FEDERAL COMMUNICATIONS COMMISSION 
Washington, DC 20554 
DA 03-1868 
May 30, 2003 
Mr. Robert L. Pettit 
Wiley Rein & Fielding LLP 
1776 K Street, N.W. 
Washington, D.C. 20006 
Dear Mr. Pettit: 
This letter responds to your letter on behalf of Nokia Inc. (Nokia) dated May 27, 2003,1 
seeking clarification of the Wireless Telecommunications Bureau’s (Bureau’s) Nokia Waiver 
Order.2 You explain that a clarification of the Nokia Waiver Order is needed so that Nokia’s 
training program will accurately cover its requirements. 
In the Second Report and Order,3 the Commission adopted section 22.921 to help improve 
911 call completion.4 In that order, the Commission delegated authority to the Wireless 
Telecommunications Bureau (Bureau) to consider and approve, deny, or approve with modification 
new or revised 911 call processing modes.5 
On October 27, 1999, Nokia filed a letter with the Bureau requesting approval for a 911 call 
completion method for Nokia’s multi-mode products.6 Nokia’s method was substantially similar to 
the Automatic A/B Roaming-Intelligent Retry (A/B-IR) method approved by the Commission.7 
Based on its delegated authority and its finding that the method appeared reasonable in both analog 
and digital modes, the Bureau approved Nokia’s method8 subject to two conditions: 
1 
Telecommunications Bureau, Federal Communications Commission (May 27, 2003) (Request). 
2 
Order). 
3 
Systems, CC Docket No. 94-102, Second Report and Order, 14 FCC Rcd 10954 (1999) (Second Report and Order). 
See Letter from Robert L. Pettit, Counsel for Nokia, Inc., to John Muleta, Chief, Wireless 
911 Call Processing Modes, WTB Docket No. 99-328, Order, 15 FCC Rcd 1911 (2000) (Nokia Waiver 
Revision of the Commission’s Rules To Ensure Compatibility With Enhanced 911 Emergency Calling 
47 C.F.R. § 22.921. This rule requires new analog wireless handsets, and multimode handsets when 4 
operating in analog mode, to be able to complete 911 calls to either analog carrier in an area, regardless of the 
programming of the handset for non-911 calls. The Commission sought to implement this rule through an 
equipment manufacturing requirement and its equipment authorization process while believing that implementation 
of the rule would require a relatively minor change to the phone’s programming. See Second Report and Order, 14 
FCC Rcd at 10992- 93. 
Second Report and Order, 14 FCC Rcd at 10993, 10995. 
Letter from David Siddall, Counsel to Nokia, to Thomas Sugrue, Chief, Wireless Telecommunications 
5
6 
Bureau, Oct. 27, 1999 (Nokia’s 1999 Request). 
In the Second Report and Order, the Commission approved three proposed 911 call processing modes 7 
including the A/B-IR method, while stating general principles for other acceptable modes and encouraging the 
development of further improvements in 911 call completion. See Second Report and Order at 10993. See also 
Nokia Waiver Order, 15 FCC Rcd at 1913. 
Nokia Waiver Order, 15 FCC Rcd at 1914-15. The Bureau also granted Nokia additional time to complete 8 
software changes to implement its method. See id. at 1915. Mr. Robert L. Pettit 
May 30, 2003 
First, the Nokia Waiver Order approved, as a feature in Nokia’s method, customer feedback 
regarding the status of the call until the call is completed.9 Accordingly, the handset must provide 
effective feedback to inform the user when 911 call processing is underway and has not finished. 
Second, Nokia’s method included a time limit for access attempts similar to the time 
requirement for the A/B-IR method.10 Under the Nokia Waiver Order, the 17-second time limit is 
applicable to access attempts.11 The Nokia Waiver Order approved Nokia’s method with the 
understanding that the handset must first attempt to complete the 911 call with the carrier operating 
the presently acquired system, and if the access attempts on that system are not successful within 
17 seconds, the handset must automatically attempt to make the call on another network.12 Under 
Nokia’s algorithm, as approved, access attempts are deemed unsuccessful if the handset has not 
received a voice or traffic channel assignment within 17 seconds. Accordingly, the initial access 
attempts on the presently acquired system must not exceed 17 seconds, regardless of whether the 
handset is operating in the digital or analog mode, before the handset attempts to call on another 
network.13 
Overall, then, for purposes of its training program, Nokia may consider that its revised 
911 call processing method was approved as described in its October 27, 1999 request, subject to 
the two conditions described above and, specifically, to the modification of its handsets to set a 
time limit on access attempts as described in its December 30, 1999 ex parte Letter. 
I hope that this clarification will assist you in ensuring Nokia’s compliance with the 
requirements of the Nokia Waiver Order. 
Sincerely, 
John B. Muleta 
Chief, 
Wireless Telecommunications Bureau 
9
10 
Nokia Waiver Order, 15 FCC Rcd at 1912-13, and 1915. 
In response to WCA’s comments that Nokia’s proposal did not specify the duration of the call attempt with 
the preferred carrier, Nokia clarified that its multi-mode handsets will comply with the time limits for access 
attempts approved by the Commission for the A/B-IR method, specifically the 17-second limit, whether the handset 
is operating in the digital or the analog mode. Letter from Davis R. Siddall, Counsel to Nokia, Inc., to Magalie 
Roman Salas, Secretary, Federal Communications Commission, WT Docket No. 99-328, at 3, n.7 (Dec. 30, 1999) 
(Nokia December 30 ex parte Letter). The 17-second time limit for initial call attempt with the preferred carrier 
limits possible lock-in problems as well as other delays when the call cannot be handled by that carrier for some 
reason. See Nokia Waiver Order, 15 FCC Rcd at 1913. See also Second Report and Order, 14 FCC Rcd at 10988. 
11 
12 
13 
See Nokia Waiver Order, 15 FCC Rcd at 1913-14. 
Nokia Waiver Order, 15 FCC Rcd at 1913-15. 
The Bureau found that the carrier operating the “presently acquired system,” normally the caller’s preferred 
carrier, is likely to be the carrier best able to deliver the call quickly and reliably while supporting the handset’s 
features, such as location capability when that feature becomes available. See Nokia Waiver Order, 15 FCC Rcd at 
1914. 
2