Minutes from FCC E911 Multi-Party Meeting

**July 6, 2000**

Tom Sugrue, Chief, Wireless Telecommunications Bureau (WTB), welcomed
participants and stated that the intent of this meeting was to discuss
potential E911 Automatic Location Identification (ALI) technologies.
E911 ALI is an important issue for the Commission, the Chairman, and the
Wireless Telecommunications Bureau, and lately there have been several
conflicting reports about the effectiveness of the different proposed
ALI technologies. Because E911 ALI is a multi-faceted process, the WTB
thought it would be useful to gather information from wireless carriers,
manufacturers, and public safety entities about the status of the
various proposed ALI technologies for input into the Commission's
reconsideration process concerning E911 ALI requirements.

# Questions for Carriers

What air interface(s) do(es) the company use? What location solutions
are available, network, handset, and hybrid, for the various interfaces,
AMPS, CDMA, TDMA, and GSM? What testing has been completed and what were
the results? Have test results been verified? What are potential
deployment time frames?

# AT&T Wireless

AT&T Wireless uses TDMA for its digital networks. AT&T has been
reviewing every location technology that is available and has
field-tested several network solutions. Early on, AT&T determined that
handset manufacturers would not be able to meet the deadlines, so it has
not pursued a handset solution. AT&T reviewed 13 technologies in the
lab, relying on test results provided by the vendors, and deployed two
network-based technologies in six cell sites for real-world testing.
Initial results from AT&T's field tests did not meet the mandated
accuracy. AT&T's experience with Enhanced Observed Time Difference
(E-OTD) shows that, due to the TDMA channelization, it will be difficult
for this technology to meet the FCC's accuracy and timing requirements
for AT&T's network.

# BellSouth Cellular

BellSouth Cellular uses AMPS, TDMA, and about 15 percent GSM for its
networks. BellSouth is pessimistic about the test results it has
obtained so far. When implementing an ALI location technology, BellSouth
said that availability of equipment must be considered, i.e., prototypes
are needed for testing in the first phase of an implementation, and a
volume of equipment is needed for installation and further testing in
later phases. BellSouth said there is a variety of network-based
equipment for AMPS and TDMA that is available for testing, and soon
there will be equipment available for GSM. Also, for a handset solution,
there are prototype handsets available for TDMA, GSM, and AMPS, but
there would not be enough handsets produced in time to meet the
deadlines.

BellSouth also believes that there will not be enough network equipment
available for a large scale deployment by the October 1, 2001, deadline
because of the time that manufacturers need to produce equipment, as
BellSouth experienced when obtaining equipment for testing. There are
many other considerations when installing a network solution, even if
network equipment is available, including RF planning, tower leases,
building leases, zoning issues, scheduling tower climbers, DS-0
installation, testing, calibration, training, maintenance, and
installing the PSAP interface. BellSouth has field-tested Angle of
Arrival (AOA), Time Difference of Arrival (TDOA) (with two different
vendors), E-OTD network equipment, and GPS handset technology, and has
seen demonstrations of other vendors' equipment. Even though some
technologies are better than others, depending on the environment,
BellSouth concluded that no technology would meet the accuracy
requirements with 100 percent certainty. None of them would be available
for deployment by the deadlines.

# NEXTEL

NEXTEL uses the iDEN air interface (with a GSM-based switch) and is
considering a network overlay solution. NEXTEL considers availability a
subjective term because even if network vendors say that equipment is
available, carriers must consider many factors, such as RF interfaces
with existing infrastructure, and PSAP interfaces using GMLC and SMLC
devices. Beginning in 1999, NEXTEL tested 15 vendors' solutions and has
narrowed their choice down to five possibilities. To compare
technologies, NEXTEL tested network overlay, assisted GPS, and E-OTD
solutions in the D.C. metropolitan area, collecting more than 2000 data
points over a four-day period. Consultants are now analyzing and
validating the data; results will be available soon. After consulting
with the single manufacturer that supplies its handsets, NEXTEL
concluded that handsets would not be produced by the deadlines. NEXTEL
is concerned about its ability to support a network solution and
expressed its preference to implement Phase II on a nationwide basis,
rather than on an individual PSAP-request basis. NEXTEL also expressed
concerns about methods to recover costs.

# SBC Wireless

SBC Wireless, which has AMPS, TDMA, and GSM networks, has had
experiences similar to those described by other carriers. SBC has no
handset experience, but it has performed a number of tests on paper and
some live network testing on technology that determines the X, Y
coordinates of location and expressed the view that converting this data
to a format that can be used by PSAPs is problematic. Two tests have
been completed and a third is in progress. SBC has the same concerns
about equipment availability, in the allowed time frame, that other
carriers have mentioned.

# U.S. Cellular

U.S. Cellular uses TDMA, AMPS, and some CDMA air interfaces. Two U.S.
Cellular engineers observed TDOA and AOA lab testing, and TDOA appears
to work well in an ideal lab environment. Due to the predominantly rural
nature of its systems, U.S. Cellular feels that it will have to deploy
multiple location technologies. U.S. Cellular cited numerous problems
with deploying a network solution. For example, TDOA requires that cell
sites be appropriately located and, in rural environments needs three
towers for an accurate location determination. AOA may work with fewer
than 3 towers, and may work adequately in a typical rural string of
pearls configuration along the highway. U.S. Cellular has tested an AMPS
GPS solution (the Tendler phone) and this appears to be the ideal
solution for its rural service areas. Based on conversations with
handset manufacturers, no product will be available by the due date.

# Questions for Handset Manufacturers

What is the availability of handset solutions? What is the deployment
time frame?

What is the time frame for production of handsets?

# Nokia 

Nokia is not the sole supplier to any carrier, and no carrier has given
it an order. Nokia supplies a "tier" of handset models---good, better,
best. There have been several requests for information (RFIs) from
carriers about potential impacts on size, cost, battery, and memory for
a handset solution, which Nokia has answered. Technology availability
varies, depending on the air interface, and the earliest availability
for a U.S./Canada GSM deployment could be near the end of 2002. Nokia
also expressed the view that production capacity for all handset-based
solutions, across air interfaces, will occur sometime in 2002. There is
a tremendous amount of risk and no firm decisions have been made.
Complicating matters is the different strategy for value-added services.
A cell phone with GPS is very much different than simply a box with a
GPS locator inside. In addition, there are no rules for the evolution of
technology in the U.S., and there are different technical innovations
occurring simultaneously, especially between 2001 and the end of 2003.
Nokia has asked customers for prioritization but nothing has been
forthcoming. While E911 ALI implementation is an important issue,
industry only has so much capacity to deploy technologies. Nothing
definite has been decided and technologies to implement E911 ALI could
take a number of different directions.

Nokia believes it would take two years from an order date to get to 50%
activation of ALI-capable handsets for a single carrier. One year would
be needed to get a handset in working shape and another year to complete
compliance and reliability testing. Also, Nokia believes that the only
way to achieve the 50% new activation requirement is to put GPS into the
lowest end handset models because high cost models sell the least. In
addition, there are complications because of the need to involve
specialists for the different air interfaces and the cooperation and
coordination required for deployment. Because there are no standards,
there is a question whether software will work between carriers.
Currently, Nokia's task is to build a product based on a standard
platform, and then customize it to fit a carrier's requests. E-OTD
equipment for GSM will be available close to the mandated dates (end of
2001-beginning of 2002). E-OTD for TDMA will not meet the accuracy
requirements.

# Motorola

Motorola agrees with the points that Nokia raised. To meet different
interface and market requirements, Motorola needs to develop a variety
of products. Firm commitments from carriers for specific products and
air interfaces would be helpful, but Motorola does not have enough
resources to deliver for all of the air interfaces. Prioritization will
be necessary, based on customer input. While Motorola can sometimes
anticipate the direction of solutions, RFIs and RFQs do not drive its
allocation of resources. Motorola can attempt to be prepared, developing
specific solutions, but based on conversations with customers, there is
no clear picture of the best way to proceed. There are many
uncertainties about how to capture a customer's business, making it
difficult to determine how to structure products and creating
substantial risk.

Assisted GPS stands the best chance of meeting the timing and accuracy
requirements. Motorola does not believe that AFLT or E-OTD will meet the
current accuracy requirements. There is also a dilemma about how to
handle a costly add-on function. In the volume needed for the market,
Motorola may not be able to hide the cost of this location solution, and
cannot offer it to operators or consumers without additional costs;
making end user purchasing decisions difficult to predict. To deploy a
cost effective solution in a given form factor, the GPS solution must be
highly integrated, which will require different chip sets for different
manufacturers, especially in the low-end market.

In June of this year, Motorola finally received a license to use
SnapTrack's GPS technology. Motorola could not use this technology
before due to an incomplete agreement, which was delayed by Qualcomm's
acquisition of SnapTrack and SnapTrack's confidentiality constraints.
Work on a cost-effective solution (chip development then product
development) can now begin. Motorola needs one year for chip development
and one year after that to integrate the chips into the product
platform. Then, time would be needed to test the technology and
integrate it with carrier systems. Motorola will not be in a position to
ship 50% of GPS units until a few months beyond the two-year development
period. Motorola does not believe that E-OTD will meet the accuracy
requirements for iDEN and GSM. A benign environment was needed to meet
the 50-meters/67% requirement and anything less than optimum degraded
the results two to three times.

# Questions for Location Technology Vendors

What technology is being developed? What trials have been performed?
Where have they been conducted? What accuracy levels were achieved? Have
test results been independently verified? What is the deployment time
frame? Is the technology scalable? Can numerous large orders be handled?

# Cell-Loc

Cell-Loc is a service provider that builds networks to provide x-y
location information. Working for the last 11 years to perfect its
technology, Cell-Loc has spent the last four years testing its
technology in the same network, with 18 months of testing in downtown
Toronto. Cell-Loc will launch its first commercial service in Calgary on
July 7, 2000. Initially, Cell-Loc will only provide 411 (information)
services and fleet management. There is no 911 requirement in Canada;
911 services will be a non-revenue-generating by-product of Cell-Loc's
system that it can make available to carriers. This is possible because
Cell-Loc can use the same hardware to provide service for all the
standards. The same "card" can provide x-y information for AMPS, CDMA,
TDMA, GSM, and other standards. Cell-Loc plans to deploy its technology,
including 911 service, in Austin, Texas September 1, and then move to
Dallas soon after. Cell-Loc hopes to double the number of cities
deployed every quarter.

Cell-Loc plans to offer its 911 service to carriers free of charge.
Revenue streams will come from other services. Cell-Loc uses a
combination TDOA/voice positioning technology and the accuracy improves
with longer conversations, the same as for assisted-GPS. Cell-Loc
indicated that with AMPS, it has achieved test results of 31-92 meters,
67% of the time and 21-148 meters, 95% of the time. Cell-Loc plans to
focus on wireless-internet and portal services, as well as other
location-oriented services (e.g., locators in dog collars and children's
clothing, location-specific advertising). Cell-Loc has, so far, declined
to trial with any U.S. carrier. Although it has not done any testing in
the U.S., Cell-Loc is confident its technology can meet the accuracy
requirements.

# IDC

IDC's technology is a type of in-band modem that can move location data
through networks. It is comprised of special software in the handset and
in LEC, CMRS, PSAP, and commercial call-center servers. IDC typically
works with location technology providers and provides an accessory to
GPS technology. Since September 1999, IDC has been focussing on
commercial applications for its technology, rather than 911
applications, but development has not yet progressed to the point of a
commercial order. While anecdotal demonstration data (from
demonstrations for handset manufacturers and car companies) has been
collected, IDC has no additional 911-test data available. IDC has
outstanding requests to demonstrate its technology and to perform
form-factor testing to determine if time frames can be met. IDC has also
announced commercial product tests with wireless carriers. Although IDC
has not received orders for its device, which is still under
development, it is hoping to receive commercial orders in the next
several months.

IDC's King County testing with Sirf chips demonstrated a high level of
accuracy for a handset-based solution, but there has not been any
testing beyond this. IDC's technology can work with a variety of air
interfaces and for the assisted-GPS solution, but will require
additional work and testing to improve the accuracy. IDC expects to have
a product in the market in 2001.

# TruePosition

TruePosition has developed a network-based TDOA solution for E911 ALI
and currently has a product that can handle AMPS, CDMA, TDMA air
interfaces, while GSM is in production and is expected early next year.
TruePosition's AOA product will be available for commercial deployment
by the end of 2000. TruePosition has done several live field deployments
and has met the Phase II accuracy requirements in many areas. While with
larger-scale deployments TruePosition has met the accuracy standards, it
is more difficult to meet the standards with small-scale installations
in rural areas. In some areas, like "string of pearls" rural
configurations, the required accuracy can only be met at great cost, due
to needed system additions (e.g., additional antennas and stand-alone
sites). TDOA needs at least three sites to obtain a location reading but
very often, because of multi-path and geometry constraints, four to
twelve sites are needed, depending on a particular location. Only two
sites may be needed if TDOA and AOA are used together.

TruePosition indicates that it will be expensive to achieve uniform
accuracy standards across diverse rural coverage areas. TruePosition
expects that its equipment suppliers will be able to produce 2000 signal
collection units a month to meet deployment deadlines, but recognizes
that carriers may be constrained in their ability to support deployment.
TruePosition estimates that it will take 2-4 months for deployment, with
2 months for RF planning design, and 1 month for installing equipment
and testing. Because TruePosition's TDOA system uses existing antennas,
it is less expensive than AOA, which usually requires independent
antennas with a time-consuming and expensive installation. Also, TDOA
installations do not require negotiating modifications to tower
agreements or obtaining zoning authorization. If a mobile unit
transmits, TruePosition's equipment will yield location data for that
mobile unit. Also, accuracy improves with multiple fixes. Accuracy is
degraded, however, when carriers, in optimizing their operations, employ
handset power controls in their networks, making it difficult to make
TDOA and AOA measurements.

# U.S. Wireless

U.S. Wireless' RadioCamera (location fingerprinting) technology will
work with AMPS. CDMA, and TDMA, and iDEN interfaces. Test results vary
slightly for each air interface, with CDMA being slightly better. There
will be no testing with GSM before the end of 2000. U.S. Wireless has
completed trials for all of these interfaces (Oakland, CA, DC
Metropolitan area, and Billings, MT), with the idea of gaining
experience and shaping company strategy. The RadioCamera system will be
deployed primarily as a standalone shared network location capability
system, so that it will not be dependent on, or constrained by,
carriers' sites. In this way, U.S. Wireless will have more control over
the performance of equipment -- its location, integration, and
optimization. This is U.S. Wireless' method of promoting and
facilitating the launch of the industry, especially since it is
primarily interested in the U.S. E911 market.

U.S. Wireless contends that because there are no standard procedures for
measuring location performance, the outcomes can be driven to look any
way that is desired, and this may account for the contention between
carriers and location technology vendors. Therefore, an industry
standard is needed on how to test to achieve accuracy standards. The
audit methodology developed for U.S. Wireless' Montana trial could be
helpful, especially since the trial was performed with a team of nine
companies, including a Phase I company, a LEC, a display entity, and a
wireless carrier. The weaknesses identified were with reaching the 95%
reliability level. U.S. Wireless performed audits similar to the Montana
audits of deployments in four other markets, some of which had
considerable traffic.

Availability of equipment is also a challenge, particularly for small
providers. U.S. Wireless has enlisted two large manufacturers to supply
enough equipment for a nationwide rollout. Phase I of its rollout will
involve 100 markets with 11,000 tower installations. The integration
aspects of this first rollout are especially challenging, especially
relating to tower site leasing. U.S. Wireless is partnered with American
Towers, and has negotiated a master leasing agreement. Financing is also
a concern and if the mandate were to weaken, U.S. Wireless might not be
able to obtain financing for the rollout. U.S. Wireless' plans are,
after an order is placed, to install its RadioCamera equipment and
arrange for back-haul transmissions and connections. After that, U.S.
Wireless is dependent on cooperative switch interfaces with carriers.
U.S. Wireless will perform all calibration, maintenance, mapping, etc.,
so the carrier will get location information without any other
involvement.

RadioCamera works on the voice channel. The carrier notifies U.S.
Wireless that there is a 911 call and U.S. Wireless provides the
location information through a Phase I pipeline to the PSAP. RadioCamera
is less sensitive in rural environments, and while it can provide a
location determination with one cell site, more sites give better
results. Power control that is coming because of network optimization
will affect everyone. Special attention must be paid to the CDMA
deployment footprint to achieve acceptable results. RadioCamera uses the
same hardware for all systems, but some need a few additional
components. RadioCamera is primarily a pc frame, with a few additional
plug-ins. The greatest costs are in setting up a tower and the related
integration equipment (e.g., cabling, shelter, etc.). The RadioCamera
equipment costs are relatively small in comparison.

# Question for Public Safety Representatives

What is the status of Phase II preparation for PSAPs?

# NENA

The ability for PSAPs to accept Phase II data is dependent on their
Phase I capability. Many communities have shown an increase in PSAP
requests for Phase I, especially after the Commission's action on cost
recovery. With Phase I implementation, many PSAPs can receive third
party data. Phase II, however, poses additional challenges and a need
for mapping or some other means for latitude and longitude data to be
converted into plain English so that the PSAP operator can dispatch
emergency personnel based on the data. Mapping, however, is a better
method of displaying Phase II data. Even though there was limited
interest in location technology early on, and public safety was late in
describing the problem to the FCC, wireless carriers should now realize
that 30-50% of 911 calls are from wireless callers. With 98% accuracy to
the PSAP for wireline calls, the average call length was shaved by 32
seconds.

The PSAP community has been proactive with the wireless community in
developing standards for Phase II to ensure that Phase II data will be
transferred to PSAPs in a standardized format, regardless of the
location technology used. Many carriers have been proactive and,
although data is still being collected, there recently appears to be a
66% percent increase in Phase I activity. Some states have even forced a
decision on E911 by the PSAPs in that state. A PSAP Phase II readiness
date, however is not clear yet. Phase II may be slowed by suspending the
target implementation date indefinitely. Would handset manufacturers
deliver if an order for one million units were placed? Public safety
entities are wondering whether they should commit resources without a
set implementation date. There will be many requests from PSAPs when
Phase II is available. But PSAPs are now being told with respect to
Phase I that if they are not absolutely ready to receive Phase I data,
then their request letter does not count.

NENA has heard conflicting stories about network-based solutions.
Carriers have reported some good and some dismal results. NENA believes
the dismal results came from tests in parking lot basements and elevator
shafts. NENA also believes that carriers are reluctant to trial
potential solutions and are obstructing the implementation of Phase II
E911. NENA predicts that the request process for Phase II will go faster
than Phase I, as many PSAPs think Phase II is a better answer than Phase
I. Phase II will help PSAPs by reducing the workload. Phase II is sorely
needed because wireless 911 calls are increasing and PSAP operators do
not know where the callers are located. More time to process calls is a
big concern.

# Question for Carriers and Manufacturers

How serious are you about implementing Phase II E911?

# AT&T

E911 is the most important issue on AT&T's list of regulatory mandates,
but there is a disconnect between the mandate and the state of the
technology. AT&T has been in the forefront on Phase I issues and has
devoted a lot of time towards developing standards. AT&T is concerned
about what will happen in October 2000 and October 2001.

# 

# 

# BellSouth

BellSouth takes both Phase I and Phase II very seriously and it has a
dozen people working on these issues. BellSouth is aware of the
seriousness of this issue, especially because emergency use is the
primary reason for a cell phone purchase. It is clear, however, that the
accuracy requirements cannot be met in all cases, and it will be
difficult to meet the deadlines with a network solution and almost
impossible with a handset solution. To maximize accuracy, the rules
should require that a PSAP request apply to all the carriers in an area.
An extension of time is needed because the current deadlines cannot be
met. In addition, the accuracy requirements should be relaxed or testing
that omits indoor areas should be mandated. Vendors should understand
that carriers could not order products sight-unseen and that they need
prototypes for testing. Vendors are the ones setting the schedule.

# Motorola

Even if a carrier were to give Motorola an order, with a check, for a
million handsets, Motorola would have to decline, because it does not
have the ability to deliver with assisted GPS in the allowed time frame.
Industry was discussing this 18 months ago when it was an infant
technology and although it has moved from a concept to something more
concrete, Motorola does not develop anything unless there is a market
for it. In reply to Qualcomm's representation that it is ready to ship
chipsets and its contention that resultant handsets could be produced in
six months, Motorola contends that this is only for CDMA and that
Qualcomm is making confusing representations. Qualcomm's MSM3300
baseband chip does not support 1X and does not meet all the needs of
CDMA operators and their customers (e.g., hands free dialing, etc.).
Although it does support a form of assisted-GPS, Qualcomm's GPS1 chip is
different than the technology used in the Tampa trial.

How can Qualcomm have GPS handsets manufactured within six months in
Asia?

# Nokia

Nokia expressed the view that it should not be required to use
Qualcomm's chip sets. There are alternatives available and Nokia has not
just been waiting for an order. Instead, it has been working to develop
proper technology. Pragmatically, it will take multiple steps to make
this technology a success. Integrating GPS with the cell phone is the
best option, because it will be the most efficient and least-cost
solution, and will support other desired features. But Nokia will not be
ready to deploy a solution 16-17 months from now. It is unrealistic to
think that it can.

To meet the 50% mandate, the technology will have to be installed in an
entry-level product at first, because of that product's price
constraints. Nokia does not believe that can provide a fully integrated
GPS handset within the current timeframe, and believes that leaving the
deadlines in place will amount to a mandate for sub-optimal,
less-integrated solutions. Nokia does not know if Qualcomm's chip set
will actually work because it has not yet seen it deployed. Nokia is
also concerned about who will perform the server assist portion for the
assisted-GPS solution. Realistically, October 1, 2001 is not going to
happen with handset approaches to E911. Starting today, Nokia would need
18-24 months to produce a sellable product.

# Motorola

Motorola has questioned the viability of GPS as a commercial offering.
Assisted GPS could be an investment with no payback in the 911 arena.
Several operators were not sure about handsets and have been leaning
towards a network solution. It is very possible that all of Motorola's
customers could be forced to choose a network solution. Motorola does
not want to rush to market with a solution that no one will use. Also,
which non-compliant solution does a carrier choose and Motorola support?

**NENA**

Manufacturers do not want to risk any money without an order for
handsets. The FCC's order holds the carriers responsible. In this case,
the free market is at work, if one player cannot deliver, another will.
Others will have to play catch-up. If it takes two years to deploy
handsets, we should only be six months away because the mandate was
modified 18 months ago. Internet phones were mentioned after this order
and now someone can purchase such a phone at BestBuy -- without a
mandate. So, it seems it is just dollars and business cases. In the end,
NENA does not mind what system is used and parties should provide safety
without any more excuses. Those who can deliver should survive, and
those who cannot, shouldn't survive.

NENA thinks it is unfair to be characterized as emotional zealots when
they present statistical information and attempt to be team players with
carriers. All NENA has done is point out the lack of progress. Wireless
telephones have been widely successful and NENA, while it understands
economic cases, feels that result comes with a moral obligation to help
fix this problem.

FCC

Tom Sugrue reminded participants that a year ago, it was said that
handset solutions would be a diversion because network-based solutions
were available and able to meet the accuracy requirements. Since then,
we seem to have made negative progress and carriers are saying the
network solutions will not work. What is the real story?

# Cell-Loc

Cell-Loc's solution will cost carriers nothing because Cell-Loc is
committed to delivering the location coordinates at no cost.

# BellSouth

We cannot accept the business model of putting control with a third
party because carriers have the regulatory burden.

# Nextel

Nextel is evaluating changes to the network that are needed for a
network-based solution versus those needed for a handset-based solution.
Standards for the PSAP interface are also needed and will not be
available until early next year. Nextel will not be able to deploy in
the October time frame with either a network or handset solution.

# TruePosition

TruePosition's solution was tested in field tests and it will meet the
accuracy requirements the majority of the time. Some areas, however,
will require additional antennas for TruePosition's technology to work
adequately, *i.e.*, within the FCC accuracy standards. TruePosition
usually uses the cellular network antennas, but can do stand alone
installations. TruePosition's equipment is easy to install; the
constraints are carrier resources and the DS-0 back-haul links.

# Cell-Loc

Cell-Loc is not dependent on antennas at existing cell sites. Cell-Loc's
separate network with "super sites" (as in Calgary) can actually reduce
the number of towers needed. As far as 50% coverage, Cell-Loc plans to
double the number of cities every quarter and will have 45 cities at 50%
coverage by 10/1/2001, which is the best they can do.

# Concluding Statements

**U.S. Wireless**

None of the network vendors have waited for an order and instead started
developing technology. But these vendors will not be able to sustain
this activity single-handedly for long, and will be looking for orders
soon. This is like the meeting of two cultures -- mature, powerful
service providers, who are working hard to improve the quality of
service, and a new, emerging industry. Measuring performance is
difficult because location technology today is like cellular service in
the 1960s. U.S. Wireless has an elegant solution that has some holes it
is working to eliminate. How will accuracy be measured in sparse
coverage areas? Do PSAPs need the mandated accuracy in these areas or is
a possible answer to relax the accuracy standards in rural areas?

# U.S. Cellular

U.S. Cellular filed a request for a six-month extension for rural
carriers facing deadlines. A network-based solution does not work in
rural areas. The mandate is clear but rural carriers do not have the
resources to participate in the standard setting process to the extent
that non-rural carriers can. The fact that U.S. Cellular does not have
the pull with manufacturers, which large carriers have, needs to be
addressed.

# TruePosition

TruePosition's system works and TDOA can locate wireless callers, but it
is still a question of range, which is a function of cost versus
performance. We really need to look at the distribution of the location
of 911 calls.

# SBC Wireless

It is clearly in the public's interest to move forward. The Commission
should carefully review the carriers' responses in October 2000, and
possibly consider extending the deployment dates and whether the
accuracy requirements are realistic.

# Nokia

Nokia provided an accurate set of statistics that show there are a
growing number of wireless 911 calls. GPS has been headed for commercial
development, even though the accuracy and timing of that deployment were
not entirely clear. Nokia believes the mandate is very clear and began
working on a handset in September 1999. The FCC needs to clarify the
implementation because Nokia cannot meet the timing or accuracy. Nokia
does not believe Qualcomm's claims that its chipsets can be turned into
handsets within 6 months of commercial availability. Nokia is not
waiting and doing nothing, but to integrate GPS into a handset, Nokia
needs product specifications from customers.

# Nextel

Nextel is taking this obligation seriously and has already spent more
than \$250,000 on Phase II. Phase II, and other wireless mandates
(CALEA, LNP, and TTY) will affect carriers' operations. Also, hands-free
dialing, voice recognition, and other safety features create memory and
power concerns. Today, there is no prototype iDEN handset incorporating
GPS that can be used to test the effect on the rest of the network.
Without good information, Nextel cannot act responsibly for its
shareholders. The situation today is making it difficult to make a
rational decision. Nextel needs changes in the deadline and possibly the
accuracy as well.

# NENA

The FCC should stick to its order and let the marketplace weed out those
who cannot produce in time. The waiver process exists for those
technologies that cannot meet the deadlines so the FCC should entertain
exceptions to its requirements on a case-by-case basis. Carriers should
not lose sight of public safety, and the process should move forward so
the public can be protected. Systems have been built that can locate.
Now data is needed to determine if the accuracy requirements are
appropriate. The network-based solution appears to work, so do not let
perfection be the enemy of the good.

# Motorola

Motorola is committed to supporting the interests of public safety and
has actively participated in standard setting. Motorola has come to the
hard conclusion that the current requirements for handsets cannot be
met. Motorola has not been silent its views---it came to the FCC prior
to the Third Report and Order and indicated that the handset
requirements would not be achievable. Motorola has concluded that
assisted GPS stands a reasonable chance of meeting the requirements,
depending on the tests. If we look at the pattern of where most 911
calls are made and design a reasonable test, then assisted GPS stands a
reasonable chance of meeting the accuracy requirements. There are
problems with in-building coverage for assisted GPS. We cannot ignore
the time that it takes to integrate complicated systems into today's
networks. A network is not just a box with an antenna. We have to be
careful with how we introduce this technology and don't cause problems.
Each network is unique.

# Cell-Loc

Cell-Loc started developed a system 11 years ago, long before the FCC's
E911 ALI order. Cell-Loc's system meets the mandate and will be
demonstrated in Calgary over the next several weeks. An Austin rollout
will follow shortly, with Dallas rolled out in September. Cell-Loc would
be happy to talk with carriers.

# BellSouth

E911 is at the top of BellSouth's priorities. BellSouth has looked at
every potential solution, but does not believe that the October 2001
timeframe can be met by either network or handset technologies.
BellSouth is concerned that no technology can meet the required accuracy
levels. BellSouth cannot report in October 2000 because it does not have
a plan or solution.

# AT&T

This Phase II E911 is the single most important regulatory mandate we
face. Right now, AT&T does not see a way that it can meet the FCC's
requirements. If AT&T cannot make it, it will do the best it can and
seek a waiver.

**FCC E911 Multi-Party Meeting**

**July 6, 2000**

**Name:** **Company/Organization:**

## Doug Brandon AT&T Wireless

Lori M. Buerger AT&T Wireless

Ben Almond Bell South

Andrew W. Clegg Bell South

Linda Lancaster Bell South

Michel Fattouche CELL-LOC

John Jimison CELL-LOC

Sean Krakiwsky CELL-LOC

Bob Eckert FCC-OET

Dale Hatfield FCC-OET

Alexander Dobrev FCC-WTB

Patrick Forster FCC-WTB

Dan Grosh FCC-WTB

Gil Hopenstand FCC-WTB

Jennifer Kolen FCC-WTB

Bill Lane FCC-WTB

Marty Liebman FCC-WTB

Ron Netro FCC-WTB

Kelly Quinn FCC-WTB

Jim Schlichting FCC-WTB

Blaise Scinto FCC-WTB

Tom Sugrue FCC-WTB

Andy Rimkus IDC

Mary Brooner Motorola

Paul De Clerck Motorola

Audrey Longhurst Motorola

Duane Rabe Motorola

Sharon Counterman NENA

Norman H. Forshee NENA

Jim Hobson NENA

John R. Melcher NENA

Bob Ewald NEXTEL

Larry Krevor NEXTEL

**FCC E911 Multi-Party Meeting**

**July 6, 2000**

**Name:** **Company/Organization:**

Leo Fitzsimon Nokia

Adam Gould Nokia

Larry Paulson Nokia

Russ Jackson SBC Wireless

Bob Tyler SBC Wireless

Michael Amarosa True Position

Joe Sheehan True Position

Phil Verveer Willkie Farr & Gallagher for True Position

James Quinlan U.S. Cellular

Tom Van Wazer U.S. Cellular

Eliot Greenwald Swidler Berlin for U.S. Wireless

Oliver Hilsenrath U.S. Wireless

Tom Dombrowsky Wiley, Rein & Fielding