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RCA criticizes FCC report to Congress on rural E911 efforts

WASHINGTON-The Rural Cellular Association told the FCC’s Wireless Telecommunications Bureau Wednesday that the Federal Communications Commission in a recent report to Congress underestimated and poorly reflected the efforts of Tier III wireless carriers to implement wireless enhanced 911 Phase II.

“With the small number of Tier III service providers close to 166, not 390, there are a comparatively small number of separately owned Tier III carriers providing service in the United States,” wrote RCA counsel David Nace. “In any event, the number ’10’ as the group of Tier III carriers currently providing Phase II service to at least one public-safety answering point understates the situation, based upon industry data that has been collected by RCA. RCA is aware of no fewer than 24 Tier III carriers that provide Phase II data that is used by PSAPs to locate E911 callers. That is a significantly different number in view of information reported by the National Emergency Number Association that only about 40 percent of the PSAPs nationwide are capable of receiving Phase II data. RCA believes that percentage to be considerably lower in rural areas where most Tier III carriers operate.”

The wireless bureau said the letter was just filed, and the bureau is looking at it.

RCA also said the wireless bureau should expect more waivers of the E911 Phase II rules.

“In some cases, waiver requests will be filed to allow more time for deployment of Phase II service where the carrier has not found an effective means to meet a current deadline,” said Nace.

NENA said Tier III carriers need to do more.

“We would rather see results than waivers. It appears that a number of Tier III carriers are only interested in waivers and editing FCC reports instead of working with the 911 community in their area,” said Stephen Seitz, NENA government affairs director.

In a report to Congress in March, the FCC told lawmakers it had granted 32 whole or partial waivers for rural wireless carrier Phase II obligations. The FCC denied or dismissed eight other requests.

The waiver requests, which had been pending for an average of 461 days, were the first major wireless actions taken under new FCC Chairman Kevin Martin. The 32 waivers continue a trend of granting rural carriers relief from E911 obligations. According to the report, the FCC has granted 175 whole or partial waivers during the past nine years. The commission has denied or dismissed nine other requests.

In addition to reporting on the status of the Tier III waiver requests, the FCC also attempted to educate Congress on wireless and E911 technology and the interplay between air interfaces and carrier circumstances. It describes the various air interfaces and the differences among handset, network and hybrid solutions for meeting the E911 Phase II mandate. It also describes the advantages and disadvantages of each.

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