based technology will provide location
accuracy of approximately 250 meters for 67 percent of calls and 750
meters for 95 percent of calls.[^8] Cingular also indicates that it will
work to ensure that any TDMA networks converted to a new air interface
are fully compliant with the Phase II requirements from the outset.

We seek comment on this waiver request. Parties interested in filing
comments may do so on or before **July 31, 2001** and reply comments on
or before **August 10, 2001**.

This is a \"permit but disclose\" proceeding pursuant to § 1.1206 of the
Commission\'s Rules.[^9] 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]{.underline}. 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 12^th^ 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 12^th^ 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 12^th^ Street, S.W., Washington, D.C. or may be
purchased from ITS.

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

[^1]: *See* 47 C.F.R. §§20.18(e)-(j).

[^2]: 47 C.F.R. §§20.18(f)-(h).

[^3]: *Cingular Wireless LLC* *Petition for Limited Waiver of Section
    20.18(e)-(h) of the Commission's Rules*, CC Docket 94-102 (filed
    July 6, 2001) (*Cingular Petition*).

[^4]: *Cingular Petition* at 1-2.

[^5]: *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.*

[^6]: *Cingular Petition* at 26-27.

[^7]: *Id*. at 30.

[^8]: *Id*. at i.

[^9]: 47 C.F.R. § 1.1206.