February 3, 2021 VIA ECFS Marlene H. Dortch, Secretary Federal Communications Commission 45 L Street, NE Washington, DC 20554 R

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February 3, 2021

VIA ECFS

Marlene H. Dortch, Secretary Federal Communications Commission 45 L Street, NE Washington, DC 20554

Re: Petition of Certain Members of CCA for Waiver or, In the Alternative, Declaratory Ruling, CG Docket No. 16-145 and GN Docket No. 15-178

Dear Ms. Dortch:

Southern Communications Services, Inc. d/b/a Southern Linc (“Southern Linc”) hereby submits its response to requests from the Consumer and Governmental Affairs Bureau for further information as it considers the request for waiver in the above-captioned dockets.1

Some portions of Southern Linc’s response are confidential. Under separate cover, Southern Linc has submitted the unredacted version consistent with 47 C.F.R. §§ 0.457 and 0.459 and the current procedures described in Public Notice DA 20-361.

Respectfully submitted,

/s/ Michael D. Rosenthal

Michael D. Rosenthal Director of Legal & External Affairs Southern Linc

Attach. cc: Suzy Rosen Singleton William D. Wallace

1 See Letter from Suzy Rosen Singleton, Chief, Disability Rights Office, Consumer and Governmental Affairs Bureau, FCC, to Michael Rosenthal, Southern Linc (Dec. 21, 2020). While Ms. Singleton’s letter set an initial 30-day deadline for responses, that deadline was extended to February 3, 2021. See Letter from Suzy Rosen Singleton, Chief, Disability Rights Office, Consumer and Governmental Affairs Bureau, FCC, to Alexi Maltas, Competitive Carriers Association (Feb. 2, 2021). REDACTED - FOR PUBLIC INSPECTION

Response of Southern Communications Services, Inc., d/b/a Southern Linc, to December 21, 2020 Letter from Consumer and Governmental Affairs Bureau

1. Describe the IP-based voice services (e.g., VoLTE, VoWi-Fi, etc.) that the Company offers. Southern Linc’s Long-Term Evolution (“LTE”) network utilizes Internet Protocol (“IP”)-based technologies across our footprint and is a 100% greenfield LTE network deployment with no 3G fallback capabilities (for voice services or otherwise). Southern Linc offers VoLTE and VoWi-Fi as well as Push to Talk (“PTT”) services. Southern Linc’s LTE network also provides mission critical data services that serve public safety and critical infrastructure customers with many critical use cases (i.e., active monitoring and execution of Southern Company’s electric companies’ bulk power and distribution systems). Because of its expansive rural coverage and history of reliability, Southern Linc’s service is widely used by state and local public safety agencies, school districts, rural local governments, public utilities, and other emergency responders. It is also used by other commercial entities in both urban and rural areas. Southern Linc’s customer base is primarily business-to-business given its mission critical data services and PTT application. 2. In what geographic areas are the Company’s IP-based voice calling services currently available, and to how many subscribers? Southern Linc provides these services over a 127,000 square mile territory covering Georgia, Alabama, southeastern Mississippi, and the panhandle of Florida. Southern Linc offers comprehensive geographic coverage, serving the extensive rural territory within its footprint as well as major metropolitan areas and highway corridors. As of December 31, 2020, Southern Linc had ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** customers throughout its service territory, with approximately ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** of those being consumer accounts.

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3. When did the Company first make IP-based voice calling services available for customers?

Southern Linc's LTE network was commercially launched in September 2018 throughout its regional service territory.

a. Provide a copy of any notice that the Company provided to consumers regarding the availability and limitations of IP-based voice calling services.

Please see the following attachments:

Attachment 1: Screenshot of Southern Linc 911 and Text to 911 Website Attachment 2: Screenshot of Southern Linc RTT FAQs Website.

4. Are the Company’s legacy networks (e.g., 2G, 3G, TDMA, GSM, CDMA, iDEN, etc.) still in use?

No. Southern Linc previously used an iDEN network but it is no longer in use. Once the manufacturer stopped supporting iDEN, it was not possible for Southern Linc to continue to maintain its iDEN network.

a. If no, when were the legacy networks retired in each geographic area served by the Company?

Southern Linc's legacy iDEN network was commercially shut down in Alabama, Florida, and Mississippi in March 2019. Commercial services in Georgia were turned down the following month in April 2019. A very small number of legacy iDEN sites continued to

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operate through March 2020 for Southern Linc's electric operating company affiliates to continue to use PTT services only.

b. If yes, describe what services are available on the legacy networks and whether and how customers know which network they are using.

Not Applicable.

c. Does the Company have plans to retire any existing legacy networks? If yes, what is that schedule?

Not Applicable.

d. Has the Company notified customers of the schedule for retirement of the legacy networks? If yes, provide a copy of the notice.

Not Applicable.

5. Does the Company currently support TTY calling?

No. However, Southern Linc supports 711 calling to Telephone Relay Service as well as Text-to- 911 for 131 PSAPs out of the 309 PSAPs within Southern Linc's footprint (as of 1/20/2021).

a. Identify the geographic areas where TTY calling is supported and any limitations on such support.

Not Applicable.

b. What has the Company done to evaluate the effectiveness of TTY calls on its networks?

Not Applicable.

c. To the extent that the Company currently supports TTY calls, explain how customers know TTY is an available option. Provide copies of any notices to customers regarding TTY calling.

Not Applicable.

d. To the extent that the Company currently supports TTY calling, describe how a TTY call would be routed in areas where the primary network is IP-based. If TTY 911 calls are routed differently from other TTY calls, describe the difference.

Not Applicable.

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e. Provide copies of any notices to customers regarding TTY calling, including any notices re 911 calling that address the use of TTYs.

Southern Linc has maintained consumer-oriented webpages with information about 911 and RTT limitations. Please see Attachments 1 and 2 for the current versions.

6. Has the Company entered into a contract with a network vendor to deploy RTT, as defined by Part 67 of the Commission’s rules?

Yes.

a. If yes, identify the vendor, the date of the contract, and the projected RTT-ready date(s) specified in the contract and in any subsequent contract amendments. Provide documentation supporting your response.

The Master Agreement with ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** was executed on December 10, 2019 (executed on behalf of Southern Linc by its affiliate, Southern Company Services, Inc.). Southern Linc issued purchase orders for the ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** project (“Replacement Project”) on February 24, 2020, which was supplemented by purchase orders for RTT/TTY transcoding on April 7, 2020 pursuant to a quote dated March 4, 2020. The purchase orders do not provide a projected ready date, but ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** submission in response to Southern Linc’s Request for Proposals for the Replacement Project included a ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** “representative project schedule” for the project.

See Attachment 3: Master Software License Agreement 2019.

b. If yes, describe the progress toward RTT deployment in the Company’s network, and provide both the vendor’s and the Company’s project status reports. Detail what elements of your network require modification to implement RTT and projected dates for completing each of those modifications.

Southern Linc has made good progress toward RTT deployment in the network. There are five main categories of network changes to implement RTT on Southern Linc’s network.

• First, to enable RTT-to-RTT capability within Southern Linc’s network, Southern Linc’s ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** infrastructure had to be configured, devices provisioned with development loads, and tested within the lab. Once lab validation was completed, the production network had to be configured. This work was completed around the end of June 2020.

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fully until early November even though it was originally expected to be complete within a few months.

System Change Freezes: Due to a combination of the COVID-19 pandemic and a series of fall storms, Southern Company ***BEGIN CONFIDENTIAL***

*** END CONFIDENTIAL***. During a normal year, change freezes ***BEGIN CONFIDENTIAL***

***END CONFIDENTIAL***. With the start of the COVID-19 pandemic, Southern Company ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***, which was extended to ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***, so then system maintenance and changes that had been delayed since ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***. However, there was an additional conservative mode of operation during most of ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** that required additional timing, planning, and scrutiny of any changes. See generally Attachment 6. Fall storm season resulted in a change freeze for Hurricane Sally that struck the Gulf Coast and Southeastern United States resulted in a change freeze from ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***. Additionally, Hurricane Sally hit Southern Linc's footprint as a Category 2 hurricane. Southern Linc’s operations were in storm mode with all hands on deck working to ensure continued operation and expedited restoration of impacts to our wireless network and backhaul infrastructure. On the heels of Hurricane Sally, we also responded to Hurricane Delta (approximately October 5 through 12) and Hurricane Zeta (approximately October 24 through November 2). The Southern system change freezes pushed back some of the requisite firewall changes mentioned in the response to Question 6(b), as well as all major systems projects that were also slated to occur in the same time period, including the virtual server infrastructure lifecycle replacement project (that needed to be installed and ready for production before the Replacement Project could move into production). Data Center and Lab Access Delays: When the COVID-19 pandemic began, ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***. However, lab testing of the ***BEGIN CONFIDENTIAL***

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***END CONFIDENTIAL*** needed to be conducted in person at the lab due to use of equipment physically located in the lab. Much of the work on 911 RTT requires physical presence in the lab, which has been delayed. At the beginning of the pandemic, we allowed multiple people in the lab and required social distancing. However, in the Alabama lab, two employees contracted COVID-19 after in-person work around September 23 through 25, even though personal protective equipment and social distancing had been utilized. After the positive cases, we had to freeze in-person work in the facility other than the minimum necessary to manage the network. Effective October 5, 2020, there was a weeklong freeze of access to the facility other than the workers necessary to run the network. Additionally, the other employees who had contact with the confirmed positive cases were subject to 2-week quarantine at home. After that, more rigorous access limitations and scheduling of in-person work were implemented, which further slowed work in the lab on the Replacement /RTT Project due to competing demands of other projects. Additionally, there were multiple hardware/firmware upgrades that had to be done in person at the lab and two data centers. The Alabama lab server installation was complete the first week of July 2020, which allowed testing to commence. However, physical access to the Georgia data center was highly restricted due to COVID-19 starting in March 2020 and precautions to limit person-to-person transmissions that comprised of a waiting period between individuals, and work could not be completed on installing other requisite servers for the virtual infrastructure lifecycle replacement project until around July 20, 2020. This delay in installing the virtual servers delayed being ready for the ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** to move to the production environment, which did not occur until August/September 2020. The relevant Alabama and Georgia production servers were able to be installed and configured the last week of October 2020.

Please also see the Company’s response to question 13.

8. Has the Company entered into a contract with a vendor for 911 routing and delivery of RTT calls to PSAPs?

Yes.

a. If yes, identify the vendor, the date of the contract, and the projected RTT-to-911 ready date(s) specified in the contract and in any subsequent contract amendments. Provide documentation supporting your response.

***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** is Southern Linc’s e911 vendor, and general discussions regarding the need for RTT-to-911 services have taken place with ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** since 2016. As with most services and new regulatory mandates, their focus was first on Tier 1 carriers and then shifted to regional carriers. Even then, Southern Linc found itself in a unique situation given it did not have a legacy 3G fallback network to use for RTT services. ***BEGIN CONFIDENTIAL*** ***END

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CONFIDENTIAL*** was able to discuss the RTT solution in April 2020, and pricing was made available around May 20, 2020. Protracted negotiations began and encompassed additional new services, but when an agreement regarding the other services could not be reached, the scope was narrowed to finalize RTT terms and pricing because we were nearing a stage of the Replacement/RTT Project where work could begin planning for the 911 implementation. The ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** RTT Service Order was executed November 30, 2020. (See Attachment 7: RTT Service Order.) The RTT Service Order does not provide a firm ready date in the contract due to the nature of the implementation/test cases being so dependent on Southern Linc and Southern Linc’s underlying Replacement Project. During contract negotiations in 2020, ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** had indicated to plan on a few months for implementation depending on how long it takes our team to work through the testing scenarios and whether any issues were encountered. b. If yes, describe the Company’s progress toward handling and delivering 911 calls over RTT, and provide the vendor’s and the Company’s project status reports. Detail what network elements require modification to accommodate the RTT-to-911 solution. First, the Replacement Project must be completed before moving to RTT-to-911 implementation. The Replacement Project itself requires re-testing/installation of ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** underlying voice e911 services (e.g., VoLTE and VoWi-Fi) because those services provide the foundation for the RTT services. In advance of full completion of the Replacement Project, Southern Linc has taken many steps towards delivering 911 calls over RTT. As part of the Replacement Project in 2020, Southern Linc upgraded its testing capabilities with ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** by installing voice 911 calling/VPNs/trunks in its lab, which was deployed around October 11, 2020. This enhanced connectivity to ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** in our lab added work and time to the Replacement Project, but this was viewed as time well spent in the interest of improved public safety and expedited e911 testing capabilities. We are currently experiencing the benefits of having this improved connectivity to ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** in our lab as we are working through the ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** Peering, VoLTE and VoWi-Fi test cases of the Replacement Project in an expedited manner by being able to test during business hours, not just during overnight maintenance windows. For example, VoLTE testing is complete and pending final review, and testing of both Peering and VoWi-Fi are scheduled for ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***. After certification of those tests with ***BEGIN CONFIDENTIAL*** ***END

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CONFIDENTIAL***, we will quickly turn to RTT testing with ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** as detailed below, which we expect will also move forward quickly in part thanks to the new lab connectivity.

***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** RTT solution will be implemented as two projects because VoLTE and VoWi-Fi utilize different call paths to be tested and implemented. ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** has provided a working draft of the RTT implementation plans, separately for VoLTE and VoWi-Fi. (See Attachments 8 and 9.) The plans show projected dates, not actual completion dates for some tasks already completed. With respect to the VoLTE RTT project, we are already in Tthe lab RT testing phase. VoLTE RTT testing by Southern Linc will commence after certification of the ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** tests, which is expected in the next week. After VoLTE RTT testing by Southern Linc, the production environment will be set up and tested, including a series of PSAP testing. Although the implementation plan sets out the tasks in a serial timeline, the ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** team has agreed with our desired approach to work on as many items in parallel as feasible and move up tasks when other tasks are completed early. ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** has indicated that this project will be prioritized, and resources will be available, even with moving forward tasks on the timeline. ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** Go live is slated around the week of ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***, absent any additional issues or delays.

c. If the Company has not contracted with a 911-to-RTT vendor, explain in detail why not. Describe the Company’s plans and timeline for implementing support of 911 calls over RTT, including its plan and timeline for negotiations with a network vendor. Explain what network elements will require modification to accommodate the RTT-to-911 Solution.

Not applicable. d. Do you have a plan for testing RTT delivery with PSAPs?

Yes. Currently, we are conducting RTT-to-911 solution testing to the ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** lab from our lab. We plan on testing RTT-to-911 (TTY) with both the City of Birmingham, Alabama, and the City of Atlanta, Georgia. Such testing is tentatively planned for the week of April 19 and May 4 through 13. There are no PSAPs in our service area of which Southern Linc or ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** are aware that are planning to implement RTT, so we plan to move into production without testing RTT-to-RTT delivery to a PSAP given the current impossibility. Once a PSAP within

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Southern Linc's service area requests RTT, Southern Linc and ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** will work together to implement at that time.

e. Have any PSAPs notified the Company that they are RTT-ready, and if so, when did they provide such notification? Provide copies of any correspondence.

No. 9. Has the Company arranged for acquisition of at least one RTT-enabled mobile device from a device manufacturer?

Yes.

a. If yes, identify the Company’s equipment vendor(s), the date(s) of its agreement(s), and the projected delivery date(s) specified in the contract and any subsequent contract amendments. Provide documentation supporting your response.

Southern Linc’s master contract with ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** is dated April 28, 2016. Southern Linc began coordinating with ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** on enabling RTT functionality in 2017 and issued a change request around February 2, 2018 to ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** for RTT backward compatibility software support. Arrangements for the remaining portion of ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** RTT release were finalized in May 2020 for delivery and scheduled acceptance by Southern Linc by June 30, 2020. ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** delivered the RTT functionality, and after testing, Southern Linc accepted the release on August 4, 2020. See Attachments 10 and 11.

b. If yes, describe the progress toward enabling RTT in mobile devices on the Company’s network. Detail what device or network elements, if any, require modification to ensure the device can be used for RTT communications.

The RTT firmware for the ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** is ready for deployment as soon as the 911 solution is in production. Once RTT-to-PSAP is in production, Southern Linc will push handset updates to the devices to enable the RTT client. Customers’ existing devices will need an over-the-air software update via Southern Linc’s Device Management platform to enable the RTT client on the handsets. Southern Linc’s device team will schedule this update in conjunction with completion of the network and 911 solutions. We are currently planning our communications/customer education to accompany this update. New ***BEGIN

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CONFIDENTIAL*** ***END CONFIDENTIAL*** devices sold after full RTT launch will have the updates preloaded on the device.

Once the update is pushed, the customers will need to power cycle their devices to receive the update. Customers interested in RTT will then need to launch the RTT client on their handset and acknowledge the device’s RTT quick-start instructions. Once the RTT client is enabled, Southern Linc subscribers will be able to make the full range of mobile-to-mobile RTT and mobile-to-PSAP communications utilizing the native RTT dialer.

The network modifications to achieve mobile-to-mobile RTT for communications only on the Southern Linc network are complete. As previously mentioned, the device solution is awaiting production of the RTT-to-PSAP solution, which will be completed after the Replacement/RTT Project. The network modifications needed to achieve mobile-to- mobile RTT with third party networks and mobile-to-PSAP RTT communications are pending as more fully described in the responses to Questions 6 and 8, respectively.

Although it is technically possible to release the ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** update to enable mobile-to-mobile RTT solely on the Southern Linc network in advance of the 911 solution being implemented, Southern Linc has strong concerns about customer confusion and potential safety issues without having RTT-to-PSAP calling enabled. If a subscriber tried to call 911 using RTT, a regular voice call would be established with the PSAP and Phase I and II location data received, and the device would not allow any RTT text to be entered. Additionally, the handset’s RTT introductory terms cannot be dynamically changed to alert customers if 911 with RTT text is not available. These safety concerns resulted in waiting to deploy the mobile RTT client until when the entire RTT solution with 911 capabilities is deployed. c. If the Company has not engaged a device manufacturer for delivery of RTT-enabled mobile devices, explain why not, and how the Company plans to support RTT- enabled devices in its initial implementation of RTT, and its timeline for completion of such plans through the date such devices will be made available to customers.

Not applicable.

i. Are there software applications or updates that can be downloaded by customers or pushed over-the-air to customers to make the current mobile devices RTT enabled? Not Applicable.

ii. Alternatively, provide the Company’s timeline to engage at least one equipment vendor to deliver RTT-enabled mobile devices, any requests for 14

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proposals, and correspondence. What is the Company’s plan for acquiring RTT-enabled mobile devices and its anticipated timeline for delivery of RTT- enabled mobile devices? Not Applicable.

iii. Under either alternative (i) or (ii), describe what device and network modifications are needed to make devices capable of mobile-to-mobile RTT and mobile-to-PSAP RTT communications. Not Applicable.

d. According to the timelines set forth in the Commission’s Report and Order on RTT, by June 30, 2021, non-Tier I service providers (including resellers) that opt to support RTT must do so for all new authorized user devices activated on their networks. FCC 16-169, para. 67. Does the Company expect to meet this deadline? If not, what is the Company’s plan and proposed timeline for completing this second phase of RTT implementation? We are striving to meet this deadline, but we once again find ourselves subject to the timelines of third-party handset manufacturers to enable RTT functionality in devices. As a non-Tier 1 carrier, Southern Linc negotiates directly with some handset manufacturers like ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***, but also leverages handset consortiums such as ***BEGIN CONFIDENTIAL*** ***END COFIDENTIAL*** for iconic handsets like ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***. Southern Linc spearheaded efforts in early 2020 within the *** BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** to have RTT added to its requirements for new devices, which is a long process that culminated in approval of RTT as a ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** requirement in October 2020. The requirements apply to the devices that Southern Linc plans to introduce later this year. In January 2021, ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** confirmed plans to include RTT in the ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** devices, and we are awaiting a timeframe from ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** on when RTT will be integrated into the operating system loaded on new ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** devices. 10. The conditions of the CCA waiver granted in April 2016 required that participants provide notice to customers that TTY is not operable on IP-based networks and to recommend alternatives for persons with hearing and speech disabilities.

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a. Describe how the Company complied with this condition, including where and in what formats it provided this notice, including hyperlinks to webpages and copies of paper formats. In April 2016, the iDEN network was operational, and TTY was available for all customers. At that time, there was a page entitled “TTY FAQs” on the Southern Linc website. Our iDEN network end of life notifications pointed customers to our website for more information on LTE. Southern Linc provided the notification that TTY is not operable on LTE as an IP-based network on our website via the “LTE 911 and Text-to- 911” page and “RTT FAQs” page. The “LTE 911 and Text-to-911” page details the “Limitations of TTY calls to 911 Emergency Services over LTE or Wi-Fi.” Specifically, the page explains that: “Southern Linc handsets only make voice calls using Voice Over LTE (VoLTE) or Voice Over Wi-Fi (VoWiFi). You should be aware that TTY does not work on VoLTE or VoWiFi. TTY calls, including, without limitation, TTY calls to 911, cannot be made using IP-based calling, including over LTE or Wi-Fi. If you have a communication disability and need to call 911 while using IP-based calling, we recommend that you use an alternative means of communicating utilizing IP-based Telecommunications Relay Services (TRS) such as IP Relay or Video Relay Services (VRS). Additionally, you may send a text message to 911 directly, where text-to-911 is available.” Additionally, the “RTT FAQs” page mentions the Text-to-911 alternative as well. The "LTE 911 and Text-to-911" page shows a map of Text-to-911 deployments.

Southern Linc provided these notifications on our website via the "LTE 911 and Text-to- 911" (https://www.southernlinc.com/privacy/wireless-accessibility/e911.aspx) page and "RTT FAQs" (https://www.southernlinc.com/privacy/wireless-accessibility/rtt.aspx) page. Please also see Attachments 1 and 2. b. When did the Company initially make this notice available to customers? In 2016, the iDEN TTY FAQs and 911 webpages were available. Upon launch of the commercial LTE network in 2018, we also published LTE terms webpages to reflect the LTE network performance, including TTY limitations on the "LTE 911 and Text-to-911" webpage and “RTT FAQs”. During the period of dual operation of both the iDEN and LTE networks commercially, iDEN 911 calling and TTY information was also available on pages dedicated to TTY FAQs and iDEN 911 and Text-to-911 calling. c. What is the current status of this notice? The LTE notices provided are still currently available on Southern Linc's webpages listed above. 11. Have any customers contacted the Company, complained to the Company, or both, regarding their ability to use a TTY with the Company’s service since it began offering IP- based voice calling services, and if so, when did each of these customers contact the Company and how did it respond? Provide copies of any correspondence.

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To the best of our knowledge, there have been no customer inquiries to Southern Linc relating to TTY, including via our customer support and sales teams or the email provided for more information on the "RTT FAQ" webpage.

12. Have any customers contacted the Company, complained to the Company, or both, regarding the availability of RTT since it began offering IP-based voice calling services, and, if so, when did each of these customers contact the Company and how did it respond? Provide copies of any correspondence.

To the best of our knowledge, there have been no customer inquiries to Southern Linc relating to RTT, including via our customer support and sales teams or the email provided on the "RTT FAQ" webpage.

13. The conditions of the CCA waiver granted in April 2016 required that participants provide semi-annual progress reports on deploying RTT. CCA’s last RTT progress report before the filing of the petition was submitted April 17, 2020.

a. As of April 17, 2020, what was the status of RTT deployment on the Company’s Network?

Our ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** handsets already had some of the necessary RTT elements incorporated, and we expected ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** to be able to deliver remaining elements in June. With respect to the network deployment, we had already tested on-network mobile-to-mobile RTT calls in March 2020, and the calls were working successfully. With respect to the other RTT use cases, we had just kicked off work on the Replacement Project with ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** and were at early stages of incorporating RTT. Later, we realized that ***BEGIN CONFIDENTIAL***

***END CONFIDENTIAL***. Additionally, as detailed in the response to Question 7, we also realized that it would not be possible to complete the RTT network production to enable standards-based off- network RTT calls in advance of the adjusted Replacement Project that was to be completed by the end of 2020.

With respect to RTT-to-PSAP, ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** was still preparing for introduction of its RTT-to-911 solution for regional carriers, so we were still working to get additional details. We knew from past conversations that the vendor was aware of the regulatory timeline, so we expected this to be supportable. Additionally, we were checking for any new “over the top” applications that could be leveraged to provide RTT with 911 calling.

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b. Describe any events or obstacles that impeded the Company’s progress toward RTT deployment between April 17 and June 30, 2020.

See response to question 7. In addition, ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** held a webinar on ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***, but the solution was not ready for deployment. c. Describe any events or obstacles encountered prior to April 17, 2020, that contributed to the Company’s inability to meet the June 30, 2020 deadline, and if there were any such events or obstacles, why they were not reported in any of the progress reports. Lack of solutions supporting RTT-to-TTY: Southern Linc’s network vendor, ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** had no solution available that met the FCC’s requirements. We kept optimistically thinking that the vendor would change course ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** or that a third-party with a plug-and-play RTT solution or over-the-top app would materialize given the obvious need with the upcoming non-Tier 1 compliance deadline in June 2020. In hindsight, the optimism was misplaced, and it would have been beneficial to have alerted the FCC sooner of the lack of TTY transcoding solutions.

Lack of OTT applications: Southern Linc searched extensively and found no over-the-top applications that could stand alone without ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** TTY backward compatibility solution and met the FCC’s other requirements.

Specifically, Southern Linc inquired of multiple vendors from 2018-2020:

i. ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** – solution was fallback to TDM (3G), which we did not have in place. ii. ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** – partial solution but Southern Linc would still need TTY conversion services from a third party, so it would not meet our needs. iii. ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** – no solution / did not provide TTY conversion. iv. ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** – no solution. v. ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL***.

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vi. Orlando CCA show, Oct. 2018; Denver CCA show, April 2019; Providence CCA show, Sept. 2019 – asked multiple vendors at each show, but no RTT solutions were offered. Often, we had to explain what RTT was to the vendors.

The few OTT applications we identified were not RTT-to-PSAP capable.

i. Speech2RTT was the over-the-top application available on the Google Play Store. However, it requires both parties to have the app installed and did not support emergency calling. For example, the Speech2RTT terms of use specify not to use Speech2RTT to place 911/emergency calls. See http://speech2rtt.com/?p=946, last visited Jan. 27, 2021. ii. Hamilton 911 RTT solution was a desktop IP phone when we reviewed their website. See https://hamiltonng911.com/wp- content/uploads/2019/07/hamiltonipphoneflyer.pdf, last visited Jan. 28, 2021.

Lack of 911 solution ready for deployment:

i. Because RTT uses a voice channel, a carrier like Southern Linc without its own peering network must utilize the same provider for both RTT and the underlying VoLTE/VoWi-Fi 911 services. This meant we could only utilize ***BEGIN CONFIDENTIAL*** ***END CONFIDENTIAL*** for our RTT- to-PSAP solution. ii. This vendor’s RTT solution was not yet ready for production and pricing was not yet available, but we had an existing relationship and expected a smooth transition at that time.

d. Provide any documentation that supports the responses to this question. 14. If the Company wishes to provide other information or relevant documentation regarding its deployment of RTT, please provide it here.

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LTE 911 and Text-to-911

When dialing 911, your Southern Linc phone may be a real lifesaver!

Today, 911 service is a vital part of our nation's emergency response and disaster preparedness system. The Federal Communications Commission (FCC) has taken steps to increase public safety by encouraging and coordinating development of a nationwide, seamless communications system for emergency services.

n order to deliver emergency help more quickly and effectively, wireless carriers and public safety entities are upgrading the 911 network on a regular basis. For example, most 911 systems now automatically report the telephone number and location of emergency calls made from phones, a capability called Enhanced 911, or E911.

The FCC also requires wireless telephone carriers to provide 911. E911 capability, and text-to-911 where a Public Safety Answering Point (PSAP) requests it. Wireless E911 will provide location information for emergency calls from wireless phones. Text-to-911 allows callers to send SMS text messages to PSAPs.

All new phones sold by Southern Linc are GPS-capable, which means there is a chip in the phone that will help provide ocation information to a PSAP when a caller dials 911. The GPS capability becomes active after calling 911 when the network prompts the phone for coordinates.

Wireless E911 Phase I

Wireless E911 Phase I requires wireless carriers to provide emergency response agencies with the telephone number of a wireless caller and the location of the tower site that received the call in order to help them dispatch assistance to the 911 caller.

Wireless E911 Phase II

Wireless E911 Phase II requires wireless carriers to provide the telephone number and far more precise location nformation-- in most cases, within 410 feet or 135 yards. Southern Linc customers must have a GPS capable phone in order for the approximate location of the caller to be sent to the 911 operator. Wireless E911 Phase II service is only available if the applicable 911 Center has upgraded its equipment.

Wireless E911 and Text-to-911 Coverage Map

Pl t th ithi th S th Li h l b i 911 lli i il bl b th

REDACTED - FOR PUBLIC INSPECTION emergency services provider, and may not be able to identify the caller’s identity, device, telephone number, or location. To facilitate appropriate 911 call routing, you must register the physical address of your Wi-Fi Equipment including any requisite building, apartment, floor, suite, or unit number (“Dispatchable Location”). This Dispatchable Location may be used to help locate 911 callers. You must keep the Dispatchable Location of your Wi-Fi Equipment up to date.

Limitations of TTY calls to 911 Emergency Services over LTE or Wi-Fi

Southern Linc handsets only make voice calls using Voice Over LTE (VoLTE) or Voice Over Wi-Fi (VoWiFi). You should be aware that TTY does not work on VoLTE or VoWiFi. TTY calls, including, without limitation, TTY calls to 911, cannot be made using IP-based calling, including over LTE or Wi-Fi. If you have a communication disability and need to call 911 while using IP-based calling, we recommend that you use an alternative means of communicating utilizing IP-based Telecommunications Relay Services (TRS) such as IP Relay or Video Relay Services (VRS). Additionally, you may send a text message to 911 directly, where text-to-911 is available.

SMS TEXT-TO-911: Call if you can. Text if you can’t.

Southern Linc transmits emergency 911 texts to Public Safety Answering Points (PSAPs) when they are capable and ready to receive text messages. Southern Linc provides text-to-911 to many PSAPs across our coverage area. Text-to-911 is only mplemented where PSAPs are capable of receiving text-to-911 and have notified Southern Linc that they are ready to mplement. This solution is an interim one until such time as Next Generation 9-1-1 solutions are available. However, if it s safe for you to dial 911, please do so. Text 911 when it is your only option.

You must have an SMS plan or a data plan with Southern Linc to text to 911 in the areas where PSAPs are able to receive texts.

As indicated in the map above, a limited number of PSAPs in Southern Linc' coverage area have enabled receipt of texts- to-911 at this time. Some PSAPs have enabled the preferred IP-based text-to-911 solutions. However, other PSAPs have opted to receive text-to-911 via the TTY solution, which has flaws. Among other limitations, as an interim SMS text-to- 911 solution, the TTY solution is very slow; it has limited character sets; it has a number of error handling issues; and most of today’s text savvy wireless users have not encountered this technology. Nevertheless, Southern Linc will mplement the needed capabilities within six months of notice from any of the remaining PSAPs once they are ready and capable of receiving texts to 911.

Links to more Interim SMS Text-to-911 Information:

Federal Communications Commission What You Need to Know About Text-to-911 http://www.fcc.gov/text-to-911

National Emergency Number Association, the 9-1-1 Association SMS Text-to9-1-1 Resources for PSAPs & 9-1-1 Authorities REDACTED - FOR PUBLIC INSPECTION http://www.nena.org/?page=textresources

National 911 Program Next Generation 911 (NG911) http://www.911.gov/911-issues/standards.html

West Safety Services Next-Generation 9-1-1: The Essential Guide to Getting Started https://www.west.com/resources/safety-services/brochures/next-generation-9-1-1-essential-guide-getting-started/

Frequently Asked Questions

What does it mean that text-to-911 is an interim solution? Short Message Service (SMS) Text-to-911 is how the solution is widely known. In 2011, the FCC acknowledged the technical limitations of SMS and called it a short-term solution:

SMS is essentially a store-and-forward messaging service that is not designed to provide immediate or reliable message delivery; does not support two-way real-time communication; does not provide the sender’s location information; and does not support the delivery of other media such as photos, video, and data. All of these factors appear to make SMS inappropriate as a long-term text-to-911 solution and warrant caution in encouraging it as a short-term solution. When PSAPs fully adopt Next Generation 911, the text-to-911 solution will no longer be interim.

How will I know which PSAPs are accepting texts to 911? The FCC maintains a list of the PSAPs that have implemented interim SMS text-to-911 solutions. It may be found at https://www.fcc.gov/files/text-911-master-psap-registryxlsx.

See the map above for Southern Linc areas offering text-to-911 service.

f I send a text-to-911, how will I know the local PSAP received the text? First, you must have an SMS plan or a data plan with Southern Linc to able to send a text to 911 in the areas where PSAPs are able to receive texts. If the local PSAP received your text, you should receive a text from the local PSAP. If the local PSAP is not accepting texts or the service is not available for another reason, you will receive a “bounce back” message that will tell you the service is not available so you should call 911. Remember: Call if you can; text if you can’t.

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All PSAPs have at least one TTY machine; it looks like a traditional typewriter. Its function is to permit persons with a disability, such as blindness or deafness, to communicate with the PSAP. The PSAP’s TTY machine will get a message that a text to 911 has been received. The PSAP will type a message back to the sender. The sender has to wait to get the essage before the sender can respond (The technical term for this functioning is half duplex ) As noted above, communicating via TTY can be slow, so let the PSAP know who you are, where you are and what your emergency is, as succinctly as possible.

What are the other interim SMS text to 911 solutions? At present, there are two other interim SMS text-to-911 solutions: (1) Web Portal, which uses a terminal with Internet access which must be monitored for incoming text messages; and (2) NG911 Interface, which requires the PSAP to have nternet Protocol (IP) capable equipment and an IP connection to the carrier over whose network the text to 911 is being transmitted You can learn how these solutions and interim SMS text to 911 works in a publication produced by the Ad Hoc National SMS Text-9-1-1 Service Coordination Group titled “Interim SMS Text-to-9-1-1 Information and Planning Guide,” version 2, May 2014, which may be found at http://c.ymcdn.com/sites/www.nena.org/resource/resmgr/Docs/SMS_Text_Info_and_Planning.pdf.

s there a long-term solution for sending messages to 911? Wireless carriers, their vendors, the FCC, public safety organizations, and standards setting bodies are working to put in place the standards needed so that Next Generation 911 (NG911) solutions can be created and implemented. The FCC told ongress in a 2013 report that NG911 networks will be able “to receive traditional 911 calls, [and] text, data, and video communications from any communications device via IP-based networks,” plus “machine-generated data from telematics applications (e.g., automatic collision notification systems in vehicles), medical alert systems, and sensors and alarms of various types.”

When will the long-term solution be available? By some estimates, the long-term solution may be more than five years away.

Do need to sign up for E911 Phase I and II service? No. When E911 service is deployed in an area by Southern Linc, it is available for all network users in that area.

How do I know whether Phase I or Phase II services have been deployed in a particular area where I'm making wireless calls? Because there are many 911 Communications Centers across our coverage area, we suggest you contact the 911 Center in our area by calling their non-emergency/administrative phone number (usually found near the front of your local phone book or directory) to determine that agency's ability to receive wireless E911 calls. Check out the E911 coverage REDACTED - FOR PUBLIC INSPECTION ap posted on this page as well

kept my phone number from a different area of the country. When I dial 911 from my phone, will my call be routed to a nearby 911 center? Yes Southern Linc will route your emergency call to the nearest 911 Communications Center, regardless of the phone number assigned to the phone. Be sure to provide your location and ten-digit phone number when asked by a 911 operator.

What should I do if I accidentally dial 911? f you accidentally dial 911, stay on the line until the 911 operator answers the call. Tell the operator that the call was made by mistake and no emergency assistance is needed.

Tips for 911 calling and preventing unintentional calls

The FCC provides the following tips for people who call 911 from a wireless phone:

Tell the emergency operator the location of the emergency right away. Give the emergency operator your wireless phone number so the operator can call you back if the call gets disconnected If your wireless phone is not "initialized" (meaning you do not have a contract for service with a wireless service provider), and your emergency call gets disconnected, you must call the emergency operator back because the operator does not have your telephone number and cannot contact you. Refrain from programming your phone to automatically dial 911 when one button, such as the "9" key, is pressed Unintentional wireless 911 calls, which often occur when auto-dial keys are inadvertently pressed, cause problems for emergency call centers. If your wireless phone came pre-programmed with the auto-dial 911 feature already turned on, turn off this feature Check your user manual to find out how Lock your keypad when not using your wireless phone. This action also prevents accidental calls to 911. Create a contact in your wireless phone's memory with the name "ICE" (In Case of Emergency) listing the phone numbers of people who should be notified if there is an emergency.

Links to more 911 information

 Federal Communications Commission  National Emergency Number Association  Association of Public Safety Communications Officials  Emergency Services Interconnection Forum REDACTED - FOR PUBLIC INSPECTION

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Southern Linc is a wireless communications network backed by the strength and reliability of Southern Company - the parent company of three electric utilities in the Southeast: Alabama Power, Georgia Power, and Mississippi Power, which are also Southern Linc customers.

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RTT FAQs

What is Real-Time Text?

Real-time text, or RTT, is a new accessibility solution to replace text telephone (TTY) on Internet Protocol (IP) based networks like Southern Linc’s LTE network. With RTT, as soon as text is typed into a device, it is received in near real- time on the receiving device. Unlike today’s messaging applications that allow users to type desired content and press Send, RTT will send text immediately on a character-by-character basis without pressing Send. RTT will also include public safety enhancements, including allowing 911 centers to turn on audio during an RTT 911 session to listen in on what is happening around the RTT caller, even if the caller cannot speak or hear. Currently, no 911 centers have enabled RTT within Southern Linc’s Mission Critical LTE coverage footprint.

When will RTT be available on Southern Linc?

Southern Linc will offer RTT once fully incorporated into our handsets and network, including the ability to call 911. Check this page for updates, or contact [email protected] to receive email updates on RTT.

Currently, Southern Linc enables customers to text-to-911 in areas where the 911 center has enabled the interim text-to- 911 solution. For more information on calling or texting emergency services, visit our 911 and Text-to-911 website.

What are the benets of Real-Time Text (RTT) over TTY?

. For the disability community, RTT can eliminate the need to purchase specialized devices, such as TTY machines, to send text in real-time over wireless phones. 2. RTT uses the same ten-digit phone numbers as voice calls. 3. Both parties to a RTT session can simultaneously send and receive text, unlike TTYs, which require taking turns on who can transmit text. 4. RTT is more reliable than TTY over IP networks, which means there will be less drop-offs and garbling. 5. RTT utilizes the full international character set, unlike TTY, which does not allow symbols, emojis and other language characters. 6. Improved experiences in contacting 911 for the deaf and hearing-impaired community. REDACTED - FOR PUBLIC INSPECTION

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