Defining a valid E9-1-1 request
One of many bickering points between wireless carriers and the public safety community about E9-1-1 Phase II has been the validity of a public safety answering point’s (PSAP) request for Phase II service.
The debate’s boiling point occurred in March 2000 when the city of Richardson, TX, requested Phase II service from VoiceStream . The Richardson PSAP said its adequate cost-recovery method was enough to validate its request to receive Phase II data. VoiceStream argued that because Richardson was not already capable of receiving Phase II data, its request was bogus. Consequently, Richardson petitioned the FCC for clarification on what makes a PSAP Phase II request valid.
Last week, the FCC released its response to Richardson’s petition. The order describes three stipulations that now define a valid PSAP request. In a nutshell, a PSAP must demonstrate 1) it has a cost-recovery mechanism in place, 2) has ordered the necessary upgrades to handle Phase II data and the equipment will be ready no later than six months following the request and 3) has made a request to the appropriate LEC for trunking and other facilities that allow Phase II data to be sent to the PSAP.
The order describes how PSAPs can substantiate that the three criteria have been met, including providing copies of funding legislation, vendor purchase orders and request letters sent to LECs. Jim Nixon, VoiceStream director of government affairs, doesn’t expect PSAPs to have a problem sharing such information, as it is in the public record.
Some parties, including CTIA, wanted more restrictive criteria to constitute a valid Phase II request. The commission declined a more regimented definition for fear it would interfere with negotiation between PSAPs and carriers and ultimately delay Phase II implementation.
“Requiring a challenged PSAP to establish that these criteria have been met properly balances the parties’ respective obligations and ensures both that PSAPs receive timely Phase I and Phase II service and that wireless carriers are not asked to commit resources needlessly,” the order states.
The order may not be as rigid as some in the wireless industry would have liked, but it’s also not as vague as public safety groups wanted. The commission rejected filings from the Association of Public-Safety Communications Officials-International and the National Emergency Number Association that a cost-recovery plan alone is enough to show that a PSAP will be Phase II-ready within six months of a request.
The order’s clarity is particularly important for carriers who, otherwise, might have faced a deluge of Phase II requests from unequipped PSAPs. In the early stages of deployment, Phase II equipment will be limited; getting the service to PSAPs that actually can use it will thus be critical to efficiency.
“The carrier needs some verification, some sense of confidence that the efforts they put forward for Phase II will bear fruit,” Nixon said. “That’s really our focus, let’s find out where we can get the most impact for the implementation dollars and effort.”