DOT E911 PRIORITY PLAN STRESSES COST RECOVERY, COORDINATION

Mineta tasked the council in April 2002 with drafting a plan for accelerating compliance with the FCC’s E911 requirements. Among its priorities: (1) Creating support for statewide coordination of wireless E911 technology and pinpointing contact points in each state. (2) Fostering more “comprehensive, coordinated implementation of wireless location technologies.” (3) Studying cost recovery/funding issues at the state level. (4) Conducting outreach programs for public safety answering points, wireless carriers and the public on wireless location issues. (5) Coordinating deployment among rural and urban areas. (6) Implementing a model location program. The steering council included NASNA, CTIA, the Assn. of Public-Safety Communications Officials, the Intelligent Transportation Society of America, International Chiefs of Police, NARUC, the National Conference of State Legislatures, the FCC, Qualcomm, USTA and others.

The action plan indicated that although many states had adopted comprehensive implementation and cost-recovery approaches for E911, state activities varied widely. Ten states have yet to adopt any approach, the plan said. It’s designed to help states that don’t yet have an implementation approach and to foster statewide coordination in “deploying wireless E911 utilizing a single statewide point-of-contact.” The 40 states with cost-recovery mechanisms differ widely in the amount of fees, the method of applying and collecting them, their allowable use and the administrative oversight of their distribution and usage, the plan said. Raiding of state E911 funds for other purposes has been a growing concern on Capitol Hill and elsewhere as some states have dipped into that money to make up for budget deficits elsewhere. “This lack of consistency adds to the confusion of which wireless carrier costs are to be reimbursed by the state or the PSAP and which are to be covered by the carrier through their own rate base,” the plan said. “States need to clarify which expenses are eligible for recovery through their state plans and which the carriers are expected to cover through their rate base.” It said “firm guidelines” are needed in areas such as system configuration and cost for PSAPs and carriers as they negotiate as part of the implementation process for E911. “Making this information widely available will speed the implementations,” the plan said. “Much time is lost today as these things are negotiated repeatedly with each PSAP.” In the area of cost recovery, the plan called for further clarification of an FCC ruling that an LEC’s selective router was the demarcation point for how E911 cost recovery was divided between PSAPs and wireless carriers. “This ruling needs to be more specific on certain cost items,” the plan said. It called for better information for PSAPs on “reasonable expense allocation.” It said: “The PSAPs need to know which expenses they can reasonably be expected to cover, which the carriers should cover, and receive guidance that will help them through negotiations with the carriers.” As for E911 Phase 2, the plan said “much confusion” remained in areas such as expenses and “how much is a reasonable amount to pay.”

“We agree with the secretary of transportation and the public safety community, deployment of this life-saving technology should be the nation’s highest priority,” CTIA Senior Vp-Govt. Affairs Steven Berry said. “It is ironic, then, that the FCC has saddled the wireless industry with another expensive and complicated mandate, designed strictly for convenience, in number portability.”