DA 01-1042

Released: April 23, 2001

**WTB SEEKS COMMENT ON WIRELESS E911 PHASE II WAIVER REQUEST FILED BY
CAROLINA PCS I, LP**

**CC DOCKET NO. 94-102**

**Comments Due: May 23, 2001**

**Reply Comments Due: June 7, 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 February 6, 2001, Carolina PCS I, LP (Carolina)
requests a waiver of the Phase II rules to permit it to deploy a hybrid
ALI approach for its Global System for Mobile Communications (GSM)
network that would include both network and handset upgrades. Carolina
proposes implementing a network software solution (NSS) and a
handset-based technology called Enhanced Observed Time Difference of
Arrival (E-OTD).

To accomplish the Phase II implementation, Carolina indicates that it
intends to deploy NSS/E-OTD, the same technology to be used by
VoiceStream Wireless Corporation (VoiceStream) under a waiver granted by
the Commission last year.[^3] Carolina claims that it faces
circumstances similar to VoiceStream and that, while E-OTD ultimately
will meet and even exceed the Commission\'s accuracy requirements,
Carolina requires a temporary waiver of the Commission\'s accuracy rules
for location technologies, specifically Sections 20.18(e) and (h) of the
Commission's rules. According to Carolina, its NSS/E-OTD approach is the
only ALI solution available in the near term for GSM systems for
compliance with Phase II.

Carolina represents that it is willing to comply with the same
conditions placed on VoiceStream pursuant to its waiver request granted
by the Commission in the *E911 Fourth Memorandum Opinion & Order.*
Specifically, Carolina proposes to deploy NSS capability by the fourth
quarter of 2001 and have NSS deployment throughout its network by or
before December 31, 2001, regardless of whether it has received any PSAP
requests. The NSS technology will provide a radial location with an
accuracy of 1000 meters for 67 percent of the calls.

In combination with NSS, Carolina proposes to implement E-OTD, and will
ensure that at least 50 percent of all new handsets are E-OTD capable by
October 2001, and that 100 percent of all new handsets are E-OTD capable
by March 31, 2002. Carolina proposes that by October 1, 2001, all new
E-OTD capable handsets will provide ALI with an accuracy of 100 meters
67 percent of the time and 300 meters 95 percent of the time. Carolina
proposes to ensure that all new E-OTD capable handsets activated on or
after October 1, 2003 comply with an accuracy requirement of 50 meters
for 67 percent of calls and 150 meters for 95 percent of calls. Carolina
states that, subject to the proposals and limitations listed above,
within 6 months after a PSAP request or October 1, 2001, whichever is
later, Carolina will implement any network or infrastructure upgrades
necessary to provide Phase II handset-based service and begin providing
Phase II location information.

Carolina also proposes that it will comply with the requirement to
achieve 95 percent penetration of location-capable handsets among its
subscribers no later than December 31, 2005. Carolina represents that it
will report to the Wireless Telecommunications Bureau semiannually
through October 1, 2003 on its experience with NSS and E-OTD, including
actual deployment and the results of all tests and trials.

We seek comment on this waiver request. Parties interested in filing
comments may do on or before **May 23, 2001** and reply comments on or
before **June 7, 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]{.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
Tomchin, Policy Division, Wireless Telecommunications Bureau, at (202)
418-1310.

-FCC-

[^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 (E911 Fourth Memorandum Opinion & Order) .*

[^4]: 47 C.F.R. § 1.1206.