The Deadline for the E911 Mandate Approaches ...Where Do Things Stand?

By David H. Williams

_A great deal has happened since US wireless carriers finally started getting their act together about Wireless E911 a couple of years ago.Most notably the big six carriers (AT&T Wireless, Cingular, Nextel, Sprint, T-Mobile and Verizon) are now the big four, with the acquisition of Nextel by Sprint and AT&T Wireless by Cingular. While all these carriers had various waivers in their implementation deadlines, granted by the FCC at various points since the original 1996 Wireless 911 Mandate, they all shared a common endpoint - have your infrastructure ready to deliver wireless user location information to Public Safety Answering Points (PSAPs) by the end of 2005.

For carriers using GPS chips to help determine a user's location, this meant that 95% of all handsets in use needed to have been upgraded to GPS-capable models by December 31st, 2005.For carriers using a network-based location solution, the end of 2005 deadline was not strictly applicable, but they in turn had other deadlines to meet prior to that time in upgrading their cell sites to determine and transmit users' location information, as well as ongoing timeframe obligations to respond to PSAP upgrade requests.

We are almost at the end of 2005 and the question is: Where do things stand? The answer, in a nut-shell: from a carrier perspective - fairly good; from a PSAP perspective - pretty bad.The culprit - continued lack of funding to upgrade the PSAPs to receive and use location information.

Here's what's going on with PSAP funding.The federal government, most states, and some municipalities, collect taxes for 911 purposes which are levied on your wireless bill.For example, on my latest bill, I've got a Connecticut state 911 tax of $1.10 and a federal e911 tax of $2.That money flows (eventually) into state coffers, which is then supposed to feed to the PSAPs, sometimes directly to the individual municipalities that actually fund/operate the PSAPs, and sometimes to regional state/quasi-state bodies that then in turn fund the PSAPs.
(Another source of funding are grants from organizations like the Association of Public-Safety Communications Officials International, but these are hit-or-miss sources.)

Too often some of these funds get diverted to pay for equipment or just to fill budget gaps.This begs the question of whether there ever was enough funding.The situation really varies state by state.The bottom line is that this "trickle down" of funding is not doing the job.More funding and better allocation and utilization of it is needed.

There are lots of PSAPs out there.It took over a decade to get to the point where over 90% of PSAPs have implemented wireline (e.g.conventional) 911, and over 400 counties still don't have it, mostly because the lack of funding and a lack of justification to implement it in sparsely populated areas.

But getting back to the status of the carriers.After a tough stretch in the early 2000s, for a while carriers did an admirable job of meeting their respective waiver requirements and interim deadlines. However, with the final deadline looming, cracks have begun to appear. On September 29th Sprint Nextel asked the FCC for a waiver of the December 31st deadline because the Nextel part of the company would only be 70% compliant, and that it might take up to two years to meet the 95% requirement.Other small carriers who adopted a GPS-based handset strategy have also filed waiver requests about the December deadline.Verizon Wireless, who also uses such a handset strategy, said in its August FCC compliance filing that it too may not meet the 95% mark by December, citing slowing upgrades of older models, but it has not yet filed a waiver request.Network-based carriers, notably Cingular (including the former AT&T Wireless) and T-Mobile have met all their interim infrastructure upgrade benchmarks, and with no similar December deadline, now only have to focus on handling requests from PSAPs to upgrade to providing them wireless location information on a timely basis.

For PSAPs (there are more than 6,000 in the U.S.) to be able to receive and use wireless location data, upgrades to their computer and communications systems, as well as personnel and training programs, are required.Part of these upgrades will usually include the implementation of mapping/GIS capabilities, since location data received will be in the form of lat/long coordinates, which in turn will need to be graphically represented via mapping software since the location represented by the lat/long may or may not correspond to an actual street address, and it may change continuously if the caller is moving.Besides funding for these upgrades at the individual PSAP level, solid coordination of upgrades at a multi-PSAP/state level is essential to ease the implementation burden on individual PSAPs that are generally resource constrained and of course have their "day job" of being emergency 1st responders, as well as ensuring that post-upgrade communications between PSAPs and other public safety agencies (referred to as interoperability) works as seamlessly as possible.Lack of interoperability has appeared as a major issue in practically every major public disruption event since and including 9/11, including the hurricanes of 2005.

GPS-based carrier hiccups aside, the real issue with respect to E911 implementation lies with the slow pace of PSAP upgrades to receive and process wireless phone location data.As Sprint put it in its most recent regulator filing (August 2005, prior to the Nextel acquisition close), "Despite Sprint's significant capital investment and support, ubiquitous deployment of enhanced 911 services does not appear to be likely any time in the near future.The vast majority of PSAPs have not gotten to the point where they were ready to request the deployment of either Phase I [which refers to the latitude/longitude coordinates of the primary cell site the caller is connected with] or II [which is the lat/long coordinates of the phone itself] services.Sprint cannot unilaterally deploy these services and must also rely upon public safety and local exchange carriers to take the steps necessary to implement these services." Nextel made a very similar statement in that quarter's filing, saying, "Unfortunately, problems such as inadequate funding at local, state, and federal levels, have impeded PSAP deployment efforts"¦.Thus, the vast majority of PSAPs throughout the country are incapable of receiving and using a caller's latitude and longitude"¦".The most recent available statistics (in 2004) put the percentage of PSAPs that have upgraded to receive wireless location information in the 15 to 18% range; current estimates have the percentage in the very low 20 percent range at best.

The good news is that wireless E911 upgrade coordination has markedly improved over the last year and a half.However, the bad news is that the funding issues have improved little, due to budget deficits, shifting priorities, uneven application, collection, and disbursement of 911-related taxes, and the like, and has now become THE critical path issue for wireless E911 implementation, instead of being just one of many factors, and one that is unlikely to be resolved soon.The General Accounting Office titled its November 2003 report to Congress, "Uneven Implementation of Wireless Enhanced 911 Raises Prospect of Piecemeal Availability for Years To Come." Unfortunately this appears to still hold true as we near the end of 2005.

Published Thursday, December 1st, 2005

Written by David H. Williams

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