Telecommunications: Uneven Implementation of Wireless Enhanced 911 Raises Prospect of Piecemeal Availability for Years to Come
Published: 2003-11-07T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: When an emergency call is placed to 911, prompt response depends on knowing the location of the caller. Enhanced 911 (E911) service automatically provides this critical information. E911 is in place in most of the country for traditional wireline telephone service, where the telephone number is linked to a street address. Expanding E911 capabilities to mobile phones is inherently more challenging because of the need to determine the caller's geographic location at the moment the call is made. Concerns have been raised about the pace of wireless E911 implementation and whether this service will be available nationwide. GAO reviewed the progress being made in implementing wireless E911 service, the factors affecting this progress, and the role of the federal government in facilitating the nationwide deployment of wireless E911 service.
section_title: What GAO Found
paragraphs: Implementation of wireless E911 is several years away in many states, raising the prospect of piecemeal availability of this service across the country for an indefinite number of years to come. Successful implementation depends on coordinated efforts by wireless carriers, local telephone companies, and more than 6,000 public safety answering points (PSAPs)--the facilities that receive 911 calls and dispatch assistance. According to a database sponsored by the Department of Transportation (DOT), as of October 2003, nearly 65 percent of PSAPs had Phase I wireless E911 service, which provides the approximate location of the caller, while only 18 percent had Phase II, which provides a more precise location and is the ultimate goal of wireless E911 service. Though valuable, the database does not differentiate between PSAPs that will require equipment upgrades and those that will not, thereby limiting its usefulness in accurately assessing progress toward full implementation. Looking forward, 24 state 911 contacts said in response to a GAO survey that their state will have Phase II implemented by 2005 or sooner; however, all other state contacts estimated dates beyond 2005 or were unable to estimate a date. Key factors hindering wireless E911 implementation involve funding and coordination. The wireless carriers, states, and localities must devise the means to fund more than $8 billion in estimated deployment costs over the next 5 years. Some states and localities have established funding mechanisms (such as E911 surcharges on phone bills), but others have not done so or have used their E911 funds for unrelated purposes. In addition, there is also a lack of coordination in some cases among the wireless carriers, local telephone companies, and PSAPs that can lead to delays in wireless E911 implementation. States with knowledgeable and involved coordinators were best able to work through these coordination issues. The Federal Communications Commission (FCC) and DOT are involved in promoting wireless E911, but their authority in overseeing its deployment is limited because PSAPs traditionally fall under state and local jurisdiction. FCC has set deadlines on the wireless carriers' E911 responsibilities and has taken actions to identify best practices and improve coordination among the parties. DOT is developing an action plan and clearinghouse for wireless E911 planning, implementation, and operations.

section_title: Letter
paragraphs: In 2001, Americans placed almost 57 million emergency calls to 911 using  mobile phones. According to the Federal Communications Commission (FCC), around one-third of 911 calls are now made from mobile phones.  With almost 150 million Americans now subscribing to a mobile phone  service and new concerns about homeland security facing our nation, the  ability to reach 911 from sidewalks, highways, and rural areas has become  increasingly important. Knowing the precise location of a 911 caller  facilitates the quick and accurate dispatch of emergency responders such  as police, firefighters, and ambulance crews. However, in some cases, 911  callers cannot speak (e.g., a caller who is suffering a heart attack) or simply  do not know their location (e.g., a caller reporting an accident along a  highway).
For traditional wireline phones, most areas across the country now employ  “enhanced 911” (E911) services, where the caller’s address automatically appears on-screen for the 911 call taker. The increasing use of mobile phones led to concerns by the Congress and others in the federal  government and the public safety community that E911 location  information is often not available for citizens dialing 911 from a mobile phone. However, implementing wireless E911 is inherently more  challenging than wireline E911. Unlike wireline phones, where the phone  number is linked to a specific street address, providing location information for a mobile phone involves technologies that must calculate  the geographic coordinates of the caller at the time of the call and display  those coordinates as a location the 911 call taker can understand.  Moreover, a wireless 911 call is routed along the networks of both a  wireless telephone company and a wireline telephone company before  terminating at a facility where 911 calls are answered, known as a public  safety answering point (PSAP). There are more than 6,000 of these  answering points nationwide, often at a county or city level. All three of these entities—wireless carriers, wireline carriers, and public safety answering points—must be properly interconnected and have certain equipment in place before wireless 911 calls can be correctly routed and  E911 location information sent with the call.
At the federal level, FCC and the U.S. Department of Transportation (DOT)  have taken steps to promote the deployment of E911 location technologies  for mobile phones. Deployment usually proceeds in two phases: Phase I  provides general location information by identifying the cell site and cell  sector receiving the wireless call as well as the telephone number of the  caller; Phase II provides a more precise location by determining the  latitude and longitude of the caller, which can be electronically displayed  on a map. Currently, the only federally mandated time frames for  installation of wireless E911 technologies are those placed on wireless  carriers by FCC. These time frames vary by wireless carrier and by the type  of location technology the carrier has selected, and currently extend out to  December 31, 2005. However, FCC has no authority to place time frames on  the public safety answering points, which are under state and local  jurisdiction. As a result, there is no ultimate nationwide deadline for full  implementation of wireless E911 services. FCC has technical and  educational initiatives under way to help the parties involved to share  information on deployment practices, problems, and experiences. Also,  DOT has recognized the relationship between wireless E911 services and  highway safety and is working with a key nongovernmental organization,  the National Emergency Number Association (NENA), to develop a PSAP  database that tracks E911 implementation. DOT is also working to  promote research, planning, and education related to wireless E911  services.
The pace of wireless E911 deployment has been a key concern for the  Congress. The Wireless Communications and Public Safety Act of 1999  designated 911 as the universal emergency telephone number within the  United States and called on FCC to encourage and support efforts by the  states to deploy wireless E911 services by working with state and local  officials, the telecommunications industry, consumer groups, and those  involved in public safety services.There is also a Congressional E911  Caucus that aims to educate lawmakers, constituents, and communities  about the importance of 911 systems.You asked us to provide an overview  of the deployment of wireless E911 services across the country. We agreed  to provide information on (1) the progress made in deploying wireless E911  services throughout the country, (2) the factors that are affecting this  progress, and (3) current federal government actions to promote the  deployment of wireless E911 services.
To address these issues, we interviewed representatives of the various  parties involved in wireless E911 implementation. We selected nine states  (California, Idaho, Indiana, Kentucky, Maryland, Missouri, South Carolina,  Texas, and Virginia) and the District of Columbia as case studies. For each  case study, we interviewed representatives of a public safety answering  point in both an urban and rural area of the state. We also interviewed the  state’s 911 coordinator and representatives of one small wireless carrierserving the state.In addition to our case studies, we interviewed  companies providing wireless telephone services nationwide, companies  providing local wireline telephone services, and a manufacturer of mobile  telephones. We interviewed federal, state, and local government officials  involved in wireless E911 implementation and representatives from several  public safety associations and wireless industry associations. Lastly, we  conducted a telephone survey of the state 911 contacts in all 50 states and  the District of Columbia (these individuals were designated by the  governor of each state as the E911 point of contact and are listed on FCC’s  Web site) to obtain an overview of implementation efforts across the  country. A more detailed discussion of our scope and methodology is found  in appendix I.
subsections: section_title: Background
paragraphs: Basic wireline 911 service provides an easily remembered universal  number that connects the caller with an emergency response center,  known as a public safety answering point (PSAP) (see fig. 1). The next  step after basic wireline 911 service is “enhanced 911” (E911), which  automatically routes the emergency call to the appropriate PSAP and  transmits to the call taker the telephone number (the “callback number,”  should the call be disconnected) and street address of the caller.  Nationwide implementation of E911 by local wireline telephone  companies, known as “local exchange carriers” (LEC), began in the 1970s  without a federal mandate or deadlines governing the rollout. By 1987, 50  percent of the United States’ population could reach emergency services  through wireline 911. Today, 99 percent of the population is covered by  wireline 911 service, and 93 percent of that coverage includes the delivery  of a callback number and location information.
In the early 1990s, FCC took note of the rising number of mobile telephone  subscribers and the resulting increase in 911 calls. In 1994, FCC requested  comments on requiring wireless carriers to provide the same level of 911  service that was available from LECs. In 1996, with input from the industry  and public safety community, FCC adopted rules for wireless E911 that  established an approach consisting of two phases for implementation by  the wireless carriers. FCC also set schedules for implementing both basic  and enhanced wireless 911 services, determined accuracy requirements  and deployment schedules for location technologies, and outlined the role  of PSAPs. Specifically, the phases required the following:
Phase I required that by April 1998, or within six months of a request  from a PSAP, whichever was later, wireless carriers were to be prepared  to provide the PSAP with the wireless phone number of the caller and  the location of the cell site receiving the 911 call.
Phase II required that by October 2001, or within 6 months of receiving a  request from a PSAP, whichever was later, wireless carriers were to be  prepared to provide the PSAP with Phase I information plus the latitude  and longitude coordinates of the caller within certain standards of  accuracy.
In 1996, when these rules were established, the technology to accurately  locate a caller on a mobile telephone had not yet been perfected, but a  “network based” solution was anticipated. With this type of solution, a  caller is located through a triangulation process using the closest cell  towers. However, as location technology was being developed, a “handset  based” solution (i.e., one using the wireless phone itself) was made  available. The most common handset solution also relies on triangulation,  but uses Global Positioning System (GPS) satellites and a GPS chip inside  the handset. In recognition of this second solution, FCC issued rules in  October 1999 for carriers that selected handset-based location  technologies. In August 2000, FCC adopted modifications to its rules for  handset-based solutions and said that even if a PSAP has not made a  request for Phase II wireless E911 service, wireless carriers deploying a  handset-based solution must ensure that by December 31, 2005, 95 percent  of their customers have mobile phones capable of providing automatic  location information.
A typical wireless 911 call is routed along both wireless and wireline  networks before terminating at the PSAP. See figure 2 below. While the  voice call is taking place over the wireless and wireline networks, several  data queries are simultaneously occurring to determine the caller’s physical  location and callback number. With wireless callers, the location  information may need to be updated throughout the call to achieve greater  accuracy or because the caller is moving during the call.
Phase II wireless E911 service is more complex to implement than Phase I  because of the need to install equipment to determine the geographic  coordinates of the caller, transfer that information through the telephone  networks, and have a mapping system in place at the PSAP that can display  the latitude and longitude coordinates of the caller as a map location for  dispatching assistance. When Phase II location data is unattainable (e.g.,  the handset does not have line of sight to enough GPS satellites to  determine the caller’s location), most wireless systems default to providing  Phase I data, including the location of the cell tower and cell sector  receiving the call.
The increased complexity of Phase II also makes it more costly than Phase  I to implement. To date, the federal government has played no role in  financing the rollout of wireless E911 services. Wireless carriers must  finance the implementation of a caller location solution and test equipment  to verify accuracy. LECs are generally responsible for ensuring that all the  necessary connections between wireless carriers, PSAPs, and databases  have been installed and are operating correctly. PSAPs purchase telephone  services from the LECs. Because the typical underlying wireline E911  network is unable to carry the additional wireless E911 information, PSAPs  often must purchase a separate data link and connection from the LEC. In  order to translate the latitude and longitude location information into a  street address, PSAPs usually purchase and install mapping software.  PSAPs may also need to acquire new computers to receive and display this  information.
In short, three parties—the wireless carriers, LECs, and PSAPs—must  interconnect and install equipment in order for wireless E911 calls to be  completed and the caller location information to be sent with the call.  However, no single entity has regulatory authority and oversight over the  entire implementation process. FCC has considerable regulatory authority  over wireless carriers and has placed location accuracy standards and  deployment deadlines on the wireless carriers. State public utility  commissions have some authority over wireless carriers’ terms and  conditions of service. The state public utility commissions also have a great  deal of authority over the LECs, including authority over intrastate service  rates, while FCC retains some authority over LEC interconnection  agreements with wireless carriers and other issues. PSAP readiness  remains a state and local issue because PSAPs serve an emergency  response function that has traditionally fallen under state or local  jurisdiction. The manner in which the more than 6,000 PSAPs across the  country are administered and funded—at a state, county, city, or other  political subdivision level—varies from state to state. According to FCC,  the Commission has no authority to set deadlines for PSAPs’ deployment of  the equipment they need in order to receive caller location information  from the wireless carriers. Setting such deadlines on PSAPs would be a  matter for states and localities.
Another federal agency with an interest in this issue is DOT. According to  DOT, its involvement stems from the department’s mandate to handle  issues of traffic safety and from a directive from the Secretary of  Transportation to become involved in wireless E911 issues. DOT officials  noted that wireless phones have become crucial to reporting highway  accidents and getting ambulances or other assistance to the scene. As will  be discussed below, DOT is involved in several initiatives to track the  progress of E911 deployment and help promote wireless E911 services,  especially at the state and local level.
As the original Phase II deadline of October 2001 approached, the six large  national wireless carriers (which provide service to approximately 75  percent of wireless telephone subscribers) requested waivers because the  location technology was not ready for implementation. In granting the  waivers, FCC negotiated different deadlines with each of these carriers,  based on the carrier-specific Phase II compliance plans. The FCC also  required these carriers to file detailed quarterly reports regarding  implementation. In July 2002, FCC also granted temporary relief from the  Phase II deadlines to those non-nationwide midsize and small wireless  carriers that had requested relief. Currently, all wireless carriers that have  chosen to deploy a handset-based location solution remain under a  deadline of having handsets containing location technologies in use by 95  percent of subscribers by December 31, 2005. Yet, despite this deadline,  Phase II service is not assured in any area by any specific date. This is  because all wireless carriers must respond within 6 months to a PSAP  request for the delivery of wireless E911 location information. PSAPs,  however, are under no federal deadlines to ever request wireless E911  services. Thus, the full rollout of wireless E911 services nationwide  depends in great part on the implementation efforts of the more than 6,000  PSAPs.
section_title: Nationwide Phase I Deployment Is More Than Halfway Complete, but Full Phase II Deployment May Be Years Away
paragraphs: Based on the best data that is available, nearly 65 percent of PSAPs across  the nation have implemented Phase I and 18 percent have implemented  Phase II with at least one wireless carrier providing location information.  However, there is still a lack of information regarding how many of the  more than 6,000 PSAPs will need to upgrade their equipment, making it  difficult to accurately measure the progress of wireless E911  implementation. Looking forward, our survey of state 911 contacts found  that less than half of them believe that wireless E911 services will be fully  in place in their state by 2005. This raises the prospect that E911  implementation will be piecemeal both within states and across the nation  for an indefinite number of years to come.
subsections: section_title: Eighteen Percent of PSAPs Have Implemented Phase II, but Measuring Progress toward Full Deployment Is Hampered by Data Problems
paragraphs: Currently, the single best information source for tracking the progress  being made in deploying wireless E911 service at the local level comes  from DOT and the National Emergency Number Association (NENA). DOT  contracted with NENA to create a database of counties and the PSAPs  within the counties to provide information about implementation of  wireless E911. This database is updated every quarter using wireless  carrier information filed with the FCC, and supplemented by data gathered  directly from PSAPs. Prior to the creation of this database, the only  national data available about PSAPs that existed comprised information  about NENA’s membership, and that information did not include all PSAPs  or track E911 deployments. Thus, the DOT/NENA initiative has provided a  key instrument for measuring wireless E911 implementation.
According to NENA, as of October 2003, nearly 65 percent of PSAPs  nationwide had implemented Phase I wireless E911 services, which  provides the call taker with the callback number and the location of the cell  tower and cell sector receiving the 911 call. Phase II, which locates the  caller with more precise geographic coordinates, has been implemented  with at least one wireless carrier in 18 percent of PSAPs. As part of our  survey of state 911 contacts, we asked respondents about their states’  progress on Phase I and Phase II deployments. The responses to our survey  were not complete because some state contacts were uncertain about their  state’s current status. However, for the 33 states and the District of  Columbia from which we did receive responses, we found that percentages  for Phase I and Phase II implementation were consistent with NENA’s data.
The percentages of counties that have implemented wireless Phase I and  Phase II E911 service are illustrated, by state, in figure 3. The percentages  are based on GAO’s analysis of NENA data as of October 2003.
Measuring the progress of wireless E911 implementation against the goal of  full nationwide Phase II deployment depends on being able to compare the  number of PSAPs that are receiving wireless Phase II location data with the  universe of PSAPs that need to be upgraded. We found, however, that there  is a lack of accurate information on the total number of PSAPs that need to  be upgraded. NENA has determined that there are 6,143 PSAPs nationwide.  However, this number includes both “primary” and “secondary” PSAPs. A  primary PSAP is defined by NENA as a PSAP to which 911 calls are directly  routed; a secondary PSAP only receives calls that have been transferred, or  passed along, from a primary PSAP. Generally, primary and secondary  PSAPs have been included in the total number of PSAPs that need to be  capable of receiving wireless E911 information.
However, our survey results of state 911 contacts, along with our case  study interviews, indicate that some states do not plan to upgrade their  secondary PSAPs. For example, in North Carolina, state statute only  permits primary PSAPs to be funded for wireless E911; in Kentucky,  Virginia, and Washington, state funds to help finance wireless E911  upgrades are only available to primary PSAPs; in Maryland, the issue is  currently under discussion, although consolidating secondary PSAPs with  primary ones has been considered. In addition, some secondary PSAPs are  so small that they may never need wireless E911 equipment. Currently, the  DOT/NENA database does not differentiate between PSAPs that will need  to be upgraded and those that will not, which limits usefulness of the  database in accurately assessing progress toward full wireless E911  implementation.
For its part, FCC requires large and midsize wireless carriers that have filed  for relief from deployment deadlines to provide information quarterly on  their progress in implementing Phase I and Phase II. Until recently, the data  submitted by the carriers and available from FCC were organized by  carrier, not by state or county, and were not easily sorted to provide  information concerning the status of wireless E911 deployment. However,  as of August 1, 2003, FCC also began requiring the large and midsize  wireless carriers to submit data in an electronic spreadsheet format  regarding deployment of Phase I and Phase II by PSAP. Because this  spreadsheet has several fields, including the state, researchers can search  by field and have numerous options for organizing the data. In addition,  small wireless carriers, which had also requested relief, also were required  to file one interim report with FCC about their E911 progress on August 1,  2003. Based on the August filings, FCC told us that most of the large and  midsize carriers appear to be making good progress toward readying their  networks to respond to PSAP requests for E911 services.
section_title: State 911 Contacts Offered a Wide Range of Estimated Phase II Completion Dates
paragraphs: In our survey of state 911 contacts (which included the District of  Columbia), we asked respondents to provide us with an estimate of when  they believed their state would have wireless Phase II E911 fully in place  for at least one wireless carrier per PSAP. Twenty-four of 51 respondents  said they thought Phase II would be fully in place in their state by 2005, the  last year for which there is any specific FCC deadline on wireless carriers.  Six of those 24 respondents said they would be ready by 2003. Contacts in  other states were either unwilling to commit to any specific year, given  their current level of implementation, or estimated a date in 2006 or  beyond. See figure 4.
As the estimates from state contacts indicate, no clear picture is emerging  on when Phase II will be fully deployed nationwide, raising the prospect of  piecemeal availability of this service across the country for an indefinite  number of years to come.
section_title: Funding and Coordination Are Key Factors Affecting Current Wireless E911 Deployment, with New Wireless Services Posing Future Challenges
paragraphs: As of October 2003, NENA estimates that over the next 5 years the  nationwide cost to deploy Phase II will be between $8 billion and $9 billion,  including capital and incremental operating expenses. Funding for PSAP  equipment upgrades remains a major issue for many states and localities  and continues to hamper nationwide deployment. Not all states have  implemented a funding mechanism for wireless E911, and of those that  have, some have redirected E911 funds to unrelated uses. In addition, poor  coordination among the parties is a factor affecting wireless E911  deployment, although some states and localities have eased this problem  with active and knowledgeable state 911 coordinators who help oversee  the process and work with all the parties. Technologically, the main hurdle  of developing wireless location equipment for mobile phones has been  solved, but the continuing emergence of new wireless devices and services  has the potential to overburden the current 911 infrastructure.
subsections: section_title: Ongoing Problems with State and Local Funding of Equipment Upgrades Are Hampering the Deployment of Wireless E911
paragraphs: It is costly to implement wireless E911 services. PSAPs need money to  upgrade their systems and equipment and to purchase new software to  receive and display caller location information. Wireless carriers incur  costs associated with handset and network upgrades, engineering design,  upgrading hardware and software, and maintaining the system. The LECs  also incur costs, but generally these are paid for by the PSAPs as they  purchase 911 services and upgrades from the LECs. Currently, funding  must come from sources other than the federal government, which has not  provided funding to PSAPs or wireless carriers for wireless E911 or  established guidelines on how wireless E911 should be funded.
At present, it is up to state and local governments to determine how to pay  for PSAP wireless E911 upgrades. To cover the costs associated with  implementing wireless E911, responses to our survey showed that the  majority of states (39 states plus the District of Columbia) require wireless  carriers to collect funds from their subscribers through a surcharge  included on subscribers’ monthly wireless phone bills. The amount of the  surcharge is usually determined by the state; responses to our survey  showed the surcharges ranged from 5 cents to $1.50 per month. Generally,  the wireless carriers submit the funds to the states, and the states have the  discretion to determine how the funds will be managed. For example, some  states have established E911 boards that oversee the funds, while other  states allow the funds to be managed at the county or PSAP level. Methods  of disbursement also varied. Some states allocated wireless E911 funds to  PSAPs based on their jurisdictional population, while some based it on the  number of wireless subscribers in the jurisdiction. Other states evenly  divided the funds among counties or PSAPs.
Although the majority of states have established some type of funding  mechanism, problems with funding PSAP equipment upgrades persist. For  example, NENA maintains that many communities are not in a position to  implement wireless E911 service because funds collected for E911  deployment are not being allocated for that purpose. Our survey of state  E911 contacts found that 13 states and the District of Columbia had used  wireless E911 funds for expenditures unrelated to wireless E911  implementation, and 9 other states had attempted to do so. For example, in  one state, more than $40 million was taken from the E911 fund for  unrelated purposes, and an additional $25 million is expected to be taken in  2004. The state contact said that if the redirection of funds continues, it  would bring E911 upgrades to a halt. Another state E911 contact told us  that the use of some E911 funds for other purposes had hindered the ability  of PSAPs to purchase necessary computer upgrades and mapping software.  In another state, funds had not been redirected to other purposes, but the  E911 funds were “frozen” by the state’s legislature and could not be used by  the PSAPs to implement Phase II. The state E911 coordinator told us that  the state’s E911 fund had sufficient monies to implement Phase II  statewide, but many PSAPs could not move forward until the state’s  legislature allocated funds for E911 initiatives, and it was unclear when or  if that would occur.
In addition to the redirection of E911 funds, our survey of state contacts  found that eight states have never instituted a statewide system for  collecting funds for wireless E911 purposes. In one state, for example, any  fee or tax proposed to be placed on the public must be approved by the  state’s voters, and legislation creating an E911 funding mechanism did not  receive voter approval. The state’s E911 contact told us that the proposed  legislation would have generated sufficient funds for deploying wireless  E911 statewide, but without the funding, most counties in the state will not  have Phase II implemented by 2005. Some of the other eight states have  experienced opposition to E911 funding because it is perceived as a tax;  another state has not addressed the issue of wireless E911 implementation  at all.
Another funding issue raised by survey respondents and by others we  interviewed was that rural PSAPs in particular face funding problems for  E911. For example, some states allocate funds to the PSAPs based on their  jurisdictional population, which may cause PSAPs serving small or rural  communities in those states to receive insufficient funds to implement  E911. While many of the costs involved in purchasing upgraded equipment  and mapping software are similar for PSAPs serving large and small  communities, PSAPs that receive fewer E911 funds because of their  smaller population base may not have adequate funds to purchase the  necessary equipment and software. Two wireless carriers told us that  numerous PSAPs they serve had either withdrawn or suspended their  request to wireless carriers for Phase II service because of funding  constraints.
Wireless carriers also incur various costs to implement E911. For example,  two wireless carriers told us they had spent about $50 million each to date  to deploy E911, and three others said their costs would exceed $100 million  each. Several of the small wireless carriers we interviewed in our case  studies said that funding E911 technologies is particularly difficult for them  because of their limited revenues and that raising their rates would risk  their competitiveness in the market. While FCC requires wireless carriers  to implement E911, the Commission has not mandated as a prerequisite to  implementation that the carriers be reimbursed for their E911 expenses.Although responses to our survey showed that 32 states and the District of  Columbia allow wireless carriers to recover their E911 costs from the state  funding mechanism, state E911 contacts sometimes reported that it might  be difficult for the carriers to recoup all of their E911 costs. For example,  some states only allow the wireless carriers to be reimbursed if funds were  appropriated for that purpose, and other states told us that only certain  wireless carrier expenditures could be reimbursed. The wireless carriers  we contacted said it was unlikely that all of their costs would be fully  recovered, especially since cost recovery mechanisms are not available in  all states. One wireless carrier told us that in some states, the E911  surcharges imposed on customers do not generate sufficient revenue to  pay for both PSAP and carrier costs incurred in E911 deployment. Another  wireless carrier said that some states make it so difficult for the wireless  carrier to recover its costs that the carrier will not even attempt to get  funds from those states. Since it is unlikely that all E911 implementation  costs can be recovered through the states, several of the wireless carriers  we contacted have chosen to charge their subscribers an additional  monthly fee to help pay for E911 costs.
section_title: Problems with Coordination Continue to Slow Wireless E911 Deployment
paragraphs: As noted earlier, the deployment of wireless E911 systems requires  wireless carriers, LECs, and PSAPs to work together in distinct yet  interdependent roles. However, according to some contacts we  interviewed, delays sometimes occur because the various parties have  difficulty coordinating their activities or working together. There was no  consistency across the interviews as to which party (or parties)—wireless  carriers, LECs, or PSAPs—was most hindering wireless E911 deployment.
The difficulties in coordination between the parties at times caused  frustration, according to some contacts we interviewed. For example,  representatives from two of the PSAPs we contacted noted that just  determining the number of wireless carriers providing service in their  PSAP’s jurisdiction can be difficult. One PSAP administrator told us that in  order to get a complete list of providers before sending out his request  letters for Phase I, a PSAP employee drove around the county to identify  the cell tower owners and contacted them to obtain the names of the  wireless carriers leasing space on the towers. The PSAP administrator  noted as well that tracking down the right contact person at the wireless  carrier was difficult.
In another example, representatives from several wireless carriers said that  some PSAPs had requested E911 service from the wireless carriers even  though the PSAPs’ call centers were not yet ready to receive caller location  information because the proper equipment had not yet been installed. This  might occur because some PSAPs fail to understand what is required of  them technologically and what tasks they need to complete prior to  requesting E911 service. Traditionally, PSAP administrators have focused  on public safety and emergency response, not telecommunications. The  complexity of implementing wireless E911, however, has forced PSAP  administrators to become telecommunications project managers and to  learn about the technology involved.
We also were told that LECs have contributed to implementation delays.  One PSAP representative told us that difficulties encountered with the LEC  were a major obstacle to implementing wireless E911 and that the LEC  delayed installing lines necessary for wireless E911 for 4 months, which  greatly slowed the process. Because of continuing problems with the LEC  in this location, the PSAP purchased its own call routing equipment.  Similarly, another PSAP representative told us the main obstacle they faced  in implementing E911 was working with the LEC. The PSAP representative  noted that no one contemplated the role the LEC would play in the  implementation of E911 and that this has led to problems and delays. A  number of stakeholders we interviewed believed that FCC needs to be  more involved with the LECs to ensure they are an active player in wireless  E911 implementation. For example, an official representing a public safety  association stated that FCC should closely monitor the role that the LECs  play in wireless E911 implementation and should employ its oversight role  to facilitate corrective action to expedite wireless E911 compliance.  Several of those we interviewed in our case studies suggested that FCC  take on greater enforcement of the LEC role in E911 implementation, and  perhaps consider placing deadlines on LECs to respond to PSAP requests  for E911 upgrades. According to FCC, the Commission does not have clear  jurisdiction over wireline carriers with regard to wireless E911  implementation, and the Commission looks to the state public utility  commissions, which have clear and sufficient authority to take the lead.  However, FCC has indicated that it is committed to monitoring the LECs’  implementation role to ensure that they are meeting their responsibilities  with regard to E911 deployment.
In response to these problems with coordination, many industry  representatives and affected parties we contacted noted that a strong,  knowledgeable state E911 coordinator was the key to helping to coordinate  the parties and successfully implement wireless E911 services within the  state. Many believed that those states with strong state E911 coordinators  had made the most progress with wireless E911 implementation. These  state coordinators perform tasks such as educating PSAPs about their wireless E911 responsibilities, providing technical assistance to PSAPs, bringing all parties together early on to discuss implementation issues  and providing a single point of contact for all the parties, and  lobbying for E911 funding and protecting the funding from being used  for purposes unrelated to wireless E911 implementation.
Besides voicing support for effective state coordinators, those we  interviewed provided several illustrations of actions their states were  taking to facilitate wireless E911 implementation:
Several parties we spoke with mentioned that they had had a conference  call or meeting early on between the wireless carrier, LEC, and PSAP to  talk through the process and try to identify problems.
Kentucky requires all PSAPs to go through a certification process with  the state board to ensure preparedness for both wireline and wireless  E911 implementation. This certification process was created to  establish an overall uniformity for the state’s PSAPs. By using a  checklist for upgrades and an inspection process, Kentucky expects all  of its PSAPs that go through the certification process will be Phase II  operational by January 2005.
California purchases equipment at the state level to create advantages in  negotiating contracts with vendors and to create economies of scale in  equipment purchases.
Indiana has an elected official in charge of funding, which provides for  greater visibility of the E911 issue in the state and helps protect against  redirection of E911 funds to other uses.
Virginia contracts with several technical consulting firms for wireless  E911 implementation. The PSAPs are allowed to use contractors from  this pool and can use the wireless E911 funding they receive from the  state to pay for contractors’ services. This arrangement provides needed  technical assistance for PSAPs while allowing greater oversight of the  contractors.
section_title: Early Problems with Location Technology Appear Resolved, but Technical Challenges Remain Regarding New Wireless Devices and Services
paragraphs: During our interviews, we were told that the basic technology for  accurately determining the location of a wireless caller and systematically  providing that data to PSAPs has now been developed. Some noted that  although occasional problems still arise due to a particular wireless  carrier/LEC/PSAP equipment configuration, these problems are lessening  as the parties gain experience with E911 implementation. A representative  of one LEC noted that the “challenging years” of coordinating  interconnection between the LEC and the wireless carrier seem to be  behind them and that implementation now generally tends to proceed more  smoothly.
We asked the officials we interviewed what they saw as the remaining  technical issues affecting wireless E911 implementation. Several parties  mentioned a variety of technical problems that might slow wireless E911  implementation or affect the quality of 911 services in general. Problems  that were mentioned include the following:
Because the United States never adopted a single standard for mobile  phone transmissions, the different systems used by wireless carriers are  not always compatible with one another, which can affect the ability of a  particular subscriber to reach 911 in the first place if they do not have a  phone that can be used with multiple systems.
While GPS can provide more accurate location data, concerns exist over  the time it takes for location data to be calculated and delivered to the  PSAP. In the context of an emergency call, even a wait of 10 or 20  seconds for the location data to be processed is considered a loss of  valuable time.
For rural wireless carriers that have selected a network-based solution,  cell towers often are placed in a straight line and spaced widely apart  along highways or other roads. This can make the determination of  location difficult because the towers cannot accurately triangulate the  location of the caller. Additionally, the handset-based solution may not  be immediately available due to equipment issues.
Another problem was raised by some of those we interviewed: the  antiquated wireline 911 infrastructure that conveys many E911 calls from  the wireless carrier to the PSAP. This issue was also raised by Dale  Hatfield, former chief of FCC’s Office of Engineering and Technology. In  2001, FCC asked Mr. Hatfield to conduct an inquiry into the technical and  operational issues associated with wireless E911 deployment. His October  2002 report to FCC noted that the wireline 911 network is fundamentally  unchanged since its inception in the 1970s and that the existing 911  infrastructure “is in no condition to accommodate the pervasive use of  wireless technologies, the Internet, or the many other product offerings  that invite or demand access to 9-1-1 services.” Those offerings include  new wireless technologies that could send E911 calls (e.g., automatic crash  notification systems on cars that would also be able to send information to  the 911 call taker about whether air bags have deployed or whether the car  has flipped over), and the 911 services may need to be expanded to  encompass such technologies. Many of those with whom we spoke  believed that such new technologies should be considered now, rather than  later. Some were critical of the LECs’ failures to upgrade to modern digital  technologies that would facilitate the rollout of wireless E911 technologies  and improve 911 services. FCC released a notice of proposed rulemaking to  reevaluate the scope of communications services that should provide  access to 911 and has received comments and reply comments from  interested parties. NENA is also trying to address the issue of new  technologies and of a “future path plan” for the 911 network.
section_title: The Recent Actions of FCC and DOT Are Focused on Enforcing Deadlines on Wireless Carriers and Improving Deployment Coordination
paragraphs: FCC and DOT have been involved in the implementation of wireless E911,  but federal authority in overseeing the deployment is limited because of the  traditional state and local jurisdiction over emergency response services.  The primary federal agency involved in wireless E911 deployment is FCC.  One of FCC’s goals is to ensure the wireless carriers comply with their  current implementation schedules. As noted earlier, FCC in the past had  granted waivers to many of the wireless carriers in order to give them more  time to resolve technical issues associated with developing wireless  location technologies. Because many of these hurdles have now been  overcome, FCC has stated that it will not hesitate to use its enforcement  power when the wireless carriers fail to meet their current deployment  timetables. For example, FCC officials noted that three wireless carriers  agreed to pay nearly $4 million to the U.S. Treasury for failure to comply  with intermediate deadlines in their E911 deployment timetables.
Beyond enforcing deadlines on wireless carriers, FCC has taken actions to  identify both roadblocks and best practices in wireless E911  implementation. For example, the Hatfield report made a number of  findings regarding obstacles to wireless E911 implementation. Those  findings involve wireless carrier implementation issues, cost recovery and  PSAP funding issues, and the lack of comprehensive stakeholder  coordination. Public comment was sought on the report in late 2002 and,  according to FCC, the Commission is currently considering both the  recommendations contained in the report and the comments received.FCC also conducted its first Enhanced 911 Coordination Initiative meeting  in April 2003. The meeting brought together representatives from the  federal government, the public safety community, wireless carriers, LECs,  and other interested stakeholders to share experiences and devise  strategies for expediting wireless E911 deployment. According to FCC,  lessons learned from the initiative include the following:
Strong leadership and vision are essential to ensure swift wireless E911  deployment.
State or regional points of contact are critical for prompt wireless  carrier deployment.
Wireless E911 in rural areas may pose additional challenges such as  financial hurdles and accuracy concerns.
Additionally, in August 2003, FCC announced the establishment of a  wireless E911 technical group to focus on network architecture and  technical standards issues. The group will be a subcommittee of the  Commission’s Network Reliability and Interoperability Council. Also in  August 2003, FCC announced a wireless E911 public awareness campaign  emphasizing coordination, outreach, and education. One of the first  outcomes of the campaign was an FCC advisory published for consumers  providing information on what people need to know about calling 911 from  a mobile phone. A copy of this consumer advisory is found in appendix II of  this report.
DOT also has efforts under way to promote wireless E911 implementation,  focusing on implementation issues at the state and local level. DOT  partnered with NENA to develop a Wireless Implementation Plan. One  major aspect of this plan is the creation of a clearinghouse of wireless E911  planning, implementation, and operations resources. The clearinghouse is  an attempt to gather and organize the best examples of information from  various states, work groups, and ongoing development efforts. The  clearinghouse also includes various forms used by parties across the nation  in implementing E911 agreements. As discussed earlier, another major  component of DOT’s efforts is the sponsorship of a PSAP database (under  contract with NENA) that tracks the current status of wireless E911  implementation across the country.
DOT also convened a Wireless E911 Steering Council to develop a Priority  Action Plan, released in May 2003, that outlines six priorities for wireless  E911 implementation:  1.	 Establish support for statewide coordination of wireless E911  technology, and identify points of contact within each state for each of  the stakeholders.  2.	 Help to convene stakeholders in appropriate 911 regions in order to  facilitate more comprehensive, coordinated implementation of wireless  location technologies.  3.  Examine cost recovery and funding issues at the state level.  4.	 Initiate a knowledge transfer and outreach program to educate PSAPs,  wireless carriers, and the public about wireless location issues.  5.	 Develop a coordinated deployment strategy encompassing both rural  and urban areas.  6.	 Implement a “model location program” to identify and isolate potential  barriers to wireless E911 deployment.
Work on implementing this plan was in its early stages at the time we  concluded our review. However, DOT had subdivided each priority into a  number of action items, identified lead agencies or associations for each  action item, and established a time frame for completion of each action  item.
FCC and DOT staff told us that the agencies coordinate their wireless E911  activities to avoid duplication of effort. An FCC representative attends DOT  meetings and events on wireless E911 to stay current with the department’s  activities; similarly, a DOT representative attends FCC meetings and  initiatives on wireless E911. DOT officials noted that their efforts have  been concentrated on providing assistance at the PSAP level since FCC has  authority over the wireless carriers and LECs. While the agencies do not  currently jointly staff or fund any wireless E911 projects, FCC officials  noted that more formalized coordination is possible in the future.
section_title: Conclusions
paragraphs: Without the readiness of all parties—wireless carriers, LECs, and PSAPs—  there can be no wireless E911 service. Efforts by FCC to monitor the  progress of the wireless carriers in meeting their timetables and take  enforcement actions, as warranted, will continue to be an important part of  the implementation process. Still, given current E911 funding and  coordination problems related to upgrading PSAPs at state and local levels,  the pace of wireless E911 deployment could be similar to what happened  with wireline E911, which took many years to implement nationwide. If this  holds true, consumers and emergency management officials will be faced  with a geographic patchwork of wireless E911 areas: Some will have  service; some will not. As Americans travel across the country, they will be  uncertain as to whether their 911 calls will convey their location. However,  successful wireless E911 deployment is possible, as illustrated in some  areas of the country. States and localities can benefit from the experiences  and best practices of others and adapt them to their own situations.  Continued efforts by the FCC, DOT, and the public safety community to  identify and publicize these successes will be a valuable means of  facilitating the deployment.
During this transition period, it is important to accurately measure  progress in wireless E911 deployment so that federal, state, and local  officials can assess whether problems are arising in parts of the country  that may require additional actions. This information would also help build  public awareness of where this service is available and may stimulate  action at the state and local level. Measuring the progress of wireless E911  implementation against the goal of full nationwide Phase II deployment  depends on being able to compare the number of PSAPs that are receiving  wireless Phase II location data with the total number of PSAPs that need to  be upgraded. We found, however, that there is a lack of information on the  total number of PSAPs that need to be upgraded. While FCC and DOT have  taken important actions to track wireless E911 deployment, additional  work is needed to create reliable data on how many of the more than 6,000  PSAPs will need to be upgraded.
section_title: Recommendation for Executive Action
paragraphs: In order to provide the Congress and federal and state officials with an  accurate assessment of the progress being made toward the goal of full  deployment of wireless E911, we recommend that the Department of  Transportation work with state-level E911 officials, the National  Emergency Number Association, and other public safety groups to  determine which public safety answering points will need to have their  equipment upgraded. This information should then be reflected in the  PSAP database managed by NENA under contract with DOT. This will  provide the baseline needed to measure progress toward the goal of full  nationwide deployment of wireless E911 service.
section_title: Agency Comments
paragraphs: We provided a draft of this report to DOT and FCC for review and  comment. DOT stated that it generally agreed with our recommendation,  and FCC offered some technical comments that we incorporated into the  report where appropriate.
As agreed with your office, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 14 days after the  date of this letter. At that time, we will send copies to interested  congressional committees; the Chairman, FCC; the Secretary, Department of Transportation; and other interested parties. We also will make copies  available to others upon request. In addition, this report will be available at  no cost on the GAO Web site at http://www.gao.gov. If you have any  questions about this report, please contact me at (202) 512-6670 or goldsteinm@gao.gov. Key contacts and major contributors to this report  are listed in appendix III.
section_title: Scope and Methodology
paragraphs: To provide information on the progress made in deploying wireless E911  services throughout the country, we conducted a telephone survey of the  state E911 contacts. We completed surveys for 50 states and the District of  Columbia. We pretested the questions with five state contacts from states  we had spoken with earlier in our research. We revised the survey as  appropriate based on responses during pretesting. For each state and the  District of Columbia, we began by contacting the person named on the  FCC’s Web site at http://www.fcc.gov/911/stateplans/contacts.html as the  point of contact for that state.In 25 states, the person named on FCC’s  Web site did complete the survey. In the remainder of our surveys, we were  directed to another person. The survey contained 17 questions about the  state’s progress in implementing Phase I and Phase II, problems  encountered, funding mechanisms in place, and the role of the state  coordinator or any state offices involved in wireless E911 implementation.  The questions were open-ended and were read to the respondents. Surveys  were completed between June 11 and September 12, 2003. In addition to  our survey results, we used data from the National Emergency Number  Association (NENA) to illustrate the progress of wireless E911  implementation as of October 2003. To assess the reliability of NENA’s data  regarding information on total costs to upgrade PSAPs to Phase II  readiness and the number of PSAPs receiving Phase II data as of the August  1, 2003, FCC quarterly filings, we interviewed knowledgeable officials from  NENA about their data collection methods and reviewed any existing  documentation relating to the data sources. We determined that the data  were reliable enough for the purposes of this report.
To provide information on the factors affecting wireless E911 rollouts  across the country, we selected nine states (California, Idaho, Indiana,  Kentucky, Maryland, Missouri, South Carolina, Texas, and Virginia) and the  District of Columbia for case studies. We selected states that were spread  geographically across the U.S. and that appeared to be having various  levels of success with wireless E911 implementation based on early  research. In particular, we selected at least one rural state and at least one  state known to have redirected funds collected for E911 implementation to  other uses. For each case study, we interviewed (in person or by telephone)  the state coordinator, a small wireless carrier serving that state, and one  urban PSAP and one rural PSAP within the state. In addition to our case  studies, we interviewed representatives from four public safety  associations and two wireless industry associations. We interviewed  representatives from five large national wireless carriers and received  written responses to our questions from a sixth large national wireless  carrier. We also interviewed representatives from six local exchange  carriers and one manufacturer of mobile phones.
To provide information on current federal government actions to promote  the deployment of wireless E911 services, we spoke with officials at FCC  and DOT about their involvement in wireless E911 implementation. We  reviewed relevant orders, filings, and other materials from FCC docket  number 94-102 on E911 implementation. We researched relevant materials  from both FCC and DOT, such as DOT’s Priority Action Plan. We attended  FCC’s daylong Enhanced 911 Coordination Initiative in April 2003.
Statistics presented in the first paragraph of the report are from the  Cellular Telecommunication & Internet Association, unless otherwise  noted. Statistics presented in the first paragraph of the background section  are from NENA. All of these statistics are presented for background  purposes and were not verified by GAO.
We conducted our review from January 2003 through October 2003 in  accordance with generally accepted government auditing standards.
section_title: FCC Consumer Advisory about Calling 911 from Your Wireless Phone
paragraphs: Among other responsibilities, FCC’s Consumer & Governmental Affairs  Bureau educates and informs consumers about telecommunications  services. To this end, the Bureau has produced a number of consumer  alerts and fact sheets. Among these is a new consumer advisory entitled  “What You Need to Know about Calling 911 from Your Wireless Phone.”  This consumer advisory is reprinted on the following pages and can be  accessed at FCC’s Web site at www.fcc.gov/cgb/consumerfacts/e911.html.
section_title: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to those named above, Michele Fejfar, Deepa Ghosh, Sally  Moino, Mindi Weisenbloom, Alwynne Wilbur, and Nancy Zearfoss made key contributions to this report.
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