HATFIELD CALLS FOR NATIONAL 911 OFFICE, CITES ‘PSAP FATIGUE’

More broadly, Hatfield stressed complexity of overlapping issues that had stalled rollout in some cases, including chronic underfunding and need for increased coordination in areas such as systems engineering and standards development. He recommended that national 911 program office be created in proposed Dept. of Homeland Security, that FCC “maintain or even increase” oversight over wireless E911 rollout and that it foster creation of national clearinghouse on wireless E911 deployment.

“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,” report said. It said that signaled that there no longer was “real disagreement” on technical feasibility of providing wireless E911 but that remaining challenge was implementation, “a process that has really just begun.” FCC named Hatfield in Nov. to head inquiry into technical and operational issues in wireless E911 deployment. He was tasked to look into issues such as carrier claims that network equipment and location- capable handsets weren’t available in time to comply with Commission’s original Phase 2 deployment deadlines and to evaluate PSAP readiness and status of LEC network upgrades to provide automatic location information to public safety answering points (PSAPs).

Among Hatfield’s conclusions was that FCC should recommend to Administration creation of national 911 program office in Homeland Security Dept. to provide coordination on those issues for local and state public safety first responders. Besides funding and other challenges that face public safety community, he said another concern “involves the lack of a PSAP advocate or ‘champion’ at the federal level of government.” Hatfield recommended that FCC: (1) Create advisory committee on technical framework for development of E911 systems, including standards. (2) Coordinate with Transportation Dept.’s E911 initiative and other efforts to reach out to state and local govts. on those services. (3) Work closely with state PUCs and NARUC to resolve issues related to LEC cost recovery and pricing. (4) Encourage development of industrywide procedures for testing and certifying wireless E911 systems to ensure they met accuracy requirements of FCC rules. He stressed need for end-to-end testing of wireless E911 systems, including information on confidence associated with determinations of caller position. FCC is seeking comments on report by Nov. 15, replies Dec. 3.

Hatfield also reported findings on E911 deployment and interlocking challenges that faced PSAPs, wireless carriers, LECs and federal officials. Report concluded that although there was strong federal interest in wireless E911 implementation, especially after Sept. 11, existing programs to encourage implementation were fragmented. “My concern about this issue is compounded by the fact that a number of states have failed to establish a statewide coordination body and/or appropriate cost recovery mechanisms,” Hatfield wrote. Citing complexity of interrelationships among various E911 stakeholders, he said critical technical and operational decisions, including those related to network infrastructure, still had to be made. “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,” he said. “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.”

On issue of ILEC readiness, which some public safety groups and carriers have called “missing link” in E911 rollouts, Hatfield said that in past ILECs hadn’t been “fully included” in development of wireless E911 and their responsibilities for supporting deployment weren’t well defined. But he added: “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 emergency service, especially in those states that do not have a cost- recovery mechanism in place.” Hatfield said that rather than drawing any conclusions on whether some pricing or tariffs proposed for cost recovery by LECs were justified, he was alerting FCC “to this potential problem which could be especially severe in those states that do not have a cost- recovery program in place.”

Report described “PSAP fatigue” as having to do with handling much education and coordination on volunteer basis. In some cases, Hatfield said he heard concerns about limited extent to which larger PSAPs in state could help out smaller, underfunded colleagues. “Clearly PSAP fatigue could be relieved to a large part if funding could be provided to allow additional personnel to be hired or consultants or other nonpermanent personnel to be retained to assist in the process,” report said, saying FCC had asked Hatfield to look at technical and operational issues, not financing per se. But Hatfield said fatigue problem pointed to larger issue of underfunding. He vetted allegations that some PSAPs had pulled back from requesting wireless E911 once full costs became known. Without adequate funding, “the rollout of wireless E911 will be delayed, perhaps significantly,” he said. Many states have legislation to fund cost recovery for facilities and equipment needed for PSAPs to process E911 data, he said. “However, a number of major states have failed to adopt legislation providing for such cost-recovery systems and, even more troubling, in some states, E911 cost- recovery funds have been used for other purposes.”

ComCare Exec. Dir. David Aylward said among surprises of report was strong wording of concerns on existing wireline E911 system, issue that has been concern of his group on E911 front. Such concerns haven’t been laid out so strongly in previous E911 reports, he noted. Point is that crash data that can be delivered via voice over IP networks or data- based latitude-longitude information about caller location run into problems on older, analog-based infrastructure. “The interlink between the LECs and the PSAPs doesn’t handle data,” he said.

On overarching issue of aged wireline E911 infrastructure, Hatfield said rollout of that service on wireline side began in late 1960s, with some in industry stressing that it hadn’t updated its analog emphasis. “While the nation should be forever grateful to the engineers and others who designed the original 911 system, it must be recognized that it was -- and remains -- somewhat of a ‘kluge,'” he wrote. “In the ensuing decades, the technology that they so cleverly relied upon has been overtaken by such developments as digital transmission, fiber optic rings, digital common channel signaling.” Although industry has made significant progress in developing technology to integrate wireless subscriber location information into existing E911 system, Hatfield said “it has the appearance of patching into an existing system that has serious limitations going forward.” That doesn’t mean resulting system necessarily will be unreliable, he said. But he said it might have to be reinvented to accommodate changes such as new technology. “Modernization of the underlying infrastructure has cost and funding implications that go beyond the cost and funding issues associated with the implementation of wireless E911.”

Hatfield acknowledged that readiness of Enhanced Observed Time Difference of Arrival (E-OTD) location technology planned for use by GSM carriers was common thread that ran through his discussions while preparing report. AT&T Wireless recently said it would continue to test E-OTD but was eyeing alternative technology that it already used for its TDMA network (CD Oct 10 p2). Cingular Wireless also recently told FCC it had suspended shipments of E-OTD equipment (CD Oct 4 p2). Hatfield said some stakeholders said interest in E-OTD as position location technology had origins in Europe, where GSM is primary network technology. Some argue that has implications for implementing E-OTD in U.S. because density of base station sites often is greater in Europe than in U.S. “No doubt some of these allegations regarding the ultimate ability for the E-OTD technology to meet the Commission’s accuracy requirements were motivated by intense commercial rivalry in a market that has some characteristics of a ‘winner-takes-all’ situation,” Hatfield said. He said quarterly E911 reports filed by carriers planning to use E-OTD technology “reflect to a greater or lesser degree their own uncertainty as to the ultimate ability of E-OTD to meet the Commission’s accuracy standards in the required time frame.” As result, he said, FCC should “closely monitor” evolution of E-OTD development “during this critical final development and testing phase lest the agency be forced -- as a practical matter given the size of the capital expenditures involved -- to differentially relax its accuracy requirements. Such a relaxation would not only have implications in terms of the quality of the emergency services delivered to the public but raise significant equity and competitive issues as well.”