> DA 03-2113
>
> Released: June 30, 2003

**WIRELESS TELECOMMUNICATIONS BUREAU PROVIDES FURTHER GUIDANCE ON
INTERIM REPORT FILINGS BY SMALL SIZED CARRIERS**

# CC Docket No. 94-102

In this Public Notice, the Wireless Telecommunications Bureau (Bureau)
provides further guidance to small sized carriers (Tier III carriers)
regarding the reporting of wireless Enhanced 911 (E911) deployment and
implementation status.

On July 26, 2002, the Commission adopted an Order staying certain E911
Phase II deployment deadlines for Tier II and Tier III carriers, with
conditions.[^1] In the *Non*- *Nationwide Carrier Order,* Tier II
carriers were defined as non-nationwide carriers that had over 500,000
subscribers as of year-end 2001, and Tier III carriers were defined as
all other non-nationwide carriers.[^2] The Commission extended the E911
Phase II interim handset and network upgrade compliance deadlines by 13
months from the date of the *Non*-*Nationwide Carrier Order* for Tier
III carriers.[^3] To assist in monitoring Tier III carriers' E911
deployment progress, the Commission required Tier III carriers to file
an Interim Report on **August 1, 2003**.[^4]

This Public Notice provides specific details regarding how to file the
Interim Report and what should be contained in the Report. The Interim
Report is intended to provide specific, verifiable information to the
Commission to assist in the monitoring of Tier III carriers' progress
and the determination of whether Tier III carriers are on track for
compliance with each of the benchmarks established in the
*Non-Nationwide Carrier Order* and with other applicable provisions of
the E911 rules.[^5]

The Interim Reports should be in a narrative format and should include
detailed statements regarding the reporting requirements outlined below.
The Reports should serve as the principal vehicle for providing the
Commission with information regarding E911 Phase I and Phase II
deployment, implementation status, and notice of any problems
encountered affecting a carrier's ability to comply with the
Commission's benchmarks. Each Tier III carrier must support each Interim
Report with an affidavit, from an officer or director of the carrier,
attesting to the truth and accuracy of the report.[^6]

> The *Non-nationwide Carrier Order* set forth categories of information
> that Tier III carriers must include in the Interim Reports:[^7] For
> Tier III Carriers' convenience, these categories are restated in
> boldface type below. In addition, the Commission encourages carriers
> to add any information that they consider pertinent to the
> Commission's understanding of issues affecting small carrier
> deployment and implementation in answering these questions. In this
> regard, the Bureau provides additional guidance in each category
> regarding specific information that the Bureau believes could be
> useful for the carriers to include if it affects their E911
> deployment.

-   **The number of Phase I and Phase II requests from PSAPs (including
    those the carrier may consider invalid)**;

    -   The Bureau encourages you to describe the specific sources of
        any problems that you have encountered in meeting any valid PSAP
        request. Please feel free to describe any trunking problems,
        other LEC issues, problems in coordination with your state or
        locality, specific PSAP issues, location technology issues,
        other vendor or equipment issues, data-base problems, funding
        limitations, or any other problem you have encountered.

    -   If you have determined that the PSAP request is not valid, what
        steps have you or the PSAP taken to resolve outstanding issues?
        What has been the outcome?

    -   Do you have any valid PSAP requests that have been or that you
        anticipate will be outstanding longer than six months? If so,
        what are the problems that you have encountered that have caused
        or contributed to the delay?

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-   **The carrier's specific technology choice (*i.e.,* network-based or
    handset-based solution, as well as the type of technology used)**;

    -   If you have begun implementation, have you experienced any
        problems, and if so, what are the major sources of the
        difficulties, and what would resolve them?

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-   **Status on ordering and/or installing necessary network
    equipment**;

    -   Have you begun to order equipment?

    -   If so, what problems, if any, have you encountered?

    -   If you have begun installing necessary equipment, what problems,
        if any, have you encountered?

    -   What problems do you anticipate encountering in ordering and
        installing necessary equipment?

> \`

-   **If the carrier is pursuing a handset-based solution, the Report
    must also include information on whether ALI-capable handsets are
    now available, and whether the carrier has obtained ALI-capable
    handsets or has agreements in place to obtain these handsets**;

    -   If you have been unable to obtain ALI-capable handsets, what has
        been the major source of the problem? What have you done to
        resolve it?

    -   Have you encountered any problems in negotiating agreements to
        obtain these handsets?

    -   Do you anticipate any problems in marketing ALI-capable handsets
        to your customers?

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-   **The estimated date on which Phase II service will first be
    available in the carrier's network**;

    -   What problems are you encountering or do you anticipate
        encountering in making Phase II service available in your
        service area or in any part of your service area?

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-   **Information on whether the carrier is on schedule to meet the
    ultimate implementation date of December 31, 2005**.

    -   If so, what factors are contributing to your anticipated
        problems?

The requirement to adhere to the above outlined reporting requirements
will not impose significant new burdens on Tier III carriers. In
November 2002, the reporting requirements were approved as a revision to
OMB Control No. 3060-1004. We further note that the Tier III carriers'
requirement to submit the Interim Reports was also included in a revised
Notice of Information Collection, pursuant to the Paperwork Reduction
Act, regarding the establishment of the format of an Excel spreadsheet
for Tier I and Tier II Carriers. OMB Control No. \[68 FR 34606, June 10,
2003\]. The Excel Spreadsheet format does not apply to Tier III
Carriers.

Interim reports are required to be submitted electronically at
<E911compliancereports@fcc.gov>. Only one copy of an electronic
submission must be filed. In completing the transmittal screen, filers
should include their full name, postal service mailing address, and the
applicable docket number, CC Docket No. 94-102. Carriers must also file
Interim Reports with the Wireless Telecommunications Bureau and the
Enforcement Bureau.

Interim Reports must also be filed electronically with the Electronic
Filing System (ECFS)[^8] or by paper with the Office of the Secretary.
Parties who choose to file by paper must file an original and four
copies of each filing. All filings must be sent to the Commission\'s
Secretary, Marlene Dortch, Office of the Secretary, Federal
Communications Commission, 445 12th Street, S.W., Washington, D.C.
20554. Quarterly Reports are available for public inspection during
regular business hours in the FCC Public Reference Room, Room CY-A257,
445 12^th^ Street, S.W., Washington, D.C. 20554.

For further information concerning the FCC's E911 reporting
requirements, contact Andra Cunningham, Policy Division, Wireless
Telecommunications Bureau at (202) 418-1310; TTY 1-888-835-5322.

**- FCC -**

[^1]: *See Revision of the Commission's Rules to Ensure Compatibility
    with Enhanced 911 Emergency Calling Systems*, CC Docket No. 94-102,
    Order to Stay (rel. July 26, 2002) (*Non-Nationwide Carrier Order*).

[^2]: *See Non-Nationwide Carrier E911 Order* at paras. 22-24.

[^3]: *See Non-Nationwide Carrier E911 Order* at para. 1.

[^4]: *Id*. at paras. 34-35.

[^5]: For specific details regarding Tier III Carrier benchmarks *see
    id.* at paras. 32-33.

[^6]: To the extent any Tier III carrier believes any of the required
    information is proprietary, it may file a request for confidential
    treatment pursuant to 47 C.F.R. § 0.459.

[^7]: *See Non-Nationwide Carrier Order* at para. 35.

[^8]: *See* *In re* *Electronic Filing of Documents in Rulemaking
    Proceedings*, 13 FCC Rcd. 11322 (1998) (amending Parts 0 and 1 of
    the Commission's rules to allow electronic filing of comments and
    other pleadings).