DA 01-1645

Released: July 13, 2001

**WTB SEEKS COMMENT ON WIRELESS E911 PHASE II AMENDED WAIVER REQUEST
FILED BY D&E OMNIPOINT WIRELESS JOINT VENTURE, L.P.**

**CC DOCKET NO. 94-102**

**Comments Due: July 30, 2001**

**Reply Comments Due: August 6, 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 be used, specifically
for handset-based and network-based ALI technologies.[^2]

In a filing made on June 20, 2001, D&E/Omnipoint Wireless Joint Venture,
L.P. d/b/a PCS One (PCS One) requests a waiver of the E911 Phase II
Location Technology Implementation 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.[^3] PCS
One proposes implementing a network software solution (NSS) and a
handset--based technology called Enhanced Observed Time Difference of
Arrival (E-OTD).[^4] PCS One's waiver request mirrors the earlier waiver
request of VoiceStream, which was granted by the Commission on September
8, 2000.[^5]

Based upon its relationship with VoiceStream, PCS One believes that the
rationale for granting VoiceStream's waiver request applies equally to
PCS One; thus the Commission should grant PCS One a waiver of the E-911
Phase II rules subject to the same conditions as the waiver granted to
VoiceStream.[^6] PCS One is a personal communications services licensee
(PCS) that operates a cellular telecommunications service network in
eastern Pennsylvania. PCS One is fifty (50) percent owned by VoiceStream
and fifty (50) percent owned by D&E Communications, Inc.[^7] PCS One
believes that it is in the interest of public safety, efficiency, and
seamless service for both PCS One and VoiceStream to utilize the same
E-911 solution.[^8] According to PCS One, the regional networks operated
by VoiceStream and D&E are subject to several cooperative arrangements
and are technically integrated.[^9] Furthermore, PCS One argues that
VoiceStream's ownership interest in PCS One, the geographic proximity to
the PCS One network of VoiceStream systems utilizing the same digital
technology, and the technical integration between the systems on a
regional basis are all reasons to grant its request for a waiver of the
Phase II E-911 rules.[^10]

We seek comment on PCS One's waiver request. Parties interested in
filing comments may do so on or before **July 30, 2001** and may file
reply comments on or before **August 6, 2001**.

This is a \"permit but disclose\" proceeding pursuant to § 1.1206 of the
Commission\'s Rules.[^11] 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 Gregory
Vadas, 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]: *D&E/Omnipoint Wireless Joint Venture, L.P. Petition for Waiver of
    the E911Phase II Location Technology Implementation Rules,* CC
    Docket 94-102, filed June 20, 2001 (*Waiver Request).*

[^4]: *Id* at 2.

[^5]: *See 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 (E911Fourth Memorandum Opinion and Order*).

[^6]: *Waiver Request* at 3.

[^7]: *Id* at 2.

[^8]: *Id* at 3.

[^9]: *Id* at 3.

[^10]: *Id* at 3.

[^11]: 47 C.F.R. § 1.1206.