911 SERVICES

Most States Used 911 

Funds for Intended 

Purposes, but FCC 

Could Improve Its 

Reporting on States’ 

Use of Funds

Report to Congressional Committees

April 2013

GAO-13-376

United States Government Accountability Office

GAO
 

United States Government Accountability Office

Highlights of GAO-13-376, a report to

congressional committees

April 2013

911 SERVICES

Most States Used 911 Funds for Intended Purposes, 

but FCC Could Improve Its Reporting on States’ Use 

of Funds

Why GAO Did This Study

Wireless E911 service refers to the 

capability of 911 call takers to 

automatically receive location 

information from 911 callers using 

mobile phones. The current E911 

system is not designed to 

accommodate emergency 

communications from the range of new 

technologies in common use today that 

support text, data, and video. Although 

deploying wireless E911 and NG911 is 

the responsibility of state and local 

governments, FCC is required by law 

to report annually on the funds states 

collect to provide 911 services such as 

E911. The Next Generation 911 

Advancement Act of 2012 required 

GAO to review states’ collection and 

use of 911 funds. In this report, GAO 

presents information on (1) progress 

implementing wireless E911 in the last 

decade, (2) states’ collection and use 

of 911 funds and the usefulness of 

FCC’s reporting on this issue, and (3) 

challenges to implementing NG911

services and federal efforts to facilitate 

its deployment. GAO reviewed FCC’s 

annual reports, states’ responses to 

FCC’s information-collecting efforts, 

and documents from FCC and DOT 

regarding E911 and NG911. GAO 

reviewed best practices for collecting 

and analyzing data and interviewed 

federal and state officials and other 

stakeholders. 

What GAO Recommends

FCC should follow best practices for 

data collection and analysis to improve 

its current method of collecting and 

reporting information on state 911 

funds. In response, FCC concurred 

with GAO’s recommendation and 

agreed to take action to address it.

What GAO Found

Although states faced challenges and delays in the past, states have made 

significant progress implementing wireless Enhanced 911 (E911) since 2003. 

Wireless E911 deployment usually proceeds through two phases: Phase I

provides general caller location information by identifying the cell tower or cell 

site that is receiving the wireless call; Phase II provides more precise callerlocation information, usually within 50 to 300 meters. Currently, according to the 

National Emergency Number Association (NENA), nearly 98 percent of 911 call 

centers, known as Public Safety Answering Points (PSAPs), are capable of 

receiving Phase I location information, and 97 percent have implemented Phase 

II for at least one wireless carrier. This represents a significant improvement

since 2003 when implementation of Phase I was 65 percent and Phase II was 18 

percent. According to NENA’s current data, 142 U.S. counties (representing 

roughly 3 percent of the U.S. population) do not have some level of wireless 

E911 service. The areas that lack wireless E911 are primarily rural and tribal

areas that face special implementation challenges, according to federal and 

association officials. 

According to data collected by the Federal Communications Commission (FCC), 

all 50 states and the District of Columbia reported collecting—or authorizing local 

entities to collect—funds for wireless E911 implementation, and most states

reported using these funds for their intended purpose. Six states—Arizona, 

Georgia, Illinois, Maine, New York, and Rhode Island—reported using a total of 

almost $77 million of funds collected for 911 implementation for other purposes

(e.g., transferring 911 funds to the general fund) in 2011. Using funds in this way 

is permissible by state law in these states, but it creates the risk of undermining 

the credibility of 911 fees in those states. The manner in which FCC collects and 

reports information on state 911 funds limits the usefulness of its annual report. 

In particular, contrary to best practices for collecting and analyzing data, FCC 

uses only open-ended questions to solicit information from states, lacks written 

guidelines for interpreting states’ responses and ensuring that results can be 

reproduced, and does not describe the methodology used to analyze the data it 

collects. As a result, FCC is missing an opportunity to analyze trends and to 

provide more detailed aggregated information that would be useful to decision

makers.

Next Generation (NG911) will enable the public to reach PSAPs through voice 

and data, such as text messages, but stakeholders have identified a variety of 

technical, regulatory, and funding challenges to implementing it. For example, 

many of the existing state and federal regulations governing 911 were written 

before the technological capabilities of NG911 existed. The federal government 

is taking steps to help states address challenges. In particular, the Department of 

Transportation (DOT) has focused on research through the NG911 Initiative, and

FCC released a 5-point plan to encourage NG911 implementation. FCC’s plan 

includes (1) developing location accuracy mechanisms for NG911; (2) enabling

consumers to send text, photos, and videos to PSAPs; (3) facilitating the 

completion and implementation of NG911 technical standards; (4) developing a 

governance framework for NG911; and (5) developing a funding model for 

NG911. FCC also released a report in March 2013 that detailed specific 

recommendations to Congress for a legal and regulatory framework for NG911. 

View GAO-13-376. For more information, 

contact Mark Goldstein at (202) 512-2834 or 

goldsteinm@gao.gov.
Page i GAO-13-376 Use and Reporting of 911 Funds

Letter 1 

Background 4

States Have Made Significant Progress Implementing Wireless 

E911 9

According to FCC’s Reporting, Some States Have Used 911 Funds 

for Other Purposes, but FCC’s Reporting Could Be More Useful 14

Although NG911 Is in Preliminary Stages and Faces Challenges, the 

Federal Government Is Supporting NG911 Activities 24

Conclusions 28

Recommendation for Executive Action 29

Agency Comments 29

Appendix I Objectives, Scope, and Methodology 31

Appendix II Comments from the Federal Communications Commission 34

Appendix III GAO Contact and Staff Acknowledgments 36

Tables

Table 1: Current 911 versus NG911 Capabilities 8

Table 2: PSAP Progress Implementing Wireless E911 since 2003, as 

of March 2013 9

Figures

Figure 1: Simplified Routing of a Wireless Enhanced 911 Call to a 

Public Safety Answering Point 6

Figure 2: Percentages of Each State’s Counties and the District of 

Columbia That Have Completed Phases I and II of 

Wireless E911, as of December 2012 13

Contents 
Page ii GAO-13-376 Use and Reporting of 911 Funds

Abbreviations

CSRIC Communications Security, Reliability, and Interoperability 

Council 

DNP did not provide

DOT Department of Transportation

E911 Enhanced 911 

FCC Federal Communications Commission

IP Internet Protocol 

NENA National Emergency Number Association

NET 911 Act New and Emerging Technologies 911 Improvement Act of 

2008 

NG911 Next Generation 911

NHTSA National Highway Traffic Safety Administration 

NTIA National Telecommunications and Information 

Administration 

PSAP Public Safety Answering Point 

USDA Department of Agriculture 

VoIP Voice-over-Internet Protocol 

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

United States. The published product 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 1 GAO-13-376 Use and Reporting of 911 Funds

United States Government Accountability Office

Washington, DC 20548

April 18, 2013

The Honorable John D. Rockefeller IV

Chairman

The Honorable John Thune

Ranking Member

Committee on Commerce, Science, and Transportation

United States Senate

The Honorable Fred Upton

Chairman

The Honorable Henry A. Waxman

Ranking Member

Committee on Energy and Commerce

House of Representatives

Knowing the 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, response services need to 

be able to automatically identify the caller’s location, such as in the case 

of a 911 caller who cannot speak because he is suffering a heart attack or 

a caller reporting an accident along a highway who does not know the 

exact location. Basic 911 service provided Americans with an easily 

remembered universal number that connects the caller to an emergency 

response center. Enhanced 911 (E911) service is a technological 

improvement that automatically provides the street address and callback 

number of a wireline caller or, in the case of wireless E911, the 

approximate geographic location of the mobile phone used to place a 911 

call and the callback number of the person calling. The continuing 

evolution of communications technologies and wireless phones has 

implications for 911 services. Since 911 call centers predominantly use 

older, analog-based infrastructure and equipment, the current E911 

system is not designed to accommodate emergency communications 

from the range of new technologies in common use today, including text 

and picture messaging and Voice-over-Internet Protocol (VoIP) telephony 

(e.g., Skype). In response to changing technologies, the Department of 

Transportation (DOT) launched the Next Generation 911 (NG911) 

Initiative, which has focused on the research required to develop an 

NG911 system. With NG911 services, the public could reach 911 call 

centers through various modes, including voice and data, and transmit 

multi-media information such as video. Deploying and operating wireless 

E911 (and NG911 going forward) is the responsibility of government 

 
 

Page 2 GAO-13-376 Use and Reporting of 911 Funds

entities at the state, county, or local level, although the federal 

government has taken steps to facilitate the nationwide deployment.

The Federal Communications Commission (FCC) is required by law1 to 

report to Congress on the identity of the states, territories, or political 

subdivisions (such as counties or localities) that collect taxes, fees, or 

other charges2 for emergency communications such as E911. This 

reporting includes the amount of those revenues used for purposes other 

than the ones specified by the state’s method of funding 911. FCC has 

been preparing these mandated reports since 2009 based on states’ 

responses to FCC’s public notices seeking relevant information. 

Hereafter, we will refer to states, territories, and political subdivisions as 

“states.” The Next Generation 911 Advancement Act of 2012 mandated 

that we review states’ collection and use of 911 funds.3

To address these issues, we analyzed county and state-level E911 

implementation information collected by the National Emergency Number 

To provide 

context for our review, we also examined the progress of E911 

implementation and federal efforts in this area. This report presents 

information on (1) the progress that has been made in implementing 

wireless E911 in the last decade, (2) the extent to which states are 

collecting and using 911 funds for 911 purposes and the usefulness of 

FCC’s annual reports on states’ 911 funds, and (3) challenges to 

implementing NG911 services and federal efforts to facilitate its 

deployment.

 

1

New and Emerging Technologies 911 Improvement Act of 2008 (NET 911 Improvement 

Act of 2008), Pub. L. No. 110-283, § 101, 112 Stat. 2620, 2621, codified at 47 U.S.C. § 

615a-1(f)(2). FCC is required to report to the Committee on Commerce, Science and 

Transportation of the Senate and the Committee on Energy and Commerce of the House 

of Representatives. 

2

FCC uses a variety of terms including fund(s), fee(s), surcharge(s), charge(s), and 

tax(es) in its report, though it uses mostly fund(s), with many instances of fee(s). States 

use fee(s) and surcharge(s); most often, though, they also use charge(s) and tax(es). For 

simplicity, we will use fund(s) whenever possible. When referring directly to FCC’s report, 

we will use fee(s) and charge(s) as that is the report’s title. When reporting information 

provided by states, we use the term used by each state.

3

Pub. L. No. 112-96, 126 Stat. 156 (2012).
 

Page 3 GAO-13-376 Use and Reporting of 911 Funds

Association (NENA) as of December 2012,4 reviewed our previous 

reports on wireless E911 implementation,

5 analyzed FCC’s 2010 through 

2012 annual reports on state collection and distribution of 911 and E911 

fees and charges,6 reviewed states’ responses to FCC’s informationcollecting effort associated with these reports, and analyzed comments 

submitted by government, industry, and association officials in response 

to FCC’s public notice on NG911. In assessing the usefulness of FCC’s 

reporting, we reviewed best practices set forth in our previous reports.7

To determine the reliability of the data used in FCC’s annual reports, we 

reviewed relevant documentation, and interviewed cognizant officials 

about their processes for reviewing the data and ensuring their accuracy. 

We determined that the NENA E911 implementation data and, with 

certain exceptions subsequently noted in this report, the information 

related to FCC’s reports to Congress are sufficiently reliable for the 

purposes of this report. We gathered further information from state 

officials in the states that reported using E911 funds for other purposes 

during calendar year 2011: Arizona, Georgia, Illinois, Maine, New York, 

and Rhode Island.8

 

4

NENA is a professional organization solely focused on 911 policy, technology, 

operations, and education issues. NENA has more than 7,000 members in 48 chapters 

across North America and around the globe and promotes the implementation and 

awareness of 911 and international three-digit emergency communications systems.

We interviewed officials associated with a Texas 

NG911 pilot project and visited Illinois, where we interviewed officials 

from the state 911 office, officials associated with a regional NG911 

5 See GAO, Telecommunications: States' Collection and Use of Funds for Wireless 

Enhanced 911 Services, GAO-06-338 (Washington, D.C.: Mar. 10, 2006); and 

Telecommunications: Uneven Implementation of Wireless Enhanced 911 Raises Prospect 

of Piecemeal Availability for Years to Come, GAO-04-55 (Washington, D.C.: Nov.7, 2003). 

6

FCC’s reports cover state activities from the previous calendar year. For example, FCC’s 

2012 report covers state activities for the calendar year ending December 31, 2011. We 

did not review FCC’s 2009 report and related state reports because we determined that 3 

years would be sufficient for our purposes and because the 2009 report was FCC’s first 

report on the subject and as such was more prone to start-up issues that would impede 

our purposes for using this information.

7

GAO, Content Analysis: A Methodology for Structuring and Analyzing Written Material, 

GAO/PEMD-10.3.1 (Washington, D.C.: September 1996); and Developing and Using 

Questionnaires, GAO/PEMD-10.1.7 (Washington, D.C.: October 1993). 

8

Guam also reported using 911 funds for other purposes in 2011. We contacted Guam 

officials and asked for further information in writing, but Guam did not respond to our 

request for information. We also attempted to contact states and territories that did not 

respond to FCC’s information requests, but they also did not respond to us.
 

Page 4 GAO-13-376 Use and Reporting of 911 Funds

project, and representatives from rural counties in southern Illinois that 

have not begun E911 implementation. We chose to visit Illinois because 

stakeholders mentioned its regional NG911 project and because the state 

had reported using E911 funds for other purposes in its 2010, 2011, and 

2012 reports to FCC. We interviewed Texas officials with responsibility for 

the state’s NG911 pilot project because Texas received the largest 911 

grant from the National Telecommunications and Information 

Administration (NTIA) and National Highway Traffic Safety Administration 

(NHTSA) and because stakeholders mentioned that the state was making 

progress on implementing NG911. We selected these states for the 

specific reasons noted above and the information we obtained is not 

generalizable to any other states. We also interviewed officials from FCC, 

DOT, and the Department of Agriculture (USDA) as well as 

representatives from associations including NENA, the National 

Association of State 911 Administrators, the Association of Public-Safety

Communications Officials, the Competitive Carriers Association, and 

CTIA-The Wireless Association.

We conducted this performance audit from July 2012 to April 2013 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. Further details on our scope 

and methodology can be found in appendix I.

Nationwide implementation of E911 by local wireline telephone 

companies began in the 1970s. With wireline E911 service, emergency 

calls are automatically routed to the appropriate 911 call center, and the 

call taker receives the telephone number and street address of the caller. 

In 1996, FCC adopted rules for wireless E911. Wireless E911 technology 

provides emergency responders with the location and callback number of 

a person calling 911 from a mobile phone. Implementing wireless E911 

involves deploying technologies that are able to calculate the geographic 

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

coordinates as a location the call taker can understand. When a wireless 

caller dials 911, the call must be routed along the networks of both a 

wireless telephone company and a wireline telephone company before 

terminating at a call center, known as a Public Safety Answering Point 

(PSAP). There are more than 6,000 PSAPs nationwide, often at a county 

or city level. PSAPs vary in size and technical sophistication. Some large 

Background 
 

Page 5 GAO-13-376 Use and Reporting of 911 Funds

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.

As shown in figure 1, the wireless carriers, local exchange carriers, 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. 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 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. 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. As a result, states and local jurisdictions establish 

timetables for implementation by their PSAPs and fund the equipment 

upgrades needed by their PSAPs for E911 service.
 

Page 6 GAO-13-376 Use and Reporting of 911 Funds

Figure 1: Simplified Routing of a Wireless Enhanced 911 Call to a Public Safety Answering Point

The only federally mandated time frames for implementing wireless E911 

technologies are those placed on wireless carriers by FCC. 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.9

 

9

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

Emergency Calling Systems, Report and Order and Further Notice of Proposed 

Rulemaking, 11 FCC Rcd 18676 (1996).

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, 
 

Page 7 GAO-13-376 Use and Reporting of 911 Funds

generally within 50 to 300 meters (Phase II information).10 As we reported 

in 2006, most states and the District of Columbia collect fees to cover the 

costs of implementing wireless E911.11 States collect fees on a variety of 

telecommunications services including wireline, wireless, “prepaid 

wireless,”12

DOT has recognized the relationship between wireless E911 services and 

highway safety and, in 2001, contracted with NENA to develop a 

state/county database that tracks E911 implementation. As part of the 

contract, NENA created a database of counties, including information 

about implementation of wireless E911, which is updated with data 

gathered directly from state and county representatives. Now completely 

funded by NENA, the database is accessible through 

and VoIP.

http://www.nena.org. 

The New and Emerging Technologies 911 Improvement Act of 2008 

(NET 911 Act) requires FCC to submit an annual report to Congress 

detailing the status in each state of the collection and distribution of fees 

or charges for the support or implementation of 911 or E911 services to 

ensure transparency and accountability. The annual reports are to include 

findings on the amount of revenues obligated or expended by each state 

or political subdivision thereof for any purpose other than the purpose 

specified in the state or local law adopting the fee or charge.13

 

10See 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. 

FCC has 

submitted four reports to Congress covering the state activities of 

calendar years 2008 to 2011. In addition, the National 911 Program—

11GAO-06-338. 

12“Prepaid wireless” service is any wireless telecommunications service that is activated in 

advance by payment for a finite dollar amount of service or for a finite number of minutes 

that terminate either upon use by any person or within a certain period of time following 

the initial purchase or activation, unless an additional payment is made.

13Pub. L. No. 110-283, § 101, codified at 47 U.S.C. § 615a-1(f).
 

Page 8 GAO-13-376 Use and Reporting of 911 Funds

housed within NHTSA’s Office of Emergency Medical Services—has 

helped to provide federal leadership and coordination in supporting and 

promoting optimal 911 services."14

Because of changes in the public’s use of communications technology 

and the aging infrastructure of the legacy 911 network, 911 services are 

transitioning to an NG911 system that uses Internet Protocol (IP)-based 

technology to deliver and process 911 traffic. Such a system will provide 

increased capabilities as shown in table 1. With NG911, PSAPs are 

expected to be able to process all types of emergency communications 

including voice, data, and video. According to NENA, Emergency 

Services IP Networks are among the basic building blocks required for 

NG911. They are managed, multipurpose networks that support public 

safety communications services and use broadband technology capable 

of carrying voice plus large amounts of data using Internet protocols and 

standards. As part of the NG911 Initiative, DOT has created an NG911 

system design and tested it to show that the design will be capable of 

accommodating communications from a wider range of devices including 

cellular calls, instant messaging, wireline calls, “telematics” (automatic 

crash notification data directly from the vehicle), VoIP calls, and live video 

feeds.

Table 1: Current 911 versus NG911 Capabilities

Current 911 capabilities Expected NG911 capabilities

Virtually all calls are voice callers via 

telephones over analog lines 

Voice, text, or video information, from many 

types of communication devices, sent over IP 

networks 

Callers routed through legacy selective 

routers, limited forwarding/backup ability

Callers routed automatically based on 

geographic location, enhanced backup 

abilities

Limited ability to handle overflow 

situations, callers could receive a busy 

signal 

PSAPs able to control call congestion 

Source: GAO presentation of DOT Information.

In September 2009, NHTSA and NTIA announced more than $40 million 

in grants to help PSAPs implement E911 and NG911 technologies. To be 

eligible for the program, the applicant had to certify that the state and 

 

14The fiscal year 2012 budget for the National 911 Program was $1.25 million.
 

Page 9 GAO-13-376 Use and Reporting of 911 Funds

other taxing jurisdictions within the state had not used designated E911 

funds for any other purpose than for which they were designated within 

180 days preceding the application date.15 The grant period concluded at 

the end of 2012. In all, NHTSA and NTIA awarded grants ranging from 

$200,000 to $5.4 million to 30 states and territories to help implement 

NG911 services.16

http://www.911.gov

NHTSA officials told us that they are currently 

conducting an evaluation of the grant program and that they will release a 

final report on . 

Although states faced challenges and delays in the past, they have made 

significant progress implementing wireless E911. According to NENA 

data as of March 2013, 98 percent of PSAPs are capable of receiving 

Phase I location information and 97 percent have implemented Phase II 

for at least one wireless carrier.17 This represents a significant 

improvement in implementation since our previous reports in 2003 and 

2006 as shown in table 2.18

Table 2: PSAP Progress Implementing Wireless E911 since 2003, as of March 2013

Phase I implementation Phase II implementation a

March 2013

a

98 percent 97 percent

January 2006 80 percent 57 percent

October 2003 65 percent 18 percent

Source: NENA data.

a

According to NENA data, 142 U.S. counties (representing roughly 3 

percent of the U.S. population) do not have some level of wireless E911 

Percentages reflect the percent of PSAPs that have implemented each phase for at least one 

wireless carrier.

 

1547 U.S.C. § 942(c)(2). Grantees were also required to agree that, as a condition of the 

grant, if the state or other taxing jurisdictions within the state used 911 funds for any other 

purpose than for which they were designated during period the grant period, the grantee 

would return all grant funds. 47 U.S.C. § 942 (c)(3). 

16Arizona was awarded a grant but later became ineligible because 911 funds were 

transferred to the general fund during the grant period. 

17NENA does not maintain E911 implementation data on U.S. territories or political 

subdivisions. 

18GAO-04-55 and GAO-06-338. 

States Have Made 

Significant Progress 

Implementing 

Wireless E911
 

Page 10 GAO-13-376 Use and Reporting of 911 Funds

service. According to federal and association officials, these areas are 

primarily rural or tribal counties that face special challenges implementing 

wireless E911 service. According to the National 911 Program, rural 

agencies may lack the funding resources needed for technology 

upgrades, equipment, and training. Rural and tribal areas typically are 

large geographically but less densely populated than urban areas. In 

addition, because it may take first responders longer to reach the scene 

of an emergency, call-takers in PSAPs serving rural areas may be 

required to stay on the phone longer with callers or provide more 

extensive emergency instruction to callers until help arrives. Furthermore, 

federal and local officials told us about the following specific challenges 

facing rural and tribal areas:

• Tribal lands face special challenges related to 911 services because 

of several barriers to improving telecommunications on tribal lands. 

We have previously reported that the barriers to improving 

telecommunications on tribal lands most often cited by tribal officials, 

service providers, and others we spoke with were the rural, rugged 

terrain of tribal lands and tribes’ limited financial resources.19 These 

barriers increase the costs of deploying infrastructure and limit the 

ability of service providers to recover their costs, which can reduce 

providers’ interest in providing or improving telecommunications 

services. Other barriers include the shortage of technically trained 

tribal members and providers’ difficulty in obtaining rights of way to 

deploy their infrastructure on tribal lands.

• The limited emergency response resources typical of rural areas can 

be relatively quickly overwhelmed in disasters or large-scale incidents, 

according to the National 911 Program. For example, officials from 

rural counties in one state told us that their PSAPs were overwhelmed 

with multiple calls following a recent derailed train incident. These 

calls paralyzed their 911 systems and prevented other 911 calls from 

reaching the PSAPs during the incident.

• According to FCC officials, network-based “triangulation”—a solution 

used by some wireless carriers to determine a caller’s location—

depends on the ability of three cell towers to access the caller’s 

 

19See GAO, Telecommunications: Challenges to Assessing and Improving 

Telecommunications for Native Americans on Tribal Lands, GAO-06-189, (Washington, 

D.C.: Jan. 11, 2006).
 

Page 11 GAO-13-376 Use and Reporting of 911 Funds

mobile device.20 Network-based triangulation can be particularly 

challenging in rural areas that have fewer cell towers than more 

densely populated areas.

• According to rural officials in one state we contacted, some homes in 

rural areas do not have addresses and some streets do not have 

names. Before E911 can be implemented in these areas, addresses 

will have to be created and mapping of those addresses will have to 

be completed so that automated location services can be provided.

Providing E911 services is primarily a state and local government 

responsibility, but USDA has programs that are available to help rural and 

tribal areas gain access to wireless E911 services. On September 12, 

2011, USDA adopted a final rule that described program eligibility 

requirements for a 911 Access Loan Program to make loans and loan 

guarantees to finance the construction of interoperable, integrated public 

safety communications networks in rural areas.21 These networks offer 

several advantages, including the ability to precisely locate rural wireless 

911 calls. Funds for this program are available through the Rural Utilities 

Service’s traditional Telecommunications Infrastructure Loan Program.22

 

20FCC’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 GPS satellites and a GPS chip inside 

the mobile phone.

In addition, USDA’s Community Facilities Program supports essential 

infrastructure and services for public use in rural areas of 20,000 in 

population or less. Financing for community facilities projects covers a 

broad range of interests, including health care, education, public safety, 

and public services. A USDA official said that this program could be used

in a variety of ways to help rural areas gain access to wireless E911, 

21See 77 Fed. Reg. 15564 (March 16, 2012).

22The Telecommunications Infrastructure Loan Program makes long-term direct and 

guaranteed loans to qualified organizations for the purpose of financing the improvement, 

expansion, construction, acquisition, and operation of telephone lines, facilities, or 

systems to furnish and improve telecommunications service in rural areas. All facilities 

financed must be capable of supporting broadband services. For more information on this 

program, see http://www.rurdev.usda.gov/utp_infrastructure.html, last accessed March 4, 

2013. 
 

Page 12 GAO-13-376 Use and Reporting of 911 Funds

including constructing PSAPs or providing the necessary equipment, 

software, computer networks, and power supplies.23

Even though some rural and tribal counties do not have wireless E911 

service, almost 97 percent of the overall population has some Phase I 

wireless coverage and approximately 98 percent has some Phase II 

wireless coverage, according to NENA data. Furthermore, as shown in 

figure 2, 25 states and the District of Columbia have fully implemented 

wireless E911 Phase I and Phase II in all counties.

 

23For more information on this program, see

http://www.rurdev.usda.gov/Community_Development.html, last accessed March 14, 

2013. 
 

Page 13 GAO-13-376 Use and Reporting of 911 Funds

Figure 2: Percentages of Each State’s Counties and the District of Columbia That Have Completed Phases I and II of Wireless 

E911, as of December 2012

Note: Based on NENA data as of December 2012, however, all NENA data are not updated at the 

same time. County information is updated individually whenever NENA receives new information 

about a change in implementation status for the county. If a county gains access to Phase I or Phase 

II wireless E911 service and does not inform NENA of the change, it may not be reflected in their 

data. NENA periodically checks with county officials in counties that have not fully implemented 

wireless E911 for status updates.
 

Page 14 GAO-13-376 Use and Reporting of 911 Funds

As we reported in 2006, all 50 states and the District of Columbia 

collect—or have authorized local entities to collect—funds for 911.24 State 

methods for collecting funds vary in structure, fee amounts, and services 

covered, among other things. For example, some states collect fees or 

charges for 911 and administer a statewide 911 program. Other states 

authorize local entities to collect fees or charges for 911 and to administer 

911 programs at the local level. Still other states use a combination of 

these approaches. However, some local jurisdictions have not begun 

collecting 911 funds even though they are authorized by their state to do 

so.25

Overall, in response to FCC’s request that states report the total amount 

of 911 funds collected in calendar year 2011, 43 states reported 

collecting—or authorizing local entities to collect—a total of about $2.3 

billion, although because of how this information was collected, the actual 

Representatives from a rural county with a population under 5,000 

told us that their county had not begun collecting 911 funds—even though 

they have state authorization to do so—because they would have had to 

collect $10 per line per month to obtain enough funding to implement 

E911.

 

24GAO-06-338. 

25For example, in Nevada, which authorizes local jurisdictions to collect funds for 911, 

only 6 of the 18 local entities that responded to FCC’s information-collecting effort collect 

funds for 911. 

According to FCC’s 

Reporting, Some 

States Have Used 911 

Funds for Other 

Purposes, but FCC’s 

Reporting Could Be 

More Useful

State Methods for 

Collecting 911 Funds
 

Page 15 GAO-13-376 Use and Reporting of 911 Funds

amount collected may be higher.26 States also reported a range of fees 

collected. For example, states reported wireline and wireless fees ranging 

from $0.08 to $5.00 per customer per month.27

According to FCC’s report, most states reported using 911 funds for 

purposes consistent with their funding statutes in 2011.28 In addition to 

spending 911 funds on implementing wireless E911 service, states and 

localities use 911 funds for operations, maintenance, personnel, and 

NG911 preliminary activities, among other things. However, six states—

Arizona, Georgia, Illinois, Maine, New York, and Rhode Island—reported 

using almost $77 million29 of funds collected for E911 implementation for 

other purposes in 2011, as detailed below.30

 

26FCC is mandated to complete this report on state 911 funds, but the mandate does not 

flow through to the states. FCC can only request that states report. Two states did not 

submit a report to FCC. Six states that did report to FCC did not provide any dollar amount 

of funds collected. For example, Arkansas and Oklahoma reported that at least some local 

entities collect funds but did not provide any information about the amount collected. 

Further, one state reported collecting funds at both the state and local level, but did not 

provide any information on the amount collected. Of the states that did provide dollar 

amounts collected, some states specifically stated that funds collected at the local level 

were not included in the amount reported. For example, New York reported over $190 

million in funds collected at the state level, but did not provide any information about the 

amount of funds collected at the local level. Furthermore, several states specified that the 

amount provided was an estimate.

State laws permit using 

funds for these purposes. 

27Not all states reported the fees or charges for 911 in terms of a dollar amount. For 

example, some states reported that the fees were based on the percentage of the phone 

bill. The range reported here reflects the answers from 21 states that reported a dollaramount statewide fee on wireline service, from 31 states that reported a dollar-amount 

statewide fee on wireless service, from 17 states that reported a dollar-amount local fee 

on wireline service, and from 12 states that reported a dollar-amount local fee on wireless 

service. 

28With respect to U.S. territories, Guam reported to FCC that it used over $486,000 for 

lease payments for ambulances and for maintenance/repair services for its public safety 

radio communications system. Puerto Rico reported that it used 911 funds only for 911

purposes. The rest of the territories did not respond to FCC’s request for information.

29New York’s response to FCC indicates a transfer of $22.8 million in state fiscal year 

2011–2012 and FCC included this amount in its annual report. However, when we spoke 

with state officials, they stated that $45 million had been transferred in calendar year 

2011.

30In some states, 911 funds are collected and expended at the local level and states are 

unable to assess whether these funds have been used for other purposes. 

States’ Use of 911 

Funds 
 

Page 16 GAO-13-376 Use and Reporting of 911 Funds

• Arizona. The state reported transferring 13 percent (or about $2.2 

million) of funds collected for 911 purposes to its general fund to help 

address the state’s budget crisis. Arizona also transferred 911 funds 

to its general fund in 2009 and 2010. According to state officials, 

these transfers occurred as part of a state budget bill that authorized 

the transfers. Once funds were transferred to the general fund, 

Arizona 911 officials could not be certain how they were spent. An 

Arizona official said that, because of the transfers to the general fund, 

Arizona had to return a $1.25 million grant to NHTSA and NTIA that 

would have been used to help Arizona with its deployment of Phase II 

of wireless E911.

• Georgia. The state reported collecting $13.7 million in 911 fees for 

prepaid wireless phones and did not allocate any of these funds for 

911 use. Georgia also collected fees on prepaid wireless phones in 

2009 and 2010 but did not allocate these funds for 911 use. According

to a written response from a Georgia official, Georgia law does not 

require that these funds be appropriated for 911 purposes. The funds 

were collected and deposited into the state’s general fund in 

accordance with state law.

• Illinois. The state reported legislatively transferring $2.9 million out of 

the state’s 911 fund in state fiscal year 2012, which is funded by a 

statewide fee on wireless subscribers and from which the state makes 

monthly distributions to local 911 authorities. According to state 

officials, these funds were transferred to another fund to maintain that 

fund’s liquidity. Moreover, in calendar years 2010 and 2011, the state 

borrowed $1.4 million and $5.2 million from the state’s fund used to 

reimburse wireless carriers for E911-related expenses, which is also 

funded by the statewide fee on wireless subscribers. These borrowed 

funds were repaid within 18 months, as required by Illinois law.31

• Maine. As part of personnel service reduction initiatives, the state 

reported imposing across-the-board furloughs and benefit reductions 

on state employees, including personnel in the state 911 office, and a 

little less than $25,000 was transferred from the state’s 911 fund to 

the state’s general fund in 2010 and 2011. Because the salaries and 

benefits for employees in the state 911 office are paid for exclusively 

through 911 funds, the funds that went to the state’s general fund for 

 

3130 ILCS 105/5h(b).
 

Page 17 GAO-13-376 Use and Reporting of 911 Funds

the furlough days and benefit reductions constituted using 911 funds 

for purposes other than 911, in accordance with state law according to 

the state’s submission to FCC. As a result, Maine was ineligible for 

911 grant funds from NHTSA and NTIA.

• New York. According to state officials, New York transferred $45 

million from the State Wireless Telephone Emergency Account to the 

state’s general fund, and made similar transfers to the general fund in 

2009 and 2010.32 According to state officials, the transfer of these 

funds, authorized by state statute, did not affect the ability of the state 

to reimburse municipalities for approved 911 expenditures or to 

otherwise support its 911 programs.

• Rhode Island. Per the state’s method of funding 911, as provided for 

in state statute according to state officials, revenues from the state’s 

911 fees are deposited into the state’s general fund, and the 911 

program receives its budget from the general fund. In 2011, 

approximately $17.3 million was collected, but only approximately 

$4.8 million was appropriated for the 911 program leaving about $13 

million in the general fund. Fee revenues were similarly distributed in 

2010 and 2011.

The District of Columbia and Louisiana did not report to FCC on their use 

of 911 fees and charges for calendar year 2011. We made several 

attempts to obtain this information, but officials did not respond to us. 

However, we can provide information from their reports to FCC in 

previous years.

• District of Columbia. The District of Columbia reported to FCC in 2011 

and 2010 on its collection and use of 911 taxes and fees. FCC did not 

report that funds were used for purposes other than 911.

• Louisiana. Louisiana did not submit a report to FCC on its taxes and 

fees in 2010, but did in 2011. In that report, Louisiana did not directly 

state whether funds were used for anything other than 911 purposes, 

and FCC did not report that the state had used funds for other 

purposes.

 

32New York’s response to FCC indicates a transfer of $22.8 million in state fiscal year 

2011–2012, and FCC included this amount in its annual report. However, when we spoke 

with state officials, they stated that $45 million had been transferred in calendar year 

2011.
 

Page 18 GAO-13-376 Use and Reporting of 911 Funds

We have previously reported that misalignment between fees and 

services for which they are charged reduces both equity and economic 

efficiency.33 Moreover, stakeholders in other industries have reported that 

misalignment between the amount of fee collections and expenditures 

undermines the credibility of the fee.34 As states collect funds for 911 

purposes and then use those revenues for other purposes, there is risk of 

confusing stakeholders and members of the public who pay these fees

and undermining the credibility of 911 fees. However, states occasionally 

pass laws allowing the use of 911/E911 fees for non-E911 purposes. 

FCC officials have stated that they do not have the authority to override 

state law in this regard.

We have identified three features of FCC’s approach to collecting and 

reporting information from states that are contrary to best practices set 

forth in our previous reports on data collection and analysis, which have 

limited the usefulness of FCC’s reports. Specifically, in its approach, FCC 

(1) uses only open-ended questions to solicit information from states, (2) 

lacks written guidelines for interpreting states’ responses and ensuring 

that results can be reproduced, and (3) does not describe the 

methodology used to analyze the information in states’ reports.

FCC has used only open-ended questions to solicit information on state 

fees and charges for 911 services. FCC officials stated that they regard 

this approach as the most effective way to elicit responsive information 

from the states because it requires the states to explain their definitions 

and procedures in plain language rather than responding to “yes/no” 

questions or submitting purely quantitative data. We have previously 

reported that while open-ended questions may be unavoidable when 

engaged in exploratory work and can be useful to obtain responses that 

might further clarify the meaning of answers to close-ended questions, 

open-ended questions have several limitations.35

 

33GAO, Federal User Fees: Substantive Reviews Needed to Align Port-Related Fees with 

the Programs They Support, 

When answering openended questions, respondents may provide wide-ranging responses that 

vary and may result in inconsistent information, making it very difficult to 

GAO-08-321 (Washington, D.C.: Feb. 22, 2008).

34GAO, Federal User Fees: A Design Guide, GAO-08-386SP (Washington, D.C.: May 29, 

2008). 

35GAO/PEMD-10.1.7. 

Limited Usefulness of 

FCC’s Reporting

FCC Used Only OpenEnded Questions
 

Page 19 GAO-13-376 Use and Reporting of 911 Funds

consistently and completely tabulate or aggregate responses. Closedended questions, on the other hand, can yield data that may be easier to 

meaningfully track and compare. FCC asks states to report, among other 

things, the amount of 911 fees or charges imposed and the total amount 

collected. States’ responses to this question varied widely and 

respondents often omitted relevant information. For example, some states 

clearly identified the services—wireline, wireless, pre-paid, and VoIP—to 

which fees applied, while other states did not specify the services to 

which fees applied. Because states were not specifically asked whether 

they collected fees for specific services, it is unclear whether these counts 

are inclusive or exclusive of these specific services. If FCC had asked 

closed-ended questions that required respondents to address such 

distinctions, FCC would have been better able to consistently track fees 

for various services over time, which could address matters such as 

whether 911 funding is evolving with changing technology. However, 

since this information has not been asked in a way that it can be tracked, 

trend analysis is not possible.

Moreover, when reporting the total amount of funds collected, states vary 

widely in their manner of reporting. Some states provide a total amount 

without any distinguishing features. Some states break out the amount 

collected by state and local authorities; others break out the amount 

collected by type of service. Some states provide an actual number 

whereas others provide an estimate. Because of the open-ended 

question format, it is nearly impossible to aggregate these results in a 

useful manner. FCC does provide all state responses in an appendix to 

its annual reports, and FCC officials stated that doing this facilitates public 

review and discussion. The inclusion of these state submissions can 

support public review, particularly in examining the relationship among 

responses in a particular state. However, the provision of the state reports 

may not readily lend itself to obtaining specific or discrete types of 

information from the responses to the open-ended questions. For 

example, one item asks whether the state has written criteria regarding 

the allowable uses of the collected funds. This item is embedded in a 

request for multiple pieces of information. If any interested parties wanted 

to know how many states and which ones reported having written criteria, 

they would have to read through all the responses to that item for all 

submitting entities to obtain the information sought. A closed-ended item 

could readily capture which state does and does not have written criteria.
 

Page 20 GAO-13-376 Use and Reporting of 911 Funds

We have previously reported that with open-ended questions, the 

responses are often textual and not easily tabulated, and a process called 

“content analysis” must be used to classify or code the responses.36

We also found that FCC has not been consistent in how it makes certain 

characterizations in its report. For example, we identified three states—

Georgia, Maine, and New York—that provided similar responses each 

year but FCC characterized the responses differently in different years. 

For example, Maine reported that it had transferred funds from the 911 

fund to the general fund in calendar years 2010 and 2011 as part of a 

statewide personnel reduction initiative, as described above. FCC 

characterized Maine as using 911 funds for other purposes in its 2012 

report but not in its 2011 report. In another example, Georgia reported 

that 911 fees on prepaid wireless devices remained in the state’s general 

fund rather than being allocated for 911 use in its 2010, 2011, and 2012 

reports to FCC. FCC identified Georgia as having used funds for other 

purposes in its 2010 and 2012 reports but not in its 2011 report. FCC 

officials acknowledged that these three states should have been identified 

as using funds for other purposes in its 2011 report, but that officials 

corrected this in the 2012 report. However, FCC did not indicate in the 

2012 report that a mistake was made in the 2011 report. A reader who 

As 

part of the process of conducting content analysis, a coding manual 

should be prepared for use by those classifying the responses. A good 

coding manual is viewed as indispensible in ensuring coding of the 

highest quality, and an important measure for judging the quality of a 

content analysis is the extent to which the results can be reproduced. 

However, FCC officials told us that, while they describe the methodology 

used to collect the data from states, they do not have an internal written 

coding manual or similar document that describes how the content of a 

state’s responses are interpreted or coded. FCC officials noted that this 

had not been problematic to date because the same FCC staff members 

had conducted the analysis each year but indicated that development of 

such a manual would be helpful to ensure future continuity. Because 

there is no written documentation on how this analysis was conducted, 

nor the decisions rules that FCC followed in developing its summary 

classification of responses, there is no basis for independently 

reproducing the results of FCC’s analysis.

 

36GAO/PEMD-10.3.1. “Content analysis” is a systematic research method for analyzing 

textual information in a standardized way that allows evaluators to make inferences about 

that information. 

FCC Lacks Written 

Guidelines for Interpreting 

States’ Responses
 

Page 21 GAO-13-376 Use and Reporting of 911 Funds

noted that the states were not listed as having used funds for other 

purposes in the 2011 report, might believe that these states changed their 

practices from one year to the next, when, in fact, the states reported 

essentially the same information each year.

We also identified inconsistent characterizations in FCC’s summary table, 

which indicates whether states used 911 fees or charges for other 

purposes. In 2012, FCC used four ways of coding whether states used 

funds for other purposes—”Yes,” “No,” “No information,” and “DNP” 

(defined in FCC’s report as “did not provide”). However, “DNP” was used 

in three very different circumstances: when the state did not submit a 

report to FCC, such as in Louisiana and the District of Columbia; when 

the state did not provide an answer to the question of whether the state 

used funds for other purposes; or when the state indicated that all or a 

portion of the funds are controlled by local entities and that the state could 

not be certain how the funds were used. As an example of this last case, 

several states indicated that local entities control some expenditure 

decisions, which in some cases received the “DNP” designation, but in 

other cases received the designation “No” or “No information.” If FCC had 

written guidelines for interpreting state responses, it could have ensured 

more consistent characterization of state responses.

According to FCC’s Information Quality Guidelines—which are meant to 

ensure that all data FCC disseminates reflect a level of quality 

commensurate with the nature of the information—quality is 

demonstrated through the incorporation of a methodological section or 

appendix that describes, at a minimum, the design and methods used 

during the creation, collection, and processing of the data, as well as the 

compilation or analysis of the data in products including reports prepared 

for Congress.37

 

37

In its annual reports, FCC included a detailed description 

of its methodology for collecting responses from states. For example, 

FCC describes how, in addition to the public notices, FCC sent letters to 

the Office of the Governor of each state and territory and the Regional 

Directors of the Bureau of Indian Affairs requesting the information sought 

in the public notices. FCC sent second notice letters and placed calls to 

those states and territories that had not responded. However, FCC has 

In the Matter of Implementation of Guidelines for Ensuring and Maximizing the Quality, 

Objectivity, Utility, and Integrity of Information Pursuant to Section 515 of Public Law No. 

105-554, Notice of Information Quality Guidelines: CORRECTED, 17 FCC Rcd 19890

(2002). 

FCC Did Not Report 

Changes in Analysis 

Methodology 
 

Page 22 GAO-13-376 Use and Reporting of 911 Funds

not published its methodology for how the report’s analysis was 

conducted. In particular, FCC has not included in its annual report a 

description of the decision rules used in determining whether a state used 

911 funds for other purposes. As stated in the previous section, FCC 

does not have an internal written procedures manual or similar document 

that describes how the content of a state’s responses are interpreted or 

coded. If FCC had one, it could use information from that coding manual 

to explain its analysis and decision rules in its annual report.

The lack of a description of the methodology for FCC’s analysis is 

particularly problematic as FCC officials told us that FCC changed its 

method of making analysis decisions in its most recent report. FCC 

officials stated that based on their experience with the first three 

information collections and associated reports, FCC revised the questions 

included in their 2012 information request. Specifically, one question was 

modified to elicit specific information on the programs and activities for 

which 911 funds were used along with how those programs and activities 

support 911. According to FCC officials, this modification enabled FCC to 

classify states’ responses with greater accuracy. While FCC’s 2012 report 

clearly states that modifications were made to the questions and each 

annual report includes the questions included in that year’s information 

request, the effects of these changes are not clear to the reader. In some 

cases, this methodological change resulted in differing characterizations 

from reports issued in 2011 to 2012, and it is not clear to the reader 

whether states no longer characterized as having used funds for other 

purposes had changed their practices of using funds for other purposes 

or whether the different characterization was a result of FCC’s change in 

methodology. For example, in FCC’s 2011 report, FCC identified both 

Virginia and West Virginia as states that had used 911 funds for other 

purposes. However, based on the additional information provided by 

these states in 2012, FCC determined that Virginia and West Virginia 

spent 911 funds in accordance with their respective state statutes 

governing 911 funding and therefore were not identified as using funds for 

other purposes. According to FCC officials, in gathering information for 

2012, FCC asked additional questions to identify the specific uses of 

911/E911 funds that were authorized under state law. They also 

characterized a state as using E911 funds for purposes other than E911 

only if the state reported that is used 911/E911 funds for purposes not 

designated by the state’s funding statute. Because FCC has not 

published its methodology for analysis and decision rules for determining 

whether a state used 911 funds for other purposes and further never 

explicitly stated that a different method was used in 2012, this lack of 

disclosure could lead report users to misinterpret the results shown in the 
 

Page 23 GAO-13-376 Use and Reporting of 911 Funds

report. In particular, although it would appear that as time has passed, 

fewer states were using funds for other purposes, at least some of this 

difference is attributable to FCC’s change of methodology.

We have previously reported that results-oriented organizations make 

sure that the information they collect are sufficiently complete and 

accurate to support decision making.38 FCC officials stated that seeking 

narrative responses from each state and publishing those responses 

demonstrate transparency. However, several pages of individual and 

varied responses may have limited usefulness to decision makers, who 

may need high-level descriptions and aggregated information. 

Furthermore, FCC is missing an opportunity to analyze funding trends 

because its method of asking questions does not result in answers that 

can be readily tracked from year to year. FCC is also missing an 

opportunity to provide more detailed aggregated information in its 

reports—such as amounts of fees, services covered, and total amount of 

funds collected—that would be helpful to decision makers who are trying 

to understand current methods of financing 911. FCC officials told us that 

they are seeking comment from stakeholders on FCC’s required annual 

report to Congress, as well as on information provided by states and 

other reporting entities, and that they will use this information to improve 

reporting.39

 

38GAO, Executive Guide: Effectively Implementing the Government Performance and 

Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996).

39See, FCC Seeks Public Comment On Fourth Annual Report To Congress On State 

Collection And Distribution Of 911 And Enhanced 911 Fees And Charges, Public Notice, 

28 FCC Rcd 183 (2013).
 

Page 24 GAO-13-376 Use and Reporting of 911 Funds

To implement NG911 nationwide, states must address technology, 

regulatory, and funding challenges, according to multiple government 

officials. For example, technological changes need to be made at PSAPs 

since existing call centers are incapable of some critical functions, such 

as linking with one another during emergencies. As such, PSAP calls 

currently cannot be transferred so PSAPs have limited means to act as 

back-up for one another when operations in one part of the country 

become overloaded or shut down because of circumstances such as 

hurricane evacuations or wildfires, according to DOT’s Research and 

Innovative Technology Administration. With respect to regulatory 

challenges, current laws and regulations in most states do not effectively 

enable the implementation of new technologies or allow the level of 

coordination and partnerships among government and public safety 

stakeholders, service and equipment providers, PSAPs, and 911 

authorities that is necessary to implement IP-enabled 911 systems, 

according to NHTSA. Moreover, in the National Broadband Plan, FCC 

noted many of the existing state and federal regulations governing 911 

were written before the technological capabilities of NG911 existed and 

have therefore hampered the implementation of NG911.40

 

40FCC, Connecting America: The National Broadband Plan (Washington, D.C.: Mar. 16, 

2010).

For example, 

state, association, and industry officials have expressed concern about 

uncertainty regarding liability protection related to NG911. Stakeholders 

also expressed concerns about funding mechanisms for NG911. State 

revenues from long-established funding methods tied to wireline services 

are decreasing as more consumers disconnect their traditional home 

Although NG911 Is in 

Preliminary Stages 

and Faces 

Challenges, the 

Federal Government 

Is Supporting NG911 

Activities

NG911 Challenges and 

State Activities
 

Page 25 GAO-13-376 Use and Reporting of 911 Funds

phones in favor of wireless devices or other services such as mobile 

VoIP.

Despite NG911 implementation challenges, many states have started 

funding preliminary NG911 activities, and some areas have developed 

regional NG911 projects. For example, in responding to FCC’s data 

collection effort, 33 states reported that expenditure of 911/E911 funds for 

NG911 activities is permissible under current state law. Of these, 16 

states reported that funds had been expended in 2011 for some NG911 

activities including planning, network development, and equipment 

acquisition. As examples of regional NG911 projects, the Counties of 

Southern Illinois Next Generation 911 project has been identified by 

NENA as an early adopter of a regional approach to NG911. The project 

includes connecting 21 PSAPs through an Emergency Service IP 

Network, creating identical data centers in 2 counties, and obtaining 

NG911 equipment and information for a 15-county region in southern 

Illinois. Similarly, the state of Texas is conducting an NG911 project that 

is partially funded with federal grants from NHTSA and NTIA. The project 

involves constructing a detailed geospatial database of over 200 Texas 

counties that will be needed for a statewide NG911 system. The database 

should allow the new system to pinpoint the PSAP that needs to respond 

to a caller based on location.

Even though 911 services remain primarily a state and local government 

responsibility and NG911 overall is in the early planning stages, FCC is 

working with federal, state, and private sector partners to help states 

address NG911 implementation challenges. For example, one of FCC’s 

federal advisory committees—the Communications Security, Reliability, 

and Interoperability Council (CSRIC)—makes recommendations to FCC 

to promote reliable 911 service and issued a report in March 2011 

framing the transitional issues to NG911.41

 

41CSRIC Working Group 4B, Transition to Next Generation 9-1-1: Final Report, 

(Washington, D.C.: March 2011).

CSRIC members are selected 

from public safety agencies, consumer or community organizations or 

other nonprofit entities, and the private sector. FCC also released a 5-

point plan, based on recommendations made in the National Broadband 

Plan, to encourage NG911 implementation and to help states address 

some of the technology, regulatory, and funding challenges to 

implementation. Key elements of FCC’s 5-point plan include:

Federal Efforts to 

Address Challenges and 

Facilitate NG911 

Implementation 
 

Page 26 GAO-13-376 Use and Reporting of 911 Funds

• Develop location accuracy mechanisms for NG911. Existing location 

technologies do not perform effectively in all environments. For 

example, global positioning technologies may not work deep inside a 

steel-and-concrete building, or even in a suburban residential 

basement, but may work in wood frame construction or near office 

windows. FCC officials said CSRIC plans to release a report in 2013 

on indoor location accuracy.

• Enable consumers to send text, photos, and videos to PSAPs. In 

December 2012, FCC issued a notice of proposed rulemaking 

examining rule changes meant to enable people to send text 

messages to 911.42

Additionally, NHTSA and NTIA have made more focused efforts to 

address NG911 technology challenges. As required in the New and 

Emerging Technologies 911 Improvement Act of 2008, NHTSA’s and 

NTIA’s National E911 Implementation Coordination Office developed a 

national plan in September 2009 for migrating to IP-Enabled 911 

Systems, which lays a foundation for addressing technological challenges 

associated with enabling consumers to send text, photos, and videos to 

PSAPs.

The proposal was based on the voluntary 

commitment by the four largest U.S. wireless carriers to make text-to911 available to their customers by May 15, 2014. The proposed 

rulemaking would also require all wireless carriers and interconnected 

text-messaging providers to send automatic “bounce back” error 

messages by June 30, 2013, to consumers attempting to text 911 

when the service is not available in order to inform consumers and 

prevent confusion.

43

• Facilitate completing and implementing NG911 technical standards.

CSRIC has identified technical standards, related technical gaps, and 

the overall readiness of the NG911 applications. In addition, CSRIC 

has classified the importance and urgency of resolving the identified 

technical gaps.

 

42In the Matter of Facilitating the Deployment of Text-to-911 and Other Next Generation 

Applications, Framework for Next Generation 911 Deployment, Further Notice of 

Proposed Rulemaking, 27 FCC Rcd 15659 (2012).

43Pub. L. No. 110-283, § 102, 122 Stat. 2620, 2623 (2008).
 

Page 27 GAO-13-376 Use and Reporting of 911 Funds

• Develop a governance framework for NG911. As required by the Next 

Generation 911 Advancement Act of 2012,

44 FCC released a report in 

March 2013 with detailed recommendations to Congress to create a 

new legal and regulatory framework for transitioning from legacy 911 

to NG911 networks.45 The report includes detailed information on the 

major NG911 challenges and 24 specific recommendations to 

Congress and others, such as state and local public safety authorities, 

to address the challenges. For example, FCC recommended that 

Congress promote a consistent nationwide approach to key elements 

of NG911 deployment, including standards that support seamless 

communication among PSAPs and between PSAPs and emergency 

responders; appropriate liability protection to encourage technological 

innovation and rapid deployment of NG911; and provisions to make 

NG911 fully accessible to people with disabilities. In addition, NHTSA 

has developed guidelines for state NG911 legislative language to help 

address state regulatory challenges. In doing so, NHTSA obtained 

input from local, regional, state, and federal public-sector 

stakeholders, as well as private-sector industry representatives and 

advocacy associations. NHTSA has also worked with the National 

Conference of State Legislatures to create a database of 911 bills that 

have been introduced in the 50 states and the District of Columbia. 

The information is updated bi-weekly and includes information on 

multiple topics including funding and appropriations.

• Develop a funding model for NG911. Based on a CSRIC 

recommendation, NHTSA is currently working with a contractor with 

expertise in economics and a Blue Ribbon Panel to help states 

develop new options for funding 911. According to NHTSA officials, a 

report on this effort is expected to be released in 2014. In addition, in 

FCC’s 2013 report to Congress on the legal and regulatory framework 

for NG911 services, FCC made three recommendations to Congress 

for updating NG911 funding mechanisms. Specifically, FCC 

recommended that Congress should (1) develop incentives for states 

to broaden the base of contributors to NG911 funding to more 

 

44Title VI, subtitle E of the Middle Class Tax Relief Act of 2012, § 6509, Pub. L. No. 112-

96, 126 Stat. 156, 244.

45Although the report was mandated to be issued February 22, 2013, FCC officials said 

the report was not released to Congress until March 1, 2013. See, Federal 

Communications Commission, Legal and Regulatory Framework for Next Generation 911 

Services, Issued Pursuant to the Next Generation 911 Advancement Act of 2012 (Pub. L. 

No. 112-96 (2012)), (2013). 
 

Page 28 GAO-13-376 Use and Reporting of 911 Funds

accurately reflect the benefits derived from NG911 service, (2) 

encourage states to provide funding for NG911 as well as legacy 911 

purposes as part of any existing or future funding mechanism, and (3) 

condition grants and other appropriate federal benefits on a 

requirement that funds collected for 911/NG911 funding be used only 

for 911 or NG911 purposes and provide for appropriate enforcement 

of such requirements.

Most of the country has now implemented wireless E911 services, but 

this took over a decade to accomplish. New technology and eroding 

funding mechanisms have highlighted the need for 911 to evolve to a new 

system that can accommodate next generation technologies and that is 

based on an adequate source of funding to maintain the system. For 

NG911 to avoid the slow start that wireless E911 experienced, networks 

will need to be formed that will require regulatory changes at multiple 

levels of government. Although NG911 is still in nascent form, FCC, DOT, 

and others in the federal government are working together to conduct the 

research and planning needed to provide the foundation for states to 

address the technology, regulatory, and funding challenges to implement 

NG911 more efficiently than they implemented E911. Notably, FCC’s 

March 2013 report identified potential steps for Congress to take to create 

a legal and regulatory environment that will assist states, PSAPs, service 

providers and other stakeholders in accelerating the nationwide transition 

from legacy 911 to NG911. The report provided 24 specific 

recommendations to Congress and others, such as state and local public 

safety authorities, to address the challenges of implementing NG911.

FCC has been collecting and reporting information on states’ use of 911 

and E911 funds on an annual basis for 4 years and, as mandated by law, 

will continue to do so. Collecting and reporting this information requires 

resources from both FCC and the states, so it is in the best interest of all 

parties for the information to be presented in the most useful way 

possible. Given that FCC’s future annual reports will likely include 

information on the transition to NG911 services, it is important that FCC 

collect information in a way that provides information that can be tracked 

over time. For example, as the federal government provides information 

for states as they transition to a potential new funding system, it would be 

helpful to have information that tracks current trends and patterns in state 

funding. However, because FCC’s method of asking questions does not 

result in answers that can be tracked from year to year, there is no federal 

tool that can be used at this time to understand how or if states are 

adjusting their funding for the transition to NG911. Furthermore, FCC is 

Conclusions 
 

Page 29 GAO-13-376 Use and Reporting of 911 Funds

missing an opportunity to provide more detailed aggregated information in 

its reports—such as amounts of fees, services covered, and total amount 

of funds collected—that would be helpful to decision makers. For 

example, having more readily accessible, detailed information about the 

current status of 911 funding would provide decision makers with a better 

understanding of how to address the challenges that arise in funding 

NG911 services. Following best practices for data collection and 

analysis—such as using closed-ended questions when possible and 

clearly communicating how open-ended information is coded and 

analyzed—would help ensure that the information FCC collects is 

measureable and could be tracked, resulting in more useful information 

for Congress and others who are researching funding mechanisms for the 

future of 911 services.

We recommend that the Chairman of FCC follow best practices for data 

collection and analysis to improve FCC’s current method of collecting and 

reporting information on states’ use of 911 funds, by, for example, using 

closed-ended questions when possible, developing written internal 

guidance for analyzing data, and fully describing the methodology for its 

report.

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

comment. In response, FCC concurred with our recommendation to 

improve its current method of collecting and reporting information on 

states’ use of 911 funds. FCC stated that it is examining ways to augment 

current collection of information to yield more precise information and to 

provide more quantitative data in future reports. Specifically, FCC noted 

that it will (1) consider using closed-ended questions as part of future data 

collections to facilitate tracking and analyzing data, (2) provide greater 

clarity in its guidelines for analyzing data, and (3) include a more detailed 

description of its methodology in future reports. FCC further stated that it 

has taken a variety of steps to enhance the transparency and usefulness 

of the information it gathers and has sought comment on the accuracy 

and completeness of state responses to FCC’s information collection. 

FCC officials believe these steps will also improve the accuracy and 

efficacy of its reporting. FCC’s written comments are reprinted in 

appendix II. DOT provided technical comments which we incorporated as 

appropriate.

We are sending copies of this report to the Chairman of FCC, the 

Secretary of Transportation, and interested congressional committees. In 

Recommendation for 

Executive Action

Agency Comments
 

Page 30 GAO-13-376 Use and Reporting of 911 Funds

addition, the report is available at no charge on our website at 

http://www.gao.gov. 

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

contact me at (202) 512-2834 or goldsteinm@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. Key contributors to this report are listed in 

appendix III. 

Mark Goldstein

Director, Physical Infrastructure Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-13-376 Use and Reporting of 911 Funds

The Next Generation 911 Advancement Act of 2012 mandated that we 

review states’ collection and use of 911 funds. This report presents 

information on (1) the progress that has been made in implementing 

wireless Enhanced 911 (E911) in the last decade, (2) the extent to which 

states are collecting and using 911 funds for 911 purposes and the 

usefulness of FCC’s reporting about this issue, and (3) challenges to 

implementing NG911 services and federal efforts to facilitate its 

deployment.

To address these issues, we interviewed federal, state, regional, and 

association representatives. We interviewed officials from the Federal 

Communications Commission (FCC) regarding states’ collection and use 

of E911 funds and the progress made in deploying wireless E911 and 

NG911 throughout the country. We also interviewed officials from offices 

within the Departments of Transportation (DOT) and Agriculture about 

E911 and NG911 deployment. We interviewed representatives from 

associations including the National Emergency Number Association 

(NENA), the National Association of State 911 Administrators, the 

Association of Public-Safety Communications Officials, CTIA-The 

Wireless Association, and the Competitive Carriers Association about 

states’ collection and use of E911 funds and about E911 and NG911 

deployment. We visited Illinois, where we interviewed officials from the 

State 911 Office, officials associated with a regional NG911 project, and 

representatives from rural counties in southern Illinois that have not yet 

begun E911 implementation. We obtained and examined relevant reports 

and materials from these officials and representatives. We selected 

Illinois because we were informed about the regional NG911 project in 

southern Illinois from stakeholders and because Illinois reported using 

911 funds for other purposes to FCC in its 2010, 2011, and 2012 reports. 

We also interviewed Texas officials with responsibility for the state’s 

NG911 pilot project because Texas received the largest E911/NG911 

grant from NTIA and NHTSA and because stakeholders mentioned that 

the state was making progress on implementing NG911. Information 

obtained from Illinois and Texas is not generalizable to any other states. 

In addition, we gathered further information from state officials in the five 

other states that reported using E911 funds for other purposes in their 

2012 reports to FCC: Arizona, Georgia,1

 

1

Officials in Georgia provided written responses.

Maine, New York, and Rhode 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-13-376 Use and Reporting of 911 Funds

Island.2

To understand the progress that has been made in deploying wireless 

E911 services throughout the country, we reviewed our previous reports 

on wireless E911 implementation in 2003 and 2006, and we obtained and 

analyzed county- and state-level E911 deployment data collected by 

NENA as of December 2012. To determine the reliability of this data, we 

reviewed relevant documentation and interviewed cognizant officials 

about their processes for reviewing the data and ensuring their accuracy. 

We determined that the NENA data were sufficiently reliable for the 

purposes of our report. To determine the extent to which states are 

collecting and using E911 revenues for E911 purposes and the 

usefulness of FCC’s reporting about this issue, we obtained FCC’s 2010 

through 2012 annual reports on state collection and distribution of 911 

and E911 fees and charges as well as states’ responses to FCC’s 

information-collecting effort upon which the FCC’s annual reports are 

based.

In addition, we attempted to contact jurisdictions that did not 

respond to FCC’s request for information—Louisiana, District of 

Columbia, American Samoa, Northern Mariana Islands, and U.S. Virgin 

Islands—but none responded to our request.

3

 

2

Guam also reported using 911 funds for other purposes in 2011. We contacted Guam 

officials and asked for further information in writing, but Guam did not respond to our 

request for information.

We analyzed the states’ reports to FCC, comparing the 

information that the states provided to the information FCC reported. We 

also performed year-to-year comparisons, identifying differences in how 

FCC characterized states’ responses in different years. To determine the 

reliability of this data, we reviewed relevant documentation, and 

interviewed cognizant officials about their processes for reviewing the 

data and ensuring their accuracy. Except where we have noted some 

inconsistencies and concerns with FCC’s analysis of state-reported 

information, we consider the data sufficiently reliable for the purposes of 

this report. In assessing the usefulness of FCC’s reporting, we reviewed 

best practices set forth in our previous reports and other professional 

literature on methods for collecting, analyzing and reporting information 

3

FCC’s reports cover state activities from the previous calendar year. For example, FCC’s 

2012 report covers state activities for the calendar year ending December 31, 2011. We 

did not review FCC’s 2009 report and related state reports because we determined that 3 

years would be sufficient for our purposes and because the 2009 report was FCC’s first 

report on the subject and as such was more prone to start-up issues that would impede 

our purposes for using this information.
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-13-376 Use and Reporting of 911 Funds

and data.4 To identify federal efforts to facilitate NG911 services, we 

reviewed FCC’s report to Congress entitled Legal and Regulatory 

Framework for Next Generation 911 Services5

 

4

as well as associated 

stakeholders’ responses to FCC’s public notice on NG911. In addition, we 

reviewed relevant laws and regulations pertaining to E911 and NG911, 

including the Wireless Communications and Public Safety Act of 1999, 

the ENHANCE 911 Act of 2004, the New and Emerging Technologies 

911 Improvement Act of 2008, and various state laws governing the 

collection and use of 911/E911 fees. We also reviewed relevant reports 

from FCC, DOT, the Congressional Research Service, industry, and other 

stakeholders, including FCC’s National Broadband Plan. 

GAO/PEMD-10.1.7 and GAO/PEMD-10.3.1. 

5

Federal Communications Commission, Legal and Regulatory Framework for Next 

Generation 911 Services, Issued Pursuant to the Next Generation 911 Advancement Act 

of 2012 (Pub. L. No. 112-96 (2012)), (2013). 
Appendix II: Comments from the Federal 

Communications Commission

Page 34 GAO-13-376 Use and Reporting of 911 Funds

Appendix II: Comments from the Federal 

Communications Commission
Appendix II: Comments from the Federal 

Communications Commission

Page 35 GAO-13-376 Use and Reporting of 911 Funds
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 36 GAO-13-376 Use and Reporting of 911 Funds

Mark L. Goldstein, (202) 512-2834 or goldsteinm@gao.gov

In addition to the contact named above, Sally Moino, Assistant Director; 

Thomas Beall; Amy Higgins; David Hooper; SaraAnn Moessbauer; 

Joshua Ormond; Amy Rosewarne; and Rebecca Rygg made key 

contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(543310)
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