The cold war may be over, but the fuse it still sizzling on a government bombshell called Telecommunications Service Priority (TSP), four years after it was originally lit.
The original intent of TSP was to provide a structured way to restore the nation's telecommunications links during times of emergency. But instead, TSP set off a firestorm of controversy over its implementation, effectiveness and cost among the nation's public safety communications officials.
The issues are as complex as the federal agencies appointed to administer it.
On one side of the dispute is the National Communications System (NCS), an obscure federal agency obligated to make TSP successful. On the other side are the nation's public safety communications administrators, who have a long list of objections. Circling these two groups is the National Emergency Number Association (NENA) and the Associated Public Safety Communication Officers (APCO), both trying to represent its members and hammer out an agreement.
In the middle of all this are the regional telephone companies, who have spent millions modifying their computer software to implement TSP, but who are trying to stay on the sidelines of the dispute.
Beyond this boxing ring of groups are questions about the effectiveness of the nation's public safety associations, who didn't recognize TSP's impact when it was proposed, and are now still desperately trying to catch up before the final phase of TSP in March 1993.
Some Background
The Department of Defense (DOD) originated TSP in April 1987 to replace the Restoration Priority System (RPS), a post-Bay of Pigs scheme to insure presidential communications.
Col. Al Moore, who headed the agency responsible for implementing TSP, remembers why the DOD proposed TSP. "We saw that the RPS system had become archaic based on time, effort and technology."
Specifically, there were four main reasons that RPS had become ineffective, says Jerry Vaughn, the Federal Communications Commission (FCC) deputy chief who's overseeing the TSP project for the federal agency.
First, RPS records were completely out of date and didn't reflect the state of equipment at comm centers across the country. Vaughn says the explosion in telecommunications technology simply left the RPS in the dust.
Second, RPS applied only to inter-city, private-line telephone service, and not to local telephone links, which limited its effectiveness.
Third, RPS applied only to the restoration of existing services and not the provisioning of new services, which greatly limited the incidents covered by the emergency service.
Lastly, RPS limited the number of circuits that qualified in each priority category, causing bunching at the top priorities. Vaughn says this limited the meaningfulness of the priorities.
"The differences were regarded as insurmountable," Vaughn says. So at the DOD's request, the FCC issued FCC Order 88-341 in November 1988, setting forth how public safety agencies would voluntarily prioritize their communications links, and how telephone companies would handle requests for restoration or new services.
The TSP operating procedures have been published and telephone companies have begun to file local tariffs that will allow them to charge for the service. Meanwhile, NENA and APCO are maneuvering to get TSP rescinded, delayed or modified until their objections can be heard.
TSP: The System
There are several important elements to TSP. First, participation in TSP is completely voluntary. Second, telephone companies are permitted to charge for TSP services. Next, TSP covers both restoring existing lines and establishing new ones. Lastly, all levels of government and certain private industries are eligible for TSP service if the conduct business that bears upon national security or emergency preparedness.
Here is how TSP works: An agency decides which telecommunications lines they consider as priority. They fill out an application for each line and submit it through a state TSP coordinator.
The form passes to the Federal Emergency Management Agency (FEMA), then to the Office of National Communications System, where it's verified and assigned a TSP authorization number. The form then returns to the public safety agency by the same paperwork route.
During this processing, NCS assigns a priority level number to each line, from one through five, with five indicating the least priority. TSP currently automatically assigns 9-1-1 lines a priority 4 level.
An authorized agency would use TSP in either of two circumstances: when they require new service or the restoration of an existing service, and the phone company cannot provide the required service at all, or provide it within the necessary time
The Objections
Mary Boyd, Executive Director of the Texas Advisory Commission on State Emergency Communications, pretty much summed up the TSP opposition to an APCO audience: "I'm in favor of the concept. I'm not in favor of the program."
Most comm center managers recognize their dependence on telecommunications and that there should be a structured method of providing emergency restoration. Beyond that, virtually everyone is critical of the way it's being implemented.
The list of objections to TSP reflects a distrust of the federal bureaucracy, a feeling that there's no local control, and the stark realities of today's comm center budgets.
"There was very little input from local government or state government when this national rule took place," says Wallace Madewell, Executive Director of the Memphis/Shelby County 9-1-1 District, and chair of NENA's National Issues Committee. "And yet we were lumped in to what had been a federal program."
Liability is also a big issue, Madewell says. "If we didn't avail ourselves of the TSP service knowing that it was out there, and if our systems were not restored, could there by some liability," he asks.
Two attorneys general, in Texas and South Carolina, have concluded there would be no additional liability. But until the issue is tested in the courts, no one knows for sure.
Larry Barnes of Southwestern Bell explains the telephone companies' position by saying, "Essentially, we want to do what is right, but we're having a very difficult time determining exactly what that is."
Without firm guidelines and operating in the middle of criticism, they are trying not to appear as the bad guys. "We're trying to be neutral in this," Barnes says. Critics say the telephone companies see TSP as a new market and a way to increase revenues.
Amid those charges, Barnes says, "We're not promoting the service. We'd like to inform all the potential customers, as much as we possibly can, as to what exactly Southwestern Bell will be providing." Then, Barnes says, the agencies must make up their minds if TSP has value for them or not.
In fact, some telephone companies, including BellSouth, have folded TSP into their standard 9-1-1 services, all for the same price they're charging now. Nevertheless, "be wary" of phone companies selling TSP, Madewell says. "Some are using this as a sales opportunity."
The Cost
"Yes, it ultimately has to come down to dollars," says Vaughn of the FCC. And this is the primary objection to TSP.
"Excellence, including preparedness, comes with a price," Vaughn told a NENA panel exploring TSP. It was relatively simple for the FCC arrive at the concept that, "the entity that causes the cost should bear the cost," says Vaughn. The commission also felt that a system without costs was open to abuse. "If there were no direct costs to bear, every business or every agency would apply for priority status."
On the tail of a recession, budgets are already straining just to sustain on-going operations. And when compared to the current cost and service already provided for emergency lines, critics wonder how better TSP service will be for the additional money they'll be paying.
Southwestern Bell's Barnes says, "Essentially, if a trouble report comes in on a 9-1-1 circuit, a code pops up at the test center, the clerk recognizes it for what it is, immediately hand-walks it to the supervisor." The supervisor picks up the phone, immediately calls the PSAP, and then begins the repair process. "And folks, it doesn't get much better than that," Barnes says.
Barnes recalls hurricanes in Houston, then wonders about the TSP restoration guidelines. "Under emergency conditions, sometimes they loose any meaning. What you repair is what you can with the resources you have," Barnes says.
"It's wonderful to have guidelines, and it gives you a place to go. But there is no absolute recipe for restoring all this (phone equipment) under true emergency conditions," Barnes says.
Early tariffs from the Bell companies include a so-called "non-recurring" per-line charge and a monthly, per-line fee. For example, Southwestern Bell's tariff application lists a $65 non-recurring charge and about $4.00 per line per month. In California, estimates put the statewide TSP costs at $2.5 million initially and $38,000 a month. Overall, TSP might increase an agency's telecommunications budget by five percent.
What does this money pay for? George Richardson, a systems expert for Bell Atlantic, says there is more than just the administrative costs of providing the service. The phone companies have already spent millions of dollars to modify computer software to accommodate TSP. There are over 20 separate computer systems in each of the 22 local Bell companies that required modification and recoding, he says.
"That money's already been spent by the phone company," Richardson says. "We didn't have a choice whether we were going to buy into this or not. The law changed and we reacted. We have done the work to make this thing work."
How Will It Work?
Paul Mason, FEMA's coordinator for implementation of the TSP system, says that all agencies that join will be treated equally. That is, federal, state, county and local agencies will receive treatment based solely on the priority assigned to their lines, not on their government status.
But a qualifying private company with more financial resources could afford to "buy" more TSP services than a budget-strapped city or county. When a disaster strikes, the private company's restoration would receive more attention, if not a higher priority.
"I think it behooves everyone to determine cost versus liability--what it's going to cost you to join, what it's going to cost you if you don't join," Mason says. And that points out other objections to the way TSP is implemented.
TSP supersedes all existing emergency restoration plans that local telephone companies and public safety agencies have arranged. So even if you're receiving priority treatment now, TSP will actually lower that priority unless you join the club.
Your choice: join the club and compete for emergency restoration with other TSP members, or don't join and compete with the butcher, the baker and the candlestick maker.
This creates an incentive to join TSP and designate a number of lines as priority, even if your agency can't afford the cost and you're already getting superior service on your emergency telephone lines.
George Richardson of Bell Atlantic points out another aspect of TSP that potential customers may not understand.
"Preemption allows the phone companies to disconnect current service for a customer and reuse those facilities or equipment for a TSP customer," Richardson explains. Often preemption will occur within the same customer's lines or services.
But if two public safety agencies have service interruptions covered by TSP, one agency's lines could be taken to restore the service of another. Richardson points out that, "We do not have to get prior consent of the customer whose service is taken. And the telephone company will be the company who's picking which service gets preempted."
What's Being Done?
When TSP was originally proposed, the FCC sent a request for comments around to public safety and communication organizations nationwide. Only 14 agencies reportedly replied, and most of those were telephone companies.
NENA's Madewell says he knows of no one in the emergency service family who saw the request and who submitted comments. "I can find no one that was ever notified."
Why didn't the FCC directly approach NENA, a national group directly involved in emergency communications? "Good question," says Madewell. "Ask the FCC. They say they fulfilled the federal requirements," and published the proposal sufficiently.
It wasn't until early 1991 that NENA members meeting with federal agency representatives in Salt Lake City realized how much TSP would cost and what it really meant.
Then, at the June 1991 NENA national conference in Dallas, a TSP panel brought together all the involved federal agencies, phone company officials and an audience eager to find out how TSP would work.
Thera Bradshaw, Chairperson of the APCO 911 Committee, moderated the panel and said, "This may the first time that all these folks have been in one room at the same time on this particular issue."
Instead of answers, the audience heard panelists raising questions about how TSP would work. Panelist Larry Barnes of Southwestern Bell expressed it best when he told the audience, "What I'd really like to do immediately after making this speech is to go into the audience and ask these guys a lot of questions, because I have some myself."
Jerry Vaughn revealed that NENA could file a petition for rehearing on the matter, which came as a surprise to all the members. Up to then, everyone believed that TSP was unchangeable.
Vaughn said it was unusual for the FCC to rescind or revise actions already passed. But he felt an organized proposal for revisions to the TSP regulations would have a chance of acceptance by the FCC.
As a result of that panel, the NENA Executive Board drafted a petition asking the FCC to rescind the implementation of TSP. The petition claimed that TSP was "flawed" in the areas of budget, liability, legal effect, potential conflicts and implementation.
NENA also formed an ad hoc committee and invited APCO and others in the public safety communications field to join and meet with the TSP Oversight Committee, which administers the program.
In December, the ad hoc committee met with a sub-committee of the Oversight Committee, and focused on nine issues considered to be critical to TSP's success. Those issues are will be presented to the full Oversight Committee in late February.
Madewell says that, in the meantime, TSP will be a major issue at the NENA convention in Orlando in June and the Telecommunications Association in September.
After all the meetings and panels, will TSP be changing? "I don't know. I can't give you an answer," Madewell says, reflecting the uncertainty in dealing with the federal government.
Eventually, Madewell says, if NENA isn't able to make some reforms through the TSP Oversight Committee, NENA will seek relief, "probably with legislative intervention or an appeal directly to the FCC to have state and local government removed from TSP."
"I'd rather this process work hand-in-hand with the TSP Oversight Committee, if they'll recognize our problems and give us some relief," Madewell says.
For now, "My recommendation is that nobody use TSP," says Madewell. Until further changes are hammered out with the TSP Oversight Committee, Madewell's recommendation to everyone is, "If they have satisfactory restoration with their local telephone company, then I would not suggest that they even consider TSP at all."
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