Before the Federal Communications Commission Washington, D
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- 189.CONCLUSION
- 191.PROCEDURAL MATTERS
- A.Comment Filing Procedures
A.Roaming Issues186.In the 2007 E911 Location Accuracy Notice and the 2010 E911 Location Accuracy Further Notice and NOI, the Commission sought comment on location accuracy while roaming.1 The Commission expressed concern that “a wireless caller whose carrier employs one type of location technology may not be provided Phase II service at all when roaming on the network of another carrier that relies on a different technology, or when there is no roaming agreement between carriers using compatible technologies.”2 In 2011, CSRIC II’s Working Group 4C similarly noted that “[t]he ability to support Phase II location for roamers may be limited in some carriers’ networks.”3 187.We seek comment on whether the provision of Phase II information for roamers continues to be a concern, or whether this concern has been addressed by the evolution of location technology since the Commission last examined this issue. In comments responding to the E911 Location Accuracy Further Notice and NOI, NENA noted that “carriers are now migrating to network-assisted GNSS positioning solutions, though not all carriers have yet adopted this technology,” and asked the Commission to “seek input from carriers on how best to ensure that E9-1-1 calls in a roaming environment are completed.”1 AT&T indicated that “at least in the case of GSM carriers, there is no clear problem in locating roamers that requires a regulatory solution,” and stated that it “can support locating roaming handsets as long as the handsets support compatible spectrum.’”2 Verizon similarly stated that it can provide Phase II location for all Code Division Multiple Access (CDMA) roamers using location-capable handsets “in the same manner as for our subscribers.”3 However, Verizon also noted that it is unable to provide Phase II location capability to customers using handsets that are not location-capable (i.e., without a GPS chip) or that use a different air interface.4 188.The record suggests that in most cases, handset-based carriers and network-based carriers can support Phase II location for roamers on their networks because roamers typically use compatible technologies. In addition, potential incompatibility in location technology used by roamers may be reduced further as both handset and network-based carriers migrate to A-GPS and move forward with the planned implementation of VoLTE. We seek comment on this analysis. Notwithstanding these technology trends, are there circumstances in which accurate location of roamers could continue to be hindered by technological incompatibilities? Could implementation of our indoor location proposals create any challenges in the roaming context that the Commission should address? 189.CONCLUSION190.By this Third Further Notice, we seek comment on proposed measures to ensure the delivery of more accurate Phase II location information. In proposing an indoor location regulatory framework, as well as measures to ensure that our existing E911 requirements continue to keep pace with technological developments and changing consumer and public safety needs, we intend to ensure that all wireless calls to 911 receive the support they need in times of an emergency. 191.PROCEDURAL MATTERSA.Ex Parte Presentations192.The proceedings initiated by this Third Further Notice shall be treated as “permit-but-disclose” proceedings in accordance with the Commission’s ex parte rules.1 Persons making ex parte presentations must file a copy of any written presentation or a memorandum summarizing any oral presentation within two business days after the presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral ex parte presentations are reminded that memoranda summarizing the presentation must: (1) list all persons attending or otherwise participating in the meeting at which the ex parte presentation was made; and (2) summarize all data presented and arguments made during the presentation. If the presentation consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s written comments, memoranda, or other filings in the proceeding, the presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them in the memorandum. Documents shown or given to Commission staff during ex parte meetings are deemed to be written ex parte presentations and must be filed consistent with rule 1.1206(b). In proceedings governed by rule 1.49(f) or for which the Commission has made available a method of electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations, and all attachments thereto, must be filed through the electronic comment filing system available for that proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in this proceeding should familiarize themselves with the Commission’s ex parte rules. A.Comment Filing Procedures193.Pursuant to sections 1.415 and 1.419 of the Commission’s rules, 47 CFR §§ 1.415, 1.419, interested parties may file comments and reply comments in response to this Third Further Notice of Proposed Rulemaking on or before the dates indicated on the first page of this document. Comments may be filed using the Commission’s Electronic Comment Filing System (ECFS). See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998).
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission’s Secretary, Office of the Secretary, Federal Communications Commission.
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