DA 01-2187

Released: September 19, 2001

**WTB SEEKS COMMENT ON WIRELESS E911 PHASE II WAIVER REQUEST FILED BY
AT&T WIRELESS SERVICES, INC.**

**CC DOCKET NO. 94-102**

**Comments Due: October 4, 2001**

**Reply Comments Due: October 11, 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 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 April 4, 2001, AT&T Wireless Services, Inc. (AT&T) requested a waiver
of the E911 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 planned Global System for Mobile
Communications (GSM) air interface network and a technology called
Mobile-Assisted Network Location System (MNLS) for its current Time
Division Multiple Access (TDMA) network.[^3]

On September 17, 2001, AT&T filed a letter amending its request for
waiver with respect to its TDMA network.[^4] In lieu of implementing
MNLS as its E911 Phase II network-based solution for its TDMA network,
AT&T seeks permission to deploy either TruePosition or Grayson Wireless
(Grayson)'s network overlay technologies. AT&T believes that it will be
able to secure a contractual commitment from one of these two technology
vendors within the next 30 days. Both TruePosition and Grayson have
represented to AT&T that their E911 Phase II solutions will meet the
Commission's accuracy requirements and that they have the resources
available to install their solutions in those TDMA markets where AT&T
currently has valid PSAP requests for Phase II E911 service beginning no
later than November 1, 2001, and ending no later than December 31, 2002.
After 2002, AT&T expects to be able to deploy Phase II technology within
six months of a valid PSAP request. In markets that utilize a
combination of air interfaces other than TDMA or TDMA/AMPS, such as
TDMA/GSM, AT&T plans to deploy either TruePosition's or Grayson's
network overlay solution, or another solution that complies with the
Commission's rules or for which AT&T has previously obtained a waiver.

We seek comment on this waiver request. Parties interested in filing
comments may do on or before **October 4, 2001** and reply comments on
or before **October 11, 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 Qualex
International, Portals II, 445 12th Street, SW, Room CY-B402,
Washington, DC, 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 at
the FCC Reference Information Center, Portals II, 445 12th Street, SW,
Room CY-A257, Washington, DC, 20554. They may also be purchased 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 via e-mail
**qualexint@aol.com**.

For further information concerning this proceeding, contact Jennifer
Tomchin, 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]: AT&T Wireless Services, Inc. Request for Waiver of the E911 Phase
    II Location Technology Implementation Rules, filed April 4, 2001.

[^4]: *Ex Parte* Letter from Douglas I. Brandon, AT&T Wireless Services
    Inc. to Thomas Sugrue, Chief, Wireless Telecommunications Bureau, CC
    Docket No. 94-102, filed September 17, 2001.

[^5]: 47 C.F.R. § 1.1206.