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06/20/2001 Agreement CLERK OF THE CIRCUIT COURT MONROE COUNTY BRANCH OFFICE MARATHON SUB COURTHOUSE 3117 OVERSEAS HIGHWAY MARATHON, FLORIDA 33050 TEL. (305) 289-6027 FAX (305) 289-1745 MONROE COUNTY COURTHOUSE 500 WHITEHEAD STREET KEY WEST, FLORIDA 33040 TEL. (305) 292-3550 FAX (305) 295-3663 BRANCH OFFICE PLANTATION KEY GOVERNMENT CENTER 88820 OVERSEAS HIGHWAY PLANTATION KEY, FLORIDA 33070 TEL. (305) 852-7145 FAX (305) 852-7146 MEMORANDUM DATE: July 17, 2001 TO: Reggie Paros, Director Public Safety Division A TIN: Norm Leggett Emergency Communications Pamela G. Han('~ Deputy Clerk 0 FROM: At the June 20, 2001, Board of County Commissioner's meeting the Board granted approval and authorized execution of the E911 Phase I - Service Agreement between Monroe County and AT & T Wireless Services for compliance with the Federal Communications Commission (FCC) requirements for E911 Wireless Phase I implementation in Florida. Enclosed is a copy of the above mentioned for your handling. Should you have any questions please do not hesitate to contact this office. Cc: County Administrator wlo document County Attorney Finance File ,/ E911 PHASE I - SERVICE AGREEMENT AT&T WIRELESS SERVICES (A WS) Name: AT&T Wirplp~~ Sprvicp~ CARRIER CONTACT (24x7x365) Address: P () Rnv Q71\/;1 Name: see National nata Service eeqt~r ,.~ .... City: Rlld....."'Dd State: W A ZIP: 98073-9761 Phone Number: Fax Number: '\0'\ "Rl_"7R?' '- ," CARRIER NOTIFICATION: :':., . :-'j~~_l:.: ....~ ..--;.; -.J :.:J Name: F()_l_l Prf\ipl'f M an"gl'r or- ;::: ::ll: Address: P.O Rox 97061 Anticipated Deployment Date: City I ST I ZIP: ~ Name: --LtlDf\1 2J)<t LV V Nt! ~ Address: 5] &:0 Cf)L-L--~ 4 r ~) ~ City: kJi:....-'-f tJtsr P 1- ZIP: "3;;0 l.jl) CUSTOMER CONTACT (24x7x365) Name: Phone Number: Fax Number: CUSTOMER NOTIFICATION: Name: Address: City I ST I ZIP: >-By signing below, each person represents that he/she is authorized to commit their company or government entity to this E911 Phas :::J Order, i uding the terms and conditions stated below and on the reverse side. Date: ()-,e ~Q ~~fJt f'iWC,dVI; MNfOe, ~ IJ I~( Name!Title: Service Description: Pursuant to this Service Order ("Order"), Carrier shall provide E911 Phase I Service ("Service"), in compliance with Phase I of the Federal Communications Commission ("FCC") Order in Docket 94-102, as amended and the laws of the State of Florida, but only in such portions ofPSAP Service Jurisdictions that Carrier operates its wireless service. A copy of functional specifications of such Service is attached hereto as Exhibit A, along with plans for the testing and implementation process as agreed to by Carrier and PSAP ("implementation Plan"). Confidential Information: The confidentiality of any information provided by Carrier to PSAP shall be governed by the Florida Public Records Act, chapter 119, Florida Statutes. The parties acknowledge that Florida law protects trade secrets from disclosure. Term: This Order is effective on the date of PSAP's signature, ("Effective Date") and shall remain effective for one (1) year ("initial Term"). This Order shall automatically renew for successive one (1) year terms ("Subsequent Term") unless written notice of termination is given to the other party not less than ninety (90) days prior to the expiration of each Subsequent Term. Limitation of Liability: The parties acknowledge their respective immunities from liability are or may be granted by Federal and state laws, as amended from time to time. Each party will honor the other party's immunity to the full extent required by law. DelaylForce Majeure: Carrier shall perform services pursuant to Federal law, state law, and the Implementation Plan, but, to the extent allowed by Federal or state law, Carrier shall not be liable for any delays resulting from acts of third parties and acts of God. The parties further acknowledge that successful and timely provision of Service is contingent upon the timely performance of actions by and cooperation of many third parties, including, but not limited to, actions that must be completed by the 9-1-1 ProviderlLEC, PSAP, and the Host ALl Provider. Federal law establishes the deadline for implementation of Service. Nothing herein shall be construed to extend the deadline as established by governing Federal and state law, if applicable. No Third-Party Beneficiary Relationship or Liability Created: Carrier offers Service to PSAP solely as an aid in PSAP's provision of E911 Service. Carrier's provision of Service to PSAP does not create any relationship or obligation, direct or indirect, to any person or entity other than PSAP. DISCLAIMER OF WARRANTIES: THE PARTIES ACKNOWLEDGE THAT THIS ORDER IS A CONTRACT FOR THE PROVISION OF SERVICES. THE PARTIES AGREE THAT THE IMPLIED WARRANTIES OF MERCHANT ABILITY AND FITNESS FOR A PARTICULAR PURPOSE AND ALL OTHER WARRANTIES, EXPRESS OR IMPLIED, ARE EXCLUDED FROM THIS TRANSACTION AND SHALL NOT APPLY TO ANY SERVICES PROVIDED HEREUNDER. CARRIER AND ITS SUBCONTRACTORS EXPRESSLY EXCLUDE AND DISCLAIM ANY AND ALL WARRANTIES, GUARANTEES OR REPRESENTATIONS WHATSOEVER, EXPRESS OR IMPLIED, ORAL, WRITTEN OR OTHERWISE RELATED TO ANY EQUWMENT, FACILITIES, PEA TURES, REPAIR, MAINTENANCE AND TO ANY AND ALL GOODS AND SERVICES PROVIDED OR TO BE PROVIDED TO PSAP BY CARRIER OR ITS SUBCONTRACTORS. THERE ARE NO WARRANTIES THAT EXTEND BEYOND THE DESCRIPTION ON THE FACE HEREOF. Independent Contractor: Carrier's relationship with PSAP under this Order is that of an independent contractor. Assignment: The parties to this Order may not assign any of their rights nor delegate any of their obligations under this Order without the prior written consent of the other party (which consent shall not be unreasonably withheld), except that Carrier may assign its rights or delegate its duties under this Order to any of its affiliates, to the surviving entity in a merger or consolidation or to a purchaser of substantially all of the assets of the business to which this Order relates without PSAP's written consent. All the terms and provisions of this Order will be binding upon and inure to the benefit of and be enforceable by the parties and their respecti ve permitted successors and assigns. AmendmentIModification: Any provision of this Order may be amended upon mutual agreement of the parties, executed in writing, and the observance of any provision may be waived only in writing signed by a duly authorized representative of the parties. In addition, the Parties may also modify this Order upon thirty (30) days written notice, if there is a change in an applicable law or if Carrier should sell or otherwise dispose of all or part of its wireless communications service license for the provision of wireless communication service in any portion of the PSAP Service Jurisdictions. Upon such event, this Order may be modified only as appropriate to reflect such disposition. This shall include removal of the relevant area from this Order. Governing Law: The laws of the State in which the Service is provided govern this Order except as otherwise provided for herein, except for matters within the exclusi ve jurisdiction of the FCC. Entire Agreement: This Service Agreement, together with the attached Exhibit A, constitutes the entire agreement between the parties and supersedes all prior agreements or understandings, whether written or oral, with respect to the provision of E911 Phase I Service. Responsibilities of Carrier: Carrier shall implement Service pursuant to Federal law, state law, and the Implementation Plan, attached hereto as Exhibit "A", as agreed to by the parties. Nothing in Exhibit "A" herein shall be construed to extend the deadline as established by governing Federal and state law, if applicable. In addition, Carrier shall not initiate Service without written acknowledgment from PSAP of completion of testing and acceptance of Service, including but not limited to date and time of Service activation. Carrier shall reasonably cooperate with PSAP and all necessary third-parties in all aspects of implementing, scheduling, testing, verifying and operating Service, including notifying any and all parties of any network changes or changes in data to be delivered to premise equipment. Responsibilities of PSAP: PSAP shall: . have sole responsibility to answer, respond to, transfer, terminate or otherwise handle E911 telephone calls, to dispatch or arrange to dispatch emergency services; . furnish Carrier, at PSAP's reasonable expense, all technical matter, data and information as reasonably necessary under this Order; . provide reasonable access to PSAP's premises, as needed by Carrier or its subcontractors; . provide written acknowledgment of completion of testing and acceptance of Service to Carrier, including but not limited to date and time of activation of Service, prior to commercial use; . reasonably cooperate with Carrier and all necessary third-parties in all aspects of implementing, scheduling, testing, verifying and operating Service, including notifying any and all parties of any PSAP jurisdiction area changes or changes in data to be delivered to premise equipment. Acknowledgements: The parties acknowledge that: . These terms and conditions are for the parties' mutual benefit and should encourage the efficient and cooperative deployment of the Service . Carrier's reasonable costs for Service shall be paid pursuant to Florida Statutes Sections 365.172 and 365.173. The parties acknowledge that PSAP shall not be responsible for payment of Carrier costs, pursuant to governing law. DOCUMENT CONTINUES ON NEXT PAGE WIlli EXHmIT A AT&T Wireless Services Florida Model 9-1-1 Contract Exhibit "A" Section A-I IMPLEMENTA TION PLAN Task TarQet Date Comoleted Percent Resoonsibilitv Date Comolete Service Agreement Signed 3/19/01 TBD 0% A WS/PSAP Boundary Validation Completed 3/19/01 TBD 75% A WS/PSAP PSAP Inventory Completed 3/19/01 TBD 75% A WS/PSAP Order Facilities (MSC to SR) 4/19/01 TBD 0% AWS Routing Complete (routing & naming) 6/20/01 TBD 0% SCC/PSAP SCP Provisioned 7/4/01 TBD 0% SCC ALl and SR Provisioned 6/4/01 TBD 0% SCC/LEC Facilities (MSC to SR) installed/tested 6/15/01 TBD 0% LEC/ A WS MSC Provisioned 6/25/01 TBD 0% AWS Testing & Turn-up 7/16/01 TBD 0% AWS Deolovment PSAP Finish Monroe County Emergency Monroe County Communications Emergency July, 2001 TBD Communications Key West Police Department Monroe County Emergency July, 2001 TBD Communications Monroe County Sheriff's Office, Monroe County Stock Island Emergency July, 2001 TBD Communications Monroe County Sheriff's Office, Monroe County Marathon Emergency July, 2001 TBD Communications Ocean Reef Public Safety Monroe County Emergency July, 2001 TBD Communications This information is subject to change through a working together process. Deployment will occur approximately 120 days after Service Agreement is signed and Boundary Validation and PSAP Inventory Request are completed. 1 Section A-2 PHASE I E9-1-1 SERVICE ROLES AND RESPONSIBILITIES According to the terms and conditions, A WS agrees to act in good faith to implement and provide Phase I E9-1-1 Service to PSAP Entity, and PSAP Entity agrees to cooperate fully and work in good faith with A WS, Vendor and, where necessary as determined by A WS, third parties (such as the 9-1-1 Provider/LEC, Host ALl Provider, other public safety answering points, SCP software developers and hardware providers, and other suppliers and manufacturers) for the successful implementation and provision of Phase I E9-1-1 Service. A. Description of Service. 1. Definition of Phase I E9-1-1 Service. "Phase I E9-1-1 Service" shall mean the service by which A WS delivers to the designated PSAP the A WS Wireless End User's Call Back Number and Cell Site/Sector Information when an A WS Wireless End User has made a 9-1-1 Call. 2. Description of Call Flow. Once implemented, Phase I E9-1-1 Service generally shall work as described in the "Call Flow Description" set forth below; provided, however, that any aspect of this call flow process is subject to reasonable modification by A WS, in its discretion, as long as Phase I E9-1-1 Service is not thereby diminished. The Parties acknowledge and agree that the nature of the technology and other unforeseen circumstances may cause the call flow to vary from the general description set forth in Attachment 3 hereto. 3. Geographic Scope of Service. Subject to the terms and conditions of this Agreement, A WS agrees to implement and provide Phase I E9-1-1 Service to PSAP Entity within those portions of the PSAP Jurisdiction Areas in which A WS provides Service. B. Responsibilities of the Parties. In addition to any and all other obligations of the Parties set forth in this Agreement, the responsibilities of the Parties shall be as generally described in this Article III, and with respect to the routing of 9-1-1 Calls, as described more specifically below. 1. Responsibilities of A WS. It shall be A WS' s responsibility, in cooperation with PSAP Entity and necessary third parties (including, but not limited to, Vendor, 9-1-1 Provider/LEC, Host ALl Provider, other public safety answering points, SCP software developers and hardware providers, and other suppliers and manufacturers), to work in good faith to implement and provide Phase I E9-1-1 Service to PSAP Entity within the Phase I E9-1-1 Service Areas. This shall include the following: . participating in network design; . causing its network elements (such as the MSC and related data links and trunks) to be installed; . operating, maintaining and provisioning these network elements; . facilitating the development of a non-binding implementation plan which will establish target dates for actions necessary for installation and activation of Phase I E9-1-1 Service; . acquiring necessary software and equipment; . helping to form routing decisions as more specifically described in Attachment 4 hereto; . making good faith calculations of the number of A WS Subscribers on a regular basis as described in Section IV.B hereof; . billing the State Wireless 911 Board for A WS' reasonable costs for pursuant to Florida Statutes Sections 365.172 and 365.173; . entering into necessary interconnection agreements for interconnecting the MSC to Selective Router/E9-1-1 Tandems and for interconnecting the SCP to the ALl Database; 2 . supervising and maintaining this Agreement (including its Attachments) and any amendments hereto; and . working with Vendor to establish internal performance measures, including, but not limited to, metrics for call volumes, call set-up times, error resolutions and other critical measurements. Unless the Parties otherwise agree in writing, interconnection with the 9-1-1 ProviderlLEC will be performed with the use of Centralized Automatic Message Accounting trunks. All Selective Router/E9-l-l Tandem and ALl Database functions lie outside ofthe responsibility of AWS. 2. Responsibilities of PSAP Entity. It shall be PSAP Entity's responsibility to cooperate fully and work in good faith with A WS and, where necessary as determined by A WS, with third parties (including, but not limited to, Vendor, 9-1-1 ProviderlLEC, Host ALl Provider, other public safety answering points, SCP software developers and hardware providers, and other suppliers and manufacturers) for the successful implementation and provision of Phase I E9-l-l Service. This shall include the following: . as described more specifically in Attachment 4 hereto, validating PSAP Jurisdiction Area map boundaries, helping to form call routing criteria, awareness of A WS's alternate and default routing procedures, forming and implementing data management processes and notifying Vendor and AWS of needed PSAP Jurisdiction Area changes; . designating one "PSAP Entity Daily Contact" for general matters and one "PSAP Emergency Contact" at each PSAP to serve as a single point of contact available to A WS and Vendor on a 24x7x365 basis, as described more specifically in Section I1I.E.2 hereof; . cooperating in the development of a non-binding implementation plan which will establish target dates for actions necessary for installation and Activation of Phase I E9-l-l Service; . providing and verifying needed data about each PSAP's existing infrastructure and any other information necessary for successful installation, maintenance and provision of Phase I E9-l-1 Service; . identifying appropriate ESN Routing Codes; . informing third party vendors, such as Computer Aided Dispatch (CAD) providers, of data to be delivered with 9-1-1 Calls for coordination with PSAP premise-based systems; . providing reasonable documentation so as to facilitate the payment of A WS' costs pursuant to Florida Statutes Sections 365.172 and 365.173; . augmenting the trunks, if necessary, between a Selective Router/E9-l-l Tandem and any PSAP; . ensuring that all PSAP premises equipment (1) has adequate capacity to handle incoming circuits in accordance with industry standards, and (2) receives data in a format acceptable to PSAP Entity; . informing Vendor and A WS of any PSAP system changes that may affect Phase I E9-l-l Service; . cooperating to ensure that necessary changes, modifications and/or updates are made with respect to the ALl Database for successful receipt of Host ALl Records; . training 9-1-1 Operators to understand the data that they will receive about 9-1-1 Calls in connection with Phase I E9-l-l Service; . supporting all testing/verification activities to be undertaken by A WS or Vendor in relation to this Agreement, including, but not limited to, cooperating with all testing/verification activities that require 9-1-1 Operator feedback on call delivery and ALl display verification, participating in any testing/verification activities that require PSAPs to call back the tester's Wireless Handset (for both roamers and in-market calls), providing an acceptable number of testing/verification time slots for completion of all A WS testing/verification activities, and assisting A WS to secure cooperation from neighboring public safety answering points for any necessary testing/verification or emergency purposes; 3 . participating in state and regional informational and educational seminars as the Parties deem appropriate; and . cooperating in the creation of a trouble reporting mechanism and associated trouble resolution process. . Further, PSAP Entity, and not A WS, shall be solely responsible for any and all aspects of the emergency service PSAP Entity regularly provides, including, but not limited to, properly answering and responding to any and all 9-1-1 Calls made by A WS Wireless End Users. The parties acknowledge that PSAP shall not be responsible for payment of Carrier costs, pursuant to governing law. 3. Responsibilities of Third Parties. The Parties acknowledge that successful and timely provision of Phase I E9-l-1 Service is highly dependent on the timely performance of actions by and cooperation of many third parties, including, but not limited to, actions that must be completed by Vendor, the 9-1-1 Provider/LEC, and the Host ALl Provider (as such third parties' roles are described generally in Attachment 5 hereto), SCP software developers and hardware providers, and various other suppliers and manufacturers. 4 Section A-3 Call Flow Description The purpose of AWS' Phase I E9-1-1 Service is to provide the 9-1-1 Operator with a Call Back Number and general location information for 9-1-1 Calls. The process starts with a 9-1-1 Call being received at an A WS Cell Site when an A WS Wireless End User dials 9-1-1 (and, as necessary, presses the "Send" or analogous transmitting button) on a Wireless Handset. The Cell Site delivers the call to its MSC (the "switch" that controls all aspects of wireless calls). Recognizing the call as a 9-1-1 Call, the MSC sends the call to the SCP database provisioned with a special software applications and cell site database which immediately splits the call into two distinct paths: a voice path and a data path. Voice path. The MSC queries the SCP database, where the Emergency Services Routing Key ("ESRK") is assigned based on the originating Cell Site or Cell Sector and the PSAP serving that area. (The ESRK is used for routing and is not able to be dialed.) This number is immediately returned to the MSC for routing along with the caller's voice to the appropriate Selective Router/9-1-1 Tandem. In the Selective Router/9-1-1 Tandem, the voice call and the ESRK are routed to the appropriate PSAP using the Emergency Service Number (ESN) Routing Code assigned to the ESRK during the data development process. Data path. Concurrently, the ESRK is also attached to the data path at the SCPo The caller's Call Back Number is passed through the SCP, along with the ESRK, to the Host ALl Provider's ALl Database. At the ALl Database, the caller's Call Back Number and the Cell Site/Sector Information are inserted into the ESRK's Host ALl Record in preparation for the PSAP's ALl Database lookup request. When the voice call and ESRK arrive at the PSAP, the ESRK is used as the search-key for the corresponding ALl Database record. The ALl Database system delivers the resulting data stream of the caller's Call Back Number and the Cell Site/Sector Information to the PSAP, where it is displayed on the 9-1-1 Operator's computer screen. The 9-1-1 Operator will have the AWS Wireless End User on the line with the corresponding Call Back Number and a text description of the location of the A WS Wireless End User identified by Cell Site or Cell Sector. Thus, in most cases, the voice and data portions of the call appear simultaneously. PSAP Entity acknowledges that various factors can prevent the call flow process from working exactly as described above. Any aspect of this call flow process is subject to reasonable modification by A WS, in its discretion, as long as the Phase I E9-1-1 Service is not thereby diminished. Upon such modification, this Attachment 3 may be appropriately amended by A WS. 5 Section A-4 9-1-1 Call Routing 1. Boundary establishment and verification for each PSAP must be accomplished to generate routing recommendations for Phase I E9-1-1 Service. Vendor or A WS shall contact each PSAP regarding this process, and each PSAP shall promptly provide to A WS and Vendor a written description or a boundary map (or shall verify the accuracy of a boundary map provided by Vendor) of the total emergency coverage area served by that PSAP. PSAP Entity represents and warrants that any such map shall provide an accurate representation of each PSAP's Jurisdiction Area. PSAP Entity shall notify A WS and Vendor promptly of any inaccuracies or changes that need to be made to the map as soon as possible after PSAP Entity becomes aware ofthe inaccuracy or change. PSAP Entity shall establish a working relationship with Vendor for boundary maintenance, database management and operational aspects of the Phase I E9-1-1 system. 2. Each PSAP shall promptly provide to Vendor and A WS all other requested data and information (or verifications of data and information) about each PSAP and its existing infrastructure relevant to the provision of Phase I E9-1-1 Service. 3. Each PSAP shall promptly communicate to Vendor and A WS any and all special criteria related to the geographic conditions within each PSAP Jurisdiction Area, including, but not limited to, special handling needed for 9-1-1 Calls made along a certain transportation route or from major land features, such as shopping malls near the boundaries of two cities, athletic stadiums or college campuses. A WS and Vendor may not be able to honor all special criteria requests, but will make good faith efforts to do so. 4. Vendor and A WS shall work together to produce routing path recommendations that determine which PSAP shall receive a 9-1-1 Call (and Call Back Number and Cell Site/Sector Information) when a 9-1-1 Call is made within a particular Cell Sector (and to establish a default PSAP in the event that it is not clear from which Cell Sector a 9-1-1 Call has been made, or if trunk blockage or system problems prevent normal routing). After these recommendations are made, the Parties shall review them and propose any desired modifications to these proposed recommendations. As appropriate, routing recommendations for a PSAP shall be made in conjunction with those made for any other public safety answering points in neighboring areas, including those in other states. Based on these proposals, Vendor and A WS shall determine the routing path for 9-1-1 Calls made from each Cell Sector ("Routing Path Decisions"). The Routing Path Decisions shall be documented in writing by Vendor and distributed to PSAP Entity. A Routing Path Decision shall be deemed accepted by PSAP Entity unless it sends written notice of objection to Vendor within ten (10) days of its receipt of the Routing Path Decisions. Such notice shall include specific grounds for the objection. Upon such an objection, the Parties shall work in good faith to reach agreement with regard to the Routing Path Decision, and until such agreement is reached, the Routing Path Decision shall be as preferred by PSAP Entity, provided that it creates no conflict with routing path decisions made with other public safety answering points. 5. Once the Routing Path Decisions for the 9-1-1 Calls are decided, Vendor shall be responsible for coordinating the changes to be made in the Selective Router/E9-1-1 Tandem as to the ESRK for purposes of call handling. The Vendor shall also be responsible for establishing the SCP's routing of Cell Sectors to the PSAP Jurisdiction Areas. Vendor shall further be responsible for coordinating any required static data elements in the ALl Database. 6. Routing Path Decisions may be modified as necessary through a data update process maintained by A WS or Vendor. This includes changes to Routing Path Decisions made by the Parties in response to (1) changing local geographic details, (2) changes to Cell Site coverage areas, or (3) changes otherwise deemed necessary. In this respect, the data developed for routing of 9-1-1 Calls will be subject to additions, changes and deletions, similar to wireline data. 7. A WS Procedures for default and alternate routing are dependent upon switch capabilities and previous decisions made by other PSAP entities served by the same MSC/ Selective Router combination. 6 A WS P-rocedures relating to individual PSAP Entities will be documented as part of the Routing Path Decisions. Possible options for default and alternate routing are as follows: Default routing at the MSC: If a breakdown occurs in the data transfer process and A WS cannot determine which PSAP to send 9-1-1 calls to, the following options are available. A single choice is available per MSC: · A WS sends all calls to a single predetermined PSAP Default routing at the selective router: If a breakdown occurs in the data transfer process and the selective router cannot determine which PSAP to send a call to, a single PSAP, per trunk group, must be designated as the default PSAP. Alternate routing at the MSC: If trunk congestion occurs between the MSC and the selective router, the following options are available. A single option is available per MSe. · A WS sends calls to a single predetermined PSAP Alternate routing at the selective router If trunk congestion occurs between the Selective Router/E9-1-1 Tandem and the PSAP Entity, routing procedures are controlled by PSAP Entity and the LEe. PSAP Entity agrees to follow the same procedure for A WS Wireless End Users making 9-1-1 Calls as it does for wireline callers making emergency 9-1-1 calls. It is A WS' understanding that under such a scenario, the PSAP Entity will send a busy signal to the caller making a 9-1-1 Call. If this is not correct, please describe the correct PSAP Entity procedure here: Initials: PSAP Entity reserves the right to alter its procedure for this situation at any time upon written notice to A WS. PSAP Entity is responsible for any procedure it adopts for such situations. 7