DA 01- 1836

Released: July31, 2001

**WTB SEEKS COMMENT ON WIRELESS E911 PHASE II WAIVER REQUEST**

**FILED BY VERIZON WIRELESS**

**CC DOCKET NO. 94-102**

# Comments Due: August 21, 2001

# Reply Comments Due: August 31, 2001

Federal Communications Commission (Commission) 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 25, 2001, Verizon Wireless requested a limited waiver of the
Phase II rules to permit it to deploy a network-assisted Global
Positioning System/Advanced Forward Link Trilateration (AGPS/AFLT)
handset solution for its CDMA broadband PCS network E-911 Phase II
solution on a schedule that deviates from the schedule contained in the
Commission's rules.[^3] In seeking a waiver, Verizon Wireless states
that it is persuaded that AGPS/AFLT is the best solution available and
will move forward to deploy that solution as aggressively as possible.
It will be unable to meet the Commission's rules' deadlines for Phase II
compliance, however, because the network updates and Phase II-capable
handsets will not be available in time and therefore seeks relief from
current Phase II implementation deadlines. Specifically, Verizon
Wireless seeks relief to:

-   Begin deploying the network-assisted portion of AGPS/AFLT by October
    1, 2100 in its switches and cell sites for Lucent markets; January
    1, 2002 for Nortel markets; and November 1, 2002 for Motorola
    markets.

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-   Complete deployment of these network upgrades by April 1, 2002 for
    Lucent markets; August 30, 2002 for Nortel markets; and March 1,
    2003 for Motorola markets.

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-   Begin selling AGPS/AFLT Phase II compliant handsets no later than
    December 31, 2001 and meet the following milestones for new handset
    activations: 25% of new handsets by July 31, 2002; 50% of new
    handsets by March 3, 2003; 100% of new handsets by December 31,
    2003; and 95% of embedded base by December 31, 2005.

Verizon Wireless also indicates that it plans to pursue two separate,
further technologies to provide enhanced location capability earlier to
bridge the transition to AGPS/AFLT: (1) installation of an interim
network-based hardware technology in three metropolitan areas on an
interim basis beginning in the Fall 2001 (St. Louis, Chicago and Houston
markets); and (2) continued testing of Enhanced Forward Link
Trilateration (ELFT), which has demonstrated that it can locate callers
on average between 250-350 meters, without the assistance of modified
handset and, if testing proves successful, to deploy EFLT in those
markets utilizing Lucent and Nortel switches.

Verizon Wireless states that in its November 9, 2000 Phase II E911
Report it chose a network-based technology based on the status of
development of location technology and the expected availability of that
technology. Although it developed and tested the network-based
technology, "based on all available information, Verizon Wireless has
determined that the AGPS/AFLT handset solution will provide the best and
most ubiquitous location capability while presenting fewer of the
problems that surfaced with the network technology."[^4] Thus, Verizon
Wireless states that approval of its comprehensive plan will serve the
public interest by permitting it to provide its customers with what it
believes is the most accurate location technology as quickly as
possible.

We seek comment on this waiver request. Parties interested in filing
comments may do so on or before August 21, 2001 and may file reply
comments on or before August 31, 2001.

This is a \"permit but disclose\" proceeding pursuant to § 1.1206 of the
Commission\'s Rules.[^5] 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 Jane
Phillips, Policy Division, Wireless Telecommunications Bureau, at (202)
418-1310.

-FCC-

[^1]: *See* 47 C.F.R. §§20.18(e)-(j).

[^2]: 47 C.F.R. §§20.18(f)-(h).

[^3]: *Updated Phase II E911 Report and Request for Limited Waiver,* CC
    Docket 94-102 (filed July 25, 2001) (*Verizon Wireless Petition*).

[^4]: Verizon Wireless Petition at 3.

[^5]: 47 C.F.R. § 1.1206.