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Testimony of Thomas J. Sugrue, Hearing on Wireless E911, Before the Subcommittee on Communications
of the Senate Committee on Commerce, Science and Transportation
Posted by WDN, October 17, 2001
Printer Friendly
 The following is a transcript of the testimony of Thomas J. Sugrue
Hearing on Wireless E911 Before the Subcommittee on Communications Committee on Commerce, Science, and Transportation United States Senate.
October 16, 2001, 10 a.m. - 253 Dirksen Senate Office Building, Washington, D.C. (Source: FCC)
Introduction
Good morning, Mr. Chairman and Members of the Subcommittee. Since it was
first designated as "9-1-1 Emergency Number Day" in 1987, September 11th has come to
symbolize our national reliance on the 911 infrastructure as a lifeline for help in
emergencies. That symbol is now more meaningful than ever. The tragic events of
September 11, 2001 may have delayed this hearing. But they also forcefully reminded us
of the importance of this nation's emergency response system, and of the men and women
of our police, fire and medical teams who go into emergencies to bring the rest of us out.
The Commission's wireless Enhanced 911 program ("E911") is one effort to help
public safety and other emergency response personnel do their jobs faster and more
effectively. I thank you for this opportunity to report to you on the Commission's
policies and rules aimed at improving wireless E911 services throughout the Nation and,
in particular, at implementing wireless E911. Let me emphasize for the record that the
Commission is serious about ensuring the deployment of wireless E911. We recognize
all too well that every second delayed in responding to an emergency call is a second lost
in critical life-saving efforts. For that reason, the Commission has issued orders with
very specific benchmarks and milestones, and we will be keeping a close and watchful
eye on compliance with these requirements. We have put the carriers on notice that if
they fail to adhere to the orders, they certainly will be subject to our enforcement
authority.
Importance of Wireless Enhanced 911 Service
Five years ago, the FCC set October 1, 2001 as the date for wireless carriers to
begin the process of deploying a new and vital technology -- the technology to accurately
report the location of wireless 911 calls. That process was based on a Consensus
Agreement reached in 1996 between the wireless carrier community and the public safety
community. The five-year development period, the specified accuracy standards, and the
October 1, 2001 start date represented the parties' best estimate of an appropriate
timetable and performance standards for development and initial deployment of
Enhanced 911. In this regard, I think it is important to note that it was never
contemplated that deployment would be a flash-cut process. Under the Commission's
rules, it will take four or so years for Phase II to be ubiquitously deployed. For example,
with handset-based technologies, the rules require carriers to hit progressively higher
penetration levels for location capable handsets, until they achieve 95 percent penetration
by the end of 2005. Similarly, with network-based solutions, a carrier is not required to
deploy its network-based solution in a particular area until six months after it receives a
valid request from the PSAP serving that area, or to complete that deployment until 18
months after such a request. Since the pace of PSAP requests and readiness for Phase II
will vary substantially in different communities across the country, deployment on a
nationwide basis will be on a graduated, incremental basis.
Since the original schedule was set, both Congress and the Commission have
continued to focus on wireless 911 issues and, in my view, taken important steps towards
the goal of a nationwide, ubiquitous, reliable E911 system. One of the cornerstones of
this progress was the passage in October 1999 of S. 800, the Wireless Communications
and Public Safety Act of 1999. That Act mandated 911 as the universal number for
emergency calling and cleared the way for full implementation of wireless E911 by, for
example, addressing carrier liability protection and privacy issues. It also directed the
Commission to work with all of the stakeholders in their efforts to make wireless 911 a
reality.
On the FCC side, we have been actively engaged on E911 matters, particularly in
encouraging new location technologies, addressing questions that have arisen in the
course of deployment, and removing obstacles to implementation of E911. Among other
things, we have:
Increased the range of options available to carriers by permitting the use of
new handset-based technologies, such as network-assisted GPS; and a "so-
called" hybrid technology - one that combines elements of both handset- and
network-based approaches.
Adjusted and clarified our rules concerning certain operational issues
affecting E911 implementation, for example, by eliminating a requirement
that public safety agencies must pay wireless carriers for their costs of
complying with the E911 mandate, and instead requiring that each party -
carrier and PSAP - pay its own costs for implementation.
Convened several multi-party meetings - including wireless carriers,
technology vendors, equipment manufacturers, and members of the public
safety community - to review the state of wireless location technology
development.
Performed extensive outreach, speaking at dozens of conferences and other
events aimed at informing and educating interested parties, including state and
local public safety agencies and carriers on our E911 rules and policies.
Today, there are more than 120 million wireless subscribers, and most PSAPs
now receive about 30 to 50 percent of their 911 calls from wireless phones. This
situation places increasing burdens on call takers at 911 call centers, particularly since
accurate location information is not now provided for those calls. E911 Phase II is
needed more than ever to help police, fire and emergency medical teams locate
emergencies more quickly and do their life-saving work more effectively and efficiently.
Current Status of Wireless E911
With the deployment of Phase II E911 now beginning, it is appropriate to ask how
far have we come - and how far we have to go?
Frankly, we are disappointed that the process of making wireless E911 a reality is
not further along. It goes without saying that there is a new sense of urgency around
using mobile phones as important safety devices. There are always challenges involved
in deploying any major new technology on a mass market basis for the first time, and
wireless location technologies are no different, but we must push forward aggressively
with a renewed commitment. To make the promise of wireless E911 a reality, much
work remains to be done by PSAPs, equipment vendors, carriers, and government to meet
the challenges involved in deploying these lifesaving technologies.
While we at the Commission are dissatisfied with the progress we have made thus
far, we should recognize that some progress has been made. On the technology and
manufacturing front, location technologies have been developed and, while none is
perfect, a number are now available or on the way that will locate wireless 911 calls
accurately and reliably, consistent with the goals of the Commission's E911 rules. Under
Phase II, the location of 911 calls will be reported in most instances with an accuracy of
100 meters or less. Network equipment and handsets with location capability are now
being manufactured and sold to meet and exceed this benchmark. Although the
development and delivery of some of this equipment lags behind what we originally
contemplated, the equipment is now in production. We expect near-term delays in E911
equipment and technology needed by wireless carriers to be resolved soon in most cases.
On the public safety front, this community also has made substantial strides
toward being able to receive and use wireless E911 location information. Many states
have adopted legislation to provide funds to upgrade 911 dispatcher work stations with
new technology, such as mapping software. Although relatively few 911 PSAPs
apparently are currently ready to receive Phase II data, or have requested Phase II from
carriers, they serve communities that would benefit from E911. In addition, many PSAPs
and other public safety organizations have been active in developing and testing upgraded
systems needed for Phase II. APCO's Project Locate is one example of the public safety
community's efforts to solve the problems of integrating Phase II with existing E911
systems.
And on the carrier front, substantial progress in deploying Phase II has been
made, though, again, efforts to reach full compliance must be redoubled. In short,
carriers have made strides but not quickly enough. On October 5, the Commission
announced decisions addressing requests from national wireless carriers and one public
safety agency regarding the deployment of Phase II. The Commission accepted, with
conditions and certain modifications, the revised implementation plans of five major
national wireless carriers - Nextel, Sprint, Verizon and the GSM portion of the AT&T
Wireless and Cingular networks. Each of those carriers, in addition to the sixth national
wireless carrier, VoiceStream, the subject of a Commission order last year, will be
subject to clear, detailed, and enforceable plans to phase-in location capability. Taken
together, these carriers serve more than 75 percent of wireless subscribers in the United
States.
It bears emphasizing that these plans permit only limited, temporary departures
from the Phase II rules. All carriers are required to achieve full compliance with the
accuracy and reliability requirements in the rules. The compliance plans involve only
modifications of the deployment schedule or temporary delays in meeting the accuracy
standard, rather than any kind of a wholesale lifting of the rules. Under the plans, with
limited exceptions, these major carriers will be required to be providing Phase II
information to public safety answering points next year and to honor all valid PSAP
requests by the end of the year. Under the plans, these carriers will achieve complete
deployment of Phase II, in full compliance with the Commission's accuracy standards.
This will occur in all areas across the nation where 911 call centers are ready and able to
use this information, by the end dates in the existing Commission rules, that is, no later
than December 31, 2005.
While accepting the plans means carriers will not be required to meet our
previous October 1, 2001 benchmark, the Commission believes that these plans are the
best way to move rapidly to full implementation of accurate and reliable location
capability for E911 calling. We examined each carrier request carefully, with the
continuing objective of implementing Phase II as soon as possible and granting relief
only when justified and necessary, and only to the extent the carrier presented a specific,
focused, limited plan leading to full compliance.
Specifically, the Commission has taken the following actions, approving plans to
implement E911 Phase II for five nationwide wireless carriers:
With respect to three companies (Nextel, Sprint, and Verizon) that had met
FCC requirements to provide a clear, detailed and enforceable plan to phase-in
its ALI capabilities, the Commission agreed to take into account the
companies' showings about equipment availability, and allow them to
implement Phase II E911 according to a modified schedule for some of the
initial 2001 and 2002 deployment milestones. It said it would strictly adhere
to enforcement of these modified plans for meeting these alternative
intermediate milestones and for completing E911 deployment by 2005.
With respect to two companies, (AT&T and Cingular) that submitted E911
compliance plans for the GSM portion of their wireless networks, the
Commission provided similar relief, also conditioned on strict FCC
enforcement of their new schedules.
The Commission noted that while AT&T and Cingular had submitted
compliance plans for the TDMA portion of their networks, the timing of those
submissions did not permit Commission consideration. Accordingly,
discussions have been initiated between these carriers and FCC Enforcement
Bureau staff concerning possible consent decrees with the Commission to
resolve this compliance issue.
The Commission stated that it expects wireless carriers to make E911 a corporate
priority and to work aggressively to implement Phase II and to achieve full compliance as
soon as possible. To monitor and enforce the compliance plans, the Commission
required that each carrier file Quarterly Reports on its E911 deployment beginning
February 1, 2002 through February 1, 2006, including reporting whether the carrier has
met the terms of its compliance plan. The Commission indicated that any carrier failing
to comply with its plan, or applicable provisions of the E911 rules, will be referred to the
Commission's Enforcement Bureau.
We know that smaller and rural carriers may face special challenges in deploying
Phase II location technology. We have received many waiver requests from smaller
wireless carriers, and it is likely that others of the 1000 or so local and regional carriers
face similar questions and difficulties. However, it is also clear that wireless E911 has
great potential to save lives in rural areas and simply giving smaller or rural carriers a
"pass" or indefinite extension for deploying these technologies would not serve the public
interest. For these reasons, the Commission established a brief additional period, until
November 30, for those smaller carriers to file requests for relief, if they have not already
done so. The FCC will evaluate these filings to decide how best to address E911
implementation by these carriers as soon as possible. During this extended filing and
evaluation period, the Commission will not initiate enforcement action under the Phase II
rules against these carriers.
We at the FCC recognize the importance of Phase II deployment to public safety.
I want to assure the Subcommittee that we are committed to taking whatever steps are
necessary to ensure that Phase II proceeds to full compliance as soon as possible. To that
end, the Commission took other steps to help clear the way for Phase II deployment:
In response to a request by the City of Richardson, Texas, the Commission
amended its rules to clarify the steps that 911 call centers should take to make
a valid request for E911 service; and
The Commission indicated it would conduct an ongoing inquiry on E911
technical issues, including technology standards issues, development of
hardware and software, and supply conditions.
What, then is the bottom line for wireless E911? In important ways, Phase II will
be deployed largely according to the schedule we had planned. Sprint announced on
October 1 the offering of handsets with Assisted-GPS location technology. Other
wireless carriers will also begin providing location-capable handsets and network
equipment soon, and I expect customers, in many areas where PSAPs are ready to use
this location information, will begin to shop for carriers and handsets that include this
important safety feature. Under the approved plans, all the nationwide carriers will have
completed implementation of Phase II by the end of the year 2005, as our rules provide.
By that time, I also expect that public safety organizations will have made substantial
progress in actually using wireless E911 location information to find people in
emergencies in communities across America.
Because of the localized nature of 911 service, the number of different
transmission standards in the U.S., and the number of parties who must all do their part,
this implementation process will be complex. It will, for example, involve several
location technologies that are deployed on schedules that vary for different carriers and
different communities. Small, rural carriers may face circumstances that warrant special
consideration. Successful deployment will certainly require continued FCC oversight to
ensure that carriers live up to their responsibilities and achieve full compliance with the
Phase II requirements.
I am reassured by factual information indicating that wireless location technology
is available, is being deployed in networks and handsets, and is capable of accurately
locating 911 callers. As deployment proceeds, I expect that technology and system-wide
performance will improve. I also expect that, as customers increasingly understand how
location capability makes their lives safer, they will insist on having it available. They
will come to rely on automatic wireless location in the same way that they rely on air
bags and seatbelts in their cars. I am confident that the future of this technology is
strong, once it is actually deployed and this "virtuous cycle" begins to kick in. But to get
to that future, all of us involved in this process will have to redouble our efforts to see
that the promise of this life-saving technology is fulfilled.
Conclusion
To sum up, the beginning of E911 Phase II deployment is now underway.
Working with the public safety community, the carriers, their suppliers, Congress and
other governmental agencies, the FCC will continue its efforts to ensure that the E911
rollout process continues as rapidly as possible, so that by "9-1-1 Day" in the year 2005
we will be able to report that full deployment, as required by the Phase II rules, has been
achieved on the scale envisioned by the Commission and by the Congress.
I would like to thank the Subcommittee for this opportunity to provide
information on the Commission's wireless E911 program. I look forward to updating this
information as wireless E911 advances and to answering any of your questions.
WDN e-911 Home
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