911 Services: Most States Used 911 Funds for Intended Purposes, but FCC Could Improve Its Reporting on States' Use of Funds
Published: 2013-04-18T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Wireless E911 service refers to the capability of 911 call takers to automatically receive location information from 911 callers using mobile phones. The current E911 system is not designed to accommodate emergency communications from the range of new technologies in common use today that support text, data, and video. Although deploying wireless E911 and NG911 is the responsibility of state and local governments, FCC is required by law to report annually on the funds states collect to provide 911 services such as E911. The Next Generation 911 Advancement Act of 2012 required GAO to review states collection and use of 911 funds. In this report, GAO presents information on (1) progress implementing wireless E911 in the last decade, (2) states collection and use of 911 funds and the usefulness of FCCs reporting on this issue, and (3) challenges to implementing NG911 services and federal efforts to facilitate its deployment. GAO reviewed FCCs annual reports, states responses to FCCs information-collecting efforts, and documents from FCC and DOT regarding E911 and NG911. GAO reviewed best practices for collecting and analyzing data and interviewed federal and state officials and other stakeholders.
section_title: What GAO Found
paragraphs: Although states faced challenges and delays in the past, states have made significant progress implementing wireless Enhanced 911 (E911) since 2003. Wireless E911 deployment usually proceeds through two phases: Phase I provides general caller location information by identifying the cell tower or cell site that is receiving the wireless call; Phase II provides more precise caller-location information, usually within 50 to 300 meters. Currently, according to the National Emergency Number Association (NENA), nearly 98 percent of 911 call centers, known as Public Safety Answering Points (PSAPs), are capable of receiving Phase I location information, and 97 percent have implemented Phase II for at least one wireless carrier. This represents a significant improvement since 2003 when implementation of Phase I was 65 percent and Phase II was 18 percent. According to NENA's current data, 142 U.S. counties (representing roughly 3 percent of the U.S. population) do not have some level of wireless E911 service. The areas that lack wireless E911 are primarily rural and tribal areas that face special implementation challenges, according to federal and association officials.
According to data collected by the Federal Communications Commission (FCC), all 50 states and the District of Columbia reported collecting--or authorizing local entities to collect--funds for wireless E911 implementation, and most states reported using these funds for their intended purpose. Six states--Arizona, Georgia, Illinois, Maine, New York, and Rhode Island--reported using a total of almost $77 million of funds collected for 911 implementation for other purposes (e.g., transferring 911 funds to the general fund) in 2011. Using funds in this way is permissible by state law in these states, but it creates the risk of undermining the credibility of 911 fees in those states. The manner in which FCC collects and reports information on state 911 funds limits the usefulness of its annual report. In particular, contrary to best practices for collecting and analyzing data, FCC uses only open-ended questions to solicit information from states, lacks written guidelines for interpreting states' responses and ensuring that results can be reproduced, and does not describe the methodology used to analyze the data it collects. As a result, FCC is missing an opportunity to analyze trends and to provide more detailed aggregated information that would be useful to decision makers.
Next Generation (NG911) will enable the public to reach PSAPs through voice and data, such as text messages, but stakeholders have identified a variety of technical, regulatory, and funding challenges to implementing it. For example, many of the existing state and federal regulations governing 911 were written before the technological capabilities of NG911 existed. The federal government is taking steps to help states address challenges. In particular, the Department of Transportation (DOT) has focused on research through the NG911 Initiative, and FCC released a 5-point plan to encourage NG911 implementation. FCC's plan includes (1) developing location accuracy mechanisms for NG911; (2) enabling consumers to send text, photos, and videos to PSAPs; (3) facilitating the completion and implementation of NG911 technical standards; (4) developing a governance framework for NG911; and (5) developing a funding model for NG911. FCC also released a report in March 2013 that detailed specific recommendations to Congress for a legal and regulatory framework for NG911.
section_title: What GAO Recommends
paragraphs: FCC should follow best practices for data collection and analysis to improve its current method of collecting and reporting information on state 911 funds. In response, FCC concurred with GAO's recommendation and agreed to take action to address it.

section_title: Letter
paragraphs: Knowing the location of a 911 caller facilitates the quick and accurate  dispatch of emergency responders such as police, firefighters, and  ambulance crews. However, in some cases, response services need to  be able to automatically identify the caller’s location, such as in the case  of a 911 caller who cannot speak because he is suffering a heart attack or  a caller reporting an accident along a highway who does not know the  exact location. Basic 911 service provided Americans with an easily  remembered universal number that connects the caller to an emergency  response center. Enhanced 911 (E911) service is a technological  improvement that automatically provides the street address and callback  number of a wireline caller or, in the case of wireless E911, the  approximate geographic location of the mobile phone used to place a 911  call and the callback number of the person calling. The continuing  evolution of communications technologies and wireless phones has  implications for 911 services. Since 911 call centers predominantly use  older, analog-based infrastructure and equipment, the current E911  system is not designed to accommodate emergency communications  from the range of new technologies in common use today, including text  and picture messaging and Voice-over-Internet Protocol (VoIP) telephony  (e.g., Skype). In response to changing technologies, the Department of  Transportation (DOT) launched the Next Generation 911 (NG911)  Initiative, which has focused on the research required to develop an  NG911 system. With NG911 services, the public could reach 911 call  centers through various modes, including voice and data, and transmit  multi-media information such as video. Deploying and operating wireless  E911 (and NG911 going forward) is the responsibility of government  entities at the state, county, or local level, although the federal  government has taken steps to facilitate the nationwide deployment.
The Federal Communications Commission (FCC) is required by law to  report to Congress on the identity of the states, territories, or political  subdivisions (such as counties or localities) that collect taxes, fees, or  other charges for emergency communications such as E911. This  reporting includes the amount of those revenues used for purposes other  than the ones specified by the state’s method of funding 911. FCC has  been preparing these mandated reports since 2009 based on states’  responses to FCC’s public notices seeking relevant information.  Hereafter, we will refer to states, territories, and political subdivisions as  “states.” The Next Generation 911 Advancement Act of 2012 mandated  that we review states’ collection and use of 911 funds. To provide  context for our review, we also examined the progress of E911  implementation and federal efforts in this area. This report presents  information on (1) the progress that has been made in implementing  wireless E911 in the last decade, (2) the extent to which states are  collecting and using 911 funds for 911 purposes and the usefulness of  FCC’s annual reports on states’ 911 funds, and (3) challenges to  implementing NG911 services and federal efforts to facilitate its  deployment.
To address these issues, we analyzed county and state-level E911  implementation information collected by the National Emergency Number  Association (NENA) as of December 2012, reviewed our previous  reports on wireless E911 implementation, analyzed FCC’s 2010 through  2012 annual reports on state collection and distribution of 911 and E911  fees and charges, reviewed states’ responses to FCC’s information- collecting effort associated with these reports, and analyzed comments  submitted by government, industry, and association officials in response  to FCC’s public notice on NG911. In assessing the usefulness of FCC’s  reporting, we reviewed best practices set forth in our previous reports.  To determine the reliability of the data used in FCC’s annual reports, we  reviewed relevant documentation, and interviewed cognizant officials  about their processes for reviewing the data and ensuring their accuracy.  We determined that the NENA E911 implementation data and, with  certain exceptions subsequently noted in this report, the information  related to FCC’s reports to Congress are sufficiently reliable for the  purposes of this report. We gathered further information from state  officials in the states that reported using E911 funds for other purposes  during calendar year 2011: Arizona, Georgia, Illinois, Maine, New York,  and Rhode Island.NG911 pilot project and visited Illinois, where we interviewed officials  from the state 911 office, officials associated with a regional NG911   We interviewed officials associated with a Texas  project, and representatives from rural counties in southern Illinois that  have not begun E911 implementation. We chose to visit Illinois because  stakeholders mentioned its regional NG911 project and because the state  had reported using E911 funds for other purposes in its 2010, 2011, and  2012 reports to FCC. We interviewed Texas officials with responsibility for  the state’s NG911 pilot project because Texas received the largest 911  grant from the National Telecommunications and Information  Administration (NTIA) and National Highway Traffic Safety Administration  (NHTSA) and because stakeholders mentioned that the state was making  progress on implementing NG911. We selected these states for the  specific reasons noted above and the information we obtained is not  generalizable to any other states. We also interviewed officials from FCC,  DOT, and the Department of Agriculture (USDA) as well as  representatives from associations including NENA, the National  Association of State 911 Administrators, the Association of Public-Safety  Communications Officials, the Competitive Carriers Association, and  CTIA-The Wireless Association.
We conducted this performance audit from July 2012 to April 2013 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives. Further details on our scope  and methodology can be found in appendix I.
subsections: section_title: Background
paragraphs: Nationwide implementation of E911 by local wireline telephone  companies began in the 1970s. With wireline E911 service, emergency  calls are automatically routed to the appropriate 911 call center, and the  call taker receives the telephone number and street address of the caller.  In 1996, FCC adopted rules for wireless E911. Wireless E911 technology  provides emergency responders with the location and callback number of  a person calling 911 from a mobile phone. Implementing wireless E911  involves deploying technologies that are able to calculate the geographic  coordinates of the caller’s location at the time of the call and display these  coordinates as a location the call taker can understand. When a wireless  caller dials 911, the call must be routed along the networks of both a  wireless telephone company and a wireline telephone company before  terminating at a call center, known as a Public Safety Answering Point  (PSAP). There are more than 6,000 PSAPs nationwide, often at a county  or city level. PSAPs vary in size and technical sophistication. Some large  urban PSAPs have dozens of call takers and split the functions of call  taking and dispatching the proper emergency responder. Smaller PSAPs  are sometimes staffed by only two or three call takers who also handle  dispatch. In some rural areas, the PSAP may be the sheriff’s office.
As shown in figure 1, the wireless carriers, local exchange carriers, and  PSAPs must have appropriate equipment and interconnections for  wireless E911 calls to be sent to and received by PSAPs with the caller’s  location information. For example, wireless carriers must finance the  implementation of a caller location solution and test their equipment to  verify its accuracy. Local exchange carriers are generally responsible for  ensuring that all the necessary connections between wireless carriers,  PSAPs, and databases have been installed and are operating correctly.  The original E911 system was designed to carry only the caller’s  telephone number with the call, and the associated fixed address was  obtained from an established database. Wireless E911, however,  requires more data items, and the mobile caller’s location must be  obtained during the call and delivered to the PSAP separately using  additional data delivery capabilities. To translate the latitude and  longitude location information into a street address, PSAPs usually must  acquire and install mapping software. PSAPs may also need to acquire  new computers to receive and display this information. Getting PSAPs the  technology needed to receive wireless E911 location information is  primarily a state and local responsibility because PSAPs serve an  emergency response function that has traditionally fallen under state or  local jurisdiction. As a result, states and local jurisdictions establish  timetables for implementation by their PSAPs and fund the equipment  upgrades needed by their PSAPs for E911 service.
The only federally mandated time frames for implementing wireless E911  technologies are those placed on wireless carriers by FCC. In 1996, FCC  responded to the rising number of mobile telephone subscribers and the  resulting increase in wireless 911 calls by adopting rules for wireless  E911 that established a two-phase implementation approach for the  wireless carriers and set deadlines for wireless carriers regarding their  part in E911 deployment.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,   FCC required that (1) by April 1998, or within 6  generally within 50 to 300 meters (Phase II information). As we reported  in 2006, most states and the District of Columbia collect fees to cover the  costs of implementing wireless E911. States collect fees on a variety of  telecommunications services including wireline, wireless, “prepaid  wireless,” and VoIP.
DOT has recognized the relationship between wireless E911 services and  highway safety and, in 2001, contracted with NENA to develop a  state/county database that tracks E911 implementation. As part of the  contract, NENA created a database of counties, including information  about implementation of wireless E911, which is updated with data  gathered directly from state and county representatives. Now completely  funded by NENA, the database is accessible through  http://www.nena.org.
The New and Emerging Technologies 911 Improvement Act of 2008  (NET 911 Act) requires FCC to submit an annual report to Congress  detailing the status in each state of the collection and distribution of fees  or charges for the support or implementation of 911 or E911 services to  ensure transparency and accountability. The annual reports are to include  findings on the amount of revenues obligated or expended by each state  or political subdivision thereof for any purpose other than the purpose  specified in the state or local law adopting the fee or charge. FCC has  submitted four reports to Congress covering the state activities of  calendar years 2008 to 2011. In addition, the National 911 Program— housed within NHTSA’s Office of Emergency Medical Services—has  helped to provide federal leadership and coordination in supporting and  promoting optimal 911 services."  Because of changes in the public’s use of communications technology  and the aging infrastructure of the legacy 911 network, 911 services are  transitioning to an NG911 system that uses Internet Protocol (IP)-based  technology to deliver and process 911 traffic. Such a system will provide  increased capabilities as shown in table 1. With NG911, PSAPs are  expected to be able to process all types of emergency communications  including voice, data, and video. According to NENA, Emergency  Services IP Networks are among the basic building blocks required for  NG911. They are managed, multipurpose networks that support public  safety communications services and use broadband technology capable  of carrying voice plus large amounts of data using Internet protocols and  standards. As part of the NG911 Initiative, DOT has created an NG911  system design and tested it to show that the design will be capable of  accommodating communications from a wider range of devices including  cellular calls, instant messaging, wireline calls, “telematics” (automatic  crash notification data directly from the vehicle), VoIP calls, and live video  feeds.
In September 2009, NHTSA and NTIA announced more than $40 million  in grants to help PSAPs implement E911 and NG911 technologies. To be  eligible for the program, the applicant had to certify that the state and  other taxing jurisdictions within the state had not used designated E911  funds for any other purpose than for which they were designated within  180 days preceding the application date. The grant period concluded at  the end of 2012. In all, NHTSA and NTIA awarded grants ranging from  $200,000 to $5.4 million to 30 states and territories to help implement  NG911 services. NHTSA officials told us that they are currently  conducting an evaluation of the grant program and that they will release a  final report on http://www.911.gov.
section_title: States Have Made Significant Progress Implementing Wireless E911
paragraphs: Although states faced challenges and delays in the past, they have made  significant progress implementing wireless E911. According to NENA  data as of March 2013, 98 percent of PSAPs are capable of receiving  Phase I location information and 97 percent have implemented Phase II  for at least one wireless carrier. This represents a significant  improvement in implementation since our previous reports in 2003 and  2006 as shown in table 2.
According to NENA data, 142 U.S. counties (representing roughly 3  percent of the U.S. population) do not have some level of wireless E911  service. According to federal and association officials, these areas are  primarily rural or tribal counties that face special challenges implementing  wireless E911 service. According to the National 911 Program, rural  agencies may lack the funding resources needed for technology  upgrades, equipment, and training. Rural and tribal areas typically are  large geographically but less densely populated than urban areas. In  addition, because it may take first responders longer to reach the scene  of an emergency, call-takers in PSAPs serving rural areas may be  required to stay on the phone longer with callers or provide more  extensive emergency instruction to callers until help arrives. Furthermore,  federal and local officials told us about the following specific challenges  facing rural and tribal areas:
Tribal lands face special challenges related to 911 services because  of several barriers to improving telecommunications on tribal lands.  We have previously reported that the barriers to improving  telecommunications on tribal lands most often cited by tribal officials,  service providers, and others we spoke with were the rural, rugged  terrain of tribal lands and tribes’ limited financial resources. These  barriers increase the costs of deploying infrastructure and limit the  ability of service providers to recover their costs, which can reduce  providers’ interest in providing or improving telecommunications  services. Other barriers include the shortage of technically trained  tribal members and providers’ difficulty in obtaining rights of way to  deploy their infrastructure on tribal lands.
The limited emergency response resources typical of rural areas can  be relatively quickly overwhelmed in disasters or large-scale incidents,  according to the National 911 Program. For example, officials from  rural counties in one state told us that their PSAPs were overwhelmed  with multiple calls following a recent derailed train incident. These  calls paralyzed their 911 systems and prevented other 911 calls from  reaching the PSAPs during the incident.
According to FCC officials, network-based “triangulation”—a solution  used by some wireless carriers to determine a caller’s location— depends on the ability of three cell towers to access the caller’s   Network-based triangulation can be particularly  mobile device.challenging in rural areas that have fewer cell towers than more  densely populated areas.
According to rural officials in one state we contacted, some homes in  rural areas do not have addresses and some streets do not have  names. Before E911 can be implemented in these areas, addresses  will have to be created and mapping of those addresses will have to  be completed so that automated location services can be provided.
Providing E911 services is primarily a state and local government  responsibility, but USDA has programs that are available to help rural and  tribal areas gain access to wireless E911 services. On September 12,  2011, USDA adopted a final rule that described program eligibility  requirements for a 911 Access Loan Program to make loans and loan  guarantees to finance the construction of interoperable, integrated public  safety communications networks in rural areas. These networks offer  several advantages, including the ability to precisely locate rural wireless  911 calls. Funds for this program are available through the Rural Utilities Service’s traditional Telecommunications Infrastructure Loan Program.In addition, USDA’s Community Facilities Program supports essential  infrastructure and services for public use in rural areas of 20,000 in  population or less. Financing for community facilities projects covers a  broad range of interests, including health care, education, public safety,  and public services. A USDA official said that this program could be used  in a variety of ways to help rural areas gain access to wireless E911,  including constructing PSAPs or providing the necessary equipment,  software, computer networks, and power supplies.
Even though some rural and tribal counties do not have wireless E911  service, almost 97 percent of the overall population has some Phase I  wireless coverage and approximately 98 percent has some Phase II  wireless coverage, according to NENA data. Furthermore, as shown in  figure 2, 25 states and the District of Columbia have fully implemented  wireless E911 Phase I and Phase II in all counties.
section_title: According to FCC’s Reporting, Some States Have Used 911 Funds for Other Purposes, but FCC’s Reporting Could Be More Useful
subsections: section_title: State Methods for Collecting 911 Funds
paragraphs: As we reported in 2006, all 50 states and the District of Columbia  collect—or have authorized local entities to collect—funds for 911. State  methods for collecting funds vary in structure, fee amounts, and services  covered, among other things. For example, some states collect fees or  charges for 911 and administer a statewide 911 program. Other states  authorize local entities to collect fees or charges for 911 and to administer  911 programs at the local level. Still other states use a combination of  these approaches. However, some local jurisdictions have not begun  collecting 911 funds even though they are authorized by their state to do  so.told us that their county had not begun collecting 911 funds—even though  they have state authorization to do so—because they would have had to  collect $10 per line per month to obtain enough funding to implement  E911.
Representatives from a rural county with a population under 5,000  Overall, in response to FCC’s request that states report the total amount  of 911 funds collected in calendar year 2011, 43 states reported  collecting—or authorizing local entities to collect—a total of about $2.3  billion, although because of how this information was collected, the actual  amount collected may be higher. States also reported a range of fees  collected. For example, states reported wireline and wireless fees ranging  from $0.08 to $5.00 per customer per month.
section_title: States’ Use of 911 Funds
paragraphs: According to FCC’s report, most states reported using 911 funds for  purposes consistent with their funding statutes in 2011. In addition to  spending 911 funds on implementing wireless E911 service, states and  localities use 911 funds for operations, maintenance, personnel, and  NG911 preliminary activities, among other things. However, six states— Arizona, Georgia, Illinois, Maine, New York, and Rhode Island—reported  using almost $77 million of funds collected for E911 implementation for  other purposes in 2011, as detailed below.funds for these purposes.
State laws permit using
Arizona. The state reported transferring 13 percent (or about $2.2  million) of funds collected for 911 purposes to its general fund to help  address the state’s budget crisis. Arizona also transferred 911 funds  to its general fund in 2009 and 2010. According to state officials,  these transfers occurred as part of a state budget bill that authorized  the transfers. Once funds were transferred to the general fund,  Arizona 911 officials could not be certain how they were spent. An  Arizona official said that, because of the transfers to the general fund,  Arizona had to return a $1.25 million grant to NHTSA and NTIA that  would have been used to help Arizona with its deployment of Phase II  of wireless E911.
Georgia. The state reported collecting $13.7 million in 911 fees for  prepaid wireless phones and did not allocate any of these funds for  911 use. Georgia also collected fees on prepaid wireless phones in  2009 and 2010 but did not allocate these funds for 911 use. According  to a written response from a Georgia official, Georgia law does not  require that these funds be appropriated for 911 purposes. The funds  were collected and deposited into the state’s general fund in  accordance with state law.
Illinois. The state reported legislatively transferring $2.9 million out of  the state’s 911 fund in state fiscal year 2012, which is funded by a  statewide fee on wireless subscribers and from which the state makes  monthly distributions to local 911 authorities. According to state  officials, these funds were transferred to another fund to maintain that  fund’s liquidity. Moreover, in calendar years 2010 and 2011, the state  borrowed $1.4 million and $5.2 million from the state’s fund used to  reimburse wireless carriers for E911-related expenses, which is also  funded by the statewide fee on wireless subscribers. These borrowed  funds were repaid within 18 months, as required by Illinois law.
Maine. As part of personnel service reduction initiatives, the state  reported imposing across-the-board furloughs and benefit reductions  on state employees, including personnel in the state 911 office, and a  little less than $25,000 was transferred from the state’s 911 fund to  the state’s general fund in 2010 and 2011. Because the salaries and  benefits for employees in the state 911 office are paid for exclusively  through 911 funds, the funds that went to the state’s general fund for  the furlough days and benefit reductions constituted using 911 funds  for purposes other than 911, in accordance with state law according to  the state’s submission to FCC. As a result, Maine was ineligible for  911 grant funds from NHTSA and NTIA.
New York. According to state officials, New York transferred $45  million from the State Wireless Telephone Emergency Account to the  state’s general fund, and made similar transfers to the general fund in  2009 and 2010. According to state officials, the transfer of these  funds, authorized by state statute, did not affect the ability of the state  to reimburse municipalities for approved 911 expenditures or to  otherwise support its 911 programs.
Rhode Island. Per the state’s method of funding 911, as provided for  in state statute according to state officials, revenues from the state’s  911 fees are deposited into the state’s general fund, and the 911  program receives its budget from the general fund. In 2011,  approximately $17.3 million was collected, but only approximately  $4.8 million was appropriated for the 911 program leaving about $13  million in the general fund. Fee revenues were similarly distributed in  2010 and 2011.
The District of Columbia and Louisiana did not report to FCC on their use  of 911 fees and charges for calendar year 2011. We made several  attempts to obtain this information, but officials did not respond to us.  However, we can provide information from their reports to FCC in  previous years.
District of Columbia. The District of Columbia reported to FCC in 2011  and 2010 on its collection and use of 911 taxes and fees. FCC did not  report that funds were used for purposes other than 911.
Louisiana. Louisiana did not submit a report to FCC on its taxes and  fees in 2010, but did in 2011. In that report, Louisiana did not directly  state whether funds were used for anything other than 911 purposes,  and FCC did not report that the state had used funds for other  purposes.
We have previously reported that misalignment between fees and  services for which they are charged reduces both equity and economic  efficiency. Moreover, stakeholders in other industries have reported that  misalignment between the amount of fee collections and expenditures  undermines the credibility of the fee. As states collect funds for 911  purposes and then use those revenues for other purposes, there is risk of  confusing stakeholders and members of the public who pay these fees  and undermining the credibility of 911 fees. However, states occasionally  pass laws allowing the use of 911/E911 fees for non-E911 purposes.  FCC officials have stated that they do not have the authority to override  state law in this regard.
section_title: Limited Usefulness of FCC’s Reporting
paragraphs: We have identified three features of FCC’s approach to collecting and  reporting information from states that are contrary to best practices set  forth in our previous reports on data collection and analysis, which have  limited the usefulness of FCC’s reports. Specifically, in its approach, FCC  (1) uses only open-ended questions to solicit information from states, (2)  lacks written guidelines for interpreting states’ responses and ensuring  that results can be reproduced, and (3) does not describe the  methodology used to analyze the information in states’ reports.
FCC has used only open-ended questions to solicit information on state  fees and charges for 911 services. FCC officials stated that they regard  this approach as the most effective way to elicit responsive information  from the states because it requires the states to explain their definitions  and procedures in plain language rather than responding to “yes/no”  questions or submitting purely quantitative data. We have previously  reported that while open-ended questions may be unavoidable when  engaged in exploratory work and can be useful to obtain responses that  might further clarify the meaning of answers to close-ended questions,   When answering open- open-ended questions have several limitations.ended questions, respondents may provide wide-ranging responses that  vary and may result in inconsistent information, making it very difficult to  consistently and completely tabulate or aggregate responses. Closed- ended questions, on the other hand, can yield data that may be easier to  meaningfully track and compare. FCC asks states to report, among other  things, the amount of 911 fees or charges imposed and the total amount  collected. States’ responses to this question varied widely and  respondents often omitted relevant information. For example, some states  clearly identified the services—wireline, wireless, pre-paid, and VoIP—to  which fees applied, while other states did not specify the services to  which fees applied. Because states were not specifically asked whether  they collected fees for specific services, it is unclear whether these counts  are inclusive or exclusive of these specific services. If FCC had asked  closed-ended questions that required respondents to address such  distinctions, FCC would have been better able to consistently track fees  for various services over time, which could address matters such as  whether 911 funding is evolving with changing technology. However,  since this information has not been asked in a way that it can be tracked,  trend analysis is not possible.
Moreover, when reporting the total amount of funds collected, states vary  widely in their manner of reporting. Some states provide a total amount  without any distinguishing features. Some states break out the amount  collected by state and local authorities; others break out the amount  collected by type of service. Some states provide an actual number  whereas others provide an estimate. Because of the open-ended  question format, it is nearly impossible to aggregate these results in a  useful manner. FCC does provide all state responses in an appendix to  its annual reports, and FCC officials stated that doing this facilitates public  review and discussion. The inclusion of these state submissions can  support public review, particularly in examining the relationship among  responses in a particular state. However, the provision of the state reports  may not readily lend itself to obtaining specific or discrete types of  information from the responses to the open-ended questions. For  example, one item asks whether the state has written criteria regarding  the allowable uses of the collected funds. This item is embedded in a  request for multiple pieces of information. If any interested parties wanted  to know how many states and which ones reported having written criteria,  they would have to read through all the responses to that item for all  submitting entities to obtain the information sought. A closed-ended item  could readily capture which state does and does not have written criteria.
We have previously reported that with open-ended questions, the  responses are often textual and not easily tabulated, and a process called  “content analysis” must be used to classify or code the responses. As  part of the process of conducting content analysis, a coding manual  should be prepared for use by those classifying the responses. A good  coding manual is viewed as indispensible in ensuring coding of the  highest quality, and an important measure for judging the quality of a  content analysis is the extent to which the results can be reproduced.  However, FCC officials told us that, while they describe the methodology  used to collect the data from states, they do not have an internal written  coding manual or similar document that describes how the content of a  state’s responses are interpreted or coded. FCC officials noted that this  had not been problematic to date because the same FCC staff members  had conducted the analysis each year but indicated that development of  such a manual would be helpful to ensure future continuity. Because  there is no written documentation on how this analysis was conducted,  nor the decisions rules that FCC followed in developing its summary  classification of responses, there is no basis for independently  reproducing the results of FCC’s analysis.
We also found that FCC has not been consistent in how it makes certain  characterizations in its report. For example, we identified three states— Georgia, Maine, and New York—that provided similar responses each  year but FCC characterized the responses differently in different years.  For example, Maine reported that it had transferred funds from the 911  fund to the general fund in calendar years 2010 and 2011 as part of a  statewide personnel reduction initiative, as described above. FCC  characterized Maine as using 911 funds for other purposes in its 2012  report but not in its 2011 report. In another example, Georgia reported  that 911 fees on prepaid wireless devices remained in the state’s general  fund rather than being allocated for 911 use in its 2010, 2011, and 2012  reports to FCC. FCC identified Georgia as having used funds for other  purposes in its 2010 and 2012 reports but not in its 2011 report. FCC  officials acknowledged that these three states should have been identified  as using funds for other purposes in its 2011 report, but that officials  corrected this in the 2012 report. However, FCC did not indicate in the  2012 report that a mistake was made in the 2011 report. A reader who  noted that the states were not listed as having used funds for other  purposes in the 2011 report, might believe that these states changed their  practices from one year to the next, when, in fact, the states reported  essentially the same information each year.
We also identified inconsistent characterizations in FCC’s summary table,  which indicates whether states used 911 fees or charges for other  purposes. In 2012, FCC used four ways of coding whether states used  funds for other purposes—”Yes,” “No,” “No information,” and “DNP”  (defined in FCC’s report as “did not provide”). However, “DNP” was used  in three very different circumstances: when the state did not submit a  report to FCC, such as in Louisiana and the District of Columbia; when  the state did not provide an answer to the question of whether the state  used funds for other purposes; or when the state indicated that all or a  portion of the funds are controlled by local entities and that the state could  not be certain how the funds were used. As an example of this last case,  several states indicated that local entities control some expenditure  decisions, which in some cases received the “DNP” designation, but in  other cases received the designation “No” or “No information.” If FCC had  written guidelines for interpreting state responses, it could have ensured  more consistent characterization of state responses.
According to FCC’s Information Quality Guidelines—which are meant to  ensure that all data FCC disseminates reflect a level of quality  commensurate with the nature of the information—quality is  demonstrated through the incorporation of a methodological section or  appendix that describes, at a minimum, the design and methods used  during the creation, collection, and processing of the data, as well as the  compilation or analysis of the data in products including reports prepared   In its annual reports, FCC included a detailed description  for Congress.of its methodology for collecting responses from states. For example,  FCC describes how, in addition to the public notices, FCC sent letters to  the Office of the Governor of each state and territory and the Regional  Directors of the Bureau of Indian Affairs requesting the information sought  in the public notices. FCC sent second notice letters and placed calls to  those states and territories that had not responded. However, FCC has  not published its methodology for how the report’s analysis was  conducted. In particular, FCC has not included in its annual report a  description of the decision rules used in determining whether a state used  911 funds for other purposes. As stated in the previous section, FCC  does not have an internal written procedures manual or similar document  that describes how the content of a state’s responses are interpreted or  coded. If FCC had one, it could use information from that coding manual  to explain its analysis and decision rules in its annual report.
The lack of a description of the methodology for FCC’s analysis is  particularly problematic as FCC officials told us that FCC changed its  method of making analysis decisions in its most recent report. FCC  officials stated that based on their experience with the first three  information collections and associated reports, FCC revised the questions  included in their 2012 information request. Specifically, one question was  modified to elicit specific information on the programs and activities for  which 911 funds were used along with how those programs and activities  support 911. According to FCC officials, this modification enabled FCC to  classify states’ responses with greater accuracy. While FCC’s 2012 report  clearly states that modifications were made to the questions and each  annual report includes the questions included in that year’s information  request, the effects of these changes are not clear to the reader. In some  cases, this methodological change resulted in differing characterizations  from reports issued in 2011 to 2012, and it is not clear to the reader  whether states no longer characterized as having used funds for other  purposes had changed their practices of using funds for other purposes  or whether the different characterization was a result of FCC’s change in  methodology. For example, in FCC’s 2011 report, FCC identified both  Virginia and West Virginia as states that had used 911 funds for other  purposes. However, based on the additional information provided by  these states in 2012, FCC determined that Virginia and West Virginia  spent 911 funds in accordance with their respective state statutes  governing 911 funding and therefore were not identified as using funds for  other purposes. According to FCC officials, in gathering information for  2012, FCC asked additional questions to identify the specific uses of  911/E911 funds that were authorized under state law. They also  characterized a state as using E911 funds for purposes other than E911  only if the state reported that is used 911/E911 funds for purposes not  designated by the state’s funding statute. Because FCC has not  published its methodology for analysis and decision rules for determining  whether a state used 911 funds for other purposes and further never  explicitly stated that a different method was used in 2012, this lack of  disclosure could lead report users to misinterpret the results shown in the  report. In particular, although it would appear that as time has passed,  fewer states were using funds for other purposes, at least some of this  difference is attributable to FCC’s change of methodology.
We have previously reported that results-oriented organizations make  sure that the information they collect are sufficiently complete and  accurate to support decision making. FCC officials stated that seeking  narrative responses from each state and publishing those responses  demonstrate transparency. However, several pages of individual and  varied responses may have limited usefulness to decision makers, who  may need high-level descriptions and aggregated information.  Furthermore, FCC is missing an opportunity to analyze funding trends  because its method of asking questions does not result in answers that  can be readily tracked from year to year. FCC is also missing an  opportunity to provide more detailed aggregated information in its  reports—such as amounts of fees, services covered, and total amount of  funds collected—that would be helpful to decision makers who are trying  to understand current methods of financing 911. FCC officials told us that  they are seeking comment from stakeholders on FCC’s required annual  report to Congress, as well as on information provided by states and  other reporting entities, and that they will use this information to improve  reporting.
section_title: Although NG911 Is in Preliminary Stages and Faces Challenges, the Federal Government Is Supporting NG911 Activities
subsections: section_title: NG911 Challenges and State Activities
paragraphs: To implement NG911 nationwide, states must address technology,  regulatory, and funding challenges, according to multiple government  officials. For example, technological changes need to be made at PSAPs  since existing call centers are incapable of some critical functions, such  as linking with one another during emergencies. As such, PSAP calls  currently cannot be transferred so PSAPs have limited means to act as  back-up for one another when operations in one part of the country  become overloaded or shut down because of circumstances such as  hurricane evacuations or wildfires, according to DOT’s Research and  Innovative Technology Administration. With respect to regulatory  challenges, current laws and regulations in most states do not effectively  enable the implementation of new technologies or allow the level of  coordination and partnerships among government and public safety  stakeholders, service and equipment providers, PSAPs, and 911  authorities that is necessary to implement IP-enabled 911 systems,  according to NHTSA. Moreover, in the National Broadband Plan, FCC  noted many of the existing state and federal regulations governing 911  were written before the technological capabilities of NG911 existed and   For example,  have therefore hampered the implementation of NG911.state, association, and industry officials have expressed concern about  uncertainty regarding liability protection related to NG911. Stakeholders  also expressed concerns about funding mechanisms for NG911. State  revenues from long-established funding methods tied to wireline services  are decreasing as more consumers disconnect their traditional home  phones in favor of wireless devices or other services such as mobile  VoIP.
Despite NG911 implementation challenges, many states have started  funding preliminary NG911 activities, and some areas have developed  regional NG911 projects. For example, in responding to FCC’s data  collection effort, 33 states reported that expenditure of 911/E911 funds for  NG911 activities is permissible under current state law. Of these, 16  states reported that funds had been expended in 2011 for some NG911  activities including planning, network development, and equipment  acquisition. As examples of regional NG911 projects, the Counties of  Southern Illinois Next Generation 911 project has been identified by  NENA as an early adopter of a regional approach to NG911. The project  includes connecting 21 PSAPs through an Emergency Service IP  Network, creating identical data centers in 2 counties, and obtaining  NG911 equipment and information for a 15-county region in southern  Illinois. Similarly, the state of Texas is conducting an NG911 project that  is partially funded with federal grants from NHTSA and NTIA. The project  involves constructing a detailed geospatial database of over 200 Texas  counties that will be needed for a statewide NG911 system. The database  should allow the new system to pinpoint the PSAP that needs to respond  to a caller based on location.
section_title: Federal Efforts to Address Challenges and Facilitate NG911 Implementation
paragraphs: Even though 911 services remain primarily a state and local government  responsibility and NG911 overall is in the early planning stages, FCC is  working with federal, state, and private sector partners to help states  address NG911 implementation challenges. For example, one of FCC’s  federal advisory committees—the Communications Security, Reliability,  and Interoperability Council (CSRIC)—makes recommendations to FCC  to promote reliable 911 service and issued a report in March 2011  framing the transitional issues to NG911. CSRIC members are selected  from public safety agencies, consumer or community organizations or  other nonprofit entities, and the private sector. FCC also released a 5- point plan, based on recommendations made in the National Broadband  Plan, to encourage NG911 implementation and to help states address  some of the technology, regulatory, and funding challenges to  implementation. Key elements of FCC’s 5-point plan include:
Develop location accuracy mechanisms for NG911. Existing location  technologies do not perform effectively in all environments. For  example, global positioning technologies may not work deep inside a  steel-and-concrete building, or even in a suburban residential  basement, but may work in wood frame construction or near office  windows. FCC officials said CSRIC plans to release a report in 2013  on indoor location accuracy.
Enable consumers to send text, photos, and videos to PSAPs. In  December 2012, FCC issued a notice of proposed rulemaking  examining rule changes meant to enable people to send text  messages to 911. The proposal was based on the voluntary  commitment by the four largest U.S. wireless carriers to make text-to- 911 available to their customers by May 15, 2014. The proposed  rulemaking would also require all wireless carriers and interconnected  text-messaging providers to send automatic “bounce back” error  messages by June 30, 2013, to consumers attempting to text 911  when the service is not available in order to inform consumers and  prevent confusion.
Additionally, NHTSA and NTIA have made more focused efforts to  address NG911 technology challenges. As required in the New and  Emerging Technologies 911 Improvement Act of 2008, NHTSA’s and  NTIA’s National E911 Implementation Coordination Office developed a  national plan in September 2009 for migrating to IP-Enabled 911  Systems, which lays a foundation for addressing technological challenges  associated with enabling consumers to send text, photos, and videos to  PSAPs.
Facilitate completing and implementing NG911 technical standards.
CSRIC has identified technical standards, related technical gaps, and  the overall readiness of the NG911 applications. In addition, CSRIC  has classified the importance and urgency of resolving the identified  technical gaps.
Develop a governance framework for NG911. As required by the Next  Generation 911 Advancement Act of 2012, FCC released a report in  March 2013 with detailed recommendations to Congress to create a  new legal and regulatory framework for transitioning from legacy 911  to NG911 networks. The report includes detailed information on the  major NG911 challenges and 24 specific recommendations to  Congress and others, such as state and local public safety authorities,  to address the challenges. For example, FCC recommended that  Congress promote a consistent nationwide approach to key elements  of NG911 deployment, including standards that support seamless  communication among PSAPs and between PSAPs and emergency  responders; appropriate liability protection to encourage technological  innovation and rapid deployment of NG911; and provisions to make  NG911 fully accessible to people with disabilities. In addition, NHTSA  has developed guidelines for state NG911 legislative language to help  address state regulatory challenges. In doing so, NHTSA obtained  input from local, regional, state, and federal public-sector  stakeholders, as well as private-sector industry representatives and  advocacy associations. NHTSA has also worked with the National  Conference of State Legislatures to create a database of 911 bills that  have been introduced in the 50 states and the District of Columbia.  The information is updated bi-weekly and includes information on  multiple topics including funding and appropriations.
Develop a funding model for NG911. Based on a CSRIC  recommendation, NHTSA is currently working with a contractor with  expertise in economics and a Blue Ribbon Panel to help states  develop new options for funding 911. According to NHTSA officials, a  report on this effort is expected to be released in 2014. In addition, in  FCC’s 2013 report to Congress on the legal and regulatory framework  for NG911 services, FCC made three recommendations to Congress  for updating NG911 funding mechanisms. Specifically, FCC  recommended that Congress should (1) develop incentives for states  to broaden the base of contributors to NG911 funding to more  accurately reflect the benefits derived from NG911 service, (2)  encourage states to provide funding for NG911 as well as legacy 911  purposes as part of any existing or future funding mechanism, and (3)  condition grants and other appropriate federal benefits on a  requirement that funds collected for 911/NG911 funding be used only  for 911 or NG911 purposes and provide for appropriate enforcement  of such requirements.
section_title: Conclusions
paragraphs: Most of the country has now implemented wireless E911 services, but  this took over a decade to accomplish. New technology and eroding  funding mechanisms have highlighted the need for 911 to evolve to a new  system that can accommodate next generation technologies and that is  based on an adequate source of funding to maintain the system. For  NG911 to avoid the slow start that wireless E911 experienced, networks  will need to be formed that will require regulatory changes at multiple  levels of government. Although NG911 is still in nascent form, FCC, DOT,  and others in the federal government are working together to conduct the  research and planning needed to provide the foundation for states to  address the technology, regulatory, and funding challenges to implement  NG911 more efficiently than they implemented E911. Notably, FCC’s  March 2013 report identified potential steps for Congress to take to create  a legal and regulatory environment that will assist states, PSAPs, service  providers and other stakeholders in accelerating the nationwide transition  from legacy 911 to NG911. The report provided 24 specific  recommendations to Congress and others, such as state and local public  safety authorities, to address the challenges of implementing NG911.
FCC has been collecting and reporting information on states’ use of 911  and E911 funds on an annual basis for 4 years and, as mandated by law,  will continue to do so. Collecting and reporting this information requires  resources from both FCC and the states, so it is in the best interest of all  parties for the information to be presented in the most useful way  possible. Given that FCC’s future annual reports will likely include  information on the transition to NG911 services, it is important that FCC  collect information in a way that provides information that can be tracked  over time. For example, as the federal government provides information  for states as they transition to a potential new funding system, it would be  helpful to have information that tracks current trends and patterns in state  funding. However, because FCC’s method of asking questions does not  result in answers that can be tracked from year to year, there is no federal  tool that can be used at this time to understand how or if states are  adjusting their funding for the transition to NG911. Furthermore, FCC is  missing an opportunity to provide more detailed aggregated information in  its reports—such as amounts of fees, services covered, and total amount  of funds collected—that would be helpful to decision makers. For  example, having more readily accessible, detailed information about the  current status of 911 funding would provide decision makers with a better  understanding of how to address the challenges that arise in funding  NG911 services. Following best practices for data collection and  analysis—such as using closed-ended questions when possible and  clearly communicating how open-ended information is coded and  analyzed—would help ensure that the information FCC collects is  measureable and could be tracked, resulting in more useful information  for Congress and others who are researching funding mechanisms for the  future of 911 services.
section_title: Recommendation for Executive Action
paragraphs: We recommend that the Chairman of FCC follow best practices for data  collection and analysis to improve FCC’s current method of collecting and  reporting information on states’ use of 911 funds, by, for example, using  closed-ended questions when possible, developing written internal  guidance for analyzing data, and fully describing the methodology for its  report.
section_title: Agency Comments
paragraphs: We provided a draft of this report to FCC and DOT for their review and  comment. In response, FCC concurred with our recommendation to  improve its current method of collecting and reporting information on  states’ use of 911 funds. FCC stated that it is examining ways to augment  current collection of information to yield more precise information and to  provide more quantitative data in future reports. Specifically, FCC noted  that it will (1) consider using closed-ended questions as part of future data  collections to facilitate tracking and analyzing data, (2) provide greater  clarity in its guidelines for analyzing data, and (3) include a more detailed  description of its methodology in future reports. FCC further stated that it  has taken a variety of steps to enhance the transparency and usefulness  of the information it gathers and has sought comment on the accuracy  and completeness of state responses to FCC’s information collection.  FCC officials believe these steps will also improve the accuracy and  efficacy of its reporting. FCC’s written comments are reprinted in  appendix II. DOT provided technical comments which we incorporated as  appropriate.
We are sending copies of this report to the Chairman of FCC, the  Secretary of Transportation, and interested congressional committees. In  addition, the report is available at no charge on our website at  http://www.gao.gov.
If you or your staff have any questions concerning this report, please  contact me at (202) 512-2834 or goldsteinm@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. Key contributors to this report are listed in  appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: The Next Generation 911 Advancement Act of 2012 mandated that we  review states’ collection and use of 911 funds. This report presents  information on (1) the progress that has been made in implementing  wireless Enhanced 911 (E911) in the last decade, (2) the extent to which  states are collecting and using 911 funds for 911 purposes and the  usefulness of FCC’s reporting about this issue, and (3) challenges to  implementing NG911 services and federal efforts to facilitate its  deployment.
To address these issues, we interviewed federal, state, regional, and  association representatives. We interviewed officials from the Federal  Communications Commission (FCC) regarding states’ collection and use  of E911 funds and the progress made in deploying wireless E911 and  NG911 throughout the country. We also interviewed officials from offices  within the Departments of Transportation (DOT) and Agriculture about  E911 and NG911 deployment. We interviewed representatives from  associations including the National Emergency Number Association  (NENA), the National Association of State 911 Administrators, the  Association of Public-Safety Communications Officials, CTIA-The  Wireless Association, and the Competitive Carriers Association about  states’ collection and use of E911 funds and about E911 and NG911  deployment. We visited Illinois, where we interviewed officials from the  State 911 Office, officials associated with a regional NG911 project, and  representatives from rural counties in southern Illinois that have not yet  begun E911 implementation. We obtained and examined relevant reports  and materials from these officials and representatives. We selected  Illinois because we were informed about the regional NG911 project in  southern Illinois from stakeholders and because Illinois reported using  911 funds for other purposes to FCC in its 2010, 2011, and 2012 reports.  We also interviewed Texas officials with responsibility for the state’s  NG911 pilot project because Texas received the largest E911/NG911  grant from NTIA and NHTSA and because stakeholders mentioned that  the state was making progress on implementing NG911. Information  obtained from Illinois and Texas is not generalizable to any other states.  In addition, we gathered further information from state officials in the five  other states that reported using E911 funds for other purposes in their  2012 reports to FCC: Arizona, Georgia, Maine, New York, and Rhode  Island.respond to FCC’s request for information—Louisiana, District of  Columbia, American Samoa, Northern Mariana Islands, and U.S. Virgin  Islands—but none responded to our request.
In addition, we attempted to contact jurisdictions that did not  To understand the progress that has been made in deploying wireless  E911 services throughout the country, we reviewed our previous reports  on wireless E911 implementation in 2003 and 2006, and we obtained and  analyzed county- and state-level E911 deployment data collected by  NENA as of December 2012. To determine the reliability of this data, we  reviewed relevant documentation and interviewed cognizant officials  about their processes for reviewing the data and ensuring their accuracy.  We determined that the NENA data were sufficiently reliable for the  purposes of our report. To determine the extent to which states are  collecting and using E911 revenues for E911 purposes and the  usefulness of FCC’s reporting about this issue, we obtained FCC’s 2010  through 2012 annual reports on state collection and distribution of 911  and E911 fees and charges as well as states’ responses to FCC’s  information-collecting effort upon which the FCC’s annual reports are  based.information that the states provided to the information FCC reported. We  also performed year-to-year comparisons, identifying differences in how  FCC characterized states’ responses in different years. To determine the  reliability of this data, we reviewed relevant documentation, and  interviewed cognizant officials about their processes for reviewing the  data and ensuring their accuracy. Except where we have noted some  inconsistencies and concerns with FCC’s analysis of state-reported  information, we consider the data sufficiently reliable for the purposes of  this report. In assessing the usefulness of FCC’s reporting, we reviewed  best practices set forth in our previous reports and other professional  literature on methods for collecting, analyzing and reporting information   We analyzed the states’ reports to FCC, comparing the  and data. To identify federal efforts to facilitate NG911 services, we  reviewed FCC’s report to Congress entitled Legal and Regulatory  Framework for Next Generation 911 Services as well as associated  stakeholders’ responses to FCC’s public notice on NG911. In addition, we  reviewed relevant laws and regulations pertaining to E911 and NG911,  including the Wireless Communications and Public Safety Act of 1999,  the ENHANCE 911 Act of 2004, the New and Emerging Technologies  911 Improvement Act of 2008, and various state laws governing the  collection and use of 911/E911 fees. We also reviewed relevant reports  from FCC, DOT, the Congressional Research Service, industry, and other  stakeholders, including FCC’s National Broadband Plan.
section_title: Appendix II: Comments from the Federal Communications Commission
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Sally Moino, Assistant Director;  Thomas Beall; Amy Higgins; David Hooper; SaraAnn Moessbauer;  Joshua Ormond; Amy Rosewarne; and Rebecca Rygg made key  contributions to this report.