Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of ) ) The Use of N11 Codes and Other ) CC Docket No. 92-105 Abbreviated Dialing Arrangements ) STATUS REPORT OF THE CELLULAR TELECOMMUNICATIONS & INTERNET ASSOCIATION ON THE WIRELESS INDUSTRY S IMPLEMENTATION OF 7-1-1 ABBREVIATED DIALING CODE FOR TELECOMMUNICATIONS RELAY SERVICE The Cellular Telecommunications & Internet Association ( CTIA ) 1 hereby submits this Status Report on the wireless industry s efforts to implement the 7-1-1 abbreviated dialing code for telecommunications relay service ( TRS ) as set forth in the Commission s Second Report and Order in the above-captioned proceeding. 2 In the Second R&O, the Commission requires all telecommunications carriers, including wireless carriers, to deploy 7-1-1 nationwide as the abbreviated dialing code for TRS by October 1, 2001. 3 Consequently, wireless carriers must translate 7-1-1 into the seven or ten-digit numbers provided by multiple TRS centers by the October 1 st compliance date. While the 1 CTIA is the international organization of the wireless communications industry for both wireless carriers and manufacturers. Membership in the association covers all Commercial Mobile Radio Service ( CMRS ) providers and manufacturers, including cellular, broadband PCS, ESMR, as well as providers and manufacturers of wireless data services and products. 2 In re The Use of N11 Codes and Other Abbreviated Dialing Arrangements, CC Docket No. 92-105, Second Report and Order, FCC 00-257 (rel. Aug. 9, 2000) ( Second R&O ). 3 See Second R&O at 32.
Commission acknowledges that wireless carriers face unique problems with the identification and routing of wireless 7-1-1 calls, it maintains that these issues do not affect the ability of wireless carriers to effectuate the 7-1-1 translation by the October 1 st compliance date. 4 The goals of this Status Report are to: 1) explain the industry s efforts to date with respect to the translation of 7-1-1 and meeting the October 1, 2001, compliance date; 2) delineate the critical role of relay centers in the identification and routing of wireless TRS calls; 3) identify steps taken to identify and assess the scope of the problem; and 4) outline the industry s plans to address the technical issues within its control. I. STATUS OF 7-1-1 TRANSLATION Since the release of the Second R&O, CTIA has been surveying its members to determine the industry s progress with respect to wireless 7-1-1 implementation. On December 15, 2000, CTIA hosted an industry meeting to assess the status of 7-1-1 translation and to prioritize outstanding implementation issues. At the meeting, CTIA also established an industry Ad-Hoc working group to address and develop a variety of solutions for wireless carriers in their efforts to deploy 7-1-1 successfully. As was discussed at the December 2000 meeting, wireless carriers are focusing their efforts and resources on assessing and resolving technical issues associated with the translation of 7-1-1 in order to meet the October 1 st compliance date. At this time, carriers are making steady progress incorporating the translation of 7-1-1 into their network architectures. It appears that the wireless industry will be able to complete its implementation of the translation of 7-1-1 by the October 1, 2001, compliance date. However, even though wireless carriers will be able to 4 Id. at 33. 2
translate 7-1-1, obtaining functional equivalency in the wireless context may require TRS centers to modify their operations to accommodate wireless rate plans. The outstanding implementation issues noted by CTIA and acknowledged by the Commission, 5 however, will not be resolved by October 1, 2001. While the majority of the industry s efforts are focused on translation issues at this time, CTIA s industry ad-hoc working group has started to lay the groundwork for addressing the various technical and operational hurdles associated with the identification and routing of wireless TRS Calls. II. OTHER IMPLEMENTATION ISSUES: IDENTIFICATION AND ROUTING OF WIRELESS TRS CALLS The record in this proceeding clearly explains the unique technical and operational challenges associated with the identification and routing of wireless TRS calls. 6 (cite CTIA July July 5, 2000, ex parte filing and the Second R&O). The parties have observed several issues as presenting challenges for the implementation of 7-1-1 abbreviated dialing code for TRS. The primary issue involves the identification and routing of wireless TRS calls. Specifically, the wireless industry has identified four fundamental issues that relay centers and industry technical and operational experts will have to address in supporting 7-1-1 implementation The capability of relay centers to properly identify wireless TRS calls Routing of "cross-border" wireless TRS calls 5 Id. at 33-40. In the Second R&O, the Commission reiterates CTIA s concern that wireless calls are often identified as interstate calls. This concern stems from the following scenarios: 1) wireless callers may be routed to a switch that is not located within the same state as the caller; 2) wireless callers roaming outside their home territory may be routed to a relay center not serving the caller s home territory; and 3) a TRS center often cannot identify a call as a wireless one. The Commission also notes other implementation issues involving payphone providers and non-common carrier private branch exchange ( PBX ) providers. R&O. 6 See Ex Parte Presentation, CC Docket No. 92-105 (filed July 5, 2000); Second 3
Roaming outside of home territory; and The billing of wireless TRS calls in accordance with customer's selected wireless rate plan III. THE CRITICAL ROLE OF RELAY CENTERS As the Commission correctly noted in the Second R&O, relay centers play a significant role in the identification and routing of wireless TRS calls. The majority of relay centers have significant problems identifying a wireless call and ensuring that wireless TRS calls are billed in in accordance with the subscriber's wireless rate plan. Many TRS centers are equipped with legacy platforms designed to accommodate wireline TRS calls. Moreover, these platforms have been extensively modified beyond their original functions to accommodate a host of other services, such as speech-to-speech, 900, HCO and VCO services. Unfortunately, these legacy platforms are not equipped to utilize the SS7 trunking information. When TRS centers capture the ANI, certain parameters are associated with the ANI to indicate whether the call is originating from a PBX, a payphone, a wireless terminal, etc. If the TRS Center's platform is not configured to recognize these parameters, the call information may be incorrect or missing. This may require TRS centers to modify or upgrade their platforms. IV. DATA COLLECTION The competitive nature of the industry requires TRS centers to handle a variety of wireless calls based on several business and subscriber models, i.e., local, regional, and nationwide footprints, roaming, pre-paid wireless, and a host of subscriber rate plans. As explained above, TRS centers must accommodate wireless rate plans to provide functional equivalent services. To assist TRS centers in their efforts, CTIA's Ad-hoc Working Group is in 4
the process of collecting information on the most common business and subscription models that TRS Centers are likely to encounter when they receive a wireless TRS call. V. NEXT STEPS The industry Ad-Hoc Working Group acknowledged at the December 2000 meeting that experts from both the wireless industry and TRS centers must first define the problem in terms of technical and operational issues, then assess the scope of the problem within the wireless and wireline network infrastructure. Relay service providers and TRS Centers must also go through a similar defining and assessment process. Such processes are necessary for developing technically and economically feasible solutions. Accordingly, CTIA is in the process of scheduling initial meetings with the four major relay service providers, i.e., AT&T Relay, Sprint Relay, MCI Relay and Hamilton Relay, to discuss the critical role of TRS centers in the identification and routing of wireless TRS calls. CTIA hopes to glean the following information from these meetings: Assessment of relay service providers technical capabilities with respect to identifying, routing and billing wireless TRS calls Whether they have the flexibility and technical capability to handle the various business/subscription models. If relay service providers have to update or modernize their equipment in order to handle wireless TRS calls, what is the extent of such modernization in terms of time, costs, and funding mechanism for modernization. Explore the possibility of harmonizing contractual arrangements between a single CMRS service provider and each TRS contractor. 5
The results of the meetings with TRS providers will be presented to CTIA s TRS Implementation Ad-Hoc Group for review and discussion in mid-april 2001. CTIA anticipates a subsequent meeting of the industry Ad-Hoc Working Group in late- May 2001 to develop recommendations on a course of action that is technically and economically feasible for resolving the identification and routing of wireless TRS calls. Furthermore, CTIA will keep the Commission informed of the industry's progress by submitting periodic status reports throughout the process. Respectfully submitted, CELLULAR TELECOMMUNICATIONS & INTERNET ASSOCIATION Andrea D. Williams Assistant General Counsel Michael F. Altschul Vice President, General Counsel 1250 Connecticut Avenue, N.W. Suite 800 Washington, D.C. 20036 (202) 785-0081 February 12, 2001 6