UNITED STATES OF AMERICA

\+ + + + +

FEDERAL COMMUNICATIONS COMMISSION

\+ + + + +

WIRELESS E911 COORDINATION INITIATIVE

INAUGURAL MEETING

\+ + + + +

TUESDAY,

APRIL 29, 2003

\+ + + + +

The meeting was held at 9:00 a.m. in the Commission Meeting Room, Room
TW-C305, 445 12th Street, SW, Washington, D.C.

[ROUNDTABLE PARTICIPANTS]{.underline}:

MICHAEL ALTSCHUL

EVELYN BAILEY

GREGORY BALLENTINE

CARESSA BENNET

HONORABLE TIM BERRY

CHARLES DAVIDSON

SARALYN DOTY

THOMAS DUNLEAVY

NORMAN FORSHEE

ANTHONY HAYNES

BILL HINKLE

ELIZABETH HOFFMAN

LAVERNE HOGAN

DAVID JONES

ELIZABETH KOHLER

KARL KORSMO

LARRY KREVOR

TOM LATINO

SHARON MAHONEY

FRAN MALNATI

STEVE MARZOLF

CHARLES MCKEE

JOHN MELCHER

[ROUNDTABLE PARTICIPANTS]{.underline}: (CONT.)

SUSAN MILLER

JACKIE MINES

JIM NIXON

MICHAEL O\'CONNOR

MIKE PEDIGO

ERNIE PETERSON

JOAN SHORES

GREGORY STRUNK

RICHARD TAYLOR

[PRESENT FROM THE FCC]{.underline}:

MICHAEL POWELL Chairman

KATHLEEN ABERNATHY Commissioner

JONATHAN ADELSTEIN Commissioner

MICHAEL COPPS Commissioner

KEVIN MARTIN Commissioner

JOHN MULETA Chief, Wireless

Telecommunications Bureau

K. DANE SNOWDEN Chief, Consumer and Governmental Affairs Bureau

DAVIS SOLOMON Chief, Enforcement Bureau

[I N D E X]{.underline}

[AGENDA ITEM]{.underline} [PAGE]{.underline}

**Opening Comments/Introduction**

John Muleta 6

Michael Powell, Chairman 7

**Hatfield Report - Overview of Findings**

Dale Hatfield 15

**Collaborative Deployment Efforts Between**

**Public Safety, Industry, and Government**

Introductory Speaker:

Commissioner Kevin Martin 25

National Emergency Number Association

\"SWAT\" Initiative (John Melcher) 28

APCO International \"Project Locate\" &

Public Safety Foundation of America

(Bill Hinkle) 36

Emergency Services Interconnection

Forum (Susan Miller) 45

Department of Transportation Wireless

E911 Steering Council (Evelyn Bailey) 51

**Wireless Carrier Implementation**

Introductory Speaker:

Commissioner Kathleen Abernathy 62

Indiana Wireless Enhanced 911 Advisory

Board (Honorable Tim Berry) 67

Mid-America Regional Council

(Saralyn Doty) 73

AT&T Wireless Services (Karl Korsmo) 79

Sprint PCS (Charles McKee) 84

Cellular Telecommunications & Internet

Association (Michael Altschul) 89

Q&A/Discussion 98

I-N-D-E-X (cont.)

[AGENDA ITEM]{.underline} [PAGE]{.underline}

**Public Safety Answering Point Funding**

**and Operation**

Introductory Speaker:

Commissioner Jonathan Adelstein 117

APCO International

(Gregory Ballentine) 119

Virginia State Emergency Services

Board (Steve Marzolf) 124

New York State Assemblyman David Koon

(Elizabeth Hoffman) 131

National Emergency Number Association

(John Melcher) 136

Q&A/Discussion 144

**Local Exchange Carrier Issues**

Introductory Speaker:

Commissioner Michael Copps 177

Texas Cost Recovery Team (Mike Pedigo) 178

SBC (Tom Latino) 184

New York State Public Service Commission

(Commissioner Tom Dunleavy) 188

Q&A/Discussion 196

**Rural Deployment Issues**

Introductory Speaker: Dale Hatfield 203

Vermont Emergency Services Board

(Evelyn Bailey) 205

Rural Cellular Corp. (Beth Kohler) 214

Rural Telecom Group (Carri Bennet) 219

Q&A/Discussion 225

I-N-D-E-X (cont.)

[AGENDA ITEM]{.underline} [PAGE]{.underline}

**Consumer and Carrier Education**

Dane Snowden 237

David Solomon 242

**Closing Remarks and Next Steps**

John Muleta 247

P-R-O-C-E-E-D-I-N-G-S

9:03 a.m.

MR. MULETA: Good morning everybody. This is the first meeting of the
Commission\'s E911 Coordination Initiative. I\'m John Muleta, Chief of
the Wireless Telecommunications Bureau. What I wanted to do before
turning it over to the Chairman was run over a few housekeeping items
since this will be a long day.

First of all, we have an official timekeeper here to my right, Leon
Jackler, who will give all the speakers a one minute warning before
their time is up. The warning will be shown as a yellow light on the
timekeeping instrument up here for those speakers that come up here. We
have only one scheduled break which is a lunch break between 12:45 p.m.
and 1:45 p.m.

There are two cafeterias in the Courtyard area which on the elevator is
CY. Both are open to the public. For the really important detail, the
bathrooms are towards the back and towards the checkpoint that you came
through. If you have not signed in somehow, we ask that you do so to get
an accurate count. We\'re talking about the sign up in the back where
you get the nametags, so please do that. We\'re trying to make sure that
we have all the people identified and also gage the interest in the
coordination initiative.

If the room does fill up and you have other people joining you at a
later time, there is an overflow room with a closed circuit television.
The room is TW-C438/468. Those are two rooms. If there are any questions
as to how to get to them or direct the people, just talk to the people
that are in the back that are helping with this meeting.

Another key point. Again if you have people that want to participate or
want to watch the initiative, the meeting is being webcast on the
Commission\'s website. It\'s also being transcribed by a Court Reporter
for the submission into the E911 docket. That said, I will turn it over
to Chairman Michael Powell.

CHAIRMAN POWELL: Thank you, John. Welcome and good morning to everybody.
All you have to do is look out at all of these people and realize this
is a group that could use some coordinating. As evidenced by the fact
that there\'s no break, there\'s a lot of work to do apparently.

It is my pleasure to welcome you. Fortunately, we have a remarkable
collection of expertise today; wireless and wireline carriers large and
small, public safety organizations and state emergency services boards,
state public utility commissions and state legislatures. All of them
will need to be pulling hard on this oar to accomplish this great task.
I\'d like to welcome those PSAPs and other interested parties who are
watching this meeting via the Internet.

Before I give some formal remarks, I want to acknowledge the remarkable
work of the Wireless Telecommunications Bureau, especially the Data
Management and Policy Divisions and the CGB staff that have made
today\'s events possible. They have really done remarkable work. In
particular, I want to thank Lauren Kravetz and Jennifer Tomchin of the
Wireless Bureau for their relentless efforts that they have done today
to make this event a success. It\'s particularly remarkable since it is
Lauren\'s birthday. Happy Birthday, Lauren.

(Applause.)

CHAIRMAN POWELL: It\'s the only leave form I\'ve turned down the whole
time I\'ve been here. It\'s good to have you here on your birthday. I
have spoken at great length about the importance of the digital
migration that is underway across America. I\'ve also detailed my strong
commitment to the Commission\'s public policy/public safety licensees
and their homeland security responsibilities.

The E911 challenge marries these twin policy goals. That is we must work
together to move wireless carriers, manufacturers, consumers along the
migration trail for E911 capability while ensuring that the necessary
ILEC capabilities are made available in a timely manner on financially
reasonable terms. Of course, all of this does not advance the public
interest unless the public safety community is technologically capable
of processing the information produced by the E911 Phase II technology.

Dale Hatfield, in his report, did an extraordinary job in detailing this
challenge. Once again, I would like to thank him and Leon Jackler of the
Wireless Bureau on their extraordinary work that has help prompted our
actions here today. This event is largely an outgrowth of their efforts.

E911 coordination initiative is attracting attention at the highest
levels throughout government. As you know, Congress has recently created
a bipartisan Congressional E911 Caucus to focus on these very issues. I
want to acknowledge the leadership of Senators Burns and Clinton and
Representatives Eshoo and Shimkus on this important issue as well.

In addition to the leadership from The Hill, the Bush Administration has
worked very aggressively to help spread deployment. With us today is NTI
Administrator Nancy Victory. In addition, I know we also have
representatives from DHS, GAO, and DOT with us today. I want to thank
them for being here as well.

Today we will launch what I hope will be a new era of coordination in
the E911 debate. Everyone in this room has been a part of the debates
and controversies that have led us here today. But as we gather here, it
strikes me that we share an extraordinary number of common goals that
should provide a solid foundation for this era of cooperation.

First, it seems to me that we are all committed to bringing the benefits
of E911 technology to as many Americans as possible and as quickly as is
practical. We all recognize that such an effort requires extensive
coordination and cooperation among all of the parties, government,
PSAPs, carriers, ILECs and the public. Third, we all believe that
resources should be deployed for E911 in such a way that every dollar
spent helps to save lives.

We all believe that consumers need to know and understand what is
possible from E911 and when to expect it. We all believe that parties
should not obstruct E911 deployment based on unnecessary delay or
procedural gamesmanship at the state or federal level either. The
coordination initiative is just that. It is designed to initiate
coordination between and among all of the parties so that this new era
of cooperation will take root and grow.

This approach grew in large part from Dale\'s report as I said, but it
is informed by the fact that I believe and the 911 Act contemplates that
the Commission should play a coordination and clearinghouse role in this
undertaking. We cannot solve all of the problems of E911, but we can
pull together all of the players who can make the E911 process work
better.

This challenge must be met because E911 will play an extraordinarily
significant part in the lives of Americans. Increasingly, 911 calls are
being made from wireless phones. PSAPs report that they now receive 30
to 50 percent of emergency calls from wireless phones and that
percentage will only go up. It is essential that first responders be
able to locate those 911 callers.

We have made significant progress in the past year. According to the
most recent data, Phase II information is being provided today by at
least one wireless carrier on 911 calls in approximately 125 markets
across the country to more than 300 PSAPs. Deployment of Phase II by
multiple carriers has been reported in the states of Rhode Island and
Vermont. Moreover, major municipal deployments have occurred in an array
of other states including Illinois, Indiana, Kansas, North Carolina,
South Carolina, Texas and my home state of Virginia. We specifically
sought out presenters and roundtable participants for today\'s meeting
from these key areas. We appreciate your time and effort in being here
with us today.

Every nationwide carrier using handset based approach is offering at
least one location-capable handset model in accordance with applicable
benchmarks. Both Sprint and Verizon offer their customers at least ten
different GPS-enabled handsets. Every nationwide carrier using a handset
based approach is offering at least one location-capable handset model
in accordance with applicable benchmarks.

Further, we have seen further progress in bringing Phase I online. In
particular, I\'d like to recognize the efforts of the wireless carriers.
Over the course of the past few years, the tone and focus of the
carriers have shifted from questioning the wireless E911 mandate to
putting the technology in place and making it a reality in a small but
growing number of localities. The most recent quarterly report showed
increased momentum in deployment. I have every confidence that these
numbers will show significant further improvement when we receive the
May 1 quarterly report shortly.

That brings us to today. We have an ambitious agenda to sort out what
has worked and get people sharing information and ideas to cooperate in
advance of our common goals. Many of the issues we\'ll be discussing
today are those raised by Mr. Hatfield in his report; namely that
wireless carrier implementation, focusing on how wireless carriers and
PSAPs in state and local governments have successfully resolved the
issues of wireless carrier implementation issues, PSAP funding and
operation, focusing on how certain states have been able to fund E911
deployment, LEC issues, focusing on how parties have resolved issues
regarding the roles and responsibilities of wireless carriers, LECs and
PSAPs and rural issues, focusing on the particular challenges facing
rural wireless carriers and PSAPs in rural areas.

The FCC E911 coordination initiative is not the only attempt to bring
together groups of stakeholders to cooperate in building solutions. In
one of the sessions later this morning, we\'ll hear from a cross section
of other such collaborative efforts including the National Emergency
Number Association and its strategic wireless action team initiative,
APCO on its Project Locate, the Emergency Services Interconnection Form
which is a partnership between NENA and the industry sponsored Alliance
for Telecommunications Industry Solutions, and the Department of
Transportation\'s Wireless E911 Steering Council.

Our intent here today is to recognize and build upon the hard work and
critical thinking that has been developed through these initiatives.
Indeed, we do not want to duplicate or diminish these efforts in any
way. Rather, we want to build on them and together make the E911 process
work smarter and better. I\'m proud to be a part of that effort.

Now it is my distinct pleasure to call up our first speaker today, Dale
Hatfield, who is an independent expert who is tasked with looking into
the technical and operational impediments to deployment. Dale will speak
today about some of the key findings and recommendations in the report.
I thank you for coming to the Commission today. I thank you for your
service. I look forward to making a significant contribution in this
effort. Dale.

(Applause.)

MR. HATFIELD: Thank you very much, Mr. Chairman, for the very kind
introduction. I was honored when the Commission originally chose me to
conduct the independent inquiry and to produce the accompanying report
on the technical and operational issues impacting on the provisioning of
wireless E911. I\'m again honored to be here today to participate in
this event.

The focus of my inquiry was on the future of wireless E911 deployment
including any obstacles to deployment and the steps that might be taken
to overcome or minimize them. As it turns out, it was just over a year
ago that many of us gathered in this same room to kick off that inquiry.
Over the succeeding months, I held literally scores of meetings with
literally hundreds of people all devoted to increasing the safety of the
American public.

As most of you probably know, the report that we prepared was delivered
to the Commission last October. I\'ve been generally very pleased with
the reaction that it\'s generated. Because of the limited time and the
fact that many if not most of you are somewhat familiar with the report,
I will not go into any detail on my findings and recommendations.
Rather, I will present a brief overview and commentaries on what I feel
are the most important points.

In the findings section of the report, I noted the strong federal
interest in the nationwide availability of E911 and on that basis
recommended that there be increased coordination between and among
federal agencies. The events of the recent past have clearly
demonstrated that E911 is not just an issue of safety of life and
property but one of critical importance to homeland security as well.
Given the increasing proportion of calls originating from wireless
devices and the growing substitution of wireless phones for wireline
phones, the need for a rapid deployment of wireless E911 becomes more
obvious every day.

Stated another way, E911 is not some sideshow. It\'s an essential part
of our nation\'s emergency communications infrastructure. Indeed, since
the submission of the report, I have gained an even greater appreciation
of its relationship to not only homeland security but to telematics, for
example, automatic crash notification systems, hazard material or HAZMAT
truck incidents, and weather events as well. Recently I had somebody
call me and describe a product that would detect cardiac incidents and
actually report that with latitude and longitude attached to the
information.

In the findings, I raised concerns about the technical limitations
associated with the existing wireline and wireless E911 infrastructure
and especially with its ability to evolve smoothly and efficiently to
address some of these emerging requirements. This morning I would merely
stress the need for a modern infrastructure that is not only capable of
efficiently and effectively handling traditional wireline and wireless
calls but one whose overall architecture facilitates the exchange of
evolving types of emergency communications information between and among
federal, state, and local agencies and the public that they serve.

I might add we need an architecture that remains true to our other
public policy values such as competitive and technical neutrality and
reliance to the maximum extent possible on competitive marketplace
forces. This last commentary leads me to another major finding of the
report. As I stated in the report when I undertook the inquiry on behalf
of the Commission, I was already somewhat aware of what was involved
from my being here.

As I dug into the subject deeper and deeper, what really struck me was
the overall complexity of the undertaking. As I pointed out a moment
ago, a variety of critical, technical, and operational choices including
critical decisions relating to network architectures must be made to
ensure the reliable and seamless E911 system contemplated by Congress
when it passed the 911 Act.

The complexity, of course, stems from the fact that there\'s no single
decision-maker, no master architect if you will, for emergency
communication systems. Instead, decision-making of this type is spread
over a large number of stakeholders in multiple jurisdictions. Because
of the total number of stakeholders involved, for the complexity of the
interrelationships among the stakeholders and the incentives and
constraints on those stakeholders, I concluded in the report, not
surprising perhaps, that an unusually high degree of coordination and
cooperation among public and private entities will be required if this
nation is going to have the type of modern infrastructure I described
and I believe that the Congress envisioned in passing the 911 Act.

In the report, I pointed specifically to the need for coordination and
corroboration among all stakeholders, public and private, in such areas
as overall systems engineering, project management, and the development
and adoption of standards. In another of the findings, I expressed
concern that the roll-out of wireless E911 service was being hampered by
the lack of funding and other resources for public safety access
providers or PSAPs in many jurisdictions across the country.

I pointed specifically to the lack of cross recovery mechanisms, the
lack of a champion within the federal government, and residual awareness
and readiness issues within the PSAP community itself. Unfortunately
perhaps in the report, I used the term \"PSAP fatigue.\" I think my
phone rang immediately the next morning. It was taken a little bit as
some sort of a criticism of PSAP efforts. I want to say here exactly the
opposite was true. It was meant to point out that they, our PSAPs, need
more support in shouldering an enormous burden.

Another of the findings in the report related to the role of the
incumbent local exchange carriers, the ILECs, in the provision of E911
services. I found that despite the central role that these carriers play
in some implementations of E911 services their responsibilities had not
been defined either in terms of their technical requirements or in terms
of cross recovery.

Lastly, I found that there appeared to be a lack of well accepted
standardized tests for determining compliance with the Commission\'s
accuracy requirements including issues regarding geographic averaging. I
went on to express the concerns that this uncertainty could ultimately
prove to be an impediment to the more rapid deployment of wireless E911
systems.

In light of those findings, I made several recommendations to the
Commission. I\'ll just briefly mention them here. First, recognizing
both the strong federal interest in the nationwide availability of E911
and the somewhat limiting scope of the Commission\'s jurisdiction. I
recommended to the Commission working more closely with other federal
agencies to encourage a coordinated approach in dealing with issues
associated with the deployment of wireless E911.

More specifically, I recommended that it work with the Administration
and particularly the then-nascent Department of Homeland Security to
establish what I referred to as a national E911 program office. As I
envisioned it at the time, the office within DHS would serve as a
resource and advocate, a champion if you will, to the nation\'s first
responders on the issue of 911 deployment.

Second, I recommended that the Commission increase its own oversight of
the efforts of E911 during this critical phase of deployment. To that
end, I recommended that the Commission establish a formal advisory
committee that would address the technical framework and longer-term
network architecture issues associated with the further development and
deployment of E911.

Third, noting that my findings suggested that in at least some
situations deployment of wireless E911 may be hampered by lack of
coordination and dialogue among stakeholders groups, I recommended that
the Commission establish an information clearinghouse, for lack of a
better term, that would collect and dissemination information critical
to deployment so the stakeholders could better coordinate with one
another. I also recommended the Commission work with and appropriately
support the efforts of public, private, and joint efforts aimed at
speeding the role out.

Let me digress briefly to say that since the publication of the report I
have been gratified to see what I perceive as an overall increase in
such coordination and communications among stakeholders and a general
increase in the level of priority and awareness of the importance of
E911 among policy-makers, industry, and the general public. In addition
to the Commission\'s own wireless E911 coordination initiative which
brings us here today, we are seeing other activities which I understand
will be described in more detail that include DOT\'s wireless E911
Steering Council, the ESIF or Emergency Services Interconnection Forum
jointly sponsored by ATIS and NENA, the Association of Public Safety
Communications Official\'s Project Locate, and NENA\'s strategic
wireless action team or SWAT initiative.

The latter for example provides a forum for communications among public
safety organizations, wireless carriers, wireline carriers, state
representatives, and other participants. As I understand it, the course
of action that they are following is intended to build on the input of
the various stakeholders and to develop consensus recommendations among
the various parties. Significantly, in my mind, it includes the
resources to conduct supporting analyses to inform and shape the
process. While I cannot and should not endorse any of the results that
they are obtaining, I do believe that it represents the cooperative
process which is required for sustainable progress in E911 deployment in
an extremely complex environment.

Returning to my recommendations. My fourth suggestion was the
development of industry-wide procedures for testing and certification
for wireless E911 systems to ensure that they do indeed meet the
Commission\'s accuracy requirements. I also recommended the Commission
undertake to more clearly define those requirements to eliminate any
remaining uncertainty as to what constitutes compliance.

I will close by noting again this is a very brief overview of what is
contained in the report. I\'m glad to say that some of the developments
that I have touched upon here this morning and others we will hear about
more later today have already made portions of my report outdated. I do
understand that PSAPs, serving about 35 million Americans, are now
providing Phase II capabilities with at least one carrier. Despite
substantial progress however I have seen figures that suggest we have a
long way to go, namely seven years after the rules were passed and two
full years after they could have written their formal Phase II request
letters, PSAPs representing over half of the population have not yet
done so. I\'m not sure of that number, but that\'s one number I did see.

The public safety agencies and the public they serve are facing a Swiss
cheese situation where a caller can be found in one city but not an
adjoining suburb. Even worse, at the switch of a wireless company or its
vendor, the exact location may be known but the information may not be
displayed to first responders because the necessary upgrades for the
PSAP equipment have not been made.

We need the benefit of the best possible thinking on how we can
accelerate our deployment of wireless E911. I\'m personally looking
forward to hearing more about current best practices and innovative
ideas for accelerating the deployment over the balance of the meeting.
Before I turn the podium over to Commissioner Martin, I would like to
personally and publicly thank all the members of the different
stakeholder groups that were so helpful to me in the preparation of the
report that I delivered to the Commission. I mean that with absolute
sincerity. I had a remarkable amount of cooperation in the preparation
of the report.

Very quickly, I would also like to thank two specific individuals for
their help. Chairman Powell already mentioned Leon Jackler of the
Wireless Telecom Bureau. He was absolutely tireless and provided me with
wise counsel throughout the process leading right up to my coming up
here to the podium. He\'s just been a super help to me.

The second person I would like to acknowledge is Sukumar Dwarkanath, my
research assistant at the University of Colorado. After helping me with
the inquiry, Sukumar used the experience gained to produce a very
interesting thesis on how emergency communication services might be
improved in his home country of India. With that, it\'s now my honor to
turn the podium over to Commissioner Martin who will be convening our
first panel.

(Applause.)

COMMISSIONER MARTIN: Good morning everyone. Thank you, Dale, for all of
your work in this regard. The other presenters were going to join me up
here. As we have all just heard, Dale\'s report contains a number of
important insights. I think that none are more important than his
conclusions that E911 deployment will ultimately require an unusually
high degree of coordination and cooperation among all of the
stakeholders.

I strongly agree with this point. In other words, it\'s not enough for
just the Commission to aggressively enforce our E911 deadlines. We must
continue to do that. We must also move beyond the finds and
finger-pointings to work cooperatively with all of the parties involved.
For example, if the PSAPs are unable to process location data sent by a
carrier, the carrier\'s tracking capabilities become moot. The same is
true if the LEC fails to make necessary upgrades.

All of the stakeholders, the PSAPs, the equipment makers, wireless
carriers, the LECs, the state PUCs all must coordinate their efforts. In
that regard, I\'m particularly grateful for the tremendous efforts of
some of the groups who are here today to speak. They have been focused
on bringing parties together to speed the deployment. I have personally
worked with a number of them. I\'m thrilled with the work that they are
doing.

The Commission\'s goal in convening this forum is not to duplicate those
efforts but instead to build upon them. First, we will hear from John
Melcher, the president of NENA, on NENA\'s strategic wireless action
teams. The SWAT initiative brings together national leaders from public
safety, finance, policy, technology, and the government to establish
priorities and benchmarks for 911 systems. Among other things, the SWAT
initiative conducts essential outreach and provides support for E911
deployment across the country.

We\'ll then hear from Bill Hinkle, chairman of APCO\'s Project Locate
and chairman of APCO\'s Public Safety Foundation of America. APCO\'s
Project Locate helps PSAPs file requests for Phase II service. It also
works to promote communication between PSAPs and wireless carriers. By
gathering and sharing information with PSAPs, it helps spot recurring
issues that require national attention. APCO\'s Public Safety Foundation
of America receives and distributes grant money for public safety
agencies. The foundation makes awards for large scale projects designed
to encourage state-wide implementation and funds projects for individual
PSAPs.

We\'ll then hear from Susan Miller, president and CEO of the Alliance
for Telecommunications Industry Solutions or ATIS. This is Emergency
Services Interconnection Forum or ESIF. It\'s hard to keep up with all
of these. ESIF serves as a venue for the telecommunications industry,
public safety and other stakeholders to resolve technical issues related
to interconnection of telephony and emergency service networks.

Finally, we will hear from Evelyn Bailey, chair of the steering
committee of the U.S. Department of Transportation\'s Wireless E911
initiative. This initiative brings national leadership to the E911 issue
providing technical assistance, guidance, and training. It also engages
the nation\'s leading information technology experts in examining the
technological approach to E911.

I want to personally thank each of the groups and their representatives
that are here today for doing all that they can and for being with us to
share their work and let us all learn from that going forward. With
that, I would like to start by asking John Melcher to tell us about the
SWAT initiative.

MR. MELCHER: Thank you, Commissioner Martin. Welcome to the class
reunion of the Class of 94-102. I\'m John Melcher. I\'m not your host,
but I\'m proud to be an alumnus of the class of 94-102. When all of this
started back in \`92 and \`93, the State of Texas Attorney General\'s
office filed a petition for reconsideration when the PCS bands were
opening up for auction.

We figured we had not signed much of a success story on locating
wireless callers to 911 in the 800 megahertz spectrum. Why are we doing
this in the higher bands before we solve it and the lower bands? That
brings us to where we are today, the first petition and all of the
subsequent efforts that have gone on.

It\'s very appropriate to applaud the Commission\'s efforts for hanging
a target on the wall. It was a very bold and brave and highly
controversial move that led to the first rule makings. But it was truly
an effort that was blessed because it caused so many things to happen.
As you know, most everyone here in this room has a lot of history with
this. There\'s been a lot of progress. There\'s also been a lot of
challenges and a lot of hurdles.

So I would like to talk a little bit about the National Emergency Number
Association and what our organization is doing to help bring closure to
some of these issues and help spread the proliferation of wireless E911.
You\'ll hear from a lot of experts today. Everyone in this room has a
role to play. Everyone\'s role is very valuable in that everybody brings
a contribution. That\'s what we would like to focus on. What the SWAT
initiative is all about is focusing on those contributions, the can dos
not the can\'t dos.

Early on, the wireless carriers did, as Chairman Powell mentioned this
morning, question and even challenge the possibilities of bringing
wireless 911 to bear. In the old days, the public safety community saw
the wireless community as a bunch of whining carpetbaggers. You are
making all of this money. Why don\'t you just do something about it?
Throw money at it. That will fix it.

But the public safety community has grown quite immensely and has
matured an incredible amount over the last ten years because we
recognize that we\'re not the only ones with challenges. Everyone has
challenges. The local exchange carriers have a vast role to play here.
They too must step up to the plate as much as public safety and the
wireless community and all of those that serve us in some shape, form,
or fashion, those third party service providers.

The SWAT initiative was actually born of a desire to bring the
appropriate intellect together to solve problems. It wasn\'t about
rehashing the past. It certainly wasn\'t about recriminations or sending
anyone to the woodshed. It was more about what can we do as opposed to
what can\'t we do.

With other initiatives going on, the Secretarial DOT initiative and with
other forums, I\'m reminiscent just a bit of the first meeting that was
held with myself and Thera Bradshaw and a collection of others. There
was everybody who was anybody that had anything to do with
telecommunications and regulations and legislation in the room. The
Secretary and the staff talked extensively about wireless and how many
lives it would save and we could deploy it and where we were going to go
and how we were going to solve this problem and that all the people in
this room were the ones to make it happen.

Then at the end of one statement about this is going to happen and it\'s
going to happen very fast most everyone in the room turned and looked at
Thera and I with the raised eyebrow signaling what are you going to do
about it. It occurred to us that we could not do anything that was
productive until public safety got their act together. Those of us in
public safety had to coordinate with those outside of public safety to
make sure that the corroborative effort was a fruitful one.

So the SWAT initiative is actually complementary to all of the other
things that are going on because it brings into bear what we often refer
to as the collective intellect. I should explain that the SWAT team got
its name by totally backing into it. We sat around a board meeting one
day and said we need a SWAT team together. You put the right people. You
kick in the door. You free the hostages. You make things happen.

So the name stuck. When we finally got the whole thing coordinated and
we got it funded and we got it put together, we said now what are we
going to call this pig. For some reason, SWAT wouldn\'t go away. So we
had to back into it. We came up with all kinds of permutations, some I
cannot share in mixed company, but the final outcome was Strategic
Wireless Action Team.

The team is actually broken into four basic components. There\'s a
technical team. There\'s an operations team. There\'s a policy and a
finance team. These four teams make up the core of the SWAT mission. Let
me state for the record this is no longer a technological challenge as
far as does the technology exist or doesn\'t it. Everything we need to
accomplish this goal is sitting on the shelf today. There will be
improvements to our technology certainly, but we are not lacking
technology to make something happen today.

One of the technical problems that we encountered was 911 is incredibly
fragmented. I wanted so bad to get up here and let my opening comment be
what Dale said because Dale is absolutely correct. We are piece-parted
across the country. If you are a wireless carrier or a local exchange
carrier with a huge multi state footprint, doing it 50 different ways in
50 different states doesn\'t make sense. In some cases, there are many
counties in a state and they do it many different ways within a state
and that doesn\'t make sense either.

I would draw the contrast to the public switch network and the long
distance arena. In an interexchange carrier mode, AT&T Long Distance,
I\'m told, manages the whole country\'s telecommunications and one-plus
dialing on the AT&T network with some 85 or 90 switches. All of these
switches are very compatible.

They are networked together. They talk to one another. They back each
other up. That does not exist on the public safety side. For the
selective routing in this country, we have almost 800 switches. That\'s
too many and none of them talk to each other in a fashion that would
back each other up.

On the operations side, we can set best practices and standards all day
long but until you educate the community about how those work you have
really not accomplished your job. So the operations part of the SWAT
team is tasked with doing that.

On the policy side, one of the reasons that we have almost 800 selective
routers in this country today is because of LATA boundaries. Things like
LATA boundaries should not exist for 911 in today\'s environment. Other
types of inter-district or inter-region or even inter-state requirements
should be lifted for 911 because 911 is sacred and special. If we have
the facilities in one place and the need in another place, we should be
able to string the wires and make it happen.

On the finance side, it\'s about the money, silly. One wants to say
it\'s the economy, stupid. But it\'s about the money, silly. So much
effort has been spent over the last several years to raise money to make
sure that wireless 911 is paid for. In this effort, we find now that
it\'s a matter of the ultimate example of bad timing.

In so many states, a savings account has been built and only when the
technology was available, only when the carriers were ready to put
spreadsheets in front of the public safety community, only when the
local exchange carriers had the tariffs filed could that money be spent.
All of what I have talked about just now is only occurring in the last
few months, not the last few years, but the last few months.

The local exchange carriers now have tariffs in place. The wireless
carriers now have invoices that have real numbers on them that know how
much this is going to cost, so when the public safety people go to get
approval to spend this money, the money is gone. So that is a huge and
important issue for us in public safety and must be addressed.

I would say that the SWAT initiative is all about coming together with
your piece of the puzzle and with your ingredient to bake this cake.
Anyone who comes to the table with adamant predispositions is not doing
a fair job to the others who are sitting around this table. Anyone who
comes to the table that cannot contribute but can only complain is also
not aiding in the final end solution. It\'s all about collaboration.
It\'s all about cooperation. It\'s about not only understanding your
needs but the needs of all of those around the table so that we can take
the collective intellect and make something happen for the good of our
citizens.

(Applause.)

COMMISSIONER MARTIN: Thank you, John. Now I would like to introduce Bill
Hinkle so we can hear about some of APCO\'s efforts.

MR. HINKLE: Thank you, Commissioner, and good morning. When APCO
launched Project Locate on April 11, 2001, it signaled a renewed
commitment by public safety to work with the wireless carriers in our
efforts to accelerate deployment of wireless location technology.

One of our first initiatives in cooperation with NENA and NASNA was to
launch a series of carrier meetings. These were meetings that were being
conducted leading up to the last round of waivers that were granted. We
also worked together to conduct briefings before the Communications
Commission and also entered joint filings. We have shared and
participated in national conference briefings and in our efforts to
continue to help our public safety community addressed the difficult
questions that remained with regards to the barriers preventing
accelerated deployment.

One of the major components of Project Locate was the identification of
50 model communities located throughout the nation. These communities
were successful in helping us develop case studies for deployment
activity. They provided valuable data detailing the complexities and the
barriers of Phase II deployment. We were able to produce special reports
detailing survey information provided by the model communities and again
to help us in our efforts to help keep the Commission informed.

We helped PSAPs cut through some of the bureaucratic barriers that
seemed to be preventing deployment. We were active in monitoring carrier
performance and working with the carriers conducted state and local
educational outreach programs. We continue to promote support for state
PSAPs and state 911 coordinators while providing national leadership and
monitoring federal legislative rule making and funding initiatives.

We continue to work with those eight or nine states that are still
attempting to pass legislative initiatives to provide funding for their
public safety communication systems. We facilitated and continue to
participate in informational programs and panel discussions such as this
at national stakeholder conferences. We have helped to coordinate
deployment activities with other groups to avoid duplication and efforts
with our limited resources. Through the foundation which I will also be
talking about, we have been able to provide some strategic funds to
promote state-wide deployment initiatives through the Public Safety
Foundation of America.

One of our most successful events through Project Locate has been the
Wireless Resource Room that we provide at our national conferences.
These are exclusive one-on-one meetings with Federal Communications
Commission representatives and the wireless carriers.

Again in August, we\'re looking forward to offering those same kinds of
unique opportunities for the average public safety director or manager
to sit down with a carrier or sit down with someone from the Federal
Communications Commission and have these one-on-one discussions without
having to make a trip to Washington. So we look forward to providing
this unique opportunity again with the wireless bureau\'s participation.

Someone once said that no one speaks for public safety. Over the years,
we have come to recognize that if we have any chance of working through
many of these national operational issues, these bureaucratic and legal
barriers that it has necessitated that public safety make a major
commitment to coordinating our efforts. Through the SWAT initiative and
many other initiatives that you will hear about today, we can
demonstrate that APCO and Project Locate have participated and are
supporting a number of national 911 initiatives created to promote the
deployment of wireless location technology.

From Evelyn, you are going to hear about the U.S. Department of
Transportation. They are actually sponsoring two programs. Evelyn will
talk about the wireless 911 Steering Council and that initiative. There
is also a Public Safety Advisory Group. Representatives of that
initiative are also here today.

Through the Joint Program Office, the Public Safety Advisory Group was
established. To date, we have been successful in encouraging the
Secretary of Transportation to make wireless location technology an
initiative in his administration. We have also produced EMS perspectives
on ITS technologies.

We have developed action items in the interest of helping to integrate
our public safety communications systems into the ITS systems. We have
continued to participate with the U.S. DOT in national conference
development programs. We work with DOT in producing trade press
articles. We continue to look for new opportunities with the United
States Department of Transportation to promote this integration of
wireless technology into the ITS system.

We\'re proud to be a part of the NENA SWAT initiative. I\'ve had the
unique opportunity to participate in that program for a number of months
now. It has been a real creative opportunity for many of the nation\'s
leading experts in the public safety communications industry to come
together in a creative think-tank environment to look for new and
creative ways to meet the challenges of wireless location technology.

We\'ve been an active participant in ATIS and the ESIF study groups. We
think that\'s a valuable opportunity for groups like APCO. We have had
an opportunity to participate with the technology leaders in our nation
to provide technical standards to help us simplify the process of
integrating public safety communications technology into our public
safety systems.

We were very pleased to be part of a study group that provided some
clarification in a verification program to satisfy the Richardson order
on verification requirements. That has been recently published and
posted on the ATIS/ESIF website. We hope that by providing this
clarification or certification process for PSAPs that we will again help
to accelerate the implementation of wireless technology.

I\'m very proud to be part of the Public Safety Foundation of America.
This was created by APCO as a unique vehicle to provide critically
needed funding directly to our PSAP community to further the deployment
of call-locating technology. Of course, this money was made possible to
us by a generous contribution from Nextel Corporation.

The Public Safety Foundation of America is making grants for PSAP
equipment and technology, planning and coordination which is one of our
biggest emphasis, strategic deployment initiatives, and educational
programs. We have created a website which we encourage you to visit if
you haven\'t already. It\'s psfa.us.

We are also proud of the national associations that have come together
to work with us, to build integrity into this foundation, to ensure that
monies are being used appropriately, to fund our public safety
communications systems. We\'re pleased to have participating as members
of the advisory group to the foundation the National League of Cities,
the National Association of Counties, the International Association of
Fire Chiefs, the National Governors Association, the National
Association of State EMS Directors, NENA, and the International
Association of Chiefs of Police. They all hold seats on the advisory
committee.

We\'re very pleased today to announce that in our first round of grants
we had 80 applications totaling \$27 million. Eight of them were for
planning and coordination, 64 for equipment and technology, five for
strategic deployment initiatives, and three for education. In all, we
ended up awarding 29 grants. We were very pleased that in awarding those
29 grants of \$2.5 million we were able to provide some funding
assistance and almost seed money in 20 states throughout the nation.
Some grants were as small as \$5,500 which made a significant difference
to some small rural communities and up to \$500,000 to Anchorage,
Alaska.

In the first quarter of this year, the foundation is accepting grant
applications. To date, we have received 111 applications totaling \$31.5
million for additional funding requests. Obviously, we are not going to
be able to provide all of this funding. Again, we hope that we\'ll be
able to provide some critical or strategic seed money that will help
some of these communities leverage other monies that might be available
through other sources in order to help spur this deployment technology.

The Project Locate continues to support all of the various national
initiatives, but there are still questions that obviously remain that
we\'re all struggling with particularly in a NENA SWAT initiative. It\'s
safe to say that traditionally public safety services are constrained or
advanced by local government funding mechanisms with varying degrees of
success and failure.

One example of these are evidenced by the 170 some counties in America
that still do not have access to 911 services and the hundreds of others
that only have basic service because of their dependance on local
government funding. So the question is will continued utilization of
traditional PSAP funding models take decades to achieve universal
wireless coverage.

Knowing that non-traditional forms of communications transcend local and
state boundaries and potentially local resources, as a nation, should we
attempt to build a national wireless 911 location technology
infrastructure using local government funding as a model? Should there
be a 911 role for the federal government perhaps as part of Homeland
Security as a backbone? I pose the question.

The position in public safety to fully utilize wireless telephone
technology is an everyday quality of life issue but also supports our
national security. Ladies and gentlemen, I think it\'s safe to say that
what makes our country great is our natural tendency to raise our
expectations when we see an opportunity to use technology to save lives
and reduce pain and suffering.

As it\'s been stated by Chairman Powell, we know that 50 percent or more
of our calls coming into our communication systems today are coming in
from cellular wireless telephone devices. We already know that these
devices save lives and reduce pain and suffering. Thank you very much.

(Applause.)

COMMISSIONER MARTIN: Thank you, Bill. Now we\'ll hear from Susan Miller
on ESIF\'s efforts.

MS. MILLER: Good morning. Thanks, Commissioner Martin. I want to thank
you for the opportunity to discuss ATIS\' leadership role regarding
enhanced 911 service for deployment for wireless phones. Specifically
I\'m here today to talk about and highlight the activities of ATIS\'
Emergency Services Interconnection Forum or ESIF.

By way of background, ATIS is a unique organization bringing together
wireline and wireless carriers, manufacturers, software developers,
users, and even government to develop technical and operational
standards and solutions to some of the industry\'s most complex
problems. We have also had a significant role in identifying the
industry\'s technical and operational priorities. The identification of
which allows for the development of market driven standards and
efficient allocation of resources in these times of economic
sensitivity.

The ATIS board representing the senior most executives from within the
industry has identified emergency services as one of the industry\'s
most pressing priorities. It\'s an industry priority that demands
careful, coordinated collaboration among numerous industry players and
public safety organizations. This should really allow you to appreciate
why ATIS and NENA came together to form ESIF.

The ESIF is a forum of key stakeholders from the industry and public
safety community such as AT&T, Bell South, Verizon, SBC, Sprint PCS,
Nextel, T-Mobile, True Position, Entrada, NENA, Tarrant County Texas 911
District, State of Washington Emergency Management Division, and APCO.
All of these organizations and others provide resources via the ESIF to
resolve technical and operational issues in an effort to ensure the
successful and complete deployment of E911 services for wireless phones.

ATIS is extremely proud to sponsor the ESIF as an industry forum and to
play a leadership role along with NENA in the ESIF activities. The ESIF
held its inaugural meeting in May 2002. Today, just shy of a four year
existence, the forum has discussed and validated more than 20 critical
technical and operational issues surrounding the implementation of E911.

During its short existence, the ESIF has proven to be a valuable venue
for collaboration among all of the affected parties as well as a source
of technical input to the Commission. In fact, several of the ESIF
activities are in direct support or response to recommendations found in
the Hatfield report. Two such key initiatives from ESIF may be directly
tied back to the Hatfield report; PSAP readiness and ESIF\'s technical
input to the FCC on the issue of non-service initialized phones.

As we know, the Hatfield report specifically recommended the need for
public safety answering points or PSAP readiness for the deployment of
Phase II E911. FCC rules require a PSAP to demonstrate that it is ready
and able to receive and utilize Phase II data before requesting Phase II
services from wireless providers.

The Commission partially defined readiness in its City of Richardson
decisions but confusion and uncertainty remained among PSAPs and
wireless carriers as to the readiness standard and how it is really
conveyed. A significant success of ESIF was the release in January 2003
of the wireless E911 Phase II readiness package.

The ESIF readiness package is a consensus-based, step-by-step, standard
evaluation method for PSAPs to determine their readiness to provide
Phase II capabilities as well as a standard process to provide
notification of such status. The ESIF readiness package is freely
available via the ATIS and NENA websites and has been distributed by
APCO as well as several wireless service providers.

Another Hatfield report recommendation reported to the need for the
establishment of an advisory committee to address the technical
framework for the further development and evolution of E911 systems and
services. To that end, ESIF has served as a source of technical
information to the Commission in the context of non-service initialized
phones.

In response to the Commission\'s order regarding non-service initialized
phones, ATIS on behalf of ESIF filed several sets of comments and
participated in a number of *ex parte* meetings setting forth the
technical justifications for the ESIF recommended solution to the call
back problem. Specifically, the ESIF recommended the use of an existing
technical solution found in an industry standard called \"Enhanced
Wireless 911 Phase II Annex C\" which was jointly developed by ATIS\'
Standards Committee T-1 and the Telecommunications Industry Association.
This solution provides for a surrogate number of 911 plus seven digits
based on the wireless handset\'s electronic serial number or
international mobile station equipment identity.

While there were a number of technical reasons documented to support the
ESIF recommendation, the forum highlighted the fact that this Annex C
solution is further reaching in that it not only addresses the callback
issue in 911 only and non-services initialized phones as targeted by the
Commission\'s order but it also addresses the callback issue in other
circumstances where a valid callback number may not be available for
delivery to the PSAP. Such circumstances include international roamers,
phones with lapsed subscriptions, or without subscriber identity modules
and other situations where a phone may not be in service, may not have
given service in given areas due to the lack of roaming agreements.

In September 2002, the FCC granted the ATIS request for a stay regarding
October 1, 2002 effective date for the mandated implementation of the
previously ordered solution which was a consecutive code of 123-456-7890
as the callback number pending consideration of the ATIS petition for
reconsideration. As recently as February 24 and March 5, the ESIF
provided further technical justifications and information regarding the
Annex C solution to the Commission. The ESIF now anxiously awaits the
Commission\'s action on this issue.

There are a number of other issues currently under study within ESIF
that are intended to expedite E911 deployment. These issues in general
deal with such topics as 911 call handling, location reliability and
confidence, mid-call location updating, 911 calls by international
roamers, standard text messages to PSAPs, standardized wireless carrier
procedures, contact lists for PSAP 911 call investigations, and uniform
location testing guidelines.

The uniform testing guideline issue is of critical importance to the
industry. Location reporting in the form of latitude and longitude is
really the crux of Phase II service. Given the highly competitive and
diversified nature among the providers of location and air interface
technologies, a uniform set of test parameters needs to be developed and
agreed to by all stakeholders in order to provide fair and comparable
test procedures. The ESIF provides a neutral body of industry
stakeholders where an agreed to set of test parameters may be developed
and applied for all technologies.

ATIS and the ESIF share the Commission\'s focus on the need for
cooperative measures to deploy and evolve E911 services and systems.
ATIS is taking the lead to ensure that the necessary technical and
operational industry standards are in place. ATIS and ESIF are also
active in both the NENA SWAT initiative described by Mr. Melcher and the
Department of Transportation Wireless E911 Steering Council that will be
presented next by Ms. Bailey.

ATIS continues to work cooperatively with NENA and its technical
development committee. ATIS and ESIF will continue to bring together the
requisite stakeholders to meet the E911 challenges and develop both
critical and essential solutions to related issues. We stand ready to
assist the Commission and the industry as a source of technical and
operational expertise. Thank you.

(Applause.)

COMMISSIONER MARTIN: Thank you, Susan. Now we\'ll hear from Evelyn
Bailey on the DOT\'s Wireless E911 initiative.

MS. BAILEY: Good morning everybody. My name is Evelyn Bailey. I am
Executive Director of the State of Vermont\'s Enhanced 911 Board. I\'m
also president of the National Association of State 911 Administrators
and chair of the U.S. Department of Transportation\'s Wireless Enhanced
911 Steering Council. It\'s in the latter capacity that I speak to you
this morning.

The Department of Transportation is complying with the FCC mandate and
has made this an urgent national priority and as a demonstration of that
convened two groups to help with the process. The Wireless Enhanced 911
Steering Council met for the first time in April 2002 at a summit here
in Washington, D.C. After that, several meetings have been held by an
expert working group doing a lot of the leg work or the grunt work as
the case may be and chaired by Bill Hinkle.

I have to say that Secretary Mineta\'s leadership has really been key to
the progress that we have made as industry leaders. I would like to talk
a little bit about the Steering Council and the organizations that make
it up because many folks are here in the room and a lot has been done.
All of the folks who are sitting at the table here are part of the
Steering Council and have been from the beginning. I\'m very proud of
what we have accomplished and hope that we continue to build upon it.

First of all, it\'s a wide cross section of stakeholders from all levels
of government, private industry, and the national nonprofit associations
of all of the stakeholders. They include Entrado Incorporated, Qualcomm,
the National Association of State EMS Directors, the Integrated Justice
Information Systems Industry Working Group, the American Association of
State Highway and Transportation Officials, the ITS America\'s Public
Safety Advisory Group, and the American Heart Association.

They also include the National Association of State EMS Physicians, the
National Conference of State Legislatures, the National Governors
Association, the International Association of Chiefs of Police, the
Cellular Association of Fire Chiefs, the Cellular Telecommunications and
Internet Association, the United States Telecommunications Association,
the National Association of Regulatory and Utility Commissioners, Bill
Hinkle who is chair of the expert working group, the ATIS/ESIF group,
and of course the National Association of State \-- Administrators, the
National Emergency Number Association, and the Association of Public
Safety Communication Officials. The FCC has also attended all of our
meetings generally in the person with Dan Grosh and has monitored our
progress and participated in our discussions.

Secretary Mineta gave us a job to do. That job was to identify solutions
to the problems of wireless E911 and to make recommendations that would
expedite deployment. The expert working group did a lot of the leg work
and then presented the results of its investigations to the Steering
Council. After several meetings of analysis and discussion, we
ultimately identified six priority actions that we believe will
accelerate compliance with the FCC\'s wireless enhanced 911 mandate.

They are as follows: (1) establish support for state-wide coordination
and identify points of contact within every state for each of the
stakeholders, (2) help to convene stakeholders in appropriate 911
regions in order to facilitate more comprehensive coordinated
implementations, (3) examine cost recovery and funding issues at the
state level to determine what is available and whether it\'s adequate,
(4) initiate a knowledge transfer and outreach program to educate PSAPs,
wireless carriers, and the public, (5) develop a coordinated deployment
strategy encompassing both rural and urban areas, and (6) implement a
model location program. Many of these elements are the elements of Dale
Hatfield\'s report. I\'m sure they sound familiar to everybody here.

Some very important things happened. I want everybody to come away
understanding that there is an incredible level of committment among all
of the stakeholders that has been achieved already. The members of the
Steering Council signed a letter of intent in which we bound ourselves
to the actions outlined in the plan. We agreed to take the lead within
our stakeholder communities and to deliver the results that Secretary
Mineta asked us to deliver. My job as chair is to hold everybody\'s feet
to the fire I guess and make sure that happens.

The Steering Council is concerned that there are many pressing issues
that could distract all of us from the work at hand. The FCC\'s 2005
deadline isn\'t very far off and there\'s still a lot of work to do. The
state of the nation\'s economy, the limitations of the existing
telecommunication system such as the earlier mentioned need to upgrade
the wireline E911 systems, and the pressing need of our nation to devote
time, energy, and resources to homeland security could all conspire to
divert energy and attention from this important work.

It goes without saying that wireless enhanced 911 is a highly political
issue and there are many competing interests and agendas. And yet under
the aegis of the DOT, the stakeholders have come together and they have
achieved consensus. What we have accomplished is the basis for the road
map forward.

One of the things that we have produced, in part due to contracts
between APCO and NENA with the Department of Transportation, is a
national web-based clearinghouse. On this clearinghouse are the PSAP
implementation checklists, master contracts, master memoranda of
understanding, model project plans, many documents that are available to
help PSAPs, wireless carriers, and all of us get the job done. We are
doing our best to pull together resources so that people don\'t have to
reinvent the wheel and start from scratch out there.

I think this is a major accomplishment. It\'s important that all of us
together sitting here in this room take the Steering Council\'s priority
action plan and work with it. Our nation\'s resources are stretched to
the max. I don\'t have to tell all of you industry folks out there. You
know your budgets are tight as well. We can\'t afford the cost in
dollars or time of duplicating effort or of starting the process anew
with different players.

The members of the Steering Council are the shakers and movers in their
organizations. They are the presidents and the CEOs and the upper level
management of these organizations. You couldn\'t get a better group of
folks. You couldn\'t get a more committed group of folks. We\'re
prepared to steamroll ahead.

In conclusion, I would like to say that we have to make wireless E911 a
national priority because it is essential to the safety of American
citizens in the post-September 11 world. We know that you believe that
because you are all here. We know the Commission believes that because
they brought us all together. We know that Senator Burns, Senator
Clinton, Representative Eshoo, and Representative Shimkus believe that
because they convened the Enhanced 911 Congressional Caucus.

We hope that the FCC and the Congressional E911 Caucus will link their
initiative with the U.S. DOT Steering Council\'s efforts and build on
the work that\'s already been done. All of us together can\'t help but
succeed. We will bring wireless enhanced 911 implementation nationwide
to a successful conclusion. Thank you.

(Applause.)

COMMISSIONER MARTIN: Thank you, Evelyn. Thanks to all of you very much
for your presentations this morning. It\'s important that we all
recognize and are grateful for the efforts that you all and your
organizations have been doing working together. I think we can all see
both the importance and the success of their efforts and certainly their
enthusiasm.

Actually when John finished his presentation, I was talking about his
enthusiasm and his inspiration for this issue. He said that\'s what you
get when you are the son and the grandson of a preacher. I thought that
maybe summarized part of what we were here to do today, E911 evangelism
maybe. Maybe that should be the theme of how we\'re going to try to
proceed.

We have just a few minutes for questions. Then we\'ll be starting up the
next presentations. The one question I did have along the lines of what
I was just saying was are there any areas that any of you think that the
public safety industry or these government efforts are not focused on.
For example, do you think there\'s been a sufficient focus on educating
the public about the benefits and about the importance of this issue? I
didn\'t know if any of you had any comments or thoughts on that.

MR. MELCHER: Well, I think that public education in the area of 911 is a
little lacking especially when it comes to wireless 911. Thanks or
curses be to William Shatner for the raising the bar public expectation
through the show \"Rescue 911.\" The adopted wisdom was you dial the
magic three digits and wonderful things happen.

I do know that in poll after poll after poll over the last nine years it
is shown that the public expectation was I thought I did have it. One of
the other big issues going on is that those who have been paying for
this service via a line item on their bill are finding out that they
don\'t have the service. They are somewhat disconcerted when that comes
up.

So public education, not only in how technology needs to be available so
that we can located you but also how your funds are being spent so that
we can actually adopt the technology, is a very critical issue. I know
that we\'ve been working very hard at it. I know that our counterparts
at APCO and NASNA have all kinds of programs in place. Once again,
we\'re probably not funded as well as we need to be to make a real true
public outreach.

The collective effort of the team would help that because wireless
carriers have a lot of presence through advertising. The local exchange
carriers certainly have a very prominent role in their communities.
Maybe a better coordination of public education is what is in order.

MS. BAILEY: I would agree with the comment about there needs to be
greater public education and greater public awareness. I would raise a
caution though. I know in our situation in Vermont depending upon where
you are there may not be coverage of any sort. You may not have location
technology available even though the carrier has implemented enhanced
911 Phase II. For a variety of reasons, that information might not
arrive at the PSAP.

Yes, there needs to be public education. But I also think that with
wireless enhanced 911 it\'s not ever going to be like wireline enhanced
911. Consumers just need to be aware and use their cell phones in an
emergency with awareness and intelligence. That\'s a message that also
has to get out there as well.

COMMISSIONER MARTIN: Thanks. Commissioner Abernathy has arrived to start
our next group in just one second so if anybody has one last quick
question for any of our panelists.

COMMISSIONER DAVIDSON: Thank you, Commissioner. There are a number of
great initiatives that seem to be working tirelessly on this. My
question for the panel is what do you see as the best model or the best
models for coordinating those initiatives without unnecessarily growing
government or adding needlessly a bureaucracy to what\'s going on.

COMMISSIONER MARTIN: Susan.

MS. MILLER: Thanks. I actually think there is significant coordination
going on as evidenced by the members of the panel here. We make every
effort to consolidate the information flow, make sure you know where to
go with the technical operational issues, and where to go with the
significant numbering issues. I think we\'re doing that, but if we can
do a better job please let us know.

We really represent the stakeholders who are involved in the process.
We\'re trying very hard to be sensitive to eliminating redundancies and
making sure there are efficiencies at every turn. So help us if there\'s
something we\'re not doing.

MR. MELCHER: I would just echo that. You have so many organizations
involved. Trying to get past the non-invented-here thing so let\'s do it
over again initially was a challenge. We\'re through most of that. So
most of it now is if we stumble across what might be a duplicitous or
redundant effort we\'re expending a lot of resources and energy to make
sure that doesn\'t happen. So we\'re actually assigning different tasks.
Things we\'ve taken on we have actually given away because somebody else
is doing it already or can do it better than we can.

COMMISSIONER MARTIN: I\'m pretty sure John meant duplicative not
duplicitous efforts. Actually I would just say in response to the
question that was actually one of Chairman Powell\'s instincts in trying
to gather this group together to make sure we have the ability to try to
coordinate the various efforts that were going on without adding any
further administrative burden to it. I think that was certainly one of
his goals in trying to organize this today. With that, let me turn it
over to Commissioner Abernathy. Thank you all this morning.

(Applause.)

COMMISSIONER ABERNATHY: Good morning. It\'s a pleasure to be here. I\'ve
been listening upstairs on television. We get that privilege so that we
don\'t have to sit down here all the time. So far, I\'ve been very
impressed with the participation and the parties and the outline of the
goals that Chairman Powell delivered and the questions and answers that
came about during Commissioner Martin\'s panel.

It is a priveledge for me to be able to follow up with this panel.
Before we go further, I do want to go ahead and echo my thanks to Lauren
Kravetz Patrich and Jennifer Tomchin for putting together the first
meeting of the FCC\'s wireless E911 initiative. I also want to thank
Bryan Traymont. I don\'t know if he\'s here but he went around selling
this idea to all of us. It wasn\'t much of a sell because once we heard
about it we thought it was a great idea. It\'s a very good means of
gathering lots of information about the various parts that have to fit
together to deliver this product to consumers.

For this panel on wireless carrier implementation, I thought I would
start by providing a brief overview of the FCC\'s rules governing
wireless carrier implementation of E911. Gosh, I hope you all know those
rules. I\'ll go through it very quickly. Then we\'ll head straight to
the panelists.

Then we\'ll follow up the panelists with questions from our roundtable
participants. I\'ll go around right after the panelists finish and ask
each of you to introduce yourself, not with the bio but just briefly
introduce yourself so that all the folks out there can know who\'s here
and what we\'re talking about.

Generally speaking, the E911 implementation requirement is triggered by
a PSAP request which is why the coordination between the PSAPs and the
wireless carriers is so critical. However, wireless carriers are also
subject to FCC deadlines. For example, when they implement Phase II
services, they must either select a handset-based or a network-based
solution.

Wireless carriers that do network-based solutions must deploy Phase II
to 50 percent of the PSAPs coverage area within six months of a valid
request and to 100 percent of the PSAPs coverage area within 18 months
of a request unless the parties mutually agree on a different schedule.
Then wireless carriers who are choosing a handset-based solution must
complete any necessary upgrades to their systems within six months of a
PSAP request.

But additionally, the rules provide for specific benchmark dates by
which the carriers must begin to sell and activate a certain percentage
of handsets that provide location information. Then by December 31,
2005, which is now just around the corner, these carriers must ensure
that 95 percent of their customers handsets are location capable.

Wireless E911 deployment is situation specific and often varies between
jurisdictions as we just heard. It depends on a number of factors
including the readiness of the PSAP equipment and then the underlying
LEC infrastructure as well as the type of location technology that\'s
being used.

I also find that because of the complex implementation requirements
states can play a very valuable role in addressing the prioritization of
the rollout. So to help ensure timely and effective rollout of E911
service, a number of states have developed state-wide plans for
deployment. This type of state-wide coordination and oversight is
exactly the kind of role that\'s been envisioned by Congress in the
Wireless Communications and Public Safety Act of 1999. The 911 Act
directed the Commission to encourage and support the states in
developing comprehensive emergency communications based on state-wide
plans so that all jurisdictions offer seamless and reliable networks for
prompt emergency service.

With that as background, let\'s move on to today\'s participants. On
this panel, we\'ll be hearing from the Honorable Tim Berry from the
Indiana Wireless Enhanced 911 Advisory Board. Indiana has experienced
great success in implementing E911.

Currently seven wireless carriers provide Phase I service to subscribers
in 90 Indiana counties. Phase II service is up and running in at least
25 Indiana counties with between two to four wireless carriers providing
service in each county. Treasurer Berry will describe how the state\'s
planning and coordination process has resulted in this implementation
success.

We\'ll also hear from Saralyn Doty from the Mid-America Regional
Council. The Mid-America Regional Council recently coordinated the
implementation of Phase II throughout the Kansas City metropolitan area.
This system serves approximately two million people through 45 PSAPs.
The Commission supports these state efforts and hope to have some of
these states by describing their programs at this meeting it will
provide useful information for other states that are still at the
forefront of trying to roll-out this product.

We\'ll also hear from Karl Korsmo from AT&T Wireless and Charles McKee
from Sprint on how they have approached this issue of implementation and
how they have built out their networks or moved to a handset based
approach. In addition, we will hear from Michael Altschul from CTIA with
an overview of wireless carrier deployment issues. With that, I\'ll ask
Treasurer Berry to take the floor and remind you that we have a hook.
The main reason is I really do want to allow time for a number of
questions and answers. Thank you.

TREASURER BERRY: Just because I\'m the only elected official, you think
I need a hook. Thank you, Commissioner, for the opportunity to be here.
I appreciate the Commission\'s invitation to participate today\'s
roundtable initiative. I\'m here today to tell the Indiana story.

As Indiana State Treasurer, I have the unique role in serving as
chairman of the Indiana Wireless Enhanced 911 Advisory Board where our
board is responsible for the oversight and implementation of wireless
enhanced 911 services. In addition to that, we manage a fund that is
derived from subscriber surcharges and reimburse both local government
and wireless carriers for their costs that are associated with the
implementation of wireless E911 services in Indiana.

Along with the other six members of our board, I take my
responsibilities very seriously. At Indiana, our goal is quite simple.
It\'s to ensure that every person who relies on a wireless phone or
purchases a wireless phone for children, aging parents, or a loved one
has the piece of mind to know that in an emergency 911 first responders
know their location and are sending help right away.

While I\'m proud of the strides that we have made, I recognize that we
still have much to do in order to reach our goals. Through that process,
we have identified several of the key elements that we believe have
facilitated our success in the state of Indiana today.

First of all, Indiana was one of the first states to pass legislation in
response to the Commission\'s Docket Number 94-102. We recognize this
opportunity both from our public safety community but also from our
carrier community who worked together to enact legislation in April
1998. It was led by Ken Lowden who serves as our vice chair of our board
and the Steuben County communications director.

We were very fortunate in our state to have three legislators in both
houses of the general assembly in Indiana who had an understanding of
public safety. In the Senate, the bill was sponsored by a former state
trooper. In the Indiana House, the legislation was co-sponsored by two
former county sheriffs who had run their own PSAPs and had first hand
knowledge of the benefits of wireless E911.

The board and its staff serve as a state-wide coordinating entity and a
resource in single point of contact for local government, wireless
carriers, LECs and other stakeholders. The presence of such an entity
has been lauded by those stakeholders and wireless carriers in
particular as a key element in implementing wireless E911.

Much is being done here today. Over the last four years, we have held
several seminars on both Phase I and Phase II wireless E911 facilitating
a cooperative effort among the stakeholders and expediting
implementation. These types of gatherings have led to bringing people
face-to-face and help immensely in breaking down the barriers or
roadblocks that have been created by stakeholders that otherwise would
have delayed the availability of E911 service.

With any organization, we recognize that there is a maturation or
growing process. While our board was just established in 1998, we have
as a result had to change and modify and be very flexible and nimble
over the last few years as we have dealt with the change in technology.
The board has amended our act on three occasions. We have adopted and
refined policies over that same timeframe that have implemented
stakeholders\' suggestions and learned from other state boards in order
to better carry out our responsibilities and encourage implementation
throughout the state of Indiana.

While the board plays a pivotal role in wireless E911 implementation, it
has largely left operational, technology, and deployment scheduling
decisions in the hands of local government and wireless carriers as well
as third party providers and LECs where we truly believe that local
control should be. Wireless carriers and local government are entitled
to reimbursement for all costs associated with the implementation of
wireless E911. To date, the board has employed a streamlined approach to
do that. At least, we believe that is a streamlined approach.

The board conducts a biannual review or a true-up of exact costs to
ensure that wireless carriers are being reimbursed properly and all the
cost documentation - at least we do not believe that the documentation
is of an overly burdensome process - and allows for reimbursement soon
after costs are incurred. With rare exceptions, this approach has
yielded very good results in the state of Indiana. To date, the board
has collected over \$63 million from subscriber surcharges and
distributed over \$40 million to wireless carriers and local governments
across our state. The board expects wireless carrier reimbursements to
increase dramatically as Phase II implementation continues to
accelerate.

As State Treasurer, I believe I am the only state-wide elected official
who is in charge of wireless E911. We have used this to our benefit as
an opportunity to ensure that state funds were not raided. During our
recent budget negotiation process where nearly every other dedicated
fund in the state of Indiana was raided, wireless 911 funds were not
raided to balance our state budget.

Additionally, we have used our role to go out there and tell our story.
As a public elected official, we have that forum to discuss issues that
are important to state residents. We go across the state to hold news
conferences when a county deploys both Phase I and Phase II service.
We\'ve also paid visits to many editorial boards, television stations,
and radio stations to tell the story of why E911 is very important.

Last year in May 2002 and again this year, in partnership with the
American Heart Association, our board will be sponsoring a public
awareness campaign across the state with some paid media advertising in
conjunction with a little race that we have in Indiana called the
Indianapolis 500 and the Memorial Day weekend when motorists begin
hitting the roads for the summer driving season. Through this process,
we are driving consumers to our website, 911coverage.org so that they
can be informed and ask the right questions when purchasing wireless
phones for themselves or for a loved one.

The 911coverage.org site has evolved from a site that is hosted by the
State Treasurer\'s website to a free-standing website where consumers
can determine the carriers overall and wireless E911 deployment coverage
area, find answers to frequently asked questions, and background on E911
itself. I\'d like to update you, Commissioner, with some of our recent
statistics to our success.

As you said, all 90 of Indiana\'s 92 counties that accept a 911 call
today are doing so. To date, we have a total of 241 Phase I deployments
in those 90 counties across the state. In 63 of our 90 counties, we are
now accepting Phase II calls with a total of 126 Phase II deployments
across our state which provides a total of 367 Phase I and Phase II
deployments in Indiana today. They are successes but yet we have many
challenges ahead of us. Thank you.

(Applause.)

COMMISSIONER ABERNATHY: Thank you very much. That\'s a great story and
one we\'ll talk about in just a bit. Now we\'ll hear from Saralyn Doty.

MS. DOTY: Good morning. I\'d just like to take a few minutes this
morning to give you a basic overview of one of the projects that we\'ve
been working on in the Kansas City area that we\'re very excited about.
To give you a little bit of a background, the Mid-America Regional
Council also known as MARC is a council of governments responsible for
the management of the Kansas City regional 911 system.

Our system is comprised of eight counties. We have 114 cities within the
eight counties in both Kansas and Missouri. We serve a population base
of about two million people. We do have 45 911 centers that are all
operated by local governments. The system handles approximately two
million 911 calls annually and over 50 percent of those calls are from
wireless devices.

For several years, the region was planning on implementing wireless
Phase I and Phase II. But we needed to look at the big picture and
determine what all we needed to do to be able to do this. For starters,
we upgraded the 911 equipment in all of our answering points to be able
to receive the enhanced wireless calls. Along with this, we also had to
think about some of those things that maybe those not involved in the
operational side didn\'t think of.

That was training the 600 dispatchers that we have in our region on how
to use the new equipment. We developed a regional map, a digital map, to
be displayed on the 911 \-- for plotting of wireless calls and just a
lot of behind the scenes work that needed to be done. While we were
doing this, we quickly realized that our PSAPs were ready but we had
significant barriers on the wireless deployment.

The first barrier was the fact that our local exchange carrier was less
than cooperative in sharing information about their readiness. Although
in meetings they would verbally say they were ready, they would not
provide documentation stating that they were for sure ready or when they
would be ready or that type of thing.

Another major issue relating to the local exchange carrier were the PNEs
or the routing numbers. Although we never accepted the PNE charges being
a PSAP cost, our wireless carriers also would not accept that cost as
being theirs so we had a barrier. Realizing that someone needed to
commit to that cost, we needed to figure out a plan for what we needed
to do.

Initially we thought that we would save more than \$1 million in costs
by doing our project, but as time has gone on we have realized that
currently we have over 5,500 PNEs loaded into our wireless database. If
we do the math, it\'s now up to about \$2.4 million rather than \$1
million.

In addition to the routing charges, at that time, our LEC had promised
that they were going to pursue another tariff rate which would be a
per-call charge for wireless calls. That would be a several hundred
thousand dollar cost on the PSAP side as well. It was at that point that
our local government decided that we would purchase and install a
selective router and database for wireless 911 calls. The result of this
decision was to take the local exchange carrier out of the equation, and
it took the cost issues and the readiness issues off of the table for
us.

Purchasing of a selective router essentially set up two separate systems
routing wireline and wireless calls with no single point of failure
before the PSAP. Wireless carriers use SS7 technology for network
infrastructure. Although this is not a new technology, in the past,
there was not a business plan for a local government or for a PSAP. It
was normally between the local exchange carrier and the wireless
carrier. So we were able to find an SS7 provider that was happy to work
with us on a new business plan to provide that service.

We were able to switch wireless 911 calls to the appropriate answering
point. We have total control over the ALI display. The information that
is sent to us by the different wireless carriers may not all be in the
same format, but we\'re able to massage that and display it to our PSAPs
in a way that\'s consistent for our dispatchers to read and understand
which we\'re happy with.

Also with the SS7 technology, it has a much faster set up time than with
our local exchange carrier which in the past was several seconds. The
SS7, our new technology, has a set up time of less than one second. So
we\'re thrilled about that and so are our dispatchers. When you are
answering a 911 call and you are sitting behind the scenes waiting for
the ALI information or your location information to come back to you,
those few seconds sometimes seem like a lifetime. I can share that
because I\'m a former dispatcher.

Phase II wireless 911 testing began in December 2002 with us. We have
six major carriers in our area. All six major carriers have implemented
Phase I region-wide. We have four carriers that are fully Phase II. Our
last two carriers are testing right now. So we hope that they will be
finished with Phase II testing very soon.

Our approach was somewhat unusual. Every step of the way we were faced
with issues and challenges that no one has been faced with before.
We\'ve been working with everyone from the wireless carrier to our
install and maintenance group to the SS7 network to the dispatchers.
Everyone has been very flexible. Everyone has been really great to work
with.

Through this entire project, we never lost sight of the importance of
the system\'s stability, redundancy, and diversity and doing this the
entire time with no cost recovery. Missouri and Kansas are two of the
few states left with no cost recovery. So we did this not with a cost
recovery but with our citizens\' lives and safety in mind.

Through the project, we kept in mind that we wanted to deploy. We
didn\'t want to wait for that cost recovery. We didn\'t want to wait for
our local exchange carrier to be ready. We wanted to start saving lives
now. We\'re all about sharing information. I know that we\'ve talked
about checklists and things that are out there.

Since our project is very new, I wanted to share with you that we\'re in
the process of developing a white paper. If we\'re able to complete
that, we\'d be happy to share and distribute it for anyone that\'s
interested in our project. We\'ve learned a lot. We\'ve made some
mistakes, and we\'ve faced issues.

We want people to learn from that. Learn from our mistakes. It may not
be the best solution, but it\'s working for us. We\'re really happy with
it. Everyone has been really great to work with. That\'s it. Thank you.

(Applause.)

COMMISSIONER ABERNATHY: Thank you, Saralyn. It\'s a very unique way of
approaching it. I think we\'ll have a lot of questions about it. Thanks
for coming. Now we\'ll move on to Karl Korsmo.

MR. KORSMO: Good morning and thank you, Mr. Chairman and Commissioner
Abernathy, for inviting AT&T Wireless to share our E911 deployment
experience with you today. As you know, AT&T Wireless is using a
network-based solution for our TDMA wireless network. In the third
quarter of last year, we decided also to deploy that same network-based
solution to our GSM network. As a result, AT&T Wireless customers will
not need to purchase new handsets to take advantage of Phase II 911 when
that becomes available in their area.

Our significant progress in Phase II and Phase I deployment will be
reported in detail this week on Thursday when we file our regular
quarterly report with the Commission. Here\'s a summary of the great
strides AT&T Wireless and our partners in public safety have been
making.

First, on our TDMA network, over 1,300 PSAPs receive Phase I service
from AT&T Wireless today. Approximately 340 PSAPs receive Phase II
service from AT&T Wireless today. I say \"approximately 340\" because we
have dozens of PSAPs. In fact, we have a couple of states which are in
various stages of Phase II deployment. We are integrating Phase II
service with additional PSAPs nearly every week.

As Tim and Saralyn know, AT&T Wireless has widespread Phase II service
in Indiana with over 30 PSAPs there with Phase II and in Kansas City
both on the Kansas and Missouri side of the border. In fact, we have
Phase II service now in 20 states with more service and more states
scheduled over the next several months.

Locally, here, we have integrated our Phase II service in Loudoun County
and Arlington County and in Alexandria, Virginia. Fairfax, Prince
William, Stafford, and Anne Arundel Counties are ready to go. We have
begun Phase II deployment in New York City in Rochester and Monroe
County and in Suffolk County, New York.

On our GSM network, we have been deploying for the last four months dual
technology equipment, GSM and TDMA equipment, in our cell sites as we
deploy Phase II. As a result, we will have as many GSM cell sites as
possible ready for full Phase II service when we complete the network
testing that we are still undergoing on our network-based GSM solution.
In fact, today we have well over 3,000 GSM cell sites fully equipped
with network-based 911 equipment.

We have been testing this GSM solution with our vendor in two markets.
In Fort Meyers, Florida, we have been testing our Nokia GSM network. In
York County, Pennsylvania, we have been testing our Ericsson GSM
network. We expect these tests to be completed shortly. We expect GSM
Phase II service to begin rolling out in May which is a couple days from
now. While a few technical hurdles remain to be overcome, our engineers
are working on them diligently with our vendor and we expect to solve
them.

Three lessons learned that I would like to share with you from our
experience in deploying Phase II to date. First, AT&T Wireless and our
vendors are getting very experienced at deploying Phase II systems. The
speed of our network design and installation has been improving so that
in my opinion the critical path issues are usually today not the
wireless carrier location technology but rather procedural and
coordination issues, some of which we have already talked about here
today. With us, it\'s such things as getting trunk orders processed by
the local exchange carriers, obtaining permits where we need new
wireless antennas and that sort of thing.

Second, we find that state and regional leadership by public safety
officials speeds Phase II deployment significantly. The Mid-America
Regional Council is a good example. Saralyn and her team prepared for a
very long time for Phase II. When we were ready to hook up and test our
Phase II wireless system with MARC, they had over 30 PSAPs scheduled and
ready for us. I would say that was probably one of our most efficient
deployments anywhere in the nation.

Likewise in Indiana, state leadership in this case by both elected
officials and public safety provided key leadership on education and
funding. Other states such as Texas, California, Tennessee, New Jersey,
Minnesota, and Illinois are examples of wide spread Phase II deployment
today due largely to the foresight of the state public safety leaders in
these states and education, planning, coordination, and physical
management. State and regional leadership have made a huge difference in
Phase II deployment.

Third, AT&T Wireless has seen significant progress on the Emergency
Services Interconnection Forum or ESIF through the collaborative
dialogue on technical issues. Having a neutral forum for industry and
public safety experts to discuss solutions to technical issues has been
a great help in getting wireless 911 deployed and speeded up.

Finally, I don\'t think the people in this room are the problem. We have
to address the people who are not in this room today. We have so much
left to do, carriers and public safety together. We must work more
efficiently together. We have now done hundreds of successful Phase II
implementations, carriers and public safety together. We need to do more
to apply our learning for the benefit of those who haven\'t.

AT&T Wireless pledges the deployment experience of our engineers, our
technicians, and our vendors to work with experts such as Saralyn and
with experts at NENA and APCO to establish predeployment Phase II/Phase
I teams. These predeployment teams could transfer that knowledge, the
lessons learned, and the best practices to public safety agencies
interested in having wireless 911 service.

We are ready. I\'m sure I\'m speaking for our other carrier brethren as
well. We are ready to begin now to establish these predeployment teams.
Perhaps we could have one predeployment team in each state. However we
organize it. If it\'s through NENA\'s SWAT, that would be fine. However
we organize it I know from experience that Phase II implementation will
become more efficient as our collective and collaborative efforts
increase. Thank you.

(Applause.)

COMMISSIONER ABERNATHY: Thank you, Karl. That was great. There were a
lot of good suggestions which we\'ll discuss. Now I would like to move
on to our next speaker, Charles McKee.

MR. MCKEE: Thank you, Commissioner. I appreciate you taking the time to
let us give a little background on Sprint\'s experience in Phase II and
the deployment challenges that we\'ve encountered and met. You have
heard a lot this morning about cooperation and coordination. What I
wanted to do was try and drive to some of the nitty gritty detail and
get down a little bit about why cooperation and coordination is so
critical.

It\'s easy to think and talk about Phase II as if it\'s a product that
simply gets turned on in a market. It\'s just not that simple. When I
was first asked to address this audience, the first thing I did was draw
myself a picture. What this picture really does for me is show all of
the elements that have to be coordinated to make this process happen.
It\'s not just pieces of equipment. There are multiple platforms,
switches, routers, all of these things that have to talk to each other
on the technical level. But then there are all of the people who control
those things, not just wireless carriers, not just PSAPs, not just LECs,
although those are certainly the big three. You also have vendors who
produce various software for the PSAPs. You have vendors who are
involved in supporting various aspects of our network, the LEC networks,
the PSAP networks. You have consultants who work with the PSAPs in an
attempt to help them coordinate things. You have state funding bodies
who have their own special rules and the manner in which you are
supposed to deploy services and the way in which you are supposed to
account for your services. You have agencies at every level who are
watching and observing your process. All of them with the best of
intentions have their own fingers to put into the pie. The result is a
very complex, technical, and administrative challenge for all wireless
carriers to address.

That brings me to keys to successful deployment. Not to over emphasize
here, but coordination, cooperation, and patience are the true keys to
getting through a Phase II deployment. We have excellent examples
sitting here in the room in front of me of people who have taken each of
these aspects of Phase II deployment and helped us.

The administrative coordination in Indiana is an excellent example of a
centralized coordinating body who allows us to interface with multiple
PSAPs and establish a uniformity to the manner in which systems are
rolled out which is a tremendous help to a national carrier who is
trying to address services in multiple states. Rhode Island, which was
our very first market, is another excellent example of a centralized one
point of contact used to deploy services throughout the entire state.

There is also coordination on the technical side. Again, MARC is an
example of that technical consolidation. Being able to have a single
point of interface, the establishment of their own selective router and
ALI database similar to what Rhode Island did allowed us to go in and
have a single point of contact which would then distribute information
out to multiple PSAPs behind that point of contact. It\'s a much more
efficient way of deploying services in any market.

Patience is also something I want to touch on. This is still a new
technology. Karl is absolutely correct. We have made tremendous strides
in perfecting the rollout of this technology. As we have deployed more
and more markets, we get better and better at it. But it\'s still a new
technology. Every deployment presents its own unique combination of
administrative and technical challenges that must be overcome.

So every time we enter into a new market, we know there are going to be
problems. Something is not going to work. There is going to be a
roadblock. We\'re going to have to figure something out. We never know
what it\'s going to be in advance, but we always know it\'s going to be
there. What we always answer right up front is we\'re going to try our
best to do everything as fast as we can but please have patience with us
as we address each of these things.

Spartanburg, South Carolina I see sitting right in front of me. That
wasn\'t planned. You are already on my list here. It\'s a wonderful
example of patience. We started working with Spartanburg, I don\'t know
how long ago it was, well over a year ago. We had conference call after
conference call after conference call talking about we\'ve run into this
roadblock and this isn\'t working.

We talked through the problems. We didn\'t stop talking. They remained
engaged. We came out and talked to the state funding board. We talked to
the LEC. We worked through problems, and we got it launched. It took a
while, but with patience and with perseverance we managed to get that
deployment done. So I want to emphasize that is an important part of
making this happen.

I\'ll turn now to the page that Jim Crouch referred to me as the
advertising page. I\'ll try not to spend too much time on that. But I do
want to emphasize that Phase II is happening. Sprint has deployed well
over 200 Phase II requests. We have deployed over 1,800 Phase I
requests. We have deployed services Phase II in 16 states. In the next
quarter, we have over 300 PSAPs scheduled for testing and deployment
alone all in Phase II.

We offer more than 14 GPS-enabled handset models. We have sold over
eight million GPS-enabled handsets. By July, we expect 100 percent of
all activations to be GPS-enabled phones throughout our network. We have
done all of the installation necessary to support Phase II nation-wide.
We have installed all of the back office systems required. We are moving
forward at a rapid clip deploying multiple PSAPs on a daily basis.

Finally the wrap up as I see the light come on, I\'m at the FCC so of
course I have to put in my chip as to what the FCC can do to help us
out. My points are simple. First, I think we need to avoid expanding the
mandate of this program. What wireless carriers should be focused on
right now is deploying services. That\'s what we are laser-focused on
right now. Expanding into other areas is not what we need to be focused
on right now. We need to be getting services rolled out.

Secondly, once again an appeal for patience. The carriers need to be
provided with a reasonable amount of flexibility to focus resources in
those areas that are ready to deploy. We are working hard everywhere we
can. We\'re going to get it done. It\'s happening now. It\'s simply a
matter of time to get it rolled out. I\'m very encouraged and I think
we\'re headed in the right direction. Thank you.

(Applause.)

COMMISSIONER ABERNATHY: Thank you very much, Mr. McKee. For a wrap up,
we will hear from Michael Altschul from CTIA.

MR. ALTSCHUL: Thank you, Commissioner Abernathy. I want to thank the
Commission for including CTIA in this panel. Time is short. You have
heard from the carriers and experts on implementation, so although it\'s
very hard for me as a lawyer to limit my remarks I really just have
three points that I would like to stress. I see Norm Forshee is already
smiling.

First, I would like to make clear and debunk any notion that wireless
carriers are foot-dragging in their deployment of E911 services. We have
already heard from the other panelists the extraordinary strides that
they are making actually deploying and providing these services. It\'s
remarkable. As John Melcher mentioned, we have progressed from what was
an idea that wasn\'t supported by any products back in 1994 to
operational Phase II services that already are serving more than ten
percent of the U.S. population.

I realize that isn\'t enough and we\'re not here to congratulate
ourselves for serving just ten percent of the U.S. population. We are
well on our way. We know that we have the skills in this room and among
all of the stakeholders to meet the FCC\'s goals. That\'s no longer an
issue or a question for debate.

Second, as you heard Charles just say, I want to emphasize the
importance of one of Dale Hatfield\'s findings that changing
requirements can only lead to delays in the rollout of wireless E911
services. Now is not the time to be moving the goalposts. Carriers are
so focused and PSAPs and all the stakeholders are so tightly focused on
accomplishing the very ambitious goals that are set out for them.

Third, like the other commentors and as I think we are going to hear all
day, I want to echo the comments that effective state as we\'ve heard in
the case of Kansas City, regional leadership and coordination is the
single most important factor for assuring the successful implementation
of wireless E911 service. The successful implementation of wireless E911
is more closely correlated to state leadership, planning, and
coordination than it is to the level of state funding.

Let me go back now since I promised to limit it to just these three
points and amplify just a few of these remarks. The Hatfield report
served the very important role of focusing attention to all of the other
stakeholders and industry segments that have to be up to speed and be
working with wireless carriers to make this happen. Remarkable progress
has been made in the past year. The voluntary industry groups and the
Commission\'s support for the industry\'s activities have all led to the
point where we\'re about to be wowed by the progress we\'re all going to
collectively make rolling out these important services.

While much work still lies ahead, the quarterly reports filed by the
Tier I wireless carriers document how much has been accomplished. I had
a long list of the reports that were filed back in February as of the
year end talking to the Tier I carriers. It dawned on me that would
probably be the wrong thing to go through and list. The reports that are
going to be filed on May 1 are going to demonstrate that in the last
quarter we have made really incredible progress. I predict that the
quarterly reports that will be filed in the next quarter will even be
more impressive.

Second, as we\'ve all mentioned, now is not the time to be moving the
goalposts. Section 4.3 of the Hatfield report urged the Commission to
avoid the addition of new requirements at this critical stage of the
rollout. Wireless carriers are stretching both their financial and human
resources to meet the Commission\'s implementation deadlines. Under
these circumstances, new requirements, either in the form of enhanced
accuracy requirements or new implementation obligations, can only dilute
carrier efforts and thus slow carrier progress. There should be no new
mandates until the Phase II implementation process is completed.

Finally, the most important message that I have for you today is that
effective state or regional leadership and coordination is the single
most important factor for assuring the successful implementation of
wireless E911 service. States and regions with strong leadership have
been the most successful in deploying wireless E911.

It is no coincidence that the current and past NENA presidents have
successfully deployed Phase II service for multiple wireless carriers in
their home PSAPs both in rural markets such as Saint Clair County,
Illinois and in urban areas. These strong leaders have been able to
deploy wireless E911 within their existing state budgets.

For example, in the case of John Melcher\'s Greater Harris County,
Texas, it has one of the smallest surcharges in the country at just 50
cents per month. As we just heard, in Kansas City, MARC has successfully
deployed Phase II without cost recovery in either Kansas or Missouri.
That\'s why we believe that deployment of Phase II service is more
closely correlated with the state-wide leadership planning and
coordination than it is with the state funding.

Thus, rather than focus on funding which is beyond the FCC\'s reach, we
believe the Commission should continue to concentrate its efforts on
encouraging this kind of planning and coordination. More importantly,
Congress has endorsed this role for the Commission in the \`99 E911 Act.

I\'m happy to see that the Commission has updated its website and
through this process has included the states in this process. It is a
process that is going to bear the greatest benefits. As we have heard
this morning and we\'ll hear throughout the day, through this
coordination one request can bring service to an entire region and to
multiple PSAPs. Scores of PSAPs can be brought up to speed at one time.

Finally, let me just state that CTIA and its members are proud to have
developed the original consensus proposal that formed the basis that
allowed the Commission to move forward with wireless E911. We\'re
committed to overcoming the obstacles to the ubiquitous deployment of
wireless E911 service.

Finally, we urge the Commission to find ways within the current
regulatory framework to adjust its rules to fit the circumstances. As
Dale Hatfield suggested in his report, this additional flexibility may
better facilitate the roll-out of wireless E911 services than the rigid
application of the Commission\'s rules. Thank you.

(Applause.)

COMMISSIONER ABERNATHY: Thank you, Mike. A rousing round of applause
because they kept to the time limits. Good work. I\'m very impressed. I
thought before we move on I would just put this in context since
everyone has been talking about where we have to go from here and what
we need to do next. It\'s interesting to go back in time when this was a
glimmer in the eyes of the FCC about E911 roll-out and appreciate at
that time because I was working on it on the outside, to coin a phrase
from my daughter, we had no clue about all the steps that had to fit
together to make this work.

Fundamentally, we were working with the FCC, the wireless carriers, and
pretty much the PSAPs. Beyond that, there was no real appreciation of
how complex the entire process would be. We thought it was one of these
things that if you said it then it would happen. So we now know a lot
more today than we did back then. That\'s the good news. The other good
news is that we\'ve seen some super success stories here which we can
build on going forward.

So before we move on to the question and answer at this stage, I thought
what we might do is allow an opportunity for each of the parties who are
sitting at the roundtable, which is actually square, to introduce
themselves. You have already met Dale Hatfield. We\'ll start here.

MR. KREVOR: Larry Krevor, Nextel.

MS. MAHONEY: Sharon Mahoney, Cingular Wireless.

MR. NIXON: Jim Nixon, T-Mobile.

MR. PETERSON: Ernie Peterson with Three Rivers Wireless representing
National Telecommunications Cooperative Association.

MS. KOHLER: Beth Kohler, Rural Cellular.

MS. BENNET: Carri Bennet with the Rural Telecommunications Group.

MR. MALNATI: I\'m Fran Malnati from Verizon Wireless.

MR. PEDIGO: Mike Pedigo, Denco Area 911 District representing the Texas
Cost Recovery Team.

COMMISSIONER DAVIDSON: Charles Davidson, Florida Public Service
Commission.

MR. MARZOLF: Steve Marzolf, the Virginia Department of Technology
Planning.

MR. JONES: David Jones, Spartanburg County, South Carolina.

MR. TAYLOR: Richard Taylor, executive director of North Carolina
Wireless 911 Board.

MR. HAYNES: Anthony Haynes, executive director of the Tennessee
Emergency Communications Board.

MR. FORSHEE: Norm Forshee, Saint Clair County, Illinois.

MS. HOFFMAN: Elizabeth Hoffman, Chief of Staff for New York State
Assemblyman Dave Koon.

MS. MILLER: Susan Miller, ATIS.

MS. HOGAN: Laverne Hogan, executive director of the Greater Harris
County 911 Emergency Network in Houston.

MS. BAILEY: Evelyn Bailey, executive director of Vermont Enhanced 911
Board, president of the national association of state 911
administrators, and chair of the Department of Transportation\'s
Wireless Steering Council.

COMMISSIONER DUNLEAVY: Tom Dunleavy, the New York Public Service
Commission.

MR. STRUNK: Greg Strunk, D&E Communications. I\'m a rural local exchange
carrier in Pennsylvania.

MR. O\'CONNOR: Michael O\'Connor, Verizon Communications.

MS. MINES: Jackie Mines, Qwest Communications.

MS. SHORES: Joan Shores, BellSouth.

MR. LATINO: Tom Latino, SBC Communication.

MR. MULETA: John Muleta from the Wireless Telecommunications Bureau.

COMMISSIONER ABERNATHY: John, thanks for being here for the entire time
and for listening and learning and for all the staff support you have
provided to make this happen. It\'s great that all of you are willing to
take the time to help us out with this issue because it is very
important as everyone has said. Now as we listened to our panelists, Mr.
McKee said that cooperation, coordination, and patience were critical.
Again, it\'s something that I\'m continually talking to my daughter
about and pretty much good life lessons.

If we move past that, what I thought we might do is get some of the
other parties up here to comment on three lessons learned that Karl
Korsmo presented to us and see if you agree with them. The first was to
summarize - and I hope that I\'m representing them accurately - that we
are past location technology issues. That\'s been done. So we\'re now at
the stage of dealing with permits and coordination with wireline and
those kinds of issues. The basic fundamental technology questions we\'re
through.

\(2\) State and regional leadership is critical to successful
implementation. A number of you touched on that. (3) The collaborative
dialogue on technical issues is a critical part. Then he closed with
maybe what we can do to move the whole process forward is to have some
predeployment teams, folks who have already worked through all of this
and have those go out to some of the states that are still struggling. I
will start with Treasurer Berry to see what your thoughts are.

TREASURER BERRY: Certainly while I think it\'s important that we have
state leadership, one of the things that has made Indiana a success
today is the fact that at the same time while we have had state-wide
leadership it\'s important that we use local PSAPs to actually employ
the technology themselves. We\'ve done that through several areas.

As I mentioned earlier, one is through our seminars that we have hosted.
There have been three seminars that we have hosted first beginning with
Phase I and now in Phase II which has empowered them with the
information and brought them together in the same room with all of the
other stakeholders. The other thing that has helped us with the PSAP
community in Indiana is there was some great concern at first when this
state-wide board was developed. They were concerned that there was going
to be state-wide oversight on them. They were concerned that they would
be taken away from the day-to-day 911 to a certain extent.

We have eliminated that through the communication but also through our
cost recovery mechanisms and providing them cost recovery based on a
percentage of their population. That\'s something that has eased their
life in not having to apply for that on a daily basis.

MS. DOTY: A couple of things for me that come into mind when you talk
about coordination in our region is I can\'t tell you how many PSAP
managers I\'ve heard from saying I\'m so glad that you are doing this
and not me. It doesn\'t take the PSAP manager away from their daily
responsibilities. Also as a regional, we have a stronger voice than an
individual PSAP.

We\'re in touch with what\'s going on around the country and what our
requirements are as well as what the wireless carriers requirements are.
If I have a carrier say you have to do this, I can be strong and have
that voice and say no this is the way that we work or this is what we
are planning to do in our region.

Another when you talk about cooperation and patience is also
flexibility. If we have an ice storm on a day that we planned to do
testing, the carriers are flexible to reschedule. We just have to work
through those issues.

COMMISSIONER ABERNATHY: Your thoughts over here. I know, Karl, you came
up with it so you probably agree.

MR. KORSMO: I would tend to agree with myself I guess.

(Laughter.)

COMMISSIONER ABERNATHY: That\'s always good.

MR. MCKEE: I agree with the points Karl had made. Although the technical
issues have been largely addressed on the wireless side that doesn\'t
mean that there are no technical issues left. The system is not just a
wireless system. The system is a series of pieces that all happen to be
joined end-to-end. All of those pieces of equipment have to all talk to
each other in the right language and in the right sequence.

That is always a challenge in every deployment. Each PSAP has opinions
about here we\'re going to do it this way. So you do have to be able to
work through what the PSAP\'s expectations are on a technical basis as
well as on an administrative basis. Those can be complicated things. It
doesn\'t mean it can\'t be handled. As Karl said, we\'re getting much
better at anticipating what those different requirements are going to
be.

COMMISSIONER ABERNATHY: We\'re probably the only country that will end
up rolling out two different technical location-based systems. One will
be handset. Others are using network-based. What are the technical
issues associated with that? Any surprises at all? Are we doing okay?

The wireless carriers certainly would state that they are now past the
initial hurdle and delays at this point are more complex than simply the
wireless carriers aren\'t ready with the technology. Two questions. The
first is dual technology. How is that playing out? The second is have
you done all you need to do. Is it pretty much a coordination effort
now, not a technology deployment effort?

MR. KORSMO: Commissioner, we do have still a few technology hurdles to
overcome on our GSM network although we are confident that we are
getting those solved. On the network-based side, we have found that
wider deployments are better for example. I see Anthony Haynes sitting
in front of me from the great state of Tennessee and Richard Taylor from
North Carolina. I\'ll use those two as an example if I may.

We have many \-- in North Carolina. We had a state-wide request from
Tennessee. Those are two examples of state-wide leadership and
state-wide coordination. The reason that\'s important on a network-based
technology is because in order to locate a person they say you need
three cell sites for triangulation. That\'s the way this network stuff
works. It works by cell site.

When you want to locate someone in a county, you can\'t just build the
cell sites in that county. You have to build the cell sites in the next
county and in the next county. When we built Norm Forshee, many of the
cell sites we built were in downtown Saint Louis - weren\'t they, Norm -
because we had to serve East Saint Louis.

So it\'s better to do these very large deployments when you are dealing
with a network-based technology. We have been driven to do deployments
by PSAP request. In some cases like Anthony in the state of Tennessee,
that\'s a pretty big \"PSAP request.\" That\'s the state of Tennessee.
I\'ve discovered that is the longest state I have ever seen in my life
from east to west.

MR. HAYNES: We have a big gas tax.

(Laughter.)

MR. KORSMO: With Richard Taylor, for example, in North Carolina, it\'s
better not just to build Greensboro but to build counties all around
Greensboro. That\'s the kind of coordination that really helps get the
service and the accuracy and everything all at once. Maybe I\'m a little
biased on the network side, but that\'s why I like to see these large
coordinated efforts. It speeds things. It gets services to more people
quicker. From our point of view, it makes things more efficient than
doing a checkerboard kind of deployment.

COMMISSIONER ABERNATHY: Anybody else?

MR. ALTSCHUL: One of the good things the Commission has done is provide
this flexibility for technology. The assumptions in 1994 are not the
assumptions in the 21st Century as to the capabilities of the different
approaches. All of the carriers, regardless of the technology they have
chosen, have benefitted from the competition from the vendors. It has
made all of the technologies better and faster to market.

The final benefit of this is that it provides a flexibility as digital
signal processing advances to continue improving these platforms and not
be locked in to any particular product or way of doing it. The industry
through ATIS and the other forms was fortunate in the beginning to
develop a common language, a common way of signaling through the network
to the PSAPs latitude and longitude. So in terms of PSAP implementation,
the choices that carriers select for location technology doesn\'t affect
their ability to receive from multiple carriers, as we have learned,
this information in a way that is useful and actionable immediately by
the dispatchers.

COMMISSIONER ABERNATHY: Why don\'t I open up for questions? I\'m still
going to let you guys talk. Why don\'t I open up questions to members of
the roundtable if you have any? If you don\'t, I can keep asking. We\'ll
also open it up to the audience.

MR. FORSHEE: I guess I\'m somewhat curious on the MARC effort. While I
agree with that effort and have long thought about following that same
road, you have a 911 system of a large number of PSAPs creating their
own selective router for wireless purposes. You have the NENA SWAT
initiative on the other side of the coin talking about too many
selective routers.

Then you have the future of being able to link all of the PSAPs across
the country together to pass calls and data back and forth. It seems to
me these are opposite theories by creating routers or eliminating
routers. I would just like to know how the panel feels about this.

COMMISSIONER ABERNATHY: A very good question. Thank you.

MS. DOTY: I guess I can speak first. We thought that was the best
solution at the time and really the only alternative that we had to
implement as quickly as possible. We would be really open-minded to
connect with other routers. Actually we mentioned that to our LEC at one
time. They didn\'t seem exactly interested in it at that point. But we
are open to discussion on that in the future and would be happy to
continue to keep communications open and working with everyone.

COMMISSIONER ABERNATHY: Anybody else?

MR. MCKEE: Well, from a wireless perspective, it\'s probably obvious
that the fewer routers that we have to connect to the easier it is for
us. The larger the coverage area we can get from a single point of
contact the better off we are.

The MARC experiment actually turned out pretty well obviously because we
were able to interconnect directly and cover the entire city of Kansas
City. Since that\'s where I live, I was happy to get the service. But
sure, if we could do one per state, that would be great. If we could do
one per four states, that would be great. Obviously the fewer points of
contact the better.

MS. BENNET: May I butt in?

COMMISSIONER ABERNATHY: Yes, hi Carri.

MS. BENNET: I know we have a whole panel on rural issues later, but I
think this is a good point to bring up something that I wasn\'t planning
on discussing. It\'s great for the big carriers, but in the sense of
being more flexible when you have a small rural carrier that\'s rural
only having all of these single routers and regional routers there\'s a
lot of facilities that the rural carrier would have to use to get the
calls to that router which increases the cost.

It might be better possibly to have the rural carrier connect directly
to the PSAP there where it\'s right in the county rather than routing
the call. Because I\'m not a technical person, I don\'t know how long it
takes for all of these calls to get through. But we have to be cognizant
of the fact that the rural-only carriers - I recognize large carriers
serve rural areas - have different set ups of their networks that might
make this more compatible. We need more flexibility on that side.

COMMISSIONER ABERNATHY: Yes, Dale.

MR. HATFIELD: If I could just comment. In the report, that\'s exactly
the point that I was making. There\'s somebody that needs to look at
some higher level architectural issues. This is exactly what I\'m
talking about. It seems to me that analytical power needs to be applied
to this to look at the cost trade-off and so forth to inform us about
that. This is precisely my point regarding the overall architecture.

MS. DOTY: Actually we\'re facing that now. I mentioned that we have six
major carriers, but we do have one rural carrier that only provides
service to one of the eight counties. We had looked into the possibility
of a direct connect into the PSAP. The issues that we faced with that
would be transfer issues.

If we understand how wireless works, a call coming in wouldn\'t
necessarily always go to that one PSAP. There\'s a possibility to
transfer out to the highway patrol or to another agency. So we faced
issues with the transfer capability and redundancy. That\'s why we would
wish that they would connect directly to our router.

COMMISSIONER ABERNATHY: Yes, we have a question from the audience, a
former panelist.

MR. MELCHER: Actually it\'s more of a comment on the architectural
interconnection of these routers. When you are trying to connect 800
switches, it\'s much more difficult than trying to connect 100 switches.
The rural comment is the one I wanted to address.

When we mentioned earlier about things like LATA boundaries and even
state boundaries disappearing for 911 because 911 is sacred and should
be given special attention, the facilities exist for you to connect to a
router even if it were in Ontario but it would be not a long distance
trunk for you. So it would be ultimately burdensome for the rural
carriers if the routers came down to a very small interoperable network
if things like long distance charges and that kind of stuff still
prevail.

There are available mechanisms. That\'s what the SWAT policy team is
looking at of things like federal tariffs and the like so that as long
as you are plugged into the 911 network it\'s a fixed price. It\'s not a
long distance. It\'s not user sensitive or anything like that. It would
still allow you to do your 911 business without the overly burdensome
cost of interchange carrier trunks.

COMMISSIONER ABERNATHY: Thanks for adding that to the mix. Anyone else?

MR. PEDIGO: I\'d also like to comment on the router issue. We have
progress in North Texas of getting different ILECs to interface their
routers. In the past, that has been difficult. We\'ve been trying to do
that for several years. Recently we have had a break through. We have
the two major ILECs in the North Texas area working on that and expect
to have within a few months interconnectivity between their tandems. We
feel really good about it. We don\'t feel like the issue is really
technical as it is getting the players to do those things.

COMMISSIONER ABERNATHY: That cooperation and coordination, yes. We have
another question from the audience.

MS. PARTYKA: Hi. I\'m Janice Partyka from TechnoCom. We are enabling
deployment right now. I\'m wondering if it\'s been anticipated that the
post-deployment issues and challenges that the carriers face are as
great as they are. I know the carriers that we are working with right
now are strategizing and creating plans for ongoing maintenance of these
networks, sometimes calibration, optimization. It seems like the eye on
the prize has been deployment, but for long-term accuracy there\'s a
whole other prize to be found. I\'m not just talking about OET
compliance.

COMMISSIONER ABERNATHY: Why don\'t we move this over then to the
carriers? You are right. Once we\'ve deployed it, it would be nice if it
worked for more than a couple of years.

MR. KORSMO: I second that. I\'ve been making a speech quite often to our
operations team which is stressed beyond belief in deploying 911. My
speech has been guys and gals we\'re in the 911 location business now
and forever. This is not just about deployment. You break the tape, rah,
got it. Then we need to make sure with quality we work with our partners
in public safety to maintain this network.

I will say it\'s challenging because a lot of the same groups that are
involved in deployment and are stressed to the maximum right now in
doing that are also the groups involved in the ongoing maintenance. But
we recognize that. We recognize the issues. We are definitely working it
out. It will probably take more of that coordination and cooperation
with our public safety bretheren to work out all of the issues which
I\'m sure we haven\'t worked out yet on the issues of maintenance,
trouble shooting, et cetera. But that\'s the next step definitely.

COMMISSIONER ABERNATHY: Mr. McKee.

MR. MCKEE: We\'ve certainly made that an important part of our process
in dealing with the engineering group as a whole as it is working its
own standards. All engineering within the company has to go through
certain processes as anything is brought on-line, and 911 and all of the
requirements associated with it are integrated into that process.

Certainly after you have launched a market, maintenance continues
immediately. It\'s not as if that\'s something that we\'ve launched it
and now you are good for a few months or you are good for a year. In a
market such as ours in which we are growing, we continue to grow at a
rapid pace in which capacity demands require that we continue to build
cell sites throughout these metropolitan areas that are being served
with Phase II. We are bringing new cell sites on-line constantly within
areas that already have Phase II service.

Accordingly, it has to be part of the basic engineering infrastructure
that our engineers as they bring on every cell site have to go through
coordination with the PSAP and let them know that the cell site is
coming on-line. We have to do the accuracy testing to make sure
everything is working. We in fact go out and drive test every new cell
site before it ever comes on-line to make sure that it is working.

In fact, we\'ve had a number of instances in which we\'ve delayed
launching a new cell site that we really needed for capacity purposes
because there was confusion over which PSAP wanted to handle those
calls, et cetera. So it is a part of our standard process.

TREASURER BERRY: Actually long-term operability is not only an issue on
the carrier side but it\'s also an issue on the PSAP side. One of our
concerns is with PSAPs rushing to find technology to accept Phase II
information and location information but then not looking at the
long-term as to whether this is a solution they are going to want to use
long-term and their belief that since we do provide cost recovery for
their technology that if they grow tired of this system we would just
provide cost recovery in the future for a new system. We\'re in the
process of trying to develop those guidelines of when we would be able
to update with new technology improvements going forward.

COMMISSIONER ABERNATHY: We have time for one more question.

MR. FORSHEE: My question would have to do this. At the beginning of
these forums, someone talked about turning this on and that it is in
fact a living breathing thing that continues to work. From the
carriers\' perspective, have you seen not necessarily at the PSAP level
but at the board levels above the PSAPS, at the administrative levels, a
lack of knowledge on the part of the public safety leadership that this
is a service that they have to continue to support and not treat as just
a job well done, cut the tape walk away from it? Have you seen that as
you go across the country?

MR. KORSMO: Norm, I can\'t say I\'ve seen it. My work so far has been so
down in the weeds with the PSAPs and the deployment teams. I will say
that\'s a risk. But I personally probably have the wrong viewpoint at
this point because I\'m so down in the weeds with deployment. Charles
maybe \--

MR. MCKEE: My response, Norm, would be the entire process has been one
of education. Much of the early antagonisms that developed were in large
part a result of no one had a complete overview of everything that this
took and how many pieces were involved. That education is an ongoing
process at all levels.

What I\'m optimistic about is that we seem to have expanded that level
of knowledge to a large degree. We\'re not done, but the more we do this
and the more we talk about it the more everyone will begin to appreciate
that complexity and the fact that you are right, you don\'t turn it on
and it\'s done. It\'s a system that has to be constantly monitored.

COMMISSIONER ABERNATHY: Okay. I want to thank all of our panelists. I
also want to give a brief summary of what we could take away from this
particular panel. The first is that there\'s coordination and state best
practices are critical whether you go with the state-wide approach or
whether you go with regions. If you don\'t have that involvement at the
state level somehow doing an overall coordination effort, then it\'s
much harder and it will take much longer.

Second is that the technological overlay issues go beyond whether you
use a handset or a network-based approach and really goes much deeper as
far as how will this massive database talk to each other across the
entire country as we promote continued mobility. That\'s the whole point
of having wireless communications. You want to be able to go anywhere
anytime and be located anywhere anytime.

Third is long-term operability issues which go beyond simply building a
deployment network today. How do you maintain it? How do you continue to
improve it and bring it to new levels of accuracy over time. I got the
message about no changing of the goalposts.

So for all of us here, I have learned a lot and I have been doing this
for about six years. Every time I\'m involved with forums like this, I
take away new information and a greater appreciation of just how complex
this is. I want to thank all of our panelists. I want to thank all of
you. I will be listening the rest of the day upstairs. Thank you very
much.

(Applause.)

COMMISSIONER ABERNATHY: By the way, there are no formal breaks here so
we\'re going to move straight to the next panel. Commissioner Adelstein
is here to lead off with the next round of participants.

COMMISSIONER ADELSTEIN: Thanks a lot. If the presenters for the PSAP
funding and operations session could join me up here, I would appreciate
it and we\'ll get started. Well, we\'ve heard a lot of good discussion
already this morning about the challenges facing E911 deployment. I was
able to watch on closed circuit up in our office.

This panel is really crucial because nothing else matters if the PSAPs
aren\'t ready, able and fully funded to provide the service. Right now,
a lot of PSAPs are in a great position to deliver the service but others
have a long way to go. So we\'ll hear today about some of the successes
that we\'ve experienced and some of the challenges that are still facing
PSAPs as they strive and gain the ability to use a lot of this E911
data.

To speed the rollout, both state and local government officials and
PSAPs need to be even more aware of how E911 can help them to do their
critical and life saving jobs even better than they already do. Everyone
who controls the purse strings has to commit the resources needed to get
this technology deployed.

PSAPs face at least two major challenges. First, they have to develop
the expertise to implement E911. The level of the expertise varies
greatly from state to state and even among PSAPs within states as we
heard today. We also heard earlier about some of the critical outreach
efforts by public safety associations regarding E911.

They are doing a great job of providing leadership on this effort. I\'m
looking forward to hearing from them. We have Greg Ballentine, the
president-elect of APCO and John Melcher, NENA\'s president. They will
outline their organization\'s outstanding efforts to help their
colleagues in the PSAP community.

The second challenge that PSAPs face is getting and keeping the funds
they need which will be a major focus this morning. As we are all
tragically aware, some states with E911 cost recovery systems have
diverted those funds for uses having nothing at all to do with E911.
Senator Burns yesterday at NARUC announced that he is considering
legislation to stop this. We will be interested in working with him to
see what ideas he will present for Congressional consideration.

On this panel, we will hear from Steve Marzolf from the Virginia State
Emergency Services Board about how the state of Virginia collects and
distributes funding. Virginia has made great progress in recent months
in Phase II in 19 Virginia cities and counties. As a resident of one of
them, I feel safer and very grateful for your efforts. I know that Steve
will touch on how centralized oversight of funding has contributed to
this success.

We\'ll also hear from Elizabeth Hoffman, Chief of Staff to New York
State Assemblyman David Koon. Mr. Koon couldn\'t be here today because
he had important business he had to attend to in New York. So we\'re
very grateful to her for sitting in. Assemblyman Koon has introduced
legislation to revise New York\'s funding mechanism to provide
localities with funding to expedite the development of E911 service.

Let\'s start off then with Greg and then Steve. I\'m going to next use
my moderator privilege to have Elizabeth speak after that because nobody
wants to follow John Melcher. Thanks a lot.

(Laughter.)

MR. BALLENTINE: Thank you, Commissioner. My name is Greg Ballentine.
I\'m the director of public safety and emergency services with the
Mid-America Regional Council in Kansas City, Missouri. Our region, as
you heard about earlier, covers eight counties in metropolitan Kansas
City. But I\'m speaking to you today on behalf of the Association of
Public Safety Communications Officials.

I serve as the president-elect of that association which includes 16,000
members that represent every state in America including the District.
APCO applauds the Commission for its continued priority on 911
deployment and for bringing this distinguished group of people together
to talk about how far we\'ve come and how far yet we have to go.

In preparing to speak to you today, I had the opportunity to engage in a
conversation with APCO\'s Project Locate team which you heard about
earlier and APCO\'s 911 committee. Our 911 committee has representatives
from throughout the nation who we often refer to as the industry\'s best
and brightest. One of the things that was very important to our
association was to bring forward some of the issues to this forum that
are being dealt with in large and small public safety centers throughout
the country as efforts move toward deployment.

APCO also supports the Commission continuing to hold strong on not
moving the goalposts per se. We don\'t want that goalpost moved back
farther, moved back from the 2005 deadline. There\'s been some talk in
the media recently about initiatives to have that brought under
reconsideration. Our association is adamantly opposed to moving that
date. That date has been in place for a number of years, and we\'ve been
working together toward that date with a focus on the 2005 full
deployment. We urge the Commission to continue to hold strong.

Having said this, we understand that public safety agencies also have a
responsibility for deployment and that agencies need to ensure that they
are ready. We heard from the gentleman from Sprint earlier who said that
the carriers are laser-focused on Phase II deployment today across
America. One of the things that APCO would like to bring forward to the
carriers is to please ensure that the laser-focus is at the local level
as well.

It\'s common that we would come to a forum such as this and hear about
the commitments both on the PSAP side and on the carrier side. What we
have to do is make sure that in the conference rooms across America when
a PSAP manager is sitting down with a local deployment specialist that
they are both laser-focused in moving forward.

Mr. Hatfield, thank you very much for that very in depth report. It has
been a tremendous value in moving deployment forward in America. The
Hatfield report was clear about the term \"PSAP fatigue.\" We believe
that efforts do need to be focused on moving deployment forward and that
continuing arguments regarding cost demarcation and accuracy and LEC
readiness really need to be addressed.

Therefore, some of my comments today are maybe seen as a reality check.
We have heard a lot of good positive news today and have put forward
some really great examples of deployment that has occurred. Keep in mind
that throughout the majority of America, deployment has not occurred.

One of the things that we keep hearing about is that the number of PSAP
requests have declined. I\'d like to talk for just a minute about why
the Association of Public Safety Communications Officials feel that
those PSAP requests have declined. It really relates to an issue of
local exchange carrier readiness and cost.

At present, there seems to be no realistic sense of obligations of third
parties such as the local exchange carrier or database provider or any
of their agents. As Mr. Hatfield reported to the Commission, the local
exchange carriers play a critical role in the deployment of wireless
E911, but their responsibilities for supporting this deployment are
still not well defined.

The Commission must define these responsibilities and promote proper
accountability particularly in non-cost recovery states. As you heard
about in the deployment in Kansas City earlier, the tariff rates that
were in place at the state level would have resulted in more than \$2.4
million on an annual basis to deploy wireless enhanced 911 in that
region.

The decline in PSAP requests is in large part attributable to the
budgets that PSAPs are putting together and the analysis that they see
that it will cost them in order to move forward with deployment. The
Commission issuing an order several years ago removing the cost recovery
requirement for carriers as a prerequisite to 911 deployment has really
created another situation in which there is a cost recovery prerequisite
but it is located at the state level with the local exchange carriers.

I think I\'ll end with that. I will again thank the Commission for the
opportunity to talk to you a little bit today about the needs that
APCO\'s members see nation-wide. I\'d like to express our appreciation
to be able to help deploy wireless 911 in a number of PSAPs both through
our Project Locate initiative and the Public Safety Foundation of
America.

NENA and APCO have both tried really hard to get the word out about
wireless 911 deployment activities through the NENA critical issues
forums and a number of APCO symposiums. We believe that those efforts
will continue. All players have to be a part of this. We would urge the
Commission to take a look at the current biggest stumbling blocks and
let\'s keep our eye on the finish line. Thank you.

(Applause.)

COMMISSIONER ADELSTEIN: Thank you, Greg. Next we will hear from Steve
Marzolf from the Virginia State Emergency Services Board.

MR. MARZOLF: Good morning. I would like to thank the Commission for the
opportunity to speak here today before you. I am Steve Marzolf, the
public safety communications coordinator for the Commonwealth of
Virginia. I am also the secretary for the National Association of State
911 Administrators.

Virginia was an early entrant into wireless E911 passing its first
legislation in January 1998. The legislation created a state-wide
surcharge of 75 cents and the wireless board to administer the fund. The
legislation established cost recovery for both wireless service
providers and the public safety answering points or PSAPs.

The board issued its first payments to localities and providers in July
1999. In 2000, the legislation was amended to expand the membership of
the board to 14 which includes seven local government, four state, and
three industry representatives and also established the division of
public safety communications which I now head to act as staff for the
board and coordinator of all 911 activities within the state.

Since its inception in 1998, the board has provided nearly \$58.5
million to PSAPs in Virginia with another \$18 million approved for the
coming fiscal year. During the same period, the board has provided \$7
million to wireless service providers for their cost recovery. Due to
the early delays of deployment, the fund has accumulated a significant
balance. With this, we\'ve been able to provide funding assistance to
localities for the deployment of landline E911 and to conduct a
state-wide based mapping project which is essential to being able to
locate the wireless caller which has produced digital aerial photography
for all 45,000 square miles of Virginia.

Yes, money has also been transferred from the fund to help Virginia\'s
\$6 billion budget shortfall. But this will not impact the deployment of
wireless 911 in the state. With this groundwork laid, we are now at a
very exciting point in our development. Every one of Virginia\'s 134
PSAPs and localities have committed to the deployment of Phase I and
Phase II. We currently have 315 Phase I deployments in 91 localities and
42 Phase II deployments in 21 localities. Actually, in an email I
received earlier today, we are up over 50 Phase II deployments in
Virginia.

Most exciting of all is that we finally feel as though all of the major
roadblocks have been overcome and that progress is being made. As we
look back at our success thus far and try to determine what we have
learned, several key factors are important. I should point out that
these will sound redundant based on some of the prior presentations that
you have already heard.

First and probably most importantly is the presence of strong leadership
and the commitment to the deployment of the service. Someone or group
needs to take the leadership role to be the advocate for the service and
the single point of contact for all the stakeholders. In Virginia, the
wireless E911 services board serves this roll. They are focused on
building a collaborative environment, removing obstacles to deployment,
and fostering a commitment to deployment from all the stakeholders. But
the board can only be successful if all of the stakeholders are
committed to the deployment of the service.

When looking at the deployments in Virginia and even around the nation,
it\'s easy to see where that commitment exists and where it does not.
Though to varying degrees all of our PSAPs have committed to the
deployment of the service and are actively working towards it. Concern
that some of our smaller localities lack the resources and the expertise
to manage a project of this technical scope, the wireless board in
Virginia has offered project management assistance in the form of a
consultant to each of the PSAPs to assist with the deployment effort.

The board did not want to create a situation of the have and have not
agencies or localities throughout Virginia. The project management
assistance has allowed even the smallest PSAPs to deploy this service. I
would be remiss if I did not also mention the support and commitment we
have received from our local exchange carriers, Verizon and Sprint.

They have been proactive with system upgrades. They have not sought per
call or per subscriber tariffs and they better not. They have been a
strong member of the deployment team almost from the start of the
project. I know many other states and PSAPs have complained. We\'ve
heard here today about problems with the local exchange carriers being
an impediment to progress. I\'m very pleased to say that\'s not been the
case for us.

Finally, of course, we owe a great deal of our success to the commitment
of the wireless service providers. Like the PSAPs, the level of
commitment varies among the companies. Some have struggled to deploy
while for others deployment has become routine. From our first Phase II
deployment with Verizon Wireless in April 2002 in York County, Virginia
to the recent deployments that have brought some wireless servers like
ALLTEL up to date with their Phase II deployments, all the stakeholders
have worked closely to ensure the work gets done.

Beyond leadership and commitment, our success has also been attributable
to our availability of resources. Due in large part to the early
enactment of our surcharge, the fund has also allowed the board to
provide incentives to the stakeholders. Of the \$58.5 million provided
to PSAPs thus far over \$37.4 million has gone for additional personnel
to handle the ever increasing workload generated by wireless E911.

To receive this funding, the PSAP need only commit to and deploy the
wireless E911 service. This and project management assistance have been
excellent incentives for the PSAPs. They may not otherwise have moved
forward so quickly.

In summary, Virginia has been successful due to the leadership and
commitment of all of the stakeholders. Starting at the top with Governor
Warner in the General Assembly, E911 has been both a priority for both
the landline and wireless service. The leadership of the wireless board
has fostered an environment of cooperation providing incentives to all
stakeholders to stay involved. The PSAPs, local exchange carriers, and
wireless service providers are all committed to deploying this service.

As we look forward, and we have had a great deal of success thus far,
there\'s still a lot of work that needs to be done. In particular, the
lack of standards especially with Phase II has become a frustration for
those of us on the leading edge. Inconsistent data formats, the
inability to differentiate a Phase I and Phase II call, and incomplete
information can confuse and even delay the call handling process.

We\'re lucky that Virginia has had the funding and the leadership in
place. Not every state is in that position. After 15 years of only local
coordination in Virginia, 37 localities did not have E911 on the
wireline side deployed. Since the creation of state-wide coordination,
18 of the 37 have now implemented the landline E911 with all of them
scheduled to deploy in the next 18 months.

Similarly national E911 will require a national 911 coordination. I
therefore support the recommendation in Dale Hatfield\'s report for a
national 911 office. This office should not pre-empt state programs but
should instead support the existing program and provide encouragement
and incentive to create programs in states where they do not exist.
Thank you again for this opportunity to speak before you today. These
forums offer an excellent opportunity to discuss problems but they must
be followed up with action. We know what needs to be done. It\'s being
done in states like Virginia, Vermont, North Carolina, Tennessee,
Indiana, and Rhode Island just to name a few. With everyone\'s continued
hard work, we will build a system that can be continually improved and
sustain public safety in the United States. Thank you very much.

(Applause.)

COMMISSIONER ADELSTEIN: Thank you, Steve, for that great success story
and that insight. A lot of us heard at the Commerce Committee hearing in
March from State Assemblyman David Koon from New York whose own tragic
loss spurred his efforts to try to bring wireless E911 to New York. Now
we\'ll hear from his chief of staff, Elizabeth Hoffman.

MS. HOFFMAN: Good morning. My name is Elizabeth Hoffman. My boss is very
sorry that he can\'t make it. Hopefully we are doing a budget in New
York state today. This is only the nineteenth year in a row that it\'s
late. Assemblyman Koon represents the eastern portion of Monroe County
in Western New York in the New York State Assembly. We truly appreciate
the opportunity to be able to participate in this roundtable and this
forum.

We would like to begin by thanking the FCC for taking the initiative to
encourage the development and deployment of wireless enhanced 911. Both
the FCC and Congress recognized early that this was an important public
safety issue. The Assemblyman is grateful for the hard work and
leadership shown during this evolving process of improving and
implementing wireless E911.

The issue of wireless E911 has a very deep personal meaning for Mr. Koon
and his family. In 1993, their daughter was abducted and murdered in
Rochester, New York. They had installed a wireless telephone in her car
in the event of an emergency so that Jennifer could call for help.
Somehow Jennie managed to dial 911 for help from her car phone, however
the 911 dispatcher was unable to locate her because the technology just
didn\'t exist.

The dispatcher listened helplessly to the last 20 minutes of Jennie\'s
life. It is this personal family tragedy that prompted the
Assemblyman\'s involvement in public service to help make New York state
a safest place. I know that he is deeply grateful to have had the
opportunity to share his story with the hope that the implementation of
E911 technology in every state will make it possible to determine the
location of a person making a wireless 911 call.

It has been recognized in New York state that there is a problem with
the funding of our public safety answering points or PSAPs. The state
collects a monthly wireless 911 surcharge that could be used for the
upgrading of the locator technology. The surcharge currently is \$1.20
state-wide with 19 counties having the ability to impose an additional
30 cent surcharge. So it could be \$1.50 in different parts of the
state. However, New York state is not using this surcharge to provide
funding for our PSAPs.

With the guidance and leadership of Speaker Sheldon Silver, Assembly
members Robert Sweeney, RoAnn Destito and Thomas DiNapoli and many of
Mr. Koon\'s other colleagues in the New York State Assembly, he has
introduced a new piece of legislation that will change how New York
state funds the deployment of wireless E911 technology. A copy of this
bill, Assembly Bill 3911, has been included in your packets. It passed
the Assembly on February 24, 2003. However, there has been no movement
in the state senate. But we\'re still working on it.

After many attempts to fund a successful E911 program in the state of
New York, we think that this is finally a solution. It\'s actually
loosely modeled after Virginia\'s successful program. The legislation
creates the wireless 911 local incentive funding enhancement or LIFE
program in order to provide localities with funding to expedite the
development of enhanced wireless 911 service.

Wireless 911 LIFE will encourage the development of enhanced wireless
911 services by providing funding to local wireless emergency dispatch
centers or PSAPs. In order to be eligible, local PSAPs would have to
submit a written plan including a financial plan and implementation time
tables to the state 911 board for approval. Upon approval, local PSAPs
would be eligible for funding related to equipment, software, and
hardware necessary to provide enhanced wireless 911 service.

Three hundred million dollars in bonds will be issued by the Dormitory
Authority to fund the costs associated with the program. The debt
service on these bonds would be paid from the existing New York state
wireless 911 surcharge. This program will give vital technology dollars
to municipalities now and avoid the postponement of this important
safety issue any further.

This current legislation is an extension of legislation passed in 2002
that enacted the local enhanced wireless 911 program. This program
provided \$20 million from the existing cellular surcharge to help
localities fund costs associated with the provision of enhanced wireless
911 service. Ten million dollars in funding was made available to
reimburse eligible wireless 911 service costs which include installation
and maintenance of equipment, hardware, and software designed to meet
the FCC enhanced wireless guidelines. Further, \$10 million in funding
was made available to purchase additional equipment.

The program is administered by a 13 member board organized within the
Department of State. The 2002 legislation reimburses localities for
incurred expenses. The current legislation, Assembly Bill 3911, will
allow localities to receive funds prospectively insuring quicker access
to costly technology.

According to the New York state emergency call locator partnerships
wireless enhanced 911 implementation guide, funding to technological
upgrades remains the most pressing barrier to implementation in New York
state. We strongly believe that enactment of this legislation would
greatly expedite the roll-out of wireless E911.

As been said several times today, and Mr. Koon wanted me to emphasize,
that it\'s important to remember the successful implementation of
wireless E911 requires the cooperation of all parties involved: local,
state and federal governments, law enforcement agencies, carriers and
manufacturers. It is also important for the public to be better informed
and educated about the process.

This roundtable is an important step towards both increasing the
participation of the public in this process and getting the input from
all of the organizations present here today. Again, thank you for the
opportunity to be here this morning. I look forward to any questions you
may have.

(Applause.)

COMMISSIONER ADELSTEIN: Thank you, Elizabeth. Next we will hear from the
great John Melcher, NENA\'s president.

MR. MELCHER: Thank you, Commissioner, nothing like setting the bar high.
It occurs to me that everyone in this room has a little bit of skin in
the game here or as we say in Texas you have a dog in this fight. But
deployment of E911, like anything else that is a great technological
challenge and great administrative and coordinated challenge, really
boils down to one thing, maybe two things: political will and funding.
Where the former exists, the latter shall surely follow.

But it\'s really more about leadership than anything. We mentioned
earlier that the Commission took a bold leap in the \`96 rules that hung
a target on the wall. From \`96 to 2003, we have learned a lot of things
in the deployment of 911. We\'ve gained a lot of lessons and a lot of
insight on what it takes to truly do it. But that certainly does not
take away from the bold leadership that the Commission showed when they
passed the rules in the first place.

When we talk about leadership, we have to talk about those who have
vision and those who have focus, even laser-focus. So you have to look
to true proven leaders who have done it, have a track record behind
them, and can speak with authority. Of those, I\'m speaking of Tim Berry
and others like him who actually have the authority to commit to the
job, they have the funding to make it happen, and they have the
political will to make sure that everyone tows the line.

Towing the line is not about sticks. It\'s also about carrots, and it\'s
building of teams. You cannot take things that are as complex as our
telecommunications infrastructure today, the hodge-podge, patchwork
network of 911 infrastructure today, the new and emerging technologies
that are being brought to bear on this solution, and all of the
desperate political agendas that exist today without building a team.
Every team has to have its leaders.

Those leaders must be possessed of knowledge and forethought. They
almost must be divinely inspired to some degree because there are
different agendas at play. However, the overarching goal for all players
is bringing location technology and emergency services to those who are
in need at the time of their greatest crisis.

We have heard all of the sob stories and terrible tragedies of people
who died because the technology wasn\'t there yet. We\'ve heard today of
successes about how people are being saved today because the technology
has been implemented. But there is a huge chasm between the haves and
the have nots.

I\'m not so sure that we can lay all of the culpability at the local
exchange carriers because they are not ready. To be quite honest with
you, I don\'t know of a local exchange carrier that isn\'t already ready
or isn\'t in the process of becoming ready. I don\'t know of a wireless
carrier out there that doesn\'t have some sort of a game plan or a
technology in their vest pocket that they are ready to deploy just
waiting on making sure that the coordination between the public safety
groups, the local exchange carriers, and the vendor community is all in
place.

So with all of these positive things, why do we still have this big gap
across the United States where there is no deployment? Well, I believe
it gets back to the first three things: political will, funding, and
leadership. Where political will and leadership exist, funding should
not be an issue. For those in their states who have taken money away,
every dollar you take away is impacting deployment.

It can either happen faster and those dollars can then be reduced or it
can happen better. Where dollars are being diverted, they should not be.
Where no game plan exists in your area or your region, it should. Put
yourself in a carrier\'s position. The 911 technology has to be rolled
out nation-wide.

Just like a CDMA conversion from amps or a TDMA conversion or a GSM
overlay has to be done, it\'s something that a carrier has to look at
within their footprint whether it\'s nation-wide or a few states. They
have to say I\'ll start here and end there, and I want to get it done by
a date certain because I don\'t want to be doing this for the rest of my
life.

The 911 should be the same. It should have a coordinated, balanced,
sensible game plan for deployment. It shouldn\'t be a little here and a
little there and let\'s get it all done quickly. It should be done
orderly. Where the PSAPs are ready, we should start. Where the PSAPs are
not ready, we should help them become ready.

Funding is an issue. Everyone should be dealt with fairly. When we talk
about the carrier cost recovery, we also have to talk about PSAP cost
recovery. It costs money to make PSAPs ready for wireless 911. The first
and only comprehensive effort to date to actually put a figure on what
this is going to cost is coming out of the fiscal and technology teams
of the NENA SWAT initiative.

We now have a figure that looks something like 8.4 billion over the next
five years to make this happen in every county and parish in the United
States of America. Now 8.4 billion would take some of these people in
the room and make them gasp. But on the other side of that equation,
we\'re looking at how much money is being raised in this country for 911
services. We find that the delta, although there is a delta, is not this
horrible chasm but we\'re actually not to far away.

So is there a roll now for the federal government to play in this? We
think so. There should be some leadership. Dale called for leadership or
a national officer for 911. Anybody that walks up to me and says I\'m
from the federal government and I\'m hear to help you scares me to
death. But is there a role for the federal government to play in
oversight and standards creation and making sure the bar is set?
Absolutely.

How do we define that role? I can tell you. You get the people who have
skin in the game at the table and you take their collective knowledge
base and you take their problems and you take their solutions and you
put them all out. Where sane, knowledgeable, reasonable people gather
together to create solutions, good things happen and those efforts are
blessed.

When you take everyone\'s issues and you make them as if they are your
own so that you understand what your brother is going through, then you
are not predisposed, or duplicitous, to an outcome that has been
prearranged. You are more likely to understand an outcome that is better
for all involved. That is the key to our success. It is building teams
and making sure that we understand not only our problems but the
problems of everybody else on the team.

When it comes to funds raiding, you are looking at people who work for
these elected officials who are raiding the funds. It\'s almost like
talking about your daddy\'s drinking problem. You just can\'t do it. You
are looking at people who work for elected officials that are not
allowed to speak out. I\'m not going to be fired over speaking out over
funds raiding, at least I don\'t think I am. My boss is in the room.
Another incredible leader who has laser focus because her goal, her
objectives, her job, everything about her employment is making 911
happen in the best possible way for her citizens.

There are others of her colleagues that are here today to talk about the
Texas cost recovery effort. That is a true example of teamsmanship and
bringing the parties together to discuss their issues. We\'ve done it
with the wireless carrier community. We\'ve done it with the local
exchange carrier community with incredible success. Not everybody got
everything they wanted but everybody walked away happy. Yes, we need a
national voice. But more than that, we need a national spirit. That
spirit should be one of kindred teamsmanship. Thank you.

(Applause.)

COMMISSIONER ADELSTEIN: Thank you, John. I think you met the high bar
that we set for you. We heard a lot, and this was an excellent panel,
about what it takes to get this done. It\'s about leadership, team
building, commitment, divine inspiration which I hope we need some more
of here at the FCC. As you heard from Steve, it also was a point of
focus that we saw in the Virginia experience.

We have a great roundtable here with us this morning. There\'s a lot of
wisdom, experience, and knowledge out there. I\'d like to really get a
dialogue going on this about drawing in also some of the experiences you
have had that have been successful or challenges that you see.

For example, I see we have Anthony Haynes here from the Tennessee
Emergency Services Board. I\'ve heard from him about the outstanding
experience of Tennessee. Maybe if you could just share with us for a
moment, Anthony, some of the experiences in Tennessee and the great job
that you\'ve done there for other states to benefit from.

MR. HAYNES: Thank you, Commissioner. We are not without bumps in the
road so to speak. We\'ve had them with industry. We\'ve had them with
PSAPs as President Melcher mentions. But it all does go back to that
leadership. It\'s not anything that we can just claim we woke up one
morning and we had a bright idea.

It was a lot of stars lining up for us together. We had leadership in
the state legislature. We had leadership among 911 types. We have had
some of the best local 911 leadership from emergency communications
districts in the country. But it is very much a struggle. We do today,
at least as of close of business Friday, had 65 of our 95 counties in
Tennessee getting live Phase II data from at least one carrier, usually
multiple.

That has been a lot of work in itself. It\'s all the way from fighting
with carriers. The FCC standard is not whether or not you have GIS
mapping to receive Phase II data. Once we get past that, we go to the
next county. Your rebid button is right here. Do you know what that\'s
for? It\'s amazing the issues we run into to make a deployment happen at
the local level.

The only thing I would add in closing, Commissioner, is that I hope that
the 911 community is not misunderstood by saying we\'re almost there,
it\'s time to stop. We still have a lot of LECs that are using camera
trunking. There\'s going to be a lot of data that comes across the
circuitry in years to come. I\'m not thinking one or two years down the
road. I\'m afraid that as a nation that\'s how far we\'re looking.

We\'re so hung up on reaching the goals that we set for ourselves five
and six years ago that no one is thinking about when my nine year old
kid is going to be having a cell phone and a car in about ten years. We
have to start thinking about that down the road. If we start after we
reach Phase II in this country, we\'re never going to get there. We\'ll
run into the same deployment issues if not greater challenges than we do
today.

So I commend the industry for what they have done in our state. I am
very happy with the wireless industry. I\'m very happy with BellSouth.
I\'m very happy with Sprint LEC. As I said, it came with bumps, but one
of the things we do is improve our communication. Every close of
business day, I have a call with the people in the field doing the
deployment for BellSouth.

That has helped more than any meeting in Atlanta or any trip to the FCC
that we\'ve done. I would just close on that as the spirit of working
together and communicating that could probably help do more to advance
E911, particularly in those rural areas, Commissioner, I know you and I
share a love for. Thank you very much.

COMMISSIONER ADELSTEIN: Thank you. I don\'t know if we have any other
observations from the experiences that you have had that you would like
to share with us. Any other state or local officials have any comments?

MS. HOGAN: One of the things that\'s helped us to be successful across
the state of Texas is the creation of 24 emergency communications
districts. Those are districts that were approved and authorized by the
state of Texas legislature and then followed up by a voter referendum so
that we know the voters and citizens that we serve really supported what
we were trying to do.

In our particular case in the Harris County area, that voter referendum
passed by a vote of 82 and a half percent in favor of establishing an
emergency communications district and assessing - at that time it was
back in 1983 - a fee on wireline service. The funds that are collected
through these emergency communications districts are dedicated funds.
They cannot be used for anything except the provision of emergency
communications.

We have local boards who are very well attuned to the needs of our
citizens. That\'s one reason why the districts in Texas have been able
to move forward because of those local boards. In addition, the 24
communication districts work very closely together. The larger ones such
as ours, Tarrant County, Bear County and others, help support the
smaller ones.

We come together. We share resources. We share the cost of contracting
for regulatory attorneys and for other kinds of assistance. The larger
districts share the bulk of the cost so that the smaller districts have
access to the same kinds of resources and information.

On the wireless side, the fee is collected state-wide. Our wireline fees
come directly to our district and are collected by our local telephone
companies. The wireless fees, however, are collected state-wide. They
are remitted to the State Comptroller\'s Office. Then they are
distributed based on population that we serve.

That\'s true for the districts. However, part of Texas has been caught
up in this situation of not having those wireless fees allocated. The
councils around the state who administer 911 have not received any
wireless fees in the last two sessions of the legislature. The Texas
legislature only meets once every two years. There is \$61 million
sitting in the Texas State Treasury that has not been appropriated.

It\'s there. It has not been taken, but it has not been appropriate.
Those areas of the state have not been able to move forward. In the case
of the districts, however, we have resources and those fees are
dedicated. I really believe that until we get to the point that
legislative bodies cannot either hold up the fees or rob the fees there
are going to be problems with deployment of wireless.

COMMISSIONER ADELSTEIN: Thank you for sharing that story. Anyone else?
Yes, Mr. Jones.

MR. JONES: David Jones from Spartanburg, South Carolina. I would like to
respond on some comments about LEC participation. In the six wireless
Phase II deployments that have been done in my jurisdiction, we made
that very specific effort that we had to forge this partnership with all
of the parties involved. This was not a singular effort by any means.

In my particular case, the LEC was BellSouth. They were very much an
active partner from the very beginning. It was a long process, but there
is no doubt that they had to be a partner. When we started, we went in
there seeking their commitment, not only the LEC commitment but also the
commitment of each of the wireless carriers and all the third-party
providers. It\'s that commitment and a term that I call
\"stick-to-it-iveness\" that is required in this type of partnership.

The idea that the LEC perhaps could have an option of not participating
is simply not so and is simply cannot be allowed to occur. So you go in
and you seek that commitment. In my case, that was given and they worked
for it throughout the deployment of six wireless carriers.

COMMISSIONER ADELSTEIN: Thank you for sharing that. I would like to open
with a question for the panelists. Then we\'ll move on to any questions
that might come to the panelists from the roundtable. Hopefully we\'ll
have a chance for questions also from the audience before we wrap up.

One of the things we would like to accomplish today is to see if there
are any recommendations that we want to promote to Congress regarding
this issue. We\'ve been asked by the leadership of the newly formed E911
Congressional Caucus for our input on this. They are watching very
closely what we are doing here today.

I wanted to ask our panelists if they believe that any national
legislation would be in order to help deal with the funding problems
that PSAPs are experiencing or to deal with the issue of the diversion
of funds and what initiatives you think would be most helpful and where
might that funding come from. Any of our panelists?

MR. MELCHER: I\'ll be happy to start I guess. NENA was very proud to
play an active role in starting to get the Caucus started along with
many of our colleagues. We think that there is a role for the federal
government, especially at the Congressional level. There are probably
several roles, not just one.

Introducing legislation that says to the states if you are raising money
in the name of 911 then you should spend that money on 911 and not
divert those funds. There are precedents out there that allow them to do
that. There are also some what we call cross-sanction type things that
have been discussed. EMS in this country was a very good example.

One would think that EMS was founded by the Department of Health or the
Surgeon General. It wasn\'t. It was founded by the National Highway
Traffic Safety Administration. Under U.S. DOT, they started putting seed
money out there to train medical technicians and equip ambulances. They
found that you can actually save lives by getting an increased level of
training and better equipment out there because EMS was handled by the
funeral homes. They had the light on the top of the hearse. If the
patient died on the way to the hospital, you make a left instead of a
right and everybody is still happy.

After they found that the program was successful, then they started
making rules that said you must put a program in place in your state to
be eligible for highway funds. If you don\'t have a certified, bona fide
EMS program in your state, then we\'re going to cut off your highway
funds. So that was an excellent way for the federal government to be
able to say this is important to us.

It gets back to 911 has to be a top priority. I know the Commission is
struggling with so many pressures that the carriers are putting on you
about all of the mandates that are out there. There are all kinds of
mandates. I don\'t even want to get into the details of them.

But my job is not to carry the water for them. My job is to say 911
should be a priority. Of all of the mandates that you have on the
carriers, whether it\'s local exchange or wireless carrier, 911 should
be the top priority. If it\'s almost like a Y2K deadline that we\'re up
against, then we have to shunt some of our other efforts in order to
make 911 happen on time.

And 911 should always happen on time. It should always be the forefront
of what we\'re thinking. The other thing you can help them do,
especially those who are very proactive in the Commission, is that 911
cannot be an afterthought. It has to be a forethought. If you are
introducing new technology for telecommunications or for data or for
voice, 911 must be part of your introduction in your business model and
your technology model.

With technology exploding the way it is today, we can no longer afford
to go back and say and how do you make that device 911 compliant. Voice
over the Internet should not be allowed until we figure out how to make
it 911 compliant. You should not be able to connect to the public switch
network and place a call for help unless you are 911 compliant.

Telematics has to be brought into the fold. I love it when I\'m
vindicated because we gave speeches two years ago about Vice President
Cheney\'s implanted pacemaker someday via bluetooth would talk to his
cell phone and tell it to call 911 and some monitoring service would
know what his heartbeat was. Now that\'s in place today. We now have
these I\'ve-fallen-and-I-can\'t-get-up devices that give you latitude
and longitude.

Those types of call centers need to be integrated into 911 so that a 911
call taker gets the same voice and the same data that the private call
center has possessed because those are the people that are sending the
resources that are going to save that human being\'s life. It can no
longer be an afterthought. It must be part of the original plan.

(Applause.)

MR. BALLENTINE: On behalf of APCO, I would echo that part of our federal
legislative platform includes placing some requirements on states that
911 funds collected for the purpose of 911 be dedicated to that purpose
and not raided for other purposes. I\'m not sure what the mechanism is
to ensure that to happen, but it probably is going to take some
leadership at the federal level in order to keep states from doing that.

The other thing that we\'ve talked about - and what this panel\'s
primary focus is - is funding. This \$8.4 billion that President Melcher
refers to is not going to come in \$100,000 increments and really
achieve ubiquitous nation-wide 911 service. We\'re really concerned
about that Swiss cheese effect. We\'ve made a lot of progress. The focus
of today has been very positive, but if we don\'t take some action now
to make sure that there is a plan in place for nation-wide 911 service
we\'re going to end up with a big block of Swiss cheese.

MR. MARZOLF: I guess to echo what John said I think that all new
technology absolutely has to be 911 compatible. I know and have read
comments from several of the Commissioners at the FCC of not wanting to
slow the deployment of new technology and not wanting to inhibit it. But
we have to decide that 911 is a basic service and it\'s a service
that\'s provided on all communications technology regardless of what it
is.

Ultimately, voice over IP would never even think about trying to deploy
the service if you could only call other voice over IP users. They have
to be able to talk to the public switch telephone network so that using
voice over IP I can call Richard in North Carolina even though he
doesn\'t have it. So 911 also has to be one of those basic services that
is absolutely provided.

As I mentioned in my statement, we absolutely support the idea of a
national 911 office. If we\'re ever going to achieve ubiquitous E911, we
absolutely have to have that national level of coordination. I want to
be very clear that I don\'t think it should pre-empt the states
approaches and that absolutely it should be there as another level to
enhance the levels that currently exist.

One of the concerns as a state coordinator that we have with that
federal involvement is the fear that we end up going to the lowest
common denominator. States like North Carolina and Virginia and Indiana
are held back to a lower standard in order to let the others catch up
rather than letting us continue to progress. I\'d absolutely encourage
and think that Congress has an absolute role in getting involved and
promoting the national effort the way many states have done in state
level government.

COMMISSIONER ADELSTEIN: Thank you. Do any of the roundtable discussants
have any comments on that?

MR. HAYNES: Commissioner, I would just add on something that Steve and
John alluded to earlier. It\'s the issue of an essential service. I have
always felt that universal service to receive support from that fund
that 911 should be a core service. Technology evolves. Issues happen to
this country. Issues happen that affect public safety.

So now instead of just looking at whether we have basic 911 as a core
requirement of universal service report, in order to receive it an be
eligible for it, one of the things \-- I guess I should say you asked
the question about what could we tell Congress. We can tell them that
there are some things that the Commission could do coming out of these
comments right here and that everything you do are we affecting 911.
Granted that may not necessarily deal with content over at the media
bureau or whatever. However, there are a lot of day-to-day decisions
made around this place that affect 911 directly or indirectly either as
it relates to wireless carriers, as it relates to the LECs, or maybe it
affects the local 911 districts.

In doing that, I would recommend to the Commission that each and every
opportunity that you have to take a look, how could this decision, how
could what the industry is asking for, how could what the regulatory
precedent is on this issue, how could that affect 911. I think that
could really help do a lot that a lot of us don\'t even have on the
radar screens right now.

I keep hearing rumblings in talking to my friends in the carrier world
about consolidation. There\'s no way in this economy. We\'re
cannibalizing each other\'s customer base. If we do have consolidations
in this industry, I think the effect ought to look on if you are going
to take this company you are going to have some E911 requirements.
That\'s going to be the condition for the approval right up front.
You\'re not just going to drag your feet and say we bought this, we
inherited the liability, and we\'ll get to it one of these days.
There\'s a lot that can be done right here at the Portals Building that
can help us advance the cause so to speak in the regulatory world that
ties into what these folks are saying.

COMMISSIONER ADELSTEIN: I\'d like to open it now for any questions or
comments on the general issue of PSAP funding and operation from the
roundtable to our panelists or to each other.

MR. NIXON: As the chair of ESIF, not as T-Mobile necessarily but
T-Mobile certainly supports ESIF, I was concerned by a comment that
Steve made earlier about one of the problems he had in deploying was a
lack of standards over signaling and data formats, et cetera. I would
simply reinforce that ESIF works very closely with NENA\'s technical
development conference and committees and APCO\'s various committees on
making sure that there are appropriate standards out there available for
all facets of this task.

If there are things that you have identified or that anybody has
identified that are lacking as far as standards go or approaches go,
ESIF, NENA, and APCO I\'m sure would be happy to field those questions
and try and either identify the currently established standard or help
work to improve or create a standard if it\'s needed. I just wanted to
make sure everybody understood that tool is out there.

MR. MARZOLF: I\'m aware of that, Jim. Most of the issues that we have
actually are being currently worked on by either the NENA TDC effort or
ESIF. The issue is when you are on the bleeding edge you find the
problems. Then you have to hand them off to the technical people to
figure out the solution. We didn\'t stop in the meantime. We\'re still
moving forward.

It\'s going to take time for those solutions to catch up to where we
are. We understand that. The implication was not that anyone is dragging
their feet and not wanting to move forward. We\'re optimistic that
everything is going to come together as we progress.

MR. NIXON: And ESIF is ready to help with the triage you have on that
bleeding edge any time.

COMMISSIONER ADELSTEIN: Any other questions or comments?

MR. FORSHEE: Going back to what Jim was talking about, I\'m not speaking
of the standard that sets the format. What I\'ve seen recently is who
decides what goes into that format. Who controls what goes into a given
field? I don\'t know if ESIF does that or NENA does that.

If you go to various LECs across the country and you are implementing
wireless 911, you soon find that LEC X says here\'s a format, put in it
what you want and LEC Y says no we want this word to appear in this
field. It gets very confusing. Somebody needs to sort that out. We need
to establish some guidelines for that.

MR. MELCHER: It\'s very good to define the line between NENA standards
setting and ATIS and other recognized standard bodies. NENA is not a
recognized standard body. We do recommended standards. For many states
of the union, NENA recommended standards are part of their state
legislation.

However, NENA is really geared towards maintaining a certain level of
expertise and it\'s strictly 911 related. When we get out into other
areas of telecom, we divest ourselves of some of that responsibility
into those who really do it for a living. If I can, ESIF is really an
extension and an augmentation to the NENA standard setting process.

It deals with bringing those who are other standards bodies into the
solutions because once you affect Cog A in the machine, Cog Z in the
machine somehow gets affected as well. That\'s where, especially under
the leadership of Susan Miller and Ed Hall by providing this kind of
forum, ESIF and their leadership has been able to take and integrate
with TIA and Committee TY and all these others that have little bits and
pieces.

As Charles McKee was saying earlier, this is very complex. It\'s not
just a wireless thing. It\'s a wireless thing. It\'s a wireline thing.
It\'s a PSAP thing. It\'s all of telecom. So it\'s really a segue from
the NENA starting on the 911 side to how does it impact the rest of the
public switch network.

MR. NIXON: I\'d just like to amplify just slightly, Norm, that we are
very sensitive to duplication of effort as was mentioned earlier. The
whole ESIF process is set up to receive an issue and then evaluate
whether it\'s appropriate for ESIF to handle it internally or if it\'s
more appropriate to hand it off to an existing NENA committee to work on
a particular standard.

So the data formats as far as the data that flows through from the
carriers to the PSAPs typically has been handled under the NENA
technical development committee structure. The signaling, J Standard 36
type things, are handled typically under the formal standards
development organization. We try to efficiently handle the interface
between those two groups, the operational user group and the technical
group, as best we can to make it efficient and effective to get an
answer out that works for everybody.

MR. FORSHEE: Jim, just to respond. Mine was more about ownership and
responsibility of format or data content as opposed to the other.

MR. NIXON: Okay. It\'s speaking more as T-Mobile and less as ESIF. I can
keep both of my hats on maybe and turn them both out a little bit. All
of the carriers rely pretty strongly on the NENA data formats as far as
what data they are going to send and in what format they are going to
put it. Once we get it from our system to the demark point to the 911
system, as was mentioned earlier, we try to get it there as generically
as possible so that once it hits that demark point if you are PSAP A
through Z or LEC A through Z you can use that data, reformat it, and
present it in whatever method is appropriate for the end user I would
hope.

MR. MARZOLF: Also in our experience what we have found is it\'s not
always driven by one of the people that we\'re talking with. It was
driven maybe by a developer some time ago developing a particular
system. We\'ve had some issues of format or of content that we wanted to
change. That individual wireless service provider maybe has their own
MPC mobile positional center for Phase II. For whatever reason, that
equipment manufacturer can\'t change the way that they do it. Or maybe
they are willing to change it but it\'s going to take a future iteration
to do it.

As an example, the issue we had come up recently in Virginia was the
presentation of the longitude and latitude for Phase I calls. Everyone
thought that was a wonderful idea in the planning stage and development
stage, but it confuses the call taker immensely to have a longitude and
latitude show up for a centroid of a sector or the tower itself rather
than per an actual Phase II location.

One of our providers came to us and said we can get rid of it if you
like. Their MPC provider said they could do that. So we started to talk
to the PSAPs about whether they wanted to. The question came up will any
of the other providers get rid of it.

The answer was a couple said maybe we could and we\'re not really sure.
A couple of them looked to their third-party provider who weren\'t right
now capable but are planning to be able to turn it off in the future. So
it depends on a lot of these early development decisions that were made
on how the system will work and isn\'t always something that can be
easily changed by anybody without some \--

COMMISSIONER ADELSTEIN: If anybody from the audience would like to pose
a question to one of our participants here in the roundtable, please
come up to the microphones. You can say who you are and ask your
question.

MS. MOORE: My name is Linda Moore. I work for the Congressional Research
Service. I\'ve spoken to a number of people in this room on several
occasions. Because I work for CRS, I\'m speaking here as a private
person. Everything I say is not a statement from Congressional Research
Service.

I have some questions about funding, two important ones really. John, I
know that the intent for getting 911 compatibility with everything,
telematics, voice via \-- is well met, but it\'s at your cost of
infrastructure. Almost everyone I have ever talked to about PSAPs,
staffing is an incredible problem. There\'s never enough staff training.
How are you going to handle an additional cost to your PSAPs by imposing
additional types of calls that they have to respond to?

That\'s my one question. The other question is even though I absolutely
agree that the leadership has been important and where PSAPs have been
successful, I\'m not sure that funding always follows. Besides how can
you give that to me as an excuse as a citizen of the United States if I
come from Tennessee which is well organized and I have an accident in
Massachusetts which has no funds? So they didn\'t have leadership. Is
that a good answer to give to somebody? Those are my two questions.

MR. MELCHER: Thank you. Is that for John or Jonathan?

MS. MOORE: John.

MR. MELCHER: I was just making sure. We don\'t want to pre-empt the
Commission\'s response.

(Laughter.)

COMMISSIONER ADELSTEIN: We want to hear from you on that one.

MR. MELCHER: We may need his input later. The first is about integration
of new technologies into the PSAP and creating the PSAP workload. Any
public safety manager who is not planning for an increased call volume
to their PSAP is not doing their job because it\'s just reality.

It used to be at five o\'clock on a Friday afternoon on a major freeway
you had a big accident and people would run from their car and go to the
pay phone and call it in so you would get one or two or three calls. Now
you get 60, 70, 80, 90 calls for the same accident. It\'s just because
we now have a proliferation of devices that allow people to communicate
that did not exist before.

So any public safety manager that\'s not planning for that and any
elected official who\'s not planning for that simply has their head in
the sand and needs to pull it out. But more so the integration of
technology really is not the biggest issue. By applying the standards
and formats and bringing the stakeholders to the table, we\'re able to
take things like wireless location technology and apply things that we
had in place before like what we called mapped ALI.

Always our addresses came in as a block number and a street name, so 123
Main Street for those who were very progressive were getting mapped ALI.
They had their communities mapped. So when 123 Main Street came up on
the screen, then the other screen that had the digital map linked the
dot on the 120 block of Main Street. By having mapping in place, can a
map do latitude and longitude for wireless calls? Sure, that was an easy
segue.

It wasn\'t really this horrendous burden of oh my God we have to get
mapping to do wireless if you were already progressively thinking in
your technology. That doesn\'t mean that all across America there are a
lot of PSAPs that don\'t have digital mapping because they didn\'t have
rural addressing. It was Route 4 Box 2. All you had to know was it was
Ms. Myrtle\'s place and we knew how to get there.

But as technology progresses and as the demands on public safety
progress, it\'s not just wireless 911. We have now demands on public
safety in the fire service and the police service. There\'s new types of
crime and new types of hazards out there with terrorism and all this
kind of stuff. There\'s more demands.

So it\'s all a matter of having the big picture in mind and making sure
you are planning for the long-term. The impact to the PSAP call taker,
although it is substantive, is not overwhelming. Training is a huge
issue. You have to make sure that you keep those dollars available for
training.

You can\'t just hire people and put them in the chair and tell them to
sink or swim because your exposure and liability goes way up. You have
to make sure they are constantly trained. Our agency and our
counterparts in Texas spent an enormous amount of money on continuing
education and training.

The second part of that was your right as a citizen to the service. I
don\'t think that 911 is an entitlement. Anyone that wants to say that
911 should be an entitlement needs to come up with the appropriate
funding source to make it so. I\'m not objecting to 911 as an
entitlement to every person in this country because my job and my career
has been about getting 911 service to every one of my citizens and now
as a national leader to everyone that lives in America.

But if we\'re going to call it something, then let\'s really define it
and let\'s support it as such. If we\'re going to say it\'s an
entitlement, then let\'s figure out how to get it paid for as an
entitlement. Until we do that, then we have to make best use of our
funds and we have to be honest about the use of our funds.

If we\'re raising money for 911 and it says it on a consumer\'s bill,
then let\'s spend it on 911. If it\'s too much money and you have
already done what you need to do to make sure you have the best 911
system available, then lower that fee. If it\'s not enough money or it
doesn\'t exist, then get off your duff and make it happen because you
have citizens that are at risk out there and it must happen. If it is
insufficient, then fix it.

I\'m not a big fan of applying global issues for one bad apple or global
rules for one rule breaker. But I am a big fan - and I think that I
speak for all of us in public safety - of being held accountable. The
wireless carriers have to be held accountable, the LECs, but public
safety has to be held accountable too. If we\'re not doing our job, then
it\'s the mandate upon everyone here to make sure that elected officials
understand their responsibility.

As an elected official in the room, I know that Tim can tell you he\'s
not an expert on every single topic. But those that are priorities for
him, he is an expert on and he has expertise available to him so that he
is knowledgeable and he\'s capable of acting in the best manner. That\'s
what\'s important here.

I applaud Commissioner Adelstein even in his confirmation hearings he
talked about the importance of 911 especially in the rural areas. He has
a very personal knowledge. I know he has a very spiritual aspect to this
because it is an important thing and it does deserve that kind of
priority. Thank you.

MR. BALLENTINE: If I could just respond to a comment or two. I certainly
would disagree with the statement that 911 is not an entitlement, but I
absolutely agree with the statement that it should be. I was reluctant
to cue the mic and speak up because the second part of that phrase was
\"whoever says it is should come up with a plan to fund it.\" That piece
I don\'t have. But certainly this nation needs to come up with some
mechanism and some method to fund 911 deployment nation-wide.

The other part of the lady\'s question was emerging technologies and how
that integration of emerging technologies into 911 centers affects the
national staffing crisis. First, on behalf of APCO, let me thank you for
recognizing that there is a national staffing crisis in 911 centers and
public safety communication centers.

The position of the Association of Public Safety Communications
Officials is that any citizen who attempts to dial 911 should have that
call delivered to the appropriate public safety communications center
immediately with the call location information accompanying that call.
Now if these emerging technologies are something other than a citizen
intending to dial 911, then perhaps the 911 center is not the
appropriate place for that call to be delivered.

It\'s hard to speak with a big paintbrush over emerging technologies.
But there are a number of services out there that have other avenues to
deliver that call through to emergency services. I don\'t know if that
answers your question or not, but it certainly is an issue; the staffing
crisis that currently exists throughout American and emerging
technologies.

MR. MELCHER: I\'d like to piggyback because Greg makes an excellent
point. One of the deals is that we are under a staffing crisis. All of
these new technologies delivering more calls, one of the things that
we\'re working very closely on - as a matter of fact we have the only up
and running system in the greater Houston metropolitan area - these call
centers that are non-911, they are private call centers, in this case a
telematics call center, is able to integrate into the 911 system with
voice and data and everything that\'s coming from the vehicle or from
the driver or from whatever they have. Whatever information they have on
their screen, we now get on our screen if it\'s pertinent to the 911
call taker.

But the value there that Greg touched on is that if it\'s not an
emergency we don\'t get it. So the Ford Safety Center answers the call
when the car runs into something. The first thing they say is do you
need an ambulance or do you need emergency services. If they say no I
just backed into my neighbor\'s tree and it caused the device to deploy,
then we\'re not going to get that call.

So if each and every device out there, whether it\'s the
Bluetooth-enabled pacemaker or whatever it is, were calling 911 then oh
my God our crisis would be ten-fold. But by taking the existing
technologies, the OnStar and the Ford Safety and all these other
centers, and letting them screen out the non-emergencies, that\'s a good
thing.

However, if it\'s an emergency call, make no mistake, those call centers
should be 911 compliant just like any other device should be 911
compliant. That voice should be a conference call to trained and
emergency response and the data that they are possessed of the 911 call
takers should be possessed of as well in order to affect the appropriate
response.

Then the 911 call taker can come off the line and affect that response.
The private call center can continue to babysit that customer as they
are paid to do. Life is good. But if they are not integrated the way
they should be integrated, that has to change.

MS. HOFFMAN: I would just like to speak to the consumer part of it and
leadership and funding to your question. I come from a state where I pay
\$1.20 a month for a surcharge on my wireless phone. My state doesn\'t
use that money to fund wireless enhanced 911 services. As a consumer, I
should be outraged. Every consumer in the state of New York and every
other state that charges consumers any sort of surcharge and doesn\'t
use that money for funding E911 should be outraged.

In the state of New York in the last ten years, we have raised \$200
million in E911 funding on surcharges. Audits have shown that money has
gone to everything but upgrading technology. That is where leadership
comes in. That\'s where leadership has to play a very large role to say
that this is enough, we have to stop, and we have to hold leaders
accountable who don\'t do that.

(Applause.)

MR. MARZOLF: I was going to give John Melcher a hallelujah there, but I
thought it would just make him talk more. One of our problems in 911 is
that we\'ve always been ralliers. We always get the job done. You can
throw any new device at us. We\'ll find a way to make it work.

It can be 2:00 on a Sunday. No one else is around. But we will try and
find a way to locate the person. That\'s hurt us staffing-wise as well
because we don\'t have crises in 911. The calls still get handled. The
calls still get processed. Help still gets dispatched. In these tough
economic times, when we go to our local legislative bodies and say we
need more staff, they look and say gosh I haven\'t had any complaints
about you but I\'ve had lots of complaints about the potholes and all
these other things so I\'m going to put the money where the squeakiest
wheel is and it\'s not 911. That has hurt.

But also to the second part of your question, Virginia like Indiana has
empowered the locals to deploy this service more so that deciding to
deploy it as a state. 911 in the United States is primarily, not
universally, a local service delivery whether it\'s greater Harris
County or whether it\'s the state of Vermont as the local area. It is a
local delivery option. The citizens locally decide do I make it a
priority or don\'t it.

Do I enjoy the fact when I travel to other places that don\'t have 911
that they don\'t and do I think they should have it? Yes. But right now,
it\'s still a local decision whether or not to deploy the service. Until
there is some sort of federal legislation or state legislation to
mandate it, it\'s going to continue to be that way.

COMMISSIONER ADELSTEIN: Thank you for that, Steve. The lunch hour is
almost upon us. I wanted to make a quick observation and announcement
and free everybody for lunch. We\'ve heard a lot of good ideas here
today about getting PSAPs up and running. I want to thank all of the
panelists and all of the roundtable participants for an incredible
session.

Certainly we heard about the need for political will and leadership and
funding. When those happen, you get the standards in place and the
expertise at the PSAP level. Certainly speaking on behalf of the FCC,
because I know I\'ve spoken to all of my Commissioners, we can at least
supply two out of three of those. You can probably guess which ones; the
will and the leadership.

But the funding, as a lot of our panelists noted in one way or another
will follow if that will is there. If the leadership is being displayed,
the money will find its way to the right place. Just as water will flow,
that will flow. So it\'s really a matter of getting those things done.
We here at the FCC prepared to do whatever it is that we can to promote
that and to support the great leadership of the type that we\'ve heard
today from all of you and some of the wonderful ideas that you have
shared today. So thank you for that.

With that, I\'ll just mention that we\'re going to reconvene at 1:45
p.m., an hour from now. For those of you who are new here, there are two
cafeteria-style establishments on the CY level of this building, that\'s
the Court Yard level. They named it Court Yard level because they wanted
to make sure we had eight floors in this building even though it has
more than eight floors. So they came up with the CY and TW. It all adds
up to eight. In our previous building, there was a famous eighth floor
which brings to mind the question of what happens if we ever move to a
taller building. Anyway, I thank you all. I thank the panelists. I thank
you all for participating today. Off the record.

(Whereupon, at 12:49 p.m., the above-entitled matter recessed to
reconvene at 1:51 p.m. the same day.)

A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N

1:51 p.m.

COMMISSIONER COPPS: Good afternoon. My name is Mike Copps. I\'m pleased
to welcome you to this panel discussion on local exchange carriers and
E911. I want to thank our three panelists for taking the time to make
presentations here today and to help us figure out how make our E911
system better and to make it available around the country with all
possible speed.

As you have heard several times today, this is not your every day FCC
topic. This is about saving lives. It does have a tremendously high
priority here, in the Congress, and around the country. We all need to
keep that in mind as we work together to overcome the challenges that
remain. We have made some good progress over recent months. There are
still challenges that remain.

Having this forum today is going to be helpful in helping us chart our
direction ahead. Our panelists today have been working to confront these
challenges head on. As they realize, this is not just plain old telecom
policy. So this is a really good event to be having.

I am here today not to talk but to listen and to moderate, so I\'m going
to turn to our panelists right away. Then when the panelists are
completed, instead of me asking a lot of questions, I might ask first
the folks at the roundtable here if they have any comments on the
presentations that have been made. We\'re supposed to be ready to turn
this over to whatever comes next at 2:30 p.m. Whatever time we have left
we\'ll open up to questions from the floor.

First, we\'re going to hear from Mike Pedigo of the Texas Cost Recovery
Team. Following him will be Tom Latino of SBC Communications. Then it
will be my good friend Tom Dunleavy from the New York Public Service
Commission. With that, I\'m going to turn the podium over to Mike.

MR. PEDIGO: Thank you, Commissioner Copps. I appreciate the opportunity
to be here. Like other times, it seems like I always follow Melcher on a
panel and after lunch. He gave the sermon this morning, so I\'m here to
testify to what he said. That\'s what this is about.

I am here to talk about one of those coordination/cooperation activities
that we heard about this morning. It\'s a real success story for the 911
districts and the entire state of Texas in whole and how we have come to
an agreement with SBC Communications that we are working together to
propose to the Public Utilities Commission of Texas. In fact, the
proposed agreement we have finalized. It\'s just a matter of getting it
together so that we can present it jointly to the PUC hopefully to get
their support on this.

We appreciate this opportunity to participate in this and to tell about
how we came about that because as Laverne Hogan mentioned this morning
there\'s 24 911 districts in Texas that work together on a lot of
projects. They cost share things and all. Back last summer, the district
directors got together and decided to put together a cost recovery team
to deal with the issues of cost recovery as related to implementation of
Phase II wireless and Phase I in those cases that had not completed
Phase I. In most cases, the districts had already completed Phase I
throughout the state.

The Texas Cost Recovery Team, which I\'ll refer to as the CRT, started
meeting last summer. We were supported by resolutions or statements of
understanding by all of the districts. Twenty-two of the twenty-four
districts in Texas supported us in concept and in who we are. We have
kept them informed throughout the process.

The purpose was to work with all of the wireless carriers to come up
with a reasonable cost associated with the implementation of Phase II
services and in the process of that to also move forward as quickly as
possible with the deployment of those services throughout those
districts. We started meeting with them. Once we realized that as we
were looking at where we were going to be spending the funds, Texas does
have a cost mechanism in that there is a 50 cent fee collected across
the state as Laverne said and sent out by population basis across the
state to the entities that administer that 911 system.

As we started working with the wireless carriers, we realized that they
weren\'t the only party in this. We needed to be careful not to commit
all of our funds to the wireless carriers. The LEC that had to connect
us to the wireless carriers were an integral part. We needed to make
sure we knew what those charges were going to be going into the terms of
agreements we had with our wireless carriers.

In October 2002, SBC Communications filed a tariff proposal to the
Public Utilities Commission of Texas. They came with a cost that the CRT
and the other 911 entities in Texas had some difficulty in the model
that they were using and wanted to work with them to come up with a
better solution that better fit our needs and yet give them what they
needed to cover their costs and a return on their investment.

We looked at the proposed tariff that the SBC submitted. It was based on
a 28 cent per month per call as well as a \$4,195 per PSAP
implementation. We had difficulty with that approach in that (1) it made
it really difficult for us as government entities to budget when you
don\'t know what the call volume is and is it going to grow or is it not
going to grow in those areas with a lot of interstate traffic and
incidents. It would make a big difference.

The second thing that probably gave us a little more problem was the
reliability and accountability for the deriving of the number of calls
per month per whatever unit. We approached SBC Communications and asked
them if they could come up with another solution or another proposal in
their tariff that would work better than a per call basis. After several
meetings, they challenged us to come back to them with a model that
would work. They said we understand you aren\'t happy with our approach.
We understand that. We\'re in business not to give services away. You
come back to us with a proposal and we\'ll talk.

The team worked together, and we did come up with a proposal that we
approached SBC with. It\'s based on the same model that we were
beginning to use with our negotiations with the wireless carriers. We
thought this model works really well and is really equitable across the
state for those large 911 entities as well as the small ones. As Laverne
alluded to this morning, our wireless service fees are sent back to 911
entities based on our percentage of the total population of the state.
So each 911 entity gets that same percentage of the total wireless pot.

So we decided that it would make sense to divvy up the expenses using
the same model. We worked with Southwestern Bell more toward not what
the individual cost per unit or whatever as how much is it going to cost
us to do this. Give us a bottom line. How many dollars do you want from
the state of Texas to do LEC services for wireless over the next five
years? Tell us how many dollars you want.

So through their cost study, we enlisted services from a cost study
expert that went in and evaluated their studies and had questions. They
worked with us on those questions resolving any issues for the services.
We came up with an agreeable rate that both parties have agreed to for
the five year term, present value, meaning that if some of those 911
entities that have been collecting wireless funds for several years and
are ready to deploy, they may have that reserve balance for wireless
that they could pay right now and pay the five year term and not have to
finance that using the monthly recurring costs.

So with that present value, we came up in an agreement with them to pay
over the \-- Red light already. Anyway, we have an agreement. We\'re
moving in that direction. We have determined it\'s a win-win solution.
For us, we have it done. We\'ve gone out and sold it to all of the home
rule cities. CSEC has been a part of this process, the state 911
commission. All have agreed in principle.

Where we are today is that we are to submit our proposal settlement to
the PUC in hopes that they will concur with this and that we have this
resolved for five years. Everybody, whether they be rural or in a
metropolitan area, pays the same amount so the burden is not shifted to
those rural areas.

In conclusion, I would really like to thank Tom and Southwestern Bell
for the spirit in which they worked with us through all of these
negotiations. They continued to implement Phase II without an agreement
and did not impede it. In fact, this is not a done deal until the PUC
signs off on it, but they have implemented numerous Phase IIs throughout
the state. Like I say, it\'s been a model that other states might want
to look at. Working may resolve some of those impediments in the future.
Thanks.

(Applause.)

COMMISSIONER COPPS: Thank you, Mike. I want you to know I was not the
one that pushed that button. Just for the record, how much time does
each speaker have? Can somebody tell me that? Eight minutes, okay. It
was very interesting. It didn\'t seem like eight minutes at all. This is
a really good opportunity though to hear the perspective from your side.
Now we can hear from SBC. That will give us a real good picture for the
synergies involved here. So Tom Latino.

MR. LATINO: Commissioner, public safety professionals, colleagues, and
interested parties, good afternoon. As you know, the first phone call in
our nation occurred March 10, 1876. Allegedly, that was also the first
emergency phone call. As it\'s rumored upon spilling acid upon his leg,
Alexander Graham Bell then reached for his new invention, the telephone,
and stated the famous words that have echoed throughout the centuries
\"Watson, come here, I want to see you.\"

Ever since that moment, ILECs have been the glue, particularly in the
last quarter of the 20th Century and into this century, that connects
the public safety infrastructure or the public safety puzzle. Today
ILECs connect more than 7,000 primary 911 call centers. Additionally, we
process more than 200 million calls annually, both landline as well as
wireless.

For as stewards of the 911 system, we recognize that good enough is not
an acceptable standard. As such, we work diligently with local and state
officials, state regulators, and public safety organizations such as
NENA and APCO in order to evolve our current infrastructure. This has
been done oftentimes in a multitude of standards as well as lock an
effective cost recovery mechanism.

Our goal is to build an effective, comprehensive, and reachable 911
public safety infrastructure capable of saving lives. However, as with
any important endeavor, more is needed than creativity, dedication, and
committment. What is also needed is economic capital to sustain that
effort.

To date, SBC has successfully reached cost recovery agreements with
several states and most notably in principal with the state of Texas who
has worked diligently with us. However, cost recovery issues remain in
other states and as such remain an issue for our industry.

The current mandate model imposes obligations upon ILECs and other 911
service providers irrespective of customer readiness or the desire to
participate. Millions have been invested without clear cost recovery
mechanisms. As we heard earlier today, some states in fact have no cost
recovery legislation in place. Additionally, some states have
reallocated funds originally earmarked for 911.

Culturally as a nation every day millions of us walk into a national
well-known coffee chain and spend more for one cup of coffee than we
spend for a month\'s worth of 911 service. As we have discussed wireless
issues here today, I was also pleased to hear new emerging technologies
rise to the forefront of this issue, for example, automatic crash
notification as well as voiceover IP.

We must learn from the lessons that wireless has taught us in these
areas. Failure to do so will result in a fragmented and more costly
overlay network that will be fragmented without delivering any increase
in benefits to its end users. 911 is in fact the premiere public service
in our nation today. As such, our challenge and our responsibility is to
ensure that it remains to by changing mechanisms that brought it to this
forefront.

Our opportunity is now. Bell\'s words more than 125 years ago, \"Watson,
come here,\" signaled that we were approaching a new era of
communications within our nation. Likewise today, we are also in the
midst of a new era. An era which must recognize the conventions and
standards put in place more than 30 years ago to build our current
infrastructure must be revamped and remodeled in order that effective
change can occur.

As an ILEC, we are justifiably proud of our 25 year public safety
heritage. We remain committed to work with public safety officials as
well as NENA, particularly through their SWAT effort, in order that
meaningful and lasting change can occur. Thank you.

(Applause.)

COMMISSIONER COPPS: Thank you, Tom. Now last but certainly not the
lesser for it to my friend from the New York Public Service Commission,
Commissioner Tom Dunleavy.

COMMISSIONER DUNLEAVY: Thanks very much, Mike. One of the problems with
coming here after lunch and after this morning\'s informative session is
that much of what I had planned to say has already been said. But let me
take my time.

(Laughter.)

COMMISSIONER DUNLEAVY: Now we\'ve heard that the fundamental shift in
the nature of 911 calls is that more people embrace the wireless
technology. Many wireless calls now to 911 are in the nature of good
samaritan calls. The fact of the matter is that the beneficiaries are
individuals who don\'t subscribe or may not even subscribe to wireless
service but in point-of-fact they are the beneficiaries of that service.

That is a fact. With that, I wonder whether or not the wireless service
can reasonably argue is a public service and not an individual service.
Perhaps it might be. This trend is likely to continue as time goes on. I
don\'t think that there is any doubt that if you just look at that
demographic of 18 to 35 year old people you will see where this business
of telecommunications is going.

While most of us hope that we will never need an emergency call, we all
would like to think that when we do that we are going to get a response.
For my purpose here, I\'d like to, if I may, review a little bit about
how 911 generally developed in New York state. As you all know, the push
for emergency telephone numbers first began 50 years ago. I remember it.
Many of you don\'t.

In 1968, AT&T assigned 911 as the emergency number. Shortly thereafter,
New York City opened its first 911 emergency call reporting center. It
was among the first in the nation. In order to facilitate the
development of that 911 service, the New York Commission issued a policy
statement directing telephone companies to absorb the cost of modifying
facilities for implementation of basic 911.

All telephone companies were required to arrange their facility so that
911 calls would reach either an emergency report center or a telephone
company operator. By 1976, as we know, 17 percent of the U.S. population
had access to basic 911, landline enhanced 911 service with selective
routing. The ALI was developed in the early \`80s.

Many public safety officials quickly realized the benefits of 911. By
2001, 97 percent of the U.S. population was living in areas served by
some type of wireline 911, and 95 percent have the benefits of fully
enhanced 911. Back in \`84, again regressing a little bit, the New York
Commission established the means for sharing the cost of telephone
service between LECs and county governments which operate the system.
That was Kitna (PH) case. The cite is 28358. The Opinion was 84-7.

Under our approach at that time, the functions necessary to root all
E911 calls to the proper destination and the ALI databases and
associated computer equipment and data links were treated as part of the
basic service and supported by the general body of rate payers. Other
E911 services, dedicated circuits to transport E911 calls, PSAP terminal
equipment were supported through charges or in the case of PSAP
equipment rental charges to the county.

When the \`84 policy was set, we expected that E911 would proliferate,
would explode, would go. Unfortunately, again as we all know, this was
not necessarily the case. The fact of the matter is that fiscal
constraints did in the early \`80s and \`90s dampen the demand. That
sounds familiar. The more things change the more they stay the same.
Right? We have exactly the same problem now. It\'s magnified
tremendously, certainly in New York.

In \`89, the state legislature enacted Article 6 of the county law which
empowered counties to impose a monthly surcharge. You have heard
something about Elizabeth Hoffman today about what our monthly
surcharges are. Today wireline surcharges in most counties outside of
New York City are roughly 35 cents per access line per month. In New
York City, the wireline surcharge is a dollar per access line per month.

That surcharge came about as a result of legislation. The New York state
legislature granted the New York City Council its home rule request. It
allowed them to increase that surcharge last year. Even with the
additional revenue source, we\'ve had to look for ways to ease the
financial burden of counties in building 911 systems.

The Commission stepped in \`94 making E911 services more affordable to
counties by generally relieving the burden of paying for E911 services
and functions that we determined were a monopoly or bottleneck service.
Determining the proper PSAP to which E911 call is to be routed, the
selective routing, and the transport of E911 calls to the point of
selective routing we considered to be bottleneck. Whereas furnishing
maintenance and operation of the ALI database is potentially
competitive.

By changing the tariff in \`94, bottleneck services are now provided to
the counties at no charge with their cost being recovered in other
rates. Today counties are charged per access expenses for operation and
maintenance of the ALI database. There are no charges for dedicated
circuits used to transport E911 calls in counties with more than two
PSAPs. Not surprisingly, New York City has two PSAPs.

These are assigned to the general body of rate payers and considered
part of the basic service. Whereas only the cost of potentially
competitive E911 services are supported by rates charged to the county.
The costs associated with maintaining the ALI database are computed on a
per access line basis. In New York, the charge is 3 cents per line in
counties with fewer than one and a half million access lines. For
counties with more than one and a half million, it\'s 2 cents per access
line.

We do not have a dip charge. Part of the reason for not having a dip
charge is that the thinking probably was that where there\'s
significantly high volume of E911 calls that dip charge would be overly
burdensome. The New York Police Department E911 PSAP handles probably
something in excess of ten million calls a year. About a third of them
are wireless calls.

New York City recently inaugurated a 311 service which is for all calls
other than emergency calls. Hopefully that will mitigate some of the
load that is there. Again, it\'s in response to budget problems. Some
99.5 percent of New Yorkers live in areas served by landline E911.
We\'ll never get to 100 percent. We have some very rural counties where
we don\'t have street addresses and things like that.

I\'m getting a yellow light here, so let me move to this survey that
NARUC did of the various 911 operations throughout the country. I left
copies of it here. It will be part of the record. I\'m not going to bore
you with it. It\'s a relatively long report. We will update it as we get
more information in. It will become part of the record and available to
you.

States obviously have an interest in this topic. Mr. Hatfield pointed
out there are several areas of potential interest that states have.
That\'s the need for upgrades and any cost recovery by ILECs to support
911, the need to assure that money specifically collected - and it\'s a
very sensitive point - to support such services is appropriately used
for such upgrades and for such services, the need to examine tariffs
that set the per E911 call charges, and the need to have a
collaborative, cooperative national effort to address this.

I\'m not going to spend any additional time trying to justify the way
that E911 money is spent. It\'s a contentious area obviously and one
that I\'m not going to be able to resolve here. The fact of the matter
is that wireless E911 services across the footprint of all of the ILECs
in the state of New York are available. The ILECs are doing a good job
but for a variety of reasons. That variety of reasons focuses on money
at the local level, at the PSAP level, perhaps not everyone is prepared
to do what they need to do.

For example, outside of New York City in most of upstate New York, 911
calls go to the New York State Police PSAP. They in turn handle these on
a manual basis. Given the nature of 911 calls, you can well understand
how difficult this is for them. All of those calls are generated by
people who are in some sort of a stressful situation, so it\'s very
difficult.

If I may just wind up here, I\'m optimistic in New York because our
governor proposed and the legislator approved the amendment Article 6
into county law. The amendment established within our Department of
State in New York the 13 member New York State 911 Board. The purpose of
which to assist local government, service suppliers, wireless telephone
service suppliers, and the appropriate state agency by facilitating the
most efficient and effective routing of 911 calls.

Now, I\'m encouraged by that. I\'m also encouraged by Assemblyman
Koon\'s efforts with regard to 911. Good things are born of tragedy
unfortunately. What I would say is that I certainly endorse the idea of
a national oversight or coordination collaborative process for wireless
911. The mechanism may be in place.

Whether this is the right thing or not, I don\'t know. But the FCC
certainly has the ability under the Act to create what would be a joint
commission to accomplish this. As I said, I don\'t know if this is the
right way. I do know that what we need to do is to bring all of the
stakeholders together. By all of the stakeholders, I mean the FCC, the
DHS, the regulators, everyone, Ms. Doty\'s organization in Missouri and
the middle states to get this thing done.

Mr. Hatfield in his very fine report proposed that the Administration
establish the National 911 Program Office within the Department of
Homeland Security. As I said, I don\'t know where it belongs but the
idea is right and we should do that. We also may want to consider taking
a contract approach as opposed to a tariff approach in all cases. Having
said that, I thank you so much for your time.

(Applause.)

COMMISSIONER COPPS: Thank you, Tom and all the panelists for a very
interesting series of presentations. Let me turn first to the folks at
the roundtable. Does anybody have any particular comments on the
presentations or questions for one of our panelists?

MS. HOGAN: I was going to ask Mike a question. I know he described the
dealings with Southwestern Bell on the wireless tariff for SBC. But the
CRT also dealt with the issue of costs from wireless carriers,
particularly the non-recurring per cell tower charges which, when the
CRT first began working, ranged anywhere from \$40,000 per cell site
non-recurring up to \$213,000 per cell site from one of the wireless
carriers. Mike, can you describe a little bit how the CRT dealt with
that issue?

MR. PEDIGO: Yes, thank you. When the CRT team was formed, there are four
districts represented on that; Harris County, Bear Metro which is in San
Antonio, Tarrant County in the Fort Worth area, and Denco which is the
Denton County area that I do.

We came together. We thought we were dealing primarily with those issues
because we knew that there was never enough money to go around to pay
those costs that we were seeing coming in. We knew that when the fee was
established in Texas a few years ago the 50 cent was not a fee supported
by any documentation. It was an arbitrary number assigned to start
collecting.

We knew that there was not enough funds to pay for that. That\'s the
reason for our negotiations. We have worked with all of the carriers on
those. Basically it\'s the same approach that we did with SBC. How much
money is it for all of your customers in Texas and all the 911 entities?
Tell us how much it is present value. We can either pay for it now. We
can borrow money on our own or work out an arrangement with you to do
that for whatever is the best.

But each one of the entities that we\'ve been able to reach an agreement
with is using that same model to break up that present value based on
the funding model so that each customer is actually paying the same
amount of money. It\'s very equitable across the state. Did that answer
your question?

MS. HOGAN: Yes. I think the important thing is that by coming together
and working as a group and saying this is the money that\'s available
for cost recovery. We understand that we owe the wireless carriers
something. There are some who would say we don\'t owe them anything. The
FCC is requiring them to do this. If we don\'t have cost recovery, we
just don\'t have it.

But the 24 districts all agreed that yes we did in fact owe cost
recovery to the wireless carriers and we had to find a way to make the
dollars go as far as possible. By coming together and negotiating with
each of the carriers and coming up with a reasonable cost and then
taking that cost across those 22 districts that were participating,
based on population, we were able to come to an arrangement that made it
possible not only for the large districts to implement Phase II but for
the smallest districts to implement Phase II. Our goal was to make Phase
II available to everybody.

COMMISSIONER COPPS: Questions from around the table or comments.
Audience?

MS. BENNET: I just had a point of clarification from something that you
said, Mike. When you were first negotiating with SBC - and maybe this
got worked out later - I heard something that SBC needed to recover
their costs in a return on your investment. I guess I\'m wondering what
kind of return on investment are people looking for. This seems like
something everybody should be putting in and not trying to make money
off of. Maybe I\'m being naive.

MR. PEDIGO: I\'m not sure that I would want to share what we came up
with on that. They are not in a business to give away these services.
They recovered their costs. We thought that there ought to be
reasonable, and reasonable under today\'s business conditions. Maybe Tom
might want to address that from SBC\'s perspective.

MR. LATINO: Yes, good afternoon. I won\'t throw out a specific number,
but any business is in business to make a return on its investment or
else it won\'t be in business or it will go to bankruptcy court and come
out debt-free \--

(Laughter.)

MR. LATINO: \-- and then further lower prices. But having said that, we
clearly believe that there\'s an obligation on our part as an ILEC to
ensure that we are priced at the appropriate point where we are not
making undue financial demands upon the public safety community. At the
same time, we will raise up the fact that, as Ford Motor Company sells
Crown Victorias in uniforms to public safety agencies across this
nation, they also in fact do make a return on investment as well.

COMMISSIONER COPPS: Let me ask Tom Latino representing one of the ILECs
a question. From your perspective, what sort of information or dialogue
do you need to have from the PSAPs in order to make this as smooth as
possible process as it can be?

MR. LATINO: It\'s been said several times today what we need. I think
it\'s what we need to contribute as well. Leadership. As we all sit in
this room stewards of the 911 public safety infrastructure, we can say
to ourselves that\'s a bad idea, that\'s not going to work or we can put
aside some personal agendas, embrace leadership, and realize, as John
Melcher, said we have to make it happen and if we don\'t make it happen
no one else will.

COMMISSIONER COPPS: Let me ask Tom a question. Generally speaking, I
know there\'s a good bit of controversy about the transparency of LEC
charges for upgrades and other interconnection problems that are out
there. Is there sufficient transparency in the LEC charges to judge when
they are being fairly passed through?

COMMISSIONER DUNLEAVY: I think that there is. The fact of the matter is
that the charges are going to reflect what it takes to build a system
and what it takes to provide the service and the quality of service. My
colleagues here make a good point when they say part and parcel of what
goes into those cost factors is a reasonable and fair return on
investment for the investors whom we are asking to pay to provide these
services. If we don\'t provide a possibility of the potential for a
return on investment, we\'re not going to get any money to build these
things. So it\'s a vicious cycle.

COMMISSIONER COPPS: A quick comment before we have to wrap up.

MR. FORSHEE: I just think you mentioned that you were able to look at
the cost studies. So I assume that this committee or group that you
formed were privy through some agreement with SBC to go over what made
up the cost of the tariff. Is that true?

MR. PEDIGO: Yes. We intervened in the find at the PUC and through that
and through non-disclosure agreements we were able to look at and view
and study their filing and all of the support and documentation.

MR. FORSHEE: Thanks.

COMMISSIONER COPPS: In closing, I just want to thank everybody again for
being here. It\'s impressive to see this kind of diversity. With all of
the stakeholders gathered here, we were all probably part of the
creation of the problem. That includes your favorite federal regulatory
agency. We all need to be part of the solution to the problem.

I gather what I\'m hearing is that the consensus is we\'re making some
real progress. I hope that\'s so. I hope we don\'t become too complacent
about that because we still have a long way to go. This remains an
urgent national priority until such time as it is up and running and
effective and saving the maximum amount of lives that it can. But I
congratulate you all.

I can\'t urge you strongly enough to keep working together, pulling
together, and identifying these problems. That\'s good for this E911
problem. I hope it also sets a good precedent for how our
telecommunications industry should be addressing problems all across the
range of its larger issues, by sitting down and talking together and
trying to reason together.

With that, our next and final panel of the afternoon is going to focus
on rural issues. It will be moderated by my friend and former colleague
here, Dale Hatfield. I\'m happy to turn the microphone over to him. I
thank you all for your attention. Thanks a lot.

(Applause.)

MR. HATFIELD: Okay. This is the session as Commissioner Copps indicated
on rural deployment issues. Having bought very recently a new house in a
very rural area of New Mexico suddenly has focused my attention on the
rural deployment issues. Of course, we all know that rural carriers face
some unique difficulties in implementing wireless E911 including both
technical and economic issues. I identified some of those in my report.

For example, rural carriers are often smaller, of course, and have less
dense subscriber bases and therefore have less ability to spread the
costs of implementing wireless 911 over its many customers or
subscribers. They also I understand tend to have a lower proportion of
heavy users than do some of the larger urban systems.

I\'ve also heard, of course, that they have more difficulty because
their purchasing power is smaller. They have a little bit more
difficulty in dealing with the equipment manufacturers. Less bargaining
power I guess is the way you would say it.

It\'s unfortunate in some ways, of course, having to rely on analog
equipment and TDMA air interfaces for which there\'s currently no
handset-based solutions as far as I know. You say logically that means
you are looking network-based solutions, but they tend to be a little
bit more problematic in rural areas because the tower sites may not be
located properly.

I mentioned before sometimes coverage holes or on the string of pearls
problem where you have a highway that makes it difficult to do.
Triangulation also is a problem as well. These are some of the things I
talked about in the report. And of course, having limiting resources. We
talked about here how important the coordination is among the different
groups. It stands to reason for your smaller companies. They probably
have a little bit less resources in turn to be able to carry out that
coordination.

Then something that was dear to my heart that I hadn\'t thought about
until I was given the job of doing the report is this averaging problem.
If you are a big carrier and you have some good areas and you have some
bad areas, you can average them together. If you are a small rural
carrier, you might be stuck in an area where you can\'t average your
accuracy over some of the other areas.

Anyway, these are some of the issues. The Commission, as most of you
know, has recognized some of these special problems that the rural
carriers face and has extended the deadlines at least for the Tier III
carriers. With that, I\'m going to get out of the way here and introduce
as our first speaker Evelyn Bailey.

She appeared on our first panel. She\'s from Vermont with the Emergency
Services Board. She spoke this morning as chairperson of the U.S.
Department of Transportation\'s Wireless E911 Steering Council. This
afternoon she\'s going to be speaking to us from the state of Vermont.
Evelyn, please.

MS. BAILEY: Thank you very much. It\'s nice to see all of you again and
you are still awake after lunch. I\'d like to give you a little bit of a
flavor of Vermont. It\'s more than just pretty trees in the fall and
nice mountains. It\'s a little gem of a state. Our wireless enhanced 911
implementation was a little gem of an implementation as well.

Hopefully there are some lessons to be learned and for those that
haven\'t gone down the path yet, perhaps some things to consider doing
that you might not have considered doing. We have six wireless carriers
providing service in Vermont. Three of them actually started doing
business in Vermont within the last year and a half. They are T-Mobile,
Nextel Partners, Sprint PCS, Verizon Wireless, United States Cellular,
and RCC.

I have to say although the point was well made that the carriers with a
national footprint can average their costs a little bit differently than
the rural carriers can, in a place like Vermont, in some respects, every
carrier that does business in a state like Vermont is a rural carrier
and has some of the same challenges and issues to face. All of our
carriers have implemented Phase I and have done for quite some time now.

T-Mobile, Nextel Partners, and Verizon Wireless have completely
implemented Phase II. RCC has implemented Phase II in the greater
Burlington area. We have Sprint PCS in the process of testing with a
technical issue that came up. I\'m going to talk a little bit about that
later and how we worked together to handle that.

United States Cellular has to completely overlay its TDMA system with
something else in order to make a handset solution work. So they are
working very hard. They have been in close communication with me. I\'ve
been very pleased with the process.

So Vermont. It\'s a rural state. We have a population of 609 thousand
souls. It\'s probably smaller than a lot of your counties. The most
urban town is the city of Burlington. That has a population of 40,000
people. That most urban county has a population of only 147,000. No
matter how you slice it, even at our most urban area, Vermont is rural.
And it\'s 9,000 square miles.

This is how we pay for enhanced 911. We\'re funded by a state universal
service fund. Wireless and wireline carriers pay into that fund at
exactly the same rate. The Vermont universal service fund doesn\'t just
pay for enhanced 911 however. It also pays for lifeline and
telecommunications relay service. The rate for the universal service
charge is set annually by our Public Utilities Commission or Public
Service Board based on the three program\'s funding needs.

So my budget, whatever the legislature tells me I can spend, that goes
into the mix. What the lifeline program needs goes into the mix. What
the telecommunications relay services needs goes into the mix. The rate
is set. All I get is what the legislature appropriates for me every
fiscal year.

That\'s actually a very streamlined process for paying for enhanced 911.
I have to budget for it. I have to make a request. I get the money and
that\'s how it works. I don\'t have a surplus and I don\'t have a
deficit. I just have my budget and I spend it every year.

There are several things that have gone into the Vermont success story.
The first is the way our legislation was set up. In 1994, the Vermont
legislature passed enhanced 911 enabling legislation and established the
Enhanced 911 Board as the single governmental agency responsible for
state-wide enhanced 911, not just wireline enhanced 911 but wireless
enhanced 911 as well.

We were given responsibility for making enhanced 911 happen. Along with
that, we were also given broad powers and authority. That\'s key. You
can have responsibility without authority. You can have authority
without responsibility. If you don\'t have them together, you don\'t get
a lot done. So we have both.

It\'s safe to say that in many states that are members of the National
Association of State 911 Administrators there are varying levels of
responsibility and authority. The ratio between authority and
responsibility determines their ability to be successful really. They
are both necessary for effective state-wide leadership.

The second thing we have going for us is vision and leadership. We have
heard that discussed many times today. The Enhanced 911 Board provided
strong leadership. I feel very fortunate to work for this board who
basically gave me everything that I wanted and everything that I needed
to do the job that I was given to do.

With that kind of leadership, we were able to set the pace for other
stakeholders and obtain their committment. We ensured that
communications were consistent and reliable. We held ourselves
accountable as well as the other stakeholders. We were tough when we
needed to be, but we were also willing to be responsive to carrier
needs, to work with them as a team, and to be flexible when a carrier
encountered technical issues that needed time to resolve.

As I mentioned earlier, one of our carriers is struggling with some
technical issues. They need some time to resolve it. They have a plan.
They have a timeline. We are working together. That is just fine with
me. The result is that the job got done where it\'s been done and is in
the process of getting done very efficiently and very effectively.

We also had support and committment from all of the stakeholders. I
can\'t thank Verizon, our LEC, enough for how proactive they have been.
They took the approach with their system upgrades that they would be
proactive. They knew that we were expecting them to be ready when we
were, so any changes that they needed to make to their ALI database they
made well in advance.

They have been a fully involved member of the Vermont team from the date
of the first report and order. As a matter of fact, it was within weeks
of that first report and order that we sent letters to all of the
wireless carriers in the state of Vermont at the time to say okay folks
let\'s get together and let\'s make this happen. So Verizon rolled all
of their upgrades into their routine schedule, and they finished their
work nearly two years ago. They have been ready in the state of Vermont.

Another thing that an approach like ours has to its advantage is the
economy of scale. In Vermont, enhanced 911 calling service is provided
via a uniform state-wide network provisioned and maintained by the
board. This state-wide network approach guaranteed that there would be
economies of scale in terms of network design and cost. A state-wide
network design is also operationally efficient. So a single state-wide
system meant that my board could maintain fiscal control and
accountability.

Then we made three technology choices before we needed to make them or
perhaps when we needed to make them that made the process so much
easier. Technology choice number one: we established the first
state-wide system in the nation with multiple PSAPs to use SS7 and ISDN.

We built it that way before the forthcoming order on 94-102. We knew it
was coming. We knew that this technology choice would position us well
and that upgrades would be minimal. As a result, the only upgrades we
needed to make were to our CPE, and that was limited to a simple
software release. That work was completed in the summer 2001.

Our second technology choice was our first state-wide use of GIS and GPS
to map all of the roads and structures for E911 addressing. Like a lot
of rural places, we didn\'t have street addresses in most of the state.
We had rural route and box numbers.

We felt, also in anticipation of 94-102, that if we used these
technologies to help all of the towns get street addressing we would
have for the same price a database that we could use for wireless
enhanced 911 without spending anything more for it. We installed our map
display in all of our PSAPs in the summer 2002, well in advance of our
first Phase II implementations which occurred at the end of last year.

Technology choice number three: we linked all of our PSAPs in a
state-wide wide area network. As a result, we can view the ALI display
and the map display for incoming calls at any PSAP in the system - and
there are nine of them - in real time.

For wireless implementation what that means is that with a simple
conference bridge my staff can coordinate implementation activities with
the other stakeholders, provide immediate feedback about what\'s
appearing on the ALI screen to the folks involved in the testing in the
field from the wireless carriers and their third party database
providers, and give them immediate feedback. There\'s no need for these
folks to have to interface with the PSAPs at all. This has streamlined
the process.

What I would like to say is that there\'s always room for improvement. I
want to conclude with just a couple of thoughts. We did a lot right. We
learned by the seat of our pants. If we had to do it over again, boy
would it be even better than it was already. Communication is critical.
I have to cut all of us a little slack. We all were learning.
Communications always could have been better between the carrier,
between the LEC, between us, between the third party database provider.
Communications haven\'t always been as organized, consistent, or timely
as they could have been. Sometimes some carriers are more organized than
others and clearly had project management experience when others did
not. One of the things that I have offered to the clearinghouse for the
U.S. DOT project is our Vermont enhanced 911 project plan so that other
people can use it as a model; our roles and responsibilities, timelines,
escalation procedures, all of that.

In conclusion, going forward, there needs to continue to be coordination
between carriers and third party database providers and us to maintain
synchronization of the wireless databases when translations and other
changes are made to towers or to any part of the wireless
infrastructure. The LECs have it down pat. When you make a change to the
ALI database, you make a change to the selective router.

On the wireless side, that lesson may still need to be learned.
Hopefully with a system like ours being able to provide immediate
feedback that we can help that so that those of you further on down the
line are going to have a much smoother transition to wireless enhanced
911.

(Applause.)

MR. HATFIELD: Thank you very much, Evelyn. Our second speaker is Beth
Kohler of the Rural Cellular Corporation, a Tier II carrier, serving
rural areas, obviously from the name.

MS. KOHLER: Thank you. I really see my role here today as two. Probably
the most important role is to vouch for everything that Evelyn said in
Vermont. We\'ve been working very closely. Vermont is the first state
where we have deployed Phase II. I also am here to highlight the unique
challenges that carriers that serve predominantly rural communities
face.

I want to thank Mr. Hatfield for so eloquently describing those
challenges in his report. I also want to thank the Commission for
convening this panel and giving us recognition to some of these unique
challenges. In Vermont, we are the only carrier at the moment that
serves the entire state of Vermont. It is our biggest market.

Rural Cellular is in 14 states, but we serve almost exclusively RSAs. We
have two MSAs. One of them is Burlington, Vermont where we are Phase II.
A lot went really well in Vermont. Evelyn has covered that well. From a
carrier perspective, we think coordination by the State E911 Board was
critical to the success. Evelyn and her board and staff are well-trained
and they have sufficient resources that really enabled the
implementation.

All the PSAPs were ready prior to our implementation. The ILEC had their
systems fully upgraded. It just went really well for us there. Vermont
is important though as a state to really highlight the unique challenges
because for everything that went right - we are now faced with a
situation where we will fully upgrade our TDMA network with a
network-based solution and not achieve the FCC\'s accuracy requirements.
We can reach the first benchmark, the first 50 percent, but we cannot
reach the 100 percent threshold.

There\'s a number of reasons for that. Before, I do want to just point
out a few of the challenges that we faced even in a smooth
implementation in Vermont. For my company, this was a huge undertaking
both financially and from a human resource standpoint. We quickly
discovered that our network-based solution could achieve higher accuracy
if we could rely on some additional AOA, angle of arrival, antennas.
These are very large panel antennas that require additional coaxial
cable.

These are installations that we could not put in even one of our cell
sites in Vermont. We predominantly lease cell sites. We\'ve been very
creative because of zoning restrictions in minimizing the size of our
cell sites. Very early on, we ruled out the ability to increase accuracy
relying on that type of technology. Right now, what we are doing
throughout the state is deploying the TDOA only.

As Dale so eloquently said, Vermont really suffers from the string of
pearls. We built our network to cover where the people are and where the
people want to use our service. That is in the highways in Vermont, and
that just means it\'s paved for Vermont. Again, those are some of the
challenges. Those challenges are typical in all of the 14 states that we
serve. It\'s highlighted a little bit to the extreme in Vermont because
of some of the land use regulations.

Rural carrier concerns as we move forward. We originally elected a
handset solution like most rural carriers who relied on a TDMA network.
It became clear that was not a viable solution because the handsets were
not going to be produced. We moved to a network-based solution. We now
face the fact that very few of our cell sites can triangulate.

We cannot take advantage of large area averaging. Our footprints are
relatively small in each of the 14 states that we serve. We are
contemplating conversions to CDMA where it makes sense. It\'s very
aggressive for a company my size to be able to affect a conversion and
deploy handsets in a manner which would meet the FCC\'s requirements.

I wanted to stress again the capital constraints and just how onerous
the financial investment is for us. Vermont again tees this up nicely.
We expect to spend about \$15 million in deploying the TDOA equipment in
our network. We estimate that would be about 30 new cell sites that we
could otherwise build in Vermont. I don\'t know how many of you have
visited my fair state, but it could definitely benefit from those
additional cell sites.

There are still many areas in our state where you cannot get a reliable
signal at all let alone worry about whether you are going to be able to
make an E911 call with location information associated with the call.
That balance is a struggle. We\'re not sure where the appropriate
balance is from a financial resources standpoint.

I really want to end with some of the recommendations that we would like
the FCC to consider. A relaxation of the accuracy standards in rural
service areas regardless of whether you are a Tier II or a Tier III
carrier or even for that matter a Tier I carrier. I have the fortune of
working for a company that is in 14 states.

It\'s unfortunate that those states are not contiguous. In fact,
there\'s thousands of miles between our regions. So we look very much
like a Tier III carrier even though when you add up all of our customers
we met the threshold of a Tier II carrier.

We would like the FCC to consider providing TDMA carriers like myself
with some additional time to try to migrate our networks to a technology
that can support GPS handsets. If there\'s any handset members out
there, we would love if you would entertain a GPS handset for TDMA or
GSM networks.

Finally - and this again highlights the success we see in Vermont - to
really encourage states to create government organizations that can act
as a coordinating body in the rollout of wireless E911 services. That is
probably the most important thing that Vermont did right. Thank you.

(Applause.)

MR. HATFIELD: Thank you very much, Beth. The third and final speaker is
Carri Bennet who is with the Rural Telecommunication Group which
represents some rural Tier III carriers.

MS. BENNET: We\'re actually an advocacy group, not a corporation. I just
want to clarify that. Before I start, I just returned from Italy so I
have to say to everybody \"buon giorno.\" I only learned a few words in
Italian and that was one of them.

Dale led off with talking a little bit about the rural part of his
report. He identified some issues for us. Unfortunately, Dale, you
didn\'t identify a solution. That\'s what I want to talk to you a little
bit about. By way of background, may of the members of the Rural
Telecommunications Group have deployed Phase I E911 as well are in the
process of deploying Phase II E911.

What I really want to focus on today though is the Phase II E911
problems that we anticipate we\'re going to be facing. It\'s covered
somewhat in Dale\'s report. Again, the solution is not in the report.
There was some delay that the Commission allowed us to try to get it
together some more. Beth identified the real problem is the accuracy
requirements.

Since we haven\'t actually gone over the numbers on the accuracy
requirements, I\'ll do that as well. The FCC requires wireless
telecommunications providers to implement E911 in their service areas.
Specifically for Phase II emergency 911, these carriers must locate a
wireless caller making an emergency call within approximately 300 meters
for a network-based solution and within 150 meters for a handset-based
solution 95 percent of the time. Much more accurate standards are
necessary 67 percent of the time.

Let\'s talk about some myths and realities in rural America. Myth number
one: rural carriers are dragging their feet on implementing E911.
Reality number one: E911 capabilities for wireless services are of
paramount importance for rural carriers and their customers.

The ability to locate a wireless caller should be available to all
citizens of the country, both urban and rural. Even with their limited
resources and smaller customer bases, rural carriers are currently
implementing E911 to the best of their ability. However, E911 deployment
obstacles are greater in rural areas.

The state of current wireless location technology depends upon the
ability to triangulate the location of a transmitted signal from various
receiving sites. In dense urban and suburban areas, wireless carriers
operate numerous cell sites to meet their service demands. The density
of cell sites most times provides a sufficient number of triangulation
points to locate the handset within the prescribed standards.

However, in rural areas, there are not always enough cell sites to
service triangulation points, i.e., the string of pearls as Beth
mentioned. It makes it difficult or impossible to achieve the FCC\'s
required level of accuracy.

Fortunately the time it takes an emergency responder to locate a victim
and transport for treatment will not be significantly increased in a
rural area if the E911 location information is for example within 500
meters instead of the required 100 meters because rural areas are
generally open, without crowded streets and giant office or apartment
building complexes. Unfortunately, right now the FCC doesn\'t recognize
that in its accuracy requirements.

Myth number two: E911 technology is affordable to implement and going
down in price. Reality number two - and again, Dale, you beat me to the
punch because you already said we don\'t have the buying power that the
big carriers have. While the large nation-wide carriers have helped
create the economies of scale that drive equipment costs down, FCC
mandated demand keeps prices higher than they should be. Further, rural
markets are more costly to serve since rural carriers do not have
sizeable customer bases throughout which they can spread their costs of
E911 deployment.

Myth number three: E911 location accuracy requirements are the same for
urban and rural carriers. Reality number three: while the location
accuracy standard is the same, it must be remembered that bigger
carriers get to average the standard throughout their respective service
territories. Accuracy requirements are stated in terms of the percentage
of calls which must locate a caller to within the specified distance.

On a nation-wide basis the vast majority of 911 calls are placed in
urban areas. Thus large carriers with licensed service areas that
include major metropolitan areas as well as rural areas can meet the
requisite accuracy requirements by relying on the fact that 95 percent
of their E911 calls are likely to be placed within the urban areas where
they have sufficient cell site density to achieve the requisite level of
accuracy.

For such large carriers, Phase II accuracy levels may not be met in the
rural areas that they serve. In sharp contrast, rural carriers must meet
the full accuracy requirements based upon rural only E911 calls. In
other words, rural carriers must effectively meet a more exacting
accuracy standard due to their inability to average their performance
over urban areas as carriers serving both urban and rural areas can do.

Myth number four: rural only carriers who have deployed a network-based
solution using TDOA will be incompliance with the FCC\'s rules. Beth
already recognized the fact that they are trying to do this. They are
going to have to use antennas to meet the requirements, and they are
still not going to be able to do it.

The vendors who sell TDOA equipment are using weighted statistical
probability to predict where emergency calls are likely to be made. I
heard ten million calls in New York. In a rural area, let\'s say we had
19 calls made during the course of a year in a very remote area. It
would only take one call to occur outside of the probability predicted
by the model to put the carrier in violation of the rule.

Using weighted statistical probability to demonstrate potential
compliance does not keep a carrier who falls outside of the accuracy
requirement from being fined for failure to comply. Also, it\'s very
likely that a rural carrier could be in compliance one day and out of
compliance the next day depending on the location and volume of calls.

So what would be the equitable solution? Beth touched on it. What we are
thinking is that the FCC should forebear from enforcing the E911
accuracy rules in rural areas where the rural carrier has deployed E911
technology using its existing antenna systems at every existing cell
site in or around the service area where a public safety entity has
requested E911 service.

Rural carriers are not seeking to delay deployment of E911. Rather, they
are seeking to accelerate the deployment of meaningful enhanced 911
service to rural Americans without being hindered by the prohibitive
expense of attempting to meet unnecessarily stringent accuracy and
reliability standards for the environments in which they operate.
Otherwise, we fear that if rural carriers are required to achieve the
same accuracy standards as carriers serving urban areas the costs will
force many to limit their coverage area to more populated areas in order
to ensure that their regulatory obligations are met thereby denying E911
service to the most remote and least populated portions of their service
territory. There can be no dispute that any 911 service and certainly
the E911 service that would be provided under this proposed solution is
better than no service at all. Thank you for your time.

(Applause.)

MR. HATFIELD: Thank you very much, Carri. I wondered among the panelists
if there was any reaction to what each of you said among yourselves. I
was particularly curious more from a users standpoint what the
relaxation on the accuracy would mean. Would you feel comfortable with
that?

MS. BAILEY: I would have to speak on behalf of the Vermont call takers
and say that it would be a challenge for them. What they need is
consistency. It\'s already difficult enough to achieve that unless
somehow we were able to flag that for them in such a way that they were
aware that they would need to fall back on their customary pre-wireless
enhanced 911 call handling skills to get at where a caller was coming
from. This would be very difficult for a 911 call taker.

MR. HATFIELD: Let me go to our assembled group here up front. Are there
any questions or comments or additional thoughts, especially focusing on
the solution? I got that criticism. It\'s valid. Okay Hatfield, you teed
up a lot of the problems or at least you reflected the fact that you
understood most of them but you didn\'t come forward with any solutions.
I\'m sensitive to that. Any comments from the roundtable?

MR. JONES: Just a question on the comment regarding relaxation of
accuracy standards. I\'m hearing some conflicting statements. On the
first point, the point is made that people in rural America deserve the
same 911 service as urban America. Then just a minute later we hear a
call for the relaxation in the standard. How do you jive those
incongruent statement?

MS. BENNET: I jive it by giving you an example. If we were to place a
911 call here today in this building and it has to be within 100 meters
for the accuracy requirement to be met, it would still be very difficult
to find exactly where that person is. Say nobody is here. It\'s late at
night.

On a rural highway, finding someone within 500 meters might be a little
easier because there you are. There\'s nothing around. There\'s no tall
building to go searching in. I don\'t think the key here is what the
accuracy level is. The key is speed of finding the person and knowing
about where that person is.

It sounds like I\'m saying a relaxing of the accuracy, but accuracy
isn\'t as significantly important in a rural area as it is in an urban
area. I think you will find that it will take you longer to search this
building to find a person than it may to find someone on a highway in a
very remote area.

MR. HATFIELD: Any other comments?

MR. ALTSCHUL: This morning we heard and we just heard on this panel that
siting and permitting continues to be an issue for the roll-out of these
technologies. I\'m wondering if anyone from the states is willing to
comment on the availability of state support to deal with really some
local zoning and siting issues that are more within their jurisdiction
than the Commission\'s.

MR. HATFIELD: We have environmental values clashing with public safety
values. Don\'t we?

MR. ALTSCHUL: Right.

MR. HATFIELD: Any comments?

MS. BAILEY: Beth and I have had a conversation about this. This is a
huge issue for RCC in the state of Vermont and I suspect for some of the
other carriers as well. The environmental law is extraordinarily
rigorous. The permit process is onerous and lengthy.

What I have done is to come to a meeting with the environmental
commission people and the carrier and say this is the situation. They
can\'t meet a federal mandate because some other things are getting in
the way. What can we do to solve this problem and see if there is a way
around it?

There\'s only just so much that they can do. There is the possibility,
as Beth mentioned, of adding some equipment. But in some instances it\'s
a co-located tower. They don\'t have permission to do that. The tower is
just physically not capable of handling any additional weight.

There are many things that need to be addressed and can appropriately be
addressed in the environmental arena. I think it\'s important. I have
offered myself to help with that. I am absolutely certain that every
state director in my position would do likewise.

MR. HATFIELD: Any other comment?

MS. KOHLER: I do think I plan on taking Evelyn up on her offer. Vermont
is particularly sensitive to that issue. We will need to go before the
commission and seek some kind of general permission to make some
modifications to our network. But the bigger issue that we struggle with
every day really comes down to is it more important to improve the
quality of our network to support just basic calls versus spending the
money on enhancing 911 when there still are so many places in our rural
markets that don\'t have coverage.

MR. HATFIELD: What percentage of coverage do you have in Vermont now?
You may have said that. I\'ve forgotten. What percentage, if you look at
cellular coverage over the whole state geographically?

MS. BAILEY: Well, I\'ve never sliced it that way. Partly because of the
terrain, there are significant pockets where there is no coverage in the
state of Vermont. It\'s just not possible without a lot more towers.

MS. BENNET: Dale, if I can just add, we\'ve looked at the AOA solution
angle. Even if we put that in, there are instances in these remote rural
areas where you can just keep spending money and doing it and doing it
and it\'s not going to hit that accuracy level.

MR. HATFIELD: The difficulty if you relaxed it entirely is what
incentive would there be to improve.

MS. BENNET: Well, I don\'t know if you caught it in the proposal that I
set forth but to deploy in a network situation TDOA at every cell site
to it that would assist the PSAP that made the request - and it maybe
someplace outside of the county whatever will assist the cell sites in
the county - on the handset-based solution, deploying the latest
greatest technology that\'s available now which isn\'t always going to
be accurate either.

MR. HATFIELD: I had a comment out here.

MR. HAYNES: Dale, our state board would be opposed to any lessening of
the standard just on a case-to-case basis. We ran into probably the same
problems. Well, we had a trial with Verizon Wireless, and we had a trial
with Advantage Cooperative, a Tier III carrier.

One reason we like to think that we were one of the leaders in the
nation is we did this in some of the most challenging terrain east of
the Mississippi River in the Cumberland Plateau Region, not Appalachian
Mountains but the Cumberland Plateau Region. The reason that\'s so
unique is that you can\'t even use a GPS solution in some of that area
because you can get the satellites but because of the terrain you will
get so many false echoes from what the engineers tell me that your
reading may be thousands of meters off so to speak. It just throws your
apparatus in a tail spin.

In working with our cooperative, we had to invest in the massive angle
of arrival antennas. We had to shore up for wind load stress. Tower
structure was different. Cable angles and everything for wind load
stress and everything else. But my bottom line is if they could do it
there I would argue it could be done just about anywhere.

The amazing thing was their cost. I would say that for the Tier III
carriers that are deploying in the state of Tennessee. Their costs are
well in line with their Tier I competitors in our state. I understand it
is a hardship. I\'m a former deputy administrator of a rural utility
service. I know what rural costs are to utilities.

But in terms of getting your hands on the money, it is about providing
equitable service to rural Americans. They should not be put at a
disadvantage. There\'s a building just a block up the street here, the
Ag Department. We have the former RUS Administrator standing up right
over here. The two of us a year ago got language in the Farm Bill
specifically on 911 for cases like this.

I respect the challenges they have because God knows that\'s where the
rest of my hair went. We pulled it out in trying to get within the FCC
standard. But it can be done and it can be done in the most challenging
terrain. Believe it or not, it can be done at Wal-Mart prices.

MR. HATFIELD: How about the environmental issues?

MR. HAYNES: Nobody wants it in their backyard. I have a 500 acre farm in
Tennessee that I still maintain. I don\'t want one near it. I don\'t
want to see the light on top of it. But God knows, I have an expensive
cell phone bill every month. So it\'s that classic \"not in my
backyard.\"

Please, if there\'s one thing that the state of Tennessee can ask of the
Commission today, do not give any more blanket waivers. If it saves one
single life, it has been worth all the headache that it cost everybody
in this room and all the billable hours that people are going to make
off of it. This is a life saving service. That\'s the discussion we need
to have.

If there was anybody that ever needed it more, it\'s the people in rural
America; the farmers, the people that are challenged by geography and
distance from the cities. That\'s one reason why the Tennessee Farm
Bureau led the charge at the American Farm Bureau convention this year
calling on the advancement of 911 and E911 services across the country.
Our state farm bureau even led the efforts to pass policy to oppose
states raiding the state funds for that very purpose.

So this is a rural quality of life issue. I would challenge that those
people that are providing service in those rural areas to put their
customers first. I respect the challenges that you have. They are there.
But we did it. If a bunch of country boys from Tennessee can do it,
anybody can do it.

MR. HATFIELD: We sure teed up the issue here. Haven\'t we? Is there a
question from the public?

MS. PARTYKA: I\'m Janice Partyka at TechnoCom. I have a real short
question. I understand the cost of infrastructure for the rural carriers
is pretty daunting. Among our carriers, we are seeing some carriers
starting to talk about sharing infrastructure. We\'re seeing talks about
\"I have room on my tower. You don\'t have a PDE. Maybe we can make a
swap here.\" I\'m wondering if that is a solution in some situations
that could perhaps eliminate some of the distress and the infrastructure
costs.

MS. BENNET: I would say to that where there are facilities and competing
carriers with the same type of technology and they can deploy and get
together, that would be great for them to work together. I would
encourage that. For my members, we\'re the only game in town in a lot of
these areas. There\'s nobody for us to share with.

I understand your situation in Tennessee. In fact, Advantage Cellular is
one of the members of RTG. I have worked with them on this project. We
have to get west of the Mississippi. We have all flown to California and
looked down from the plane to see what kind of challenges we face.
There\'s not a lot of stuff out there. If there\'s nothing to
triangulate from, there\'s nothing to triangulate from.

I understand your situation. But Tennessee had that situation. Montana,
Utah, other areas of the country have a different situation. That\'s the
thing that we have to keep in mind here. You cannot lump rural wireless
carriers into one boat. We just can\'t be. We\'re just too different.
I\'ve been to the E911 Caucus with this message. I\'ve been to the
eighth floor with this message.

The question that I get repeatedly asked is what level of accuracy can
you hit. I have to say I really don\'t know because it changes from
carrier to carrier and location to location depending on how these cell
sites were deployed. I agree with you - and we\'re working cooperatively
to do this - to make this a nation priority. But we would have to build
tons and tons of cell sites to be able to do the things that you all are
talking about doing and hitting the accuracy requirements that you want
to hit.

MR. HATFIELD: We need to wrap up. Chris, can you do it real quickly?

MR. MCLEAN: You bet. My name is Christopher McLean. I\'m with the
ComCARE Alliance. Thank you, Anthony, for the introduction. We served
together in the previous administration at the Rural Utilities Service.
There are a couple of resources available at your neighbors here, the
Department of Agriculture, that might be useful to both carriers and to
communities and PSAPs.

The new authority that Anthony mentioned and the Rural Extrication (PH)
Act provides loan authority to make loans to municipalities as well as
to carriers to improve 911 service. There is about to be rolled out some
announcements on grants that will provide broadband service to rural
areas that will include free service to public safety.

In a program called Community Facilities, there are grants available to
communities and non-profits to be able to upgrade emergency
communications facilities, among many other purposes, but that\'s one of
the purposes that is possible. So I would encourage rural communities
and rural carriers and rural public agencies to work closely with the
United States Department of Agriculture Rural Development Agencies to
see if there are ways to see if they can help you solve some the
problems.

MR. HATFIELD: Okay. We need to move on to our next panel. I want to
thank you all very much.

(Applause.)

MR. HATFIELD: Our next session is on consumer and carrier education with
Dane Snowden, the Chief of the Consumer and Government Affairs Bureau
and David Solomon, Chief of the Enforcement Bureau.

MR. SNOWDEN: Good afternoon. Thank you very much, Dale. I want to thank
everyone for sticking around and for participating in this coordination
initiative to address the important issue of wireless E911 deployment.

Last week, I had the opportunity of visiting a PSAP in Fairfax, Virginia
and saw first hand the role E911 plays in the daily lives of Americans
across this country. In addition, it was very evident to me that without
location information PSAPs aren\'t able to quickly and efficiently
deploy emergency services. As Dale has outlined in his report and this
morning, this is a very complex issue with many different stakeholders
at work, and of course all of you in this room are very aware of this
particular issue.

Today\'s efforts are an important step toward ensuring that the wireless
E911 is deployed expeditiously so that vital emergency services are
available to consumers. My role today as the Chief of Consumer and
Governmental Affairs Bureau is to talk about our outreach plans when we
look at consumers, outreach plans of public safety answer points and
their organizations, and also to government entities.

First, if you look at the issue of consumers - and this is of course
working with our colleagues in the wireless bureau - we all know it is
important to note that all stakeholders want to see E911 deployed
quickly. However, it is equally important for consumers to be aware of
the challenges that we all face in implementing wireless E911.

So it is our view that it is important that information is shared with
all the various key stakeholders. That is why we have developed several
fact sheets which outline the opportunities and the challenges this
issue particularly poses for all consumers. Of course, this information
is all available for you.

We have also developed a website that provides important consumer
information about 911 services. Of course, we have links to the
Mid-America Regional Council and CTIA. Our goal, as we develop all of
these outreach materials, is to make sure consumers have information at
their fingertips. If you have ideas or thoughts about what we need to
include or alter, please speak up and let us know because we want to
make sure it\'s effective for all stakeholders going forward.

When we look at the issue of state and local and public service
organization outreach, it\'s important that from our standpoint we find
innovative solutions to speed up the wireless 911 deployment. In our
outreach efforts, we seek to identify and coordinate with key
organizations representing state, local, and tribal organizations across
the country including, just to name a few, the National Governors
Association, the National Association of Regulatory and Utility
Commissioners or NARUC, U.S. Conference of Mayors, and the National
Congress of American Indians.

We also want to engage the points of contact identified by the governors
across the country. I\'m actually very proud of both the staff of my
bureau and of the wireless telecommunications bureau to report that we
have all 50 states accounted for in terms of having points of contact to
start debating or start having conversations on this important issue of
funding regarding this important issue. We also have U.S. territories
involved. We plan to do outreach in the Indian country to get points of
contact as well.

Our goal is to draw upon the experience of public safety organizations
to collaborate, to coordinate, and focus upon wireless E911 deployment
strategies. In doing so, we want to also coordinate with APCO, also the
National Association of State 911 Administrators, and NENA. That\'s what
we have been doing.

Looking forward, what we plan to do in conjunction with our colleagues
in the wireless bureau is that we do plan to hold an E911 summit with
the governors\' designees to share wireless E911 options and identify
solutions. We do plan to engage the FCC\'s Local and State Government
Advisory Committee to work on the development of state-by-state funding
and an implementation survey. We will continue to develop additional
training and outreach materials here at the Commission for consumers
across the country.

One of the things we have just launched as a nation-wide campaign last
week is the Telecommunications Services Priority program or TSP. The TSP
is a great program. It is the program that governs which
telecommunications lines are restored on a priority basis in the event
of a national crisis or an attack. Since the launch of this program last
Thursday, we have seen an increase of public service answering points
signing up for TSP to make sure they are part of this important program.

If you are a PSAP and are not familiar with this program, I encourage
you to pick up information at the back of the room and encourage you
equally to sign up for this very important program. This is a national
campaign that we have launched in conjunction with the National
Communications System to enroll more PSAPs across the country.

So we have a lot on our plate in terms of coordinating all of our
efforts with the various stakeholders and in terms of getting the
message out about what E911 is today and what we hope it will be
tomorrow. We look forward to working with each of you as various
stakeholders to make sure that we get this agenda moving forward.

I would like to take a personal note and applaud my colleague John
Muleta and his wonderful staff for putting this wonderful coordination
initiative on. I want to thank each of you for participating today. I
look forward to working with each of you as the days and months go on.
Thank you.

(Applause.)

MR. SOLOMON: Let me also thank John and all of you for coming here
today. As someone who is asked to speak today next to last in an all day
meeting, I came back here this afternoon wondering if anyone would be
left from this morning. The fact that so many of you are still here
really underscores the point that all of you and the Commission share a
common goal which is to try to work cooperatively and together to move
E911 forward.

Dane talked about how he\'s looking forward to working with all of you,
and all of you are looking forward to working with him. Probably most of
you aren\'t looking forward to working with me. Those that have worked
with me probably don\'t want to do it again.

(Laughter.)

MR. SOLOMON: If E911 works well and the sessions that have been started
today continue in the spirit of today, E911 should be implemented on
schedule, and then further enforcement actions shouldn\'t be necessary.
We have a couple of enforcement matters pending, and we\'re going to
clean those up. But our hope is that if everyone works cooperatively
together there will be compliance, consumers will benefit, and there
won\'t be a need for further enforcement action. If problems do arise,
we\'re here and ready to move into the area if need be.

What I want to do today is give you some brief advice about how to deal
with us in the Enforcement Bureau and the processes that are available
if problems do arise either from the perspective of a PSAP or a consumer
with problems with the wireless carriers or if a wireless carrier has a
problem with a wireline carrier about E911 development. There are
basically three options that you have in coming to deal with the
Enforcement Bureau.

One is mediation. One is a formal complaint. One is to try to get us to
start an investigation that might lead to a forfeiture or a consent
decree. In the mediation area, we have experienced mediators in our
Market Disputes Resolution Division that are available if you come to
them with a problem and you are looking for an informal solution. You
are not looking for either a legal proceeding or for us to take formal
enforcement action.

For example, if a PSAP has a concern that the wireless carrier isn\'t
responding correctly or the wireless carrier has a concern that a
wireline carrier isn\'t responding correctly, we can help bring you
together and help work out the problem informally. We have had so far
nine mediation requests in the E911 area. All of them have resulted in
successful settlements that haven\'t led to litigation.

If you are interested in taking advantage of our mediation program, you
can contact Radhika Karmarkar who is Deputy Chief of our Market Disputes
Resolution Division. Her phone number is 418-7330. If mediation doesn\'t
work and you want to bring a formal action at the FCC, you can file a
formal complaint with the Market Disputes Resolution Division.

If you are thinking of filing a formal complaint, I encourage you to
contact them first. We have all sorts of rules about what you have to
say in the complaint. We don\'t want to get people hung up and not
filing them procedurally correctly. So far we haven\'t had any formal
complaints in the E911 area. If we get them, it\'s basically like a law
suit. We adjudicate it. We would come to a formal decision deciding
based on the facts in the law whether the Defendant is responsible for
the problem. If the Defendant is held responsible, then there\'s a
potential opportunity for damages.

The third option is for us to start an investigation. It\'s basically a
discretionary action by us. We do it based on the information that we
get from a variety of sources. Obviously we get the carrier reports and
we look at those. Sometimes information is brought to us informally by
PSAPs or others raising certain concerns. Typically such investigations
would lead, as I mentioned, to a monetary forfeiture or a consent
decree. We\'ve had some of both.

If you have information that leads you to want us to begin an
investigation in the E911 area, the contact person for that is Kathy
Berthot of our Technical and Public Safety Division. That number is
418-1160. Basically what happens in one of these investigations is
typically we would begin with a letter of inquiry. We would ask you
essentially interrogatories or series of questions to try to get at the
facts. We would probably or may ask for some documents.

One thing I would mention is if you are the subject of one of those
investigations it\'s very important that you be very forthcoming in the
facts, give us the facts we ask for, be truthful. In the end, if you
start hiding stuff from us or fudging the facts, you are going to end up
in a lot worse trouble than just having E911 problems.

I can tell you we did in another area. We started a revocation
proceeding a couple of weeks ago where the basis for the revocation is
issues that someone may have lied to us in connection with a slamming
investigation and in connection with applying to discontinue service
with the Wireline Competition Bureau. So the lying gets you nowhere.

If you want us to start an investigation, it\'s important for you just
to be aware of what your role in the investigation is. If you want to be
a formal player in a formal enforcement action, you can file a formal
complaint. You\'ll be a party. You\'ll get copied with pleadings.
You\'ll be notified of everything that goes on.

But if you come to us and ask us to exercise our discretion, you are not
a party. We will decide based on the facts how strong the case is,
whether or not to go forward, and how to go forward. While you may be
able to find some information out about what\'s happening, you\'re not a
party in the same way. Sometimes people get frustrated that I came and
talked to somebody and that means I \"filed a complaint\" and I have a
right to know what\'s going on at every stage. That doesn\'t happen
under this option.

If you are the subject of one of these investigations, the typical
process if we find that there appears to be a violation is we would
issue a Notice of Apparent Liability and propose a forfeiture. If you
are interested in a consent decree, which would involve typically a
payment and a compliance program, then come and talk to us about it.
It\'s for you to come and talk to us and give us some sort of detailed
proposal that we can work with you on. We are open to such consent
decrees as is clear from the action we\'ve taken.

In conclusion, we\'ve taken strong enforcement action in this area.
We\'re big supporters of what\'s going on today and the Commission\'s
approach to everyone working together and trying to have this compliance
developed in a cooperative fashion. We hope that will be the result.
Thank you.

(Applause.)

MR. MULETA: Why don\'t we open it up for a few minutes and see if there
are any questions either from the table or from people sitting out in
the audience? There aren\'t. With that, I guess you guys are free to go.
Thank you very much. We\'ve come to the last part of today\'s meeting.
What I\'m going to do is in two parts.

The first thing I\'m going to do is show you the database that we\'re
building based on the quarterly reports that are being filed. For those
that might have come to the meeting late and weren\'t here for the
announcement of where the bathrooms are, that was my first job today.

I am actually John Muletta, Chief of the Wireless Bureau. What I\'m
going to talk about is first the database. The second thing is as part
of this coordination initiative I would like to summarize some of the
key findings that I took notes of the whole day and relay that to you.

First of all, again, I\'d like to give my thanks to the Chairman for his
leadership in initiating the coordination meeting and also the other
Commissioners for their great and willing participation in this and
taking an active leadership role. The second thing I would like to do
again is thank my staff and also the staff from the other bureaus, and
particularly Lauren Kravetz, Jennifer Tomchin, and Blaise Scinto from
the Policy Division, the Chief of the Policy Division who has done a
great job and can now go and have her baby now that this initiative is
over.

That said, I also want to thank John Chudovan and Steve Miller from the
data management group who have been very active in helping us with the
database which I\'m just going to get to. Finally, I also again want to
close this by thanking all of you who participated and sat through the
whole day. Your input has been tremendous and very useful and very
educational. That said, Steve, if you can take me to the database
please.

Actually if you can go to the cover page. I want to emphasize something
here. The key here is in this collaboration one of the key lessons that
I learned was that in order for us to move and advance the ball in E911
it\'s important that we have information and that we track it and update
it and be consistent about it. So what the Commission has been doing as
part of our process is we\'ve been collecting information based on the
quarterly filings of Phase I and Phase II deployment, status, and so on.

The goal here is again more efficient tracking and rapidly identifying
the trends that are taking place. It helps to have an informed dialogue.
The way we do it is with these quarterly filings. Additionally, what we
would like to do is provide it to the public, meaning all of the
interested parties so that you can accurately see the development.

One of the intentions that we have is - for example PSAPs operate on a
monthly regional basis and carriers operate on much larger geographic
areas and ILECs operate on a much narrower basis - so what we need to do
is match all of this data and make sense as to what\'s going on the
deployment. Then over time, we can use this information to provide
greater help to the carriers as they implement E911.

One of the key components that we\'re doing again is to have a universal
database in a sense. What we\'ve done is worked to identify the PSAPs
through NENA\'s PSAP Registry. So the data that we\'re collecting is
going to be tied into that PSAP Registry. Thanks to NENA for that.

What we\'ll do with this information is assign each PSAP a number so
that we will have universal association of the related data. Again, what
you will get is greater granularity in terms of geographic deployment.
Then we\'ll be able to help the whole community take the right action
based on this information.

What I\'d like to tell you is what we have today. There is a URL. It\'s
www.fcc.gov/911/enhanced that takes you to what we have today. There are
paper filings available in pdf format for the quarterly carrier data.
Any of the FCC actions or any other related information that we have
available can be found at this site. So again like ESIF and NENA and
APCO and all the other players, we do have these databases. I know some
of the states also have this type of information. We\'re trying to find
an easy access point for this.

What we\'re trying to move to - and this is the next set of discussion
for us - is moving this into an electronic format. What that will do is
it will give all of the players enough information that they can
manipulate to do their own analysis of what\'s going on. What the FCC
will also do is prepare a set of reports that we\'ll publish that will
relay some of the key information that we think is important to advance
the ball.

It\'s very difficult for me to point to this, but if you take a look at
the screen, what we have is essentially the kinds of reports that we\'ll
be able to generate. So what you\'ll see is a PSAP with a particular
unique identifier in the left hand column. Then it will be effectively
what counties are involved so that we\'ll be able to tell, even if it\'s
multi-jurisdictional, rollout. You\'ll be able to see what those are.
And you\'ll be able to identify multiple states, again, multiple
jurisdictions and how it interrelates.

Then moving further to the right, you will see the time period that
we\'re talking about in what has been deployed or not; Phase I, Phase
II, and in the future it might be a Phase III. What we want to
incorporate is where the state of the art is in terms of that particular
geography and that particular carrier or carriers. Then what we\'ll have
is a code for telling us why it\'s in the status it is. For example, you
could have a Phase I deployed but not Phase II. The issue could be
reason A, B, or Z. So that\'s what we\'re going to try to do.

The kind of reports that we\'ll be doing again will provide carrier
status, geographic granularity, deployment by PSAP, and the total
picture that we have by phase. Again, these are things that we\'re
considering. The key issue here, like we\'ve talked about today, is
uniformity in terms of the filing process.

One of the things that I wanted to do is explain to you that right now
we\'re getting paper filings. We thought about the logistics of bringing
in all of the paper filings and demonstrating to you how cumbersome that
is and how hard it is to get the data available. So one of the moves
that we are going to go to is to ask the carriers to file this
electronically so that we\'ll have uniform filing. It will be a lot
easier to manipulate and include into a database.

Steve, if you could maybe show them some of the examples on how we\'re
building this database. What you have here is effectively an ability to
load as the carrier by going to a website that we have your carrier\'s
name and then you\'ll be able to load the Excel spreadsheets that we\'re
going to ask for the carriers to implement by the next quarterly filing
which is in August, not the May one but August. Effectively the
uploading process is just attaching a file onto the webpage. It\'s in
Excel file format. We\'ll give you some of the success parameters.

Let\'s say you don\'t do it the right way. There\'s some missing
information. What effectively the carrier will get is a file that will
be sent back to them that says here is an exception reporting of the
things that are missing and the reasons why the filing was returned to
you. Again, all the things in red are things that were missing and that
we\'re sending back and asking you to fill that in.

This can be done from a desktop. It doesn\'t require somebody to shift
paper and then resubmit it or whatever. This is basically the printout
of an Excel spreadsheet. All you have to do is focus on the red. The
important thing is we\'re asking for certain information that has been
inconsistent or has lacked uniformity. We\'re asking for that
information to be consistently applied and brought in.

We\'re going to release a public notice in the very near future. We\'re
going to ask is for electronic filing of these documents that are now
submitted by paper. The target for doing this would be for the August
quarterly reporting. We think this is an easy capability, easy to do,
and will provide flexibility to the FCC in manipulating the data and
getting the results out to you faster. It will also help us by allowing,
for example, PSAPs who want to take a look at the information understand
where their carrier is in terms of deployment and access to some of this
information in a much easier fashion.

That said, I just want to open it up for any questions that you might
have on this process from the table or from the parameter. This is one
of the key issues Dale had identified, effectively building
clearinghouses and things like that to enable information exchange. Any
questions or comments? I\'m trying to beat my 4:00 p.m. deadline, so
I\'m talking fast.

MS. BAILEY: More a hopeful comment than a question. It would be great if
this information could somehow be linked to the DOT clearinghouse which
has a whole largely different type of information but complimentary. The
more closely we can bring those two together that would be very helpful
to folks so they have at least what looks like a one place to go for
everything they might need.

MR. MULETA: Okay. I think it would be easy for us to do that in a portal
format. The other thing we can also do is after this if you can give me
a contact name for whoever is administering the database I\'ll make sure
that our folks are in communication. Again, whether it\'s the ESIF or
Locate or SWAT and everything else, we would like to make sure this is a
coordinated effort.

This is something that we\'re already doing, but it\'s in paper format.
I would like to move it to something electronic and have the response be
a lot faster. We\'ll definitely work with you. Any other questions or
comments? No, okay.

That said, what I\'ll do now - and I\'ll do it as quickly as I can - is
I will try and summarize what I got out of it today. Hopefully this will
match and you\'ll be out in five minutes. How\'s that? All right. I was
taking notes. I think I was up to six pages. I\'m left-handed, and I
write really slow so this was very painful for me. I want to thank
Jennifer Tomchin for also helping me with this.

If we can go to the first page, let me point out what the key lessons
are. I\'ll start out with what the Chairman said. E911 is on a digital
migration. That\'s important for us to remember as we do things going
forward. We\'re moving from analog to digital. The tension that we have
between the wireline and wireless is wireless went from zero to digital
and wireline has a historical transition. We need to marry the two as
quickly as possible.

Two things that really came out for me. One is on the soft side. The
other one is on the really hard technical stuff and very related.
Leadership matters. Many of the points that were made here were that if
you don\'t have the leadership then it will fail. The other thing I
heard was long-term planning, long-term architectural thinking about the
issues, the evolution of this, the digital migration aspects of it have
to be considered, have to have a leadership level, has to be funded at
that level, and it\'s very important. So leadership matters and
architecture matters.

We heard a lot about the national collaborative efforts that are going
on. One of the most important things that I heard was the thread that
almost every one of the collaborative efforts had joint membership. John
is member of the group, as is Susan, as is Evelyn, and so on. So the
thread of people working collaboratively across the groups and within
the groups is very important.

This relates to the architectural issues as well. The evolutionary
aspects of E911, these groups, are going to become terribly important in
reducing the transaction costs and collective action problems that are
associated with the deployment of E911. A very important point that I
learned on a summary level is every region, state, local community needs
a single point of contact that can deal with the issues and that can
provide the leadership.

A key point that I heard here from Tim Berry, who has left already, but
it\'s very important for me to note that the integration of the policy
and the finances at the highest levels is critical. I note today there
is a summit of sorts between Governor Warner from the Commonwealth of
Virginia and Governor Erlich from Maryland and Mayor Anthony Williams of
D.C. One of the subjects that they are going to talk about is homeland
security public safety. As a specific item, I think that\'s great. They
need to figure out how to fund it.

On the wireless carrier implementation, one of the things that I drew
out of that was that again there needs to be an attempt to have a single
point of contact. It\'s important, especially when we are talking about
the network-based technologies that need to be deployed, to focus on
large geographic \-- to reduce implementation blockages and also manage
the cost side of the equation.

The third bullet point says \"central planning.\" I\'ll edit that. We
don\'t do central planning in this country. Anyway, the idea is central
coordination. Single points of contact are going to be terribly
important. Collaborative efforts. Again, sharing of information, sharing
of successes, participation in the SWAT initiative or any of those kinds
of things would be terribly important for rapid deployment.

On the PSAP funding and operation, this was probably one of the
liveliest exchanges that I saw. Again, this is where I see the
integration between policy and finances being closely aligned.
Leadership also plays a key role. The best thing on this one is don\'t
divert the funds, don\'t do things like that. The central point is about
leadership and understanding the importance of E911 to the benefit of
the public.

On the LEC issues, what I would like to do as we go to the next page is
there are taking lessons maybe from the legal bar on developing model
tariffs, model cost recovery systems, working on a joint basis, creating
collaborative efforts in that area is a way of reducing the transaction
costs and something that should be modeled in those states that haven\'t
already broached that approach. It helps legislators to say here\'s a
document on cost recovery or the Commissioners.

Here\'s how we would do it on a joint effort to model cost recovery by
getting ILECs and LECs and the wireless carriers and also the PUC folks
to work on a joint effort. That\'s the key lesson that I draw on that. I
ask the national groups again to help facilitate this by taking the
Texas model or the Indiana model and whatever and apply it to other
states.

On rural issues, I\'ll move down to the bottom. That will address the
high points on that discussion. Obviously rural areas because of the
geography consideration - be that in the population density issues -
raise financial hurdles on implementation of E911. There is a
counterpoint that Anthony Haynes from Tennessee made which is the
problems can actually be solved with a greater deal of collaboration and
a let\'s-fix-it-type of attitude. But still there are hurdles that need
to be recognized and addressed.

The related issue is the standards that are applied on the performance
metrics, especially on the accuracy. That\'s an important consideration.
Obviously that\'s something that the Commission will be considering as
we broach the rural issues with a greater focus now that we have
resolved some of the technical issues on the denser population
implementation.

That said, the key question is what\'s next. For me, there\'s really a
multitude of steps that need to take place. One is we need to get more
deployments out on the marketplace both Phase I and Phase II. We need to
continue working cooperatively along those lines. I look forward to
participating or hearing from the NENA SWAT CEO summit meeting that is
in early June. I\'m planning to be there.

Again, that is solution focused, company focused, and organizationally
getting the various constituencies to work each other at the most senior
levels because it\'s all about the leadership is what we heard today. So
leadership on the carrier side, leadership on the PSAP side, leadership
at the state level. NENA SWAT\'s efforts in that area are great. I hope
to see results out of that.

Also, we have the APCO meeting slated for August in which there will be
the sidebars and the various things that Bill Hinkle mentioned that the
Locate service is doing. Again, that\'s another point where we\'re going
to see a collaborative effort to get results. What we will do in the
fall is we will convene another E911 coordination initiative which will
be based on being informed during the summer months and over the next
proceeding six months or so as to the developments.

Hopefully we will have the electronic filing of the quarterly reports
and we\'ll have much greater detail about the level of deployment and
the kind of issues that are presenting themselves in the meantime. That
said, I\'m under the 4:00 p.m. time. I\'m over my own 3:50 p.m. time
limit.

But what I want to do again is thank everybody for coming in and
spending the time with us today. It was highly informative. I want to
thank again the Chairman and Bryan Traymont his Senior Legal Advisor who
just stepped in. I want to thank all of them for helping us get this
program up and running. I want to again thank also the staff for the
great work that they have done and also I thank you all for the great
service that you are doing for the American public. With that, I will
close this session. Thank you.

(Whereupon, the above-entitled matter concluded at 3:56 p.m.)