oversight

Telecommunications: Uneven Implementation of Wireless Enhanced 911 Raises Prospect of Piecemeal Availability for Years to Come

Published by the Government Accountability Office on 2003-11-07.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                United States General Accounting Office

GAO	            Report to the Chairman, Subcommittee
                on Communications, Committee on
                Commerce, Science, and Transportation,
                U.S. Senate

November 2003
                TELECOMMUNICATIONS
                Uneven
                Implementation of
                Wireless Enhanced
                911 Raises Prospect of
                Piecemeal Availability
                for Years to Come




GAO-04-55

                a

                                                  November 2003

                                                TELECOMMUNICATIONS

                                                Uneven Implementation of Wireless
                                                Enhanced 911 Raises Prospect of
Highlights of GAO-04-55, a report to the
Chairman, Subcommittee on                       Piecemeal Availability for Years to Come
Communications, Committee on
Commerce, Science, and Transportation,
U.S. Senate




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

www.gao.gov/cgi-bin/getrpt?GAO-04-55.

To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Mark Goldstein
at (202) 512-6670 or goldsteinm@gao.gov.
Contents




Letter
                                                                                                 1
                            Results in Brief 
                                                          4
                            Background                                                                  6

                            Nationwide Phase I Deployment Is More Than Halfway Complete, 

                              but Full Phase II Deployment May Be Years Away 
                         12
                            Funding and Coordination Are Key Factors Affecting Current

                              Wireless E911 Deployment, with New Wireless Services Posing 

                              Future Challenges 
                                                      17
                            The Recent Actions of FCC and DOT Are Focused on Enforcing 

                              Deadlines on Wireless Carriers and Improving Deployment

                              Coordination
                                                             25
                            Conclusions                                                                
28
                            Recommendation for Executive Action 
                                       29
                            Agency Comments
                                                            29


Appendixes
              Appendix I:   Scope and Methodology                                                      31

             Appendix II:	 FCC Consumer Advisory about Calling 911 from Your 

                           Wireless Phone                                                              33

             Appendix III:	 GAO Contacts and Staff Acknowledgments                                     36

                            GAO Contacts                                                               36

                            Staff Acknowledgments                                                      36



Figures	                    Figure 1:
 Call Taker Handling a 911 Call at a Public Safety 

                                       Answering Point                                                  7

                            Figure 2:
 Simplified Wireless E911 Call to PSAP with Phase II 

                                       Capability                                                       9

                            Figure 3:
 Percentage of Counties, by State, That Have Implemented 

                                       Wireless E911 Phase I and Phase II as of October 2003           14

                            Figure 4:
 Estimates by State 911 Contacts of Year Their State Would 

                                       Have Phase II Wireless E911 Fully Implemented (Includes 

                                       the District of Columbia)                                       16





                            Page i                                                 GAO-04-55 Wireless E911
Contents




Abbreviations

DOT          Department of Transportation

E911         enhanced 911

FCC          Federal Communications Commission

GPS          Global Positioning System

LEC          local exchange carrier

NENA         National Emergency Number Association

PSAP         public safety answering point



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Page ii                                                          GAO-04-55 Wireless E911
A

United States General Accounting Office
Washington, D.C. 20548



                                    November 7, 2003


                                    The Honorable Conrad Burns

                                    Chairman

                                    Subcommittee on Communications

                                    Committee on Commerce, Science, and Transportation

                                    United States Senate


                                    Dear Mr. Chairman:


                                    In 2001, Americans placed almost 57 million emergency calls to 911 using 

                                    mobile phones. According to the Federal Communications Commission

                                    (FCC), around one-third of 911 calls are now made from mobile phones. 

                                    With almost 150 million Americans now subscribing to a mobile phone 

                                    service and new concerns about homeland security facing our nation, the 

                                    ability to reach 911 from sidewalks, highways, and rural areas has become 

                                    increasingly important. Knowing the precise location of a 911 caller 

                                    facilitates the quick and accurate dispatch of emergency responders such 

                                    as police, firefighters, and ambulance crews. However, in some cases, 911 

                                    callers cannot speak (e.g., a caller who is suffering a heart attack) or simply 

                                    do not know their location (e.g., a caller reporting an accident along a 

                                    highway). 


                                    For traditional wireline phones, most areas across the country now employ 

                                    “enhanced 911” (E911) services, where the caller’s address automatically

                                    appears on-screen for the 911 call taker. The increasing use of mobile

                                    phones led to concerns by the Congress and others in the federal 

                                    government and the public safety community that E911 location 

                                    information is often not available for citizens dialing 911 from a mobile

                                    phone. However, implementing wireless E911 is inherently more 

                                    challenging than wireline E911. Unlike wireline phones, where the phone 

                                    number is linked to a specific street address, providing location

                                    information for a mobile phone involves technologies that must calculate 

                                    the geographic coordinates of the caller at the time of the call and display 

                                    those coordinates as a location the 911 call taker can understand. 

                                    Moreover, a wireless 911 call is routed along the networks of both a 

                                    wireless telephone company and a wireline telephone company before 

                                    terminating at a facility where 911 calls are answered, known as a public 

                                    safety answering point (PSAP). There are more than 6,000 of these 

                                    answering points nationwide, often at a county or city level. All three of

                                    these entities—wireless carriers, wireline carriers, and public safety

                                    answering points—must be properly interconnected and have certain




                                    Page 1                                                    GAO-04-55 Wireless E911
equipment in place before wireless 911 calls can be correctly routed and
E911 location information sent with the call.

At the federal level, FCC and the U.S. Department of Transportation (DOT)
have taken steps to promote the deployment of E911 location technologies
for mobile phones. Deployment usually proceeds in two phases: Phase I
provides general location information by identifying the cell site1 and cell
sector2 receiving the wireless call as well as the telephone number of the
caller; Phase II provides a more precise location by determining the
latitude and longitude of the caller, which can be electronically displayed
on a map. Currently, the only federally mandated time frames for
installation of wireless E911 technologies are those placed on wireless
carriers by FCC. These time frames vary by wireless carrier and by the type
of location technology the carrier has selected, and currently extend out to
December 31, 2005. However, FCC has no authority to place time frames on
the public safety answering points, which are under state and local
jurisdiction. As a result, there is no ultimate nationwide deadline for full
implementation of wireless E911 services. FCC has technical and
educational initiatives under way to help the parties involved to share
information on deployment practices, problems, and experiences. Also,
DOT has recognized the relationship between wireless E911 services and
highway safety and is working with a key nongovernmental organization,
the National Emergency Number Association (NENA), to develop a PSAP
database that tracks E911 implementation.3 DOT is also working to
promote research, planning, and education related to wireless E911
services.



1
 Wireless carriers deliver mobile phone service by subdividing large geographic areas into
smaller sections called cells. Each cell has a base station equipped with one or more
antennas to receive and transmit radio signals to the mobile phones within its coverage
area. The distance covered by the base station can range from less than a mile to 20 miles.
For more information on cell phones, see U.S. General Accounting Office,
Telecommunications: FCC Should Include Call Quality in Its Annual Report on
Competition in Mobile Phone Services, GAO-03-501 (Washington, D.C.: Apr. 28, 2003).
2
 The cell sector refers to the coverage area of a cellular antenna. Cell sites often contain
three antennas, which define three unique coverage areas or sectors, helping to narrow the
field of search for the wireless caller.
3
 NENA is a membership organization of emergency communications professionals in
government and industry that fosters the technological advancement, availability, and the
implementation of a universal emergency telephone number system. The database is
accessible through http://www.nena.org.




Page 2                                                             GAO-04-55 Wireless E911
The pace of wireless E911 deployment has been a key concern for the
Congress. The Wireless Communications and Public Safety Act of 1999
designated 911 as the universal emergency telephone number within the
United States and called on FCC to encourage and support efforts by the
states to deploy wireless E911 services by working with state and local
officials, the telecommunications industry, consumer groups, and those
involved in public safety services.4 There is also a Congressional E911
Caucus that aims to educate lawmakers, constituents, and communities
about the importance of 911 systems.5 You asked us to provide an overview
of the deployment of wireless E911 services across the country. We agreed
to provide information on (1) the progress made in deploying wireless E911
services throughout the country, (2) the factors that are affecting this
progress, and (3) current federal government actions to promote the
deployment of wireless E911 services.




4
 Pub. L. No. 106-81, 113 Stat. 1286 (1999). According to its purpose section, the act is meant
to “encourage and facilitate the prompt deployment throughout the United States of a
seamless, ubiquitous, and reliable end-to-end infrastructure for communications, including
wireless communications, to meet the Nation’s public safety and other communications
needs.”
5
 The establishment of the E911 Institute, a not-for-profit organization that will support the
work of the Congressional E911 Caucus, was announced in July 2003. More information can
be found at the organization’s Web site, www.e911institute.org.




Page 3                                                              GAO-04-55 Wireless E911
                    To address these issues, we interviewed representatives of the various
                    parties involved in wireless E911 implementation. We selected nine states
                    (California, Idaho, Indiana, Kentucky, Maryland, Missouri, South Carolina,
                    Texas, and Virginia) and the District of Columbia as case studies.6 For each
                    case study, we interviewed representatives of a public safety answering
                    point in both an urban and rural area of the state.7 We also interviewed the
                    state’s 911 coordinator and representatives of one small wireless carrier8
                    serving the state.9 In addition to our case studies, we interviewed
                    companies providing wireless telephone services nationwide, companies
                    providing local wireline telephone services, and a manufacturer of mobile
                    telephones. We interviewed federal, state, and local government officials
                    involved in wireless E911 implementation and representatives from several
                    public safety associations and wireless industry associations. Lastly, we
                    conducted a telephone survey of the state 911 contacts in all 50 states and
                    the District of Columbia (these individuals were designated by the
                    governor of each state as the E911 point of contact and are listed on FCC’s
                    Web site) to obtain an overview of implementation efforts across the
                    country. A more detailed discussion of our scope and methodology is found
                    in appendix I.



Results in Brief	   Implementation of wireless E911 is several years away in many states,
                    raising the prospect of piecemeal availability of this service across the
                    country for an indefinite number of years to come. According to a DOT-
                    sponsored database, as of October 2003, nearly 65 percent of the more than
                    6,000 public safety answering points nationwide are receiving Phase I


                    6
                     We selected states that were spread geographically across the United States 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.
                    7
                     There were exceptions to this in one state and the District of Columbia. California has no
                    rural public safety answering points that take wireless calls, so we interviewed the
                    California Highway Patrol, which handles most of the wireless 911 calls in California. The
                    District of Columbia has only one public safety answering point.
                    8
                     For purposes of our case studies, a small wireless carrier was considered any wireless
                    carrier other than the six large nationwide wireless carriers (AT&T Wireless, Cingular,
                    Nextel, Sprint, T-Mobile, and Verizon Wireless).
                    9
                     Again, there were exceptions to this in one state and the District of Columbia. We were
                    unable to schedule an interview with a small wireless carrier in Missouri, and the District of
                    Columbia is not served by any small wireless carriers.




                    Page 4                                                               GAO-04-55 Wireless E911
location information, but only about 18 percent are receiving Phase II
location information. Although the DOT-sponsored database has greatly
increased the amount of information available about E911 progress, the
database does not differentiate between public safety answering points
that will require equipment upgrades and those that will not. This limits its
usefulness in accurately assessing progress toward full implementation.
Looking forward, 24 state 911 contacts said in response to a GAO survey
that their state will have Phase II implemented by 2005 or sooner; however,
all other state contacts estimated dates beyond 2005 or were unable to
estimate a date.

Lack of funding for equipment upgrades and a lack of coordination among
the parties involved are factors slowing the pace of the rollout of wireless
E911 technologies. Based on our interviews, lack of state or local funding is
the largest factor affecting the progress of wireless E911. No federal
funding was provided to the states and localities to cover the cost of E911
implementation, estimated to be at least $8 billion over the next five years.
Our survey of state contacts showed that 39 states and the District of
Columbia have put in place a surcharge on wireless customers to pay for
E911 upgrades to public safety answering points. Yet, some states have no
funding mechanism in place and even those that do sometimes redirect the
collected funds to uses unrelated to wireless E911 implementation.
Another factor slowing wireless E911 rollouts is a lack of coordination
among the parties involved. This problem has been avoided in some
localities with early coordination meetings among all the parties, where
personal contacts can be established and early concerns raised and
addressed. We were told by many of those we interviewed that states with
knowledgeable and involved state coordinators have had an easier time
with coordination and with public safety answering point readiness.
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.

The federal government has been involved in the promotion of wireless
E911, but has limited authority over the entire process. FCC has
concentrated its regulatory efforts toward the wireless carriers, where it
has the most enforcement authority. FCC has established implementation
schedules with each of the major wireless carriers and has recently taken
enforcement actions against wireless carriers that failed to meet deadlines.
According to FCC, the Commission does not have clear jurisdiction over
wireline carriers with regard to wireless E911 implementation and looks to



Page 5                                                  GAO-04-55 Wireless E911
              the state public utility commissions, which have clear and sufficient
              authority, to take the lead. However, FCC has said it will monitor the
              wireline carriers’ efforts to ensure that they are meeting their
              responsibilities with regard to E911 deployment. In April 2003, FCC held
              the first coordination initiative meeting to bring the parties involved in
              E911 together and has established a technical group to examine relevant
              E911 infrastructure issues. DOT is developing an action plan and
              clearinghouse for wireless E911 planning, implementation, and operations.
              FCC and DOT coordinate their wireless E911 activities to avoid duplication
              of effort. However, the agencies do not jointly staff or fund any wireless
              E911 projects.

              To address the limitations in the DOT-sponsored database on public safety
              answering points’ readiness for wireless E911 service, we are
              recommending that the department work with state officials and public
              safety groups to develop a more accurate assessment of the number and
              location of answering points that still need equipment upgrades. A draft of
              this report was provided to DOT and to FCC. In commenting on the draft of
              this report, DOT stated that it generally agreed with the report’s
              recommendation, and FCC offered some technical comments that were
              incorporated where appropriate.



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).10 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



              10
               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.




              Page 6                                                           GAO-04-55 Wireless E911
wireline 911 service, and 93 percent of that coverage includes the delivery
of a callback number and location information.



Figure 1: Call Taker Handling a 911 Call at a Public Safety Answering Point




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.




Page 7                                                       GAO-04-55 Wireless E911
•	 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.11 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.12 In recognition of this second solution, FCC issued rules in
October 199913 for carriers that selected handset-based location
technologies.14 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.15

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


11
   Triangulation is a method of locating the source of a radio signal, generally through the use
of three receivers, or antennas.
12
 The most commonly used handset-based solution is “assisted GPS,” in which some of the
processing is carried out in the network to improve system performance.
13
   In the Matter of Revision of the Commission’s Rules to Ensure Compatibility with
Enhanced 911 Emergency Calling Systems, CC Docket No. 94-102, Third Report and
Order, FCC 99-245 (released Oct. 6, 1999).
14
   A third approach to caller location is known as “enhanced observed time difference of
arrival,” which is regarded as a hybrid because the required measurements are distributed
between the handset and the network.
15
   In the Matter of Revision of the Commission’s Rules to Ensure Compatibility with
Enhanced 911 Emergency Calling Systems, CC Docket No. 94-102, Fourth Memorandum
Opinion and Order, FCC 00-326, (released Sept. 8, 2000).




Page 8                                                                GAO-04-55 Wireless E911
                                                        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.



Figure 2: Simplified Wireless E911 Call to PSAP with Phase II Capability


                                                                                                               Voice
                                                                                                                and     PSAP equipment
                                                                          Voice                                data
                                                Wireless carrier           and           LEC call routing              to receive location
                                                switching center          data             equipment                    information and
                                                                                                                        callback number




                      Voice                                                                                                           Voice
                       and                                                                                                             and
                      data                                         Data                                 Data                          data




                                                                                                  Database                   PSAP
                                                                                  Data
                                                        Equipment                             providing callback
                                                         used to                                 number and
                                                       locate caller                               location
                                                                                                 information



                                                                                                                          E911 call takers



Sources: GAO; and Nova Development (clipart).




                                                        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.



                                                        Page 9                                                         GAO-04-55 Wireless E911
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



Page 10                                                 GAO-04-55 Wireless E911
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.16 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.17 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.




16
 On October 10, 2003, the FCC issued a six-month stay of applicable provisions of E911
rules, or until it decides on the merits, whichever is shorter, with regard to all pending
petitions of small wireless carriers seeking relief. In the Matter of Revision of the
Commission’s Rules to Ensure Compatibility with Enhanced 911 Emergency Calling
Systems, CC Docket No. 94-102, Order to Stay, FCC 03-241 (Oct. 10, 2003).
17
  Under FCC rules, however, a wireless carrier and a PSAP can mutually agree to a time
frame other than a 6-month response. 47 C.F.R. §20.18(j)(5).




Page 11                                                             GAO-04-55 Wireless E911
Nationwide Phase I           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
Deployment Is More           Phase II with at least one wireless carrier providing location information.
Than Halfway                 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
Complete, but Full           difficult to accurately measure the progress of wireless E911
Phase II Deployment          implementation. Looking forward, our survey of state 911 contacts found
May Be Years Away            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    Currently, the single best information source for tracking the progress
Have Implemented Phase II,   being made in deploying wireless E911 service at the local level comes
                             from DOT and the National Emergency Number Association (NENA). DOT
but Measuring Progress
                             contracted with NENA to create a database of counties and the PSAPs
toward Full Deployment Is    within the counties to provide information about implementation of
Hampered by Data             wireless E911. This database is updated every quarter using wireless
Problems                     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




                             Page 12                                                 GAO-04-55 Wireless E911
state’s current status.18 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.




18
  The state contacts were taken from a list provided on FCC’s Web site. The names were
provided to FCC by the governor of each state. However, not all state contacts were actively
involved in E911 issues, and some could provide only limited responses to our questions. We
did speak with others suggested by the state contacts in some of our surveys. See appendix
I for more information about our survey.




Page 13                                                            GAO-04-55 Wireless E911
Figure 3: Percentage of Counties, by State, That Have Implemented Wireless E911
Phase I and Phase II as of October 2003
     Phase I




     Phase II




          30 percent or less of counties have implemented wireless E911
          More than 30 percent but less than 60 percent of counties have implemented wireless E911
          60 percent or more of counties have implemented wireless E911

Source: GAO analysis of NENA data.

Note: As of October 2003, the District of Columbia had not implemented Phase I or Phase II.




Page 14                                                                        GAO-04-55 Wireless E911
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




Page 15                                                 GAO-04-55 Wireless E911
                               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   In our survey of state 911 contacts (which included the District of
Wide Range of Estimated        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
Phase II Completion Dates      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.



                               Figure 4: Estimates by State 911 Contacts of Year Their State Would Have Phase II
                               Wireless E911 Fully Implemented (Includes the District of Columbia)
                                Number of respondents

                                18
                                                                                                   16
                                16

                                14

                                12
                                                                                       11
                                                          10
                                10

                                                                          8
                                 8
                                            6
                                 6

                                 4

                                 2

                                 0
                                         2003           2004           2005           2006      Unable to
                                                                                     or later   estimate
                                     Estimated year

                                Source: GAO state survey (June to September 2003).




                               Page 16                                                                      GAO-04-55 Wireless E911
                             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                  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,
Coordination Are Key         including capital and incremental operating expenses. Funding for PSAP
Factors Affecting            equipment upgrades remains a major issue for many states and localities
                             and continues to hamper nationwide deployment. Not all states have
Current Wireless E911        implemented a funding mechanism for wireless E911, and of those that
Deployment, with New         have, some have redirected E911 funds to unrelated uses. In addition, poor
Wireless Services            coordination among the parties is a factor affecting wireless E911
                             deployment, although some states and localities have eased this problem
Posing Future                with active and knowledgeable state 911 coordinators who help oversee
Challenges                   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        It is costly to implement wireless E911 services. PSAPs need money to
State and Local Funding of   upgrade their systems and equipment and to purchase new software to
                             receive and display caller location information. Wireless carriers incur
Equipment Upgrades Are
                             costs associated with handset and network upgrades, engineering design,
Hampering the Deployment     upgrading hardware and software, and maintaining the system. The LECs
of Wireless E911             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.




                             Page 17                                                 GAO-04-55 Wireless E911
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.19 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


19
 Three other states had a wireless E911 funding mechanism in place, but did not impose
surcharges on wireless subscribers. To pay for wireless E911 implementation, one state
used funds from general revenue, one used funds from the state’s Universal Service Fund,
and one state used funds collected for wireline 911.




Page 18                                                          GAO-04-55 Wireless E911
legislature allocated funds for E911 initiatives, and it was unclear when or
if that would occur.20

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


20
   Legislation introduced in the U.S. Senate and House of Representatives would provide
annual grants to states and localities to improve emergency communications (see S.1250,
108th Cong., 1st Sess. (2003); H.R. 2898, 108th Cong., 1st Sess. (2003)). Both bills would require
states and localities to match the grants provided by the federal government and would
prohibit federal grant monies from being awarded to states that redirect funds collected
specifically for E911 initiatives to nonemergency communication uses.




Page 19                                                                GAO-04-55 Wireless E911
                             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.21
                             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.22 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   As noted earlier, the deployment of wireless E911 systems requires
Continue to Slow Wireless    wireless carriers, LECs, and PSAPs to work together in distinct yet
                             interdependent roles. However, according to some contacts we
E911 Deployment
                             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

                             21
                              Initially, FCC said wireless carriers were not required to provide E911 service unless a cost
                             recovery mechanism was in place, but FCC reversed this decision in November 1999.
                             22
                              A representative from one PSAP told us that some wireless carriers might not seek to
                             recoup costs incurred with deploying E911 if they plan to use the location technologies for
                             commercial purposes.




                             Page 20                                                             GAO-04-55 Wireless E911
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.23 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


23
 According to FCC, PSAPs can find wireless carrier licenses that serve their area from
FCC’s Universal Licensing System database. However, FCC stated that it might be difficult
to link the name of the licensee to the name under which the actual operating carrier does
business. The FCC database is available via its Web site at http://wireless.FCC.gov/uls/.




Page 21                                                           GAO-04-55 Wireless E911
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.24

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:25



24
   In the Matter of Revision of the Commission’s Rules to Ensure Compatibility with
Enhanced 911 Emergency Calling Systems, Petition of City of Richardson, Texas, CC
Docket 94-102, Order on Reconsideration, FCC 02-318 (released Nov. 26, 2002).
25
   In addition to efforts by state officials to improve coordination, several public safety and
industry associations have worked to provide information and assistance with wireless
E911 implementation.




Page 22                                                               GAO-04-55 Wireless E911
                       •	 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 2005.26

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


                       26
                            However, 25 counties in Kentucky still do not have wireline E911.




                       Page 23                                                              GAO-04-55 Wireless E911
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.”27 Those offerings include


27
 Dale N. Hatfield, A Report on Technical and Operational Issues Impacting the Provision
of Wireless Enhanced 911 Services, prepared for the FCC (Oct. 15, 2002), Docket No. 02-46,
pp. 13-14, quoting SCC Communications Corp., 9-1-1 Networks in the 21st Century—The
Case for Competition (Feb. 20, 2001), p. 2.




Page 24                                                          GAO-04-55 Wireless E911
                         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.28 NENA is also trying to address the issue of new
                         technologies and of a “future path plan” for the 911 network.29



The Recent Actions of    FCC and DOT have been involved in the implementation of wireless E911,
                         but federal authority in overseeing the deployment is limited because of the
FCC and DOT Are          traditional state and local jurisdiction over emergency response services.
Focused on Enforcing     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
Deadlines on Wireless    current implementation schedules. As noted earlier, FCC in the past had
Carriers and Improving   granted waivers to many of the wireless carriers in order to give them more
Deployment               time to resolve technical issues associated with developing wireless
                         location technologies. Because many of these hurdles have now been
Coordination             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.




                         28
                          See In the Matter of Revision of the Commission’s Rules to Ensure Compatibility with
                         Enhanced 911 Emergency Calling Systems, CC Docket 94-102, Further Notice of Proposed
                         Rulemaking, FCC 02-326 (released Dec. 20, 2002).
                         29
                          NENA is working to develop a plan for aggressively managing the technical evolution of
                         the overall 911 system and emergency communications process in ways that serve local and
                         national emergency needs. This technical plan will seek to provide a long-term direction for
                         911 to support new call sources (such as text messaging devices) and needs.




                         Page 25                                                            GAO-04-55 Wireless E911
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.30
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.31




30
  In his report to the FCC, Mr. Hatfield recommended that a national 911 program office be
established within the Department of Homeland Security. He also recommended that FCC
(1) maintain or even increase its oversight of the rollout of wireless E911 services; (2)
establish an advisory committee to address the development and evolution of E911 systems
and services; (3) continue to urge the creation of organizations at the state, regional, and
local levels to coordinate the rollout of wireless E911; (4) encourage the creation of a
national clearinghouse to collect, store, and disseminate wireless E911 information; (5)
actively coordinate with and support DOT’s Wireless E911 initiative and other efforts; (6)
continue to support the efforts of the Emergency Services Interconnection Forum to
address the issues of PSAP readiness; (7) work closely with individual state and regulatory
commissions and their association, the National Association of Regulatory Utility
Commissioners, in resolving issues relating to LEC cost recovery and pricing; and (8) urge
stakeholders to develop industrywide procedures for testing and certification of wireless
E911 to ensure that they meet the accuracy requirements in FCC rules. Mr. Hatfield also
made several other recommendations relating to technical, regulatory, and consumer issues.
31
 Near the end of our review, FCC announced that they would be conducting another
Wireless E911 Coordination Initiative to be held October 29-30, 2003.




Page 26                                                           GAO-04-55 Wireless E911
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.32

DOT also convened a Wireless E911 Steering Council33 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.



32
   Links to the clearinghouse and the database are available on DOT’s Web site. See
http://www.itspublicsafety.net/wireless.htm.
33
 The Wireless E911 Steering Council includes leaders of the telecommunications, public
safety, and highway safety communities.




Page 27                                                            GAO-04-55 Wireless E911
               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



               Page 28                                                GAO-04-55 Wireless E911
                     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   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
Executive Action     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



                     Page 29                                                  GAO-04-55 Wireless E911
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.


Sincerely yours,





Mark L. Goldstein

Director, Physical Infrastructure Issues





Page 30                                                   GAO-04-55 Wireless E911
Appendix I

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.1 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)



              1
               These names were provided to FCC by the governor of each state in response to a request
              from FCC’s Chairman. FCC did not list a contact person for the states of Wisconsin and
              Oklahoma, so we obtained a contact name from NENA for these two states. We also did not
              receive a response from the contact for New York and completed the New York survey with
              a person suggested by NENA.




              Page 31                                                         GAO-04-55 Wireless E911
Appendix I

Scope and Methodology





the state coordinator, a small wireless carrier serving that state,2 and one
urban PSAP and one rural PSAP within the state.3 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.




2
 For purposes of our case studies, a small wireless carrier was considered any wireless
carrier other than the six large nationwide wireless carriers (AT&T Wireless, Cingular,
Nextel, Sprint, T-Mobile, and Verizon Wireless).
3
 There were some exceptions to our case study formula. The District of Columbia has only
one PSAP and has no small wireless carriers. California has no rural PSAPs that take
wireless calls. Instead, we interviewed the California Highway Patrol, which handles most
of the wireless 911 calls in California. Lastly, we were unable to schedule an interview with a
small wireless carrier serving the state of Missouri.




Page 32                                                              GAO-04-55 Wireless E911
Appendix II

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.




              Page 33                                             GAO-04-55 Wireless E911
Appendix II

FCC Consumer Advisory about Calling 911 

from Your Wireless Phone





Page 34                                     GAO-04-55 Wireless E911
Appendix II

FCC Consumer Advisory about Calling 911 

from Your Wireless Phone





Page 35                                     GAO-04-55 Wireless E911
Appendix III

GAO Contacts and Staff Acknowledgments




GAO Contacts	     John Finedore, (202) 512-6248
                  Faye Morrison, (202) 512-6448
                  Andy Clinton, (214) 777-5616



Staff 	           In addition to those named above, Michele Fejfar, Deepa Ghosh, Sally
                  Moino, Mindi Weisenbloom, Alwynne Wilbur, and Nancy Zearfoss made key
Acknowledgments   contributions to this report.




(545026)          Page 36                                           GAO-04-55 Wireless E911
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