National Emergency Number Association
`The Voice of 9-1-1
`The Honorable Daniel R. Pearson, Chairman
`United States International Trade Commission
`500 E. Street, S.W.
`Washington, D.C. 20436
`Re. Certain Baseband Processor Chips and Chipsets, Transmitter and Receiver (Radio)
`Chips Power Control Chips, and Products Containing Same, Including Cellular
`Telephone Handsets, Inv. No. 337-TA-543.
`: ‘”
`Dear Chairman Pearson:
`The purpose of this letter is to express our concern about the remedy that has been
`proposed in the case above. Specifically, we have been informed that the remedy that the
`complainant requests would block the importation of CDMA chips and chipsets made by
`QUALCOMM that support “EV-DO” wireless broadband technology as well as the vast
`number of cell phones that contain these chips. While NENA offers no opinion on the
`merits of the underlying issues, I am concerned about the continued availability of this
`equipment in the United States because the organization I lead, the National Emergency
`Number Association (“NENA”), serves as one of the nation’s largest professional
`associations addressing emergency communications services.
`NENA is a not-for-profit professional organization dedicated to the enhancement of
`public safety communications. NENA is recognized by both Congress and the FCC as a
`leading authority on public safety telecommunications. Our members include police, fire,
`emergency medical response (“EMS”) personnel, and other public safety professionals
`who operate, manage, and design 9-1 -1 emergency call centers. Our members span fiom
`the first-line responders who answer and dispatch 9- 1 - 1 calls to the people who develop,
`implement, and supervise these 9- 1 - 1 services. Obviously, accurate communications is a
`key tool to public safety, particularly in a crisis management situation.
`A key aspect of our member’s work is receiving 9- 1 - 1 calls placed from cellular
`telephones, physically locating the caller, and timely dispatching the appropriate first
`response. Cell phones that are equipped with EV-DO chipsets offer several critical
`features that improve wireless 9- 1 - 1 performance and enhance the safety of the citizen
`using that cell phone.
`As you know, when a cellular subscriber dials “9- 1 - 1 ,” the Federal Communications
`Commission requires cellular operators to provide an estimate of the physical location of
`the caller to the local 9- 1-1 operator. Some of the biggest wireless operators in the United
`States use GPS technology on the cell phones to meet this requirement. Because EV-DO
`chipsets operate at a faster processing speed than previous technology, cell phones
`equipped with this technology can more accurately calculate a caller’s GPS position and
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`deliver a much more precise location to the 9-1-1 operator (e.g., up to 120 meter greater
`accuracy than other technologies). Such greater accuracy means, for example, being able
`to determine the building where the caller is located rather than just the street or block
`from which he is calling. Thus, in a fire, police, or EMS situation, when 9-1-1 calls are
`located with greater precision, NENA members can save more lives.
`In addition, EV-DO technology also eliminates a phenomenon known as “voice
`blanking” which sometimes occurs when the transmission of location coordinates from
`the cell phone to the public safety answering point disrupts the voice channel between the
`caller and the 9- 1 - 1 dispatcher, often by letting the caller hear nothing but silence from
`the 9- 1 - 1 operator while his cell phone’s position is transmitted to the authorities.
`Disruption of the voice channel during emergency situations is considered unacceptable,
`and the membership of NENA is pleased that the adoption of EV-DO cell phones is
`quickly eliminating voice blanking. A ban on EV-DO technology importation by the ITC
`would retard resolution of the “voice blanking” problem. On behalf of NENA, its
`members, and the public we serve, I strongly recommend that the parties be directed to
`find remedies in this matter short of outright ban of critical technology, through
`mediation if necessary.
`The public safety mission of NENA requires our members to share broadband
`communications between multiple public safety agencies in a mobile environment. Many
`of our members currently utilize EV-DO equipment to meet these requirements and plan
`to continue to do so. The capabilities provided by EV-DO would be difficult, time
`consuming and expensive (often in terms of tax dollars) for us to replicate. We hope that
`the ITC will not consider remedies that disrupt the availability of EV-DO equipment.
`From the perspective of first responders, a ban on the importation of this equipment
`would undoubtedly harm the public interest.
`Sincerely,
`Jason Barbour, ENP
`President
`CC: NENA Executive Board
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