Telecommunications: States' Collection and Use of Funds for Wireless Enhanced 911 Services
Published: 2006-03-10T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: "Enhanced 911" (E911) service refers to the capability of public safety answering points to automatically receive an emergency caller's location information. An industry association estimates that nearly 82 million 911 calls are placed each year by callers using mobile phones. Wireless E911 technology provides emergency responders with the location and callback number of a person calling 911 from a mobile phone. The ENHANCE 911 Act of 2004 called for GAO to study state and local use of funds collected for the purpose of wireless E911 implementation. We are reporting on (1) the progress made in implementing wireless E911 services throughout the country, (2) the states and localities that have established taxes, fees, or charges for wireless E911 implementation, and (3) the states or localities that have used funds collected for the purposes of wireless E911 for unrelated purposes. To address these issues, we surveyed state-level E911 contacts on the collection and use of E911 funds. Of the 51 state E911 contacts (including the District of Columbia) who were asked to participate in our survey, we received 44 responses. We provided the Federal Communications Commission (FCC) with a draft of this report and FCC provided technical comments that we incorporated.
section_title: What GAO Found
paragraphs: Significant progress has been made towards implementing wireless E911 throughout the country since our November 2003 report. Deployment of wireless E911 usually proceeds through two phases: Phase I provides general location information by identifying the cell tower or cell site that is receiving the wireless call. Phase II provides more precise caller-location information, within 50 to 300 meters in most cases. We reported in November 2003, that nearly 65 percent of the more than 6,000 public safety answering points nationwide were capable of receiving Phase I information with wireless 911 calls and 18 percent had implemented Phase II wireless E911 with at least one wireless carrier. Currently, according to the National Emergency Number Association (NENA), nearly 80 percent of public safety answering points are capable of receiving Phase I location information and 57 percent have implemented Phase II for at least one wireless carrier. However, based on our survey results, full implementation is still several years away in many states. In response to our survey, three state E911 contacts reported that it will take more than 5 years to have wireless E911 completely implemented in their states, and five others said that the technology might never be fully implemented in their states. Based on our survey results and NENA data, we found that nearly all states--48 states and the District of Columbia--require the wireless carriers to collect surcharges from their subscribers to cover the costs associated with implementing wireless E911. Responses to our survey showed the per-subscriber surcharges ranged from $0.20 to $3.00 per month. The two states that do not impose surcharges fund E911 through general revenue or the state's Universal Service Fund, which was established to support various telecommunications programs. States have the discretion to determine how they will manage and distribute the funds and we found the management of the funds and methods of disbursement varied. According to our survey results, many of the states that responded have written criteria on the allowable uses of E911 funds. Allowable uses of the E911 funds include purchasing equipment upgrades and software packages. Four state E911 contacts responded to our survey that their states did not use all of the funds collected for E911 on E911 implementation purposes during 2005. Six states, and the District of Columbia, did not respond to our survey so we do not know whether those states used E911 funds or made them available for other purposes. Four other states reported that they were unsure if all E911 funds were used solely for E911 purposes because the funds are collected and managed at the local level. The four states that reported that E911 funds were made available or used for purposes not related to E911 indicated that the E911 funds were transferred to their state's general fund. For example, one state told us that E911 funds were transferred to the general fund to help balance the state budget. Another state reported that some E911 funds were transferred to the state police since they answer emergency calls in some areas of the state.

section_title: Letter
paragraphs: According to an industry association, 200 million 911 emergency calls are  placed annually. Another industry association estimates that nearly 82  million 911 calls are placed each year by callers using mobile (wireless)  phones. A capability known as “enhanced 911” (E911) provides emergency  responders with the location of, and a callback number for, a person calling  911. This information facilitates the quick and accurate dispatch of  emergency responders, especially in cases where the caller does not know  or cannot clearly state his or her location (e.g., the caller is suffering from a  heart attack).
Most areas across the country now have E911 capabilities for traditional  wireline phones, where the caller’s street address automatically appears  on-screen for the 911 call taker. As the use of mobile phones has increased,  Congress and others in the federal government and public safety  communities have grown more concerned that E911 location information  was not often available for those dialing 911 from a mobile phone.  Implementing E911 for mobile phones is inherently more challenging.  Unlike wireline phones, where the phone number is linked to a specific  street address, providing E911 call takers with location information for a  mobile phone involves technologies that must calculate the geographic  coordinates of the caller’s location at the time of the call and display these  coordinates as a location the 911 call taker can understand. Moreover, a  wireless 911 call must be routed along the networks of both a wireless  telephone company and a wireline telephone company before terminating  at a facility where 911 calls are answered, known as a public safety  answering point (PSAP); there are more than 6,000 PSAPs nationwide,  often at a county or city level. All three entities—wireless carriers, wireline  carriers, and PSAPs—must be properly interconnected and have certain  equipment in place in order for location information to be captured, sent,  and displayed to 911 call takers. Deployment usually proceeds through two  phases: Phase I provides general location information by identifying the  cell tower or cell site that is receiving the wireless call and also provides  the phone number of the caller, while Phase II provides more precise caller- location information—within 50 to 300 meters in most cases.
The Wireless Communications and Public Safety Act of 1999 called on the  Federal Communications Commission (FCC) to encourage and support  efforts by the states to deploy wireless E911 services by working with state  and local officials, the telecommunications industry, consumer groups, and  those involved in public safety services. At the federal level, FCC and the  U.S. Department of Transportation (DOT) have taken steps to promote the  deployment of E911 location technologies for mobile phones. According to  FCC, the Commission monitors the deployment of wireless E911 service by  larger carriers, enforces its wireless E911 requirements, and grants  appropriate waivers of its wireless E911 requirements when consistent  with the public interest. FCC further stated that it works with public safety  organizations, wireless carriers, and manufacturers to foster wireless E911  deployment. Also, DOT has recognized the relationship between wireless  E911 services and highway safety and is working with a key  nongovernmental organization, the National Emergency Number  Association (NENA), to develop a PSAP database that tracks E911  implementation. The only federally mandated timeframes for installation  of wireless E911 technologies are those placed on wireless carriers by FCC.  FCC has no authority to place timeframes on PSAPs, which are under state  and local jurisdiction. States and local jurisdictions establish timetables for  implementation by their PSAPs, which must have the necessary equipment  to receive and display location information that the 911 call taker can relay  to police, fire, and rescue services. States must also fund the equipment  upgrades needed by their PSAPs for E911 service.
The pace of wireless E911 deployment has been a key concern for the  Congress. In our November 2003 report on wireless E911, we noted that the  implementation of wireless E911 was several years away in many states,  raising the prospect of piecemeal availability of this service across the  country for an indefinite number of years to come. We found that the  funding of equipment upgrades at PSAPs was a major issue for many states  and localities and was the largest factor affecting the progress of E911  implementation. Most states had put in place a surcharge on wireless  customers to pay for E911 upgrades to their PSAPs. We found, though, that  some states had redirected these funds to uses that were unrelated to E911.
Recently, the ENHANCE 911 Act of 2004 authorized a federal grant  program to provide assistance to states, local governments, or tribal  organizations in implementing E911. Recognizing that some states had  used the funds raised for E911 for other purposes, the act (among other  things) stipulated that a state or local government would not be eligible for  a federal E911 grant if it had used its E911 taxes, fees, or charges for  unrelated purposes during the period beginning 180 days immediately  preceding the date of the application and continuing until the funds are  available to the applicant. Furthermore, if the grantee used state or local  E911 funds for unrelated purposes during the term of the grant, the grant  would have to be repaid. The act also called for us to study state and local  use of funds collected for the purpose of wireless E911 implementation.  Accordingly, we are reporting on (1) the progress made in implementing  wireless E911 services throughout the country, (2) the states and localities  that have established taxes, fees, or charges for wireless E911  implementation, and (3) the states or localities that have used funds  collected for the purposes of wireless E911 for unrelated purposes during  2005.
To address these issues, we collected information from state-level E911  contacts from October 2005 to January 2006 using a Web-based survey. We  designed the survey to cover the collection, management, and use of  wireless E911 funds at the state and local level. Of the 51 state-level E911  contacts (including the District of Columbia) who were asked to  participate in our survey, we received 44 completed questionnaires. We did  not receive completed questionnaires from Alaska, Colorado, the District  of Columbia, Nevada, New York, Oklahoma, and South Dakota. To view  selected results of this survey, go to http://www.gao.gov/cgi-bin/getrpt?  GAO-06-400sp.
We used data from NENA, current as of January 2006, to provide  information on the progress made in deploying wireless E911. To assess the  reliability of NENA’s data regarding the number of PSAPs receiving Phase II  data, we interviewed knowledgeable officials from NENA about their data  collection methods. We determined that the data were sufficiently reliable  for the purposes of this report. We conducted our review between February  2005 and January 2006 in accordance with generally accepted government  auditing standards. See appendix I for a more detailed discussion of our  scope and methodology.
subsections: section_title: Background
paragraphs: Nationwide implementation of E911 by local wireline telephone companies  began in the 1970s; today, 99 percent of the population is covered by  wireline 911 service. With wireline E911 service, emergency calls are automatically routed to the appropriate PSAP and the call taker receives  the telephone number and street address of the caller. In 1996, FCC  responded to the rising number of mobile telephone subscribers and the  resulting increase in wireless 911 calls by adopting rules for wireless E911  that established a two-phase implementation approach for the wireless  carriers and set deadlines for wireless carriers regarding their part in E911  deployment. FCC required that (1) by April 1998, or within 6 months of a  request from a PSAP, wireless carriers be prepared to provide the PSAP  with the wireless phone number of the caller and the location of the cell  site receiving the 911 call (Phase I information); and (2) by October 2001, or  within 6 months of receiving a request from a PSAP, wireless carriers be  prepared to provide the PSAP with the geographic coordinates of the  caller’s location with greater precision, generally within 50 to 300 meters  (Phase II information).
As shown in figure 1, the wireless carriers, local exchange carriers (LECs),  and PSAPs must have appropriate equipment and interconnections for  wireless E911 calls to be sent to and received by PSAPs with the caller’s  location information. For example, wireless carriers must finance the  implementation of a caller location solution and test their equipment to  verify its accuracy. 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.  In order to translate the latitude and longitude location information into a  street address, PSAPs usually must acquire and install mapping software.  PSAPs may also need to acquire new computers to receive and display this  information. Getting PSAPs the technology needed to receive wireless  E911 location information is primarily a state and local responsibility  because PSAPs serve an emergency response function that has  traditionally fallen under state or local jurisdiction. FCC has no authority to  set deadlines for the PSAPs’ readiness.
The ENHANCE 911 Act of 2004 was enacted to coordinate 911 and E911  services at the federal, state, and local level; and to ensure that the taxes,  fees, or charges imposed for enhancing 911 services are used only for the  purposes for which the funds are collected. The act called for the creation  of an E911 Implementation Coordination Office to improve E911  coordination and communication. This office will be operated jointly by the  National Highway Traffic Safety Administration (NHTSA) and the National  Telecommunications and Information Administration (NTIA), and will be  housed at NHTSA. Although the office had not received an appropriation as  of January 2006, a DOT official told us that NHTSA and NTIA are working  together to delineate their respective responsibilities. The act also  authorized matching federal grants for eligible state, local, and tribal  entities for the deployment and operation of Phase II E911 services. The act  requires applicants for a matching federal grant to certify that no portion of  any designated state and local E911 funds are being obligated or expended  for any purpose other than the purposes for which the funds are  designated. The act authorized $250 million per year for matching grants  for fiscal years 2005 through 2009. However, no funds were appropriated  for these grants in 2005.
section_title: Significant Progress Has Been Made toward Nationwide Wireless E911 Implementation but Full Deployment is Years Away
paragraphs: Significant progress has been made in implementing wireless E911 services  since our last report on this topic in November 2003. At that time, using  data from NENA, we reported that nearly 65 percent of PSAPs nationwide  had implemented Phase I wireless E911 services and 18 percent of PSAPs  had implemented Phase II wireless E911 with at least one wireless carrier.  Since that time, there has been a marked increase in both of these  percentages. As of January 2006, NENA reports that nearly 80 percent of  PSAPs nationwide had implemented Phase I wireless E911 services and 57  percent had implemented Phase II with at least one wireless carrier. At the  county level, NENA reports that approximately 70 percent of counties  nationwide have implemented Phase I wireless E911 services and 44  percent of the counties have implemented Phase II with at least one  wireless carrier. According to NENA, many of the PSAPs that have  implemented Phase I and Phase II are in areas that cover higher  concentrations of people, and as a result, approximately 85 percent of the  U.S. population is now covered by Phase I and nearly 69 percent by Phase II  with at least one wireless carrier. See figure 2 for nationwide deployment of  Phase I and II based on population coverage by state.
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While progress is being made in wireless E911 implementation, the  estimates from state contacts indicate that no clear picture is emerging on  when Phase II will be fully deployed nationwide. As noted earlier, FCC has  no authority to set deadlines for PSAPs to implement wireless E911  services. As a result, there is no federal requirement for full wireless E911  implementation and states may or may not have set their own deadlines for  implementation. In our survey of state E911 contacts, we asked  respondents to provide us with an estimate of when they believed their  state would have wireless Phase II service fully in place with at least one  wireless carrier per PSAP. We found that state E911 contacts offered a wide  range of estimated Phase II completion dates. As shown in figure 3, 10 of 44  state contacts who responded to our survey indicated that Phase II was  already in place throughout their state. Eight state contacts noted that they  would have Phase II in place for all of their PSAPs with at least one  wireless carrier within a year. Thirteen state contacts provided a range of 1  to 5 years for Phase II to be implemented, with three state contacts  responding that it would take more than 5 years. Furthermore, five state  contacts noted that their state might never be 100 percent complete for  Phase II service. For example, one state contact noted that four rural  counties opted not to apply for state funding to implement wireless E911  and two of these counties have only decided to implement wireline E911.  Contacts in five states had no basis to judge when Phase II would be in  place in their states.
section_title: Most States Collect Funds for Wireless E911 Implementation, Although Collection and Disbursement Practices Vary
paragraphs: Based on our survey results and NENA data, we found most states obtain  E911 funds through state-mandated surcharges collected by wireless  carriers from the carriers’ wireless subscribers. States have the discretion  to determine how these funds will be managed and distributed. Some states  allocate funds using a formula based approach, while others distribute the  funds based on PSAP requests. According to our survey results, 35 states  had established written criteria on the allowable uses of E911 funds.  Examples of allowable uses for the funds included the purchase of  equipment upgrades, software packages, and training of personnel.
subsections: section_title: Most States Collect Surcharges for Wireless E911 Implementation
paragraphs: At present, state and local governments determine how to pay for PSAP  wireless E911 upgrades. We found, based on our survey results and NENA  data, that 48 states and the District of Columbia collect surcharges to cover  the costs of implementing wireless E911 (see fig. 4). For these states, funds  are collected by wireless carriers from their subscribers. The other two  states do not impose surcharges on wireless subscribers, but still have a  wireless E911 funding mechanism in place. Specifically, the state E911  contact for Missouri told us that the state uses funds from the local general  revenue, local 911 taxes, and wireline funds for E911 implementation; and  the Vermont state E911 contact said the state uses funds from the state’s  Universal Service Fund, which supports various telecommunications  programs. For states that impose surcharges, the surcharge amount is  usually established in state law. Responses to our survey indicated that  the per-subscriber surcharges varied from state to state and ranged from  $0.20 to $3.00 per month. We also found the surcharge amount could vary  within a state. For example, one state has a maximum monthly surcharge  amount of $1.50, and although most of the counties collect the maximum  amount, several counties collect less than the maximum.
Based on the responses to our survey, several states indicated that  insufficient funding collected for wireless E911 was impeding the state’s  ability to implement this service. We heard from one state that relies on  funds collected from both the wireline and wireless surcharges to fund  E911 that due to Hurricane Katrina, the state expected to see a drop in  wireline funding over the next 2 to 3 years. A county official from that state  said that because many residents and businesses impacted by the storm  have not reestablished telephone service, the state is not receiving  telephone fees from those residents. Another state reported that one of the  biggest issues in implementing wireless E911 is the inability to collect  funds from seasonal populations in many of the state’s resort areas. Small  towns in the state experience a large influx of tourists during various times  of the year. However, because the state collects funds based on the billing  address of the subscriber, counties in the state are limited in their ability to  cover the costs of E911 services that out-of-state tourists expect while  visiting local resort areas.
section_title: States Employ Different Methods for Managing and Disbursing Funds
paragraphs: States and local governments have the authority to determine how they will  manage and disburse their E911 funds. Of the 31 states that answered our  question pertaining to the management of E911 funds, 23 indicated that the  funds are managed at the state level, 6 said funds are managed locally, and  2 others indicated that the funds are managed by a mix of state and local  entities. We found that various state-level entities can have authority to  manage the funds collected for wireless E911 implementation, including  the public utility commission, the treasury office, and state-level boards. In  one state, for example, a state-level board comprised of members from  municipal organizations, PSAPs, state and local law enforcement agencies,  local exchange service providers, and the wireless carriers industry  established the criteria and guidelines for administering the funds. Of the  seven states indicating that the local government manages the funds, one  state said that the governing boards of 54 local 911 jurisdictions (51  counties and 3 cities) have the ultimate authority over the expenditure of  wireless E911 funds.
Methods of disbursement also varied. Some states use formulas based on  various criteria to determine the amount of funds distributed to different  localities. For example, a number of states allocate the funds to localities  based on criteria such as the volume of 911 calls made in the jurisdiction or  the number of wireless subscribers. Other states allocate funds based on  PSAP requests. One state reported that it reimburses county governments  and providers for the costs they have incurred to implement wireless E911  services. Alternatively, the PSAPs in another state must first request  funding from the state, which a state-level office must then approve.
section_title: Most States Have Written Criteria on the Allowable Use of E911 Funds
paragraphs: As part of our survey, we asked the state E911 contacts if their states had  established written criteria on the allowable uses of funds collected for the  purposes of wireless E911 implementation. Of the 38 state contacts who  responded to this question, 35 reported that their state had established  written criteria, while the other 3 indicated that written criteria had not  been established. Examples of allowable uses of funding include the  purchase of equipment upgrades or software, personnel costs directly  attributable to the delivery of 911 service, and costs related to the  maintenance of Phase I and II services. For example, according to one  state, its law permits wireless E911 funds to cover the salaries, benefits,  and uniforms of 911 service employees such as call takers, dispatchers, and  supervisors. We also asked the state E911 contacts if the state had any kind  of oversight procedures to control the use of E911 funds. Of the 38 state  contacts who responded to this question, 33 reported that their state had  established oversight procedures to control the use of E911 funds, 3 others  indicated no oversight procedures had been established, and 2 contacts did  not know. According to our survey results, audits were the most common  approach used to oversee the use of E911 funds. For example, one state  reported that the wireless E911 fund and the state’s wireless E911 services  board is audited annually by the state’s Auditor of Public Accounts and that  the reports are available to the public online.
section_title: A Few States Reported Using Wireless E911 Funds for Unrelated Purposes
paragraphs: Based on the responses of the 44 state E911 contacts who completed our  survey, four states that collected funds for the purposes of wireless E911  implementation made those funds available or used them for purposes  unrelated to E911 during 2005. For the six states and the District of  Columbia that did not respond to our survey, we do not know whether they  used any of their E911 funds for unrelated purposes. Four other states were  unsure if their wireless E911 funds have been used for unrelated purposes  because the funds are collected and maintained at the local level. See figure  5 for a complete breakout by state of their use of E911 funds during 2005,  along with their progress in implementing E911 in their counties.
For the four states that reported E911 funds were made available or used  for purposes not related to E911 during 2005, the state contacts reported  that the E911 funds were transferred to their state’s general fund. For  example, the E911 contact for North Carolina reported that E911 funds  were transferred to the general fund to help balance the state budget.  According to the E911 contact for Virginia, funds were transferred to both  the general fund and to the state police, which responds to emergency calls  in some areas of the state. One of these four states, Rhode Island, has  implemented Phase II services in all of its counties and Virginia has  implemented Phase II for 83 percent of its counties. For the remaining two  states, Illinois has implemented Phase II in 47 percent of its counties and  North Carolina for 71 percent of its counties.
One state responded to our survey that, while E911 funds have not been  made available for other purposes, approximately $72 million in state  wireline and wireless E911 fees collected have not been appropriated to the  state 911 program. In other words, the funds remain in dedicated E911  accounts, but are “frozen” and are not being used to deploy or maintain  E911 services. We heard from four other states that because funds for  wireless E911 are collected and managed by local jurisdictions without any  state involvement, the state is unsure if wireless E911 funds have been used  for purposes other than wireless E911 implementation. For example, one  state E911 contact told us that the state currently has no mechanism to  monitor the use of wireless E911 funds at the local level. However, this  contact further said that if a federal grant program for wireless E911 is  funded, the state could establish a mechanism to validate that local  jurisdictions were using wireless E911 funds only for allowable purposes.
section_title: Agency Comments
paragraphs: We provided FCC with a draft of this report for their review and comment.  In response, FCC provided technical comments that we incorporated  where appropriate.
We are sending copies of this report to interested congressional  committees and the Chairman, FCC. We will make copies available to  others upon request. The report is available at no charge on GAO’s Web site  at http://www.gao.gov. Contact points for our offices of Congressional  Relations and Public Affairs may be found on the last page of this report.
If you or your staff have any questions concerning this report, please  contact me on (202) 512-2834 or goldsteinm@gao.gov. Key contributors to  this report were John Finedore, Assistant Director; Kimberly Berry, Andy  Clinton, Stuart Kaufman, Sally Moino, Josh Ormond, Jay Smale, and Mindi  Weisenbloom.
section_title: Scope and Methodology
paragraphs: The ENHANCE 911 Act of 2004 required us to review the imposition and  use of taxes, fees, or other charges by states or localities that are  designated to improve emergency communications services, including  “enhanced 911” (E911). As such, we are reporting on (1) the progress made  in implementing wireless E911 services throughout the country, (2) the  states and localities that have established taxes, fees, or charges for  wireless E911 implementation, and (3) the states or localities that have  used funds collected for the purposes of wireless E911 for unrelated  purposes.
To obtain general information on wireless E911 implementation, we  interviewed officials from the National Emergency Number Association  (NENA), the National Association of State 9-1-1 Administrators, and the  Federal Communications Commission (FCC). We also met with officials  from the Department of Transportation to learn the status of the E911  Implementation Coordination Office. To obtain information pertaining to  the collection, management, and use of wireless E911 funds at the state and  local level, we developed and administered a Web-based survey to state- level E911 contacts. The state E911 contacts are listed on FCC’s Web site as  the point of contact for emergency communications in their states and  were provided by the governor of each state in response to a request from  FCC. From September 21, 2005, through September 28, 2005, we conducted  a series of “pretests” with state E911 contacts to help further refine our  questions, clarify any ambiguous portions of the survey, and identify any  potentially biased questions. Upon completion of the pretests and  development of the final survey questions and format, we sent an  announcement of the upcoming survey to the state E911 contacts  (including the District of Columbia) on October 4, 2005. They were notified  that the survey was available online on October 6, 2005. We sent follow-up  e-mail messages to non-respondents as of October 30, 2005, and then  attempted several times to contact those who had not completed the  survey. The survey was available online until January 20, 2006. Of the  population of 51 state E911 contacts who were asked to participate in our  survey, we received 44 completed questionnaires for an overall response  rate of 86 percent. Although the individual listed as the Wyoming state E911  contact was unable to answer the questionnaire, a representative at the  county level completed it. We did not receive completed questionnaires  from Alaska, Colorado, the District of Columbia, Nevada, New York,  Oklahoma, and South Dakota. We administered the survey between  October 2005 and January 2006. To view selected results of the survey, go  to http://www.gao.gov/cgi-bin/getrpt?GAO-06-400sp.
The practical difficulties of conducting surveys may introduce errors  commonly referred to as “nonsampling error.” For example, differences in  how a particular question is interpreted or the sources of information  available to respondents may introduce error. To minimize nonsampling  error, we worked with a social science survey specialist to develop the  questionnaire and conducted three pretests. In addition, steps were taken  during the data analysis to minimize error further, such as performing  computer analyses to identify inconsistencies and completing a review of  data analysis by an independent reviewer.
We contacted state budget officials for the four states that reported using  funds collected for the purpose of E911 implementation for unrelated  purposes to verify the information we received in response to our survey.  Other than this, we did not independently verify the survey results. To  provide information on the progress made in deploying wireless E911, in  addition to the survey, we used NENA data current as of January 2006. To  assess the reliability of NENA’s data regarding the number of public safety  answering points receiving Phase II data, we interviewed knowledgeable  officials from NENA about their data collection methods and reviewed any  existing documentation relating to the data sources. We determined that  the data were sufficiently reliable for the purposes of this report.
We conducted our review between February 2005 and January 2006 in  accordance with generally accepted government auditing standards.