United States General Accounting Office 

GAO	 Report to the Chairman, Subcommittee 

on Communications, Committee on 

Commerce, Science, and Transportation, 

U.S. Senate 

November 2003 TELECOMMUNICATIONS 

Uneven 

Implementation of 

Wireless Enhanced 

911 Raises Prospect of 

Piecemeal Availability 

for Years to Come 

GAO-04-55


a
Highlights of GAO-04-55, a report to the 

Chairman, Subcommittee on 

Communications, Committee on 

Commerce, Science, and Transportation, 

U.S. Senate 

When an emergency call is placed 

to 911, prompt response depends 

on knowing the location of the 

caller. Enhanced 911 (E911) 

service automatically provides this 

critical information. E911 is in 

place in most of the country for 

traditional wireline telephone 

service, where the telephone 

number is linked to a street 

address. Expanding E911 

capabilities to mobile phones is 

inherently more challenging 

because of the need to determine 

the caller’s geographic location at 

the moment the call is made. 

Concerns have been raised about 

the pace of wireless E911 

implementation and whether this 

service will be available 

nationwide. GAO reviewed the 

progress being made in 

implementing wireless E911 

service, the factors affecting this 

progress, and the role of the federal 

government in facilitating the 

nationwide deployment of wireless 

E911 service. 

In order to provide the Congress 

and federal and state officials with 

an accurate assessment of the 

progress being made toward full 

deployment of wireless E911, we 

are recommending that the 

Department of Transportation 

work with state officials and public 

safety groups to develop data 

identifying which PSAPs will need 

to have E911 equipment upgrades. 

In response, DOT stated that it 

generally agreed with our 

recommendation. 

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

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Mark Goldstein 

at (202) 512-6670 or goldsteinm@gao.gov. 

November 2003 

TELECOMMUNICATIONS 

Uneven Implementation of Wireless 

Enhanced 911 Raises Prospect of 

Piecemeal Availability for Years to Come 

Implementation of wireless E911 is several years away in many states, 

raising the prospect of piecemeal availability of this service across the 

country for an indefinite number of years to come. Successful 

implementation depends on coordinated efforts by wireless carriers, local 

telephone companies, and more than 6,000 public safety answering points 

(PSAPs)—the facilities that receive 911 calls and dispatch assistance. 

According to a database sponsored by the Department of Transportation 

(DOT), as of October 2003, nearly 65 percent of PSAPs had Phase I wireless 

E911 service, which provides the approximate location of the caller, while 

only 18 percent had Phase II, which provides a more precise location and is 

the ultimate goal of wireless E911 service. Though valuable, the database 

does not differentiate between PSAPs that will require equipment upgrades 

and those that will not, thereby limiting its usefulness in accurately 

assessing progress toward full implementation. Looking forward, 24 state 

911 contacts said in response to a GAO survey that their state will have 

Phase II implemented by 2005 or sooner; however, all other state contacts 

estimated dates beyond 2005 or were unable to estimate a date. 

Key factors hindering wireless E911 implementation involve funding and 

coordination. The wireless carriers, states, and localities must devise the 

means to fund more than $8 billion in estimated deployment costs over the 

next 5 years. Some states and localities have established funding 

mechanisms (such as E911 surcharges on phone bills), but others have not 

done so or have used their E911 funds for unrelated purposes. In addition, 

there is also a lack of coordination in some cases among the wireless 

carriers, local telephone companies, and PSAPs that can lead to delays in 

wireless E911 implementation. States with knowledgeable and involved 

coordinators were best able to work through these coordination issues. 

The Federal Communications Commission (FCC) and DOT are involved in 

promoting wireless E911, but their authority in overseeing its deployment is 

limited because PSAPs traditionally fall under state and local jurisdiction. 

FCC has set deadlines on the wireless carriers’ E911 responsibilities and has 

taken actions to identify best practices and improve coordination among the 

parties. DOT is developing an action plan and clearinghouse for wireless 

E911 planning, implementation, and operations. 

Call Taker Station at a Public Safety Answering Point 
Contents


Letter


Results in Brief 


Background 


Nationwide Phase I Deployment Is More Than Halfway Complete, 


but Full Phase II Deployment May Be Years Away 


Funding and Coordination Are Key Factors Affecting Current


Wireless E911 Deployment, with New Wireless Services Posing 


Future Challenges 


The Recent Actions of FCC and DOT Are Focused on Enforcing 


Deadlines on Wireless Carriers and Improving Deployment


Coordination


Conclusions 


Recommendation for Executive Action 


Agency Comments


1 

4 

6 

12 

17 

25 

28 

29 

29 

Appendixes 

Appendix I: Scope and Methodology 31


Appendix II:	 FCC Consumer Advisory about Calling 911 from Your 


Wireless Phone 33


Appendix III:	 GAO Contacts and Staff Acknowledgments 36


GAO Contacts 36


Staff Acknowledgments 36


Figures	 Figure 1:


Figure 2:


Figure 3:


Figure 4:


Call Taker Handling a 911 Call at a Public Safety 


Answering Point 7


Simplified Wireless E911 Call to PSAP with Phase II 


Capability 9


Percentage of Counties, by State, That Have Implemented 


Wireless E911 Phase I and Phase II as of October 2003 14


Estimates by State 911 Contacts of Year Their State Would 


Have Phase II Wireless E911 Fully Implemented (Includes 


the District of Columbia) 16


Page i GAO-04-55 Wireless E911 
Contents 

Abbreviations 

DOT Department of Transportation


E911 enhanced 911


FCC Federal Communications Commission


GPS Global Positioning System


LEC local exchange carrier


NENA National Emergency Number Association


PSAP public safety answering point


This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 

Page ii GAO-04-55 Wireless E911 
Page 1 GAO-04-55 Wireless E911 

A

United States General Accounting Office 

Washington, D.C. 20548 

November 7, 2003


The Honorable Conrad Burns


Chairman


Subcommittee on Communications


Committee on Commerce, Science, and Transportation


United States Senate


Dear Mr. Chairman:


In 2001, Americans placed almost 57 million emergency calls to 911 using 


mobile phones. According to the Federal Communications Commission


(FCC), around one-third of 911 calls are now made from mobile phones. 


With almost 150 million Americans now subscribing to a mobile phone 


service and new concerns about homeland security facing our nation, the 


ability to reach 911 from sidewalks, highways, and rural areas has become 


increasingly important. Knowing the precise location of a 911 caller 


facilitates the quick and accurate dispatch of emergency responders such 


as police, firefighters, and ambulance crews. However, in some cases, 911 


callers cannot speak (e.g., a caller who is suffering a heart attack) or simply 


do not know their location (e.g., a caller reporting an accident along a 


highway). 


For traditional wireline phones, most areas across the country now employ 


“enhanced 911” (E911) services, where the caller’s address automatically


appears on-screen for the 911 call taker. The increasing use of mobile


phones led to concerns by the Congress and others in the federal 


government and the public safety community that E911 location 


information is often not available for citizens dialing 911 from a mobile


phone. However, implementing wireless E911 is inherently more 


challenging than wireline E911. Unlike wireline phones, where the phone 


number is linked to a specific street address, providing location


information for a mobile phone involves technologies that must calculate 


the geographic coordinates of the caller at the time of the call and display 


those coordinates as a location the 911 call taker can understand. 


Moreover, a wireless 911 call is routed along the networks of both a 


wireless telephone company and a wireline telephone company before 


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


safety answering point (PSAP). There are more than 6,000 of these 


answering points nationwide, often at a county or city level. All three of


these entities—wireless carriers, wireline carriers, and public safety


answering points—must be properly interconnected and have certain


Page 1 GAO-04-55 Wireless E911 
equipment in place before wireless 911 calls can be correctly routed and 

E911 location information sent with the call. 

At the federal level, FCC and the U.S. Department of Transportation (DOT) 

have taken steps to promote the deployment of E911 location technologies 

for mobile phones. Deployment usually proceeds in two phases: Phase I 

provides general location information by identifying the cell site1

 and cell 

sector2

 receiving the wireless call as well as the telephone number of the 

caller; Phase II provides a more precise location by determining the 

latitude and longitude of the caller, which can be electronically displayed 

on a map. Currently, the only federally mandated time frames for 

installation of wireless E911 technologies are those placed on wireless 

carriers by FCC. These time frames vary by wireless carrier and by the type 

of location technology the carrier has selected, and currently extend out to 

December 31, 2005. However, FCC has no authority to place time frames on 

the public safety answering points, which are under state and local 

jurisdiction. As a result, there is no ultimate nationwide deadline for full 

implementation of wireless E911 services. FCC has technical and 

educational initiatives under way to help the parties involved to share 

information on deployment practices, problems, and experiences. Also, 

DOT has recognized the relationship between wireless E911 services and 

highway safety and is working with a key nongovernmental organization, 

the National Emergency Number Association (NENA), to develop a PSAP 

database that tracks E911 implementation.

3 DOT is also working to 

promote research, planning, and education related to wireless E911 

services. 

1

Wireless carriers deliver mobile phone service by subdividing large geographic areas into 

smaller sections called cells. Each cell has a base station equipped with one or more 

antennas to receive and transmit radio signals to the mobile phones within its coverage 

area. The distance covered by the base station can range from less than a mile to 20 miles. 

For more information on cell phones, see U.S. General Accounting Office, 

Telecommunications: FCC Should Include Call Quality in Its Annual Report on 

Competition in Mobile Phone Services, GAO-03-501 (Washington, D.C.: Apr. 28, 2003). 

2

The cell sector refers to the coverage area of a cellular antenna. Cell sites often contain 

three antennas, which define three unique coverage areas or sectors, helping to narrow the 

field of search for the wireless caller. 

3

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. The database is 

accessible through http://www.nena.org. 

Page 2 GAO-04-55 Wireless E911 
The pace of wireless E911 deployment has been a key concern for the 

Congress. The Wireless Communications and Public Safety Act of 1999 

designated 911 as the universal emergency telephone number within the 

United States and called on FCC to encourage and support efforts by the 

states to deploy wireless E911 services by working with state and local 

officials, the telecommunications industry, consumer groups, and those 

involved in public safety services.4 There is also a Congressional E911 

Caucus that aims to educate lawmakers, constituents, and communities 

about the importance of 911 systems.5 You asked us to provide an overview 

of the deployment of wireless E911 services across the country. We agreed 

to provide information on (1) the progress made in deploying wireless E911 

services throughout the country, (2) the factors that are affecting this 

progress, and (3) current federal government actions to promote the 

deployment of wireless E911 services. 

4

Pub. L. No. 106-81, 113 Stat. 1286 (1999). According to its purpose section, the act is meant 

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

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

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

needs.” 

5

The establishment of the E911 Institute, a not-for-profit organization that will support the 

work of the Congressional E911 Caucus, was announced in July 2003. More information can 

be found at the organization’s Web site, www.e911institute.org. 

Page 3 GAO-04-55 Wireless E911 
To address these issues, we interviewed representatives of the various 

parties involved in wireless E911 implementation. We selected nine states 

(California, Idaho, Indiana, Kentucky, Maryland, Missouri, South Carolina, 

Texas, and Virginia) and the District of Columbia as case studies.6

 For each 

case study, we interviewed representatives of a public safety answering 

point in both an urban and rural area of the state.7

 We also interviewed the 

state’s 911 coordinator and representatives of one small wireless carrier8 

serving the state.

9 In addition to our case studies, we interviewed 

companies providing wireless telephone services nationwide, companies 

providing local wireline telephone services, and a manufacturer of mobile 

telephones. We interviewed federal, state, and local government officials 

involved in wireless E911 implementation and representatives from several 

public safety associations and wireless industry associations. Lastly, we 

conducted a telephone survey of the state 911 contacts in all 50 states and 

the District of Columbia (these individuals were designated by the 

governor of each state as the E911 point of contact and are listed on FCC’s 

Web site) to obtain an overview of implementation efforts across the 

country. A more detailed discussion of our scope and methodology is found 

in appendix I. 

Results in Brief	 Implementation of wireless E911 is several years away in many states, 

raising the prospect of piecemeal availability of this service across the 

country for an indefinite number of years to come. According to a DOTsponsored database, as of October 2003, nearly 65 percent of the more than 

6,000 public safety answering points nationwide are receiving Phase I 

6

We selected states that were spread geographically across the United States and that 

appeared to be having various levels of success with wireless E911 implementation based 

on early research. In particular, we selected at least one rural state and at least one state 

known to have redirected funds collected for E911 implementation to other uses. 

7

There were exceptions to this in one state and the District of Columbia. California has no 

rural public safety answering points that take wireless calls, so we interviewed the 

California Highway Patrol, which handles most of the wireless 911 calls in California. The 

District of Columbia has only one public safety answering point. 

8

For purposes of our case studies, a small wireless carrier was considered any wireless 

carrier other than the six large nationwide wireless carriers (AT&T Wireless, Cingular, 

Nextel, Sprint, T-Mobile, and Verizon Wireless). 

9

Again, there were exceptions to this in one state and the District of Columbia. We were 

unable to schedule an interview with a small wireless carrier in Missouri, and the District of 

Columbia is not served by any small wireless carriers. 

Page 4 GAO-04-55 Wireless E911 
location information, but only about 18 percent are receiving Phase II 

location information. Although the DOT-sponsored database has greatly 

increased the amount of information available about E911 progress, the 

database does not differentiate between public safety answering points 

that will require equipment upgrades and those that will not. This limits its 

usefulness in accurately assessing progress toward full implementation. 

Looking forward, 24 state 911 contacts said in response to a GAO survey 

that their state will have Phase II implemented by 2005 or sooner; however, 

all other state contacts estimated dates beyond 2005 or were unable to 

estimate a date. 

Lack of funding for equipment upgrades and a lack of coordination among 

the parties involved are factors slowing the pace of the rollout of wireless 

E911 technologies. Based on our interviews, lack of state or local funding is 

the largest factor affecting the progress of wireless E911. No federal 

funding was provided to the states and localities to cover the cost of E911 

implementation, estimated to be at least $8 billion over the next five years. 

Our survey of state contacts showed that 39 states and the District of 

Columbia have put in place a surcharge on wireless customers to pay for 

E911 upgrades to public safety answering points. Yet, some states have no 

funding mechanism in place and even those that do sometimes redirect the 

collected funds to uses unrelated to wireless E911 implementation. 

Another factor slowing wireless E911 rollouts is a lack of coordination 

among the parties involved. This problem has been avoided in some 

localities with early coordination meetings among all the parties, where 

personal contacts can be established and early concerns raised and 

addressed. We were told by many of those we interviewed that states with 

knowledgeable and involved state coordinators have had an easier time 

with coordination and with public safety answering point readiness. 

Technologically, the main hurdle of developing wireless location equipment 

for mobile phones has been solved, but the continuing emergence of new 

wireless devices and services has the potential to overburden the current 

911 infrastructure. 

The federal government has been involved in the promotion of wireless 

E911, but has limited authority over the entire process. FCC has 

concentrated its regulatory efforts toward the wireless carriers, where it 

has the most enforcement authority. FCC has established implementation 

schedules with each of the major wireless carriers and has recently taken 

enforcement actions against wireless carriers that failed to meet deadlines. 

According to FCC, the Commission does not have clear jurisdiction over 

wireline carriers with regard to wireless E911 implementation and looks to 

Page 5 GAO-04-55 Wireless E911 
the state public utility commissions, which have clear and sufficient 

authority, to take the lead. However, FCC has said it will monitor the 

wireline carriers’ efforts to ensure that they are meeting their 

responsibilities with regard to E911 deployment. In April 2003, FCC held 

the first coordination initiative meeting to bring the parties involved in 

E911 together and has established a technical group to examine relevant 

E911 infrastructure issues. DOT is developing an action plan and 

clearinghouse for wireless E911 planning, implementation, and operations. 

FCC and DOT coordinate their wireless E911 activities to avoid duplication 

of effort. However, the agencies do not jointly staff or fund any wireless 

E911 projects. 

To address the limitations in the DOT-sponsored database on public safety 

answering points’ readiness for wireless E911 service, we are 

recommending that the department work with state officials and public 

safety groups to develop a more accurate assessment of the number and 

location of answering points that still need equipment upgrades. A draft of 

this report was provided to DOT and to FCC. In commenting on the draft of 

this report, DOT stated that it generally agreed with the report’s 

recommendation, and FCC offered some technical comments that were 

incorporated where appropriate. 

Background	 Basic wireline 911 service provides an easily remembered universal 

number that connects the caller with an emergency response center, 

known as a public safety answering point (PSAP) (see fig. 1).10 The next 

step after basic wireline 911 service is “enhanced 911” (E911), which 

automatically routes the emergency call to the appropriate PSAP and 

transmits to the call taker the telephone number (the “callback number,” 

should the call be disconnected) and street address of the caller. 

Nationwide implementation of E911 by local wireline telephone 

companies, known as “local exchange carriers” (LEC), began in the 1970s 

without a federal mandate or deadlines governing the rollout. By 1987, 50 

percent of the United States’ population could reach emergency services 

through wireline 911. Today, 99 percent of the population is covered by 

10PSAPs vary in size and technical sophistication. Some large urban PSAPs have dozens of 

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

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

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

Page 6 GAO-04-55 Wireless E911 
wireline 911 service, and 93 percent of that coverage includes the delivery 

of a callback number and location information. 

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

In the early 1990s, FCC took note of the rising number of mobile telephone 

subscribers and the resulting increase in 911 calls. In 1994, FCC requested 

comments on requiring wireless carriers to provide the same level of 911 

service that was available from LECs. In 1996, with input from the industry 

and public safety community, FCC adopted rules for wireless E911 that 

established an approach consisting of two phases for implementation by 

the wireless carriers. FCC also set schedules for implementing both basic 

and enhanced wireless 911 services, determined accuracy requirements 

and deployment schedules for location technologies, and outlined the role 

of PSAPs. Specifically, the phases required the following: 

•	 Phase I required that by April 1998, or within six months of a request 

from a PSAP, whichever was later, wireless carriers were to be prepared 

to provide the PSAP with the wireless phone number of the caller and 

the location of the cell site receiving the 911 call. 

Page 7 GAO-04-55 Wireless E911 
•	 Phase II required that by October 2001, or within 6 months of receiving a 

request from a PSAP, whichever was later, wireless carriers were to be 

prepared to provide the PSAP with Phase I information plus the latitude 

and longitude coordinates of the caller within certain standards of 

accuracy. 

In 1996, when these rules were established, the technology to accurately 

locate a caller on a mobile telephone had not yet been perfected, but a 

“network based” solution was anticipated. With this type of solution, a 

caller is located through a triangulation process using the closest cell 

towers.11 However, as location technology was being developed, a “handset 

based” solution (i.e., one using the wireless phone itself) was made 

available. The most common handset solution also relies on triangulation, 

but uses Global Positioning System (GPS) satellites and a GPS chip inside 

the handset.12 In recognition of this second solution, FCC issued rules in 

October 199913 for carriers that selected handset-based location 

technologies.14 In August 2000, FCC adopted modifications to its rules for 

handset-based solutions and said that even if a PSAP has not made a 

request for Phase II wireless E911 service, wireless carriers deploying a 

handset-based solution must ensure that by December 31, 2005, 95 percent 

of their customers have mobile phones capable of providing automatic 

location information.15 

A typical wireless 911 call is routed along both wireless and wireline 

networks before terminating at the PSAP. See figure 2 below. While the 

voice call is taking place over the wireless and wireline networks, several 

11Triangulation is a method of locating the source of a radio signal, generally through the use 

of three receivers, or antennas. 

12The most commonly used handset-based solution is “assisted GPS,” in which some of the 

processing is carried out in the network to improve system performance. 

13In the Matter of Revision of the Commission’s Rules to Ensure Compatibility with 

Enhanced 911 Emergency Calling Systems, CC Docket No. 94-102, Third Report and 

Order, FCC 99-245 (released Oct. 6, 1999). 

14A third approach to caller location is known as “enhanced observed time difference of 

arrival,” which is regarded as a hybrid because the required measurements are distributed 

between the handset and the network. 

15In the Matter of Revision of the Commission’s Rules to Ensure Compatibility with 

Enhanced 911 Emergency Calling Systems, CC Docket No. 94-102, Fourth Memorandum 

Opinion and Order, FCC 00-326, (released Sept. 8, 2000). 

Page 8 GAO-04-55 Wireless E911 
Page 9 GAO-04-55 Wireless E911

data queries are simultaneously occurring to determine the caller’s physical 

location and callback number. With wireless callers, the location

information may need to be updated throughout the call to achieve greater 

accuracy or because the caller is moving during the call. 

Figure 2: Wireless E911 Call to PSAP with Phase II Capability

Phase II wireless E911 service is more complex to implement than Phase I 

because of the need to install equipment to determine the geographic 

coordinates of the caller, transfer that information through the telephone 

networks, and have a mapping system in place at the PSAP that can display

the latitude and longitude coordinates of the caller as a map location for 

dispatching assistance. When Phase II location data is unattainable (e.g., 

the handset does not have line of sight to enough GPS satellites to 

determine the caller’s location), most wireless systems default to providing 

Phase I data, including the location of the cell tower and cell sector 

receiving the call.

Sources: GAO; and Nova Development (clipart).

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

Simplified 
The increased complexity of Phase II also makes it more costly than Phase 

I to implement. To date, the federal government has played no role in 

financing the rollout of wireless E911 services. Wireless carriers must 

finance the implementation of a caller location solution and test equipment 

to verify accuracy. LECs are generally responsible for ensuring that all the 

necessary connections between wireless carriers, PSAPs, and databases 

have been installed and are operating correctly. PSAPs purchase telephone 

services from the LECs. Because the typical underlying wireline E911 

network is unable to carry the additional wireless E911 information, PSAPs 

often must purchase a separate data link and connection from the LEC. In 

order to translate the latitude and longitude location information into a 

street address, PSAPs usually purchase and install mapping software. 

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

information. 

In short, three parties—the wireless carriers, LECs, and PSAPs—must 

interconnect and install equipment in order for wireless E911 calls to be 

completed and the caller location information to be sent with the call. 

However, no single entity has regulatory authority and oversight over the 

entire implementation process. FCC has considerable regulatory authority 

over wireless carriers and has placed location accuracy standards and 

deployment deadlines on the wireless carriers. State public utility 

commissions have some authority over wireless carriers’ terms and 

conditions of service. The state public utility commissions also have a great 

deal of authority over the LECs, including authority over intrastate service 

rates, while FCC retains some authority over LEC interconnection 

agreements with wireless carriers and other issues. PSAP readiness 

remains a state and local issue because PSAPs serve an emergency 

response function that has traditionally fallen under state or local 

jurisdiction. The manner in which the more than 6,000 PSAPs across the 

country are administered and funded—at a state, county, city, or other 

political subdivision level—varies from state to state. According to FCC, 

the Commission has no authority to set deadlines for PSAPs’ deployment of 

the equipment they need in order to receive caller location information 

from the wireless carriers. Setting such deadlines on PSAPs would be a 

matter for states and localities. 

Another federal agency with an interest in this issue is DOT. According to 

DOT, its involvement stems from the department’s mandate to handle 

issues of traffic safety and from a directive from the Secretary of 

Transportation to become involved in wireless E911 issues. DOT officials 

noted that wireless phones have become crucial to reporting highway 

Page 10 GAO-04-55 Wireless E911 
accidents and getting ambulances or other assistance to the scene. As will 

be discussed below, DOT is involved in several initiatives to track the 

progress of E911 deployment and help promote wireless E911 services, 

especially at the state and local level. 

As the original Phase II deadline of October 2001 approached, the six large 

national wireless carriers (which provide service to approximately 75 

percent of wireless telephone subscribers) requested waivers because the 

location technology was not ready for implementation. In granting the 

waivers, FCC negotiated different deadlines with each of these carriers, 

based on the carrier-specific Phase II compliance plans. The FCC also 

required these carriers to file detailed quarterly reports regarding 

implementation. In July 2002, FCC also granted temporary relief from the 

Phase II deadlines to those non-nationwide midsize and small wireless 

carriers that had requested relief.16 Currently, all wireless carriers that have 

chosen to deploy a handset-based location solution remain under a 

deadline of having handsets containing location technologies in use by 95 

percent of subscribers by December 31, 2005. Yet, despite this deadline, 

Phase II service is not assured in any area by any specific date. This is 

because all wireless carriers must respond within 6 months to a PSAP 

request for the delivery of wireless E911 location information.17 PSAPs, 

however, are under no federal deadlines to ever request wireless E911 

services. Thus, the full rollout of wireless E911 services nationwide 

depends in great part on the implementation efforts of the more than 6,000 

PSAPs. 

16On October 10, 2003, the FCC issued a six-month stay of applicable provisions of E911 

rules, or until it decides on the merits, whichever is shorter, with regard to all pending 

petitions of small wireless carriers seeking relief. In the Matter of Revision of the 

Commission’s Rules to Ensure Compatibility with Enhanced 911 Emergency Calling 

Systems, CC Docket No. 94-102, Order to Stay, FCC 03-241 (Oct. 10, 2003). 

17Under FCC rules, however, a wireless carrier and a PSAP can mutually agree to a time 

frame other than a 6-month response. 47 C.F.R. §20.18(j)(5). 

Page 11 GAO-04-55 Wireless E911 
Nationwide Phase I 

Deployment Is More 

Than Halfway 

Complete, but Full 

Phase II Deployment 

May Be Years Away 

Based on the best data that is available, nearly 65 percent of PSAPs across 

the nation have implemented Phase I and 18 percent have implemented 

Phase II with at least one wireless carrier providing location information. 

However, there is still a lack of information regarding how many of the 

more than 6,000 PSAPs will need to upgrade their equipment, making it 

difficult to accurately measure the progress of wireless E911 

implementation. Looking forward, our survey of state 911 contacts found 

that less than half of them believe that wireless E911 services will be fully 

in place in their state by 2005. This raises the prospect that E911 

implementation will be piecemeal both within states and across the nation 

for an indefinite number of years to come. 

Eighteen Percent of PSAPs 

Have Implemented Phase II, 

but Measuring Progress 

toward Full Deployment Is 

Hampered by Data 

Problems 

Currently, the single best information source for tracking the progress 

being made in deploying wireless E911 service at the local level comes 

from DOT and the National Emergency Number Association (NENA). DOT 

contracted with NENA to create a database of counties and the PSAPs 

within the counties to provide information about implementation of 

wireless E911. This database is updated every quarter using wireless 

carrier information filed with the FCC, and supplemented by data gathered 

directly from PSAPs. Prior to the creation of this database, the only 

national data available about PSAPs that existed comprised information 

about NENA’s membership, and that information did not include all PSAPs 

or track E911 deployments. Thus, the DOT/NENA initiative has provided a 

key instrument for measuring wireless E911 implementation. 

According to NENA, as of October 2003, nearly 65 percent of PSAPs 

nationwide had implemented Phase I wireless E911 services, which 

provides the call taker with the callback number and the location of the cell 

tower and cell sector receiving the 911 call. Phase II, which locates the 

caller with more precise geographic coordinates, has been implemented 

with at least one wireless carrier in 18 percent of PSAPs. As part of our 

survey of state 911 contacts, we asked respondents about their states’ 

progress on Phase I and Phase II deployments. The responses to our survey 

were not complete because some state contacts were uncertain about their 

Page 12 GAO-04-55 Wireless E911 
state’s current status.18 However, for the 33 states and the District of 

Columbia from which we did receive responses, we found that percentages 

for Phase I and Phase II implementation were consistent with NENA’s data. 

The percentages of counties that have implemented wireless Phase I and 

Phase II E911 service are illustrated, by state, in figure 3. The percentages 

are based on GAO’s analysis of NENA data as of October 2003. 

18The state contacts were taken from a list provided on FCC’s Web site. The names were 

provided to FCC by the governor of each state. However, not all state contacts were actively 

involved in E911 issues, and some could provide only limited responses to our questions. We 

did speak with others suggested by the state contacts in some of our surveys. See appendix 

I for more information about our survey. 

Page 13 GAO-04-55 Wireless E911 
Page 14 GAO-04-55 Wireless E911

Figure 3: Percentage of Counties, by State, That Have Implemented Wireless E911

Phase I and Phase II as of October 2003

Note: As of October 2003, the District of Columbia had not implemented Phase I or Phase II.

Phase I

Phase II

30 percent or less of counties have implemented wireless E911

More than 30 percent but less than 60 percent of counties have implemented wireless E911

60 percent or more of counties have implemented wireless E911

Source: GAO analysis of NENA data.
Measuring the progress of wireless E911 implementation against the goal of 

full nationwide Phase II deployment depends on being able to compare the 

number of PSAPs that are receiving wireless Phase II location data with the 

universe of PSAPs that need to be upgraded. We found, however, that there 

is a lack of accurate information on the total number of PSAPs that need to 

be upgraded. NENA has determined that there are 6,143 PSAPs nationwide. 

However, this number includes both “primary” and “secondary” PSAPs. A 

primary PSAP is defined by NENA as a PSAP to which 911 calls are directly 

routed; a secondary PSAP only receives calls that have been transferred, or 

passed along, from a primary PSAP. Generally, primary and secondary 

PSAPs have been included in the total number of PSAPs that need to be 

capable of receiving wireless E911 information. 

However, our survey results of state 911 contacts, along with our case 

study interviews, indicate that some states do not plan to upgrade their 

secondary PSAPs. For example, in North Carolina, state statute only 

permits primary PSAPs to be funded for wireless E911; in Kentucky, 

Virginia, and Washington, state funds to help finance wireless E911 

upgrades are only available to primary PSAPs; in Maryland, the issue is 

currently under discussion, although consolidating secondary PSAPs with 

primary ones has been considered. In addition, some secondary PSAPs are 

so small that they may never need wireless E911 equipment. Currently, the 

DOT/NENA database does not differentiate between PSAPs that will need 

to be upgraded and those that will not, which limits usefulness of the 

database in accurately assessing progress toward full wireless E911 

implementation. 

For its part, FCC requires large and midsize wireless carriers that have filed 

for relief from deployment deadlines to provide information quarterly on 

their progress in implementing Phase I and Phase II. Until recently, the data 

submitted by the carriers and available from FCC were organized by 

carrier, not by state or county, and were not easily sorted to provide 

information concerning the status of wireless E911 deployment. However, 

as of August 1, 2003, FCC also began requiring the large and midsize 

wireless carriers to submit data in an electronic spreadsheet format 

regarding deployment of Phase I and Phase II by PSAP. Because this 

spreadsheet has several fields, including the state, researchers can search 

by field and have numerous options for organizing the data. In addition, 

small wireless carriers, which had also requested relief, also were required 

to file one interim report with FCC about their E911 progress on August 1, 

2003. Based on the August filings, FCC told us that most of the large and 

Page 15 GAO-04-55 Wireless E911 
midsize carriers appear to be making good progress toward readying their 

networks to respond to PSAP requests for E911 services. 

State 911 Contacts Offered a 

Wide Range of Estimated 

Phase II Completion Dates 

In our survey of state 911 contacts (which included the District of 

Columbia), we asked respondents to provide us with an estimate of when 

they believed their state would have wireless Phase II E911 fully in place 

for at least one wireless carrier per PSAP. Twenty-four of 51 respondents 

said they thought Phase II would be fully in place in their state by 2005, the 

last year for which there is any specific FCC deadline on wireless carriers. 

Six of those 24 respondents said they would be ready by 2003. Contacts in 

other states were either unwilling to commit to any specific year, given 

their current level of implementation, or estimated a date in 2006 or 

beyond. See figure 4. 

Figure 4: Estimates by State 911 Contacts of Year Their State Would Have Phase II 

Wireless E911 Fully Implemented (Includes the District of Columbia) 

Number of respondents 

18 

16 

16 

14 

12 

10 

8 

6 

4 

2 

0 

10 

8 

11 

6 

2003 2004 2005 2006 Unable to 

or later estimate 

Estimated year 

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

Page 16 GAO-04-55 Wireless E911 
As the estimates from state contacts indicate, no clear picture is emerging 

on when Phase II will be fully deployed nationwide, raising the prospect of 

piecemeal availability of this service across the country for an indefinite 

number of years to come. 

Funding and 

Coordination Are Key 

Factors Affecting 

Current Wireless E911 

Deployment, with New 

Wireless Services 

Posing Future 

Challenges 

As of October 2003, NENA estimates that over the next 5 years the 

nationwide cost to deploy Phase II will be between $8 billion and $9 billion, 

including capital and incremental operating expenses. Funding for PSAP 

equipment upgrades remains a major issue for many states and localities 

and continues to hamper nationwide deployment. Not all states have 

implemented a funding mechanism for wireless E911, and of those that 

have, some have redirected E911 funds to unrelated uses. In addition, poor 

coordination among the parties is a factor affecting wireless E911 

deployment, although some states and localities have eased this problem 

with active and knowledgeable state 911 coordinators who help oversee 

the process and work with all the parties. Technologically, the main hurdle 

of developing wireless location equipment for mobile phones has been 

solved, but the continuing emergence of new wireless devices and services 

has the potential to overburden the current 911 infrastructure. 

Ongoing Problems with 

State and Local Funding of 

Equipment Upgrades Are 

Hampering the Deployment 

of Wireless E911 

It is costly to implement wireless E911 services. PSAPs need money to 

upgrade their systems and equipment and to purchase new software to 

receive and display caller location information. Wireless carriers incur 

costs associated with handset and network upgrades, engineering design, 

upgrading hardware and software, and maintaining the system. The LECs 

also incur costs, but generally these are paid for by the PSAPs as they 

purchase 911 services and upgrades from the LECs. Currently, funding 

must come from sources other than the federal government, which has not 

provided funding to PSAPs or wireless carriers for wireless E911 or 

established guidelines on how wireless E911 should be funded. 

Page 17 GAO-04-55 Wireless E911 
At present, it is up to state and local governments to determine how to pay 

for PSAP wireless E911 upgrades. To cover the costs associated with 

implementing wireless E911, responses to our survey showed that the 

majority of states (39 states plus the District of Columbia) require wireless 

carriers to collect funds from their subscribers through a surcharge 

included on subscribers’ monthly wireless phone bills.19 The amount of the 

surcharge is usually determined by the state; responses to our survey 

showed the surcharges ranged from 5 cents to $1.50 per month. Generally, 

the wireless carriers submit the funds to the states, and the states have the 

discretion to determine how the funds will be managed. For example, some 

states have established E911 boards that oversee the funds, while other 

states allow the funds to be managed at the county or PSAP level. Methods 

of disbursement also varied. Some states allocated wireless E911 funds to 

PSAPs based on their jurisdictional population, while some based it on the 

number of wireless subscribers in the jurisdiction. Other states evenly 

divided the funds among counties or PSAPs. 

Although the majority of states have established some type of funding 

mechanism, problems with funding PSAP equipment upgrades persist. For 

example, NENA maintains that many communities are not in a position to 

implement wireless E911 service because funds collected for E911 

deployment are not being allocated for that purpose. Our survey of state 

E911 contacts found that 13 states and the District of Columbia had used 

wireless E911 funds for expenditures unrelated to wireless E911 

implementation, and 9 other states had attempted to do so. For example, in 

one state, more than $40 million was taken from the E911 fund for 

unrelated purposes, and an additional $25 million is expected to be taken in 

2004. The state contact said that if the redirection of funds continues, it 

would bring E911 upgrades to a halt. Another state E911 contact told us 

that the use of some E911 funds for other purposes had hindered the ability 

of PSAPs to purchase necessary computer upgrades and mapping software. 

In another state, funds had not been redirected to other purposes, but the 

E911 funds were “frozen” by the state’s legislature and could not be used by 

the PSAPs to implement Phase II. The state E911 coordinator told us that 

the state’s E911 fund had sufficient monies to implement Phase II 

statewide, but many PSAPs could not move forward until the state’s 

19Three other states had a wireless E911 funding mechanism in place, but did not impose 

surcharges on wireless subscribers. To pay for wireless E911 implementation, one state 

used funds from general revenue, one used funds from the state’s Universal Service Fund, 

and one state used funds collected for wireline 911. 

Page 18 GAO-04-55 Wireless E911 
legislature allocated funds for E911 initiatives, and it was unclear when or 

if that would occur.

20 

In addition to the redirection of E911 funds, our survey of state contacts 

found that eight states have never instituted a statewide system for 

collecting funds for wireless E911 purposes. In one state, for example, any 

fee or tax proposed to be placed on the public must be approved by the 

state’s voters, and legislation creating an E911 funding mechanism did not 

receive voter approval. The state’s E911 contact told us that the proposed 

legislation would have generated sufficient funds for deploying wireless 

E911 statewide, but without the funding, most counties in the state will not 

have Phase II implemented by 2005. Some of the other eight states have 

experienced opposition to E911 funding because it is perceived as a tax; 

another state has not addressed the issue of wireless E911 implementation 

at all. 

Another funding issue raised by survey respondents and by others we 

interviewed was that rural PSAPs in particular face funding problems for 

E911. For example, some states allocate funds to the PSAPs based on their 

jurisdictional population, which may cause PSAPs serving small or rural 

communities in those states to receive insufficient funds to implement 

E911. While many of the costs involved in purchasing upgraded equipment 

and mapping software are similar for PSAPs serving large and small 

communities, PSAPs that receive fewer E911 funds because of their 

smaller population base may not have adequate funds to purchase the 

necessary equipment and software. Two wireless carriers told us that 

numerous PSAPs they serve had either withdrawn or suspended their 

request to wireless carriers for Phase II service because of funding 

constraints. 

Wireless carriers also incur various costs to implement E911. For example, 

two wireless carriers told us they had spent about $50 million each to date 

to deploy E911, and three others said their costs would exceed $100 million 

each. Several of the small wireless carriers we interviewed in our case 

studies said that funding E911 technologies is particularly difficult for them 

20Legislation introduced in the U.S. Senate and House of Representatives would provide 

annual grants to states and localities to improve emergency communications (see S.1250, 

108th Cong., 1st Sess. (2003); H.R. 2898, 108th Cong., 1st Sess. (2003)). Both bills would require 

states and localities to match the grants provided by the federal government and would 

prohibit federal grant monies from being awarded to states that redirect funds collected 

specifically for E911 initiatives to nonemergency communication uses. 

Page 19 GAO-04-55 Wireless E911 
because of their limited revenues and that raising their rates would risk 

their competitiveness in the market. While FCC requires wireless carriers 

to implement E911, the Commission has not mandated as a prerequisite to 

implementation that the carriers be reimbursed for their E911 expenses.21 

Although responses to our survey showed that 32 states and the District of 

Columbia allow wireless carriers to recover their E911 costs from the state 

funding mechanism, state E911 contacts sometimes reported that it might 

be difficult for the carriers to recoup all of their E911 costs.22 For example, 

some states only allow the wireless carriers to be reimbursed if funds were 

appropriated for that purpose, and other states told us that only certain 

wireless carrier expenditures could be reimbursed. The wireless carriers 

we contacted said it was unlikely that all of their costs would be fully 

recovered, especially since cost recovery mechanisms are not available in 

all states. One wireless carrier told us that in some states, the E911 

surcharges imposed on customers do not generate sufficient revenue to 

pay for both PSAP and carrier costs incurred in E911 deployment. Another 

wireless carrier said that some states make it so difficult for the wireless 

carrier to recover its costs that the carrier will not even attempt to get 

funds from those states. Since it is unlikely that all E911 implementation 

costs can be recovered through the states, several of the wireless carriers 

we contacted have chosen to charge their subscribers an additional 

monthly fee to help pay for E911 costs. 

Problems with Coordination 

Continue to Slow Wireless 

E911 Deployment 

As noted earlier, the deployment of wireless E911 systems requires 

wireless carriers, LECs, and PSAPs to work together in distinct yet 

interdependent roles. However, according to some contacts we 

interviewed, delays sometimes occur because the various parties have 

difficulty coordinating their activities or working together. There was no 

consistency across the interviews as to which party (or parties)—wireless 

carriers, LECs, or PSAPs—was most hindering wireless E911 deployment. 

The difficulties in coordination between the parties at times caused 

frustration, according to some contacts we interviewed. For example, 

representatives from two of the PSAPs we contacted noted that just 

21Initially, FCC said wireless carriers were not required to provide E911 service unless a cost 

recovery mechanism was in place, but FCC reversed this decision in November 1999. 

22A representative from one PSAP told us that some wireless carriers might not seek to 

recoup costs incurred with deploying E911 if they plan to use the location technologies for 

commercial purposes. 

Page 20 GAO-04-55 Wireless E911 
determining the number of wireless carriers providing service in their 

PSAP’s jurisdiction can be difficult. One PSAP administrator told us that in 

order to get a complete list of providers before sending out his request 

letters for Phase I, a PSAP employee drove around the county to identify 

the cell tower owners and contacted them to obtain the names of the 

wireless carriers leasing space on the towers.23 The PSAP administrator 

noted as well that tracking down the right contact person at the wireless 

carrier was difficult. 

In another example, representatives from several wireless carriers said that 

some PSAPs had requested E911 service from the wireless carriers even 

though the PSAPs’ call centers were not yet ready to receive caller location 

information because the proper equipment had not yet been installed. This 

might occur because some PSAPs fail to understand what is required of 

them technologically and what tasks they need to complete prior to 

requesting E911 service. Traditionally, PSAP administrators have focused 

on public safety and emergency response, not telecommunications. The 

complexity of implementing wireless E911, however, has forced PSAP 

administrators to become telecommunications project managers and to 

learn about the technology involved. 

We also were told that LECs have contributed to implementation delays. 

One PSAP representative told us that difficulties encountered with the LEC 

were a major obstacle to implementing wireless E911 and that the LEC 

delayed installing lines necessary for wireless E911 for 4 months, which 

greatly slowed the process. Because of continuing problems with the LEC 

in this location, the PSAP purchased its own call routing equipment. 

Similarly, another PSAP representative told us the main obstacle they faced 

in implementing E911 was working with the LEC. The PSAP representative 

noted that no one contemplated the role the LEC would play in the 

implementation of E911 and that this has led to problems and delays. A 

number of stakeholders we interviewed believed that FCC needs to be 

more involved with the LECs to ensure they are an active player in wireless 

E911 implementation. For example, an official representing a public safety 

association stated that FCC should closely monitor the role that the LECs 

play in wireless E911 implementation and should employ its oversight role 

23According to FCC, PSAPs can find wireless carrier licenses that serve their area from 

FCC’s Universal Licensing System database. However, FCC stated that it might be difficult 

to link the name of the licensee to the name under which the actual operating carrier does 

business. The FCC database is available via its Web site at http://wireless.FCC.gov/uls/. 

Page 21 GAO-04-55 Wireless E911 
to facilitate corrective action to expedite wireless E911 compliance. 

Several of those we interviewed in our case studies suggested that FCC 

take on greater enforcement of the LEC role in E911 implementation, and 

perhaps consider placing deadlines on LECs to respond to PSAP requests 

for E911 upgrades. According to FCC, the Commission does not have clear 

jurisdiction over wireline carriers with regard to wireless E911 

implementation, and the Commission looks to the state public utility 

commissions, which have clear and sufficient authority to take the lead. 

However, FCC has indicated that it is committed to monitoring the LECs’ 

implementation role to ensure that they are meeting their responsibilities 

with regard to E911 deployment.24 

In response to these problems with coordination, many industry 

representatives and affected parties we contacted noted that a strong, 

knowledgeable state E911 coordinator was the key to helping to coordinate 

the parties and successfully implement wireless E911 services within the 

state. Many believed that those states with strong state E911 coordinators 

had made the most progress with wireless E911 implementation. These 

state coordinators perform tasks such as 

• educating PSAPs about their wireless E911 responsibilities, 

• providing technical assistance to PSAPs, 

•	 bringing all parties together early on to discuss implementation issues 

and providing a single point of contact for all the parties, and 

•	 lobbying for E911 funding and protecting the funding from being used 

for purposes unrelated to wireless E911 implementation. 

Besides voicing support for effective state coordinators, those we 

interviewed provided several illustrations of actions their states were 

taking to facilitate wireless E911 implementation:25 

24In the Matter of Revision of the Commission’s Rules to Ensure Compatibility with 

Enhanced 911 Emergency Calling Systems, Petition of City of Richardson, Texas, CC 

Docket 94-102, Order on Reconsideration, FCC 02-318 (released Nov. 26, 2002). 

25In addition to efforts by state officials to improve coordination, several public safety and 

industry associations have worked to provide information and assistance with wireless 

E911 implementation. 

Page 22 GAO-04-55 Wireless E911 
•	 Several parties we spoke with mentioned that they had had a conference 

call or meeting early on between the wireless carrier, LEC, and PSAP to 

talk through the process and try to identify problems. 

•	 Kentucky requires all PSAPs to go through a certification process with 

the state board to ensure preparedness for both wireline and wireless 

E911 implementation. This certification process was created to 

establish an overall uniformity for the state’s PSAPs. By using a 

checklist for upgrades and an inspection process, Kentucky expects all 

of its PSAPs that go through the certification process will be Phase II 

operational by January 2005.26 

•	 California purchases equipment at the state level to create advantages in 

negotiating contracts with vendors and to create economies of scale in 

equipment purchases. 

•	 Indiana has an elected official in charge of funding, which provides for 

greater visibility of the E911 issue in the state and helps protect against 

redirection of E911 funds to other uses. 

•	 Virginia contracts with several technical consulting firms for wireless 

E911 implementation. The PSAPs are allowed to use contractors from 

this pool and can use the wireless E911 funding they receive from the 

state to pay for contractors’ services. This arrangement provides needed 

technical assistance for PSAPs while allowing greater oversight of the 

contractors. 

Early Problems with 

Location Technology 

Appear Resolved, but 

Technical Challenges 

Remain Regarding New 

Wireless Devices and 

Services 

During our interviews, we were told that the basic technology for 

accurately determining the location of a wireless caller and systematically 

providing that data to PSAPs has now been developed. Some noted that 

although occasional problems still arise due to a particular wireless 

carrier/LEC/PSAP equipment configuration, these problems are lessening 

as the parties gain experience with E911 implementation. A representative 

of one LEC noted that the “challenging years” of coordinating 

interconnection between the LEC and the wireless carrier seem to be 

behind them and that implementation now generally tends to proceed more 

smoothly. 

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

Page 23 GAO-04-55 Wireless E911 
We asked the officials we interviewed what they saw as the remaining 

technical issues affecting wireless E911 implementation. Several parties 

mentioned a variety of technical problems that might slow wireless E911 

implementation or affect the quality of 911 services in general. Problems 

that were mentioned include the following: 

•	 Because the United States never adopted a single standard for mobile 

phone transmissions, the different systems used by wireless carriers are 

not always compatible with one another, which can affect the ability of a 

particular subscriber to reach 911 in the first place if they do not have a 

phone that can be used with multiple systems. 

•	 While GPS can provide more accurate location data, concerns exist over 

the time it takes for location data to be calculated and delivered to the 

PSAP. In the context of an emergency call, even a wait of 10 or 20 

seconds for the location data to be processed is considered a loss of 

valuable time. 

•	 For rural wireless carriers that have selected a network-based solution, 

cell towers often are placed in a straight line and spaced widely apart 

along highways or other roads. This can make the determination of 

location difficult because the towers cannot accurately triangulate the 

location of the caller. Additionally, the handset-based solution may not 

be immediately available due to equipment issues. 

Another problem was raised by some of those we interviewed: the 

antiquated wireline 911 infrastructure that conveys many E911 calls from 

the wireless carrier to the PSAP. This issue was also raised by Dale 

Hatfield, former chief of FCC’s Office of Engineering and Technology. In 

2001, FCC asked Mr. Hatfield to conduct an inquiry into the technical and 

operational issues associated with wireless E911 deployment. His October 

2002 report to FCC noted that the wireline 911 network is fundamentally 

unchanged since its inception in the 1970s and that the existing 911 

infrastructure “is in no condition to accommodate the pervasive use of 

wireless technologies, the Internet, or the many other product offerings 

that invite or demand access to 9-1-1 services.”

27 Those offerings include 

27Dale N. Hatfield, A Report on Technical and Operational Issues Impacting the Provision 

of Wireless Enhanced 911 Services, prepared for the FCC (Oct. 15, 2002), Docket No. 02-46, 

pp. 13-14, quoting SCC Communications Corp., 9-1-1 Networks in the 21st Century—The 

Case for Competition (Feb. 20, 2001), p. 2. 

Page 24 GAO-04-55 Wireless E911 
new wireless technologies that could send E911 calls (e.g., automatic crash 

notification systems on cars that would also be able to send information to 

the 911 call taker about whether air bags have deployed or whether the car 

has flipped over), and the 911 services may need to be expanded to 

encompass such technologies. Many of those with whom we spoke 

believed that such new technologies should be considered now, rather than 

later. Some were critical of the LECs’ failures to upgrade to modern digital 

technologies that would facilitate the rollout of wireless E911 technologies 

and improve 911 services. FCC released a notice of proposed rulemaking to 

reevaluate the scope of communications services that should provide 

access to 911 and has received comments and reply comments from 

interested parties.

28 NENA is also trying to address the issue of new 

technologies and of a “future path plan” for the 911 network.29 

The Recent Actions of 

FCC and DOT Are 

Focused on Enforcing 

Deadlines on Wireless 

Carriers and Improving 

Deployment 

Coordination 

FCC and DOT have been involved in the implementation of wireless E911, 

but federal authority in overseeing the deployment is limited because of the 

traditional state and local jurisdiction over emergency response services. 

The primary federal agency involved in wireless E911 deployment is FCC. 

One of FCC’s goals is to ensure the wireless carriers comply with their 

current implementation schedules. As noted earlier, FCC in the past had 

granted waivers to many of the wireless carriers in order to give them more 

time to resolve technical issues associated with developing wireless 

location technologies. Because many of these hurdles have now been 

overcome, FCC has stated that it will not hesitate to use its enforcement 

power when the wireless carriers fail to meet their current deployment 

timetables. For example, FCC officials noted that three wireless carriers 

agreed to pay nearly $4 million to the U.S. Treasury for failure to comply 

with intermediate deadlines in their E911 deployment timetables. 

28See In the Matter of Revision of the Commission’s Rules to Ensure Compatibility with 

Enhanced 911 Emergency Calling Systems, CC Docket 94-102, Further Notice of Proposed 

Rulemaking, FCC 02-326 (released Dec. 20, 2002). 

29NENA is working to develop a plan for aggressively managing the technical evolution of 

the overall 911 system and emergency communications process in ways that serve local and 

national emergency needs. This technical plan will seek to provide a long-term direction for 

911 to support new call sources (such as text messaging devices) and needs. 

Page 25 GAO-04-55 Wireless E911 
Beyond enforcing deadlines on wireless carriers, FCC has taken actions to 

identify both roadblocks and best practices in wireless E911 

implementation. For example, the Hatfield report made a number of 

findings regarding obstacles to wireless E911 implementation. Those 

findings involve wireless carrier implementation issues, cost recovery and 

PSAP funding issues, and the lack of comprehensive stakeholder 

coordination. Public comment was sought on the report in late 2002 and, 

according to FCC, the Commission is currently considering both the 

recommendations contained in the report and the comments received.30 

FCC also conducted its first Enhanced 911 Coordination Initiative meeting 

in April 2003. The meeting brought together representatives from the 

federal government, the public safety community, wireless carriers, LECs, 

and other interested stakeholders to share experiences and devise 

strategies for expediting wireless E911 deployment. According to FCC, 

lessons learned from the initiative include the following: 

•	 Strong leadership and vision are essential to ensure swift wireless E911 

deployment. 

•	 State or regional points of contact are critical for prompt wireless 

carrier deployment. 

•	 Wireless E911 in rural areas may pose additional challenges such as 

financial hurdles and accuracy concerns.

31 

30In his report to the FCC, Mr. Hatfield recommended that a national 911 program office be 

established within the Department of Homeland Security. He also recommended that FCC 

(1) maintain or even increase its oversight of the rollout of wireless E911 services; (2) 

establish an advisory committee to address the development and evolution of E911 systems 

and services; (3) continue to urge the creation of organizations at the state, regional, and 

local levels to coordinate the rollout of wireless E911; (4) encourage the creation of a 

national clearinghouse to collect, store, and disseminate wireless E911 information; (5) 

actively coordinate with and support DOT’s Wireless E911 initiative and other efforts; (6) 

continue to support the efforts of the Emergency Services Interconnection Forum to 

address the issues of PSAP readiness; (7) work closely with individual state and regulatory 

commissions and their association, the National Association of Regulatory Utility 

Commissioners, in resolving issues relating to LEC cost recovery and pricing; and (8) urge 

stakeholders to develop industrywide procedures for testing and certification of wireless 

E911 to ensure that they meet the accuracy requirements in FCC rules. Mr. Hatfield also 

made several other recommendations relating to technical, regulatory, and consumer issues. 

31Near the end of our review, FCC announced that they would be conducting another 

Wireless E911 Coordination Initiative to be held October 29-30, 2003. 

Page 26 GAO-04-55 Wireless E911 
Additionally, in August 2003, FCC announced the establishment of a 

wireless E911 technical group to focus on network architecture and 

technical standards issues. The group will be a subcommittee of the 

Commission’s Network Reliability and Interoperability Council. Also in 

August 2003, FCC announced a wireless E911 public awareness campaign 

emphasizing coordination, outreach, and education. One of the first 

outcomes of the campaign was an FCC advisory published for consumers 

providing information on what people need to know about calling 911 from 

a mobile phone. A copy of this consumer advisory is found in appendix II of 

this report. 

DOT also has efforts under way to promote wireless E911 implementation, 

focusing on implementation issues at the state and local level. DOT 

partnered with NENA to develop a Wireless Implementation Plan. One 

major aspect of this plan is the creation of a clearinghouse of wireless E911 

planning, implementation, and operations resources. The clearinghouse is 

an attempt to gather and organize the best examples of information from 

various states, work groups, and ongoing development efforts. The 

clearinghouse also includes various forms used by parties across the nation 

in implementing E911 agreements. As discussed earlier, another major 

component of DOT’s efforts is the sponsorship of a PSAP database (under 

contract with NENA) that tracks the current status of wireless E911 

implementation across the country.

32 

DOT also convened a Wireless E911 Steering Council33 to develop a Priority 

Action Plan, released in May 2003, that outlines six priorities for wireless 

E911 implementation: 

1.	 Establish support for statewide coordination of wireless E911 

technology, and identify points of contact within each state for each of 

the stakeholders. 

2.	 Help to convene stakeholders in appropriate 911 regions in order to 

facilitate more comprehensive, coordinated implementation of wireless 

location technologies. 

32Links to the clearinghouse and the database are available on DOT’s Web site. See 

http://www.itspublicsafety.net/wireless.htm. 

33The Wireless E911 Steering Council includes leaders of the telecommunications, public 

safety, and highway safety communities. 

Page 27 GAO-04-55 Wireless E911 
3. Examine cost recovery and funding issues at the state level. 

4.	 Initiate a knowledge transfer and outreach program to educate PSAPs, 

wireless carriers, and the public about wireless location issues. 

5.	 Develop a coordinated deployment strategy encompassing both rural 

and urban areas. 

6.	 Implement a “model location program” to identify and isolate potential 

barriers to wireless E911 deployment. 

Work on implementing this plan was in its early stages at the time we 

concluded our review. However, DOT had subdivided each priority into a 

number of action items, identified lead agencies or associations for each 

action item, and established a time frame for completion of each action 

item. 

FCC and DOT staff told us that the agencies coordinate their wireless E911 

activities to avoid duplication of effort. An FCC representative attends DOT 

meetings and events on wireless E911 to stay current with the department’s 

activities; similarly, a DOT representative attends FCC meetings and 

initiatives on wireless E911. DOT officials noted that their efforts have 

been concentrated on providing assistance at the PSAP level since FCC has 

authority over the wireless carriers and LECs. While the agencies do not 

currently jointly staff or fund any wireless E911 projects, FCC officials 

noted that more formalized coordination is possible in the future. 

Conclusions	 Without the readiness of all parties—wireless carriers, LECs, and PSAPs— 

there can be no wireless E911 service. Efforts by FCC to monitor the 

progress of the wireless carriers in meeting their timetables and take 

enforcement actions, as warranted, will continue to be an important part of 

the implementation process. Still, given current E911 funding and 

coordination problems related to upgrading PSAPs at state and local levels, 

the pace of wireless E911 deployment could be similar to what happened 

with wireline E911, which took many years to implement nationwide. If this 

holds true, consumers and emergency management officials will be faced 

with a geographic patchwork of wireless E911 areas: Some will have 

service; some will not. As Americans travel across the country, they will be 

uncertain as to whether their 911 calls will convey their location. However, 

successful wireless E911 deployment is possible, as illustrated in some 

areas of the country. States and localities can benefit from the experiences 

Page 28 GAO-04-55 Wireless E911 
and best practices of others and adapt them to their own situations. 

Continued efforts by the FCC, DOT, and the public safety community to 

identify and publicize these successes will be a valuable means of 

facilitating the deployment. 

During this transition period, it is important to accurately measure 

progress in wireless E911 deployment so that federal, state, and local 

officials can assess whether problems are arising in parts of the country 

that may require additional actions. This information would also help build 

public awareness of where this service is available and may stimulate 

action at the state and local level. Measuring the progress of wireless E911 

implementation against the goal of full nationwide Phase II deployment 

depends on being able to compare the number of PSAPs that are receiving 

wireless Phase II location data with the total number of PSAPs that need to 

be upgraded. We found, however, that there is a lack of information on the 

total number of PSAPs that need to be upgraded. While FCC and DOT have 

taken important actions to track wireless E911 deployment, additional 

work is needed to create reliable data on how many of the more than 6,000 

PSAPs will need to be upgraded. 

Recommendation for 

Executive Action 

In order to provide the Congress and federal and state officials with an 

accurate assessment of the progress being made toward the goal of full 

deployment of wireless E911, we recommend that the Department of 

Transportation work with state-level E911 officials, the National 

Emergency Number Association, and other public safety groups to 

determine which public safety answering points will need to have their 

equipment upgraded. This information should then be reflected in the 

PSAP database managed by NENA under contract with DOT. This will 

provide the baseline needed to measure progress toward the goal of full 

nationwide deployment of wireless E911 service. 

Agency Comments	 We provided a draft of this report to DOT and FCC for review and 

comment. DOT stated that it generally agreed with our recommendation, 

and FCC offered some technical comments that we incorporated into the 

report where appropriate. 

As agreed with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 14 days after the 

Page 29 GAO-04-55 Wireless E911 
date of this letter. At that time, we will send copies to interested 


congressional committees; the Chairman, FCC; the Secretary, Department


of Transportation; and other interested parties. We also will make copies 


available to others upon request. In addition, this report will be available at 


no cost on the GAO Web site at http://www.gao.gov. If you have any 


questions about this report, please contact me at (202) 512-6670 or


goldsteinm@gao.gov. Key contacts and major contributors to this report 


are listed in appendix III.


Sincerely yours,


Mark L. Goldstein


Director, Physical Infrastructure Issues


Page 30 GAO-04-55 Wireless E911 
Appendix I 

Scope and Methodology


To provide information on the progress made in deploying wireless E911 

services throughout the country, we conducted a telephone survey of the 

state E911 contacts. We completed surveys for 50 states and the District of 

Columbia. We pretested the questions with five state contacts from states 

we had spoken with earlier in our research. We revised the survey as 

appropriate based on responses during pretesting. For each state and the 

District of Columbia, we began by contacting the person named on the 

FCC’s Web site at http://www.fcc.gov/911/stateplans/contacts.html as the 

point of contact for that state.1 In 25 states, the person named on FCC’s 

Web site did complete the survey. In the remainder of our surveys, we were 

directed to another person. The survey contained 17 questions about the 

state’s progress in implementing Phase I and Phase II, problems 

encountered, funding mechanisms in place, and the role of the state 

coordinator or any state offices involved in wireless E911 implementation. 

The questions were open-ended and were read to the respondents. Surveys 

were completed between June 11 and September 12, 2003. In addition to 

our survey results, we used data from the National Emergency Number 

Association (NENA) to illustrate the progress of wireless E911 

implementation as of October 2003. To assess the reliability of NENA’s data 

regarding information on total costs to upgrade PSAPs to Phase II 

readiness and the number of PSAPs receiving Phase II data as of the August 

1, 2003, FCC quarterly filings, we interviewed knowledgeable officials from 

NENA about their data collection methods and reviewed any existing 

documentation relating to the data sources. We determined that the data 

were reliable enough for the purposes of this report. 

To provide information on the factors affecting wireless E911 rollouts 

across the country, we selected nine states (California, Idaho, Indiana, 

Kentucky, Maryland, Missouri, South Carolina, Texas, and Virginia) and the 

District of Columbia for case studies. We selected states that were spread 

geographically across the U.S. and that appeared to be having various 

levels of success with wireless E911 implementation based on early 

research. In particular, we selected at least one rural state and at least one 

state known to have redirected funds collected for E911 implementation to 

other uses. For each case study, we interviewed (in person or by telephone) 

1

These names were provided to FCC by the governor of each state in response to a request 

from FCC’s Chairman. FCC did not list a contact person for the states of Wisconsin and 

Oklahoma, so we obtained a contact name from NENA for these two states. We also did not 

receive a response from the contact for New York and completed the New York survey with 

a person suggested by NENA. 

Page 31 GAO-04-55 Wireless E911 
Appendix I


Scope and Methodology


the state coordinator, a small wireless carrier serving that state,2 and one 

urban PSAP and one rural PSAP within the state.3

 In addition to our case 

studies, we interviewed representatives from four public safety 

associations and two wireless industry associations. We interviewed 

representatives from five large national wireless carriers and received 

written responses to our questions from a sixth large national wireless 

carrier. We also interviewed representatives from six local exchange 

carriers and one manufacturer of mobile phones. 

To provide information on current federal government actions to promote 

the deployment of wireless E911 services, we spoke with officials at FCC 

and DOT about their involvement in wireless E911 implementation. We 

reviewed relevant orders, filings, and other materials from FCC docket 

number 94-102 on E911 implementation. We researched relevant materials 

from both FCC and DOT, such as DOT’s Priority Action Plan. We attended 

FCC’s daylong Enhanced 911 Coordination Initiative in April 2003. 

Statistics presented in the first paragraph of the report are from the 

Cellular Telecommunication & Internet Association, unless otherwise 

noted. Statistics presented in the first paragraph of the background section 

are from NENA. All of these statistics are presented for background 

purposes and were not verified by GAO. 

We conducted our review from January 2003 through October 2003 in 

accordance with generally accepted government auditing standards. 

2

For purposes of our case studies, a small wireless carrier was considered any wireless 

carrier other than the six large nationwide wireless carriers (AT&T Wireless, Cingular, 

Nextel, Sprint, T-Mobile, and Verizon Wireless). 

3

There were some exceptions to our case study formula. The District of Columbia has only 

one PSAP and has no small wireless carriers. California has no rural PSAPs that take 

wireless calls. Instead, we interviewed the California Highway Patrol, which handles most 

of the wireless 911 calls in California. Lastly, we were unable to schedule an interview with a 

small wireless carrier serving the state of Missouri. 

Page 32 GAO-04-55 Wireless E911 
Appendix II 

FCC Consumer Advisory about Calling 911 

from Your Wireless Phone 

Among other responsibilities, FCC’s Consumer & Governmental Affairs 

Bureau educates and informs consumers about telecommunications 

services. To this end, the Bureau has produced a number of consumer 

alerts and fact sheets. Among these is a new consumer advisory entitled 

“What You Need to Know about Calling 911 from Your Wireless Phone.” 

This consumer advisory is reprinted on the following pages and can be 

accessed at FCC’s Web site at www.fcc.gov/cgb/consumerfacts/e911.html. 

Page 33 GAO-04-55 Wireless E911 
Appendix II


FCC Consumer Advisory about Calling 911 


from Your Wireless Phone


Page 34 GAO-04-55 Wireless E911 
Appendix II


FCC Consumer Advisory about Calling 911 


from Your Wireless Phone


Page 35 GAO-04-55 Wireless E911 
Appendix III 

GAO Contacts and Staff Acknowledgments


GAO Contacts	 John Finedore, (202) 512-6248 

Faye Morrison, (202) 512-6448 

Andy Clinton, (214) 777-5616 

Staff 	 In addition to those named above, Michele Fejfar, Deepa Ghosh, Sally 

Moino, Mindi Weisenbloom, Alwynne Wilbur, and Nancy Zearfoss made key Acknowledgments contributions to this report. 

(545026) Page 36 GAO-04-55 Wireless E911 
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