1. doc.: IEEE 802_21-07/xxxx Submission July, 2007 Scott Henderson, Research In Motion Emergency Services Regulations (An Engineer’s Viewpoint) Notice: This document has been prepared to assist IEEE 802.21. It is offered as a basis for discussion and is not binding on the contributing individual(s) or organization(s). The material in this document is subject to change in form and content after further study. The contributor(s) reserve(s) the right to add, amend or withdraw material contained herein. Release: The contributor grants a free, irrevocable license to the IEEE to incorporate material contained in this contribution, and any modifications thereof, in the creation of an IEEE Standards publication; to copyright in the IEEE’s name any IEEE Standards publication even though it may include portions of this contribution; and at the IEEE’s sole discretion to permit others to reproduce in whole or in part the resulting IEEE Standards publication. The contributor also acknowledges and accepts that this contribution may be made public by IEEE 802.21. Patent Policy and Procedures: The contributor is familiar with the IEEE 802 Patent Policy and Procedures, including the statement "IEEE standards may include the known use of patent(s), including patent applications, provided the IEEE receives assurance from the patent holder or applicant with respect to patents essential for compliance with both mandatory and optional portions of the standard." Early disclosure to the Working Group of patent information that might be relevant to the standard is essential to reduce the possibility for delays in the development process and increase the likelihood that the draft publication will be approved for publication. Please notify the Chair as early as possible, in written or electronic form, if patented technology (or technology under patent application) might be incorporated into a draft standard being developed within the IEEE 802.21 Working Group. If you have questions, contact the IEEE Patent Committee Administrator at.http:// ieee802.org/guides/bylaws/sb-bylaws.pdfpatcom@ieee.org Date: 2007-07-16 Authors:

2. doc.: IEEE 802_21-07/xxxx Submission July, 2007 Scott Henderson, Research In Motion Emergency Services Organizations Government –FCC –UE Commission (Expert Group on Emergency Access (EGEA) ) –ATIS ESIF NGES –ANSI HSSP –US DoT –Emergency Services Project in Austria –Canadian Radio-television and Telecommunications Commission (CRTC) ES –NENA = National Emergency Number Assoc. –APCO = Assoc. of Public Safety Communications Officials Standards –IETF ECRIT –IETF GEOPRIV / LoST –WiMAX Forum –WiFi Alliance –ETSI EMTEL –ETSI TISPAN –3GPP (IMS) –3GPP2 –IEEE 802.1AB –IEEE 802.11 u, v –IEEE 802.16 –TIA LLDP-MED –TIA TR-45 –OMA –ITU-T –OCG –CTIA

3. doc.: IEEE 802_21-07/xxxx Submission July, 2007 Scott Henderson, Research In Motion Some of the Regulations/Standards Wireless Communications and Public Safety Act of 1999, Pub. L. No. 106- 81, 113 Stat. 1286, § 2(b) (1999) (911 Act). –U.S. Senate Bill 2007 S428 (amends The Wireless Communications and Public Safety Act of 1999 (47 U.S.C. 615 et seq.) to include IP services) FCC –FCC 05-116 FIRST REPORT AND ORDER AND NOTICE OF PROPOSED RULEMAKING –FCC 94-102 Docket no 94-102 including order numbers 96-264, 99-96, 99-245 –FCC DA 05-2945 November 28, 2005 Interconnected VoIP 911 Compliance Letters EIA/J-STD-034-1997, Wireless Enhanced Emergency Services TIA-J-STD-036-B Enhanced Wireless 9-1-1 Phase 2, 06/2005 NENA Interim VoIP Architecture for Enhanced 9-1-1 Services (i2) EU Requirements (ETSI EMTEL, TISPAN, EGEA) ROW requirements

4. doc.: IEEE 802_21-07/xxxx Submission July, 2007 Scott Henderson, Research In Motion Distillation: Requirements as they affect IEEE 802 Now Location (Automatic Location Identifier) –Initial with MS ES request –Enhanced upon NSAP request –Most regulatory domains require, some are opt in only Support for callback Unauthenticated calls –Roaming and non roaming Multi level priority for calls (not universal) Multi level priority for LBS (location based services) flows (not universal)

5. doc.: IEEE 802_21-07/xxxx Submission July, 2007 Scott Henderson, Research In Motion Future Requirements ECALL –Automated emergency calls NG911 –Support for non voice ES connections

6. doc.: IEEE 802_21-07/xxxx Submission July, 2007 Scott Henderson, Research In Motion Location Issues FCC 05-116 indicated multiple times that MS assisted location was OK for a start but long term “must include a method for determining a user’s location without assistance from the user” Further, wireless VoIP should eventually be equivalent to cellular for 9-1-1 services NENA has indicated that current cellular performance is inadequate and are requesting requirements be tightened Handover after initiation could affect enhanced location requests, callback

7. doc.: IEEE 802_21-07/xxxx Submission July, 2007 Scott Henderson, Research In Motion Current Location Requirements Carriers are required to have the capability to identify the latitude and longitude of the mobile units making 911 calls - For network-based solutions: 100 meters for 67% of calls, and 300 meters for 95% of calls; For handset-based solutions: 50 meters for 67% of calls, and 150 meters for 95% of calls

8. doc.: IEEE 802_21-07/xxxx Submission July, 2007 Scott Henderson, Research In Motion Other Location Interests Lawful Intercept (CALEA, RIPA, etc.) –Communications Asssistance for Law Enforcement Act, Pub. L. No. 103-414, 108 Stat. 4279 (1994) (codified as amended in sections of 18 U.S.C. and 47 U.S.C.) –Communications Assistance for Law Enforcement Act, Report and Order, CC Docket No. 97- 213, released March 15, 1999 (“First Report and Order”) –Communications Assistance for Law Enforcement Act, Report and Order, CC Docket No. 97- 213, released August 31, 1999 (“Second Report and Order”) –Communications Assistance for Law Enforcement Act, Report and Order, CC Docket No. 97- 213, released August 31, 1999 (“Third Report and Order”) –Communications Assistance for Law Enforcement Act and Broadband Access and Services, ET Doc. 04-295, 19 FCC Rcd 15676 (Aug. 9, 2004) (“CALEA and Broadband Notice of Proposed Rulemaking and Declaratory Ruling”) –Communications Assistance for Law Enforcement Act and Broadband Access and Services, ET Doc. 04-295, released September 23, 2005 (“CALEA and Broadband First Report and Order”) –FCC regulations: 47 C.F.R (Subpart U) § 64.100 et seq. –J-STD 025B (TIA/ANSI) Location Based Commercial Services DFS –Prevent erroneous AP setup –Loss of spectrum in Canada, possibly France