The National Emergency Number Association sent key House and Senate appropriators a letter Friday asking them to consider, in economic stimulus legislation, investment in technology supporting 911 and emergency communications. “There can be no more critical infrastructure than the 911 systems relied on by the public and the emergency communications systems used by those responding to emergencies,” NENA CEO Brian Fontes wrote. “Similarly, while promotion of broadband access for the general public is an important investment, it is even more important for the future of 911 and emergency communications, which will increasingly depend on high bandwidth networks to effectively prepare for, and respond to, emergencies.” Public safety’s needs include “the establishment of IP backbone networks and the application-layer software infrastructure needed to interconnect the multitude of emergency response organizations,” the letter said.

Adoption of numbers-based system as part of Universal Service Fund reform would have a negative effect on “important emergency communications services” if the fee is imposed on vehicle telematics services, such as OnStar or ATX, APCO and the National Emergency Number Association warned the FCC. Telematics companies were also at the FCC for recent meetings to ask the FCC not to impose the fee on their lines, a step proposed in all three rulemakings on USF reform now before commissioners.

The FCC should create an E-911 Technology Advisory Group, but doesn’t need to wait to complete E-911 location accuracy rules, APCO and the National Emergency Number Association said in reply comments filed at the agency. Meanwhile, T-Mobile and the Rural Cellular Association reiterated concerns that the two main proposals for E-911 location accuracy rules, worked out between AT&T and Verizon Wireless and the two public safety groups, aren’t workable for all carriers. Motorola said the objections they raise are “valid and reasonable.”

The FCC Office of Engineering and Technology at our deadline released a report on AWS-3 interference tests conducted at the Boeing Lab in Seattle, witnessed in part by OET engineers. Industry officials said the release of the report likely means FCC Chairman Kevin Martin plans to ask commissioners to vote on AWS-3 rules as early as the Nov. 4 meeting. Industry officials were still evaluating the conclusions drawn. OET said in two key conclusions that for a desired signal level of -95 dBm or greater, an AWS-3 UMTS handset, under static conditions, “can safely operate with maximum [equivalent isotropic radiated power] of about 23 dBm/MHz without causing disruption of service to nearby AWS-1 handsets.” A WiMAX AWS-3 handset “can safely operate with an EIRP of about 33 dBm/MHz without causing disruption.” But OET noted that test conditions were not ideal since no AWS-3 handsets are yet available. Still, OET noted, interference generators of the type used in tests generally result in higher out-of-band energy levels “than would typically be produced using an actual handset.” In a Friday letter to the FCC, the National Emergency Number Association voiced public safety concerns over the risk of interference to AWS-1 incumbents posed by a free broadband service in the AWS-3 band. The letter was sent before release of OET test results. T-Mobile and others predict that AWS-3 operations will cause significant interference to AWS-1 handsets, NENA noted. “If these claims are accurate, this interference could prevent some 911 calls from being set up and delivered, as well as increasing the incidence of dropped and degraded calls,” NENA CEO Brian Fontes said. “Wireless consumers cannot be in a position in which the most important calls they make, 9-1-1 calls, are disrupted or blocked. Therefore, we encourage the Commission to take into consideration the potential impact on 911 service for consumers and public safety operations as you consider your technical rules in the AWS-3 proceeding.” “We will read the report in detail to determine if they have correctly evaluated the extensive record from multiple parties that have expressed concern about interference,” T-Mobile said in a statement. “Given the importance and complexity of these technical issues, the FCC needs to provide for sufficient time for comment on their report before any FCC action on these rules.”

The New York Police Department urged the FCC to reject E-911 location accuracy plans from AT&T and Verizon Wireless and keep rules the FCC approved in September 2007, triggering a court challenge by wireless carriers. “The accuracy of location information is critical to emergency response,” the NYPD said. “Absent a compelling reason to change the existing standards, they should be maintained.” The Court of Appeals for the District of Columbia Circuit issued a stay of the original rules in March, and in August the FCC told the court it would propose revised standards.

The nation’s major wireless carriers told the FCC that siting cell towers and other wireless facilities can take years. They filed in support of a CTIA petition asking the commission to clarify federal authority over cell towers and wireless facility siting. The petition also asks the agency to set deadlines for local governments to make decisions in siting cases. FCC officials said Tuesday action on the petition appears unlikely during the remainder of Kevin Martin’s term as chairman.

T-Mobile asked the FCC not to adopt new requirements for dual-mode CMRS-VoIP phones as the commission revises rules for VoIP E-911. The dual-mode phone issue loomed large last month as commissioners debated a rulemaking required by the NET 911 Improvement Act. Other commenters said the dual-mode issue appears unique to T-Mobile and asked the FCC to table the issue to focus on the Act’s main thrust: Ensuring that interconnected VoIP providers have access to E911 services.

The National Emergency Number Association, APCO and AT&T together proposed revised E-911 location rules. In a Monday letter to FCC Chairman Kevin Martin, the parties said they “worked together to develop technologically feasible compliance measurements that improve the ability of providers to locate customers making calls to 9-1-1 from wireless phones.” The proposal doesn’t compete with a similar one (CD Aug 22 p2) made last week by Verizon Wireless, NENA and APCO, but covers different technologies. AT&T’s proposal relates to tracking via cellphone tower triangulation, whereas Verizon’s involves GPS tracking. The AT&T plan would measure wireless 911 location accuracy at the county level, said AT&T, NENA and APCO. However, “it is not technically feasible for carriers to meet the current accuracy standard in all counties using location accuracy technology currently available,” they said. “Any location accuracy rules that the Commission adopts for carriers that employ network-based solutions must be limited” to metrics and schedules in the group’s proposal, they said. AT&T and other carriers using network-based location solutions “may be expected to deploy handset-based solutions as an overlay to existing network-based solutions in order to meet the more stringent county-level requirements,” the group said. Their proposal would allow network-based carriers to “elect to use a system of blended reporting for their accuracy measurements,” or to report “based solely on the handset-based accuracy standards,” the group said.

The National Emergency Number Association, APCO and Verizon Wireless together proposed revised E-911 location rules with new targets and a new timetable. The rules would apply the same standard to GSM and CDMA networks and allow an exception for heavily forested counties where systems wouldn’t work as well as elsewhere. Industry sources said the plan emerged in talks between public safety groups and the two largest carriers - AT&T and Verizon Wireless -- held at the urging of FCC Chairman Kevin Martin. AT&T didn’t sign on to a letter that Verizon Wireless and the associations filed at the FCC. AT&T is expected to submit a separate letter on the proposal.

Deaf interest groups, telecom relay providers and others argued details on an FCC plan to give 10-digit phone numbers to deaf people using Internet-based TRS services. They filed comments Friday on a rulemaking (CD June 26 p2) on the 10-digit numbering plan. The FCC sought comment on 911 and other issues, as well as how it might apply customer proprietary network information (CPNI), slamming and other customer privacy rules to relay providers. Relay providers have until Dec. 31 to implement a 10-digit plan.