Rural Networks Ask for Location Aware Delay

The USA's Rural Telecommunications Group (RTG) has filed a Petition with the telecoms regulator, the FCC requesting Temporary Limited Stay of Section 20.18 of the Commission's Rules, and asking that the commission create a Tier IV class of rural wireless carriers that will be eligible for additional time to meet the E911 Phase II accuracy requirements set forth in Section 20.18 of the FCC's rules. The Tier IV classification would apply to carriers with 100,000 or fewer subscribers. RTG has created categories or "baskets" of relief for Tier IV carriers that fit into specific, narrowly focused situations. The relief requested applies to Tier IV carriers who have chosen handset and network based solutions and varies according to the particular carrier's situation.

For carriers choosing a network-based solution, RTG has developed a Tower Density Factor (TDF). The group has specifically requested more time to meet the Phase II accuracy requirements for those carriers with low tower density -- a ratio based on distance between towers that affects triangulation. The Petition seeks additional relief for those carriers who have deployed less than three cell sites.

"We have members in Alaska and Texas that operate very small systems that only have one or two cell sites," stated Carri Bennet, General Counsel for RTG. "Triangulation with standard cellular antenna configurations requires a minimum of three locations and cannot occur from two cell sites."

Added Michael K. Kurtis, an attorney and RF engineer with Kurtis & Associates, "No meaningful location information can be obtained from any antenna system from a single isolated cell site."

RTG is working closely with the Tier III Coalition for Wireless E-911, a group of rural carriers who have a Petition for Forbearance currently pending at the FCC, as well as the National Telecommunications Cooperative Association (NTCA) and the Organization for the Promotion and Advancement of Small Telecommunications Companies (OPASTCO) to craft relief for their respective members.

For carriers choosing a handset-based solution, RTG has requested that additional time be given to carriers to obtain ALI-capable CDMA and GSM handsets.

"Handset manufacturers enter into exclusive deals with large carriers for the newer, more accurate handsets," said William Casto, CEO of Cellular 2000 serving St. Cloud, Minnesota. "For Rural carriers who have less buying clout, it is substantially more difficult for them to obtain these handsets initially. Allowing some additional time for smaller carriers to get handsets into consumers' hands that meet the accuracy requirements is absolutely a necessity."

The RTG has asked the FCC to consider tying handset deployment to PSAP requests. The group notes that having Tier IV carriers who have not received a PSAP request be required to sell ALI-capable handsets, isn't fair to rural consumers who will not receive the benefit locally because the PSAP cannot support the ALI technology.

"RTG's alternative proposal is a technologically neutral solution because it keys handset sales benchmarks to a PSAP request," stated Michael Bennet, a partner at Bennet & Bennet. "A Tier IV carrier who has not received a PSAP request may have been predisposed to a handset based solution, but then was forced to choose a network-based solution simply because handsets were not readily available."

Bennet went on to say, "Unfortunately, the rules provide an incentive for carriers who intend to employ a handset-based solution to inform the Commission that they are relying on a network-based solution in order to avoid incurring Phase II implementation expenses. Such carriers may then change to a handset-based solution after receipt of a PSAP request, providing them with a competitive advantage over carriers who had honestly declared their intent all along to rely on a handset-based solution."

Many rural wireless carriers have financing arrangements that are contingent on compliance with all Commission rules and regulations. Carriers that fail to meet the September 1 deadline or any subsequently imposed deadline potentially face the loss of the very financing they will use to implement Phase II if the deadline is not stayed and adequate relief given.

"As a lender to many rural wireless carriers, we would like to see the FCC resolve these issues so that our borrowers are not put in a position that may jeopardize their loan covenants," stated Robert West, Senior Vice President of CoBank, which finances 240 rural communications companies. "It is critical that the FCC immediately grant RTG's request to stay the September 1 deadline so that those who have not been able to comply can have protection."

Jeffrey Smith, Policy Analyst with OPASTCO said, "We are pleased that RTG took the initiative to get something on file with the FCC that focuses on rural E-911 deadlines. One size does not fit all in rural America and the establishment of these categories to try to be as inclusive as possible without capturing carriers who do not need relief is not an easy task. We are reviewing the filing and discussing it with our members to determine if other relief may be necessary."

Posted to the site on 3rd September 2003