Subject: [NEXTEL-1] Rural networks ask for location aware delay

From: [email-masked]
Date: Wed, 03 Sep 2003 02:43:02 -0400

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 03-Sep-03

http://www.cellular-news.com/story/9646.shtml

------------------------ Yahoo! Groups Sponsor ---------------------~-->
Buy Ink Cartridges or Refill Kits for Your HP, Epson, Canon or Lexmark
Printer at Myinks.com. Free s/h on orders $50 or more to the US & Canada. http://www.c1tracking.com/l.asp?cid=5511
http://us.click.yahoo.com/l.m7sD/LIdGAA/qnsNAA/61FxlB/TM
---------------------------------------------------------------------~->

Your use of Yahoo! Groups is subject to http://docs.yahoo.com/info/terms/