DA 01-1857

Released: August 2, 2001

WTB Seeks Comment on E911 phase II waiver request

filed by Sprint Spectrum L.P.

(CC DOCKET 94-102)

# Comments Due: August 22, 2001

**Reply Comments Due: September 1, 2001**

The Federal Communications Commission\'s (Commission\'s) rules require
wireless carriers to begin deploying a 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 30, 2001, Sprint Spectrum L.P. d/b/a Sprint PCS (Sprint)
provided additional information on its efforts to meet Phase II rules
and requested a waiver of those rules to permit it to deploy an assisted
Global Positioning Satellite (GPS) solution for its CDMA network.[^3]
Sprint states that by October 1, 2001, it will have taken a number of
concrete actions to implement Phase II services, but it will not be able
to comply fully with Phase II rules or complete a simultaneous, national
roll out of E911 location systems by October 1, 2001.

Sprint requests a waiver of the Phase II requirement that carriers'
network infrastructure must be capable of supporting Phase II service as
early as October 1, 2001.[^4] It currently operates Lucent, Nortel and
Motorola switches, and Nortel switches are currently replacing Motorola
switches. Sprint indicates that at least one Lucent market should be
Phase II compliant by October 1, 2001, and it plans to begin deploying
additional Lucent markets on or shortly after the October 1 deadline.
However, Sprint estimates that it will need four-to-five months to
complete the Phase II conversion of Lucent MSC switching software. This
period covers conversion only and not the full deployment of Phase II
services.[^5] In addition, Sprint states that Nortel has been unable to
make available the necessary Phase II modifications for commercial
deployment by the October 1, 2001 deadline. Sprint plans to begin to
test Nortel switch software modifications later this year so that the
Nortel switches can begin to be converted to Phase II by the end of
First Quarter 2002. Sprint states that given the number of markets
involved in its national network, Sprint will also need a period of at
least four-to-five months to phase in Nortel's switching software.
Sprint indicates that once the software is available and testing has
begun it will provide the Commission with a more detailed launch
schedule for Nortel markets.

With respect to Phase II handset activation requirements, Sprint states
that it expects to begin selling location-capable handsets by the
Commission's October 1, 2001 deadline, with 100% of all new handsets
sold being GPS compatible by December 31, 2002. However, Sprint
indicates that it is unlikely that it will meet the interim activation
levels specified in Phase II rules (25% of all new handsets by December
31, 2001 and 50% of all new handsets by June 30, 2002) due to the
conversion of the Sprint network to 3G technology. Accordingly, Sprint
seeks a waiver of Commission Rule 20.18 (g)(1).

Sprint states that the volume of PSAP requests that must be processed
and the custom network designs that must be installed, make it unlikely
that Sprint can engage in a simultaneous rollout of Phase II services
based on PSAP requests received to date. Sprint seeks a temporary waiver
that permits Sprint to prioritize Phase II implementation. Sprint claims
that it is difficult at present to estimate when it will be in full
compliance with Phase II rules, and that a firm schedule cannot be
determined until it has an opportunity to test Nortel's Phase II
software and the status of ALI database upgrades is known. Sprint
recommends that beginning on November 1, 2001, and continuing until it
is in full compliance, Sprint submit quarterly reports to the Commission
describing the status of its Phase II implementation.

The Wireless Telecommunications Bureau seeks comment on this waiver
request. Parties interested in filing comments may submit their comments
on or before **August 22, 2001** and reply comments on or before
**September 1, 2001**.

This is a \"permit but disclose\" proceeding pursuant to § 1.1206 of the
Commission\'s Rules.[^6] 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>. 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 Steve
Rangel, 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]: *See* Sprint PCS Supplemental Phase II Implementation Report and
    Request for Temporary and Limited Waiver, CC Docket No. 94-102
    (filed July 30, 2001) (*Sprint Request*).

[^4]: *See* 47 C.F.R. §20.18 (g)(2); Sprint Request at 4.

[^5]: *See* Sprint Request, Appendix A (providing a tentative launch
    schedule for its Lucent markets and proposing implementation start
    dates for different markets/PSAP requests that span from October 1,
    2001 through October 15, 2002).

[^6]: 47 C.F.R. § 1.1206.