10. E911 Capabilities

In its Response to the ALJ ruling DTS described its E911 architecture as very similar to that of a traditional local exchange carrier. However, traditional landline carriers are required to have an agreement or interconnection agreement with the State's two 911 network providers to provision the dedicated trunks to deliver 911 calls to each of the Pacific Bell Telephone d/b/a AT&T California (AT&T) 35 selective routers or Verizon's 11 selective routers serving the proposed territory. The agreements specify the provisioning of subscriber records to the 911 database and timeliness and process for subscriber record changes, etc. In addition, the 911 Office has statewide requirements/standards regarding the content and format of the 911 caller's information and service provider's class of service (technology), default trunking and 24/7 carrier support information. DTS' proposal to provide satellite service is an important detail that public safety answering points would use to evaluate the call and required response. This information would have to be shown in DTS' subscriber records.

Communication's Division staff contacted the 911 Office and there is no record of contact with representatives of DTS. The 911 Office has a policy memo that details the issues and procedures for delivering 911 calls and information. Therefore, prior to offering service to customers, DTS will need to File a Tier 1 Advice Letter with the Director of the Communications Division and provide:

1. A description of any third parties utilized to deliver 911 calls;

2. A description of the FCC's 911 requirements for satellite service providers and whether it is exempt or simply purchasing services and capacity from the satellite service provider; and

3. A letter from the 911 Office with approval of DTS' proposed delivery of 911 calls.

4. A letter from DTS attesting to its provisioning of 911 service to all of its customers.

In addition to providing intra- and interstate service, as an incumbent local exchange carrier DTS will also be obligated to provide international calling capability to its customers. Therefore, prior to offering service to customers DTS will file a Tier 1 Advice Letter with the Director of the Communications Division with copies of the pertinent approval and/or license certifying that it has obtained FCC approval for international Section 214 authority and a VSAT (very small aperture terminal) operator's license pursuant to C.F.R. Section 25.134.