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
******************************************************************
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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 [email protected].
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
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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
[email protected]. 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.
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