A Report on Technical and Operational Issues Impacting
`The Provision of Wireless Enhanced 911 Services
`
`Prepared for the
`
`Federal Communications Commission
`
`By
`
`Dale N. Hatfield
`Telecommunications Consultant
`
`Apple Inc. 1016
`U.S. Patent No. 9,445,251
`
`

`

`Executive Summary
`
`
`The purpose of this report is to convey the results of an independent inquiry into the
`technical and operational issues affecting the deployment of wireless Enhanced 911
`(“E911”) services in the United States. The inquiry was carried out by the author on
`behalf of the Federal Communications Commission (“Commission”) over a six month
`period beginning on April 15, 2002.
`
`Before turning to my principal findings and recommendations, I would like to offer three
`preliminary comments:
`
`First, the importance of 911 as the Nation’s universal emergency assistance number has
`long been recognized. That importance was acknowledged with the passage of the
`Wireless Communications and Public Safety Act of 1999. Subsequent developments,
`e.g., the tragic events of September 11, 2001 and growing dependence on wireless
`networks, serve to further emphasize the importance of E911 in general, and wireless
`E911 in particular, to the safety of life and property and homeland security. The
`automatic provision of location information with wireline and wireless 911 calls – i.e.,
`E911” – is critical to those emergency services.
`
`Second, over the past several years, the center of attention of the industry has clearly
`shifted from discovering, developing, evaluating and selecting the ways of locating
`mobile units in wireless systems to integrating the location information into the existing
`E911 system. I regard this as very good news as it indicates that there is no longer any
`real disagreement regarding the technical feasibility of providing wireless E911 to the
`approximately 130 million wireless subscribers in the United States. The challenge now
`is to successfully complete the implementation of wireless E911, a process that has really
`just begun.
`
`Third, one over-arching issue that immediately emerged in my inquiry is that the existing
`wireline E911 infrastructure, while generally reliable, is seriously antiquated. Indeed, it
`turns out that the existing wireline E911 infrastructure is built upon not only an outdated
`technology, but one that was originally designed for an entirely different purpose. It is an
`analog technology in an overwhelmingly digital world. Yet it is a critical building block
`in the implementation of wireless E911.
`
`From a national policy perspective, this latter observation is troubling for a number of
`reasons. It is troubling because it means that the additional network elements and
`functionalities necessary to handle the increasing volume of wireless E911 calls are being
`built upon a platform or foundation that has serious limitations in terms of speed,
`scalability, and adaptability. Additionally, it is troubling because these limitations not
`only burden the development of wireless E911 services, but they will also constrain our
`ability to extend E911 access to a rapidly growing number of non-traditional devices
`(e.g., PDAs), systems (e.g., telematics) and networks (e.g., voice networks that employ
`Voice-over-the-Internet Protocol -- VoIP). Finally, it is troubling because of uncertainty
`surrounding the willingness and ability of Public Safety Answering Points (“PSAPs”) to
`
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`pay for wireless E911, let alone the other, long term upgrades to the local exchange
`carriers’ networks and their own customer premises equipment necessary to provide
`E911 access to these emerging devices, systems, and networks.
`
`With respect to the specific technical and operational issues relating to the
`implementation of wireless E911 services, I have reached six principal findings or
`conclusions.
`
` •
`
` First, I find that there is a strong Federal interest in the implementation of wireless
`E911 and that that interest has increased as a result of the tragic events of September
`11, 2001. I further conclude that existing Federal programs to encourage the
`implementation are fragmented and that the most visible program, while very
`commendable, does not totally reflect the broader implications of wireless E911 for
`the safety of life and property and homeland security. My concern about this issue is
`compounded by the fact that a number of states have failed to establish a state-wide
`coordination body and/or appropriate cost recovery mechanisms.
`
`• Second, I find that the deployment of wireless E911 in the U.S. is an extremely
`complex undertaking and that a variety of critical technical and operational choices –
`including critical decisions relating to network architectures – must be made to ensure
`the reliable and seamless E911 system contemplated by Congress when it passed the
`911 Act. Because of the total number of stakeholders involved, the complexity of the
`inter-relationships among the stakeholders, and the incentives and constraints on
`those stakeholders, I conclude that an unusually high degree of coordination and
`cooperation among public and private entities will be required if that vision is to be
`realized.
`
` Third, in light of my second finding, I conclude that for the efficient, timely, and cost-
`effective deployment of wireless E911, there is a need for increased coordination
`among stakeholder groups in three areas: overall systems engineering,
`implementation/project management and the development and adoption of standards.
`
` Fourth, unless corrective steps are taken, I find that the rollout of wireless E911
`services will continue to be constrained by what I refer to in shorthand as PSAP
`“fatigue,” the lack of cost recovery and other funding mechanisms, and the lack of a
`“champion” within the Federal government. I also conclude that, even when good
`faith efforts are made on all sides, PSAP awareness and readiness remains a potential
`detriment to the rapid and efficient rollout of wireless E911 services.
`
` Fifth, I find that the incumbent local exchange carriers (“ILECs”) play a critical role
`in the deployment of wireless E911 service in the reliable and seamless manner
`contemplated by Congress when it passed 911 Act. I also find that, in the past, the
`ILECs were not fully included in the development of wireless E911 and that their
`responsibilities for supporting wireless E911 deployment were not well defined. I
`further conclude that the prices charged by the ILECs for the cost of upgrading their
`existing wireline E911 system to support wireless E911 may impede the rollout of the
`
`iii
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` •
`
` •
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` •
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`

`emergency service, especially in those states that do not have a cost recovery
`mechanism in place.
`
` Sixth, I find that (a) the lack of well-accepted, standardized tests for determining
`whether the various position location systems selected by the wireless carriers comply
`with the accuracy requirements set forth in the Commission’s rules, (b) uncertainty
`over the interaction between delay and accuracy in obtaining position location
`information, and (c) uncertainty as to the area over which the test results can be
`averaged may cause delay in the deployment, acceptance and certification of wireless
`E911 systems.
`
` The Commission should work more closely with other Federal agencies to ensure that
`accurate location information for emergency calls is gathered, delivered, accepted and
`made available for use in the dispatching of first responders. I further recommend
`that the Commission suggest to the Administration that a “National 911 Program
`Office” be established within the proposed Department of Homeland Security to
`coordinate with, and be a resource for, local and state public safety first responders
`and other stakeholders.
`
` Because of the importance of E911 to the safety of life and property and to homeland
`security and the critical nature of the network architecture and industry structure
`choices being made, and because of the overall complexity of the situation, I
`recommend that the Commission maintain or even increase its oversight of the rollout
`of wireless E911 services in the U.S. over the next several years.
`
`
`
`In order to respond to the need for increased coordination in the rollout of wireless
`E911 and the evolution of E911 more generally, I recommend that the Commission
`(a) establish, or cause to have established, an advisory committee that would address
`the technical framework for the further development and evolution of E911 systems
`and services, (b) continue to urge the creation of organizations at the state, regional
`and local levels of government that can act as a coordinating body in the rollout of
`wireless E911 services, (c) encourage the creation of a national level clearinghouse to
`the collect, store, and disseminate status information on the rollout of wireless E911,
`and (d) charge the advisory committee recommended above with conducting an
`overall review of the standards situation as related to wireless E911 while continuing
`to encourage industry-based voluntary standards activities.
`
` Because PSAPs are on the frontlines in the Nation’s defense against the threat of
`terrorism as well as in responding to more conventional emergencies, I recommend
`that the Commission actively coordinate with and support the U.S. Department of
`Transportation’s Wireless E911 Initiative and other formal and informal efforts at all
`levels of government to educate state and local governments and PSAPs on the
`
`iv
`
` •
`
` •
`
` •
`
` •
`
` •
`
`
`In order to resolve some of the issues and concerns raised during the course of my
`inquiry, I have included a number of recommendations. These recommendations include
`suggestions that:
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`

`

`benefits and importance of wireless E911 services. On a longer term basis, I would
`recommend that the National E911 Program Office (whose creation I urged above)
`take on the role of educating and advocating for PSAPs at the Federal level of
`government. I also recommend that the Commission continue to support the efforts
`of the Emergency Services Interconnection Forum (jointly sponsored by the National
`Emergency Number Association and the Alliance for Telecommunications Industry
`Solutions) to address the issue of PSAP readiness. In the text of the full report, I also
`suggest the possibility of some form of an independent third party process for
`certifying PSAP readiness.
`
` During the period of my inquiry, the Commission requested that the largest ILECs
`provide certain critical information regarding their readiness to carry out their role in
`wireless E911 deployment and committed itself to monitoring the situation to see
`whether additional obligations are necessary. This action is consistent with my
`recommendation concerning the creation of national clearinghouse of such
`information. I further recommend that the Commission work closely with individual
`state regulatory commissions and their association, the National Association of
`Regulatory Utility Commissioners, in resolving issues relating to ILEC cost recovery
`and pricing.
`
` The Commission should urge the stakeholders to cooperatively develop industry-wide
`procedures for testing and certification (and recertification) of wireless E911 to
`ensure that they meet (and continue to meet) the accuracy requirements specified in
`the Commission’s rules.
`
` •
`
` •
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Certain other issues were raised during the course of my inquiry. These other issues
`included concerns about the need for end-to-end testing of wireless E911 systems,
`conveying confidence/uncertainty information associated with position determination and
`routing choices, accommodating new requirements and requirement “creep,” the impact
`of future technological developments, consumer expectations, the implications of
`commercial location based services, and the need for a more adaptable regulatory
`approach. Recommendations concerning these issues and more details regarding the
`recommendations recorded above are contained in the main body of the report.
`
`
`v
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`

`
`
`Acknowledgements and Disclaimer
`
`
`The author would like to thank Leon Jackler, Attorney Advisor in the Commercial
`Wireless Division of the Wireless Telecommunications Bureau at the Federal
`Communications for his tireless help and wise counsel in the conduct of this inquiry and
`in the preparation of this report. The author would also like to acknowledge the help of
`his research assistant, Sukumar Dwarkanath, in carrying out the study.
`
`The analyses and opinions contained in this report are strictly those of the author and do not
`necessarily reflect the views of the University of Colorado or any other institution with
`which the author is affiliated.
`
`vi
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`

`
`
`1
`
`Table of Contents
`Introduction ................................................................................................................ 1
`1.1 Background............................................................................................................ 1
`1.2 Purpose of the Inquiry and Report......................................................................... 1
`1.3 Methodology.......................................................................................................... 1
`1.4 Timeliness of the Recommendations..................................................................... 2
`1.5 Organization of the Balance of the Report ............................................................ 2
`2 History and Overall Status........................................................................................ 3
`2.1 History of Wireline 911/E911 Systems................................................................. 3
`2.2 History of Wireless E911 ...................................................................................... 6
`2.3 Overall Status of Wireless E911.......................................................................... 12
`3 Principal Findings and Recommendations ............................................................ 15
`3.1
`Importance of E911 in General and Wireless E911 in Particular to the Safety of
`Life and Property and Homeland Security .................................................................... 15
`3.2 Complexity of the Task Facing the Nation.......................................................... 18
`3.3 Need for Increased Coordination Among Stakeholder Group ............................ 21
`3.4 PSAP Readiness .................................................................................................. 28
`3.5 Local Exchange Carrier Readiness...................................................................... 32
`3.6 Lack of Well-Defined, Standardized Tests for Compliance................................ 34
`4 Other Issues Raised.................................................................................................. 37
`4.1 Need for End-to-End Testing .............................................................................. 37
`4.2 Confidence/Uncertainty and Routing Issues ....................................................... 38
`4.3 Accommodating New Requirements and Requirements “Creep”....................... 40
`4.4
`Impact of Future Technological Developments .................................................. 41
`4.5 Consumer Expectations ....................................................................................... 42
`4.6
`Implications of Commercial Location Based Services........................................ 43
`4.7 Need for a More Adaptable Regulatory Approach.............................................. 44
`
`
`
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`
`
`1 Introduction
`
`
`1.1 Background
`
`On November 20, 2001, the Federal Communications Commission (“FCC” or “the
`Commission”) issued a news release announcing that the author of this report, Dale
`Hatfield, had been retained by the agency to lead an inquiry into the technical and
`operational issues affecting the deployment of Wireless Enhanced 911 Services.1
`Subsequently, on March 5, 2002, the Wireless Telecommunications Bureau (“WTB”) of
`the Federal Communications Commission (“FCC” or “the Commission”) released a
`Public Notice announcing the details of the inquiry.2 In doing so, the Commission
`opened a separate docket for the inquiry, WT Docket No. 02-46.
`
`1.2 Purpose of the Inquiry and Report
`
`As described in the Public Notice, the purpose of the inquiry was to identify technical and
`operational problems in wireless E911 deployment. After identifying the entities
`involved and reviewing certain claims regarding the barriers in deploying wireless E911,
`the Public Notice more specifically laid out the purpose of the inquiry as follows:
`
`
`The purpose of this inquiry is to obtain an expert, informed, unbiased assessment
`of these and other technical and operational issues that impact wireless E911
`deployment. We anticipate that the scope of the inquiry will be as broad as
`appropriate to perform that assessment. Information will be gathered and
`evaluated from many sources, including from technology vendors, network
`equipment and handset manufacturers, carriers, the public safety community, and
`other knowledgeable sources concerning technology standards issues,
`development of hardware and software, and supply conditions. This inquiry also
`will address the provisioning by LECs of the facilities and equipment necessary to
`receive and utilize E911 data elements. The focus of the inquiry will be on the
`future of wireless E911 deployment including any obstacles to deployment and
`steps that might be taken to overcome or minimize them.
`
`The purpose of this report is to convey the results of the inquiry that I carried out on
`behalf of the Commission.
`
`1.3 Methodology
`
`This inquiry began with an initial meeting of the principal stakeholders on April 15, 2002
`at the Commission’s offices in Washington, DC. Over the next 100 days or so, further
`
`
`1 News Release, “FCC Announces Dale Hatfield to Lead Inquiry of Technical and Operational Issues
`Affecting Deployment of Wireless Enhanced 911 Services, rel. Nov. 20, 2001.
`
` Public Notice, “Wireless Bureau Announces Details of Inquiry on Technical and Operational Wireless
`E911 Issues, DA 02-523, rel. March 5, 2002.
`
`
` 2
`
`1
`
`

`

`
`
`meetings were held with individuals and representatives of these stakeholder groups. At
`the initial meeting and subsequent individual meetings, participants were asked to
`identify the major technical and operational obstacles to the successful and timely rollout
`of wireless E911 systems. In accordance with the Public Notice, emphasis was placed
`upon those obstacles that remained rather than on rehashing issues that may have arisen
`in the past but that are no longer a major impediment. Particular attention was paid to
`identifying steps that could be taken by the Commission—or by stakeholder groups
`acting on a voluntary basis—that would minimize the prospects for litigation or the need
`for time-consuming Commission rulings.
`
`In addition to being asked to identify the obstacles and to suggest steps that could be
`taken to facilitate the rollout of wireless E911 systems, participants were also asked to
`identify other organizations or individuals that might have information to contribute to
`the process. In-person or telephone interviews were then arranged with many of the
`groups or organizations so identified. Finally, an on-line search for relevant materials
`was conducted. This included a search for relevant “White Papers” and other materials
`published by vendors and other industry groups as well as a search for professional
`journal articles on the topic of E911. Over a roughly 100-day period stretching from
`April 15, 2002, until the latter part of July 2002, dozens of separate interviews were
`conducted involving well over one hundred individuals.
`
`
`1.4 Timeliness of the Recommendations
`
`Given the importance of wireless E911 implementation to the nation, it is not surprising
`that the Commission and the various stakeholder groups have pressed forward to resolve
`some of the issues described in this report. Consequently, some of the recommendations
`contained herein may have been overtaken by events. Nevertheless, it is my hope that the
`descriptions and analyses provided will prove to be useful background as the rollout of
`wireless E911 proceeds.
`
`1.5 Organization of the Balance of the Report
`
`The balance of this report is divided into three sections. Section 2 provides basic
`background on both wireline and wireless 911 systems and a brief description of the
`current status of wireless E911 deployment. Section 3 contains the principal findings and
`recommendations of the inquiry. It is divided into six subsections corresponding to each
`principal conclusion and the associated recommendation. Section 4 contains descriptions
`of other issues that were raised during the course of the inquiry along with observations
`or recommendations concerning them. A brief biographical sketch of the author is
`attached as an appendix.
`
`2
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`

`
`
`
`
`
`2 History and Overall Status
`
`
`2.1 History of Wireline 911/E911 Systems
`
`It is widely agreed that the first-ever 911 call was placed in Haleyville, Alabama in 1968.
`In the early implementations of wireline 911, the processor associated with the switching
`machine in the local telephone company Central Office or End Office interpreted or
`translated the dialed 9-1-1 sequence and routed the call to a single Public Safety
`Answering Point (“PSAP”).3 A PSAP is a facility equipped and staffed to receive 911
`calls.4
`
`While this arrangement assured that a subscriber dialing the easily remembered
`abbreviated dialing sequence 9-1-1 would be connected to a PSAP and had the advantage
`of requiring little modification or additions to the LEC’s network, it suffered from a
`number of limitations. First, it provided no automatic means of identifying the origin of
`the call (e.g., the calling number) and thus no way for the PSAP operator to identify the
`caller or a way to reach the caller in the event the call was disconnected (callback).
`Without knowing the origin of the call, there was also no way of knowing the location of
`the caller. This meant that the PSAP operator had to waste valuable time eliciting this
`information from the caller with no assurance that the caller would, in fact, be able to
`convey the information accurately. Second, the geographic area served by a telephone
`company End Office was (and is) unlikely to match the relevant political boundaries. For
`example, in some cases, there may be several political jurisdictions within the area served
`by the switching machines in a single End Office and, in other cases, one large
`jurisdiction may encompass the geographic areas served by multiple End Offices. These
`two situations complicate the problem of correctly and efficiently delivering the call to
`the proper PSAP.
`
`The first limitation was overcome by introduction of Automatic Number Identification
`(“ANI”). It allowed the delivery of the calling party’s telephone number along with the
`emergency call itself. The calling number is an example of control information and it can
`be carried on the signaling network (rather than the associated “conversation” or
`information network) if it is capable of doing so.5 At the time basic 911 services were
`
`
`3 The discussion which follows draws directly from an undated hardcopy of a presentation entitled “9-1-1
`Tutorial” and presented by Billy Ragsdale, Bob Gojanovich, Barb Thornburg, and Roger Hixson at a
`NENA Technical Development Conference.
`
` 4
`
` 5
`
` National Emergency Number Association (NENA), NENA Master Glossary of 9-1-1 Terminology,
`NENA-01—002, March 1998. http://www.nena.org/9-1-1TechStandards/Standards_PDF/NENA_01-
`002.pdf. (NENA Glossary)
`
` Besides conveying the subscriber’s actual telephone message or conversation, a telephone network must
`also convey other information associated with setting up, disconnecting, and otherwise controlling the call
`itself. The transmission and reception of such control information between the customer and the network
`or between elements (e.g., switching machines) interior to the network is called signaling. Signaling is
`
`3
`
`

`

`
`
`introduced, the Public Switched Telephone Network (“PSTN”) did not typically carry the
`calling number in interoffice signaling and Caller Identification services were not offered.
`However, the calling number was needed to properly bill for long distance toll calls and a
`special signaling system known as Centralized Automatic Message Accounting
`(“CAMA”) was devised for this (billing) purpose. This system, CAMA, was adapted to
`deliver the calling party’s telephone number to the PSAP. CAMA uses in-band, analog
`MF signaling and, as a consequence, suffers from significant limitations. The limitations
`of these legacy systems continue to hinder the provision of efficient wireline 911 services
`and, as we will see later, to haunt the rollout of wireless E911 systems, the subject of this
`report.
`
`Since the local telephone company must, by necessity, be able to associate a particular
`telephone line and telephone number with the subscriber’s name and address, it is
`possible for the network to deliver this information to the PSAP as well. The database
`that contains the necessary information is known as the Automatic Location
`Identification (“ALI”) database. If the necessary modernization has occurred, it is easy to
`see that the processor in the End Office could query the ALI database and have delivered
`back the name and address to the PSAP using modern digital, common channel signaling
`techniques. Because of constraints imposed by the legacy analog CAMA system and
`legacy equipment employed in the equipment at the PSAP, this technique has apparently
`not been widely used. Instead, the equipment at the PSAP – known as Customer
`Premises Equipment or “CPE” – is connected to the ALI database over a separate data
`circuit.6 When an incoming call is received at the PSAP, the CPE uses the calling
`number delivered over the CAMA network to compose and send a query to the ALI
`database over this data circuit. The software in the ALI database then returns the name
`and address of the caller thus greatly facilitating the handling of the emergency call.
`
`Recall that the second limitation of the original basic 911 service is that a single PSAP
`may be responsible for a geographic area that encompasses the areas served by multiple
`telephone company End Offices or a single End Office may serve an area that
`encompasses multiple political jurisdictions. With regard to the former, just as it is often
`uneconomical to directly connect every End Office to every other End Office or
`Interexchange Carrier (“IXC”) Point-of-Presence (“POP”) for the carriage of ordinary
`telephone calls, it is often uneconomical to directly connect all end offices in a large
`jurisdiction to a single PSAP. Instead, the emergency calls from a number of End Offices
`are concentrated at a Tandem Office and then delivered over a single group of trunks to
`
`
`necessary for the establishment and control of connections – including 911 calls – through the network
`(e.g., the PSTN) or collection of networks (e.g., a wireless cellular network and the PSTN). It is separate
`and distinct from the telephone message or conversation itself. An example of signaling information would
`be the telephone number (network address) of the called party or an indication that the called party has
`“gone off hook” or answered the call. Control information is needed, for example, to route the call and to
`properly bill for it. The signaling network is sometimes referred to as the nervous system of the telephone
`network for the critical role it plays in its functioning.
`
` 6
`
` Customer Premises Equipment or CPE is a general term for the terminal equipment installed on the
`customer’s premises that is connected to the telephone network. In the context of 911, the term CPE
`normally refers to the equipment used by the PSAP to receive and process 911 calls.
`
`4
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`

`

`
`
`the PSAP. If, as in the case of the latter, there are multiple PSAPs in areas served by the
`End Offices subtending the Tandem Office, then some means must be provided to route
`the 911 calls to the proper PSAP. This additional functionality performed at the Tandem
`Office – referred to as Selective Routing – routes the 911 call to the proper PSAP based
`upon the caller’s location.
`
`The Selective Routing functionality is what distinguishes Enhanced 911 (“E911”) from
`Basic 911. In other words, Basic 911 may or may not involve the delivery of number
`(ANI) and name and location (ALI) information. E911 includes the necessary network
`switching, database and CPE elements for delivering the voice call to the proper PSAP
`along with the associated ANI and ALI information. The switching machine that
`provides the tandem switching of 911 calls is known as the E911 Control Office.7 Note
`that two things must happen in E911: the voice call must be routed to the correct PSAP –
`the one serving the geographic area where the caller is located – and the location (i.e.,
`ALI) information must be delivered to the PSAP. In order to accomplish the first, the
`E911 Control Office must have access to a database, referred to as the Selective Router
`Data Base. The data base and associated logic maps the telephone numbers served by its
`subtending End Offices to the proper PSAP. This, in turn, requires the creation of a
`database called the Master Street Address Guide that links the street address associated
`with a telephone number to a particular PSAP. So to summarize, with E911, the
`emergency call – the conversation – is delivered via the End Office and E911 Control
`(Tandem) Office to the proper PSAP along with the ANI information. The proper PSAP
`is determined by the Selective Router through a query to the Selective Router Data Base.
`The CPE at the PSAP then utilizes the data link to the ALI database to retrieve the name
`and address information associated with the telephone number. Note that, as before,
`these functions could be performed more efficiently with modern digital, common
`channel signaling techniques that, among other things, eliminate many of the constraints
`associated with CAMA signaling on the trunks between the E911 Control
`Office/Selective Router and the PSAP.
`
`According to the NENA Report Card to the Nation, there are approximately 190 million
`calls to 911 each year.8 According to the same report, wireline 911 service is available to
`97.9 percent of the U.S. population. However, the report goes on to note that there are
`over 200 counties in the United States that are without even basic 911 services. Among
`the population currently receiving service, the report does not distinguish between Basic
`911 and Enhanced 911 services.
`
`
`
`7 NENA Glossary.
`
` 8
`
` National Emergency Number Association, “NENA Report Card to the Nation: The Effectiveness,
`Accessibility and Future of America’s 9-1-1 Service,” 2001, p. 18 (available at http://www.nena9-1-
`1.org/initiatives/RCN/rcn_final.pdf) (NENA Report Card to the Nation).
`
`5
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`

`
`
`2.2 History of Wireless E911
`
`2.2.1 Early Regulatory Developments9
`
`The regulatory interest in extending E911 services to wireless mobile subscribers started
`when the Commission began developing rules for the broadband Personal
`Communications Service (“PCS”) in 1993. In that proceeding, the Commission urged the
`industry and standards setting bodies to direct their attention to E911 access, including
`the automatic location of callers. In 1994, the Association of Public-Safety
`Communications Officials (“APCO”), the National Emergency Number Association
`(“NENA”), the National Association of State Nine One One Administrators (“NASNA”),
`and the Personal Communications Industry Association issued an “Emergency Access
`Position Paper” which they filed as an ex parte filing in the PCS proceeding. Later in
`1994, representatives of the wireless telecommunications community and emergency
`service and public safety community convened a Joint Experts Meeting (JEM) which
`