APCO, NENA Say FCC Has What It Needs to Act on E-911 Accuracy

The FCC sought comments on the E-911 location accuracy agreements. AT&T’s proposal was for GSM carriers, which use a network-based E-911 solution. Verizon Wireless’ is a plan for carriers using CDMA technology and a handset-based solution. Replies were due this week.

APCO and NENA said they would offer “detailed suggestions on the structure, goals and activities” of the proposed advisory group at the appropriate time. But they said the FCC should approve final rules without waiting for the group to start work. Some smaller carriers say the broad-based committee will be critical to writing new rules.

“The Commission should issue rules based on the proposals and comments received establishing accuracy requirements and benchmarks measured at the county level,” APCO and NENA said. “The ETAG should be established to address additional issues beyond the scope of this notice.”

T-Mobile, a GSM carrier, asked why the FCC is hastening to complete the proceeding, allowing only a 20-day comment cycle. “The Commission should… reconsider its rush to judgment here,” the carrier said. “Both affected parties and the Commission particularly need time for detailed analysis.” The record is clear that rules that might work for one carrier are not necessarily suitable for all, T-Mobile said. “Almost every commenter makes the point that, although the Verizon Wireless and AT&T proposals may be suitable for those companies, they are not technically and economically feasible for other carriers.”

T-Mobile described AT&T as being in a position different from many of its smaller competitors and not equipped to speak for all GSM carriers. “AT&T is more than two years ahead of all other GSM carriers in rolling out a 3G network - - which means that AT&T has been able to start selling A-GPS handsets earlier than other carriers -- and now has a near nationwide deployment of 3G services that makes it much easier for AT&T to sell A-GPS capable 3G handsets to its customers,” T-Mobile said.

RCA responded mainly to Verizon’s plan. “As currently proposed, the location accuracy standards provided by Verizon Wireless and public safety groups are not technically and economically feasible for the Tier II and Tier III carriers that RCA represents,” the group said. “If the Commission ultimately adopts new testing and reporting requirements, it must ensure that any new requirements are reasonable for small and regional carriers which inherently have less administrative and economic resources at their disposal.”

Motorola said the concerns raised by RCA and T-Mobile are “valid and reasonable considering past E911 experiences.” Motorola said the GSM market is going through record low growth and churn. As a result, carriers will have a tough time getting handsets capable of meeting new guidelines into customers’ hands. “Handset turnover is lower (and deployment therefore more difficult) than when CDMA and iDEN carriers were deploying A-GPS handsets,” Motorola said. “The Commission should take into account the unique circumstances described by RCA and T-Mobile in developing their E911 benchmarks for such carriers.”

Nokia and Nokia Siemens Networks also said the FCC should heed T-Mobile’s and the RCA’s concerns. The AT&T proposal, Nokia said, is “a potentially workable framework for achieving county-level accuracy.” But like other commenters, “the proposed requirements may not be feasible for all carriers at this time,” Nokia said. It added, “As AT&T states, the proposed benchmarks are ‘aggressive’ and ’they cannot be met solely in reliance on technology that is available today.'”