Wireless Carriers are Making Great Progress Implementing Wireless E911…So What’s the Problem?

By David H. Williams

E911_Carrier_Status Most Americans dialing 911 from their home or business phone expect nearly instant results on their doorstep from emergency responders.What is less clear to them and even seasoned technology, government, and business professionals is the level of technology infrastructure and operational processes required to provide these 911 services.For most of them it just works, and that is all that matters.

Many of them would be upset or even horrified to find out that dialing 911 from their wireless phone would likely give them far different results.Emergency dispatchers today responding to wireless 911 calls cannot, for the vast majority of these calls, determine the caller's current location, often jeopardizing response time and too often resulting in the victim not being found in time.(See http://www.nena.org/Wireless911/Tragedies.htm for examples of these tragedies.)

Well over 150,000 911 calls a day are made by wireless callers, and that number will continue to grow rapidly as the number of cellular subscribers grows.Consumers are discontinuing their landline service in large numbers in favor of the mobile phone, as those consumers buy wireless phones for their children for safety and peace-of-mind purposes.This expansion of wireless technology into everyday business and consumer life has enormous implications for the design of our public safety system, how we approach decisions involving homeland security, and how our federal, state and local officials develop and implement policy and allocate funds.

While many people, and the media, view the key obstacles to Wireless 911 implementation being the wireless carriers themselves, this is no longer true.The key obstacles are now lack of funding for Public Safety Answering Points (PSAPs), and the need to support them in marshalling and coordinating resources so they don't have to implement Wireless 911 on their own.

Historical Context
Wireless Carriers for several years were the "Bad Boys" of wireless E911 implementation ("E" stands for Enhanced - we will use E911 for simplicity), and justifiably so, as they resisted the original Wireless E911 mandate of 1996, begged and fought for waivers to the deadlines, and missed many deadlines even with the waivers they eventually obtained.PSAPs - the point of first response for fire, police, and other 911 calls (both wireline and wireless) complained about the lack of carrier responsiveness, and the FCC levied $1 million + fines on more than one unresponsive carrier.

Implementation Status
However, over the last two years in particular the carriers have gotten their acts together, admirably so, and continue to meet their respective waiver deadlines quarter after quarter.Here's an overview of their status, before we get into the remaining obstacles.

AT&T Wireless (AWS)
AWS, like Cingular and T-Mobile, originally selected Enhanced-Observed Time Difference (E-OTD) technology to deliver its network-based Phase II E911 strategy.Since that technology's collapse, AWS has done well despite significant obstacles to deploy its replacement, Time Difference of Arrival (TDOA), within the timeline dictated by its FCC waiver.

Since AWS is pursuing a network-based location strategy, its waiver depends on two dimensions for both its TDMA and GSM networks: 1) the number of cell sites it has modified to comply with E911 Phase II rules by certain dates; and 2) how long it has taken to comply with valid PSAP requests for Phase II E911 service.For several quarters, AWS has met the requirements on both of those dimensions.

However, the simultaneous management and execution issues of dealing with Cingular's acquisition of AWS, the continued conversion from TDMA to GSM, the scramble to replace E-OTD with TDOA and still meet its FCC deadlines, and other issues such as customer losses from Wireless Number Portability (WNP) and the introduction of new competitors (e.g.the new AT&T Wireless brand plus other re-branded competitors such as Virgin), will put an enormous strain on AWS' management and employees.Customers, regulators, and competitors for different reasons need to keep a keen eye on AWS over the next 6 - 12 months, as its challenges arguably are the greatest in its brief history, and it could falter, if not managed exceptionally.

Cingular Wireless is a joint venture launched in 2000 between SBC communications (owning 60% of the venture) and BellSouth, owning 40%.The venture joined SBC's and BellSouth's U.S.wireless operations into a nationwide carrier serving roughly 25 million subscribers.

Like AWS and T-Mobile, Cingular originally selected Enhanced-Observed Time Difference (E-OTD) technology to deliver its network-based E911 strategy.Since that technology's collapse Cingular has also struggled, but struggled successfully to deploy its replacement, TDOA, in the timeline dictated by its FCC waiver.The additional good news is that Cingular's waiver has slightly greater flexibility than does the AWS waiver.However, it is unclear what impact the acquisition of AWS will have on its waiver deadlines.

Similar to AWS, Cingular's waivers for its various network types is keyed off of two dimensions for its TDMA/AMPS and GSM networks: 1) the number of cell sites it has modified to comply with E911 Phase II rules by certain dates; and 2) how long it has to comply with valid PSAP requests for Phase I or Phase II E911 service. Cingular has met its deadlines for several quarters.

Going forward, the primary challenge of course will be its acquisition of AWS, and its ability to integrate/rationalize the two networks.With respect to E911, this means performing analyses to determine redundant cell sites and redundant TDOA-enabling equipment.This has the potential for producing dramatic cost savings and accelerating E911 deployment if managed correctly; not doing so could have the opposite effect: major needless costs and a dramatically slowed E911 implementation timetable, with fines to boot.

Nextel is notable among the "Big 6" U.S.wireless carriers in that it uses iDEN technology, which is based on its history of aggregating literally hundreds of SMR (Specialized Mobile Radio) licenses that were originally used by taxis and other dispatch services.This technological history gave rise to Nextel's "Push-To-Talk" feature, a walkie-talkie type capability that was alone in the industry until 2003 when other carriers started to introduce it.

Nextel made an early decision to deploy A-GPS technology to fulfill the E911 mandate.It got a slow tactical start, primarily because of technology development issues tied to its status as the only nation-wide iDEN carrier.Nextel has made a solid recovery, though, in its ability to meet the deadlines committed to in its waiver application and approval.It has been hampered recently with software problems that prevent users from benefiting from the full capabilities of E911, limiting location information to that of the location of the cell site the user is connected to, not the latitude and longitude of the actual user.Nextel says it is working on the problem, according to its most recent FCC filing (8/1/04).

Sprint PCS
Beginning in 1995, together with a number of partners, Sprint acquired PCS wireless licenses in 29 major trading areas in the FCC's first auction.By 1998 Sprint acquired its partners' interests and had full management control of Sprint PCS.

Sprint PCS is the clear leader of all U.S.carriers in implementing E911.It was the first and only carrier to meet the original FCC deadline of selling GPS-enabled handsets on October 1, 2001, and has met nearly all original deadlines since then.It was the first carrier to deploy a handset-based Phase II operating system (for Rhode Island in December 2001).And it was the first and only carrier to effectively reach the 100% of all new handset activations to GPS-enabled devices, reaching 99% of new handset activations at the end of June 2003.

Despite being the clear leader in implementing E911, Sprint PCS has done little to promote this fact to a wide audience or to leverage its lead into the deployment of commercial location-based services.While this is understandable to a certain extent (it might raise customer expectations inappropriately since so few PSAPs have the ability to process Phase I or II information), it also has been slow to capitalize on this widespread technology deployment for location-based services, which are not dependent on PSAP Phase I/II implementation.

T-Mobile USA is a subsidiary of German communications company Deutsche Telekom, and the product of many mergers and acquisitions over the last several years.This history illustrates a key advantage and key disadvantage that T-Mobile (USA) historically has had with respect to other carriers, particularly its U.S.GSM network brethren AWS and Cingular.Its advantage is that it has been a GSM-based carrier since early in its history, and thus has not had to deal with the technology migration issues that AWS and Cingular currently are encountering.

However, much of that advantage has been offset in its growth through (many) acquisitions.Many of these acquisitions (Omnipoint is a great example) were generated in the "wild, wild west" days of carrier build-out, where the goal was to create an adequate network as quickly as possible, gain an attractive number of subscribers, and get bought out by a larger carrier.

Many of these acquisitions had little operational, management, and support systems infrastructure to add to the acquirer, which was often a heavy burden.For that reason among others, T-Mobile did not enjoy the advantage one would have expected when it came to deploying E911 services, with its need to pull all aspects of a wireless business - technology planning, network provisioning, management, operations, back office support, and program management discipline - together at the same time.

Like AWS and Cingular, T-Mobile got slammed by the failure of E-OTD technology, and has been scrambling to make up for lost time.Though T-Mobile did not have to apply for multiple waivers because it was a GSM-only carrier, it did have to adopt a two-pronged approach regarding the number of cell sites that were Phase II-compliant, and the response requirements to PSAP requests.In addition, the FCC required T-Mobile to implement an interim E911 plan using NSS ("Network Safety Solution") technology.

In many ways, T-Mobile had a lot of advantages that its competitors did not, and to a very significant degree it did not capitalize on them.It didn't have to deal with multiple network technologies; it was one the last major carriers to apply for a Phase II waiver and receive it; and as a result of that and great lobbying, its E911 deadlines are the furthest out from the present timeframe among all the major carriers.Despite this, T-Mobile has been fined for Phase I violations, which have been less of an issue for competitors that did not have the same timeline advantages.

Verizon Wireless
Verizon Wireless, also known legally as Cellco Partnership, is the leading wireless carrier in the U.S. in terms of subscribers (this may or may not change after the acquisition of AT&T Wireless by Cingular closes).Verizon Wireless was created when Bell Atlantic (now Verizon) and Vodafone combined their U.S.wireless assets: Verizon Communications owns 55% of Verizon Wireless and Vodafone, 45%.The future of this relationship is uncertain; Vodafone has nearly always preferred to have a controlling stake in partnerships with other companies, and its recent attempt to buy AT&T Wireless (losing to Cingular) reinforced this perception as well as throwing doubt as to its long-term position with the Verizon partnership.In addition, Vodafone is a GMS-based carrier, and Verizon is a CDMA-based carrier.Vodafone also attempted a bid for AWS in competition with Cingular, confusing many investors.

Verizon Wireless has clearly performed solidly with respect to its negotiated FCC waiver deadlines, having not missed one for several quarters.It's only "bruising" has been a software problem, akin to Nextel's problem and similar to one Sprint PCS encountered last year, that prevented the ability to provide the precise latitude/longitude position of a user.Resolution of that issue at this writing is unclear.

Of all major U.S.Carriers, Verizon Wireless is the hardest to read "between the lines." They are very succinct in their public statements and findings, and are in general tightlipped as to internal issues.The author's opinion: Verizon is a close third behind Nextel (after Sprint PCS), but well above AWS, Cingular, and T-Mobile in terms of E911 implementation progress.

Regional/Rural Wireless Carriers
While there are over 100 wireless carriers in the U.S., in addition to the Big Six (soon to be five), only 24 of them to-date have filed E911 status reports with the FCC.Regardless of names, the most important fact is that the vast majority of these carriers serve rural markets that the major carriers (understandably from their perspective) choose not to focus on given the low ROI.From an E911 perspective, they have additional issues.

Rural areas by definition are more dispersed by geography than urban areas, and so it goes with the wireless carriers serving these areas.According to CTIA, rural wireless carriers, while serving only 18 percent of the wireless subscribers (approximately 24 million per CTIA figures), are estimated to cover over 60 percent of the geographic area of the U.S.Clearly such "remoteness," for lack of a better term, of a typical rural wireless subscriber would indicate a high likelihood of being far away from emergency service providers during a traffic accident, and thus increasing the importance of having very specific location information to reduce the time before help arrives.Moreover, other geographic challenges - tall mountains, wide valleys, vast prairies, deserts - provide additional obstacles to locating an accident victim.

The good news for users in these areas is that technology exists to better serve these areas in emergencies, such as GPS technology and ever more comprehensive mapping technology, which enables a very detailed digital mapping basis for PSAPs in remotely populated areas.The bad news is that many states with rural populations have been slow to enact taxes to help fund the deployment of the technology, or even worse, have raided those funds for other purposes.

In addition, FCC "rules" (the quotes indicating a lack of clarity with respect to the specificity and power of law around the applicable statements on the issue, in this case accuracy) with regard to accuracy of E911 systems are biased against rural carriers, in that they have fewer urban areas, which are used by larger carriers to "weight" overall accuracy compliance calculation requirements with their coverage of high population densities, and more importantly higher density of cell sites that in turn enable higher accuracy for a large portion of their user population.So far Congress, while recognizing the problem, has not cut the rural carriers a break, though many legislators understand the issue.

Ok, So What's the Problem?
There are two sets of problems: 1) (Relatively) Minor Carrier Problems, and 2) Major PSAP Support Problems.

The "Minor" Problems

These are essentially in the Carrier camp in what they view as their major issues, but are relatively small compared to those faced by the PSAPs.These carrier problems are no longer the "long-pole-in-the-tent," e.g.on the strategic critical path for E911 implementation.However, Carriers continue to complain about several issues with justification, from the strategic to the tactical, including (Reasons taken directly from recent FCC filings) the following.

  • Inadequate funding at local, state, and federal levels (addressed below)
  • Lack of E911 coordination bodies (addressed below)
  • Phase II technology complexity
  • PSAP lack of readiness
  • Lack of Local Exchange Carrier (LEC) cooperation - specifically, LECs that are still unable to pass Phase II data to their PSAPs or are awaiting further cost-recovery mechanisms before they permit Phase II services to be deployed, to the great annoyance of all concerned
  • Lack of upgraded PSAP Customer Premises Equipment (CPE), including "head fakes" of PSAPs that say we are ready...wait, no we're not
  • Improper connectivity between the PSAP's Automatic Location Identification (ALI) database and its CPE
  • PSAP "one-off" operational or technical requests
  • "Invalid" requests (many, many definitions of such but basically boil down to a he said/she said argument between Carriers and PSAPs on PSAP readiness issues).
The Major PSAP Support Problems
The most strategic issues include the following.

Funding - The collection, protection, and usage of E911 funds has become the critical path bottleneck to E911 implementation.Various U.S.States, particularly given the economic situation of the last two years, have resorted to co-opting E911 funds to fill budget shortfalls.There are few legal obstacles (yet, and none at the federal level) to this practice, though legislation pending in Congress will hopefully place strong deterrents to this practice going forward.In addition to the dollars themselves, it is critical to have robust safeguards and processes in place to ensure adequate and timely funding support at the state, and individual level of the nation's 6,700-plus PSAPs.Which leads to ...

Coordination - Coordinating the implementation of E911 programs has to be elevated to a multi-PSAP or state level.Several states do this already, with Rhode Island being the best example (though they obviously have a size advantage, in this instance), and Texas (on the other end of the size scale, which essentially takes a regional/multi-PSAP approach within the state via their regional coordination bodies).While the federal government has a role, through agencies such as the NHTSA, DOT, ITS, and of course the FCC and DHS, the key "line" coordination roles need to occur at the state level or, in cases of large states or states with many PSAPs, to multi-PSAP coordinating bodies within those states.This approach provides the best balance of scale and responsiveness, handling enough PSAPs to leverage implementation expertise and scale, but close enough to the PSAPs that they are a responsive enabler of E911 implementation, not a bureaucratic obstacle.Lessons from Rhode Island and Texas need to be applied nationwide.

Other Issues include:

Standards - The use of standards or guidelines, best articulated at the coordinating-body level or even individually at a PSAP level via consultation with its neighboring PSAPs, will help ease the challenges with technology decisions, which can accelerate individual implementation and improve...
...Interoperability - More than ever in this era of terrorism, PSAPs need to communicate and share information seamlessly with governmental agencies and quasi-governmental organizations.

Wireless Carrier Management - After many fits and starts, the FCC has stabilized how carriers are regulated with respect to E911 implementation and the support of PSAPs.Now that this system is working well, including the threat of fines, the FCC (and legislators) needs to keep the pressure on, not harshly, but firmly.In addition, the FCC needs to keep an eye on the LECs; many carriers and PSAPs have frequently accused LECs of being obstacles to E911 implementation.

Rural Carriers - These carriers represent an exception to the Wireless Carrier Management point above.The FCC and regulators in general need to give them a break with respect to accuracy requirements.They are at a distinct disadvantage due to the lack of densely populated areas whose more higher accuracy "weighting" can offset the relatively poorer accuracy that is a natural result of much less densely populated areas that form the core of rural carriers' subscriber bases.

Privacy and Security - Mobile location information needs to be properly protected yet still be available to provide valuable public safety and other LBS services. The federal government needs to take a leading role on this issue, in conjunction with other legislative initiatives in the related areas of SPAM/CAN SPAM, phishing, spyware, and general hacking threats.

The prognosis for wireless carriers progress in E911 implementation is quite positive, particularly given their progress over the last two years.While carriers are somewhat out-of-the-woods, they do have issues and can't let up on the good progress they have achieved.

Now, the biggest challenge to E911 implementation is on the public sector side - funding, coordination and other obstacles on the critical path to a nationwide implementation of wireless E911.These are now THE obstacles whose removal can prevent individual tragedies and enhance our overall security in the process.

Published Thursday, September 23rd, 2004

Written by David H. Williams

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