Gary K Jones Director of Technical Standards

1. Gary K JonesDirector of Technical Standards OES/CPUC/Lieutenant Governor’s Office Workshop for California Emergency Alerts

2. T-Mobile USA • A nationwide wireless service provider providing service in the state of California • The first carrier to provide wireless priority service allowing federal, state and local officials priority calling on our network in times of network congestion • Provider of wireless E911 service caller locations and call back numbers for delivery to public safety agencies • Active participant in industry efforts such as asthe Third Generation Partnership Project (3GPP), 3G America, CSM Association, Open Mobile Alliance, CTIA, IETF and ATIS and it is a member of the U.S. delegation to the ITU • Active participant in federal efforts to develop technical standards and protocols for the voluntary transmission of emergency alerts by wireless providers as part of the WARN Act, creating what is referred to as Commercial Mobile Alert Service (“CMAS”)

3. Current Messaging Capability Short Messaging Service (SMS) • Point to Point – requires a distinct connection between users • Connection set up is exactly the same as a voice call • There is no ability in the GSM network to send SMS to a particular geographic area or to a group of users • Each message must be uniquely addressed to an individual subscriber – and received wherever they are • Capacity is limited by network and radio resources • SMS designed for “busy hour” commercial messaging needs and that capacity would be exceeded quickly with emergency messages • SMS emergency alert message delivery times can exceed one hour to a large city

4. Emergency Alert Requirements • Timely delivery of alerts to even a small number of users in a small geographic area requires a “broadcast” point-to-multipoint messaging system • A single message is sent to multiple users at the same time • Impact to the network is manageable – as long as the alert does not result in heavy usage of the network resources • Messages must be authentic and meet requirements for a wireless emergency alert • Imminent threat to life and property • Informative within the message length limitations • Does not drive behavior destructive to the wireless network (immediate placing of wireless calls or accessing the web)

5. Emergency Alert Challenges • Message Initiation • Traditional EAS has been local in nature – local EOC talking to local radio and TV managers • T-Mobile is a nationwide wireless service provider and has no such local presence • Messages must be authenticated, authorized, formatted correctly and sent to a central location in our network – most probably the Network Operations Center (NOC) • Messages must come with sufficient information so the NOC knows where to send the message for transmission, how often to repeat, expiration time, etc. • It is not feasible for a nationwide wireless service provider to have a connection to thousands of individual emergency managers/message initiators – so messages should come from one trusted source

6. CMSP Administered C A’ CMSP Gateway Possibly Government Administered Federal Agencies B CMSP Infrastructure Alert Aggregation Local EOC Alert Gateway Mobile Device State EOC CMAS Architecture

7. State of our Network • SMS is deployed and available in every handset, but the capacity for both voice and messaging is provisioned for “busy hour” and will break down with heavy usage • No broadcast capability (cell broadcast, MBMS, etc.) exists in our network or on the majority of our handsets • Even where cell broadcast software is available on a handset: • The menu is hidden from the user or “buried” • Cell broadcast has never been tested or certified for network use • Regardless of what you have been told: • Any messaging system must have the underlying messaging technology present in the wireless service provider’s network and handsets • Any messaging system must have the capacity in the wireless service provider’s network and handsets in order to deliver messages in a timely and effective manner

8. Summary • T-Mobile has and continues to support the needs of our customers and the public safety community • T-Mobile participates in the FCC’s Commercial Mobile Service Alert Advisory Committee and is committed to developing an effective nationwide Commercial Mobile Alert Service • T-Mobile believes a national wireless alert service, available to authorized federal, state and local emergency managers is the best way to approach the complex but worthwhile task of using wireless devices for emergency alerts • T-Mobile recommends state participation in the ongoing FCC’s wireless alert proceeding

9. Thank you Questions?