Telecommunications: Uneven Implementation of Wireless Enhanced 911 Raises Prospect of Piecemeal Availability for Years to Come
Released: 2003-11-12T00:00:00

Letter

Background

Basic wireline 911 service provides an easily remembered universal number that connects the caller with an emergency response center, known as a public safety answering point (PSAP) (see fig. 1). 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.

Nationwide Phase I Deployment Is More Than Halfway Complete, but Full Phase II Deployment May Be Years Away

Based on the best data that is available, nearly 65 percent of PSAPs across the nation have implemented Phase I and 18 percent have implemented Phase II with at least one wireless carrier providing location information. However, there is still a lack of information regarding how many of the more than 6,000 PSAPs will need to upgrade their equipment, making it difficult to accurately measure the progress of wireless E911 implementation. Looking forward, our survey of state 911 contacts found that less than half of them believe that wireless E911 services will be fully in place in their state by 2005. This raises the prospect that E911 implementation will be piecemeal both within states and across the nation for an indefinite number of years to come.

Eighteen Percent of PSAPs Have Implemented Phase II, but Measuring Progress toward Full Deployment Is Hampered by Data Problems

Currently, the single best information source for tracking the progress being made in deploying wireless E911 service at the local level comes from DOT and the National Emergency Number Association (NENA). DOT contracted with NENA to create a database of counties and the PSAPs within the counties to provide information about implementation of wireless E911. This database is updated every quarter using wireless carrier information filed with the FCC, and supplemented by data gathered directly from PSAPs. Prior to the creation of this database, the only national data available about PSAPs that existed comprised information about NENA’s membership, and that information did not include all PSAPs or track E911 deployments. Thus, the DOT/NENA initiative has provided a key instrument for measuring wireless E911 implementation.

According to NENA, as of October 2003, nearly 65 percent of PSAPs nationwide had implemented Phase I wireless E911 services, which provides the call taker with the callback number and the location of the cell tower and cell sector receiving the 911 call. Phase II, which locates the caller with more precise geographic coordinates, has been implemented with at least one wireless carrier in 18 percent of PSAPs. As part of our survey of state 911 contacts, we asked respondents about their states’ progress on Phase I and Phase II deployments. The responses to our survey were not complete because some state contacts were uncertain about their 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.

State 911 Contacts Offered a Wide Range of Estimated Phase II Completion Dates

In our survey of state 911 contacts (which included the District of Columbia), we asked respondents to provide us with an estimate of when they believed their state would have wireless Phase II E911 fully in place for at least one wireless carrier per PSAP. Twenty-four of 51 respondents said they thought Phase II would be fully in place in their state by 2005, the last year for which there is any specific FCC deadline on wireless carriers. Six of those 24 respondents said they would be ready by 2003. Contacts in other states were either unwilling to commit to any specific year, given their current level of implementation, or estimated a date in 2006 or beyond. See figure 4.

As the estimates from state contacts indicate, no clear picture is emerging on when Phase II will be fully deployed nationwide, raising the prospect of piecemeal availability of this service across the country for an indefinite number of years to come.

Funding and Coordination Are Key Factors Affecting Current Wireless E911 Deployment, with New Wireless Services Posing Future Challenges

As of October 2003, NENA estimates that over the next 5 years the nationwide cost to deploy Phase II will be between $8 billion and $9 billion, including capital and incremental operating expenses. Funding for PSAP equipment upgrades remains a major issue for many states and localities and continues to hamper nationwide deployment. Not all states have implemented a funding mechanism for wireless E911, and of those that have, some have redirected E911 funds to unrelated uses. In addition, poor coordination among the parties is a factor affecting wireless E911 deployment, although some states and localities have eased this problem with active and knowledgeable state 911 coordinators who help oversee the process and work with all the parties. Technologically, the main hurdle of developing wireless location equipment for mobile phones has been solved, but the continuing emergence of new wireless devices and services has the potential to overburden the current 911 infrastructure.

Ongoing Problems with State and Local Funding of Equipment Upgrades Are Hampering the Deployment of Wireless E911

It is costly to implement wireless E911 services. PSAPs need money to upgrade their systems and equipment and to purchase new software to receive and display caller location information. Wireless carriers incur costs associated with handset and network upgrades, engineering design, upgrading hardware and software, and maintaining the system. The LECs also incur costs, but generally these are paid for by the PSAPs as they purchase 911 services and upgrades from the LECs. Currently, funding must come from sources other than the federal government, which has not provided funding to PSAPs or wireless carriers for wireless E911 or established guidelines on how wireless E911 should be funded.

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.

Problems with Coordination Continue to Slow Wireless E911 Deployment

As noted earlier, the deployment of wireless E911 systems requires wireless carriers, LECs, and PSAPs to work together in distinct yet interdependent roles. However, according to some contacts we interviewed, delays sometimes occur because the various parties have difficulty coordinating their activities or working together. There was no consistency across the interviews as to which party (or parties)—wireless carriers, LECs, or PSAPs—was most hindering wireless E911 deployment.

The difficulties in coordination between the parties at times caused frustration, according to some contacts we interviewed. For example, representatives from two of the PSAPs we contacted noted that just 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.

Early Problems with Location Technology Appear Resolved, but Technical Challenges Remain Regarding New Wireless Devices and Services

During our interviews, we were told that the basic technology for accurately determining the location of a wireless caller and systematically providing that data to PSAPs has now been developed. Some noted that although occasional problems still arise due to a particular wireless carrier/LEC/PSAP equipment configuration, these problems are lessening as the parties gain experience with E911 implementation. A representative of one LEC noted that the “challenging years” of coordinating interconnection between the LEC and the wireless carrier seem to be behind them and that implementation now generally tends to proceed more smoothly.

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.

The Recent Actions of FCC and DOT Are Focused on Enforcing Deadlines on Wireless Carriers and Improving Deployment Coordination

FCC and DOT have been involved in the implementation of wireless E911, but federal authority in overseeing the deployment is limited because of the traditional state and local jurisdiction over emergency response services. The primary federal agency involved in wireless E911 deployment is FCC. One of FCC’s goals is to ensure the wireless carriers comply with their current implementation schedules. As noted earlier, FCC in the past had granted waivers to many of the wireless carriers in order to give them more time to resolve technical issues associated with developing wireless location technologies. Because many of these hurdles have now been overcome, FCC has stated that it will not hesitate to use its enforcement power when the wireless carriers fail to meet their current deployment timetables. For example, FCC officials noted that three wireless carriers agreed to pay nearly $4 million to the U.S. Treasury for failure to comply with intermediate deadlines in their E911 deployment timetables.

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.

Conclusions

Without the readiness of all parties—wireless carriers, LECs, and PSAPs— there can be no wireless E911 service. Efforts by FCC to monitor the progress of the wireless carriers in meeting their timetables and take enforcement actions, as warranted, will continue to be an important part of the implementation process. Still, given current E911 funding and coordination problems related to upgrading PSAPs at state and local levels, the pace of wireless E911 deployment could be similar to what happened with wireline E911, which took many years to implement nationwide. If this holds true, consumers and emergency management officials will be faced with a geographic patchwork of wireless E911 areas: Some will have service; some will not. As Americans travel across the country, they will be uncertain as to whether their 911 calls will convey their location. However, successful wireless E911 deployment is possible, as illustrated in some areas of the country. States and localities can benefit from the experiences and best practices of others and adapt them to their own situations. Continued efforts by the FCC, DOT, and the public safety community to identify and publicize these successes will be a valuable means of facilitating the deployment.

During this transition period, it is important to accurately measure progress in wireless E911 deployment so that federal, state, and local officials can assess whether problems are arising in parts of the country that may require additional actions. This information would also help build public awareness of where this service is available and may stimulate action at the state and local level. Measuring the progress of wireless E911 implementation against the goal of full nationwide Phase II deployment depends on being able to compare the number of PSAPs that are receiving wireless Phase II location data with the total number of PSAPs that need to be upgraded. We found, however, that there is a lack of information on the total number of PSAPs that need to be upgraded. While FCC and DOT have taken important actions to track wireless E911 deployment, additional work is needed to create reliable data on how many of the more than 6,000 PSAPs will need to be upgraded.

Recommendation for Executive Action

In order to provide the Congress and federal and state officials with an accurate assessment of the progress being made toward the goal of full deployment of wireless E911, we recommend that the Department of Transportation work with state-level E911 officials, the National Emergency Number Association, and other public safety groups to determine which public safety answering points will need to have their equipment upgraded. This information should then be reflected in the PSAP database managed by NENA under contract with DOT. This will provide the baseline needed to measure progress toward the goal of full nationwide deployment of wireless E911 service.

Agency Comments

We provided a draft of this report to DOT and FCC for review and comment. DOT stated that it generally agreed with our recommendation, and FCC offered some technical comments that we incorporated into the report where appropriate.

As agreed with your office, unless you publicly announce its contents earlier, we plan no further distribution of this report until 14 days after the 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.

Scope and Methodology

To provide information on the progress made in deploying wireless E911 services throughout the country, we conducted a telephone survey of the state E911 contacts. We completed surveys for 50 states and the District of Columbia. We pretested the questions with five state contacts from states we had spoken with earlier in our research. We revised the survey as appropriate based on responses during pretesting. For each state and the District of Columbia, we began by contacting the person named on the FCC’s Web site at http://www.fcc.gov/911/stateplans/contacts.html as the point of contact for that state.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.

FCC Consumer Advisory about Calling 911 from Your Wireless Phone

Among other responsibilities, FCC’s Consumer & Governmental Affairs Bureau educates and informs consumers about telecommunications services. To this end, the Bureau has produced a number of consumer alerts and fact sheets. Among these is a new consumer advisory entitled “What You Need to Know about Calling 911 from Your Wireless Phone.” This consumer advisory is reprinted on the following pages and can be accessed at FCC’s Web site at www.fcc.gov/cgb/consumerfacts/e911.html.

GAO Contacts and Staff Acknowledgments

GAO Contacts

Staff Acknowledgments

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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