    Telecommunications: Uneven Implementation of Wireless Enhanced
    911 Raises Prospect of Piecemeal Availability for Years to Come
    (07-NOV-03, GAO-04-55).

    When an emergency call is placed to 911, prompt response depends
    on knowing the location of the caller. Enhanced 911 (E911)
    service automatically provides this critical information. E911 is
    in place in most of the country for traditional wireline
    telephone service, where the telephone number is linked to a
    street address. Expanding E911 capabilities to mobile phones is
    inherently more challenging because of the need to determine the
    caller's geographic location at the moment the call is made.
    Concerns have been raised about the pace of wireless E911
    implementation and whether this service will be available
    nationwide. GAO reviewed the progress being made in implementing
    wireless E911 service, the factors affecting this progress, and
    the role of the federal government in facilitating the nationwide
    deployment of wireless E911 service.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-04-55
        ACCNO:   A08820
      TITLE:     Telecommunications: Uneven Implementation of Wireless
    Enhanced 911 Raises Prospect of Piecemeal Availability for Years
    to Come
         DATE:   11/07/2003
      SUBJECT:   Communication
    	     Emergency preparedness
    	     Federal funds
    	     Safety
    	     Surveys
    	     Cellular telephone
    	     Telephone
    	     Federal/state relations
    	     Strategic planning

    ******************************************************************
    ** This file contains an ASCII representation of the text of a  **
    ** GAO Product.                                                 **
    **                                                              **
    ** No attempt has been made to display graphic images, although **
    ** figure captions are reproduced.  Tables are included, but    **
    ** may not resemble those in the printed version.               **
    **                                                              **
    ** Please see the PDF (Portable Document Format) file, when     **
    ** available, for a complete electronic file of the printed     **
    ** document's contents.                                         **
    **                                                              **
    ******************************************************************
    GAO-04-55

    United States General Accounting Office

    GAO	Report to the Chairman, Subcommittee on Communications, Committee on

                   Commerce, Science, and Transportation, U.S. Senate

    November 2003

    TELECOMMUNICATIONS

      Uneven Implementation of Wireless Enhanced 911 Raises Prospect of Piecemeal
                             Availability for Years to Come

                                           a

    GAO-04-55

    Highlights of GAO-04-55, a report to the Chairman, Subcommittee on
    Communications, Committee on Commerce, Science, and Transportation, U.S.
    Senate

    When an emergency call is placed to 911, prompt response depends on
    knowing the location of the caller. Enhanced 911 (E911) service
    automatically provides this critical information. E911 is in place in most
    of the country for traditional wireline telephone service, where the
    telephone number is linked to a street address. Expanding E911
    capabilities to mobile phones is inherently more challenging because of
    the need to determine the caller's geographic location at the moment the
    call is made. Concerns have been raised about the pace of wireless E911
    implementation and whether this service will be available nationwide. GAO
    reviewed the progress being made in implementing wireless E911 service,
    the factors affecting this progress, and the role of the federal
    government in facilitating the nationwide deployment of wireless E911
    service.

    In order to provide the Congress and federal and state officials with an
    accurate assessment of the progress being made toward full deployment of
    wireless E911, we are recommending that the Department of Transportation
    work with state officials and public safety groups to develop data
    identifying which PSAPs will need to have E911 equipment upgrades. In
    response, DOT stated that it generally agreed with our recommendation.

    www.gao.gov/cgi-bin/getrpt?GAO-04-55.

    To view the full product, including the scope and methodology, click on
    the link above. For more information, contact Mark Goldstein at (202)
    512-6670 or goldsteinm@gao.gov.

    November 2003

    TELECOMMUNICATIONS

    Uneven Implementation of Wireless Enhanced 911 Raises Prospect of Piecemeal
    Availability for Years to Come

    Implementation of wireless E911 is several years away in many states,
    raising the prospect of piecemeal availability of this service across the
    country for an indefinite number of years to come. Successful
    implementation depends on coordinated efforts by wireless carriers, local
    telephone companies, and more than 6,000 public safety answering points
    (PSAPs)-the facilities that receive 911 calls and dispatch assistance.
    According to a database sponsored by the Department of Transportation
    (DOT), as of October 2003, nearly 65 percent of PSAPs had Phase I wireless
    E911 service, which provides the approximate location of the caller, while
    only 18 percent had Phase II, which provides a more precise location and
    is the ultimate goal of wireless E911 service. Though valuable, the
    database does not differentiate between PSAPs that will require equipment
    upgrades and those that will not, thereby limiting its usefulness in
    accurately assessing progress toward full implementation. Looking forward,
    24 state 911 contacts said in response to a GAO survey that their state
    will have Phase II implemented by 2005 or sooner; however, all other state
    contacts estimated dates beyond 2005 or were unable to estimate a date.

    Key factors hindering wireless E911 implementation involve funding and
    coordination. The wireless carriers, states, and localities must devise
    the means to fund more than $8 billion in estimated deployment costs over
    the next 5 years. Some states and localities have established funding
    mechanisms (such as E911 surcharges on phone bills), but others have not
    done so or have used their E911 funds for unrelated purposes. In addition,
    there is also a lack of coordination in some cases among the wireless
    carriers, local telephone companies, and PSAPs that can lead to delays in
    wireless E911 implementation. States with knowledgeable and involved
    coordinators were best able to work through these coordination issues.

    The Federal Communications Commission (FCC) and DOT are involved in
    promoting wireless E911, but their authority in overseeing its deployment
    is limited because PSAPs traditionally fall under state and local
    jurisdiction. FCC has set deadlines on the wireless carriers' E911
    responsibilities and has taken actions to identify best practices and
    improve coordination among the parties. DOT is developing an action plan
    and clearinghouse for wireless E911 planning, implementation, and
    operations.

    Call Taker Station at a Public Safety Answering Point

    Contents

      Letter

    Results in Brief
    Background
    Nationwide Phase I Deployment Is More Than Halfway Complete,

    but Full Phase II Deployment May Be Years Away

    Funding and Coordination Are Key Factors Affecting Current
    Wireless E911 Deployment, with New Wireless Services Posing
    Future Challenges

    The Recent Actions of FCC and DOT Are Focused on Enforcing
    Deadlines on Wireless Carriers and Improving Deployment
    Coordination

    Conclusions
    Recommendation for Executive Action
    Agency Comments

    1 4 6

    12

    17

    25 28 29 29

    Appendixes

    Appendix I: Scope and Methodology 31

    Appendix II:	FCC Consumer Advisory about Calling 911 from Your
    Wireless Phone 33

    Appendix III:	GAO Contacts and Staff Acknowledgments 36
    GAO Contacts 36
    Staff Acknowledgments 36

    Figures	Figure 1:
    Figure 2:
    Figure 3:
    Figure 4:

    Call Taker Handling a 911 Call at a Public Safety
    Answering Point 7
    Simplified Wireless E911 Call to PSAP with Phase II
    Capability 9
    Percentage of Counties, by State, That Have Implemented
    Wireless E911 Phase I and Phase II as of October 2003 14
    Estimates by State 911 Contacts of Year Their State Would
    Have Phase II Wireless E911 Fully Implemented (Includes
    the District of Columbia) 16

    Contents

    Abbreviations

    DOT Department of Transportation
    E911 enhanced 911
    FCC Federal Communications Commission
    GPS Global Positioning System
    LEC local exchange carrier
    NENA National Emergency Number Association
    PSAP public safety answering point

    This is a work of the U.S. government and is not subject to copyright
    protection in the United States. It may be reproduced and distributed in
    its entirety without further permission from GAO. However, because this
    work may contain copyrighted images or other material, permission from the
    copyright holder may be necessary if you wish to reproduce this material
    separately.

    A

    United States General Accounting Office Washington, D.C. 20548

    November 7, 2003

    The Honorable Conrad Burns
    Chairman
    Subcommittee on Communications
    Committee on Commerce, Science, and Transportation
    United States Senate

    Dear Mr. Chairman:

    In 2001, Americans placed almost 57 million emergency calls to 911 using
    mobile phones. According to the Federal Communications Commission
    (FCC), around one-third of 911 calls are now made from mobile phones.
    With almost 150 million Americans now subscribing to a mobile phone
    service and new concerns about homeland security facing our nation, the
    ability to reach 911 from sidewalks, highways, and rural areas has become
    increasingly important. Knowing the precise location of a 911 caller
    facilitates the quick and accurate dispatch of emergency responders such
    as police, firefighters, and ambulance crews. However, in some cases, 911
    callers cannot speak (e.g., a caller who is suffering a heart attack) or
    simply
    do not know their location (e.g., a caller reporting an accident along a
    highway).

    For traditional wireline phones, most areas across the country now employ
    "enhanced 911" (E911) services, where the caller's address automatically
    appears on-screen for the 911 call taker. The increasing use of mobile
    phones led to concerns by the Congress and others in the federal
    government and the public safety community that E911 location
    information is often not available for citizens dialing 911 from a mobile
    phone. However, implementing wireless E911 is inherently more
    challenging than wireline E911. Unlike wireline phones, where the phone
    number is linked to a specific street address, providing location
    information for a mobile phone involves technologies that must calculate
    the geographic coordinates of the caller at the time of the call and
    display
    those coordinates as a location the 911 call taker can understand.
    Moreover, a wireless 911 call is routed along the networks of both a
    wireless telephone company and a wireline telephone company before
    terminating at a facility where 911 calls are answered, known as a public
    safety answering point (PSAP). There are more than 6,000 of these
    answering points nationwide, often at a county or city level. All three of
    these entities-wireless carriers, wireline carriers, and public safety
    answering points-must be properly interconnected and have certain

    equipment in place before wireless 911 calls can be correctly routed and
    E911 location information sent with the call.

    At the federal level, FCC and the U.S. Department of Transportation (DOT)
    have taken steps to promote the deployment of E911 location technologies
    for mobile phones. Deployment usually proceeds in two phases: Phase I
    provides general location information by identifying the cell site1 and
    cell sector2 receiving the wireless call as well as the telephone number
    of the caller; Phase II provides a more precise location by determining
    the latitude and longitude of the caller, which can be electronically
    displayed on a map. Currently, the only federally mandated time frames for
    installation of wireless E911 technologies are those placed on wireless
    carriers by FCC. These time frames vary by wireless carrier and by the
    type of location technology the carrier has selected, and currently extend
    out to December 31, 2005. However, FCC has no authority to place time
    frames on the public safety answering points, which are under state and
    local jurisdiction. As a result, there is no ultimate nationwide deadline
    for full implementation of wireless E911 services. FCC has technical and
    educational initiatives under way to help the parties involved to share
    information on deployment practices, problems, and experiences. Also, DOT
    has recognized the relationship between wireless E911 services and highway
    safety and is working with a key nongovernmental organization, the
    National Emergency Number Association (NENA), to develop a PSAP database
    that tracks E911 implementation.3 DOT is also working to promote research,
    planning, and education related to wireless E911 services.

    1Wireless carriers deliver mobile phone service by subdividing large
    geographic areas into smaller sections called cells. Each cell has a base
    station equipped with one or more antennas to receive and transmit radio
    signals to the mobile phones within its coverage area. The distance
    covered by the base station can range from less than a mile to 20 miles.
    For more information on cell phones, see U.S. General Accounting Office,

    Telecommunications: FCC Should Include Call Quality in Its Annual Report
    on Competition in Mobile Phone Services, GAO-03-501 (Washington, D.C.:
    Apr. 28, 2003).

    2The cell sector refers to the coverage area of a cellular antenna. Cell
    sites often contain three antennas, which define three unique coverage
    areas or sectors, helping to narrow the field of search for the wireless
    caller.

    3NENA is a membership organization of emergency communications
    professionals in government and industry that fosters the technological
    advancement, availability, and the implementation of a universal emergency
    telephone number system. The database is accessible through
    http://www.nena.org.

    The pace of wireless E911 deployment has been a key concern for the
    Congress. The Wireless Communications and Public Safety Act of 1999
    designated 911 as the universal emergency telephone number within the
    United States and called on FCC to encourage and support efforts by the
    states to deploy wireless E911 services by working with state and local
    officials, the telecommunications industry, consumer groups, and those
    involved in public safety services.4 There is also a Congressional E911
    Caucus that aims to educate lawmakers, constituents, and communities about
    the importance of 911 systems.5 You asked us to provide an overview of the
    deployment of wireless E911 services across the country. We agreed to
    provide information on (1) the progress made in deploying wireless E911
    services throughout the country, (2) the factors that are affecting this
    progress, and (3) current federal government actions to promote the
    deployment of wireless E911 services.

    4Pub. L. No. 106-81, 113 Stat. 1286 (1999). According to its purpose
    section, the act is meant to "encourage and facilitate the prompt
    deployment throughout the United States of a seamless, ubiquitous, and
    reliable end-to-end infrastructure for communications, including wireless
    communications, to meet the Nation's public safety and other
    communications needs."

    5The establishment of the E911 Institute, a not-for-profit organization
    that will support the work of the Congressional E911 Caucus, was announced
    in July 2003. More information can be found at the organization's Web
    site, www.e911institute.org.

    To address these issues, we interviewed representatives of the various
    parties involved in wireless E911 implementation. We selected nine states
    (California, Idaho, Indiana, Kentucky, Maryland, Missouri, South Carolina,
    Texas, and Virginia) and the District of Columbia as case studies.6 For
    each case study, we interviewed representatives of a public safety
    answering point in both an urban and rural area of the state.7 We also
    interviewed the state's 911 coordinator and representatives of one small
    wireless carrier8 serving the state.9 In addition to our case studies, we
    interviewed companies providing wireless telephone services nationwide,
    companies providing local wireline telephone services, and a manufacturer
    of mobile telephones. We interviewed federal, state, and local government
    officials involved in wireless E911 implementation and representatives
    from several public safety associations and wireless industry
    associations. Lastly, we conducted a telephone survey of the state 911
    contacts in all 50 states and the District of Columbia (these individuals
    were designated by the governor of each state as the E911 point of contact
    and are listed on FCC's Web site) to obtain an overview of implementation
    efforts across the country. A more detailed discussion of our scope and
    methodology is found in appendix I.

    Results in Brief	Implementation of wireless E911 is several years away in
    many states, raising the prospect of piecemeal availability of this
    service across the country for an indefinite number of years to come.
    According to a DOT-sponsored database, as of October 2003, nearly 65
    percent of the more than 6,000 public safety answering points nationwide
    are receiving Phase I

    6We selected states that were spread geographically across the United
    States and that appeared to be having various levels of success with
    wireless E911 implementation based on early research. In particular, we
    selected at least one rural state and at least one state known to have
    redirected funds collected for E911 implementation to other uses.

    7There were exceptions to this in one state and the District of Columbia.
    California has no rural public safety answering points that take wireless
    calls, so we interviewed the California Highway Patrol, which handles most
    of the wireless 911 calls in California. The District of Columbia has only
    one public safety answering point.

    8For purposes of our case studies, a small wireless carrier was considered
    any wireless carrier other than the six large nationwide wireless carriers
    (AT&T Wireless, Cingular, Nextel, Sprint, T-Mobile, and Verizon Wireless).

    9Again, there were exceptions to this in one state and the District of
    Columbia. We were unable to schedule an interview with a small wireless
    carrier in Missouri, and the District of Columbia is not served by any
    small wireless carriers.

    location information, but only about 18 percent are receiving Phase II
    location information. Although the DOT-sponsored database has greatly
    increased the amount of information available about E911 progress, the
    database does not differentiate between public safety answering points
    that will require equipment upgrades and those that will not. This limits
    its usefulness in accurately assessing progress toward full
    implementation. Looking forward, 24 state 911 contacts said in response to
    a GAO survey that their state will have Phase II implemented by 2005 or
    sooner; however, all other state contacts estimated dates beyond 2005 or
    were unable to estimate a date.

    Lack of funding for equipment upgrades and a lack of coordination among
    the parties involved are factors slowing the pace of the rollout of
    wireless E911 technologies. Based on our interviews, lack of state or
    local funding is the largest factor affecting the progress of wireless
    E911. No federal funding was provided to the states and localities to
    cover the cost of E911 implementation, estimated to be at least $8 billion
    over the next five years. Our survey of state contacts showed that 39
    states and the District of Columbia have put in place a surcharge on
    wireless customers to pay for E911 upgrades to public safety answering
    points. Yet, some states have no funding mechanism in place and even those
    that do sometimes redirect the collected funds to uses unrelated to
    wireless E911 implementation. Another factor slowing wireless E911
    rollouts is a lack of coordination among the parties involved. This
    problem has been avoided in some localities with early coordination
    meetings among all the parties, where personal contacts can be established
    and early concerns raised and addressed. We were told by many of those we
    interviewed that states with knowledgeable and involved state coordinators
    have had an easier time with coordination and with public safety answering
    point readiness. Technologically, the main hurdle of developing wireless
    location equipment for mobile phones has been solved, but the continuing
    emergence of new wireless devices and services has the potential to
    overburden the current 911 infrastructure.

    The federal government has been involved in the promotion of wireless
    E911, but has limited authority over the entire process. FCC has
    concentrated its regulatory efforts toward the wireless carriers, where it
    has the most enforcement authority. FCC has established implementation
    schedules with each of the major wireless carriers and has recently taken
    enforcement actions against wireless carriers that failed to meet
    deadlines. According to FCC, the Commission does not have clear
    jurisdiction over wireline carriers with regard to wireless E911
    implementation and looks to

    the state public utility commissions, which have clear and sufficient
    authority, to take the lead. However, FCC has said it will monitor the
    wireline carriers' efforts to ensure that they are meeting their
    responsibilities with regard to E911 deployment. In April 2003, FCC held
    the first coordination initiative meeting to bring the parties involved in
    E911 together and has established a technical group to examine relevant
    E911 infrastructure issues. DOT is developing an action plan and
    clearinghouse for wireless E911 planning, implementation, and operations.
    FCC and DOT coordinate their wireless E911 activities to avoid duplication
    of effort. However, the agencies do not jointly staff or fund any wireless
    E911 projects.

    To address the limitations in the DOT-sponsored database on public safety
    answering points' readiness for wireless E911 service, we are recommending
    that the department work with state officials and public safety groups to
    develop a more accurate assessment of the number and location of answering
    points that still need equipment upgrades. A draft of this report was
    provided to DOT and to FCC. In commenting on the draft of this report, DOT
    stated that it generally agreed with the report's recommendation, and FCC
    offered some technical comments that were incorporated where appropriate.

    Background	Basic wireline 911 service provides an easily remembered
    universal number that connects the caller with an emergency response
    center, known as a public safety answering point (PSAP) (see fig. 1).10
    The next step after basic wireline 911 service is "enhanced 911" (E911),
    which automatically routes the emergency call to the appropriate PSAP and
    transmits to the call taker the telephone number (the "callback number,"
    should the call be disconnected) and street address of the caller.
    Nationwide implementation of E911 by local wireline telephone companies,
    known as "local exchange carriers" (LEC), began in the 1970s without a
    federal mandate or deadlines governing the rollout. By 1987, 50 percent of
    the United States' population could reach emergency services through
    wireline 911. Today, 99 percent of the population is covered by

    10PSAPs vary in size and technical sophistication. Some large urban PSAPs
    have dozens of call takers and split the functions of call taking and
    dispatching the proper emergency responder. Smaller PSAPs are sometimes
    staffed by only two or three call takers who also handle dispatch. In some
    rural areas, the PSAP may be the sheriff's office.

    wireline 911 service, and 93 percent of that coverage includes the
    delivery of a callback number and location information.

    Figure 1: Call Taker Handling a 911 Call at a Public Safety Answering
    Point

    In the early 1990s, FCC took note of the rising number of mobile telephone
    subscribers and the resulting increase in 911 calls. In 1994, FCC
    requested comments on requiring wireless carriers to provide the same
    level of 911 service that was available from LECs. In 1996, with input
    from the industry and public safety community, FCC adopted rules for
    wireless E911 that established an approach consisting of two phases for
    implementation by the wireless carriers. FCC also set schedules for
    implementing both basic and enhanced wireless 911 services, determined
    accuracy requirements and deployment schedules for location technologies,
    and outlined the role of PSAPs. Specifically, the phases required the
    following:

    o 	Phase I required that by April 1998, or within six months of a request
    from a PSAP, whichever was later, wireless carriers were to be prepared to
    provide the PSAP with the wireless phone number of the caller and the
    location of the cell site receiving the 911 call.

    o 	Phase II required that by October 2001, or within 6 months of receiving
    a request from a PSAP, whichever was later, wireless carriers were to be
    prepared to provide the PSAP with Phase I information plus the latitude
    and longitude coordinates of the caller within certain standards of
    accuracy.

    In 1996, when these rules were established, the technology to accurately
    locate a caller on a mobile telephone had not yet been perfected, but a
    "network based" solution was anticipated. With this type of solution, a
    caller is located through a triangulation process using the closest cell
    towers.11 However, as location technology was being developed, a "handset
    based" solution (i.e., one using the wireless phone itself) was made
    available. The most common handset solution also relies on triangulation,
    but uses Global Positioning System (GPS) satellites and a GPS chip inside
    the handset.12 In recognition of this second solution, FCC issued rules in
    October 199913 for carriers that selected handset-based location
    technologies.14 In August 2000, FCC adopted modifications to its rules for
    handset-based solutions and said that even if a PSAP has not made a
    request for Phase II wireless E911 service, wireless carriers deploying a
    handset-based solution must ensure that by December 31, 2005, 95 percent
    of their customers have mobile phones capable of providing automatic
    location information.15

    A typical wireless 911 call is routed along both wireless and wireline
    networks before terminating at the PSAP. See figure 2 below. While the
    voice call is taking place over the wireless and wireline networks,
    several

    11Triangulation is a method of locating the source of a radio signal,
    generally through the use of three receivers, or antennas.

    12The most commonly used handset-based solution is "assisted GPS," in
    which some of the processing is carried out in the network to improve
    system performance.

    13In the Matter of Revision of the Commission's Rules to Ensure
    Compatibility with Enhanced 911 Emergency Calling Systems, CC Docket No.
    94-102, Third Report and Order, FCC 99-245 (released Oct. 6, 1999).

    14A third approach to caller location is known as "enhanced observed time
    difference of arrival," which is regarded as a hybrid because the required
    measurements are distributed between the handset and the network.

    15In the Matter of Revision of the Commission's Rules to Ensure
    Compatibility with Enhanced 911 Emergency Calling Systems, CC Docket No.
    94-102, Fourth Memorandum Opinion and Order, FCC 00-326, (released Sept.
    8, 2000).

    The increased complexity of Phase II also makes it more costly than Phase
    I to implement. To date, the federal government has played no role in
    financing the rollout of wireless E911 services. Wireless carriers must
    finance the implementation of a caller location solution and test
    equipment to verify accuracy. LECs are generally responsible for ensuring
    that all the necessary connections between wireless carriers, PSAPs, and
    databases have been installed and are operating correctly. PSAPs purchase
    telephone services from the LECs. Because the typical underlying wireline
    E911 network is unable to carry the additional wireless E911 information,
    PSAPs often must purchase a separate data link and connection from the
    LEC. In order to translate the latitude and longitude location information
    into a street address, PSAPs usually purchase and install mapping
    software. PSAPs may also need to acquire new computers to receive and
    display this information.

    In short, three parties-the wireless carriers, LECs, and PSAPs-must
    interconnect and install equipment in order for wireless E911 calls to be
    completed and the caller location information to be sent with the call.
    However, no single entity has regulatory authority and oversight over the
    entire implementation process. FCC has considerable regulatory authority
    over wireless carriers and has placed location accuracy standards and
    deployment deadlines on the wireless carriers. State public utility
    commissions have some authority over wireless carriers' terms and
    conditions of service. The state public utility commissions also have a
    great deal of authority over the LECs, including authority over intrastate
    service rates, while FCC retains some authority over LEC interconnection
    agreements with wireless carriers and other issues. PSAP readiness remains
    a state and local issue because PSAPs serve an emergency response function
    that has traditionally fallen under state or local jurisdiction. The
    manner in which the more than 6,000 PSAPs across the country are
    administered and funded-at a state, county, city, or other political
    subdivision level-varies from state to state. According to FCC, the
    Commission has no authority to set deadlines for PSAPs' deployment of the
    equipment they need in order to receive caller location information from
    the wireless carriers. Setting such deadlines on PSAPs would be a matter
    for states and localities.

    Another federal agency with an interest in this issue is DOT. According to
    DOT, its involvement stems from the department's mandate to handle issues
    of traffic safety and from a directive from the Secretary of
    Transportation to become involved in wireless E911 issues. DOT officials
    noted that wireless phones have become crucial to reporting highway

    accidents and getting ambulances or other assistance to the scene. As will
    be discussed below, DOT is involved in several initiatives to track the
    progress of E911 deployment and help promote wireless E911 services,
    especially at the state and local level.

    As the original Phase II deadline of October 2001 approached, the six
    large national wireless carriers (which provide service to approximately
    75 percent of wireless telephone subscribers) requested waivers because
    the location technology was not ready for implementation. In granting the
    waivers, FCC negotiated different deadlines with each of these carriers,
    based on the carrier-specific Phase II compliance plans. The FCC also
    required these carriers to file detailed quarterly reports regarding
    implementation. In July 2002, FCC also granted temporary relief from the
    Phase II deadlines to those non-nationwide midsize and small wireless
    carriers that had requested relief.16 Currently, all wireless carriers
    that have chosen to deploy a handset-based location solution remain under
    a deadline of having handsets containing location technologies in use by
    95 percent of subscribers by December 31, 2005. Yet, despite this
    deadline, Phase II service is not assured in any area by any specific
    date. This is because all wireless carriers must respond within 6 months
    to a PSAP request for the delivery of wireless E911 location
    information.17 PSAPs, however, are under no federal deadlines to ever
    request wireless E911 services. Thus, the full rollout of wireless E911
    services nationwide depends in great part on the implementation efforts of
    the more than 6,000 PSAPs.

    16On October 10, 2003, the FCC issued a six-month stay of applicable
    provisions of E911 rules, or until it decides on the merits, whichever is
    shorter, with regard to all pending petitions of small wireless carriers
    seeking relief. In the Matter of Revision of the Commission's Rules to
    Ensure Compatibility with Enhanced 911 Emergency Calling Systems, CC
    Docket No. 94-102, Order to Stay, FCC 03-241 (Oct. 10, 2003).

    17Under FCC rules, however, a wireless carrier and a PSAP can mutually
    agree to a time frame other than a 6-month response. 47 C.F.R.
    S:20.18(j)(5).

      Nationwide Phase I Deployment Is More Than Halfway Complete, but Full Phase II
      Deployment May Be Years Away

    Based on the best data that is available, nearly 65 percent of PSAPs
    across the nation have implemented Phase I and 18 percent have implemented
    Phase II with at least one wireless carrier providing location
    information. However, there is still a lack of information regarding how
    many of the more than 6,000 PSAPs will need to upgrade their equipment,
    making it difficult to accurately measure the progress of wireless E911
    implementation. Looking forward, our survey of state 911 contacts found
    that less than half of them believe that wireless E911 services will be
    fully in place in their state by 2005. This raises the prospect that E911
    implementation will be piecemeal both within states and across the nation
    for an indefinite number of years to come.

        Eighteen Percent of PSAPs Have Implemented Phase II, but Measuring Progress
        toward Full Deployment Is Hampered by Data Problems

    Currently, the single best information source for tracking the progress
    being made in deploying wireless E911 service at the local level comes
    from DOT and the National Emergency Number Association (NENA). DOT
    contracted with NENA to create a database of counties and the PSAPs within
    the counties to provide information about implementation of wireless E911.
    This database is updated every quarter using wireless carrier information
    filed with the FCC, and supplemented by data gathered directly from PSAPs.
    Prior to the creation of this database, the only national data available
    about PSAPs that existed comprised information about NENA's membership,
    and that information did not include all PSAPs or track E911 deployments.
    Thus, the DOT/NENA initiative has provided a key instrument for measuring
    wireless E911 implementation.

    According to NENA, as of October 2003, nearly 65 percent of PSAPs
    nationwide had implemented Phase I wireless E911 services, which provides
    the call taker with the callback number and the location of the cell tower
    and cell sector receiving the 911 call. Phase II, which locates the caller
    with more precise geographic coordinates, has been implemented with at
    least one wireless carrier in 18 percent of PSAPs. As part of our survey
    of state 911 contacts, we asked respondents about their states' progress
    on Phase I and Phase II deployments. The responses to our survey were not
    complete because some state contacts were uncertain about their

    state's current status.18 However, for the 33 states and the District of
    Columbia from which we did receive responses, we found that percentages
    for Phase I and Phase II implementation were consistent with NENA's data.

    The percentages of counties that have implemented wireless Phase I and
    Phase II E911 service are illustrated, by state, in figure 3. The
    percentages are based on GAO's analysis of NENA data as of October 2003.

    18The state contacts were taken from a list provided on FCC's Web site.
    The names were provided to FCC by the governor of each state. However, not
    all state contacts were actively involved in E911 issues, and some could
    provide only limited responses to our questions. We did speak with others
    suggested by the state contacts in some of our surveys. See appendix I for
    more information about our survey.

    Measuring the progress of wireless E911 implementation against the goal of
    full nationwide Phase II deployment depends on being able to compare the
    number of PSAPs that are receiving wireless Phase II location data with
    the universe of PSAPs that need to be upgraded. We found, however, that
    there is a lack of accurate information on the total number of PSAPs that
    need to be upgraded. NENA has determined that there are 6,143 PSAPs
    nationwide. However, this number includes both "primary" and "secondary"
    PSAPs. A primary PSAP is defined by NENA as a PSAP to which 911 calls are
    directly routed; a secondary PSAP only receives calls that have been
    transferred, or passed along, from a primary PSAP. Generally, primary and
    secondary PSAPs have been included in the total number of PSAPs that need
    to be capable of receiving wireless E911 information.

    However, our survey results of state 911 contacts, along with our case
    study interviews, indicate that some states do not plan to upgrade their
    secondary PSAPs. For example, in North Carolina, state statute only
    permits primary PSAPs to be funded for wireless E911; in Kentucky,
    Virginia, and Washington, state funds to help finance wireless E911
    upgrades are only available to primary PSAPs; in Maryland, the issue is
    currently under discussion, although consolidating secondary PSAPs with
    primary ones has been considered. In addition, some secondary PSAPs are so
    small that they may never need wireless E911 equipment. Currently, the
    DOT/NENA database does not differentiate between PSAPs that will need to
    be upgraded and those that will not, which limits usefulness of the
    database in accurately assessing progress toward full wireless E911
    implementation.

    For its part, FCC requires large and midsize wireless carriers that have
    filed for relief from deployment deadlines to provide information
    quarterly on their progress in implementing Phase I and Phase II. Until
    recently, the data submitted by the carriers and available from FCC were
    organized by carrier, not by state or county, and were not easily sorted
    to provide information concerning the status of wireless E911 deployment.
    However, as of August 1, 2003, FCC also began requiring the large and
    midsize wireless carriers to submit data in an electronic spreadsheet
    format regarding deployment of Phase I and Phase II by PSAP. Because this
    spreadsheet has several fields, including the state, researchers can
    search by field and have numerous options for organizing the data. In
    addition, small wireless carriers, which had also requested relief, also
    were required to file one interim report with FCC about their E911
    progress on August 1, 2003. Based on the August filings, FCC told us that
    most of the large and

    midsize carriers appear to be making good progress toward readying their
    networks to respond to PSAP requests for E911 services.

        State 911 Contacts Offered a Wide Range of Estimated Phase II Completion
        Dates

    In our survey of state 911 contacts (which included the District of
    Columbia), we asked respondents to provide us with an estimate of when
    they believed their state would have wireless Phase II E911 fully in place
    for at least one wireless carrier per PSAP. Twenty-four of 51 respondents
    said they thought Phase II would be fully in place in their state by 2005,
    the last year for which there is any specific FCC deadline on wireless
    carriers. Six of those 24 respondents said they would be ready by 2003.
    Contacts in other states were either unwilling to commit to any specific
    year, given their current level of implementation, or estimated a date in
    2006 or beyond. See figure 4.

    Figure 4: Estimates by State 911 Contacts of Year Their State Would Have
    Phase II Wireless E911 Fully Implemented (Includes the District of
    Columbia)

    Number of respondents

    18

    16 16

    14

    12

    10

    8

    6

    4

    2

    0

    2003 2004 2005 2006 Unable to or later estimate

    Estimated year

    Source: GAO state survey (June to September 2003).

    As the estimates from state contacts indicate, no clear picture is
    emerging on when Phase II will be fully deployed nationwide, raising the
    prospect of piecemeal availability of this service across the country for
    an indefinite number of years to come.

      Funding and Coordination Are Key Factors Affecting Current Wireless E911
      Deployment, with New Wireless Services Posing Future Challenges

    As of October 2003, NENA estimates that over the next 5 years the
    nationwide cost to deploy Phase II will be between $8 billion and $9
    billion, including capital and incremental operating expenses. Funding for
    PSAP equipment upgrades remains a major issue for many states and
    localities and continues to hamper nationwide deployment. Not all states
    have implemented a funding mechanism for wireless E911, and of those that
    have, some have redirected E911 funds to unrelated uses. In addition, poor
    coordination among the parties is a factor affecting wireless E911
    deployment, although some states and localities have eased this problem
    with active and knowledgeable state 911 coordinators who help oversee the
    process and work with all the parties. Technologically, the main hurdle of
    developing wireless location equipment for mobile phones has been solved,
    but the continuing emergence of new wireless devices and services has the
    potential to overburden the current 911 infrastructure.

        Ongoing Problems with State and Local Funding of Equipment Upgrades Are
        Hampering the Deployment of Wireless E911

    It is costly to implement wireless E911 services. PSAPs need money to
    upgrade their systems and equipment and to purchase new software to
    receive and display caller location information. Wireless carriers incur
    costs associated with handset and network upgrades, engineering design,
    upgrading hardware and software, and maintaining the system. The LECs also
    incur costs, but generally these are paid for by the PSAPs as they
    purchase 911 services and upgrades from the LECs. Currently, funding must
    come from sources other than the federal government, which has not
    provided funding to PSAPs or wireless carriers for wireless E911 or
    established guidelines on how wireless E911 should be funded.

    At present, it is up to state and local governments to determine how to
    pay for PSAP wireless E911 upgrades. To cover the costs associated with
    implementing wireless E911, responses to our survey showed that the
    majority of states (39 states plus the District of Columbia) require
    wireless carriers to collect funds from their subscribers through a
    surcharge included on subscribers' monthly wireless phone bills.19 The
    amount of the surcharge is usually determined by the state; responses to
    our survey showed the surcharges ranged from 5 cents to $1.50 per month.
    Generally, the wireless carriers submit the funds to the states, and the
    states have the discretion to determine how the funds will be managed. For
    example, some states have established E911 boards that oversee the funds,
    while other states allow the funds to be managed at the county or PSAP
    level. Methods of disbursement also varied. Some states allocated wireless
    E911 funds to PSAPs based on their jurisdictional population, while some
    based it on the number of wireless subscribers in the jurisdiction. Other
    states evenly divided the funds among counties or PSAPs.

    Although the majority of states have established some type of funding
    mechanism, problems with funding PSAP equipment upgrades persist. For
    example, NENA maintains that many communities are not in a position to
    implement wireless E911 service because funds collected for E911
    deployment are not being allocated for that purpose. Our survey of state
    E911 contacts found that 13 states and the District of Columbia had used
    wireless E911 funds for expenditures unrelated to wireless E911
    implementation, and 9 other states had attempted to do so. For example, in
    one state, more than $40 million was taken from the E911 fund for
    unrelated purposes, and an additional $25 million is expected to be taken
    in 2004. The state contact said that if the redirection of funds
    continues, it would bring E911 upgrades to a halt. Another state E911
    contact told us that the use of some E911 funds for other purposes had
    hindered the ability of PSAPs to purchase necessary computer upgrades and
    mapping software. In another state, funds had not been redirected to other
    purposes, but the E911 funds were "frozen" by the state's legislature and
    could not be used by the PSAPs to implement Phase II. The state E911
    coordinator told us that the state's E911 fund had sufficient monies to
    implement Phase II statewide, but many PSAPs could not move forward until
    the state's

    19Three other states had a wireless E911 funding mechanism in place, but
    did not impose surcharges on wireless subscribers. To pay for wireless
    E911 implementation, one state used funds from general revenue, one used
    funds from the state's Universal Service Fund, and one state used funds
    collected for wireline 911.

    legislature allocated funds for E911 initiatives, and it was unclear when
    or if that would occur.20

    In addition to the redirection of E911 funds, our survey of state contacts
    found that eight states have never instituted a statewide system for
    collecting funds for wireless E911 purposes. In one state, for example,
    any fee or tax proposed to be placed on the public must be approved by the
    state's voters, and legislation creating an E911 funding mechanism did not
    receive voter approval. The state's E911 contact told us that the proposed
    legislation would have generated sufficient funds for deploying wireless
    E911 statewide, but without the funding, most counties in the state will
    not have Phase II implemented by 2005. Some of the other eight states have
    experienced opposition to E911 funding because it is perceived as a tax;
    another state has not addressed the issue of wireless E911 implementation
    at all.

    Another funding issue raised by survey respondents and by others we
    interviewed was that rural PSAPs in particular face funding problems for
    E911. For example, some states allocate funds to the PSAPs based on their
    jurisdictional population, which may cause PSAPs serving small or rural
    communities in those states to receive insufficient funds to implement
    E911. While many of the costs involved in purchasing upgraded equipment
    and mapping software are similar for PSAPs serving large and small
    communities, PSAPs that receive fewer E911 funds because of their smaller
    population base may not have adequate funds to purchase the necessary
    equipment and software. Two wireless carriers told us that numerous PSAPs
    they serve had either withdrawn or suspended their request to wireless
    carriers for Phase II service because of funding constraints.

    Wireless carriers also incur various costs to implement E911. For example,
    two wireless carriers told us they had spent about $50 million each to
    date to deploy E911, and three others said their costs would exceed $100
    million each. Several of the small wireless carriers we interviewed in our
    case studies said that funding E911 technologies is particularly difficult
    for them

    20Legislation introduced in the U.S. Senate and House of Representatives
    would provide annual grants to states and localities to improve emergency
    communications (see S.1250, 108th Cong., 1st Sess. (2003); H.R. 2898,
    108th Cong., 1st Sess. (2003)). Both bills would require states and
    localities to match the grants provided by the federal government and
    would prohibit federal grant monies from being awarded to states that
    redirect funds collected specifically for E911 initiatives to nonemergency
    communication uses.

    because of their limited revenues and that raising their rates would risk
    their competitiveness in the market. While FCC requires wireless carriers
    to implement E911, the Commission has not mandated as a prerequisite to
    implementation that the carriers be reimbursed for their E911 expenses.21
    Although responses to our survey showed that 32 states and the District of
    Columbia allow wireless carriers to recover their E911 costs from the
    state funding mechanism, state E911 contacts sometimes reported that it
    might be difficult for the carriers to recoup all of their E911 costs.22
    For example, some states only allow the wireless carriers to be reimbursed
    if funds were appropriated for that purpose, and other states told us that
    only certain wireless carrier expenditures could be reimbursed. The
    wireless carriers we contacted said it was unlikely that all of their
    costs would be fully recovered, especially since cost recovery mechanisms
    are not available in all states. One wireless carrier told us that in some
    states, the E911 surcharges imposed on customers do not generate
    sufficient revenue to pay for both PSAP and carrier costs incurred in E911
    deployment. Another wireless carrier said that some states make it so
    difficult for the wireless carrier to recover its costs that the carrier
    will not even attempt to get funds from those states. Since it is unlikely
    that all E911 implementation costs can be recovered through the states,
    several of the wireless carriers we contacted have chosen to charge their
    subscribers an additional monthly fee to help pay for E911 costs.

        Problems with Coordination Continue to Slow Wireless E911 Deployment

    As noted earlier, the deployment of wireless E911 systems requires
    wireless carriers, LECs, and PSAPs to work together in distinct yet
    interdependent roles. However, according to some contacts we interviewed,
    delays sometimes occur because the various parties have difficulty
    coordinating their activities or working together. There was no
    consistency across the interviews as to which party (or parties)-wireless
    carriers, LECs, or PSAPs-was most hindering wireless E911 deployment.

    The difficulties in coordination between the parties at times caused
    frustration, according to some contacts we interviewed. For example,
    representatives from two of the PSAPs we contacted noted that just

    21Initially, FCC said wireless carriers were not required to provide E911
    service unless a cost recovery mechanism was in place, but FCC reversed
    this decision in November 1999.

    22A representative from one PSAP told us that some wireless carriers might
    not seek to recoup costs incurred with deploying E911 if they plan to use
    the location technologies for commercial purposes.

    determining the number of wireless carriers providing service in their
    PSAP's jurisdiction can be difficult. One PSAP administrator told us that
    in order to get a complete list of providers before sending out his
    request letters for Phase I, a PSAP employee drove around the county to
    identify the cell tower owners and contacted them to obtain the names of
    the wireless carriers leasing space on the towers.23 The PSAP
    administrator noted as well that tracking down the right contact person at
    the wireless carrier was difficult.

    In another example, representatives from several wireless carriers said
    that some PSAPs had requested E911 service from the wireless carriers even
    though the PSAPs' call centers were not yet ready to receive caller
    location information because the proper equipment had not yet been
    installed. This might occur because some PSAPs fail to understand what is
    required of them technologically and what tasks they need to complete
    prior to requesting E911 service. Traditionally, PSAP administrators have
    focused on public safety and emergency response, not telecommunications.
    The complexity of implementing wireless E911, however, has forced PSAP
    administrators to become telecommunications project managers and to learn
    about the technology involved.

    We also were told that LECs have contributed to implementation delays. One
    PSAP representative told us that difficulties encountered with the LEC
    were a major obstacle to implementing wireless E911 and that the LEC
    delayed installing lines necessary for wireless E911 for 4 months, which
    greatly slowed the process. Because of continuing problems with the LEC in
    this location, the PSAP purchased its own call routing equipment.
    Similarly, another PSAP representative told us the main obstacle they
    faced in implementing E911 was working with the LEC. The PSAP
    representative noted that no one contemplated the role the LEC would play
    in the implementation of E911 and that this has led to problems and
    delays. A number of stakeholders we interviewed believed that FCC needs to
    be more involved with the LECs to ensure they are an active player in
    wireless E911 implementation. For example, an official representing a
    public safety association stated that FCC should closely monitor the role
    that the LECs play in wireless E911 implementation and should employ its
    oversight role

    23According to FCC, PSAPs can find wireless carrier licenses that serve
    their area from FCC's Universal Licensing System database. However, FCC
    stated that it might be difficult to link the name of the licensee to the
    name under which the actual operating carrier does business. The FCC
    database is available via its Web site at http://wireless.FCC.gov/uls/.

    to facilitate corrective action to expedite wireless E911 compliance.
    Several of those we interviewed in our case studies suggested that FCC
    take on greater enforcement of the LEC role in E911 implementation, and
    perhaps consider placing deadlines on LECs to respond to PSAP requests for
    E911 upgrades. According to FCC, the Commission does not have clear
    jurisdiction over wireline carriers with regard to wireless E911
    implementation, and the Commission looks to the state public utility
    commissions, which have clear and sufficient authority to take the lead.
    However, FCC has indicated that it is committed to monitoring the LECs'
    implementation role to ensure that they are meeting their responsibilities
    with regard to E911 deployment.24

    In response to these problems with coordination, many industry
    representatives and affected parties we contacted noted that a strong,
    knowledgeable state E911 coordinator was the key to helping to coordinate
    the parties and successfully implement wireless E911 services within the
    state. Many believed that those states with strong state E911 coordinators
    had made the most progress with wireless E911 implementation. These state
    coordinators perform tasks such as

    o  educating PSAPs about their wireless E911 responsibilities,

    o  providing technical assistance to PSAPs,

    o 	bringing all parties together early on to discuss implementation issues
    and providing a single point of contact for all the parties, and

    o 	lobbying for E911 funding and protecting the funding from being used
    for purposes unrelated to wireless E911 implementation.

    Besides voicing support for effective state coordinators, those we
    interviewed provided several illustrations of actions their states were
    taking to facilitate wireless E911 implementation:25

    24In the Matter of Revision of the Commission's Rules to Ensure
    Compatibility with Enhanced 911 Emergency Calling Systems, Petition of
    City of Richardson, Texas, CC Docket 94-102, Order on Reconsideration, FCC
    02-318 (released Nov. 26, 2002).

    25In addition to efforts by state officials to improve coordination,
    several public safety and industry associations have worked to provide
    information and assistance with wireless E911 implementation.

    o 	Several parties we spoke with mentioned that they had had a conference
    call or meeting early on between the wireless carrier, LEC, and PSAP to
    talk through the process and try to identify problems.

    o 	Kentucky requires all PSAPs to go through a certification process with
    the state board to ensure preparedness for both wireline and wireless E911
    implementation. This certification process was created to establish an
    overall uniformity for the state's PSAPs. By using a checklist for
    upgrades and an inspection process, Kentucky expects all of its PSAPs that
    go through the certification process will be Phase II operational by
    January 2005.26

    o 	California purchases equipment at the state level to create advantages
    in negotiating contracts with vendors and to create economies of scale in
    equipment purchases.

    o 	Indiana has an elected official in charge of funding, which provides
    for greater visibility of the E911 issue in the state and helps protect
    against redirection of E911 funds to other uses.

    o 	Virginia contracts with several technical consulting firms for wireless
    E911 implementation. The PSAPs are allowed to use contractors from this
    pool and can use the wireless E911 funding they receive from the state to
    pay for contractors' services. This arrangement provides needed technical
    assistance for PSAPs while allowing greater oversight of the contractors.

        Early Problems with Location Technology Appear Resolved, but Technical
        Challenges Remain Regarding New Wireless Devices and Services

    During our interviews, we were told that the basic technology for
    accurately determining the location of a wireless caller and
    systematically providing that data to PSAPs has now been developed. Some
    noted that although occasional problems still arise due to a particular
    wireless carrier/LEC/PSAP equipment configuration, these problems are
    lessening as the parties gain experience with E911 implementation. A
    representative of one LEC noted that the "challenging years" of
    coordinating interconnection between the LEC and the wireless carrier seem
    to be behind them and that implementation now generally tends to proceed
    more smoothly.

    26However, 25 counties in Kentucky still do not have wireline E911.

    We asked the officials we interviewed what they saw as the remaining
    technical issues affecting wireless E911 implementation. Several parties
    mentioned a variety of technical problems that might slow wireless E911
    implementation or affect the quality of 911 services in general. Problems
    that were mentioned include the following:

    o 	Because the United States never adopted a single standard for mobile
    phone transmissions, the different systems used by wireless carriers are
    not always compatible with one another, which can affect the ability of a
    particular subscriber to reach 911 in the first place if they do not have
    a phone that can be used with multiple systems.

    o 	While GPS can provide more accurate location data, concerns exist over
    the time it takes for location data to be calculated and delivered to the
    PSAP. In the context of an emergency call, even a wait of 10 or 20 seconds
    for the location data to be processed is considered a loss of valuable
    time.

    o 	For rural wireless carriers that have selected a network-based
    solution, cell towers often are placed in a straight line and spaced
    widely apart along highways or other roads. This can make the
    determination of location difficult because the towers cannot accurately
    triangulate the location of the caller. Additionally, the handset-based
    solution may not be immediately available due to equipment issues.

    Another problem was raised by some of those we interviewed: the antiquated
    wireline 911 infrastructure that conveys many E911 calls from the wireless
    carrier to the PSAP. This issue was also raised by Dale Hatfield, former
    chief of FCC's Office of Engineering and Technology. In 2001, FCC asked
    Mr. Hatfield to conduct an inquiry into the technical and operational
    issues associated with wireless E911 deployment. His October 2002 report
    to FCC noted that the wireline 911 network is fundamentally unchanged
    since its inception in the 1970s and that the existing 911 infrastructure
    "is in no condition to accommodate the pervasive use of wireless
    technologies, the Internet, or the many other product offerings that
    invite or demand access to 9-1-1 services."27 Those offerings include

    27Dale N. Hatfield, A Report on Technical and Operational Issues Impacting
    the Provision of Wireless Enhanced 911 Services, prepared for the FCC
    (Oct. 15, 2002), Docket No. 02-46, pp. 13-14, quoting SCC Communications
    Corp., 9-1-1 Networks in the 21st Century-The Case for Competition (Feb.
    20, 2001), p. 2.

    new wireless technologies that could send E911 calls (e.g., automatic
    crash notification systems on cars that would also be able to send
    information to the 911 call taker about whether air bags have deployed or
    whether the car has flipped over), and the 911 services may need to be
    expanded to encompass such technologies. Many of those with whom we spoke
    believed that such new technologies should be considered now, rather than
    later. Some were critical of the LECs' failures to upgrade to modern
    digital technologies that would facilitate the rollout of wireless E911
    technologies and improve 911 services. FCC released a notice of proposed
    rulemaking to reevaluate the scope of communications services that should
    provide access to 911 and has received comments and reply comments from
    interested parties.28 NENA is also trying to address the issue of new
    technologies and of a "future path plan" for the 911 network.29

      The Recent Actions of FCC and DOT Are Focused on Enforcing Deadlines on
      Wireless Carriers and Improving Deployment Coordination

    FCC and DOT have been involved in the implementation of wireless E911, but
    federal authority in overseeing the deployment is limited because of the
    traditional state and local jurisdiction over emergency response services.
    The primary federal agency involved in wireless E911 deployment is FCC.
    One of FCC's goals is to ensure the wireless carriers comply with their
    current implementation schedules. As noted earlier, FCC in the past had
    granted waivers to many of the wireless carriers in order to give them
    more time to resolve technical issues associated with developing wireless
    location technologies. Because many of these hurdles have now been
    overcome, FCC has stated that it will not hesitate to use its enforcement
    power when the wireless carriers fail to meet their current deployment
    timetables. For example, FCC officials noted that three wireless carriers
    agreed to pay nearly $4 million to the U.S. Treasury for failure to comply
    with intermediate deadlines in their E911 deployment timetables.

    28See In the Matter of Revision of the Commission's Rules to Ensure
    Compatibility with Enhanced 911 Emergency Calling Systems, CC Docket
    94-102, Further Notice of Proposed Rulemaking, FCC 02-326 (released Dec.
    20, 2002).

    29NENA is working to develop a plan for aggressively managing the
    technical evolution of the overall 911 system and emergency communications
    process in ways that serve local and national emergency needs. This
    technical plan will seek to provide a long-term direction for 911 to
    support new call sources (such as text messaging devices) and needs.

    Beyond enforcing deadlines on wireless carriers, FCC has taken actions to
    identify both roadblocks and best practices in wireless E911
    implementation. For example, the Hatfield report made a number of findings
    regarding obstacles to wireless E911 implementation. Those findings
    involve wireless carrier implementation issues, cost recovery and PSAP
    funding issues, and the lack of comprehensive stakeholder coordination.
    Public comment was sought on the report in late 2002 and, according to
    FCC, the Commission is currently considering both the recommendations
    contained in the report and the comments received.30 FCC also conducted
    its first Enhanced 911 Coordination Initiative meeting in April 2003. The
    meeting brought together representatives from the federal government, the
    public safety community, wireless carriers, LECs, and other interested
    stakeholders to share experiences and devise strategies for expediting
    wireless E911 deployment. According to FCC, lessons learned from the
    initiative include the following:

    o 	Strong leadership and vision are essential to ensure swift wireless
    E911 deployment.

    o 	State or regional points of contact are critical for prompt wireless
    carrier deployment.

    o 	Wireless E911 in rural areas may pose additional challenges such as
    financial hurdles and accuracy concerns.31

    30In his report to the FCC, Mr. Hatfield recommended that a national 911
    program office be established within the Department of Homeland Security.
    He also recommended that FCC (1) maintain or even increase its oversight
    of the rollout of wireless E911 services; (2) establish an advisory
    committee to address the development and evolution of E911 systems and
    services; (3) continue to urge the creation of organizations at the state,
    regional, and local levels to coordinate the rollout of wireless E911; (4)
    encourage the creation of a national clearinghouse to collect, store, and
    disseminate wireless E911 information; (5) actively coordinate with and
    support DOT's Wireless E911 initiative and other efforts; (6) continue to
    support the efforts of the Emergency Services Interconnection Forum to
    address the issues of PSAP readiness; (7) work closely with individual
    state and regulatory commissions and their association, the National
    Association of Regulatory Utility Commissioners, in resolving issues
    relating to LEC cost recovery and pricing; and (8) urge stakeholders to
    develop industrywide procedures for testing and certification of wireless
    E911 to ensure that they meet the accuracy requirements in FCC rules. Mr.
    Hatfield also made several other recommendations relating to technical,
    regulatory, and consumer issues.

    31Near the end of our review, FCC announced that they would be conducting
    another Wireless E911 Coordination Initiative to be held October 29-30,
    2003.

    Additionally, in August 2003, FCC announced the establishment of a
    wireless E911 technical group to focus on network architecture and
    technical standards issues. The group will be a subcommittee of the
    Commission's Network Reliability and Interoperability Council. Also in
    August 2003, FCC announced a wireless E911 public awareness campaign
    emphasizing coordination, outreach, and education. One of the first
    outcomes of the campaign was an FCC advisory published for consumers
    providing information on what people need to know about calling 911 from a
    mobile phone. A copy of this consumer advisory is found in appendix II of
    this report.

    DOT also has efforts under way to promote wireless E911 implementation,
    focusing on implementation issues at the state and local level. DOT
    partnered with NENA to develop a Wireless Implementation Plan. One major
    aspect of this plan is the creation of a clearinghouse of wireless E911
    planning, implementation, and operations resources. The clearinghouse is
    an attempt to gather and organize the best examples of information from
    various states, work groups, and ongoing development efforts. The
    clearinghouse also includes various forms used by parties across the
    nation in implementing E911 agreements. As discussed earlier, another
    major component of DOT's efforts is the sponsorship of a PSAP database
    (under contract with NENA) that tracks the current status of wireless E911
    implementation across the country.32

    DOT also convened a Wireless E911 Steering Council33 to develop a Priority
    Action Plan, released in May 2003, that outlines six priorities for
    wireless E911 implementation:

    1.	Establish support for statewide coordination of wireless E911
    technology, and identify points of contact within each state for each of
    the stakeholders.

    2.	Help to convene stakeholders in appropriate 911 regions in order to
    facilitate more comprehensive, coordinated implementation of wireless
    location technologies.

    32Links to the clearinghouse and the database are available on DOT's Web
    site. See http://www.itspublicsafety.net/wireless.htm.

    33The Wireless E911 Steering Council includes leaders of the
    telecommunications, public safety, and highway safety communities.

    3. Examine cost recovery and funding issues at the state level.

    4.	Initiate a knowledge transfer and outreach program to educate PSAPs,
    wireless carriers, and the public about wireless location issues.

    5.	Develop a coordinated deployment strategy encompassing both rural and
    urban areas.

    6.	Implement a "model location program" to identify and isolate potential
    barriers to wireless E911 deployment.

    Work on implementing this plan was in its early stages at the time we
    concluded our review. However, DOT had subdivided each priority into a
    number of action items, identified lead agencies or associations for each
    action item, and established a time frame for completion of each action
    item.

    FCC and DOT staff told us that the agencies coordinate their wireless E911
    activities to avoid duplication of effort. An FCC representative attends
    DOT meetings and events on wireless E911 to stay current with the
    department's activities; similarly, a DOT representative attends FCC
    meetings and initiatives on wireless E911. DOT officials noted that their
    efforts have been concentrated on providing assistance at the PSAP level
    since FCC has authority over the wireless carriers and LECs. While the
    agencies do not currently jointly staff or fund any wireless E911
    projects, FCC officials noted that more formalized coordination is
    possible in the future.

    Conclusions	Without the readiness of all parties-wireless carriers, LECs,
    and PSAPs- there can be no wireless E911 service. Efforts by FCC to
    monitor the progress of the wireless carriers in meeting their timetables
    and take enforcement actions, as warranted, will continue to be an
    important part of the implementation process. Still, given current E911
    funding and coordination problems related to upgrading PSAPs at state and
    local levels, the pace of wireless E911 deployment could be similar to
    what happened with wireline E911, which took many years to implement
    nationwide. If this holds true, consumers and emergency management
    officials will be faced with a geographic patchwork of wireless E911
    areas: Some will have service; some will not. As Americans travel across
    the country, they will be uncertain as to whether their 911 calls will
    convey their location. However, successful wireless E911 deployment is
    possible, as illustrated in some areas of the country. States and
    localities can benefit from the experiences

    and best practices of others and adapt them to their own situations.
    Continued efforts by the FCC, DOT, and the public safety community to
    identify and publicize these successes will be a valuable means of
    facilitating the deployment.

    During this transition period, it is important to accurately measure
    progress in wireless E911 deployment so that federal, state, and local
    officials can assess whether problems are arising in parts of the country
    that may require additional actions. This information would also help
    build public awareness of where this service is available and may
    stimulate action at the state and local level. Measuring the progress of
    wireless E911 implementation against the goal of full nationwide Phase II
    deployment depends on being able to compare the number of PSAPs that are
    receiving wireless Phase II location data with the total number of PSAPs
    that need to be upgraded. We found, however, that there is a lack of
    information on the total number of PSAPs that need to be upgraded. While
    FCC and DOT have taken important actions to track wireless E911
    deployment, additional work is needed to create reliable data on how many
    of the more than 6,000 PSAPs will need to be upgraded.

      Recommendation for Executive Action

    In order to provide the Congress and federal and state officials with an
    accurate assessment of the progress being made toward the goal of full
    deployment of wireless E911, we recommend that the Department of
    Transportation work with state-level E911 officials, the National
    Emergency Number Association, and other public safety groups to determine
    which public safety answering points will need to have their equipment
    upgraded. This information should then be reflected in the PSAP database
    managed by NENA under contract with DOT. This will provide the baseline
    needed to measure progress toward the goal of full nationwide deployment
    of wireless E911 service.

    Agency Comments	We provided a draft of this report to DOT and FCC for
    review and comment. DOT stated that it generally agreed with our
    recommendation, and FCC offered some technical comments that we
    incorporated into the report where appropriate.

    As agreed with your office, unless you publicly announce its contents
    earlier, we plan no further distribution of this report until 14 days
    after the

    date of this letter. At that time, we will send copies to interested
    congressional committees; the Chairman, FCC; the Secretary, Department
    of Transportation; and other interested parties. We also will make copies
    available to others upon request. In addition, this report will be
    available at
    no cost on the GAO Web site at http://www.gao.gov. If you have any
    questions about this report, please contact me at (202) 512-6670 or
    goldsteinm@gao.gov. Key contacts and major contributors to this report
    are listed in appendix III.

    Sincerely yours,

    Mark L. Goldstein
    Director, Physical Infrastructure Issues

    Appendix I

    Scope and Methodology

    To provide information on the progress made in deploying wireless E911
    services throughout the country, we conducted a telephone survey of the
    state E911 contacts. We completed surveys for 50 states and the District
    of Columbia. We pretested the questions with five state contacts from
    states we had spoken with earlier in our research. We revised the survey
    as appropriate based on responses during pretesting. For each state and
    the District of Columbia, we began by contacting the person named on the
    FCC's Web site at http://www.fcc.gov/911/stateplans/contacts.html as the
    point of contact for that state.1 In 25 states, the person named on FCC's
    Web site did complete the survey. In the remainder of our surveys, we were
    directed to another person. The survey contained 17 questions about the
    state's progress in implementing Phase I and Phase II, problems
    encountered, funding mechanisms in place, and the role of the state
    coordinator or any state offices involved in wireless E911 implementation.
    The questions were open-ended and were read to the respondents. Surveys
    were completed between June 11 and September 12, 2003. In addition to our
    survey results, we used data from the National Emergency Number
    Association (NENA) to illustrate the progress of wireless E911
    implementation as of October 2003. To assess the reliability of NENA's
    data regarding information on total costs to upgrade PSAPs to Phase II
    readiness and the number of PSAPs receiving Phase II data as of the August
    1, 2003, FCC quarterly filings, we interviewed knowledgeable officials
    from NENA about their data collection methods and reviewed any existing
    documentation relating to the data sources. We determined that the data
    were reliable enough for the purposes of this report.

    To provide information on the factors affecting wireless E911 rollouts
    across the country, we selected nine states (California, Idaho, Indiana,
    Kentucky, Maryland, Missouri, South Carolina, Texas, and Virginia) and the
    District of Columbia for case studies. We selected states that were spread
    geographically across the U.S. and that appeared to be having various
    levels of success with wireless E911 implementation based on early
    research. In particular, we selected at least one rural state and at least
    one state known to have redirected funds collected for E911 implementation
    to other uses. For each case study, we interviewed (in person or by
    telephone)

    1These names were provided to FCC by the governor of each state in
    response to a request from FCC's Chairman. FCC did not list a contact
    person for the states of Wisconsin and Oklahoma, so we obtained a contact
    name from NENA for these two states. We also did not receive a response
    from the contact for New York and completed the New York survey with a
    person suggested by NENA.

    Appendix I
    Scope and Methodology

    the state coordinator, a small wireless carrier serving that state,2 and
    one urban PSAP and one rural PSAP within the state.3 In addition to our
    case studies, we interviewed representatives from four public safety
    associations and two wireless industry associations. We interviewed
    representatives from five large national wireless carriers and received
    written responses to our questions from a sixth large national wireless
    carrier. We also interviewed representatives from six local exchange
    carriers and one manufacturer of mobile phones.

    To provide information on current federal government actions to promote
    the deployment of wireless E911 services, we spoke with officials at FCC
    and DOT about their involvement in wireless E911 implementation. We
    reviewed relevant orders, filings, and other materials from FCC docket
    number 94-102 on E911 implementation. We researched relevant materials
    from both FCC and DOT, such as DOT's Priority Action Plan. We attended
    FCC's daylong Enhanced 911 Coordination Initiative in April 2003.

    Statistics presented in the first paragraph of the report are from the
    Cellular Telecommunication & Internet Association, unless otherwise noted.
    Statistics presented in the first paragraph of the background section are
    from NENA. All of these statistics are presented for background purposes
    and were not verified by GAO.

    We conducted our review from January 2003 through October 2003 in
    accordance with generally accepted government auditing standards.

    2For purposes of our case studies, a small wireless carrier was considered
    any wireless carrier other than the six large nationwide wireless carriers
    (AT&T Wireless, Cingular, Nextel, Sprint, T-Mobile, and Verizon Wireless).

    3There were some exceptions to our case study formula. The District of
    Columbia has only one PSAP and has no small wireless carriers. California
    has no rural PSAPs that take wireless calls. Instead, we interviewed the
    California Highway Patrol, which handles most of the wireless 911 calls in
    California. Lastly, we were unable to schedule an interview with a small
    wireless carrier serving the state of Missouri.

    Appendix II

    FCC Consumer Advisory about Calling 911 from Your Wireless Phone

    Among other responsibilities, FCC's Consumer & Governmental Affairs Bureau
    educates and informs consumers about telecommunications services. To this
    end, the Bureau has produced a number of consumer alerts and fact sheets.
    Among these is a new consumer advisory entitled "What You Need to Know
    about Calling 911 from Your Wireless Phone." This consumer advisory is
    reprinted on the following pages and can be accessed at FCC's Web site at
    www.fcc.gov/cgb/consumerfacts/e911.html.

    Appendix II
    FCC Consumer Advisory about Calling 911
    from Your Wireless Phone

    Appendix II
    FCC Consumer Advisory about Calling 911
    from Your Wireless Phone

    Appendix III

                         GAO Contacts and Staff Acknowledgments

    GAO Contacts	John Finedore, (202) 512-6248 Faye Morrison, (202) 512-6448
    Andy Clinton, (214) 777-5616

    Staff 	In addition to those named above, Michele Fejfar, Deepa Ghosh,
    Sally Moino, Mindi Weisenbloom, Alwynne Wilbur, and Nancy Zearfoss made
    key

      Acknowledgments contributions to this report.

    GAO's Mission	The General Accounting Office, the audit, evaluation and
    investigative arm of Congress, exists to support Congress in meeting its
    constitutional responsibilities and to help improve the performance and
    accountability of the federal government for the American people. GAO
    examines the use of public funds; evaluates federal programs and policies;
    and provides analyses, recommendations, and other assistance to help
    Congress make informed oversight, policy, and funding decisions. GAO's
    commitment to good government is reflected in its core values of
    accountability, integrity, and reliability.

      Obtaining Copies of GAO Reports and Testimony

    The fastest and easiest way to obtain copies of GAO documents at no cost
    is through the Internet. GAO's Web site (www.gao.gov) contains abstracts
    and full-text files of current reports and testimony and an expanding
    archive of older products. The Web site features a search engine to help
    you locate documents using key words and phrases. You can print these
    documents in their entirety, including charts and other graphics.

    Each day, GAO issues a list of newly released reports, testimony, and
    correspondence. GAO posts this list, known as "Today's Reports," on its
    Web site daily. The list contains links to the full-text document files.
    To have GAO e-mail this list to you every afternoon, go to www.gao.gov and
    select "Subscribe to e-mail alerts" under the "Order GAO Products"
    heading.

    Order by Mail or Phone	The first copy of each printed report is free.
    Additional copies are $2 each. A check or money order should be made out
    to the Superintendent of Documents. GAO also accepts VISA and Mastercard.
    Orders for 100 or more copies mailed to a single address are discounted 25
    percent. Orders should be sent to:

    U.S. General Accounting Office 441 G Street NW, Room LM Washington, D.C.
    20548

    To order by Phone: 	Voice: (202) 512-6000 TDD: (202) 512-2537 Fax: (202)
    512-6061

    To Report Fraud, 	Contact: Web site: www.gao.gov/fraudnet/fraudnet.htm

      Waste, and Abuse in E-mail: fraudnet@gao.gov

    Federal Programs Automated answering system: (800) 424-5454 or (202)
    512-7470

    Public Affairs	Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202)
    512-4800 U.S. General Accounting Office, 441 G Street NW, Room 7149
    Washington, D.C. 20548

                                   Presorted Standard
                                  Postage & Fees Paid
                                          GAO
                                    Permit No. GI00

    United States
    General Accounting Office
    Washington, D.C. 20548-0001

    Official Business
    Penalty for Private Use $300

    Address Service Requested
    *** End of document. ***