**WIRELESS TELECOMMUNICATIONS BUREAU**

**STAFF REPORT**

**Prevention of**

**Unintentional Wireless 911 Calls**

**CC Docket No. 94-102**

**Released**: December 11, 2002

Unintentional wireless 911 calls today can be a significant problem for
the nation's Public Safety Answering Points (PSAPs). These unintentional
911 calls can occur when a consumer accidentally presses a key on his or
her handset automatically programmed to dial 911 via speed dial. The
consumer unknowingly ties up a 911 call taker at the other end of the
line who has to confirm, based on little information, that the call is,
in fact, accidental, and not from a person in distress. That call taker
now also is unable to field other, real, 911 emergency calls. According
to the National Emergency Number Association (NENA), individual 911
PSAPs have estimated that between 25 and 70% of their wireless calls are
unintentional calls. Thousands of PSAP call taker hours are thus wasted
every year on unintentional wireless 911 calls.

In response to a request from various public safety organizations, the
staff of the Wireless Telecommunications Bureau has investigated this
problem, and in this document reports on the steps that are being taken
to address it. The Commission, public safety organizations, wireless
carriers, handset manufacturers, and consumers share a common goal in
curtailing the incidence of unintentional wireless 911 calls. We are
encouraged that key carriers and handset manufacturers are taking steps
to combat the problem. We also recognize that the problem cannot be
solved overnight, and intend actively to monitor and follow-up in the
future if the incidence of unintentional 911 calls is not reduced. We
also applaud the efforts of public safety organizations, including NENA,
the Association of Public-Safety Communications Officials-International,
Inc. (APCO), and the National Association of State Nine One One
Administrators (NASNA), in focusing government, industry and consumer
attention on this important issue.

I.  **[EXECUTIVE SUMMARY]{.underline}**

    More specifically, building on efforts undertaken by NENA, the staff
    of the Wireless Telecommunications Bureau (Bureau) has worked with
    public safety agencies, wireless handset manufacturers, and wireless
    carriers to help ensure that steps are being taken to address the
    problems caused by unintentional 911 calls. As a result of these
    efforts, the Bureau has found the following:

    -   Unintentional 911 calls pose a significant problem for PSAPs
        because they must expend scarce resources to determine that
        these false calls are not actually emergency situations.

    -   Industry participants are taking steps to eliminate the
        unintentional call problem:

        -   All wireless carriers surveyed have requested that
            manufacturers deactivate the auto-dial 911 feature prior to
            shipment of new handsets to the carriers. In addition, The
            Cellular Telecommunications and Internet Association (CTIA)
            has recently incorporated a requirement in its certification
            program that CTIA-certified handsets may not be
            pre-programmed with an auto-dial 911 feature.

        -   The major manufacturers of wireless handsets have reported
            that currently none of their phones come pre-programmed with
            an auto-dial 911 feature.

        -   Many carriers have attempted to reduce the occurrence of
            unintentional 911 calls by providing their customers with
            educational information through inserts in their monthly
            bills, through direct mailings/newsletters, and through
            postings on carrier websites.

    -   Consumers who possess handsets with the auto-dial 911 feature
        can assist efforts to eliminate the unintentional call problem
        by disabling the auto-dial 911feature or by locking their key
        pad.

    -   Commission staff will assist efforts to eliminate unintentional
        911 calls by continuing to monitor, in partnership with public
        safety organizations, carrier developments in this area,
        including steps taken by carriers and handset manufacturers, and
        by providing information to the public through a Consumer Alert
        available on the FCC website (www.fcc.gov/cgb/information\_
        directory.html) on how they can prevent unintentional 911 calls.

II. **[BACKGROUND]{.underline}**

During the last several years, wireless handset manufacturers have
produced various models of wireless mobile telephones with an "auto-dial
911" feature, providing the user with one touch dialing to 911. The user
simply presses one button on the handset (usually the "1" or the "9"
key) for approximately two seconds and the handset dials 911. The
handsets containing this feature have often been delivered to the end
user with the auto-dial 911 feature activated, and the user may not be
aware that the feature is available and active when the handset is
placed into service.

While initially considered a useful safety feature for wireless
handsets, over the last few years, many Public Safety Answering Points
(PSAPs) have reported answering high percentages of wireless 911 calls
where no caller is on the other end of the line. These "unintentional
911 calls" can occur when the preprogrammed auto-dial 911 key is
accidentally pressed while the phone is in the user's pocket, purse, or
briefcase, or is carried on the user's belt. Wireless phones with a
"clam shell" design, in which the keyboard is kept covered when not in
use, are not as susceptible to this problem. Of course, these calls can
occur in other ways---for example, children playing with wireless phones
may dial 9-1-1---but the scope of this report is limited to the
auto-dial 911 function.

When an unintentional 911 call is placed, PSAP operators' general
practice is to remain on the line in an attempt to determine if the call
is intentional or unintentional. If the PSAP has E911 Phase I
capability, which provides the PSAP with the caller's telephone number,
the operator can disconnect and call the user back to verify that the
original call was unintentional. If the PSAP is unable to call the user
back and has E911 Phase II capability, which provides the PSAP with the
location of the caller, operators may be compelled to dispatch emergency
services to the caller's location if the PSAP cannot determine that the
911 call has been made unintentionally. All these practices result in
the diversion of PSAP personnel and resources from the intake of other
911 calls reporting real emergencies.

On January 9, 2002, NENA, APCO, and NASNA sent a letter to the Federal
Communications Commission (FCC), requesting an examination of the "very
serious problems posed by unintentional wireless telephone calls to
9-1-1, which are clogging many Public Safety Answering Points ('PSAPs')
and diverting scarce resources necessary to respond to real
emergencies."[^1] The public safety groups requested further
investigation of the extent of this problem.[^2]

One month earlier, on December 12, 2001, NENA sent a letter to
twenty-one wireless carriers, requesting information on what each
carrier had done or was willing to do, to reduce or eliminate
unintentional 911 calls. The NENA letter outlined the unintentional 911
calls problem being experienced by numerous PSAPs, stating that between
25% and 70% of all wireless calls to 911 are unintentional. In its
letter, NENA proposed several "solutions that give carriers an
opportunity to work cooperatively with public safety to try to solve the
most visible and vexing problem facing 9-1-1 centers today."[^3] NENA
stated that the unintentional 911 calls problem could be best addressed
through "a joint cooperative effort by carriers, manufacturers and the
public safety community," and asked "for a commitment to voluntary
action by carriers and manufacturers to remedy this problem."[^4]

# [POSSIBLE SOLUTIONS]{.underline}

In its December 12, 2001, letter, NENA proposes several possible
solutions that, if adopted by wireless handset manufacturers and
carriers, could significantly reduce the number of unintentional
wireless 911 calls made to PSAPs. NENA first requests that carriers
direct their handset manufacturers to cease production of handsets with
an auto-dial 911 feature, or to ship the handsets to the carriers with
the feature deactivated.[^5] Second, NENA requests that carrier
personnel ensure that an auto-dial 911 feature, if available, is
deactivated prior to delivery of the handset to the customer.[^6] Third,
NENA proposes that carriers provide their customers with information
regarding the unintentional 911 calls problem, both for customers
getting new handsets and for customers using legacy handsets that may
still have an active auto-dial 911 feature.[^7] Providing existing
customers with educational information can be accomplished through
inserts in their monthly bills, through direct mailings/newsletters, and
through postings on carrier websites.[^8] Finally, NENA proposes that
carriers list all 911 calls placed by customers on their monthly bills,
allowing customers to recognize any unintentional 911 calls, and to take
steps to prevent dialing 911 unintentionally in the future.[^9]

On August 6, 2002, the Bureau requested information from several
carriers[^10] regarding steps they were taking to address the
unintentional 911 calls problem, specifically:

1)  whether the carrier had communicated to its handset manufacturers
    its desire that mobile phones not be preprogrammed to dial 911 by
    pushing a single button on the keypad;

2)  whether personnel had been instructed to deactivate the auto-dial
    911 feature if it comes preprogrammed on certain mobile phones;

3)  the extent to which customers had been provided information
    regarding the unintentional 911 calls problem, both for existing
    handsets and new handsets; and

4)  whether 911 calls were itemized on customers' bills to alert them
    that they may be placing 911 calls unintentionally.

In response to the NENA and Bureau requests, handset manufacturers and
wireless carriers have acknowledged the existence of the unintentional
911 calls problem and have committed to taking active steps to curtail
the number of such calls made by customers. Bureau staff has also
discussed this issue with other interested parties, including handset
manufacturers.[^11]

A.  **Wireless Handset Manufacturers**

Bureau staff contacted the three major manufacturers of handsets sold in
the United States. The collective market share of Motorola, Nokia, and
Sony/Ericsson is approximately two-thirds of all wireless handsets.[^12]

Motorola and Nokia have advised the Bureau that they have taken steps to
correct the unintentional 911 calls problem, including not offering an
auto-dial 911 feature as an option on their handsets on a going-forward
basis. While one current Nokia model has an auto-dial 911 feature
available, the user must activate the function through several menu
steps. Sony/Ericsson reported that a pre-programmed auto-dial 911
feature has not been part of its manufacturing process for any handset
offered, and it has no plans to offer it in the future. Although the
number of handsets in the market that possess this pre-programmed
auto-dial 911 feature has not been reported, as newer handsets are
manufactured without the feature, the percentage of auto-dial 911
enabled handsets will decrease.

Motorola, Nokia, and Sony/Ericsson also reported that their "candybar"
style handsets (i.e., those with an open-faced design where the keypad
is exposed), which appear to be more prone to unintentional 911 calls,
have keypad locks that can be activated by the user. These keypad locks,
some of which can be programmed to activate automatically, prevent any
keys from being pressed until the user unlocks the keypad with a short
combination of key presses. "Clam shell" style handsets are likely not a
large contributor to the unintentional call problem due to the nature of
their design.

B.  **Cellular Telecommunications and Internet Association (CTIA)**

CTIA states that it recognizes that the number of unintentional calls to
911 triggered by the "one-touch" dialing feature is an important public
safety issue.[^13] In efforts to reduce the incidence of unintentional
wireless 911 calls, CTIA's Board of Directors has very recently modified
the CTIA Certification Program[^14] to include the requirement,
effective January 1, 2003, that CTIA-certified handsets will not be
pre-programmed at the factory to dial 911. The new requirement will not
prohibit consumers from programming "911" as a one-touch number.

C.  **Wireless Carriers**

All nationwide wireless carriers have either responded to NENA's
December 12, 2001, letter or to the Bureau's August 6, 2002, request for
information. These wireless carriers have now advised the Bureau that
they have taken an active role in addressing the unintentional 911 calls
problem.

Carrier actions include employing some or all of the solutions proposed
by NENA in its December 12, 2001, letter. At a minimum, nationwide
carriers have requested that their vendors cease shipping phones with an
active, auto-dial 911 feature. In nearly all cases, wireless phones
distributed by these carriers have not had an auto-dial 911 feature
since at least February of this year.

Beginning in December, 2000, Nextel Communications, Inc. (Nextel), for
instance, requested that its sole handset manufacturer, Motorola, no
longer include an auto-dial 911 feature on the phones supplied to
Nextel.[^15] Nextel has provided its customers with a free software
upgrade to remove the feature from customers' existing handsets.[^16]
Nextel also has instituted employee education programs, advising its
employees of the unintentional 911 calls problem and directing them to
encourage their customers to deactivate the feature or to use the keypad
lock on the handset to avoid accidentally dialing 911.[^17] Nextel has
further provided its customers with additional consumer information
through billing inserts and flyers, and by listing 911 calls on its
customers' monthly bills.[^18]

Cingular Wireless (Cingular) also is implementing a plan to address the
unintentional 911 calls problem.[^19] Cingular does not sell or donate
any wireless handsets preprogrammed with an auto-dial 911 key. Cingular
also has provided its customers with consumer information through
billing inserts with reference to its website where customers can read a
more detailed explanation of the problem, and receive information on
whom to contact to disable an auto-dial 911 feature on their
handsets.[^20]

ALLTEL Communications, Inc. (ALLTEL) requested that its handset
manufacturers cease pre-programming an auto-dial 911 feature into its
handsets, and is advising its sales channels to disable all auto-dial
911 features on handsets currently in stock.[^21] ALLTEL does note that
one of its vendor's handsets is pre-programmed with an auto-dial 911
feature that cannot be disabled, but this is not a standard model for
ALLTEL.[^22] ALLTEL also is providing its customers with informational
flyers with their new handsets.[^23] ALLTEL additionally will provide
each customer with information on their monthly bill, and will advise
them on how to disable the auto-dial 911 feature on their handsets.[^24]

Sprint PCS (Sprint) does not support the manufacture of handsets with
auto-dial 911 features.[^25] Sprint states that only a small minority of
handsets being used by current subscribers have a pre-programmed 911
button.[^26] In addition, Sprint states that since the majority of its
handsets are a "clamshell" design, where the user must open the handset
in order to access the keypad, the chances of unintentional 911 calls
are greatly reduced.[^27] Sprint's customer bills list all 911 calls
made by the handset, and Sprint has also updated its website with
instructions to consumers on how to disable the auto-dial 911 feature.

In addition to taking active steps to curb unintentional 911 calls made
by their customers, in response to NENA's letter, all of the wireless
carriers surveyed for this report have expressed an interest in working
directly with public safety officials on this issue by participating in
dialogs with national public safety organizations.[^28] All of the
wireless carriers surveyed also have offered to work with individual
PSAPs in gathering specific information on any customer who has made
numerous unintentional 911 calls to the PSAP.[^29]

In response to the Bureau's August 6 request, Verizon Wireless states
that it believes that the unintentional calls problem is not widespread
among its equipment base[^30] because it has not required handset
vendors to provide the "one-touch emergency 911 dialing" feature.
Verizon also states that it has made a written request to all vendors
that the one-touch 911 feature be deactivated from all handsets being
shipped. Verizon states that it will not offer any new handset models
that have the one-touch feature, and Verizon further notes that it will
provide instructions to its customers via its website on how to
deactivate the auto-dial feature. Finally, Verizon states that it is
unable due to billing system limitations, to itemize 911 calls on its
customers' bills.

AT&T Wireless responds that it has worked with vendors to ensure that
the auto-dial for 911 is pre-programmed to "OFF." [^31] In a recent
staff conversation, AWS confirmed that all phones come with the
auto-dial feature disabled. AWS further states that its website advises
customers about the one-touch feature problem and instructs them to
disable the feature. AWS has also provided direction to its customers in
its "Welcome Guide," an instructional booklet included with each
handset, and other newsletters. AWS notes that it does not itemize calls
on its customer bills because its billing system is not designed to
capture non-billed call data.

T-Mobile (formerly VoiceStream Wireless) responds that all of its
handsets come from the handset manufacturer with the 911 speed-dialing
feature disabled.[^32] T-Mobile states that it is working with its
marketing department and handset vendors to modify its instructional
booklet and handset manuals to address the unintentional 911 call issue
and to encourage the use of the "key lock" feature on phones.
VoiceStream further states that it provides 911 call details on
post-paid customer bills and that it will be putting a message directly
on customer bills and providing bill inserts to address the
unintentional 911 call problem.

#### [CONCLUSIONS]{.underline}

Based on the information received by the Bureau's investigation
regarding unintentional 911 calls, it appears that wireless handset
manufacturers, wireless carriers, and public safety associations are
working to reduce the incidence of unintentional 911 calls made to
PSAPs. It also is apparent that a concerted effort among all interested
parties may be the most cost-effective and least burdensome means by
which an adequate resolution to this issue can be reached. Handset
manufacturers and wireless carriers have acknowledged the problem as
reported by the PSAPs, and have made commitments to take affirmative
steps to reduce the likelihood that wireless customers will
unintentionally dial 911.

Based on the information received by the Bureau, it appears that many of
the affected parties are interested in resolving this issue voluntarily.
We encourage all parties to continue to work together to resolve the
problem of unintentional 911 calls. Future action by the Bureau or
Commission, if necessary, will be based on the actions or inactions of
the affected parties.

####  V. [NEXT STEPS]{.underline} {#v.-next-steps .unnumbered}

Commission staff will undertake the following steps in the next few
months to further address the unintended calls problem:

Concurrently with today's report, the Consumer and Governmental Affairs
Bureau is releasing a Consumer Alert that calls attention to the issues
in this report and informs consumers on how to prevent unintended 911
calls. In addition to placing the Consumer Alert on the Commission's
website,[^33] the Bureau will send the Alert electronically over the
next few days to the roughly 1,300 consumer groups and individual
consumers who subscribe to the Consumer and Governmental Affairs
Bureau's consumer information e-mail service.[^34]

Working with nationwide public safety organizations and CTIA, we will
contact carriers in addition to those mentioned in this report to alert
them to the issue, point out best practices, and gather information
about what steps they have taken to mitigate this problem.

Working with nationwide public safety organizations and CTIA, we will
contact wireless handset manufacturers in addition to those mentioned in
this report to alert them to the issue, point out best practices, and
gather information about what steps they have taken to mitigate this
problem.

In a continuing partnership with nationwide public safety organizations,
we will:

-   monitor developments in this area to see whether these steps, in
    conjunction with handset churn, are beginning to lead to reduction
    in the portion of wireless E911 calls that are unintentional.

-   seek specific information about the causes, and initiate action to
    reduce the volume of unintentional wireless 911 calls, if the
    actions taken by wireless carriers and equipment manufacturers do
    not appear to be ameliorating the problem of unintentional 911
    calls.

**[Further Information]{.underline}**

For further information regarding this report, contact Andra Cunningham,
Policy Division, Wireless Telecommunications Bureau, at (202) 418-1310
(voice) and (202) 418-1169 (TTY).

[^1]: *See* Letter to Michael K. Powell, Chairman, Federal
    Communications Commission, dated January 9, 2002, sent by APCO,
    NENA, and NASNA at 1. The letter is available in PDF format via the
    following website link:
    <http://www.nena9-1-1.org/Wireless911/index.htm>.

[^2]: *Id*. at 2.

[^3]: *See* Letter to Wireless Carriers, dated December 12, 2001, filed
    by the National Emergency Number Association (NENA) at 1. The letter
    is available in PDF format via the following website link:
    [http://www.nena9‑1‑1.org/Wireless911/index.htm]().

[^4]: *Id*. at 3.

[^5]: *Id*. at 2.

[^6]: *Id*. at 2.

[^7]: *Id*. at 2.

[^8]: *Id*. at 2.

[^9]: *Id*. at 3.

[^10]: *See* Letters from Thomas Sugrue, Chief, Wireless
    Telecommunications Bureau, to John T. Scott, III, Vice President and
    Deputy General Counsel, Regulatory Law, Verizon Wireless; Douglas I.
    Brandon, Vice President, External Affairs and Law, AT & T Wireless
    Services, Inc.; and Brian T. O'Connor, Vice President, Legislative
    and Regulatory Affairs, VoiceStream Wireless Corporation, dated
    August 6, 2002.

[^11]: Bureau staff has relied on the representations of carriers and
    handset manufacturers in preparing this report, and we expect that
    the information they have provided to be accurate. If further
    investigation proves otherwise, we will seek appropriate action
    against the party providing inaccurate information.

[^12]: *See* Roger O, Crockett, *Company News: Is Nokia Missing an
    Important Call?*, BusinessWeek Online, March 27, 2002.

[^13]: *See* Letter from Michael Altschul, Senior Vice President, Policy
    and Administration and General Counsel, Cellular Telecommunications
    and Internet Association, to Thomas Sugrue, Chief, Wireless
    Telecommunications Bureau, dated October 23, 2002 (*CTIA Letter*).

[^14]: CTIA's Certification Program is a voluntary program for suppliers
    and carriers. It provides impartial evaluation of new wireless
    products, such as handsets, to ensure these products meet
    established industry performance standards and consumer information
    requirements. *See CTIA Letter*.

[^15]: *See* Letter to Roger Hixson, NENA Technical Issues Director,
    dated February 6, 2002, issued by Nextel at 2.

[^16]: *Id*. at 2.

[^17]: *Id*. at 2.

[^18]: *Id*. at 2-3.

[^19]: *See* E-Mail to Roger Hixson, NENA Technical Issues Director,
    dated February 12, 2002, issued by Cingular.

[^20]: *Id*. at 2-3.

[^21]: *See* Letter to Roger Hixson, NENA Technical Issues Director,
    dated February 13, 2002, issued by ALLTEL at 1.

[^22]: *Id.* at 1.

[^23]: *Id*. at 1.

[^24]: *Id*. at 1-2.

[^25]: *See* Letter to Roger Hixson, NENA Technical Issues Director,
    dated February 21, 2002, issued by Sprint at 1.

[^26]: *Id*. at 1. In a staff conversation, Sprint stated that only
    three of over 80 handsets Sprint has marketed have ever had the
    auto-dial 911 feature.

[^27]: *Id*. at 2.

[^28]: *See* Nextel letter at 3; Cingular e-mail at 2; and Sprint letter
    at 2.

[^29]: *See* Nextel letter at 3; Cingular e-mail at 2.

[^30]: *See* Letter from John T. Scott, III, Vice President and Deputy
    General Counsel, Regulatory Law, Verizon Wireless, to Thomas Sugrue,
    Chief, Wireless Telecommunications Bureau, dated August 21, 2002.

[^31]: *See* Letter from Douglas I. Brandon, Vice President, External
    Affairs and Law, AT & T Wireless Services, Inc. to Thomas Sugrue,
    Chief, Wireless Telecommunications Bureau, dated August 21, 2002.

[^32]: *See* Letter from Brian T. O'Connor, Vice President, Legislative
    and Regulatory Affairs, VoiceStream Wireless Corporation, to Thomas
    Sugrue, Chief, Wireless Telecommunications Bureau, dated August 22,
    2002.

[^33]: This Consumer Alert can be found on the Commission's website at
    [www.fcc.gov/cgb](http://www.fcc.gov/cgb), by clicking on "Consumer
    Alerts and Factsheets."

[^34]: To subscribe to this Consumer Alert and automatically receive
    information on other consumer topics, a consumer need only contact
    [www.fcc.gov/cgb/emailservice.html](http://www.fcc.gov/cgb/emailservice.html).