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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:

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-55] GAO-04-55:

GAO Highlights:

Highlights of GAO-04-55, a report to the Chairman, Subcommittee on 
Communications, Committee on Commerce, Science, and Transportation, 
U.S. Senate 

Why GAO Did This Study:

When an emergency call is placed to 911, prompt response depends on 
knowing the location of the caller. Enhanced 911 (E911) service 
automatically provides this critical information. E911 is in place in 
most of the country for traditional wireline telephone service, where 
the telephone number is linked to a street address. Expanding E911 
capabilities to mobile phones is inherently more challenging because 
of the need to determine the caller’s geographic location at the 
moment the call is made. Concerns have been raised about the pace of 
wireless E911 implementation and whether this service will be 
available nationwide. GAO reviewed the progress being made in 
implementing wireless E911 service, the factors affecting this 
progress, and the role of the federal government in facilitating the 
nationwide deployment of wireless E911 service. 

What GAO Found:

Implementation of wireless E911 is several years away in many states, 
raising the prospect of piecemeal availability of this service across 
the country for an indefinite number of years to come. Successful 
implementation depends on coordinated efforts by wireless carriers, 
local telephone companies, and more than 6,000 public safety answering 
points (PSAPs)—the facilities that receive 911 calls and dispatch 
assistance. According to a database sponsored by the Department of 
Transportation (DOT), as of October 2003, nearly 65 percent of PSAPs 
had Phase I wireless E911 service, which provides the approximate 
location of the caller, while only 18 percent had Phase II, which 
provides a more precise location and is the ultimate goal of wireless 
E911 service. Though valuable, the database does not differentiate 
between PSAPs that will require equipment upgrades and those that will 
not, thereby limiting its usefulness in accurately assessing progress 
toward full implementation. Looking forward, 24 state 911 contacts 
said in response to a GAO survey that their state will have Phase II 
implemented by 2005 or sooner; however, all other state contacts 
estimated dates beyond 2005 or were unable to estimate a date. 

Key factors hindering wireless E911 implementation involve funding and 
coordination. The wireless carriers, states, and localities must 
devise the means to fund more than $8 billion in estimated deployment 
costs over the next 5 years. Some states and localities have 
established funding mechanisms (such as E911 surcharges on phone 
bills), but others have not done so or have used their E911 funds for 
unrelated purposes. In addition, there is also a lack of coordination 
in some cases among the wireless carriers, local telephone companies, 
and PSAPs that can lead to delays in wireless E911 implementation. 
States with knowledgeable and involved coordinators were best able to 
work through these coordination issues.

The Federal Communications Commission (FCC) and DOT are involved in 
promoting wireless E911, but their authority in overseeing its 
deployment is limited because PSAPs traditionally fall under state and 
local jurisdiction.  FCC has set deadlines on the wireless carriers’ 
E911 responsibilities and has taken actions to identify best practices 
and improve coordination among the parties. DOT is developing an 
action plan and clearinghouse for wireless E911 planning, 
implementation, and operations.


What GAO Recommends:

In order to provide the Congress and federal and state officials with 
an accurate assessment of the progress being made toward full 
deployment of wireless E911, we are recommending that the Department 
of Transportation work with state officials and public safety groups 
to develop data identifying which PSAPs will need to have E911 
equipment upgrades. In response, DOT stated that it 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.

[End of section]

Contents:

Letter: 

Results in Brief: 

Background: 

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

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

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

Conclusions: 

Recommendation for Executive Action: 

Agency Comments: 

Appendixes:

Appendix I: Scope and Methodology: 

Appendix II: FCC Consumer Advisory about Calling 911 from Your Wireless 
Phone: 

Appendix III: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Staff Acknowledgments: 

Figures: 

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

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

Figure 3: Percentage of Counties, by State, That Have Implemented 
Wireless E911 Phase I and Phase II as of October 2003: 

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

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:

Letter 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 equipment in place before wireless 911 calls can be 
correctly routed and E911 location information sent with the call.

At the federal level, FCC and the U.S. Department of Transportation 
(DOT) have taken steps to promote the deployment of E911 location 
technologies for mobile phones. Deployment usually proceeds in two 
phases: Phase I provides general location information by identifying 
the cell site[Footnote 1] and cell sector[Footnote 2] 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.[Footnote 3] DOT is also working to promote research, 
planning, and education related to wireless E911 services.

The pace of wireless E911 deployment has been a key concern for the 
Congress. The Wireless Communications and Public Safety Act of 1999 
designated 911 as the universal emergency telephone number within the 
United States and called on FCC to encourage and support efforts by the 
states to deploy wireless E911 services by working with state and local 
officials, the telecommunications industry, consumer groups, and those 
involved in public safety services.[Footnote 4] There is also a 
Congressional E911 Caucus that aims to educate lawmakers, constituents, 
and communities about the importance of 911 systems.[Footnote 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.

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.[Footnote 6] For each case study, we interviewed 
representatives of a public safety answering point in both an urban and 
rural area of the state.[Footnote 7] We also interviewed the state's 
911 coordinator and representatives of one small wireless 
carrier[Footnote 8] serving the state.[Footnote 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 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 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).[Footnote 
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 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:

[See PDF for image]

[End of figure]

In the early 1990s, FCC took note of the rising number of mobile 
telephone subscribers and the resulting increase in 911 calls. In 1994, 
FCC requested comments on requiring wireless carriers to provide the 
same level of 911 service that was available from LECs. In 1996, with 
input from the industry and public safety community, FCC adopted rules 
for wireless E911 that established an approach consisting of two phases 
for implementation by the wireless carriers. FCC also set schedules for 
implementing both basic and enhanced wireless 911 services, determined 
accuracy requirements and deployment schedules for location 
technologies, and outlined the role of PSAPs. Specifically, the phases 
required the following:

* Phase I required that by April 1998, or within six months of a 
request from a PSAP, whichever was later, wireless carriers were to be 
prepared to provide the PSAP with the wireless phone number of the 
caller and the location of the cell site receiving the 911 call.

* Phase II required that by October 2001, or within 6 months of 
receiving a request from a PSAP, whichever was later, wireless carriers 
were to be prepared to provide the PSAP with Phase I information plus 
the latitude and longitude coordinates of the caller within certain 
standards of accuracy.

In 1996, when these rules were established, the technology to 
accurately locate a caller on a mobile telephone had not yet been 
perfected, but a "network based" solution was anticipated. With this 
type of solution, a caller is located through a triangulation process 
using the closest cell towers.[Footnote 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.[Footnote 12] In recognition of this second solution, FCC 
issued rules in October 1999[Footnote 13] for carriers that selected 
handset-based location technologies.[Footnote 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.[Footnote 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 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:

[See PDF for image]

[End of figure]

Phase II wireless E911 service is more complex to implement than Phase 
I because of the need to install equipment to determine the geographic 
coordinates of the caller, transfer that information through the 
telephone networks, and have a mapping system in place at the PSAP that 
can display the latitude and longitude coordinates of the caller as a 
map location for dispatching assistance. When Phase II location data is 
unattainable (e.g., the handset does not have line of sight to enough 
GPS satellites to determine the caller's location), most wireless 
systems default to providing Phase I data, including the location of 
the cell tower and cell sector receiving the call.

The increased complexity of Phase II also makes it more costly than 
Phase I to implement. To date, the federal government has played no 
role in financing the rollout of wireless E911 services. Wireless 
carriers must finance the implementation of a caller location solution 
and test equipment to verify accuracy. LECs are generally responsible 
for ensuring that all the necessary connections between wireless 
carriers, PSAPs, and databases have been installed and are operating 
correctly. PSAPs purchase telephone services from the LECs. Because the 
typical underlying wireline E911 network is unable to carry the 
additional wireless E911 information, PSAPs often must purchase a 
separate data link and connection from the LEC. In order to translate 
the latitude and longitude location information into a street address, 
PSAPs usually purchase and install mapping software. PSAPs may also 
need to acquire new computers to receive and display this information.

In short, three parties--the wireless carriers, LECs, and PSAPs--must 
interconnect and install equipment in order for wireless E911 calls to 
be completed and the caller location information to be sent with the 
call. However, no single entity has regulatory authority and oversight 
over the entire implementation process. FCC has considerable regulatory 
authority over wireless carriers and has placed location accuracy 
standards and deployment deadlines on the wireless carriers. State 
public utility commissions have some authority over wireless carriers' 
terms and conditions of service. The state public utility commissions 
also have a great deal of authority over the LECs, including authority 
over intrastate service rates, while FCC retains some authority over 
LEC interconnection agreements with wireless carriers and other issues. 
PSAP readiness remains a state and local issue because PSAPs serve an 
emergency response function that has traditionally fallen under state 
or local jurisdiction. The manner in which the more than 6,000 PSAPs 
across the country are administered and funded--at a state, county, 
city, or other political subdivision level--varies from state to state. 
According to FCC, the Commission has no authority to set deadlines for 
PSAPs' deployment of the equipment they need in order to receive caller 
location information from the wireless carriers. Setting such deadlines 
on PSAPs would be a matter for states and localities.

Another federal agency with an interest in this issue is DOT. According 
to DOT, its involvement stems from the department's mandate to handle 
issues of traffic safety and from a directive from the Secretary of 
Transportation to become involved in wireless E911 issues. DOT 
officials noted that wireless phones have become crucial to reporting 
highway accidents and getting ambulances or other assistance to the 
scene. As will be discussed below, DOT is involved in several 
initiatives to track the progress of E911 deployment and help promote 
wireless E911 services, especially at the state and local level.

As the original Phase II deadline of October 2001 approached, the six 
large national wireless carriers (which provide service to 
approximately 75 percent of wireless telephone subscribers) requested 
waivers because the location technology was not ready for 
implementation. In granting the waivers, FCC negotiated different 
deadlines with each of these carriers, based on the carrier-specific 
Phase II compliance plans. The FCC also required these carriers to file 
detailed quarterly reports regarding implementation. In July 2002, FCC 
also granted temporary relief from the Phase II deadlines to those non-
nationwide midsize and small wireless carriers that had requested 
relief.[Footnote 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.[Footnote 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.

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

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

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

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

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

Figure 3: Percentage of Counties, by State, That Have Implemented 
Wireless E911 Phase I and Phase II as of October 2003:

[See PDF for image]

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

[End of figure]

Measuring the progress of wireless E911 implementation against the goal 
of full nationwide Phase II deployment depends on being able to compare 
the number of PSAPs that are receiving wireless Phase II location data 
with the universe of PSAPs that need to be upgraded. We found, however, 
that there is a lack of accurate information on the total number of 
PSAPs that need to be upgraded. NENA has determined that there are 
6,143 PSAPs nationwide. However, this number includes both "primary" 
and "secondary" PSAPs. A primary PSAP is defined by NENA as a PSAP to 
which 911 calls are directly routed; a secondary PSAP only receives 
calls that have been transferred, or passed along, from a primary PSAP. 
Generally, primary and secondary PSAPs have been included in the total 
number of PSAPs that need to be capable of receiving wireless E911 
information.

However, our survey results of state 911 contacts, along with our case 
study interviews, indicate that some states do not plan to upgrade 
their secondary PSAPs. For example, in North Carolina, state statute 
only permits primary PSAPs to be funded for wireless E911; in Kentucky, 
Virginia, and Washington, state funds to help finance wireless E911 
upgrades are only available to primary PSAPs; in Maryland, the issue is 
currently under discussion, although consolidating secondary PSAPs with 
primary ones has been considered. In addition, some secondary PSAPs are 
so small that they may never need wireless E911 equipment. Currently, 
the DOT/NENA database does not differentiate between PSAPs that will 
need to be upgraded and those that will not, which limits usefulness of 
the database in accurately assessing progress toward full wireless E911 
implementation.

For its part, FCC requires large and midsize wireless carriers that 
have filed for relief from deployment deadlines to provide information 
quarterly on their progress in implementing Phase I and Phase II. Until 
recently, the data submitted by the carriers and available from FCC 
were organized by carrier, not by state or county, and were not easily 
sorted to provide information concerning the status of wireless E911 
deployment. However, as of August 1, 2003, FCC also began requiring the 
large and midsize wireless carriers to submit data in an electronic 
spreadsheet format regarding deployment of Phase I and Phase II by 
PSAP. Because this spreadsheet has several fields, including the state, 
researchers can search by field and have numerous options for 
organizing the data. In addition, small wireless carriers, which had 
also requested relief, also were required to file one interim report 
with FCC about their E911 progress on August 1, 2003. Based on the 
August filings, FCC told us that most of the large and midsize carriers 
appear to be making good progress toward readying their networks to 
respond to PSAP requests for E911 services.

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

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

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

[See PDF for image]

[End of figure]

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

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

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

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

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

At present, it is up to state and local governments to determine how to 
pay for PSAP wireless E911 upgrades. To cover the costs associated with 
implementing wireless E911, responses to our survey showed that the 
majority of states (39 states plus the District of Columbia) require 
wireless carriers to collect funds from their subscribers through a 
surcharge included on subscribers' monthly wireless phone 
bills.[Footnote 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 legislature allocated funds 
for E911 initiatives, and it was unclear when or if that would 
occur.[Footnote 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 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.[Footnote 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.[Footnote 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 Continue to Slow Wireless E911 Deployment:

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

The difficulties in coordination between the parties at times caused 
frustration, according to some contacts we interviewed. For example, 
representatives from two of the PSAPs we contacted noted that just 
determining the number of wireless carriers providing service in their 
PSAP's jurisdiction can be difficult. One PSAP administrator told us 
that in order to get a complete list of providers before sending out 
his request letters for Phase I, a PSAP employee drove around the 
county to identify the cell tower owners and contacted them to obtain 
the names of the wireless carriers leasing space on the 
towers.[Footnote 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 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.[Footnote 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:[Footnote 25]

* 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.[Footnote 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 Location Technology Appear Resolved, but Technical 
Challenges Remain Regarding New Wireless Devices and Services:

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

We asked the officials we interviewed what they saw as the remaining 
technical issues affecting wireless E911 implementation. Several 
parties mentioned a variety of technical problems that might slow 
wireless E911 implementation or affect the quality of 911 services in 
general. Problems that were mentioned include the following:

* Because the United States never adopted a single standard for mobile 
phone transmissions, the different systems used by wireless carriers 
are not always compatible with one another, which can affect the 
ability of a particular subscriber to reach 911 in the first place if 
they do not have a phone that can be used with multiple systems.

* While GPS can provide more accurate location data, concerns exist 
over the time it takes for location data to be calculated and delivered 
to the PSAP. In the context of an emergency call, even a wait of 10 or 
20 seconds for the location data to be processed is considered a loss 
of valuable time.

* For rural wireless carriers that have selected a network-based 
solution, cell towers often are placed in a straight line and spaced 
widely apart along highways or other roads. This can make the 
determination of location difficult because the towers cannot 
accurately triangulate the location of the caller. Additionally, the 
handset-based solution may not be immediately available due to 
equipment issues.

Another problem was raised by some of those we interviewed: the 
antiquated wireline 911 infrastructure that conveys many E911 calls 
from the wireless carrier to the PSAP. This issue was also raised by 
Dale Hatfield, former chief of FCC's Office of Engineering and 
Technology. In 2001, FCC asked Mr. Hatfield to conduct an inquiry into 
the technical and operational issues associated with wireless E911 
deployment. His October 2002 report to FCC noted that the wireline 911 
network is fundamentally unchanged since its inception in the 1970s and 
that the existing 911 infrastructure "is in no condition to accommodate 
the pervasive use of wireless technologies, the Internet, or the many 
other product offerings that invite or demand access to 9-1-1 
services."[Footnote 27] Those offerings include new wireless 
technologies that could send E911 calls (e.g., automatic crash 
notification systems on cars that would also be able to send 
information to the 911 call taker about whether air bags have deployed 
or whether the car has flipped over), and the 911 services may need to 
be expanded to encompass such technologies. Many of those with whom we 
spoke believed that such new technologies should be considered now, 
rather than later. Some were critical of the LECs' failures to upgrade 
to modern digital technologies that would facilitate the rollout of 
wireless E911 technologies and improve 911 services. FCC released a 
notice of proposed rulemaking to reevaluate the scope of communications 
services that should provide access to 911 and has received comments 
and reply comments from interested parties.[Footnote 28] NENA is also 
trying to address the issue of new technologies and of a "future path 
plan" for the 911 network.[Footnote 29]

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

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

Beyond enforcing deadlines on wireless carriers, FCC has taken actions 
to identify both roadblocks and best practices in wireless E911 
implementation. For example, the Hatfield report made a number of 
findings regarding obstacles to wireless E911 implementation. Those 
findings involve wireless carrier implementation issues, cost recovery 
and PSAP funding issues, and the lack of comprehensive stakeholder 
coordination. Public comment was sought on the report in late 2002 and, 
according to FCC, the Commission is currently considering both the 
recommendations contained in the report and the comments 
received.[Footnote 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.[Footnote 31]

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.[Footnote 32]

DOT also convened a Wireless E911 Steering Council[Footnote 33] to 
develop a Priority Action Plan, released in May 2003, that outlines six 
priorities for wireless E911 implementation:

1. Establish support for statewide coordination of wireless E911 
technology, and identify points of contact within each state for each 
of the stakeholders.

2. Help to convene stakeholders in appropriate 911 regions in order to 
facilitate more comprehensive, coordinated implementation of wireless 
location technologies.

3. Examine cost recovery and funding issues at the state level.

4. Initiate a knowledge transfer and outreach program to educate PSAPs, 
wireless carriers, and the public about wireless location issues.

5. Develop a coordinated deployment strategy encompassing both rural 
and urban areas.

6. Implement a "model location program" to identify and isolate 
potential barriers to wireless E911 deployment.

Work on implementing this plan was in its early stages at the time we 
concluded our review. However, DOT had subdivided each priority into a 
number of action items, identified lead agencies or associations for 
each action item, and established a time frame for completion of each 
action item.

FCC and DOT staff told us that the agencies coordinate their wireless 
E911 activities to avoid duplication of effort. An FCC representative 
attends DOT meetings and events on wireless E911 to stay current with 
the department's activities; similarly, a DOT representative attends 
FCC meetings and initiatives on wireless E911. DOT officials noted that 
their efforts have been concentrated on providing assistance at the 
PSAP level since FCC has authority over the wireless carriers and LECs. 
While the agencies do not currently jointly staff or fund any wireless 
E911 projects, FCC officials noted that more formalized coordination is 
possible in the future.

Conclusions:

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

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

Recommendation for Executive Action:

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

Agency Comments:

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

:

As agreed with your office, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 14 days 
after the date of this letter. At that time, we will send copies to 
interested congressional committees; the Chairman, FCC; the Secretary, 
Department of Transportation; and other interested parties. We also 
will make copies available to others upon request. In addition, this 
report will be available at no cost on the GAO Web site at [Hyperlink, 
http://www.gao.gov] http://www.gao.gov. If you have any questions about 
this report, please contact me at (202) 512-6670 or [Hyperlink, 
goldsteinm@gao.gov] 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:

Signed by Mark L. Goldstein: 

Appendixes: 

[End of section]

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 [Hyperlink, http://www.fcc.gov/
911/stateplans/contacts.html] http://www.fcc.gov/911/stateplans/
contacts.html as the point of contact for that state.[Footnote 34] In 
25 states, the person named on FCC's Web site did complete the survey. 
In the remainder of our surveys, we were directed to another person. 
The survey contained 17 questions about the state's progress in 
implementing Phase I and Phase II, problems encountered, funding 
mechanisms in place, and the role of the state coordinator or any state 
offices involved in wireless E911 implementation. The questions were 
open-ended and were read to the respondents. Surveys were completed 
between June 11 and September 12, 2003. In addition to our survey 
results, we used data from the National Emergency Number Association 
(NENA) to illustrate the progress of wireless E911 implementation as of 
October 2003. To assess the reliability of NENA's data regarding 
information on total costs to upgrade PSAPs to Phase II readiness and 
the number of PSAPs receiving Phase II data as of the August 1, 2003, 
FCC quarterly filings, we interviewed knowledgeable officials from NENA 
about their data collection methods and reviewed any existing 
documentation relating to the data sources. We determined that the data 
were reliable enough for the purposes of this report.

To provide information on the factors affecting wireless E911 rollouts 
across the country, we selected nine states (California, Idaho, 
Indiana, Kentucky, Maryland, Missouri, South Carolina, Texas, and 
Virginia) and the District of Columbia for case studies. We selected 
states that were spread geographically across the U.S. and that 
appeared to be having various levels of success with wireless E911 
implementation based on early research. In particular, we selected at 
least one rural state and at least one state known to have redirected 
funds collected for E911 implementation to other uses. For each case 
study, we interviewed (in person or by telephone):

the state coordinator, a small wireless carrier serving that 
state,[Footnote 35] and one urban PSAP and one rural PSAP within the 
state.[Footnote 36] 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.

[End of section]

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 [Hyperlink, www.fcc.gov/cgb/
consumerfacts/e911.html.] www.fcc.gov/cgb/consumerfacts/e911.html.

[End of section]

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 Acknowledgments:

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

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FOOTNOTES

[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.

[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. 

[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.

[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.

[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).

[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).

[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.

[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. 

[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.

[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.

[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/.

[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. 

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

[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.

[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. 

[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.

[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.

[34] 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.

[35] 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).

[36] 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.

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