WTB/Policy
`January 2001
`
`F A C T S H E E T
`
`FCC WIRELESS 911 REQUIREMENTS
`
`In a series of orders since 1996, the Federal Communications Commission (FCC)
`has taken action to improve the quality and reliability of 911 emergency services for
`wireless phone users, by adopting rules to govern the availability of basic 911 services
`and the implementation of enhanced 911 (E911) for wireless services.
`
`BACKGROUND ON WIRELESS 911
`
`The FCC’s wireless 911 rules seek to improve the reliability of wireless 911
`services and to provide emergency services personnel with location information that will
`enable them to locate and provide assistance to wireless 911 callers much more quickly.
`To further these goals, the agency has required wireless carriers to implement E911
`service, subject to certain conditions and schedules. The wireless 911 rules apply to all
`cellular licensees, broadband Personal Communications Service (PCS) licensees, and
`certain Specialized Mobile Radio (SMR) licensees.
`
`BASIC WIRELESS 911 SERVICES
`
`The basic 911 rules require wireless carriers to transmit all 911 calls to a Public
`Safety Answering Point (PSAP) without regard to validation procedures intended to
`identify and intercept calls from non-subscribers. Under the rules, therefore, both
`subscribers and non-subscribers can dial 911 and reach emergency assistance providers
`without having to prove their subscription status.
`
`Many wireless 911 calls are made by “Good Samaritans” reporting traffic
`accidents, crimes, or other emergencies. Prompt delivery of these and other wireless 911
`calls to public safety organizations benefits the public at large by promoting safety of life
`and property.
`
`911 CALL PROCESSING PROCEDURES
`
`In May 1999, the FCC adopted requirements to improve the ability of cellular
`phone users to complete wireless 911 calls. The 911 call completion rules are intended to
`improve the security and safety of analog cellular users, especially in rural and suburban
`areas.
`
`Under the rules, all mobile phones manufactured for sale in the United States after
`February 13, 2000, that are capable of operating in an analog mode, including dual-mode
`and multi-mode handsets, must include a special method for processing 911 calls. When
`
`Apple Inc. Exhibit 1003 Page 1
`
`

`
`WTB/Policy
`December 2000
`
`a 911 call is made, the handset must override any programming that determines the
`handling of ordinary calls and must permit the call to be handled by any available carrier,
`regardless of whether the carrier is the customer’s preferred service provider. Handsets
`capable of operating in analog mode must incorporate any one or more of the 911 call
`system selection processes endorsed or approved by the Commission.
`
`PHASE I E911 REQUIREMENTS
`
`As of April 1, 1998, or within six months of a request by the designated Public
`Safety Answering Point (PSAP), whichever is later, covered carriers are required to
`provide to the PSAP the telephone number of the originator of a 911 call and the location
`of the cell site or base station receiving a 911 call. This information assists in the
`provision of timely emergency responses both by providing some information about the
`general location from which the call is being received and by permitting emergency call-
`takers to re-establish a connection with the caller if the call is disconnected.
`
`PHASE II E911 REQUIREMENTS
`
`Wireless carriers are required to provide Automatic Location Identification (ALI)
`as part of Phase II E911 implementation beginning October 1, 2001, as detailed below.
`Originally, the FCC’s rules envisioned that carriers would need to deploy network-based
`technologies to provide ALI. In the past several years, there have been significant
`advances in location technologies that employ new or upgraded handsets. In September
`1999, the FCC revised its rules to better enable carriers to use handset-based location
`technologies to meet the Phase II requirements. In particular, the FCC established
`separate accuracy requirements and deployment schedules for network-based and
`handset-based technologies. In August 2000, the FCC made minor adjustments to the
`deployment schedule for handset-based technologies. The E911 Phase II requirements
`are as follows:
`
`§ Handset-Based ALI Technology: Wireless carriers who employ a Phase II location
`technology that requires new, modified or upgraded handsets (such as GPS-based
`technology) may phase-in deployment of Phase II subject to the following
`requirements:
`• Without respect to any PSAP request for Phase II deployment, the carrier shall:
`
`1. Begin selling and activating ALI-capable handsets no later than October 1,
`2001;
`2. Ensure that at least 25 percent of all new handsets activated are ALI-capable
`no later than December 31, 2001;
`3. Ensure that at least 50 percent of all new handsets activated are ALI-capable
`no later than June 30, 2002; and
`4. Ensure that 100 percent of all new digital handset activated are ALI-capable
`no later than December 31, 2002 and thereafter.
`
`2
`
`Apple Inc. Exhibit 1003 Page 2
`
`

`
`WTB/Policy
`December 2000
`
`5. By December 31, 2005, achieve 95 percent penetration of ALI-capable
`handsets among its subscribers.
`• Once a PSAP request is received, the carrier shall, in the area served by the PSAP,
`within 6 months or by October 1, 2001, whichever is later:
`
`1. Install any hardware and/or software in the CMRS network and/or other fixed
`infrastructure, as needed, to enable the provision of Phase II E911 service; and
`2. Begin delivering Phase II E911 service to the PSAP.
`
`§ Network-Based ALI Technology: As of October 1, 2001, within 6 months of a PSAP
`request, carriers employing network-based location technologies must provide Phase
`II information for at least 50 percent of the PSAP’s coverage area or population.
`Within 18 months of a PSAP request, carriers must provide Phase II information for
`100 percent of the PSAP’s coverage area or population.
`
`§ ALI Accuracy Standards: The FCC adopted the following revised standards for Phase
`II location accuracy and reliability:
`• For handset-based solutions: 50 meters for 67 percent of calls, 150 meters for 95
`percent of calls;
`• For network-based solutions: 100 meters for 67 percent of calls, 300 meters for 95
`percent of calls.
`
`§ ALI Implementation Plan Report: The FCC required wireless carriers to report their
`plans for implementing E911 Phase II, including the technology they plan to use to
`provide caller location, by November 9, 2000. This report was aimed at providing
`information to permit planning for Phase II implementation by public safety
`organizations, equipment manufacturers, local exchange carriers, and the FCC, in
`order to support Phase II deployment by October 1, 2001.
`
`CONDITIONS FOR ENHANCED 911 SERVICES
`
`The E911 Phase I requirements, as well as certain of the Phase II requirements,
`are applicable to wireless carriers only if the administrator of the designated PSAP has
`requested the service and is capable of receiving and utilizing information provided. In
`November 1999, the FCC revised its E911 rules to remove the prerequisite that a cost
`recovery mechanism for wireless carriers be in place before carriers are obligated to
`provide E911 service in response to a PSAP request. The PSAP must have the means of
`covering its costs of receiving and utilizing the E911 information, however, in order to
`make a valid request for E911 service. The FCC’s rules do not mandate any specific
`state action nor specify any particular mechanism for funding the technology and service
`capabilities necessary to enable the PSAP to make a valid service request.
`
`3
`
`Apple Inc. Exhibit 1003 Page 3
`
`

`
`WTB/Policy
`December 2000
`
`IMPLEMENTATION OF 911 ACT
`
`In August 2000, the FCC adopted an Order to implement the Wireless
`Communications and Public Safety Act of 1999 (911 Act), enacted on October 26,1999.
`The purpose of the 911 Act is to enhance public safety by encouraging and facilitating
`the prompt deployment of a nationwide, seamless communications infrastructure for
`emergency services that includes wireless communications. The FCC initiated the
`implementation proceeding to address the provisions of the 911 Act and to fulfill the
`Congressional mandates set forth therein. Specifically, in the Order adopted in August
`2000, the FCC took the following initiatives:
`• designated 911 as the universal emergency telephone number within the
`United States for reporting an emergency to appropriate authorities and
`requesting assistance, effective upon August 29, 2000;
`• sought comment on appropriate transition periods for areas in which 911 is
`not currently in use as an emergency number, as well as on service area-
`specific circumstances and capabilities that must be addressed before carriers
`can deploy 911 as the uniform emergency number; and
`• sought comment on how the FCC should facilitate states’ efforts to deploy
`comprehensive emergency communications systems – for example, through
`guidelines, meetings, or other information-sharing measures – in a manner
`that does not impose obligations or costs on any person.
`
`The 911 Act also added provisions dealing specifically with wireless location
`information to 47 U.S.C. § 222, the section of the Communications Act that governs
`treatment of customer proprietary network information (CPNI) and subscriber list
`information (SLI). The Commission expects to initiate a proceeding to interpret and
`clarify these provisions in early 2001.
`
`4
`
`Apple Inc. Exhibit 1003 Page 4