Trade Pointed Letters on Upcoming Phase II Milestone |
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Trade Pointed Letters on Upcoming Phase II Milestone |
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The Cellular Telephone and Internet Association (CTIA) sent an open letter to APCO and NENA asking for their cooperation in making Phase II wireless E911 a reality, but also pointedly calling into question the readiness of America's PSAPs to accept the location data that wireless carriers will provide.
That letter prompted a joint response from NENA, APCO and NASNA, which in turn prompted a second letter from CTIA. Compare Wheeler's first letter with our report on the speech of another CTIA official during the 2001 annual NENA Conference in Orlando. updated 7-23-2001
Cellular Telecommunications & Internet Association
June 14 2001
The Board of Directors National Emergency Number Association
P.O. Box 360960 Columbus, OH 43236
The Board of Directors Association of Public-Safety Communications Officials
International, Inc.
351 N. Williamson Blvd. Daytona Beach, FL 32114
Dear Director:
I want to thank both NENA and APCO for is opportunity to continue our dialog at this gathering together of the two Association's Boards in conjunction with the start of NENA's 20th Annual Conference in Orlando, Florida. If we are to succeed in delivering enhanced wireless 9-1-1 services to the American public, it will require our mutual cooperation and dedication to satisfy the expectations of Congress, the Federal Communications Commission, and most importantly, the public we all serve.
I am extremely proud of the fact that CTIA, on behalf of the wireless industry, joined your associations more than six years ago to jointly ask the FCC to establish the now familiar two phase deployment of wireless E9-1-1. Contrast our industry's record with that of the wireline industry. In 1994, the FCC began a proceeding, CC Docket 94-102, with the goal of providing enhanced 9-1-1 services to wireline customers served by a PBX, and a single segment of the wireless industry-- the new Personal Communications Services (PCS) carriers. While the wireline industry has continued to find reasons to delay delivering call back information and location information for customers located behind a PBX, the wire less industry joined with public safety to develop and deploy new lifesaving technology available no where else on earth. With CTIA's support, the FCC adopted an aggressive deployment schedule for wireless E9-1-1--a schedule that puts wireline 9-1-1 deployment to shame and expands the scope of the original' petition to include not only PCS.providers, but all cellular and enhanced Specialized Mobile Radio Service licensees.
We are now midway through delivering on our joint promise. As you know, every wireless switch in the country is Phase I compliant (even if the PSAP is not able to utilize the information). Expanding upon that deployment, b October 1, 2001, wireless carriers will have implemented the Phase II capabilities or will have committed to binding deployment schedules with the FCC. While some may call these schedules "waivers," that is an incorrect appellation since they constitute a binding agreement with the regulatory agency for the delivery of specified capabilities. The FCC has made clear, as recently as two weeks ago in testimony to the Telecommunications Subcommittee of the Commerce Committee of the United States House of Representatives, that wireless carriers will not be relieved of their obligations to deploy E9-1 -1 If a carrier is unable to meet the October 1 date, the FCC is requiring a commitment to an implementation schedule based on a detailed review of the carrier's wireless technology y and network capabilities.
Our experience deploying Phase I E 9-1 -1 has demonstrated that three parties are essential to a successful resolution of this challenge: the wireless industry (both carriers and suppliers), the Federal Communications Commission, and you and our colleagues, the Public Safety Answering Points (PSAPs). This is neither the time nor place to catalog our differences with the FCC, but their actions have had consequences that affected the deployment of wireless E9-1-1. Public safety and the wireless industry, for instance, both asked the FCC not to do what it ultimately did on uninitialized phones, a decision that makes it impossible for a PSAP to call back to verify an emergency call or reconnect if a call has been dropped or terminated. In another matter, concerning a fundamental change in the cost recovery rules that shifted additional implementation costs to wireless carriers, our two organizations did not agree. And in what is probably the most critical of these actions that have consequences, the FCC continually shifted the location accuracy requirements so that the standard upon which our organizations had agreed was never a stable platform for technological development. Regardless of the outcome, the FCC required a year or more to resolve each disputed issue, thus freezing the parties' positions, impacting technology decisions by carriers and their suppliers, and delaying deployment planning while the FCC deliberated.
October 1st is less than one hundred days away. The purpose of.this letter is to ask how we can work together to assure that the Public Safety community will be as ready to deliver on the FCC-carrier agreements as the carriers will be. Neither one of us wants to be caught in a "tree falling in the forest" situation where the information from a location equipped phone or network, is not usable by the PSAP because its equipment has not been upgraded to utilize the wireless location information (e.g., to receive and process latitude/longitude into a dispatch address). This is particularly important because, the concept of a "soft launch" of E 9-1-1 service is hard to imagine.
When the first wireless customer receives a location-enabled wireless phone, and when wireless carriers deploy network-based solutions, the public is going to expect Phase 11 E9-1-1 features and service wherever they roam because, to state the obvious, a wireless phone is a mobile device. Project LOCATE may be a start, but it is not an answer to what wireless carriers, policy makers and the public are seeking. Not only is Project LOCATE limited to fewer than fifty of the nation's 6800 PSAPs, but our review of the specific PSAPs participating in Project LOCATE suggests that a significant number lack either the funding or the technical capabilities required for Phase II wireless E9-1-1 service. As carriers deploy Phase 11 technology, attention will shift to PSAPs that lack the ability to provide lifesaving enhancements to wireless customers with location-enabled handsets or those who roam in and out of PSAPs with and without Phase 11 capability..
The wireless industry is entering into binding agreements' with the FCC that will specify the rollout of E 9-1-1 technology and attach penalties thereto. How can the PSAP community make a similar binding and enforceable commitment? We recognize that you are not regulated by the FCC (nor by any Federal body), however, as the wireless industry commits to an enforceable delivery of E 9-1 -1 capabilities, should not the 6 800 PSAPs embrace a similar level of commitment?
We must work together to avoid the potential for massive confusion and dissatisfaction that could result if customers who believe they have purchased a phone (or wireless service) with enhanced wireless 9-1-1 capabilities discover that their phone (or service) does not deliver on its promise because the PSAP involved can not deliver on its promise. The wireless industry, in some instances for many years, has been collecting monthly fees to pay for PSAP E9-1-1 upgrades. Currently these payments to PSAPs are estimated to amount to approximately $700 million per year. Yet, to the best of our knowledge, these fees have not resulted in any where near the upgrades necessary to enable PSAPs to receive Phase I location information, let alone the Phase II information carriers will shortly be delivering. The billions of dollars collected from consumers must be put to work immediately to enable Public Safety to keep their end of the E9-1-1 commitment.
Another challenge we face together is the lack of uniform implementation plans. Individual dealings with 6800 PSAPs is cumbersome, costly and counter productive. CTIA has long sought the ability to work with PSAPs to develop unified statewide E9-1-1 deployment plans. Absent such statewide coordination and implementation, deployment of wireless E 9-1-1 will require tens of thousands of individual contracts, and extensive local program management. Congress recognized the benefits of statewide implementation in the 9-1-1 law passed in 1999, and specifically instructed the FCC to facilitate the development of such plans. Unfortunately the FCC has done nothing to further the intent of Congress in those states that do not have a comprehensive plan for deployment of wireless E9-1-1 service. Our organizations and members must work to develop and adopt statewide implementation.plans in each of the fifty states.
Together, our members should be seamless links in a single chain. Policy makers, and the public they serve, expect the chain to support ubiquitous wireless E9-1-1 service. The wireless industry will invest billions of dollars to upgrade its networks and handsets. The nation's 120 million.wireless subscribers will pay an estimated $700 million a year in 91 1 surcharges intended to support PSAP deployment of the Phase I and Phase II features. As I have said throughout this correspondence, these realities create a common challenge that is only resolvable together.
Just last week, Chairman Upton asked CTIA and its members to improve our communication with the Public Safety community. I hope this letter can be the start of a constructive new dialog. CTIA joined with NENA and APCO to urge the FCC to adopt the original Phase I and Phase II wireless E9-1-1 rules, and CTIA wants to join with making the promise of the rules life enhancing reality.
Very truly yours,
Thomas E. Wheeler
[download Acrobat version of this letter]
APCO immediately issued the following press release in response to the CTIA's letter, and then followed up with a longer letter:
For IMMEDIATE Release
Media contact: Cindy Lorow, Director, Association Operations
APCO International
351 N. Williamson Blvd.
Daytona Beach, FL 32114
(386) 322-2500 or (888) APCO-9-1-1
lorowc@apco911.org
JOINT STATEMENT OF APCO, NENA & NASNA
DAYTONA BEACH, Fla - On June 24, 2001, the Boards of the Association of Public-Safety Communications Officials-International, Inc. (APCO) and the National Emergency Number Association (NENA) received a letter from Thomas Wheeler, President of the Cellular Telephone and Internet Association (CTIA). The letter was released by CTIA to the press, and was the subject of an address by a CTIA official at the recently completed NENA Annual Conference in Orlando.
The leadership of APCO and NENA, along with the National Association of State Nine One One Administrators (NASNA), are currently preparing a written response to Mr. Wheeler's letter. In the meantime, APCO, NENA, and NASNA wish to make clear that they were dismayed and offended by both the tone and the substance of Mr. Wheeler's letter, which contains inaccurate statements, unfairly attacks the integrity and commitment of public safety officials and agencies, and attempts to shift the blame for the status of wireless E9-1-1 deployment from carriers to PSAPs and the FCC. Mr. Wheeler's letter is also inconsistent with the more cooperative nature of prior discussions between our organizations and most of the major wireless carriers. Several of those carriers have indicated to us in recent days that they strongly disagree with Mr. Wheeler's letter.
A formal response to Mr. Wheeler will be sent to him during the week of July 2. [see next section]
From: ASSOCIATION OF PUBLIC SAFETY COMMUNICATIONS OFFICIALS-INTERNATIONAL, INC.
NATIONAL EMERGENCY NUMBER ASSOCIATION
NATIONAL ASSOCIATION OF STATE NINE ONE ONE ADMINISTRATORS
July 2, 2001
To: Mr. Thomas E. Wheeler President/CEO, CTIA, 1250 Connecticut Avenue, Suite 800 ,Washington, DC 20036
Dear Mr. Wheeler:
We have received your letter of June 24, 2001, to the Boards of the Association of Public-Safety Communications Officials-International, Inc. (APCO) and the National Emergency Number Association (NENA). We agree with your assessment that industry (including wired telephone companies), public safety, and the FCC must work together to accomplish wireless E9-1-1 as quickly as possible. We have cooperated with CTIA and its members in the past, and will continue to do so in the future. Indeed, the leadership of APCO, NENA, and the National Association of Nine One One Administrators (NASNA) recently held detailed meetings with each of the nationwide wireless carriers to discuss the status of E9-1-1 deployment and areas of mutual concern. Unfortunately, the tone and substance of your letter does little to further the cooperative spirit necessary to make wireless E9-1-1 a reality, and several of the carriers with whom we had met have contacted us to express alarm regarding the content of your letter.
We have always recognized that implementing wireless E9-1-1 is not a simple task, and that it will require the devotion of substantial resources by all parties. Our associations and the PSAP community as a whole have placed the highest priority on overcoming these obstacles, as it is PSAPs who must confront the life-threatening problems posed every day by the inability to identify quickly and accurately the location of emergencies reported with wireless telephones. Thus, we disagree with, and are frankly offended by, CTIA's apparent effort to deflect criticism of carriers by suggesting that there needs to be a "binding and enforceable commitment" by the PSAP community to make wireless E9-1-1 a reality.
PSAPs are driven by one factor, and one factor alone: saving lives. It is the PSAPs who are forced to send "search parties" to look for emergencies because wireless 9-1-1 callers cannot identify their locations or because calls are "dropped." It is the PSAPs who must use up critical minutes to gather verbal location information, lengthening the time before emergency personnel can arrive at the scene and delaying the answer of other 9-1-1 calls in queue. It is the PSAPs who must answer dozens of calls reporting the same incident because they have no way of distinguishing those calls from others reporting different incidents. In short, the PSAPs do not need "binding and enforceable commitments" as incentives to implement wireless E9-1-1.
We are also deeply troubled by your implication that PSAPs and local governments have misappropriated the 9-1-1 fees collected through wireless telephone bills by failing to use those funds for wireless E9-1-1 upgrades. You appear to assume that implementing wireless E9-1-1 is the only expense that PSAPs incur and the only purpose for which 9-1-1 fees should be expended. The reality is that, even without E9-1-1 capability, PSAPs must still respond to approximately 120,000 wireless 9-1-1 calls every day, representing 40% of all the calls they receive. That creates a huge drain on PSAP resources, made worse by the fact that call-takers must obtain verbal location information from every wireless caller and have no way to manage the dozens of duplicate calls regarding the same emergency. Wireless 9-1-1 fees have helped, and will continue to help, fund Phase II upgrades. However, to suggest that those funds have not otherwise been "put to work" is a gross mischaracterization.
Your comments are particularly troublesome in light of the fact that the willingness and ability of PSAPs to accept and respond to wireless 9-1-1 calls (despite the limitations and frustrations of doing so) has played a major role in the tremendous success of the wireless industry that you represent. Most of the over 110 million wireless subscribers first acquired wireless telephones specifically for safety purposes, and CTIA itself has often championed those safety benefits. However, those safety benefits would not exist without the 9-1-1 capabilities provided by PSAPs, which in turn are supported in large part by the 9-1-1 fees collected on subscriber bills.
We also question the accuracy of your assertion that every wireless switch in the country is Phase I compliant. In any event, even if true, why are there still carriers who have failed to provide Phase I service despite valid PSAP requests made well over six months ago, and in some instances nearly two years ago?
You also comment upon the status of Phase II requests, suggesting that only a tiny number of PSAPs (and only some of the Project Locate model PSAPs) are currently ready to receive and process Phase II information. First, PSAPs that are not ready today will be within six months following their Phase II request. Second, Project Locate's efforts, and those of APCO, NENA, and NASNA, are not limited to the small number of model PSAPs. Many other PSAPs from across the nation have submitted or will soon submit their own Phase II requests. Third, counting Phase II requests can be misleading, as there have been state-wide and county-wide Phase II requests that represent dozens, if not hundreds, of individual PSAPs, covering substantial portions of the nation and its population. Of course, we agree that much, much more needs to be done to ensure that every PSAP is Phase II-ready, and we hope to cooperate with CTIA and wireless carriers to achieve that goal. Unfortunately, the tone of your letter does not lend itself to that necessary degree of cooperation.
Finally, we also take issue with your suggestion that changes in FCC policy have led to significant delays in carrier compliance. The basic wireless E9-1-1 requirements have been in place since 1996. Carriers knew then that they would have to provide Phase I and Phase II capability and have had no legitimate reason to freeze in their tracks or "delay deployment while the FCC deliberated." Many of the changes made since 1996 were made at the carriers' request and provided greater flexibility as to how and when to implement E9-1-1. The dates were pushed back, and provisions were made to accommodate carriers' desires to implement handset solutions on an incremental basis. Furthermore, to the extent there were delays in final Commission action, those delays were in some instances the result of carrier petitions and other actions that were hardly intended to speed the process.
We would very much have preferred to send you a letter congratulating CTIA on its devotion to wireless E9-1-1 deployment and thanking you for a cooperative spirit in getting the job done. We do not wish to be seen as extending our differences with CTIA, and are therefore disturbed that we found it necessary to send this letter to set the record straight. While we are troubled and offended by portions of your letter, we strongly agree with your call for cooperation. We are determined to move forward, and remain committed to working with you and your membership to overcome the obstacles that we all face.
Sincerely,
Lyle Gallagher, President Association of Public-Safety Communications Officials-International, Inc.
351 N. Williamson Blvd. Daytona Beach, FL 32114
Sharon Counterman, President National Emergency Number Association
P.O. Box 360960 Columbus, OH 43236
Evelyn Bailey, President National Association of State Nine One One Administrators
Vermont Enhanced 9-1-1 Board 94 State Street Drawer 20 Montpelier, VT 05620-6501
[download Word version of this letter]
Cellular Telecommunications & Internet Association
July 17, 2001
The Board of Directors National Emergency Number Association 422 Beecher Road, Tahanna, OH 43230
The Board of Directors Association of Public Safety Communications Officials International, Inc. 351 N. Williamson Blvd. Daytona Beach, FL 32114
Dear Directors:
I am writing in response to your July 2, 2001 letter, and to continue our dialogue about the challenges we jointly face implementing wireless enhanced E 9-1-1 services. That you were "troubled and offended" by portions of my letter is, of course, of great concern to me and to the industry CTIA represents. That letter was an effort to, as you suggest, "further the cooperative spirit necessary to make wireless E 9-1-1 a reality." I hope you will view this communication in that light as well. As I stated in my previous letter, there is a tri-party responsibility for the delivery of nationwide wireless E 9-1-1 deployment--the wireless industry, PSAPs and the FCC.
There can be no doubt that wireless carriers will begin the deployment of Phase II wireless E 9-1-1 service either on October 1st, or pursuant to a detailed carrier-specific schedule approved by the Federal Communications Commission. In either event, carriers are bound by the FCC rules and their commitments to the Commission. These regulatory actions will have consequences in terms of deployment. These consequences will directly affect your members and, through them, wireless consumers. The purpose of my previous letter was to inquire of your organizations how you intend to establish equivalent deliverable expectations for your members.
Your response to my inquiry was, "PSAPs that are not ready today will be within six months following their Phase 11 request." With all due respect, that is exactly the heart of the problem I was trying to raise in my earlier correspondence. With carrier-enabled handsets or networks available, consumers will expect location capability whether or not a particular PSAP has determined it wants to make a Phase II request.
What's more, consumers will expect wireless E9-1-1 not just in their home market, but also when they roam. While the rollout of wireline E 9-1-1 took thirty or more years (and still isn't ubiquitous), that was a manageable situation because, whatever the service limitation was, it was contained in one area. If my PSAP didn't offer E9-1-1 I knew it and acted accordingly. The situation with wireless E9-1-1, however, is not as containable: wireless consumers are, by definition, mobile, when they have E9-1-1 service at home, they will expect it everywhere. The FCC has mandated that carriers provide the capability to send location information; how is a wireless consumer to know if he or she is in an area where this is not possible because the PSAP has not decided to implement this capability?
The successful implementation of E9- I -1 is not a matter of "within six months following" a PSAP's request. Consumers will know immediately whether they have purchased an E9-1-1 capable handset, or whether their local network supports location capability. The only way they will have equivalent knowledge that the information being transmitted can be for their safety is for all of America's PSAPs to step up and commit to a parallel implementation schedule.
The essence of my earlier letter was to ask what can be done to assure that the PSAP community has an expectation of deliverability that is the equivalent to the expectation being shouldered by the carriers. The fact that your earlier letter observed, "Of course, we agree that much, much more needs to be done to ensure that every PSAP is Phase II-ready," only adds to the concern on this matter.
Wireless carriers have had Phase I capable switches in place for at least two years. Yet our understanding is that less than twenty percent of PSAPs have availed themselves of this capability. You asked, appropriately, "why are there still carriers who have failed to provide Phase I service despite valid PSAP requests made well over six months ago ... ?" I recognize it was a rhetorical question, however, doesn't the answer suggest that there are still major problems that have yet to be ironed out and that those problems won't get any easier with Phase In fact since Phase I is a technical precursor to Phase II, should not those problems get worked out before Phase II makes things even more difficult?
The lesson of Phase I is that while every switch is Phase I capable, the data it can send is either not reaching the PSAP (an issue involving companies different from the wireless or the PSAP is unable to deal with the information as it is transmitted (an issue associated with the PSAP not having done an upgrade). The FCC is putting the wireless industry on a time schedule to iron out all the issues at its end; my inquiry was to seek a similar commitment by the PSAPs to deal with their key issues in a manner in which the solutions are binding on every PSAP.
For example, whether a network-based or handset-based solution, the PSAP will find it necessary to take the latitude/longitude information generated by the wireless carrier and translate it to a specific dispatch address. A significant concern in the wireless community is the lack of a standardized (or at least agreed-to) methodology to interconnect and process this information. As you know, one of the experiences that has troubled the implementation of Phase I E9-1-1 is that there is no standard interconnection. Thus, even though a carrier may have standardized the way it handles information throughout its network, a local PSAP's insistence on something different can slow down the whole process. If this has been a problem when only about 1,000 PSAPs have requested Phase I capability, imagine what it will be like when 6800 PSAPs decide they want Phase II, but there is no standard as to just how it should be accomplished.
Another issue that will affect whether or not a consumer's call for help will be translated into specific location information at all PSAPs is the protocol that is used to transmit data. As you know, most wireless networks transmit call identifying information on the SS-7 protocol. We understand that some PSAPs want the information to come in Internet Protocol (IP) for format. It makes no sense for one PSAP to do it one way and another to do it another. Nor does It make sense to insist that the carriers' signaling system be changed for this one purpose. These are matters that can be worked out, but there must be some sort of structure that will resolve them and then enforce the resolution.
We understand that you have created a committee to look into these issues. If we can with that committee, please let us know. However, with October 1 less than 75 days away, are concerned that the calendar and the FCC's mandate are moving faster than any committee can reasonably be expected to reach and implement its conclusions. Again we fear a situation where the consumer expects location capability because the FCC has mandated it of the carrier, but a PSAP cannot provide it because of technical considerations.
You will recall that it was CTIA that joined with your organizations to petition the FCC to adopt an E9-1-1 requirement that we had together worked out. We do not underestimate the challenge of implementing the E9-1-1 rules on both our members. The regulatory process is imposing uniform requirements on wireless carriers, what will be the equivalent solution for your members?
For instance, carriers' Phase I deployment has been complicated by the lack of a unified PSAP implementation plan. Individual dealings with the approximately 6,800 PSAPs are cumbersome, costly and inefficient. CTIA has long sought the development of unified E9-1-1 deployment plans. Absent such statewide or regional coordination and implementation, deployment of wireless E9-1-1 will require tens of thousands of individual contracts, and extensive local program management. Congress recognized the benefits of statewide implementation in the Wireless Communications and Public Safety Act of 1999, and in Section 3(b) specifically instructed the FCC to facilitate the development of such plans. I invite Public Safety to work with us to develop and then implement statewide E9-1-1 plans.
There is no doubt that the nation's PSAPs face incredible challenges in their daily support and delivery of life-saving services. One of these challenges is financial. Although wireless subscribers contribute approximately $700 million a year to support wireless E9-1-1 service, this money may not be provided to the PSAP serving the subscriber's home market (see, for example, The New York Times, "Counties with 911 Systems Want Share of Surcharge on Phones." July 1, 2001), or it might be diverted by the state to other uses as recently has happened in North Carolina and California. Consumers' access to emergency location information would be greatly enhanced if PSAPs both had access to, and could prioritize the use of the hundreds of million dollars being collected from wireless consumers.
As a technical matter, Phase I is a required element of Phase 11 services and many of the hurdles associated with Phase 11 implementation can be addressed in part, by implementing Phase I. Moreover, as Phase 11 services begin to be deployed in some of the more sophisticated call centers, the lack of even Phase I in other areas will risk creating a "Safety Divide" with every more consequences than those associated with the so-called "Digital Divide".
While there are many reasons why Phase I service has not been deployed ubiquitously, CTIA has identified certain key elements that are associated with the successful introduction of Phase I service. Where these elements are missing, the public is more likely to be denied the benefits of Phase I and we fear Phase II, capabilities. Alabama, Florida, Iowa and Tennessee are representative states where the deployment of Phase I service has been the most successful. In each of these states, three factors contributed to their significant progress in the deployment Phase I services:
In Alabama, Florida and Tennessee, some carriers have fully deployed Phase I services throughout the state, while other carriers are well on their way. Iowa, a state that first began collecting wireless surcharges in January, 1999, is already well along in implementing a coordinated, phased, statewide roll out of Phase I services. While undoubtedly there are individual PSAP and/or carrier issues in each of these four states, the results to date demonstrate the critical importance of statewide funding, centralized coordination, and a technology neutral approach to implementation.
Unfortunately, approximately half of the nation's states still have no Phase I service. While rapid progress is being made in many states, in other states, PSAP or state-level choices that lean towards one or another technology platform impose an impediment to additional deployment. Even in states with cost recovery for wireless carriers, there are compensation- parity issues, where carriers who choose CAS (or NCAS) solutions are financially penalized if they have made the "wrong" choice. A state-level approach that supports both CAS and NCAS solutions clearly facilitates the implementation of the Phase I services.
By reviewing the record to date, it is clear that implementation is facilitated when all three factors are present in a state. Sixteen states appear to have no Phase I implementations yet, but the PSAPs and wireless carriers are in implementation mode as evidenced by items such as ordering trunks, and undertaking database conversions, network upgrades and cutover activities. In some of these Pre-Phase I states, stronger statewide leadership could assist their deployment. Iowa, for example, has gone from zero to a plan for statewide Phase I implementation in. less than two years due to this statewide leadership. Of greater concern, however, are the eleven states that have no Phase I implementation underway. While three of these states have not passed legislation that will support funding and PSAP upgrades, the majority of these states appear to have little or no activity underway. Wireless subscribers in these states will fall on the wrong side of the "Safety Divide" if leadership and support are not provided in the very near future. With statewide leadership and coordination, however, I am certain every state in the Union can support Phase I and then implement Phase II services.
There are other issues where a strong, programmatic approach seems appropriate. Many of these are technical issues that impact the PSAP, primarily through its wireline local exchange (LEC) provider. In particular, certain software modifications for LEC switches designed to support Phase II services (J-STD 36) are behind schedule. While neither the PSAPs nor the LECs can necessarily control the software development schedules of the underlying switch vendors, CTIA stands willing to work with you to highlight the issue and support the prioritization needed to facilitate the timely deployment of Phase II services. Technical standards issues exist in other areas, such as IP versus SS7 transport protocols for Phase II services. Again, this might be an area where national leadership might facilitate the developing work required to ensure timely delivery of the modifications. We understand that some of' these issues are being addressed within the NENA Technical, and Wireless Committees and we applaud their efforts to provide the technical and operational planning the nation's PSA.P will need.
The work currently being done by NENA, APCO, and NASNA to inform and educate PSAPs throughout the nation is to be commended. But if we are to deliver on the promise of this life saving technology, we must do more. Funding mechanisms are not as straightforward as they could be. Monies in E9-1-1 funds can be diverted from their intended purposes. CT IA supports appropriate cost recovery mechanisms, and a technology- and platform-neutral approach within each state. Best practices can provide operational and technical frameworks for speedier implementation. But to Provide the ubiquitous wireless E9-1-1 service Congress intended, each state should have a centralized implementation mechanism that can support. and coordinate the deployment of wireless E9-1-1 services throughout the state.
Putting millions of location-enabled handsets into wireless customers' hands is meaningless if the information is not usable by the PSAP. Building Phase II networks is meaningless if the wireline switch is not compatible with that information. Providing Phase II services in one county, when the adjacent county has not even deployed Phase I will confuse the public's trust and expectations. These are very real concerns, and we are asking you, the PSAPs to keep pace with the commitments that the wireless industry is required to honor with an enforceable set of commitments for all American PSAPs.
The wireless industry is committed to the successful implementation of E9-1-1 service. In my June 24, 2001, letter, I expressed CTIA's willingness to work with the Public Safety community to develop a programmatic approach to delivering Phase II wireless E9-1-1 in a planned, coordinated effort nationwide. The challenging issues wireless carriers face are well known. Public Safety must address its own list of implementation issues if we are to deliver on our joint commitment of providing enhanced wireless emergency services. This letter is another attempt at a constructive dialogue between the wireless industry and the nation's PSAPs. We look forward to working with you in the weeks and months ahead in our joint responsibility - wireless carriers delivering location information, and PSAPs prepared to use that important information to use saving lives.
Very truly yours,
Thomas E. Wheeler
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