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`Federal Communications Commission
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`FCC 96-264
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`Before the
`FEDERAL COMMUNICATIONS COMMISSION
`Washington, D.C.
`
`))
`
`In the Matter of
`
`)
`Revision of the Commission's Rules
`)
`To Ensure Compatibility with
`Enhanced 911 Emergency Calling Systems )
`
`CC Docket No. 94-102
`RM-8143
`
`REPORT AND ORDER
`AND
`FURTHER NOTICE OF PROPOSED RULEMAKING
`
`Adopted: June 12, 1996
`
`Released: July 26, 1996
`
`Comment Date: August 26, 1996
`
`Reply Date: September 10, 1996
`
`By the Commission: Commissioner Chong is issuing a statement
`
`TABLE OF CONTENTS
`
`I.
`
`INTRODUCTION
`
`..............................................
`
`II. OVERVIEW
`
`.................................................
`
`A. Value of 911 Services
`........................................
`....................................
`1. Overall Growth in Usage
`........................
`2. Reliance on 911 by Wireless Service Users
`..............
`3. Current Service Limitations; Commission Responsibilities
`........................
`B. Executive Summary of Commission Actions
`....................
`...................
`1. Report and Order
`.
`2. Further Notice of Proposed Rulemaking
`.........................
`
`III. BACKGROUND OF PROCEEDING
`
`.................................
`
`A. Jint Paper, JEM Report
`......................................
`B. Wireless E911 Notice of Proposed Rulemaking
`
`......................
`
`Paragraph
`I
`
`3
`
`3
`3
`6
`8
`10
`10
`13
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`15
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`15
`17
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`21
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`24
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`24
`24
`47
`54
`54
`77
`85
`91
`102
`106
`113
`113
`120
`126
`
`133
`
`133
`136
`136
`144
`154
`155
`156
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`157
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`159
`
`160
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`C. Consensus Agreement
`
`.......................................
`
`IV . DISCU SSION
`
`................................................
`
`A. General 911 Service Requirements and Provisions
`....................
`1. 911 Availability Without Customer Validation
`.....................
`2. 911 Access to Text Telephone Devices
`.........................
`B. Enhanced 911 Service Requirements and Provisions
`...................
`1. E911 Deployment Schedule ..................................
`2. Carriers and Services Required To Offer E911
`....................
`3. Cost Recovery
`..........................................
`.................................
`4. Liability and Privacy Issues
`5. Preem ption
`............................................
`6. Equipment Manufacture, Importation, and Labelling
`................
`C. Specific E911 Technical and Other Issues
`.........................
`1. Call Priority
`...........................................
`2. Grade of Service
`........................................
`3. Common Channel Signalling
`................................
`
`V.
`
`FURTHER NOTICE OF PROPOSED RULEMAKING
`
`...................
`
`.............................................
`A. Background
`.............................................
`B. Discussion
`1. Location Information Technology
`............................
`2. Access to 911 Service via Multiple Mobile Systems
`................
`Initial Paperwork Reduction Act of 1995 Analysis
`C.
`..................
`................................................
`D . Ex Parte
`E. Comment Period
`.........................................
`
`VI. CONCLUSION
`
`.............................................
`
`VII. ADMINISTRATIVE PROVISION
`
`.................................
`
`VIII. ORDERING CLAUSES
`
`........................................
`
`APPENDICES
`
`APPENDIX A.
`APPENDIX B. I.
`II.
`APPENDIX C.
`
`List of Commenters and Abbreviations
`Final Regulatory Flexibility Analysis
`Initial Regulatory Flexibility Analysis
`Final Rules
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`APPENDIX D.
`
`Tables
`
`I. INTRODUCTION
`
`1. By our action today we are taking several important steps to foster major
`improvements in the quality and reliability of 911 services available to the customers of
`wireless telecommunications service providers. Our decisions in this Repurt and Order reflect
`our longstanding and continuing commitment to manage use of the electromagnetic spectrum
`in a manner that promotes the safety and welfare of all Americans. In addition, our Further
`Notice of Proposed Rulemaking represents our desire to ensure continuity of our dedication to
`new and innovative 911 services by seeking comment on further refinements of our wireless
`911 rules.
`
`2. The principal issue in this phase of the Docket 94-102 rulemaking proceeding'
`involves the steps the Commission should take to optimize the delivery and processing of 911
`calls and to prompt the accelerated delivery of enhanced wireless 911 features and functions
`to administrators of Public Safety Answering Points (PSAPs), to assist them in responding to
`emergency calls for assistance. We believe that it is critically important that rigorous
`enhancement criteria be established, that firm target dates for implementation be set, and that
`reasonable cost recovery mechanisms be encouraged as a means of ensuring that
`implementation goals can be achieved. The actions we take in this Report and Order are
`designed to accomplish these objectives -- we believe that we are taking reasonable and
`effective steps to promote cooperative efforts by state and local governments, PSAP
`administrators, wireless carriers, and equipment manufacturers that will lead to improved
`wireless 911 services.
`
`1. OVERVIEW
`
`A. Value of 911 Services
`
`1. Overall Growth in Usage
`
`3. Dialing 911 is the most effective and familiar way the American public has of
`finding help in an emergency. Since it was first introduced in 1968, 911 service has spread
`
`I We began this rulemaking with the issuance of a Notice of Proposed Rulemaking on October
`19, 1994. Revision of the Commission's Rules To Ensure Compatibility with Enhanced 911
`Emergency Calling Systems, CC Docket 94-102, RM-8143, Notice of Proposed Rulemaking, 9 FCC
`Red 6170 (1994) (Notice). The Notice also sought comment regarding the compatibility of private
`branch exchanges (PBXs) with E911 emergency calling systems. We will address these issues in a
`separate proceeding.
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`across the Nation and become synonymous with emergency assistance. Nationwide, 95
`million 911 calls are made each year, or 260,000 every day.2 These calls are typically routed
`by local exchange carriers (LECs) to PSAPs staffed by professionals trained to assist callers in
`need of emergency assistance and to direct calls to police, fire, and health emergency response
`providers. The 911 systems in place today encourage those providing communications
`services and those providing emergency assistance to coordinate their efforts and facilities and
`work together, resulting in the saving of lives and property
`
`4. In the basic form of 911, the attendant who receives the 911 call at the PSAP
`gathers all the necessary information about the nature and location of the emergency by
`questioning the caller. Over the last decade, most 911 systems and PSAPs have been
`upgraded to enhanced 911 (E91 1), which adds features that permit more efficient and speedy
`response by emergency service personnel. When a wireline 911 call is placed in a region
`with E911 capability, the telephone number of the phone used for the call is typically passed
`to the LEC central office. A database, usually maintained by the LEC, is then used to
`selectively route the call to the most appropriate PSAP. In addition, the caller's telephone
`number and other useful information are transmitted to the PSAP along with the location of
`the telephone, based on LEC records.4
`
`5. E911 saves lives and property by helping emergency services personnel do their
`jobs more quickly and efficiently. Automatic Location Identification (ALl) capability permits
`rapid response in situations where callers are disoriented, disabled, unable to speak, or do not
`know their location. In these situations, ALl permits the immediate dispatch of emergency
`assistance to the address of the wireline phone. ALl also reduces errors in reporting the
`location of the emergency and in forwarding accurate information to emergency personnel.
`Where telephone exchange boundaries extend into two or more PSAP jurisdictions, the ALl
`feature permits selective routing (SR) of calls to the appropriate PSAP for the identified
`location. A dispatcher at a PSAP with E911 capability can also call back in the event the call
`is disconnected. Currently, 89 percent of wireline phones in the United States are served by
`911, and about 85 percent of 911 services include some form of E91 .
`
`2 Notice, 9 FCC Red at 6171 (para. 3).
`
`See "The National Policy for Emergency Telephone Number '911'," prepared by Executive
`3
`Office of the President, Office of Telecommunications Policy, Mar. 21, 1973, attached in Oregon
`Comments at Exhibit B.
`4 Joint Comments of APCO, NENA, and NASNA (APCO Comments) at 9-11, 27; Notice, 9
`
`FCC Rcd at 6171 (paras. 4-6).
`
`See Notice, 9 FCC Rcd at 6171 (paras. 3, 6).
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`2. Reliance on 911 by Wireless Service Users
`
`6. Although 911 was originally developed for wireline telephones, wireless customers
`place a large and increasing portion of 911 calls. According to the Cellular
`Telecommunications Industry Association (CTIA), virtually all cellular carriers today provide
`basic 911 service or some close alternative. In 1994, almost 18 million wireless calls were
`made to 911 and other public service numbers. The number of such calls is growing rapidly,
`spurred by the rapid growth in cellular subscribers. The total number of cellular subscribers
`in the United States currently exceeds 33 million, and 9.6 million new subscribers were added
`in 1995 alone. 6 The roll-out of broadband Personal Communications Service (PCS), now
`underway, will increase the number of mobile phones and wireless 911 calls.! With this
`growing popularity of mobile communications has come a recognition on the part of wireless
`customers that their phone provides them with a valuable communications link in
`emergencies. According to a recent survey, for example, 62 percent of cellular users cited
`safety and security as their main reason for purchasing a mobile phone.'
`
`7. Wireless carriers currently provide access only to basic 911 service, not to the
`advanced features of E9 11. The mobile nature of wireless technology creates complexities for
`providing even basic 911 service. For example, a wireless 911 caller may not be a subscriber
`of the wireless provider with coverage in the area and therefore 911 calls may be blocked.
`Also, there may be technical reasons such as the use of different protocols that may lead to
`blocked 911 calls. Moreover, the nature of wireless technology and service presents
`significant obstacles to making E911 effective for wireless calls. For example, selective
`routing of calls to the appropriate PSAP is complicated by the fact that a cellular caller is
`often moving and the transmission may be received at more than one cell site. Automatically
`identifying the location of a wireless caller also presents new technological and policy issues.
`
`3. Current Service Limitations; Commission Responsibilities
`
`6 According to the latest semi-annual report prepared by CTIA, a total of 33.8 million people
`were cellular customirs in the United States at the end of 1995, a 140 percent rise compared with the
`24 million customers reported in 1994. CTIA gathered data on current cellular systems, but did not
`include PCS customers. See "CTIA's Newest Report Shows 40 Percent Customer Growth," Radio
`Communications Report, Mar. 25, 1996, at 4.
`7 Notice, 9 FCC Red at 6172 (paras. 9-10).
`a Lockheed Reply Comments at 6.
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`8. One of the Commission's statutory mandates under the Communications Act is
`"promoting safety of life and property through the use of wire and radio communication." 9
`Recognizing this responsibility, the Commission has expressed increasing concern regarding
`the inability of wireless customers to benefit from the advanced emergency capabilities of
`E911 systems that are available to most wireline customers. In developing rules for
`broadband PCS, we urged industry and standards-setting bodies to direct particular attention to
`E911 access, including, to the extent feasible, automatic location of callers.'0 We recognized
`that the health and safety of citizens would be affected by whether broadband PCS carriers are
`capable of providing E911 access that is equivalent to access provided to wireline customers.
`While we declined to delay the introduction of broadband PCS service until E911 issues had
`been resolved, we stated our intention to initiate a proceeding to address E911 and related
`issues with regard to broadband PCS, cellular, and any other relevant mobile service."
`
`9. The Notice in this docket began that endeavor. In-adopting this Report and Order,
`we are promulgating requirements and establishing a framework to improve wireless 911
`services. We believe that these actions will result in the deployment of technologies that will
`help speed the delivery of assistance to people in need of help in emergency situations. It is
`important, however, to acknowledge what we are not able to achieve in this Order. We
`recognize that expanding the availability and increasing the reliability of wireless 911 service
`depend upon more than actions that we are able to take at this time.
`
`" The implementation of E911 service will require a separate decisional process by many
`state and local public safety organizations to invest in facility and equipment upgrades
`to be able to receive E911 call location information.
`
`• Proper incentives should be developed to encourage wireless service providers to
`transition to improved and more extensive network technology and infrastructures in
`order to provide more reliable 911 service coverage over wider geographic areas. We
`must ensure that reasonable requirements and incentives are in place to facilitate the
`application of this technology to improve wireless 911 services. For example, we need
`to explore further the steps that can be taken to improve upon the ALl specifications we
`are adopting in this Order.
`
`9 Section 1 of the Communications Act, 47 U.S.C. § 151.
`, Amendment of the Commission's rules to Establish New Personal Communications Services,
`GEN Docket No. 90-314, Second Report and Order, 8 FCC Rcd 7700 (1993) (PCS Second Report and
`Order).
`
`11 PCS Second Report and Order, 8 FCC Red at 7756 (para. 139).
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`m Solutions to wireless service interoperability should be pursued in order to reduce
`current limitations on the ability of callers to switch from one provider's network to
`another as the caller roams between wireless systems.
`
`m We need to explore further the steps that can be taken to improve upon the ALI
`specifications we are adopting in this Order. As technology leads to the development of
`cost effective location systems that can improve upon the accuracy and reliability
`standards we are adopting, we must ensure that reasonable requirements and incentives
`are in place to facilitate the application of this technology to improve wireless 911
`services.
`
`m We need to explore further means of improving consumer education so that users of
`wireless services will be able to determine rationally and accurately the scope of their
`options in accessing 911 services from mobile handsets.
`
`These are some of the goals that the Commission, state and local governments, the wireless
`industry, and PSAP organizations should strive to achieve during the five-year period for
`implementing enhancements to wireless 911 services. The Further Notice of Proposed
`Rulemaking we are adopting today will serve as one means for the pursuit of these goals.
`One of our principal objectives is to make sure that ongoing processes are in place that will
`make technological advances available to 911 service providers, and that will give PSAP
`administrators the means to acquire and utilize these new technologies. Such a process will
`ensure that users of wireless services will receive effective and reliable 911 services.
`
`B. Executive Summary of Commission Actions
`
`1. Report and Order
`
`10. In this proceeding, we adopt several requirements pursuant to our authority under
`Sections 301 and 303(r) of the Communications Act, and make them applicable to all cellular
`licensees, broadband PCS licensees, and certain Specialized Mobile-Radio (SMR) licensees (as
`defined in Section IV.B.2, infra). These classes of licensees are hereafter referred to as
`"covered carriers." Certain other SMR licensees and Mobile Satellite Service (MSS) carriers
`are exempt from our requirements. The requirements we adopt in this Report and Order are
`as follows:
`
`m Not later than 12 months after the effective date of the rules adopted in this proceeding,
`covered carriers must process and transmit to any appropriate PSAPs all 911 calls made
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`from wireless mobile handsets which transmit a code identification, 2 including calls
`initiated by roamers. The processing and transmission of such calls shall not be subject
`to any user validation or similar procedure that otherwise may be invoked by the
`covered carrier.
`
`s In the case of 911 calls made from wireless mobile handsets that do not transmit a code
`identification, not later than 12 months after the effective date of the rules adopted in
`this proceeding, covered carriers must process and transmit such calls to any appropriate
`PSAP which previously has issued a formal instruction to the carrier involved that the
`PSAP desires to receive such calls from the carrier.
`
`m Not later than 12 months after the effective date of the rules adopted in this proceeding,
`covered carriers must be capable of transmitting calls by individuals with speech or
`hearing disabilities through devices used in conjunction with or as a substitute for
`traditional wireless mobile handsets, e.g., through the use of Text Telephone Devices
`(TTY) to local 911 services.
`
`n The implementation and deployment of enhanced 911 features and functions will be
`accomplished in two phases. Under Phase I, not later than 12 months after the effective
`date of the rules adopted in this proceeding, covered carriers must have initiated the
`actions necessary to enable them to relay a caller's Automatic Number Identification
`(ANT) and the location of the base station or cell site receiving a 911 call to the
`designated PSAP. Not later than 18 months after the effective date of the rules adopted
`in this Order, such carriers must have completed these actions. These capabilities will
`allow the PSAP attendant to call back if the 911 call is disconnected.
`
`n Under Phase II, not later than five years after the effective date of the rules adopted in
`this proceeding, covered carriers are required to achieve the capability to identify the
`
`identification," when used in this Order in conjunction with 911 calls, means
`12 The term "code
`(1) in the case of calls transmitted over the facilities of a covered carrier other than a Specialized
`Mobile Radio carrier that is subject to the requirements of this Order, a call originated from a mobile
`unit which has a Mobile Identification Number (MIN); and (2) in the case of calls transmitted over the
`facilities of a Specialized Mobile Radio carrier that is subject to the requirements of this Order, a call
`originated from a mobile unit which has the functional equivalent of a MIN. A MIN is a 34-bit
`binary number that a PCS or cellular handset transmits as part of the process of identifying itself to
`wireless networks. Each handset has one MIN, and it is derived from the ten-digit North American
`Numbering Plan (NANP) telephone number that generally is programmed into the handset at the time
`service for a new subscriber is initiated. See, e.g., EIAITIA Standard 553, Mobile Station - Land
`Station Compatibility Specification, September 1989, at 2.3.1.
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`latitude and longitude of a mobile unit making a 911 call, within a radius of no more
`than 125 meters in 67 percent of all cases.
`
`11. We also provide that the E911 (Phase I and Phase II) requirements imposed upon
`covered carriers by our actions in this Order shall apply only if (1) a carrier receives a request
`for such E911 services from the administrator of a PSAP that is capable of receiving and
`utilizing the data elements associated with the services; and (2) a mechanism for the recovery
`of costs relating to the provision of such services is in place. If the carrier receives a request
`less than 6 months before the implementation dates of Phase I and Phase II, then it must
`comply with the Phase I and Phase II requirements within 6 months after the receipt of the
`notice specifying the request.
`
`12. Covered carriers, in coordination with the public safety organizations, are directed
`to resolve certain E911 implementation issues, including grade of service and interface
`standards, through industry consensus in conjunction with standard-setting bodies. This
`Commission intends to remain actively involved, as appropriate, to ensure resolution of issues
`necessary to prompt widespread availability of E91 1 service.
`
`2. Further Notice of Proposed Rulemaking
`
`13. The E911 system requirements we are establishing in this Order are a first step
`toward our goal of improving the availability and quality of 911 service. In view of the
`Nation's important public safety needs, we find a compelling public interest in taking steps to
`ensure that E911 system performance keeps pace with the latest technologies. Therefore, we
`are also issuing a Further Notice of Proposed Rulemaking to develop additional means of
`ensuring that improvements made possible by technological advances are incorporated into
`E911 systems.
`
`14. In the Further Notice of Proposed Rulemaking, we tentatively conclude and request
`comment as follows:
`
`m We seek comment on possible approaches to avoid customer confusion that could be
`generated by a system under which customers in the same geographic area may or may
`not be able to complete non-code identification 13 911 calls depending upon the practices
`of the various PSAPs serving that area. Specifically, we request comment regarding
`whether, within a reasonable time after the one-year period, PSAPs should no longer
`
`,3 The term "non-code
`identification," when used in this Order in conjunction with 911 calls,
`means a call originated from a mobile unit which does not have a code identification See note 12,
`329a.
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`have the option to refuse to accept non-code identification 911 calls. Thus, covered
`carriers would be obligated to transmit all 911 calls to PSAPs.
`
`" We tentatively conclude that covered carriers should continue to upgrade and improve
`911 service to increase its accuracy, availability, and reliability, while also recognizing
`that our rules should ensure that covered carriers' development and application of new
`technologies for E911 services also contribute to the overall quality of service and range
`of services that carriers provide to all their customers. These efforts will ensure that the
`public benefits from technological innovations, through the application of those
`innovations to public safety needs.
`
`" We seek comment on a range of related issues, including the following: (1) Should
`covered carriers provide PSAPs information that locates a wireless 911 caller within a
`radius of 40 feet, using longitude, latitude, and altitude data, and that provides this
`degree of accuracy for 90 percent of the 911 calls processed?
`(2) Should wireless
`service providers be required to supply location information to the PSAP regarding a
`911 caller within a certain number of seconds after the 911 call is made? (3) Should
`wireless service providers be required to update this location information throughout the
`duration of the call? (4) What steps could be taken to enable 911 calls to be completed
`or serviced by mobile radio systems regardless of the availability (in the geographic area
`in which a mobile user seeks to place a 911 call) of the system or technology utilized
`by the user's wireless service?
`
`, We also tentatively conclude that a consumer education program should be initiated to
`inform the public of the capabilities and limitations of 911 service, and we seek
`comment regarding the scope of such a program and carrier obligations that could be
`established in connection with such a program. One purpose of such a program would
`be to address a concern that consumers currently may not have a sufficient
`understanding of technological limitations that can impede transmission of wireless 911
`calls and the delivery of emergency assistance.
`
`][[. BACKGROUND OF PROCEEDING
`
`A. Joint Paner: JEM Regort
`
`15. Public safety organizations and the wireless telecommunications industry have both
`recognized the limitations that the unique characteristics of wireless communications impose
`on current emergency service systems, and have been exploring paths to deliver E911 to
`wireless customers. On June 30, 1994, the Association of Public-Safety Communications
`Officials International, Inc. (APCO), the National Emergency Number Association (NENA),
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`and the National Association of State Nine One One Administrators (NASNA), and the
`Personal Communications Industry Association (PCIA) issued an "Emergency Access
`Position Paper" (Joint Paper), which they filed as an ex parte comment in the PCS
`proceeding. In July 1994, representatives of the wireless telecommunications community and
`the emergency service and public safety community undertook a joint examination of the
`issues related to wireless support of 911.
`
`16. The two communities convened a Joint Experts Meeting (JEM) in October 1994,
`including representatives of communications, public safety, satellite, Specialized Mobile
`Radio, and intelligent vehicle highway system (IVHS) industries, as well as vendors to these
`industries. The outcome of this meeting was a JEM Report that included a prioritized list of
`PSAP service requirements, the mapping of emergency services features to evolutionary paths
`showing which features need to be upgraded, identification of information elements
`transferred between the wireless system and the emergency service system, and the
`identification of radio location techniques that may provide wireless ALL. The JEM meeting
`and report, however, did not produce wireless E911 standards or any firm plan or schedule for
`implementing wireless E9l 1.
`
`B. Wireless E911 Notice of Proposed Rulemakine
`
`17. In the Notice, we stated our belief "that Commission action is necessary to ensure
`that, over time, mobile radio service users on the public switched telephone network have the
`same level of access to 911 emergency services as wireline callers."' 4 We thus proposed to
`require that mobile radio transmitters supplied to wireless customers provide the same level of
`access to 911 emergency services as is available to wireline customers." We did not
`anticipate adopting extensive technical standards for E911 operation - a task for which
`standards-setting committees are better equipped -- but proposed that general performance
`criteria be adopted. 6
`
`feature, the ability to report the caller's
`18. With respect to the most crucial E91
`location to the PSAP, we tentatively concluded that ALI should be implemented by wireless
`carriers in three steps over five years:
`
`x We proposed that wireless carriers would be required to design their systems so that the
`location of the base station or cell site receiving a 911 call from a mobile unit would be
`
`14 Notice, 9 FCC Rcd at 6176 (par. 37).
`
`Is
`
`Id
`
`16 ld at 6177 (para. 40).
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`relayed to the PSAP. This requirement would take effect within one year after the
`effective date of the Order adopting rules in this proceeding.
`
`" Within three years, the wireless service provider would be required to include an
`estimate of the approximate location and distance of the mobile unit from the receiving
`base station or cell site.
`
`" After five years, the location of the mobile unit would be identified within three
`dimensions, within a radius of no more than 125 meters. We reasoned that this
`information should enable the PSAP to assist emergency service personnel by providing
`a relatively precise location for a wireless 911 caller.17
`
`19. We also discussed and sought comment on a range of other issues, principally
`issues that must be resolved in order to implement the wireless E911 capabilities identified as
`essential by the wireless industry and public safety groups. These issues are summarized in
`Table A in Appendix D.
`
`20. In response to the Notice, over 110 parties filed comments and reply comments
`regarding the wireless 911 issues, including wireless service providers, public safety
`In addition, a Petition for Rulemaking
`organizations, equipment manufacturers, and others."
`was filed on October 27, 1995, by the Ad Hoc Alliance for Public Access to 911 (Alliance)
`requesting that 911 access be provided to any cellular phone, regardless of whether it is listed
`as a cellular carrier's subscriber, and that mobile handsets be equipped to select and use the
`channel with the strongest cellular signal whenever a 911 call is placed. On November 13,
`1995, the Commission sought comment regarding this Petition. 9 In response to our Public
`Notice, eight comments and one set of reply comments were filed.
`
`C. Consensus Agreement
`
`21. In the initial comment round, the wireless industry and representatives of public
`safety organizations generally supported the goals of the Notice, including the benefits and
`importance of deploying wireless E911 capability. Broadly speaking, the industry and public
`
`17 Id. at 6178-79 (paras. 49-51).
`
`" A list of these pleadings, as well as related pleadings filed in the docket, is included in
`Appendix A. Abbreviations used in this Order in citing to pleadings also are included in Appendix A.
`" Public Notice, Commission Seeks Comment on Petitions for Rulemaking filed by Ad Hoc
`Alliance for Public Access to 911 in Conjunction with Wireless Enhanced 911 Rulemaking
`Proceeding, CC Docket No. 94-102, Nov. 13, 1995; 60 FR 58593 (Nov. 28, 1995).
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`FCC 96-264
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`safety groups differed principally with regard to the schedule for E911 deployment and the
`need for Federal regulation. The public safety community supported the proposed mandatory
`five-year schedule for full E911 implementation by wireless carriers.20 The wireless carriers,
`on the other hand, generally opposed a fixed schedule."
`
`22. On February 12, 1996, after the comment cycle had closed, a Consensus
`Agreement on some of the issues in this proceeding was filed with the Commission by the
`Cellular Telecommunications Industry Association (CTIA), a trade association representing
`certain wireless industry participants (including service providers, manufacturers, and others)
`and three national public safety organizations -- APCO, NENA, and NASNA. The
`Commission sought comment regarding the Consensus Agreement," and 17 comments and 14
`reply comments were filed.
`
`23. The Consensus Agreement proposes a two-step implementation schedule for
`wireless E91 1. In Phase I, within 12 (according to the public safety signatories) or 18 months
`the Agreement proposes
`(according to CTIA) after the adoption of a Commission Order,'
`implementation of cell site information, calling party Automatic Number Identification (ANI),
`911 availability from any service initiated mobile handset that is subscribed to the wireless
`carriers on whose system the call is made, 911 access for speech and hearing-impaired callers
`using TTY devices, and call-back capability. Under Phase II, within five years, the
`Consensus Agreement proposes to require deployment of ALI for wireless callers in two
`dimensions, latitude and longitude, within 125 meters Root Mean Square (RMS), of the call's
`originat