NOTICES
PENNSYLVANIA PUBLIC UTILITY COMMISSION
Petition of Bell Atlantic-Pennsylvania, Inc. for a Declaratory Order Relating to Provision of Master Street Address Guides to Competitive Local Exchange Carriers; P-00971203; Joint Petition for Relief Establishing Uniformity for 9-1-1 Provisioning; M-00991217
[30 Pa.B. 2864] Public Meeting held
May 11, 2000Commissioners Present: John M. Quain, Chairperson; Robert K. Bloom, Vice Chairperson; Nora Mead Brownell; Aaron Wilson, Jr.; Terrance Fitzpatrick
Supplemental Final Order Before the Commission:
Before the Commission for consideration is the Consensus Report of the Stakeholder Working Group filed August 4, 1999, in compliance with the Commission's Secretarial Letter of June 23, 1999.1 As noted in the Secretarial Letter, the Commission previously approved a Settlement Agreement of All Parties and Joint Petition for Relief at Docket No. P-00971203, which resolved issues relating to Competitive Local Exchange Carrier (CLEC) access to the Master Street Address Guide (MSAG) maintained by the City of Philadelphia (City) for provisioning 9-1-1 service in the City. In taking this action, the Commission concomitantly undertook to establish Statewide 9-1-1 protocols based on the Philadelphia model, and established the Stakeholder Working Group (Working Group) to address on a generic basis issues relating to 9-1-1 provisioning across the Commonwealth.
In the Final Order entered June 16, 1999 at M-00991217, protocol guidelines were approved but the Working Group was expressly tasked to address the remaining issues:
1. Under what circumstances and conditions service providers (both CLECs and ILECs) should be permitted to modify and/or create derivatives of a municipality's MSAG (Protocol No. 5, Section e),
2. The potential for further defining those changes in a service provider's network properly classified as ''significant'' so as to trigger the requirement for a report to the involved municipality (Protocol No. 5, Section b), and
3. The possibility for additional procedures addressing service provider/municipality dispute resolution (Protocol No. 5, Section a).
This order will address the resolution of these issues and finalize these proceedings.
History of Proceedings By Opinion and Order entered July 14, 1997, the Commission granted a Petition for Issuance of a Declaratory Order filed May 16, 1997 by Bell Atlantic-Pennsylvania, Inc. (BA-PA). The effect of our July 14, 1997 Order was to permit BA-PA to provide MSAGs2 to interconnecting CLECs pursuant to interconnection agreements even though the affected public agency withheld its consent for BA-PA to provide a copy of the MSAG to a CLEC, PECO Hyperion Telecommunications (PHT), based on PHT's refusal to execute a letter of intent as required by the City.
The City appealed our July 14, 1997 Order to Commonwealth Court. The Court vacated the July 14, 1997 Order and remanded the case for further findings to determine whether the City's conditions were based upon legitimate public safety and welfare concerns.3
The proceedings on remand were assigned to Administrative Law Judge (ALJ) Marlene Chestnut as presiding officer. On April 13, 1998, a prehearing conference was scheduled. The City, the Commission's Law Bureau Prosecutory Staff (Prosecutory Staff), the Pennsylvania Telephone Association (PTA), Sprint Communication Company L.P. (Sprint), and PHT were participants.4 Also present at the Prehearing Conference was Herbert Nurick, Esquire, ADR Mediation Coordinator, Office of Administrative Law Judge. Herbert Nurick described the mediation process and all parties agreed to attempt to resolve the proceeding through mediation.
On August 14, 1998, the presiding ALJ was notified that a complete settlement of all issues had been achieved. A Mediation Report was submitted to ALJ Chestnut. Appended to the Mediation Report was a document titled ''Settlement Agreement of All Parties and Joint Petition for Relief.'' The PHT signed the Settlement Agreement of All Parties (Settlement Agreement), but did not sign the Joint Petition for Relief (Joint Petition), although the PHT indicated that it had no objection to the Joint Petition. After the filing of the Settlement Agreement and Joint Petition, statements in support thereof were filed by Prosecutory Staff; the City, and BA-PA.
By Recommended Decision issued September 1998, ALJ Chestnut recommended the adoption of the Settlement Agreement, including the Joint Petition. By Order entered February 17, 1999, we adopted the Recommended Decision of ALJ Chestnut which resolved litigation between the Commission and the City pertaining to the provision of MSAGs to Local Exchange Carriers (LECs).
The Settlement Agreement contained the terms for resolving the remanded proceedings. Essentially, the settlement provides that each service provider's 9-1-1 and E-9-1-1 tariff provisions will state that the service provider will comply with the City's 9-1-1 protocols as set forth in, and in the form of, certain attached exhibits pertaining to service provider E-9-1-1 Protocols, service provider E-9-1-1 Questionnaire, and testing procedures. (Exhibits A--C of the Settlement Agreement, respectively).
The Settlement Agreement further contained a list of tariff provisions pertaining to liability and indemnification, insurance, service interruptions, an agreement concerning the proper use of the City's MSAG, the computerized format of the MSAG, an agreement not to modify the content of the MSAG, and restrictions on the sale, lease, license, rental, loan, or transfer of the MSAG. The MSAG is released to the service provider within 48 hours of compliance with and satisfaction of the protocols and certification process. Finally, the City agreed to work with other municipalities to establish uniform Statewide standards for access to 9-1-1 systems; these standards will consist of the Protocols contained in Exhibits A--C.
We concluded that the Settlement Agreement was in the public interest based on the following considerations:
a. Promotion of public safety by making 9-1-1 systems more efficient;
b. Promotion of local exchange competition by enabling CLECs to have certainty as to terms and conditions of access to the City's 9-1-1 system;
c. Avoidance of significant time, expense and delay involved in full litigation of the matter;
d. Amicable resolution of divergent positions by 9-1-1 stakeholders and the City; and
e. Resolution of alleged conflicts between the Public Safety Emergency Telephone Act (35 P. S. §§ 7011--7021) (Act 78) and the Telecommunications Act of 1996 (47 U.S.C.A. §§ 160 et seq.) (TA 96) in a manner which harmonizes their provisions as applied to 9-1-1 service and regulation in Pennsylvania.
Included in the settlement document was a section entitled ''Joint Petition of Parties Seeking a Tentative Order or Rulemaking Establishing Uniformity for 9-1-1 Provisioning,'' which is the Joint Petition for Relief. The supporting reasons for adopting the Joint Petition were the same reasons as stated in support of the Settlement Agreement. ALJ Chestnut further explained this process as follows:
Essentially, the parties are requesting that the Commission issue a tentative order which incorporates the terms of the proposed settlement or, in the alternative, institute a rulemaking ''to accomplish the same.'' The reasons given in support of the Petition are the same five reasons in support of the proposed settlement and set out above.The petitioners note that Pennsylvania has 67 counties and 2,571 municipalities that have 9-1-1 service and that there are approximately 89 local exchange companies (certified ILECs and CLECs), with an additional 44 CLEC applications pending before the Commission. They claim that all of these entities will benefit ''from the adoption of uniform and reasonable conditions.'' I agree with this general statement.(R. D., p. 6).
ALJ Chestnut, therefore, recommended that the Joint Petition be approved. ALJ Chestnut was convinced that uniformity of conditions would benefit the public agencies and the service providers, and avoid uncertainty and litigation. In addition to recommending that we grant the Joint Petition, ALJ Chestnut further recommended the establishment of a working group of stakeholders to address the issue on a generic basis.
By our Order entered February 17, 1999, at Docket No. P-00971203, we also adopted the recommendation of the ALJ to grant the Joint Petition. We agreed that the parties had offered sufficient language on uniformity of 9-1-1 provisioning for inclusion in a tentative order to which comments could be offered. We also agreed with the ALJ recommendation that a working group of stakeholders should be established to address this issue on a generic basis. Therefore we agreed to issue a tentative order, in substantially the form suggested by the parties, and solicit comments thereon.
In a Tentative Order entered February 19, 1999 at M-00991217, we proposed, consistent with the terms of the Settlement Agreement and Joint Petition reached in the matter, to adopt certain tariff guidelines addressing municipal 9-1-1 systems, access to municipal 9-1-1 systems by competitive local exchange telecommunications carriers, and uniform Statewide protocols related to municipal 9-1-1 systems. The Tentative Order was published at 29 Pa.B. 1576 (March 20, 1999). The following parties filed comments to the Tentative Order: ALLTEL Pennsylvania, Inc. (ALLTEL), AT&T Communications of Pennsylvania, Inc. (AT&T) and the PTA. Reply Comments were received from the City.
Prior to the publication of the Tentative Order,5 the City filed a Petition for Clarification (Clarification Petition) at Docket No. P-00971203. The City requested clarification that the ''working group of stakeholders to be established will include all parties to the Settlement Agreement. . . .'' In the Clarification Petition, the City further expressed a concern that the purpose and scope of authority of the working group of stakeholders should be explicitly stated as ''implementation of the Settlement Agreement and Joint Petition, and shall not include development of procedures or protocols which are inconsistent with the Settlement Agreement and Joint Petition.''
On March 17, 1999, BA-PA filed an answer to the Clarification Petition responding that ''while BA-PA believes that the Commission's Order as presently written does stand for the proposition requested by the City, it does not object to such clarification.'' BA-PA agreed with the City's position that during several stages of litigating the instant controversy involving the MSAG, all interested parties had legal notice and an opportunity to participate. Thus, BA-PA concurred with the City that the results of the Settlement Agreement and Joint Petition should be binding on all service providers seeking 9-1-1 access in the City of Philadelphia and access to the MSAG for purposes of providing service in the City of Philadelphia.
On June 16, 1999, we issued a Final Order at M-00991217 to address comments to the Tentative Order and the Clarification Petition filed by the City. In this Final Order, we addressed the following issues raised by the commentators: liability and indemnity provisions, statement of insurance coverage, statement of policy and service interruptions, modifications and derivatives of the MSAG, ''Read Only'' format for MSAG, reporting of changes in management, dispute resolution procedures, notification to service providers of updates, notification of test cancellation and the City's request for clarification.
In regard to liability and indemnity provisions, insurance coverage and service interruptions, we declined to direct an amendment of the protocols. However, on the issue of permitting a modification or derivative of the MSAG, we noted that the City did not expressly foreclose the possibility that there may be conditions or circumstances warranting this action. As a result, we requested that the Working Group consider those circumstances and conditions under which the municipality would permit the modification and/or creation of a derivative of the MSAG. Similarly, on the issue of the appropriateness of a ''Read Only'' format for the MSAG, we declined to upset the status quo which permits the ILEC the ability to update the MSAG on an ongoing basis. However, we a gain instructed the Working Group to consider this issue.
With respect to the reporting of changes in management, we concluded that this reporting requirement is not unduly burdensome. However, we acknowledged that the types of changes in a service provider's network which are significant could be further developed. Consequently, we requested the Working Group to further refine those changes in the network, which would fall within the definition of ''significant.''
For dispute resolution procedures, we concluded that the Commission's Alternative Dispute Resolution Guidelines (52 Pa. Code § 69.395) provide a sufficient administrative forum for the prompt consideration of issues arising between the service provider and the municipality. Although the protocols contemplate that the municipality and the service provider will work together to resolve issues amicably, we acknowledged that this will not always be the case and the Working Group should consider additional procedures.
To enhance the public safety effectiveness of the MSAG, we agreed that the municipality should also provide notification to the service provider of any updates or revisions to the MSAG. Instead of requiring modification of protocols, we added an ordering paragraph that required the municipality to exercise a good faith obligation to notify the service provider of updates to the MSAG no less than quarterly.
We also adopted the same position on the issue of notification of test cancellation requiring that the municipality (PSAP) should exercise a good faith obligation to notify the service provider of cancellations (7 business days notice) for scheduled testing.
Finally, we granted the City's Clarification Petition finding, first, that the Settlement Agreement which was reached among the parties and approved by the Commission is binding upon the signatories. However, we held that even though the Working Group should respect the terms of the Settlement Agreement in fashioning any proposed recommendations to the Commission, issues pertaining to MSAG on a generic basis may involve broader concerns than those reflected in the Settlement Agreement.
Working Group Conclusions and Discussion On July 14, 1999, a meeting of the Stakeholder Working Group was held. The discussions and negotiations engaged in at that meeting resulted in the preparation of the Consensus Report.
The Working Group was comprised of BA-PA, the City, PTA, GTE and Prosecutory Staff. A consensus was reached on the issues of: 1) under what circumstances and conditions the host telephone company should be able to modify and/or create derivatives of the municipality's MSAG, 2) what is a ''significant'' change in a service provider's network for purposes of reporting such change to a county/municipality, and 3) an alternate expedited dispute resolution procedure.
According to the Consensus Report (page 5), the Working Group agreed to the following:
1) The host telephone company should, with the permission of the municipality/county, or at the request of the municipality/county, be able to modify the content of the MSAG;
2) That telephone companies/service providers should not be able to otherwise modify the content of the MSAG, but should be able to make formatting changes approved by the municipality/county that are necessary to enable the MSAG to conform to the telephone companies'/service providers' information systems;
3) That a content modification or formatting change does not include the use of the MSAG content in telephone companies service providers' operational support systems to validate customer information for input to the ALJ database.
This agreement is reflected in revised Protocol No. 5, Section e (Attached to the Consensus Report as Appendix A).
The Working Group submits that the revised protocol is in the public interest because it ''protects and promotes the municipality's/county's interest in ensuring the integrity of the MSAG, fosters efficient updating of MSAG information by the host telephone company, and allows telephone companies to use the MSAG for validation of customer information, database reconciliation, address verification for new service connections, and planning for service to new housing developments.'' Consensus Report, pages 5-6.
On the issue of notification of ''significant changes in the service provider's network,'' the Working Group first recognized that every conceivable significant change cannot be listed, but acknowledged that the clear intent to update the questionnaire is for major network changes. Therefore, footnote 4 to Protocol No. 5 Section (b)(2) (Appendix B to the Consensus Report) was modified to provide that significant changes in the service provider's network should reflect those physical or virtual changes which would cause the questionnaire to be non-representative of the current network architecture of the telephone company/service provider, for example, converting from MF to SS7 signaling, a new switching station, or a new 9-1-1 tandem.
Finally, the Working Group agreed to an alternative dispute resolution (ADR) procedure which is essentially the same as the consensus procedure in the Global collaborative held in late 1998 and early 1999,6 but modified to be pertinent to the MSAG and related issues (Appendix C to the Consensus Report).
Conclusion We agree with the rationale and recommendations provided by the Working Group. Accordingly, based on the consensus reached by the Working Group, we shall adopt revised Protocol No. 5, Section e, in the form set forth in Appendix A to the Consensus Report, the modified definition of significant changes for questionnaire update purposes as contained in Appendix B to the Consensus Report, and the ADR procedure for resolving MSAG related disputes as appears in Appendix C to the Consensus Report.
Our adoption of the Joint Petition provided for a Tentative Order which established tariff terms and conditions for connection by LECs to municipal/county 9-1-1 systems. The Tentative Order was published in the Pennsylvania Bulletin and served for comment upon all LECs, CLECs, counties, municipalities having their own 9-1-1 systems under Act 78, the Pennsylvania Emergency Management Association (PEMA), and other interested parties. The tariff requirements under our Final Order are hereby modified and will be imposed upon all existing and future telecommunications public utilities which request or require connection to county/municipal 9-1-1 systems.7 As expressly recognized by the parties in the adopted Joint Petition (pages 17-18), the Commission has jurisdiction and authority to grant the relief requested in the Joint Petition. The provision of and access to 9-1-1 service is a regulated and tariffed telecommunications service. As such, the Commission has the power and authority to determine the terms and conditions for providing this public utility service for both the service providers and customers. By including these conditions in tariffs of an LEC, formalization of telecommunication utility 9-1-1 obligations can be accomplished as part of a binding and enforceable tariff requirement.
Given that the protocols have been revised from the Final Order entered June 16, 1999, we shall provide additional notice of the conclusion of this proceeding and the changes that have been made to the protocols. Accordingly, we shall direct publication of this order and the revised protocols hereby adopted. The changes reflected in Appendices A and B to the Consensus Report have been incorporated in Protocol No. 5, Section (e) and (b)(2), respectively. The protocols, questionnaire and test procedures follow this order. Finally, the adopted ADR procedures will be referred to in Protocol No. 5 (a) and also follow this order;
Therefore,
It Is Ordered That:
1. Revised Protocol No. 5, Section e, in the form set forth in Appendix A to the Stakeholder Working Group Consensus Report, the modified definition of significant changes for questionnaire update purposes as contained in Appendix B to the Consensus Report, and the ADR procedure for resolving MSAG related disputes as appears in Appendix C to the Consensus Report are hereby adopted such that the applicable protocols, questionnaire and ADR procedure shall be as attached to this order.
2. The Secretary shall cause this Order and attachment to be published in the Pennsylvania Bulletin.
3. A copy of this Supplemental Final Order, together with the attachment, shall be served upon all certificated telecommunications public utilities, the Pennsylvania Emergency Management Agency, the Law Bureau Prosecutory Staff, the Office of Small Business Advocate, the Office of Consumer Advocate, Sprint Communications Company, L.P., and the Pennsylvania Telephone Association.
4. The Secretary shall mark these dockets closed.
JAMES J. MCNULTY,
Secretary
Appendix A
Service Provider E-9-1-1 Protocols
Required Process for Entities Seeking to Access
County E-9-1-1 SystemsThe following list of Protocols is set forth in the interest of public safety. All service providers, including LECs (Local Exchange Carriers), CLECs (Competitive Local Exchange Carriers) (facilities based and resellers), and any other certified telecommunications public utility which has or requires connection to the county/municipal 9-1-1 system or connection to the serving selective router, must comply with the following procedures to gain access to the county's/municipality's E-9-1-1 system.
(1) At least 30 days prior to any service provider testing for compatibility with the county's/municipality's E-9-1-1 system, all service providers must provide written notice to:
9-1-1 Coordinator
County of ______ /City of
_________________ , PA(2) Once written notice is received, the 9-1-1 Coordinator will send a standard E-9-1-1 Questionnaire, a standard test format, and a list of surcharge guidelines for the Public Safety Emergency Telephone Act (35 P. S. §§ 7011--7021) and 16 Pa. Code § 36a.101--36a.112 (reserved and renumbered as 4 Pa. Code §§ 120b.101--120b.112) (collectively, Act 78). The cover letter from the Communications Director/9-1-1 Coordinator which accompanies this material may also contain a request for current financial statements of the CLEC/PCS provider.
(3) Testing of the service provider's connection into the county's/municipality's E-9-1-1 system will be arranged upon receipt by the 9-1-1 Coordinator of satisfactory written responses to the E-9-1-1 Questionnaire.
(4) Once satisfactory answers to the E-9-1-1 Questionnaire have been completed, a Public Safety Answering Point (PSAP) representative will contact the service provider within 10 business days. All testing is done according to PSAP conditions. These conditions change from day to day and hour to hour, therefore all testing is subject to cancellation without prior notice to the service provider. Any testing canceled by the county/municipality will be rescheduled at the earliest available date. Service provider must provide at least 7 business days prior notice to the PSAP representative upon any cancellation of testing by a service provider, or upon any request for additional testing.
(5) The following shall govern release of the MSAG and certification for connection to the county's/municipality's 911 system:
Conditions
a. Each PUC-regulated service provider's 9-1-18 tariff provisions shall state that the service provider will comply with the county/municipal9 9-1-1 Protocols.10 Future revisions or additions to the form and content of the Protocols by a county/municipality will be provided to PEMA as part of the county's/municipality's 9-1-1 Plan which is submitted to the Pennsylvania Emergency Management Agency (PEMA) for approval, and will be served by facsimile, by overnight mail or hand-delivery, and by a confirmation copy by United States Mail, on each service provider prior to implementation. Within 10 business days of confirmed receipt, each service provider will respond with comments on the proposed revisions or additions. If any service provider does not respond to the proposed revisions or additions within the 10 business days, that service provider will be deemed to have agreed to the proposed revisions or additions. If a service provider submits comments stating it does not agree with the proposed revisions or additions, it must set forth its reasons in its comments and the county/municipality will not implement the revisions or additions against the objecting party until the matter is resolved. The county/municipality and the service provider will work together to resolve the issues in a mutually agreeable manner. To the extent this manner of resolving issues is not successful, the county/municipality and service provider agree to the abbreviated dispute resolution process for disputes involving the Master Street Address Guide attached to the Consensus Report as Appendix C.
b. Each service provider shall update the service provider questionnaire triennially to include any changes to its previously submitted questionnaire or to confirm the absence of any changes in conjunction with review of the county's/municipality's 9-1-1 Plan by PEMA under Act 78 or its successor. The county/municipality will notify the service provider when this update is required for the triennial review. Additionally, each service provider agrees to provide the county/municipality with an updated questionnaire upon:
1) A change of ownership of the service provider;
2) A significant change in the service provider's network;11
3) A change of the service provider's 9-1-1 manager/supervisor or primary contact; or,
4) A change in the service provider's administrative charge for the billing system.
When a service provider has changes in items 6D, 7A3, 10B or 21C of the Questionnaire, the service provider shall provide such updated information to the county/municipality no less than quarterly.
c. Each service provider's tariff shall fully state its liability and indemnification provisions relative to 9-1-1 service. To the extent that the service provider is relying on the general tariff indemnification and liability provisions as covering 9-1-1 service, the 91-1 section of the tariff shall cross-reference the applicable general tariff indemnification or liability sections.
d. Each service provider's tariff shall fully state its insurance provisions, or those which obviate the need for insurance in whole or in part, relative to 9-1-1 service. To the extent that the service provider is relying on the general tariff provisions as covering insurance or obviating the need in whole or in part for insurance for 9-1-1 service, the 9-1-1 section of the tariff shall cross-reference the applicable general tariff sections.
e. Each service provider's 9-1-1 tariff provisions will state:
1) The following definitions:
Host telephone company: The service provider, which is also the telecommunications public utility that provides 9-1-1 service to the county/municipality, and that houses the Automatic Location Identification (ALI)/MSAG data used for providing 9-1-1 service.
Telephone company: A telecommunications public utility regulated by the Pennsylvania Public Utility Commission and which has or requests access to the county/municipal 9-1-1 system or connection to the serving selective router, including, but not limited to, local exchange carriers and competitive local exchange carriers. This term is synonymous with ''service provider.''
Content: The data elements of the MSAG including (but not necessarily limited to) the data elements that are entered into the following fields A-I of a standard MSAG record:
A Tax area record
B Locality
C Street
D Thoroughfare
E Directional [where required]
F Even (E), odd (O), or all (A) [applied to house numbers]
G Low-high range of house numbers
H PSAP (Public Safety Answering Point)
I LAT/LONG (Latitude/Longitude) [where required];
Formatting, Format: Shall include changes to the identity of fields, order of fields, and number and arrangement of data elements in each field, and a telephone company's rearrangement or regrouping of such data, without changing the MSAG content, for purposes of validating against MSAG records;
2) How the service provider will handle 9-1-1 service interruptions;
3) That the service provider agrees not to use the county's/municipality's MSAG for any purpose that is not directly related to and required for the provision of 9-1-1 service to its customers;
4) That the Host Telephone Company will install the county's/municipality's MSAG in read/write format and will not modify the content of the MSAG unless requested or permitted to do so by the county/municipality. A request to modify content by the Host Telephone Company shall be responded to by the county/municipality within 10 business days or the request is deemed to be approved. The request shall be in writing and shall set forth in reasonable detail the proposed modification and all reasons in support. The request shall be granted provided the modification is necessary for the Host Telephone Company's provision, maintenance, or upgrading of 9-1-1 service;
5) That a telephone company shall not otherwise modify the content of the MSAG, but may make formatting changes approved by the county/municipality necessary to enable the MSAG to conform to the telephone company's information systems. The request shall be in writing and shall set forth in reasonable detail the formatting changes and all reasons in support. The county/municipality shall respond to the request within 10 business days or the request is deemed to be approved. The request shall be granted provided the formatting change does not impair the integrity and accuracy of the MSAG database.
For purposes of this Section e., a content modification or formatting change does not include the use of the MSAG content in telephone companies' operational support systems to validate customer information for input to the /ALI database;
6) That the service provider will not sell, lease, license, rent, loan or provide, or transfer the county's/municipality's MSAG to any other persons, or entities without the express written authorization of the county's/municipality's 9-1-1 coordinator, or his/her designee; and
7) That a telephone company may not, without the written consent of the county/municipality, modify or create any derivative of the county's/municipality's MSAG, except as follows: one mirror image copy of the MSAG may be made in electronic form for archival purposes (the copy may be made in read/write format by the host telephone company, but shall be made solely in read-only format by all other telephone companies), and the telephone company may make a mirror image copy, solely in read-only format and only for database reconciliation, address verification for new connections of service, and other functions that are necessary to ensure that the name and address information provided by the service provider to the county/municipality is accurate and conforms to the county's/municipality's MSAG format.
Procedure for MSAG Release
f. The county's/municipality's 9-1-1 Coordinator shall notify the provider that actually renders 9-1-1 service (for example, BA-PA in Philadelphia) in writing (by facsimile followed by the mailed original) within 48 hours of a service provider's compliance with, and satisfaction of, the standard Protocols and certification process and upon such notification the provider of 9-1-1 service may release the MSAG to the compliant and certified service provider.
Miscellaneous
g. To promote uniformity and certainty, the standard protocols and questionnaires shall be the same for each county/municipality, but tests may be different due to system configuration in each county/municipality.
h. The certification process envisioned by the Protocols will allow each county/municipality to address its public safety concerns and will provide that the City and each county/municipality will authorize release of the MSAG, as amended from time to time, if the service provider complies with the county's/municipality's certification process. Certification will be evidenced by formal written documentation from the county/municipal 9-1-1 Coordinator to the service provider in compliance with the Protocols. The certification process will require that the county/municipality recertify the service providers on a triennial basis and will provide that the county's/municipality's authorization for use of the MSAG will be rescinded if it fails to become recertified until such time as the county/municipality determines that the service provider has complied with the recertification requirements. Recertification shall mean updating the questionnaire and retesting shall not be necessary unless there is a significant change in the network, such as the addition of a switch or going from MF to SS7 signaling. The county/municipality will be responsible for providing to service providers all forms for certification and any updates.
i. 9-1-1 service shall be provided in accordance with the service provider's applicable tariff.12 Trunking charges are to be governed by service provider tariffs.
j. The county's/municipality's 9-1-1 Plan shall amend its 9-1-1 plan with PEMA to conform to these Protocols and shall rescind any contrary or additional regulations, ordinances, resolutions or other requirements for Pa. PUC-regulated telephone service provider access to the county's/municipality's 9-1-1 System so long as any Pa. PUC or PEMA order or determination approving the Protocols is of legal effect.
k. All consents, approvals and responses referenced under these Protocols shall not be unreasonably delayed or withheld.
l. All notifications under these Protocols shall be in writing and transmitted by facsimile (on the day the notice is issued) and by overnight mail or hand delivery.
Appendix B
Service Provider E-9-1-1 Questionnaire Each service provider shall update the service provider questionnaire triennially to include any changes to its previously submitted questionnaire, or to confirm the absence of any changes in conjunction with review of the county's municipality's 9-1-1 Plan by the Pennsylvania Emergency Management Agency under Act 78 or its successor. The county/municipality will notify the service provider when this update is required for the triennial review. Additionally, each service provider agrees to provide the county/municipality13 with an updated questionnaire upon a) a change of ownership of the service provider; b) a significant change in the service provider's network; c) a change of the service provider's 9-1-1 manager/supervisor or primary contact; or, d) a change in the service provider's administrative charge for the billing system.
When a service provider has changes in items 6D, 7A3, 10B or 21C of the questionnaire, the service provider shall provide such updated information to the county/municipality no less than quarterly.
1. What is the design of the company's network? __________
A. Provide a network schematic including the connection to the 911 network. Include Circuit IDs. __________
2. How will the company's network be interfaced to 911? __________
A. How many end trunks will be used? __________
1. The company will be expected to comply with trunking as per Act 78. __________
2. The company will be expected to maintain at least a P.01 grade of service. __________
B. Will these trunks be diversely routed? __________
C. When will the trunks be installed? __________
3. Outline the network test plan that will be used by your company to test the 911 interface. __________
A. When is testing scheduled to begin? __________
B. Who will be in charge of testing? Name/address/phone number __________
C. It will be required for the county/municipality to be contacted prior to the state of testing. __________
4. Who is expected to pay for 911 connection (end office trunks)? __________
A. Identify all costs to the county/municipality. __________
5. How often will the company provide traffic studies (CCS counts) on the end office trunks? __________
A. Can your company continuously monitor CCS counts on the end office trunks? __________
B. Does the company plan to do this? __________
1. Will it make the necessary adjustments in trunking automatically so as to conform to Act 78 trunking standards? __________
6. Is the company's network continuously moni- tored? __________
A. Provide a 24x7 number for the monitoring center.
__________B. Where is the center located? __________
C. What monitoring capabilities does this center have? __________
1. Will the end office trunks be monitored/alarmed? __________
D. Who is the center's manager? __________
1. Provide name/address/phone number for the manager. __________
2. Provide name/address/phone number for the manager's supervisor. __________
7. Provide a trouble reporting procedure. __________
A. Is there a dedicated trouble reporting center? __________
1. What is the location of this center? __________
2. Provide a 24x7 number for trouble reporting. __________
3. Who is the center's manager? __________
a. Name/address/phone number of manager? __________
b. Can the manager be reached 24x7? How? __________
8. Provide a trouble escalation procedure. __________
9. Since it will often be impossible for the county/municipality to determine the origin of the trouble, will the company accept trouble reports from the host phone company? __________
10. Will the company manage it's own ALI data? __________
A. How will the transfer of data from the service provider to the host telco be accomplished? __________
B. Who is the county's/municipality's contact, from the company, for database additions/deletions/correction? __________
1. Provide contacts name/address/phone number. __________
2. Is there a 24x7 number for database work? __________
3. Provide the name/address/phone number of the contact's supervisor. __________
C. How will the company ensure the accuracy of the ALI data? __________
D. Who will deliver ALI record to PSAP? __________
E. Does the company's ALI data meet NENA standards as far as format? __________
11. Will database additions/deletions/corrections be accepted from the county/municipality on the current database correction form? __________
A. How are database correction forms to be sent to the company's database contact? __________
1. Mail? __________
2. Fax? __________
B. Does the company have a 9-1-1 Data Control center? __________
12. How long will database correction take? __________
A. Will there be a verification process in place to ensure the accuracy of corrections? __________
13. Provide a database escalation procedure. __________
14. When does the company believe it will begin offering service to customers in the county/municipality? __________
A. Business? __________
B. Residential? __________
15. Are there particular areas of the county/municipality in which the company is targeting serv- ice? __________
A. Provide a list of these areas. __________
B. Indicate when the company anticipates providing service in each area. __________
16. Will the company be utilizing unique NXXs? __________
A. What are the NXXs? __________
B. What wire center is each NXX assigned to? __________
C. The company will be expected to continually update the City whenever new NXXs are assigned. __________
17. Will the company be offering number portabili- ty? __________
A. Will there be portability between local exchange carriers? __________
B. Will there be portability between wire center? __________
18. How will the company provide operator serv- ices? __________
19. How will operator services be interfaced to 911? __________
A. How will ALI identify operator assisted calls? __________
20. How will operator services identify which PSAP an emergency call should go to? __________
A. Mailing address v. Municipality v. Exchange? __________
B. What database information will operator services have available to them? __________
C. What other tools will operator services have to help them? __________
D. Can a call be transferred to another 911 center and a seven digit number? __________
21. Provide a 24x7 phone number for ALI lookup (i.e. local law enforcement needs, search warrants, trace & traps, etc.). __________
A. Where is the department located? __________
B. What information/databases does company security have access to? __________
C. Provide the name/address/phone number for the manager. __________
22. Provide a 24x7 phone number to be used for purposes of abandoned or 911 hangups. Failure to do so delays the ability of the PSAP to deliver public safety services. __________
23. Will there be a charge for establishing the 911 billing system? __________
24. The County's line contribution rate of /line/month is to be collected by your company and remitted to the county/municipality on a monthly basis. The remittance check should be made payable to: __________
The attached remittance form shall accompany the check. __________
25. What is the company's administrative charge for the billing system? __________
26. What is the company's position with respect to: __________
A. Uncollectables? __________
B. Refusals to pay? __________
27. When the Line Contribution Rate revenue is remanded to the county/municipality, how will charges, uncollectables be detailed? _________________
A. Will the company provide this information in the same format from which it is received from the host telco today? __________
28. Who will handle the billing for the company? __________
A. Provide the name/address/phone number of the billing contact. __________
B. Provide the name/address/phone number of the billing contact's supervisor. __________
29. Will the company have a group or individual dedicated to 911 service? __________
A. Provide the name/address/phone number for the 911 service manager. __________
B. Provide the name/address/phone number for the 911 service manager's supervisor. __________
30. Who is the company's single point of contact for the County's 911 coordinator? __________
A. Provide name/address/phone number. __________
B. Can contact be reached at all times (24x7)? __________
C. Provide name/address/phone number for this contact's supervisor. __________
31. Will the company be providing any of the following services? __________
A. Coin phones or COCOTS? __________
B. Foreign Exchange (FX) lines? __________
C. Long Distance? __________
D. Cellular of PCS? __________
1. Will the company conform to project 31 stand- ards? __________
E. Paging? __________
32. How will the company handle all trunks busy? __________
A. Provide the text (bilingual) of the company's standard announcement when all lines are busy. Unless the company only uses a busy signal, the county/municipality must approve the text. __________
B. Will the message have a background busy sig- nal? __________
C. Will the message be TDD/TTY compliant? __________
By signing below, I represent and warrant that the foregoing information is true and correct to the best of my knowledge, information and belief.
Name: __________
Title: __________
Service Provider: __________
Date: __________
Appendix C SAMPLE--will be modified to reflect configuration of other county 9-1-1 systems
City of Philadelphia
TEST PROCEDURES PHILA E-911 ALL CALLTAKERS DURING EACH TEST CALL MUST STATE THE FOLLOWING TO THE PHILA E-911 CALLTAKERS.
THIS IS A TEST CALL FROM
DIAL TONE PROVIDER
(COMPANY NAME)
TEST PLAN CHECK TRANSMIT AND RECEIVE LEVELS DURING ALL CALLS.
TEST 1
IN SWITCH UNDER TEST, MAKE BUSY TRUNK #2 (LOCUST) OF THE DEFAULT TRUNK GROUP. PLACE A 9-1-1 CALL FROM YOUR SEVEN DIGIT NUMBER. TEST EACH TRUNK IN GROUP 1.
EXPECTED RESULT
CALLS SHOULD COMPLETE TO THE PSAP, OPERATOR RECEIVES PROPER ANI AND ALI DATA VIA MARKET TANDEM.
TEST 2
DURING CALL IN PROGRESS, REQUEST PSAP OPERATOR TO EFFECT CALL-TRANSFER TO THE PSAP SUPERVISOR.
EXPECTED RESULT
VERIFY PSAP SUPERVISOR RECEIVES CALL WITH PROPER ANI AND ALI.
TEST 3
IN THE SWITCH UNDER TEST, (LOCUST) RESTORE TO SERVICE TRUNK #2 AND MAKE BUSY TRUNK #1 (MARKET) OF THE DEFAULT TRUNK GROUP. PLACE A CALL FROM YOUR SEVEN DIGIT NUMBER. TO EACH TRUNK.
EXPECTED RESULT
CALL COMPLETES TO PSAP, OPERATOR RECEIVES PROPER ANI AND ALI DATA VIA LOCUST TANDEM.
TEST 4
DURING CALL IN PROGRESS, REQUEST PSAP OPERATOR TO EFFECT CALL TRANSFER TO THE OPERATIONS DESK.
EXPECTED RESULT
CALL COMPLETES TO OPERATIONS DESK, NO ANI OR ALI IS EXPECTED.
TEST 4A
MAKE BUSY TRUNK GROUPS 1 AND 2 AND PLACE TEST CALL TO PSAP OPERATOR.
EXPECTED RESULTS
RECEIVES RECORDED MESSAGE ALL LINES BUSY FROM (COMPANY PROVIDING DIAL TONE)
TEST 4B
BELL ATLANTIC BUSY OUT MARKET PSAP TRUNKS. PLACE CALL FROM SWITCH UNDER TEST TO MARKET TANDEM.
EXPECTED RESULTS
TESTING OF INTER-TANDEM TRUNKING AND RECEIVING CALL. ANI/ALI INFORMATION.
TEST 5
IN SWITCH UNDER TEST, MAKE BUSY TRUNK 2 OF THE SOUTH DIVISION TRUNK GROUP. PLACE A CALL FROM YOUR SEVEN DIGIT NUMBER.
EXPECTED RESULT
CALL COMPLETES TO THE SOUTH DIVISION, OPERATOR RECEIVES PROPER ANI AND ALI DATA VIA MARKET TANDEM.
TEST 6
DURING CALL IN PROGRESS, REQUEST PSAP OPERATOR TO EFFECT CALL TRANSFER TO FIRE/EMS.
EXPECTED RESULT
CALL COMPLETES TO FIRE/EMS, NO ALI OR ANI IS EXPECTED.
TEST 7
IN THE SWITCH UNDER TEST, RESTORE TO SERVICE ALL 911 TRUNKS. PLACE A 911 CALL FROM YOUR SEVEN DIGIT NUMBER.
EXPECTED RESULT
CALL COMPLETES TO PSAP, OPERATOR RECEIVES ANI WITH NOT IN DATABASE INDICATION.
TEST 8
SIMULATE AN ANI FAILURE BY OUTPULSING THE 911 DIGITS ON THE TEST TRUNK.
TEST 9
PLACE A 911 CALL USING THE TEST SET OVER TRUNK #1 OF DEFAULT TRUNK GROUP TO MARKET TANDEM.
EXPECTED RESULT
CALL COMPLETES TO PSAP WITH 911 DIGITS AND ESCO CODE.
TEST 10
PLACE AT LEAST 3 SIMULTANEOUS CALLS FROM THREE SEVEN DIGIT NUMBERS.
EXPECTED RESULT
ALL 3 CALLS SHOULD GO TO THE PSAP.
TEST 11
HAVE PSAP OPERATOR PERFORM A FORCED DISCONNECT ON ONE LINE. HAVE A SECOND CALL TRANSFERRED TO FIRE BOARD.
EXPECTED RESULT
1ST CALL IS DISCONNECTED FROM PSAP.
2ND CALL SHOULD TRANSFER TO FIRE BOARD WITH NO ANI/ALI EXPECTED.TEST 12
HAVE A PSAP SUPERVISOR RE-DIAL ANY SEVEN DIGIT NUMBER THAT WAS PERFORMED IN TEST 12.
EXPECTED RESULT
PSAP SUPERVISOR REESTABLISHES CALL TO THE SAME NUMBER.
TEST 13
PLACE A TEST CALL TO PUBLIC OPERATOR FROM THE SWITCH UNDER TEST AND HAVE CALL RE-ROUTED TO PSAP OPERATOR.
EXPECTED RESULT
CALL RECEIVING WITH OPERATOR ON THE LINE AND ANI/ALI INFORMATION THAT DENOTES OPERATOR ASSISTED CALL.
END OF PHILA E-9-1-1 TEST
Abbreviated Dispute Resolution Process for Disputes Involving the Master Street Address Guide 1. The Abbreviated Dispute Resolution Process described below will be limited to disputes which involve action or inaction of a telecommunications entity and a county/municipality which allegedly affects the use, release, modification, or application of the Master Street Address Guide (MSAG) or tariff provisions pertaining to the MSAG. Before such a petition is referred to the Abbreviated Dispute Resolution Process, as part of the petition the petitioning party must provide detailed evidence that it has engaged in good faith negotiations with the answering party with respect to the dispute in question for at least 30 days.
2. A party directly involved in a dispute as defined in paragraph 1 (Party or Parties) which cannot be resolved through good faith negotiations may file a Petition for Resolution of Disputed Issues (Dispute Resolution Petition) with the Commission. If possible, such petitions should be submitted jointly, by both parties. The Petition shall be served on the opposing party if not joint, the Consumer Advocate, the Small Business Advocate, and the Commission's Office of Trial Staff (Public Advocates).
3. Any Party filing a Dispute Resolution Petition may also request an interim ruling on whether the party is entitled to relief pending the resolution of the merits of the dispute. The purpose of this procedure is to provide an interim remedy when the dispute compromises the ability of a party to provide uninterrupted service, unreasonably precludes the provisioning of scheduled service, contains allegations that a proposed tariff involves predatory pricing, or involves collocation space limitation.
a. Any requests for an interim ruling shall be filed at the same time and in the same document as the Dispute Resolution Petition. A Dispute Resolution Petition that includes a request for interim relief need not allege that the petitioning party has engaged in good faith negotiations for at least 30 days; provided, however, that petitions that omit allegations of 30 days of good faith negotiations under this subparagraph shall be dismissed without prejudice if the request for interim relief is denied. The petitioning party shall give 24 hours notice to its opposing party prior to filing a request for interim relief.
b. A Dispute Resolution Petition that includes a request for an interim ruling shall include the phrase ''Request for Interim Ruling'' in the heading and shall clearly identify and set forth the specific grounds supporting the request for interim relief pending the resolution of the dispute, including a statement of the potential harm that may result if interim relief is not provided. A Dispute Resolution Petition that includes a request for interim ruling shall be verified by affidavit and served by hand-delivery, or by facsimile with telephonic confirmation of receipt, on the same day as the pleading is filed with the Commission. The certificate of service filed with the Dispute Resolution Petition shall state how the petitioning party has complied with this service requirement.
c. Within three business days of the filing and service of a Dispute Resolution Petition that includes a request for interim ruling, the Arbitrator assigned to the dispute under the Abbreviated Dispute Resolution Process shall conduct a hearing to determine whether interim relief should be granted during the Abbreviated Dispute Resolution Process. The Arbitrator will notify the parties of the date and time of the hearing by facsimile within 24 hours of the filing of a complaint and request for interim ruling. The Parties should be prepared to present their positions and evidence on factors including, but not limited to, the type of service requested, the economic and technical feasibility of providing that service, and the potential harm that may result if interim relief is not provided. The Arbitrator will issue an interim ruling on the request based on the evidence provided at the hearing within 24 hours of the close of the hearing and will notify the parties by facsimile of the ruling. In reaching a decision on interim relief, the Arbitrator may base his or her decision on whether the party has provided ample information to allow a full evaluation of the merits of the case. The petitioning party carries the burden of proof. The interim ruling will be effective throughout the dispute resolution proceeding until a final decision is issued under the Abbreviated Dispute Resolution Process. If the request for interim ruling is denied and the Dispute Resolution Petition contains the detailed evidence of 30 days of good faith negotiations as described in paragraph 1, above, the dispute resolution proceeding shall proceed under the procedures set forth herein. If the request for interim ruling is denied and the Dispute Resolution Petition does not contain such evidence, the petition shall be dismissed without prejudice and refiled only after a 30 day negotiation period.
4. The Parties will be the primary participants in the Abbreviated Dispute Resolution Process. The Public Advocates may participate in the proceeding but may not conduct formal discovery and are precluded from opposing the voluntary withdrawal of a Dispute Resolution Petition due to consummation of a settlement between the Parties. Each Dispute Resolution Petition will be assigned a separate docket number by the Commission's Secretary.
5. All Dispute Resolution Petitions will be assigned by the Commission to principal Arbitrator(s) with subject matter expertise, designated as having continuing jurisdiction to resolve the above referenced disputes.
6. The Parties shall submit a joint filing, if possible, within 5 business days of the filing of a Dispute Resolution Petition which clearly and concisely sets forth the dispute between the parties and includes as an attachment all relevant documentation material to resolution of the dispute. The filings will be served on the Public Advocates and on the opposing party if not joint.
7. Within 14 days of the filing of a Dispute Resolution Petition, a conference will be scheduled and held among the Parties, the participating Public Advocates and the Arbitrator.
8. At the conference, which will not be conducted as an evidentiary hearing, the Interconnecting Parties shall and the participating Public Advocates may informally present their positions to the Arbitrator and, with the assistance of the Arbitrator, shall attempt to resolve their differences. The conference will be open to the public, shall be transcribed and subject to the traditional proprietary safeguards.
9. Neither the conference nor the remainder of the informal phase of the administration of a Dispute Resolution Petition shall be subject to the ex parte prohibition to the extent the Arbitrator conducts discussions with each party alone to facilitate settlement.
10. If differences remain at the close of the conference, the Arbitrator may issue an informal decision from the bench which resolves the dispute. If the Arbitrator determines not to issue an informal bench decision, the Arbitrator will issue an informal decision resolving the dispute within 5 business days of the conference. In either case, the Arbitrator's informal decision will be filed in the document file.
11. There will be a 5 business day appeal period to the Commission following issuance of the Arbitrator's informal decision. If no party or Public Advocate files an appeal within that time, the informal decision will become a final Commission order as evidenced by a Secretarial letter.
12. If a matter is settled by the Parties at any point in the informal proceedings described above, including during the 5-day appeal period, the Parties will have the choice of filing the settlement with the Commission for approval or withdrawing the Dispute Resolution Petition. This provision shall supersede the provisions of 52 Pa. Code §§ 5.94 and 1.82.
13. If the Parties choose to seek Commission approval of a settlement agreement, the Parties will file a joint petition for adoption of the settlement agreement with the Commission. The Public Advocates and any certificated LEC may file a response to the joint petition within 10 days. The Arbitrator will issue an Initial Decision addressing the settlement petition within 15 days of the filing of the petition.
14. Interested parties may file exceptions to the Initial Decision within 7 business days of issuance. If no timely exceptions are filed and if two Commissioners do not ''call up'' the matter within 5 days of issuance, the Initial Decision will become a final order by operation of law. If timely exceptions are filed, the matter will be assigned to the Office of Special Assistants for preparation of a recommendation for Commission consideration at the earliest possible Public Meeting.
15. The filing of an appeal to an informal decision issued under paragraph 11 above will commence de novo review of a Dispute Resolution Petition. If the Office of Administrative Law Judge finds it to be appropriate in a given case, the appeal will be assigned to the same ALJ who rendered the informal decision.
16. The filing of an appeal shall not automatically stay the Arbitrator's informal decision. Any party to the proceeding may file a motion for stay of the informal decision with the ALJ. Only if the motion is approved will the informal decision be stayed during the pendency of the appeal.
17. Upon the filing of an appeal, interested parties other than the Parties may intervene, in the case of the Public Advocates, or seek intervention, in the case of other parties, in the proceedings.
18. De novo review shall consist of the conduct of an evidentiary hearing on the dispute. The presiding ALJ will conduct a hearing and issue an Initial Decision resolving the dispute within 30 days of the filing of the appeal unless the ALJ extends the time frame for good cause shown recognizing an expeditious result is in the public's interest.
19. Participating parties may file exceptions to the Initial Decision of the ALJ within 7 business days of issuance. Reply exceptions must be filed within 5 business days after exceptions are filed.
20. If no exceptions are filed and if two Commissioners do not ''call up'' the matter within 10 days of issuance, the Initial Decision of the ALJ will become a final order by operation of law on the 10th day after its issuance.
21. If exceptions are filed, the matter will be assigned to the Office of Special Assistants for preparation of a recommendation for Commission consideration at the earliest possible Public Meeting.
22. With the exception of 52 Pa. Code §§ 5.94 and 1.82, this dispute resolution process is not intended to replace or preclude any other remedies or procedures otherwise available to any of the parties, and a party's participation in this dispute resolution process shall not be considered a waiver of any available substantive or procedural rights. However, the parties to the above proceeding each agree that no party will raise issues pertaining to the legal adequacy of the Abbreviated Dispute Resolution Process either before the Commission or before any court of law or equity.
23. After these procedures have been in effect for a period of 1 year, any party to this proceeding may petition the Commission to re-examine and/or revise any of these procedures.
[Pa.B. Doc. No. 00-969. Filed for public inspection June 2, 2000, 9:00 a.m.] _______
1 The Commission's Secretarial Letter required that the report be submitted to the Commission for consideration on or before August 2, 1999. An extension of the August 2, 1999 deadline was extended to the Stakeholder Working Group so as to enable the parties to reach final consensus on all issues.
2 MSAGs are used in the provision of Enhanced 9-1-1 service (E-9-1-1). MSAGs include the listing of all street names, house/building numbers and address ranges in the 9-1-1 service area as well as routing information to the Public Safety Answering Point (PSAP) locations and the appropriate emergency service providers. The MSAGs were compiled and are maintained by the municipality, and are used for the automatic location identification (ALl) function, which is a component of the E-9-1-1 service purchased by the municipality from BA-PA.
3 City of Philadelphia v. Pennsylvania Public Utility Commission, 702 A.2d 1139 (Pa. Cmwlth. 1997)
4 ALJ Chestnut granted separate Petitions to Intervene by PTA and Sprint.
5 March 4, 1999.
6 See Joint Petition of Nextlink Pennsylvania, Inc., et al. and Joint Petition of Bell Atlantic-Pennsylvania, Inc. et al., Docket Nos. P-00991648 and P-00991649, Opinion and Order entered September 30, 1999.
7 More specifically, this tariff requirement will be imposed upon service providers by the Commission contingent upon the counties/municipalities reciprocating as stated in paragraph 5 of the Joint Petition, by amending their 9-1-1 plans with PEMA.
8 References to 9-1-1 in this Settlement Agreement shall include all 9-1-1 services provided by telecommunications providers including E-9-1-1 services.
9 References to county/municipality means the entity that is responsible for the 9-1-1 plan under Act 78. Thus, notices or updates need only be provided to such entity as opposed to all municipalities that may be covered by a county-wide 9-1-1 plan.
10 The service provider E-9-1-1 Protocols, questionnaire, and testing procedures are hereinafter collectively referred to as the ''Protocols.''
11 ''Significant changes in the service provider's network'' for purposes of updating the questionnaire previously supplied to the county/municipality shall mean those physical or virtual changes which would cause the questionnaire to be non-representative of the current network architecture of the telephone company/service provider. Examples of these would include converting from MF to SS7 signaling, a new switching station, or a new 9-1-1 tandem. The Working Group stresses that, particularly in this day of rapid equipment changes in the telecommunications industry, that every conceivable significant change cannot be listed but the clear intent and obligation to update should be for those major network changes.
12 ''The General Assembly declares it to be in the public interest to provide a toll-free number 911 for any individual within this Commonwealth to gain rapid, direct access to emergency aid.'' The Preamble to Act 78 (Public Safety Emergency Telephone Act (35 P. S. §§ 7011--7021)).
13 County/municipality as used herein is intended to designate the entity that files a 9-1-1 plan with PEMA. Thus, a service provider's obligation to update information is limited to such entity as opposed to the multitude of municipalities that may be covered by a county-wide 9-1-1 plan.
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