a

GAO

United States Government Accountability Office

Report to Congressional Committees

March 2006 TELECOMMUNICATIONS

States’ Collection and 

Use of Funds for 

Wireless Enhanced 

911 Services

GAO-06-338
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

March 2006

TELECOMMUNICATIONS 

States’ Collection and Use of Funds for 

Highlights of GAO-06-338, a report to Wireless Enhanced 911 Services 

congressional committees 

www.gao.gov/cgi-bin/getrpt?GAO-06-338.

To view the full product, including the scope 

and methodology, click on the link above. To 

view selected results of the survey, go to 

http://www.gao.gov/cgi-bin/getrpt?GAO-06-

400sp. 

For more information, contact Mark Goldstein 

at (202) 512-2834 or goldsteinm@gao.gov. 

“Enhanced 911” (E911) service 

refers to the capability of public

safety answering points to

automatically receive an 

emergency caller’s location 

information. An industry 

association estimates that nearly 82

million 911 calls are placed each

year by callers using mobile

phones. Wireless E911 technology 

provides emergency responders

with the location and callback 

number of a person calling 911

from a mobile phone. The 

ENHANCE 911 Act of 2004 called 

for GAO to study state and local

use of funds collected for the 

purpose of wireless E911 

implementation. We are reporting

on (1) the progress made in

implementing wireless E911

services throughout the country,

(2) the states and localities that 

have established taxes, fees, or

charges for wireless E911

implementation, and (3) the states

or localities that have used funds 

collected for the purposes of 

wireless E911 for unrelated

purposes. To address these issues,

we surveyed state-level E911

contacts on the collection and use

of E911 funds. Of the 51 state E911

contacts (including the District of

Columbia) who were asked to

participate in our survey, we

received 44 responses. 

We provided the Federal 

Communications Commission 

(FCC) with a draft of this report 

and FCC provided technical

comments that we incorporated. 

Significant progress has been made towards implementing wireless E911 

throughout the country since our November 2003 report. Deployment of 

wireless E911 usually proceeds through two phases: Phase I provides 

general location information by identifying the cell tower or cell site that is 

receiving the wireless call. Phase II provides more precise caller-location 

information, within 50 to 300 meters in most cases. We reported in 

November 2003, that nearly 65 percent of the more than 6,000 public safety 

answering points nationwide were capable of receiving Phase I information 

with wireless 911 calls and 18 percent had implemented Phase II wireless

E911 with at least one wireless carrier. Currently, according to the National 

Emergency Number Association (NENA), nearly 80 percent of public safety 

answering points are capable of receiving Phase I location information and 

57 percent have implemented Phase II for at least one wireless carrier.

However, based on our survey results, full implementation is still several 

years away in many states. In response to our survey, three state E911 

contacts reported that it will take more than 5 years to have wireless E911 

completely implemented in their states, and five others said that the 

technology might never be fully implemented in their states. 

Based on our survey results and NENA data, we found that nearly all 

states—48 states and the District of Columbia—require the wireless carriers

to collect surcharges from their subscribers to cover the costs associated 

with implementing wireless E911. Responses to our survey showed the persubscriber surcharges ranged from $0.20 to $3.00 per month. The two states

that do not impose surcharges fund E911 through general revenue or the 

state’s Universal Service Fund, which was established to support various 

telecommunications programs. States have the discretion to determine how 

they will manage and distribute the funds and we found the management of 

the funds and methods of disbursement varied. According to our survey 

results, many of the states that responded have written criteria on the 

allowable uses of E911 funds. Allowable uses of the E911 funds include 

purchasing equipment upgrades and software packages. 

Four state E911 contacts responded to our survey that their states did not 

use all of the funds collected for E911 on E911 implementation purposes 

during 2005. Six states, and the District of Columbia, did not respond to our 

survey so we do not know whether those states used E911 funds or made 

them available for other purposes. Four other states reported that they were 

unsure if all E911 funds were used solely for E911 purposes because the 

funds are collected and managed at the local level. The four states that 

reported that E911 funds were made available or used for purposes not 

related to E911 indicated that the E911 funds were transferred to their 

state’s general fund. For example, one state told us that E911 funds were 

transferred to the general fund to help balance the state budget. Another 

state reported that some E911 funds were transferred to the state police 

since they answer emergency calls in some areas of the state. 
Page i GAO-06-338 Collection and Use of Wireless E911 Funds

Contents

Letter 1

Results in Brief 4

Background 5

Significant Progress Has Been Made toward Nationwide Wireless 

E911 Implementation but Full Deployment is Years Away 8

Most States Collect Funds for Wireless E911 Implementation, 

Although Collection and Disbursement Practices Vary 12

A Few States Reported Using Wireless E911 Funds for Unrelated 

Purposes 17

Agency Comments 20

Appendix

Appendix I: Scope and Methodology 21

Figures Figure 1: Simplified Wireless E911 Call to PSAP with Phase II 

Capability 7

Figure 2: Percentage of State Population That Has Phase I and 

Phase II Wireless E911 Coverage with at Least One 

Wireless Carrier as of January 2006 10

Figure 3: State E911 Contacts’ Estimates of When Their State 

Would Have Phase II Wireless E911 Implemented for all 

PSAPs with at Least One Wireless Carrier 12

Figure 4: Range of Monthly Wireless E911 Surcharges by State as of 

2005 14

Figure 5: State Wireless E911 Implementation by County, as of 

January 2006, and the Use of E911 Funds during 2005 18
Contents

Page ii GAO-06-338 Collection and Use of Wireless E911 Funds

Abbreviations

DOT Department of Transportation

E911 enhanced 911

FCC Federal Communications Commission

GPS Global Positioning System

LEC local exchange carrier

NENA National Emergency Number Association

PSAP public safety answering point

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Page 1 GAO-06-338 Collection and Use of Wireless E911 Funds

United States Government Accountability Office

Washington, D.C. 20548

A

March 10, 2006 Letr

The Honorable Ted Stevens

Chairman

The Honorable Daniel K. Inouye

Co-Chairman

Committee on Commerce, Science, and Transportation

United States Senate

The Honorable Joe Barton

Chairman

The Honorable John D. Dingell

Ranking Minority Member

Committee on Energy and Commerce

House of Representatives

According to an industry association, 200 million 911 emergency calls are 

placed annually. Another industry association estimates that nearly 82 

million 911 calls are placed each year by callers using mobile (wireless) 

phones. A capability known as “enhanced 911” (E911) provides emergency 

responders with the location of, and a callback number for, a person calling 

911. This information facilitates the quick and accurate dispatch of 

emergency responders, especially in cases where the caller does not know 

or cannot clearly state his or her location (e.g., the caller is suffering from a 

heart attack). 

Most areas across the country now have E911 capabilities for traditional 

wireline phones, where the caller’s street address automatically appears 

on-screen for the 911 call taker. As the use of mobile phones has increased, 

Congress and others in the federal government and public safety 

communities have grown more concerned that E911 location information 

was not often available for those dialing 911 from a mobile phone. 

Implementing E911 for mobile phones is inherently more challenging. 

Unlike wireline phones, where the phone number is linked to a specific 

street address, providing E911 call takers with location information for a 

mobile phone involves technologies that must calculate the geographic 

coordinates of the caller’s location at the time of the call and display these 

coordinates as a location the 911 call taker can understand. Moreover, a 

wireless 911 call must be routed along the networks of both a wireless 

telephone company and a wireline telephone company before terminating 

at a facility where 911 calls are answered, known as a public safety 

answering point (PSAP); there are more than 6,000 PSAPs nationwide, 
Page 2 GAO-06-338 Collection and Use of Wireless E911 Funds

often at a county or city level. All three entities—wireless carriers, wireline 

carriers, and PSAPs—must be properly interconnected and have certain 

equipment in place in order for location information to be captured, sent, 

and displayed to 911 call takers. Deployment usually proceeds through two 

phases: Phase I provides general location information by identifying the 

cell tower or cell site that is receiving the wireless call and also provides 

the phone number of the caller, while Phase II provides more precise callerlocation information—within 50 to 300 meters in most cases. 

The Wireless Communications and Public Safety Act of 1999 called on the 

Federal Communications Commission (FCC) to encourage and support 

efforts by the states to deploy wireless E911 services by working with state 

and local officials, the telecommunications industry, consumer groups, and 

those involved in public safety services.1 At the federal level, FCC and the 

U.S. Department of Transportation (DOT) have taken steps to promote the 

deployment of E911 location technologies for mobile phones. According to 

FCC, the Commission monitors the deployment of wireless E911 service by 

larger carriers, enforces its wireless E911 requirements, and grants 

appropriate waivers of its wireless E911 requirements when consistent 

with the public interest. FCC further stated that it works with public safety 

organizations, wireless carriers, and manufacturers to foster wireless E911 

deployment. Also, DOT has recognized the relationship between wireless 

E911 services and highway safety and is working with a key 

nongovernmental organization, the National Emergency Number 

Association (NENA), to develop a PSAP database that tracks E911 

implementation.2

 The only federally mandated timeframes for installation 

of wireless E911 technologies are those placed on wireless carriers by FCC. 

FCC has no authority to place timeframes on PSAPs, which are under state 

1

Pub. L. No. 106-81, 113 Stat. 1286 (1999). The purpose section of the act states that it is 

meant to “encourage and facilitate the prompt deployment throughout the United States of a 

seamless, ubiquitous, and reliable end-to-end infrastructure for communications, including 

wireless communications, to meet the Nation’s public safety and other communications 

needs.”

2

NENA is a membership organization of emergency communications professionals in 

government and industry that fosters the technological advancement, availability, and the 

implementation of a universal emergency telephone number system. DOT contracted with 

NENA to create a database of PSAPs, including information about implementation of 

wireless E911, which is updated on a quarterly basis using wireless carrier information filed 

with FCC, and supplemented by data gathered directly from the PSAPs. The NENA database 

is accessible through http://www.nena.org. FCC also maintains a registry of PSAPs in 

connection with the wireless carrier E911 deployment reports filed with FCC. This registry 

is located at http://www.fcc.gov/911/enhanced/reports/psapregistry.html.
Page 3 GAO-06-338 Collection and Use of Wireless E911 Funds

and local jurisdiction. States and local jurisdictions establish timetables for 

implementation by their PSAPs, which must have the necessary equipment 

to receive and display location information that the 911 call taker can relay 

to police, fire, and rescue services. States must also fund the equipment 

upgrades needed by their PSAPs for E911 service. 

The pace of wireless E911 deployment has been a key concern for the 

Congress. In our November 2003 report on wireless E911, we noted that the 

implementation of wireless E911 was several years away in many states, 

raising the prospect of piecemeal availability of this service across the 

country for an indefinite number of years to come.3

 We found that the 

funding of equipment upgrades at PSAPs was a major issue for many states 

and localities and was the largest factor affecting the progress of E911 

implementation. Most states had put in place a surcharge on wireless 

customers to pay for E911 upgrades to their PSAPs. We found, though, that 

some states had redirected these funds to uses that were unrelated to E911.

Recently, the ENHANCE 911 Act of 2004 authorized a federal grant 

program to provide assistance to states, local governments, or tribal 

organizations in implementing E911.4

 Recognizing that some states had 

used the funds raised for E911 for other purposes, the act (among other 

things) stipulated that a state or local government would not be eligible for 

a federal E911 grant if it had used its E911 taxes, fees, or charges for 

unrelated purposes during the period beginning 180 days immediately 

preceding the date of the application and continuing until the funds are 

available to the applicant. Furthermore, if the grantee used state or local 

E911 funds for unrelated purposes during the term of the grant, the grant 

would have to be repaid. The act also called for us to study state and local 

use of funds collected for the purpose of wireless E911 implementation. 

Accordingly, we are reporting on (1) the progress made in implementing 

wireless E911 services throughout the country, (2) the states and localities 

that have established taxes, fees, or charges for wireless E911 

implementation, and (3) the states or localities that have used funds 

collected for the purposes of wireless E911 for unrelated purposes during 

2005. 

3

GAO, Telecommunications: Uneven Implementation of Wireless Enhanced 911 Raises the 

Prospect of Piecemeal Availability for Years to Come, GAO-04-55 (Washington, D.C.: Nov. 7, 

2003).

4

Pub. L. 108-494, title I, 118 Stat. 3986 (2004) (to be codified at 47 U.S.C § 942).
Page 4 GAO-06-338 Collection and Use of Wireless E911 Funds

To address these issues, we collected information from state-level E911 

contacts5

 from October 2005 to January 2006 using a Web-based survey. We 

designed the survey to cover the collection, management, and use of 

wireless E911 funds at the state and local level. Of the 51 state-level E911 

contacts (including the District of Columbia) who were asked to 

participate in our survey, we received 44 completed questionnaires. We did 

not receive completed questionnaires from Alaska, Colorado, the District 

of Columbia, Nevada, New York, Oklahoma, and South Dakota. To view 

selected results of this survey, go to http://www.gao.gov/cgi-bin/getrpt? 

GAO-06-400sp.

We used data from NENA, current as of January 2006, to provide 

information on the progress made in deploying wireless E911. To assess the 

reliability of NENA’s data regarding the number of PSAPs receiving Phase II 

data, we interviewed knowledgeable officials from NENA about their data 

collection methods. We determined that the data were sufficiently reliable 

for the purposes of this report. We conducted our review between February 

2005 and January 2006 in accordance with generally accepted government 

auditing standards. See appendix I for a more detailed discussion of our 

scope and methodology.

Results in Brief Since our last report in November 2003, significant progress has been made 

in implementing wireless E911 throughout the country. At that time, we 

reported that nearly 65 percent of the more than 6,000 PSAPs nationwide 

were capable of receiving Phase I location information with wireless 911 

calls and 18 percent of PSAPs had implemented Phase II wireless E911 with 

at least one wireless carrier. According to data from NENA, as of January 

2006, nearly 80 percent of PSAPs are capable of receiving Phase I location 

information and 57 percent have implemented Phase II with at least one 

wireless carrier. Of the 44 state E911 contacts who completed our survey 

about E911 implementation in their states, 10 responded that Phase II 

wireless services have already been implemented in their state and 21 

others reported that their state will have Phase II wireless E911 

implemented in the next 5 years with at least one wireless carrier. However, 

5

The state E911 contacts are listed on FCC’s Web site as the point of contact for emergency 

communications. This list can be found at http://www.fcc.gov/911/stateplans/contacts.html. 

The contacts were provided by the governor of each state in response to a request from 

FCC. The request was made to fulfill FCC’s responsibility under the Wireless 

Communications and Public Safety Act. See 47 U.S.C. § 615.
Page 5 GAO-06-338 Collection and Use of Wireless E911 Funds

three state contacts stated it will take more than 5 years to have Phase II 

wireless E911 capabilities throughout their states, five stated that this 

service might never be implemented statewide, and five others had no basis 

to judge when the service would be available. 

Based on our survey results and NENA data, almost all states (48 states and 

the District of Columbia) require wireless carriers to collect monthly 

surcharges from their subscribers to cover the costs associated with 

deploying wireless E911 service. Responses to our survey showed that the 

surcharges ranged from $0.20 to $3.00 per month. For the two states that do 

not impose surcharges, one funds E911 with general revenues and the 

other with the state’s Universal Service Fund, which supports various 

telecommunications programs. States have the discretion to determine 

how they will manage and distribute funds collected for wireless E911. 

Some states allocate funds to localities using a formula based approach, 

while others distribute the funds directly to the localities based on certain 

criteria. We found that many states that responded to our survey had 

established written criteria on the allowable uses of E911 funds, such as for 

equipment upgrades, software packages, and training of personnel.

Based on the responses to our survey, we found that four states did not use 

all E911 funds for E911 implementation purposes during 2005. These states 

reported that some E911 funds were transferred to their state’s general 

fund. For example, one state told us that E911 funds were transferred to 

the general fund to help balance the state budget. Another state reported 

that some E911 funds were transferred to the state police since the police 

answer emergency calls in some areas of the state. For the six states and 

the District of Columbia that did not respond to our survey, we do not 

know whether they used E911 funds or made them available for purposes 

unrelated to E911 implementation. We heard from four other state E911 

contacts that they were unsure if all E911 funds had been used for E911 

purposes because funds are collected and maintained at the local level. 

Background Nationwide implementation of E911 by local wireline telephone companies 

began in the 1970s; today, 99 percent of the population is covered by 

wireline 911 service. With wireline E911 service, emergency calls are
Page 6 GAO-06-338 Collection and Use of Wireless E911 Funds

automatically routed to the appropriate PSAP6 and the call taker receives 

the telephone number and street address of the caller. In 1996, FCC 

responded to the rising number of mobile telephone subscribers and the 

resulting increase in wireless 911 calls by adopting rules for wireless E911 

that established a two-phase implementation approach for the wireless 

carriers and set deadlines for wireless carriers regarding their part in E911 

deployment.7

 FCC required that (1) by April 1998, or within 6 months of a 

request from a PSAP, wireless carriers be prepared to provide the PSAP 

with the wireless phone number of the caller and the location of the cell 

site receiving the 911 call (Phase I information); and (2) by October 2001, or 

within 6 months of receiving a request from a PSAP, wireless carriers be 

prepared to provide the PSAP with the geographic coordinates of the 

caller’s location with greater precision, generally within 50 to 300 meters 

(Phase II information).8

As shown in figure 1, the wireless carriers, local exchange carriers (LECs), 

and PSAPs must have appropriate equipment and interconnections for 

wireless E911 calls to be sent to and received by PSAPs with the caller’s 

location information. For example, wireless carriers must finance the 

implementation of a caller location solution and test their equipment to 

verify its accuracy.9

 Local exchange carriers are generally responsible for 

ensuring that all the necessary connections between wireless carriers, 

PSAPs, and databases have been installed and are operating correctly. The 

6

PSAPs vary in size and technical sophistication. Some large urban PSAPs have dozens of 

call takers and split the functions of call taking and dispatching the proper emergency 

responder. Smaller PSAPs are sometimes staffed by only two or three call takers who also 

handle dispatch. In some rural areas, the PSAP may be the sheriff’s office.

7

Revision of the Commission’s Rules to Ensure Compatibility with Enhanced 911 

Emergency Calling Systems, CC Docket No.94-102; RM-8143, FCC 96-264, Report and Order 

and Further Notice of Proposed Rulemaking, 11 FCC Rcd 18676 (rel. July 26, 1996).

8

See 47 C.F.R. § 20.18(d)-(g) for further information on FCC’s Phase I and Phase II 

deployment requirements. FCC’s rules allow wireless carriers to choose a network-based or 

a handset-based approach to determine a 911 caller’s location. A network-based solution 

involves locating a caller through a triangulation process involving the cell towers closest to 

the caller. A handset-based solution relies on triangulation using Global Positioning System 

(GPS) satellites and a GPS chip inside the mobile phone. FCC’s accuracy requirements vary 

depending on whether a carrier deploys a network-based or handset-based solution. See 47 

C.F.R. § 20.18(h) for more details on FCC’s Phase II location accuracy requirements. FCC 

has granted waivers of the Phase II rules to wireless carriers.

9

For additional information on the technical aspects of wireless E911 service, see GAO-04-

55.
Page 7 GAO-06-338 Collection and Use of Wireless E911 Funds

original E911 system was designed to carry only the caller's telephone 

number with the call, and the associated fixed address was obtained from 

an established database. Wireless E911, however, requires more data items, 

and the mobile caller's location must be obtained during the call and 

delivered to the PSAP separately using additional data delivery capabilities. 

In order to translate the latitude and longitude location information into a 

street address, PSAPs usually must acquire and install mapping software. 

PSAPs may also need to acquire new computers to receive and display this 

information. Getting PSAPs the technology needed to receive wireless 

E911 location information is primarily a state and local responsibility 

because PSAPs serve an emergency response function that has 

traditionally fallen under state or local jurisdiction. FCC has no authority to 

set deadlines for the PSAPs’ readiness. 

Figure 1: Simplified Wireless E911 Call to PSAP with Phase II Capability

Source: GAO; Nova Development (clip art).

Voice 

and 

data

Voice 

and 

data

Voice 

and 

data

Voice 

and 

data

Data Data

E911 call takers

Data

Wireless carrier 

switching center

LEC call routing

equipment

Equipment 

used to 

locate caller

Database 

providing callback 

number and 

location 

information

PSAP equipment 

to receive location 

information and 

callback number

PSAP
Page 8 GAO-06-338 Collection and Use of Wireless E911 Funds

The ENHANCE 911 Act of 2004 was enacted to coordinate 911 and E911 

services at the federal, state, and local level; and to ensure that the taxes, 

fees, or charges imposed for enhancing 911 services are used only for the 

purposes for which the funds are collected. The act called for the creation 

of an E911 Implementation Coordination Office to improve E911 

coordination and communication. This office will be operated jointly by the 

National Highway Traffic Safety Administration (NHTSA) and the National 

Telecommunications and Information Administration (NTIA), and will be 

housed at NHTSA. Although the office had not received an appropriation as 

of January 2006, a DOT official told us that NHTSA and NTIA are working 

together to delineate their respective responsibilities. The act also 

authorized matching federal grants for eligible state, local, and tribal 

entities for the deployment and operation of Phase II E911 services. The act 

requires applicants for a matching federal grant to certify that no portion of 

any designated state and local E911 funds are being obligated or expended 

for any purpose other than the purposes for which the funds are 

designated.10 The act authorized $250 million per year for matching grants 

for fiscal years 2005 through 2009. However, no funds were appropriated 

for these grants in 2005.11

Significant Progress 

Has Been Made toward 

Nationwide Wireless 

E911 Implementation 

but Full Deployment is 

Years Away 

Significant progress has been made in implementing wireless E911 services 

since our last report on this topic in November 2003.12 At that time, using 

data from NENA, we reported that nearly 65 percent of PSAPs nationwide 

had implemented Phase I wireless E911 services and 18 percent of PSAPs 

had implemented Phase II wireless E911 with at least one wireless carrier. 

Since that time, there has been a marked increase in both of these 

percentages. As of January 2006, NENA reports that nearly 80 percent of 

PSAPs nationwide had implemented Phase I wireless E911 services and 57 

10The act requires certification that no funds were used during the period beginning 180 days 

immediately preceding the date of the application and continuing until the funds are 

available to the applicant. 47 U.S.C. § 942 (c)(2).

11The Deficit Reduction Act of 2005, Pub. L. No. 109-171, 120 Stat. 4 (2006), among other 

things, sets a definite date for the release of spectrum held by broadcasters and requires 

FCC to auction the freed spectrum to begin no later than January 28, 2008. The act 

establishes the Digital Television Transition and Public Safety Fund to receive spectrum 

auction proceeds and disburse designated sums to the Treasury and for other purposes. 

Among the proceeds for the funds are contributions totaling no more than $43.5 million to 

implement the ENHANCE 911 Act of 2004. 

12GAO-04-55.
Page 9 GAO-06-338 Collection and Use of Wireless E911 Funds

percent had implemented Phase II with at least one wireless carrier. At the 

county level, NENA reports that approximately 70 percent of counties 

nationwide have implemented Phase I wireless E911 services and 44 

percent of the counties have implemented Phase II with at least one 

wireless carrier. According to NENA, many of the PSAPs that have 

implemented Phase I and Phase II are in areas that cover higher 

concentrations of people, and as a result, approximately 85 percent of the 

U.S. population is now covered by Phase I and nearly 69 percent by Phase II 

with at least one wireless carrier. See figure 2 for nationwide deployment of 

Phase I and II based on population coverage by state.13

13Figure 5 has specific information on each state’s implementation status at the county level. 
Page 10 GAO-06-338 Collection and Use of Wireless E911 Funds

Figure 2: Percentage of State Population That Has Phase I and Phase II Wireless 

E911 Coverage with at Least One Wireless Carrier as of January 2006

Phase I

Phase II

Hawaii

Ore.

Nev.

Ariz.

Colo.

N.Dak.

Tex.

Kans.

Minn.

Iowa

Ark.

Ill. Ind.

Ky.

Tenn.

Ala.

Fla.

N.C.

Va.

N.H.

Mass.

Mich. R.I.

Calif.

Wash.

N.Y.

Maine

Vt.

W.Va.

Conn.

N.J.

Del.

Md.

D.C.

Hawaii

Ore.

Nev. Utah

Ariz. N.Mex.

Colo.

N.Dak.

Nebr.

Tex.

Kans.

Minn.

Iowa

Mo.

Ark.

La.

Ill.

Miss.

Ind.

Ky.

Tenn.

Ala.

Fla.

Ga.

S.C.

N.C.

Va.

N.H.

Mass.

Mich. R.I.

Calif.

Wash.

N.Y.

Maine

Vt.

W.Va.

Conn.

N.J.

Del.

Md.

D.C.

40 percent or less of state population has wireless E911 coverage

More than 40 percent but less than 60 percent of state population has wireless E911 coverage

At least 60 percent but less than 80 percent of state population has wireless E911 coverage

80 percent or more of state population has wireless E911 coverage

Source: GAO analysis of NENA data.

Mont.

Ohio

Wis.

Pa.

Mont.

Wyo.

Utah

N.Mex.

S.Dak.

Nebr.

Okla.

Miss.

Ohio

Wis. Idaho

Mo.

La.

Ga.

S.C.

Alaska

Alaska

Pa.

Idaho S.Dak.

Okla.

Wyo.
Page 11 GAO-06-338 Collection and Use of Wireless E911 Funds

While progress is being made in wireless E911 implementation, the 

estimates from state contacts indicate that no clear picture is emerging on 

when Phase II will be fully deployed nationwide. As noted earlier, FCC has 

no authority to set deadlines for PSAPs to implement wireless E911 

services. As a result, there is no federal requirement for full wireless E911 

implementation and states may or may not have set their own deadlines for 

implementation. In our survey of state E911 contacts, we asked 

respondents to provide us with an estimate of when they believed their 

state would have wireless Phase II service fully in place with at least one 

wireless carrier per PSAP. We found that state E911 contacts offered a wide 

range of estimated Phase II completion dates. As shown in figure 3, 10 of 44 

state contacts who responded to our survey indicated that Phase II was 

already in place throughout their state. Eight state contacts noted that they 

would have Phase II in place for all of their PSAPs with at least one 

wireless carrier within a year. Thirteen state contacts provided a range of 1 

to 5 years for Phase II to be implemented, with three state contacts 

responding that it would take more than 5 years. Furthermore, five state 

contacts noted that their state might never be 100 percent complete for 

Phase II service. For example, one state contact noted that four rural 

counties opted not to apply for state funding to implement wireless E911 

and two of these counties have only decided to implement wireline E911. 

Contacts in five states had no basis to judge when Phase II would be in 

place in their states. 
Page 12 GAO-06-338 Collection and Use of Wireless E911 Funds

Figure 3: State E911 Contacts’ Estimates of When Their State Would Have Phase II Wireless E911 Implemented for all PSAPs 

with at Least One Wireless Carrier 

Most States Collect 

Funds for Wireless 

E911 Implementation, 

Although Collection 

and Disbursement 

Practices Vary

Based on our survey results and NENA data, we found most states obtain 

E911 funds through state-mandated surcharges collected by wireless 

carriers from the carriers’ wireless subscribers. States have the discretion 

to determine how these funds will be managed and distributed. Some states 

allocate funds using a formula based approach, while others distribute the 

funds based on PSAP requests. According to our survey results, 35 states 

had established written criteria on the allowable uses of E911 funds. 

Examples of allowable uses for the funds included the purchase of 

equipment upgrades, software packages, and training of personnel.

Already

complete

10

Vermont

Washington

Tennessee

Rhode Island

North Dakota

New Hampshire

Minnesota

Maryland

Maine

Connecticut

From

1 - 3 years

9

Utah

South Carolina

North Carolina

New Mexico

Montana

Indiana

Florida

California

Arkansas

From

4 - 5 years

4

West Virginia

Pennsylvania

Ohio

Georgia

More than

5 years

3

Texas

Mississippi

Kansas

May never

be complete

5

Wisconsin

Illinois

Idaho

Arizona

Alabama

No basis

to judge

Hawaii

5

Nebraska

Wyoming

Missouri

Louisiana

Less than

1 year

8

Virginia

Oregon

New Jersey

Michigan

Massachusetts

Kentucky

Iowa

Deleware

Source: GAO analysis of state survey responses.

As noted earlier, we did not receive survey responses from Alaska, Colorado, the District of Columbia, Nevada, New York, Oklahoma, and South Dakota.
Page 13 GAO-06-338 Collection and Use of Wireless E911 Funds

Most States Collect 

Surcharges for Wireless 

E911 Implementation

At present, state and local governments determine how to pay for PSAP 

wireless E911 upgrades. We found, based on our survey results and NENA 

data, that 48 states and the District of Columbia collect surcharges to cover 

the costs of implementing wireless E911 (see fig. 4). For these states, funds 

are collected by wireless carriers from their subscribers. The other two 

states do not impose surcharges on wireless subscribers, but still have a 

wireless E911 funding mechanism in place. Specifically, the state E911 

contact for Missouri told us that the state uses funds from the local general 

revenue, local 911 taxes, and wireline funds for E911 implementation; and 

the Vermont state E911 contact said the state uses funds from the state’s 

Universal Service Fund, which supports various telecommunications 

programs. For states that impose surcharges, the surcharge amount is 

usually established in state law.14 Responses to our survey indicated that 

the per-subscriber surcharges varied from state to state and ranged from 

$0.20 to $3.00 per month. We also found the surcharge amount could vary 

within a state. For example, one state has a maximum monthly surcharge 

amount of $1.50, and although most of the counties collect the maximum 

amount, several counties collect less than the maximum. 

14We did not review or verify state law.
Page 14 GAO-06-338 Collection and Use of Wireless E911 Funds

Figure 4: Range of Monthly Wireless E911 Surcharges by State as of 2005

0

1

2

3

4

Surcharge amount in dollars

Louisiana

Kentucky

Kansas

Iowa

Indiana

City of Chicago

Illinois

Idaho

Hawaii

Georgia

Florida

District of Columbia

Delaware

Connecticut

Colorado

Californiaa

Arkansas

Arizona

Alaska

Alabama

State/city

0.70

2.00

(max)

0.37

0.50

0.70

(max)

0.37

0.60 0.60 0.50

1.50

(max)

0.66

1.00

(max)

0.75

1.25

0.65 0.65

0.50

0.70

0.85

(max)
Page 15 GAO-06-338 Collection and Use of Wireless E911 Funds

a

California collects 0.65 percent of intrastate calls.

b

According to the state E911 contact, Missouri uses funds from the local general revenue, local 911 

taxes, and wireline funds for E911 implementation. 

c

According to the state E911 contact, Vermont uses funds from the state’s Universal Service Fund for 

E911 implementation.

Based on the responses to our survey, several states indicated that 

insufficient funding collected for wireless E911 was impeding the state’s 

ability to implement this service. We heard from one state that relies on 

funds collected from both the wireline and wireless surcharges to fund 

E911 that due to Hurricane Katrina, the state expected to see a drop in 

wireline funding over the next 2 to 3 years. A county official from that state 

said that because many residents and businesses impacted by the storm 

have not reestablished telephone service, the state is not receiving 

telephone fees from those residents. Another state reported that one of the 

biggest issues in implementing wireless E911 is the inability to collect 

funds from seasonal populations in many of the state’s resort areas. Small 

Wyoming

Wisconsin

West Virginia

Washington

Virginia

Vermontc

Utah

Texas

Tennessee

South Dakota

South Carolina

Rhode Island

Pennsylvania

Oregon

Oklahoma

Ohio

North Dakota

North Carolina

New York

New Jer

New Mexico

sey

New Hampshire

Nevada

Nebraska

Mi

Montana

ssourib

Mississippi

Minnesota

Michigan

Massachusetts

Maryland 

Maine

0.50

1.00

(max)

0.30

0.52

0.65

1.00

0.50

0 0

0.50

1.00

(max)

0.42

0.90

0.51

1.50

(max)

0.80

1.00

0.32

0.50

0.75

1.00

1.26

0.60

0.75

1.00

0.50

0.65 0.75

0.20

3.00

0.83

0.75

(max)

Source: GAO analysis of state survey responses and NENA data.
Page 16 GAO-06-338 Collection and Use of Wireless E911 Funds

towns in the state experience a large influx of tourists during various times 

of the year. However, because the state collects funds based on the billing 

address of the subscriber, counties in the state are limited in their ability to 

cover the costs of E911 services that out-of-state tourists expect while 

visiting local resort areas.

States Employ Different 

Methods for Managing and 

Disbursing Funds 

States and local governments have the authority to determine how they will 

manage and disburse their E911 funds. Of the 31 states that answered our 

question pertaining to the management of E911 funds, 23 indicated that the 

funds are managed at the state level, 6 said funds are managed locally, and 

2 others indicated that the funds are managed by a mix of state and local 

entities. We found that various state-level entities can have authority to 

manage the funds collected for wireless E911 implementation, including 

the public utility commission, the treasury office, and state-level boards. In 

one state, for example, a state-level board comprised of members from 

municipal organizations, PSAPs, state and local law enforcement agencies, 

local exchange service providers, and the wireless carriers industry 

established the criteria and guidelines for administering the funds. Of the 

seven states indicating that the local government manages the funds, one 

state said that the governing boards of 54 local 911 jurisdictions (51 

counties and 3 cities) have the ultimate authority over the expenditure of 

wireless E911 funds. 

Methods of disbursement also varied. Some states use formulas based on 

various criteria to determine the amount of funds distributed to different 

localities. For example, a number of states allocate the funds to localities 

based on criteria such as the volume of 911 calls made in the jurisdiction or 

the number of wireless subscribers. Other states allocate funds based on 

PSAP requests. One state reported that it reimburses county governments 

and providers for the costs they have incurred to implement wireless E911 

services. Alternatively, the PSAPs in another state must first request 

funding from the state, which a state-level office must then approve. 

Most States Have Written 

Criteria on the Allowable 

Use of E911 Funds 

As part of our survey, we asked the state E911 contacts if their states had 

established written criteria on the allowable uses of funds collected for the 

purposes of wireless E911 implementation. Of the 38 state contacts who 

responded to this question, 35 reported that their state had established 

written criteria, while the other 3 indicated that written criteria had not 

been established. Examples of allowable uses of funding include the 

purchase of equipment upgrades or software, personnel costs directly 
Page 17 GAO-06-338 Collection and Use of Wireless E911 Funds

attributable to the delivery of 911 service, and costs related to the 

maintenance of Phase I and II services. For example, according to one 

state, its law permits wireless E911 funds to cover the salaries, benefits, 

and uniforms of 911 service employees such as call takers, dispatchers, and 

supervisors. We also asked the state E911 contacts if the state had any kind 

of oversight procedures to control the use of E911 funds. Of the 38 state 

contacts who responded to this question, 33 reported that their state had 

established oversight procedures to control the use of E911 funds, 3 others 

indicated no oversight procedures had been established, and 2 contacts did 

not know. According to our survey results, audits were the most common 

approach used to oversee the use of E911 funds. For example, one state 

reported that the wireless E911 fund and the state’s wireless E911 services 

board is audited annually by the state’s Auditor of Public Accounts and that 

the reports are available to the public online.

A Few States Reported 

Using Wireless E911 

Funds for Unrelated 

Purposes 

Based on the responses of the 44 state E911 contacts who completed our 

survey, four states that collected funds for the purposes of wireless E911 

implementation made those funds available or used them for purposes 

unrelated to E911 during 2005.15 For the six states and the District of 

Columbia that did not respond to our survey, we do not know whether they 

used any of their E911 funds for unrelated purposes. Four other states were 

unsure if their wireless E911 funds have been used for unrelated purposes 

because the funds are collected and maintained at the local level. See figure 

5 for a complete breakout by state of their use of E911 funds during 2005, 

along with their progress in implementing E911 in their counties. 

15We contacted the state budget offices for these four states and asked the offices to verify 

the accuracy of the amount of E911 funds made available or used for purposes not related to 

E911.
Page 18 GAO-06-338 Collection and Use of Wireless E911 Funds

Figure 5: State Wireless E911 Implementation by County, as of January 2006, and the Use of E911 Funds during 2005

41% 32%

4% 2%

60% 2%

24% 18%

100% 100%

100% 86%

36% 0%

76% 60%

100% 71%

100% 98%

23% 6%

13% 1%

100% 33%

25% 18%

100% 100%

93% 50%

18% 6%

100% 100%

100% 19%

3% 3%

100% 100%

93% 83%

100% 87%

75% 47%

15% 15%

26% 13%

Missouri

Montana

Nebraska

Nevada

New Hampshire

New Jersey

New Mexico

New York

North Carolina

North Dakota

Ohio

Oklahoma

Oregon

Pennsylvania

Rhode Island

South Carolina

South Dakota

Tennessee

Texas

Utah

Vermont

Virginia

Washington

West Virginia

Wisconsin

Wyoming

N/A

N/A

N/A

Unknown

N/A

N/A

N/A

Unknown

$25 million

N/A

N/A

Unknown

N/A

N/A

$9 million

N/A

Unknown

N/A

Unknown

N/A

N/A

$4.7 million

N/A

N/A

N/A

Unknown

Source: GAO analysis of state survey responses and NENA data.

d

e

g

h

i

j

f

Percentage

of counties

that have

Phase I

Percentage

of counties

that have

State Phase II

Reported using all

E911 funds for E911

purposes in 2005

Amount of

E911 funds

not used

for E911

in 2005 eY s

oN oN

eR s nop se

Alabama

Alaska

Arizona

Arkansas

California

Colorado

Connecticut

District of 

Columbia

Delaware

Florida

Georgia

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Maryland

Massachusetts

Michigan

Minnesota

Mississippi

96% 54%

8% 4%

N/A

Unknown

N/A

N/A

N/A

Unknown

N/A

Unknown

N/A

N/A

Unknown

N/A

Unknown

N/A

N/A

N/A

N/A

Unknown

N/A

N/A

N/A

N/A

N/A

N/A

47% 13%

93% 60%

29% 28%

87% 33%

100% 100%

100% 100%

100% 100%

90% 72%

55% 15%

25% 25%

23% 16%

74% 47%

99% 95%

100% 63%

28% 22%

98% 73%

75% 22%

100% 100%

100% 100%

100% 100%

100% 92%

100% 100%

77% 5%

$254,000

a

re th O

Percentage

of counties

that have

Phase I

Percentage

of counties

that have

State Phase II

Reported using all

E911 funds for E911

purposes in 2005

Amount of

E911 funds

not used

for E911

in 2005 eY s

oN oN

eR s nop se

re th O

b

b

c

b

b
Page 19 GAO-06-338 Collection and Use of Wireless E911 Funds

a

According to the state E911 contact, funds are not specifically collected for wireless E911. Rather, 

funds are collected for wireline and wireless 911 and these revenues are used to support the overall 

statewide 911 program. 

b

According to the state E911 contact, use of wireless E911 funds is determined at the county or local 

level.

c

According to the state E911 contact, some funds have been transferred to the state’s General 

Revenue Fund. The amount was verified by a state budget official.

d

According to the state E911 contact, E911 funds are not collected in the state.

e

According to the state E911 contact, the state’s General Assembly took funds from the E911 fund to 

help balance the state’s budget. The amount was verified by a state budget official. 

f

According to the state E911 contact, the wireless E911 fund was just created in 2005.

g

According to the state E911 contact, E911 surcharge revenues are deposited into the state’s General 

Fund. The amount not used on E911 implementation was verified by a state budget official.

h

According to the state E911 contact, E911 funds have been frozen and are not being used to deploy 

E911 services. 

i

According to the state E911 contact, the state does not collect E911 funds; rather, the state uses 

monies from the state’s Universal Service Fund to implement wireless E911 services.

j

According to the state E911 contact, some E911 funds were transferred to the state’s General Fund 

and some were transferred to the state police since they answer wireless E911 calls in some areas of 

the state. The amount was verified by a state budget official.

For the four states that reported E911 funds were made available or used 

for purposes not related to E911 during 2005, the state contacts reported 

that the E911 funds were transferred to their state’s general fund. For 

example, the E911 contact for North Carolina reported that E911 funds 

were transferred to the general fund to help balance the state budget. 

According to the E911 contact for Virginia, funds were transferred to both 

the general fund and to the state police, which responds to emergency calls 

in some areas of the state. One of these four states, Rhode Island, has 

implemented Phase II services in all of its counties and Virginia has 

implemented Phase II for 83 percent of its counties. For the remaining two 

states, Illinois has implemented Phase II in 47 percent of its counties and 

North Carolina for 71 percent of its counties. 

One state responded to our survey that, while E911 funds have not been 

made available for other purposes, approximately $72 million in state 

wireline and wireless E911 fees collected have not been appropriated to the 

state 911 program. In other words, the funds remain in dedicated E911 

accounts, but are “frozen” and are not being used to deploy or maintain 

E911 services. We heard from four other states that because funds for 

wireless E911 are collected and managed by local jurisdictions without any 

state involvement, the state is unsure if wireless E911 funds have been used 

for purposes other than wireless E911 implementation. For example, one 

state E911 contact told us that the state currently has no mechanism to 

monitor the use of wireless E911 funds at the local level. However, this 
Page 20 GAO-06-338 Collection and Use of Wireless E911 Funds

contact further said that if a federal grant program for wireless E911 is 

funded, the state could establish a mechanism to validate that local 

jurisdictions were using wireless E911 funds only for allowable purposes. 

Agency Comments We provided FCC with a draft of this report for their review and comment. 

In response, FCC provided technical comments that we incorporated 

where appropriate.

We are sending copies of this report to interested congressional 

committees and the Chairman, FCC. We will make copies available to 

others upon request. The report is available at no charge on GAO’s Web site 

at http://www.gao.gov. Contact points for our offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

If you or your staff have any questions concerning this report, please 

contact me on (202) 512-2834 or goldsteinm@gao.gov. Key contributors to 

this report were John Finedore, Assistant Director; Kimberly Berry, Andy 

Clinton, Stuart Kaufman, Sally Moino, Josh Ormond, Jay Smale, and Mindi 

Weisenbloom. 

Mark L. Goldstein

Director, Physical Infrastructure Issues
Page 21 GAO-06-338 Collection and Use of Wireless E911 Funds

Appendix I

Scope and Methodology AAppenednxidexiIs

The ENHANCE 911 Act of 2004 required us to review the imposition and 

use of taxes, fees, or other charges by states or localities that are 

designated to improve emergency communications services, including 

“enhanced 911” (E911). As such, we are reporting on (1) the progress made 

in implementing wireless E911 services throughout the country, (2) the 

states and localities that have established taxes, fees, or charges for 

wireless E911 implementation, and (3) the states or localities that have 

used funds collected for the purposes of wireless E911 for unrelated 

purposes. 

To obtain general information on wireless E911 implementation, we 

interviewed officials from the National Emergency Number Association 

(NENA), the National Association of State 9-1-1 Administrators, and the 

Federal Communications Commission (FCC). We also met with officials 

from the Department of Transportation to learn the status of the E911 

Implementation Coordination Office. To obtain information pertaining to 

the collection, management, and use of wireless E911 funds at the state and 

local level, we developed and administered a Web-based survey to statelevel E911 contacts. The state E911 contacts are listed on FCC’s Web site as 

the point of contact for emergency communications in their states and 

were provided by the governor of each state in response to a request from 

FCC. From September 21, 2005, through September 28, 2005, we conducted 

a series of “pretests” with state E911 contacts to help further refine our 

questions, clarify any ambiguous portions of the survey, and identify any 

potentially biased questions. Upon completion of the pretests and 

development of the final survey questions and format, we sent an 

announcement of the upcoming survey to the state E911 contacts 

(including the District of Columbia) on October 4, 2005. They were notified 

that the survey was available online on October 6, 2005. We sent follow-up 

e-mail messages to non-respondents as of October 30, 2005, and then 

attempted several times to contact those who had not completed the 

survey. The survey was available online until January 20, 2006. Of the 

population of 51 state E911 contacts who were asked to participate in our 

survey, we received 44 completed questionnaires for an overall response 

rate of 86 percent. Although the individual listed as the Wyoming state E911 

contact was unable to answer the questionnaire, a representative at the 

county level completed it. We did not receive completed questionnaires 

from Alaska, Colorado, the District of Columbia, Nevada, New York, 

Oklahoma, and South Dakota. We administered the survey between 

October 2005 and January 2006. To view selected results of the survey, go 

to http://www.gao.gov/cgi-bin/getrpt?GAO-06-400sp.
Appendix I

Scope and Methodology 

Page 22 GAO-06-338 Collection and Use of Wireless E911 Funds

The practical difficulties of conducting surveys may introduce errors 

commonly referred to as “nonsampling error.” For example, differences in 

how a particular question is interpreted or the sources of information 

available to respondents may introduce error. To minimize nonsampling 

error, we worked with a social science survey specialist to develop the 

questionnaire and conducted three pretests. In addition, steps were taken 

during the data analysis to minimize error further, such as performing 

computer analyses to identify inconsistencies and completing a review of 

data analysis by an independent reviewer.

We contacted state budget officials for the four states that reported using 

funds collected for the purpose of E911 implementation for unrelated 

purposes to verify the information we received in response to our survey. 

Other than this, we did not independently verify the survey results. To 

provide information on the progress made in deploying wireless E911, in 

addition to the survey, we used NENA data current as of January 2006. To 

assess the reliability of NENA’s data regarding the number of public safety 

answering points receiving Phase II data, we interviewed knowledgeable 

officials from NENA about their data collection methods and reviewed any 

existing documentation relating to the data sources. We determined that 

the data were sufficiently reliable for the purposes of this report.

We conducted our review between February 2005 and January 2006 in 

accordance with generally accepted government auditing standards. 

 (543119)
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