Subject: [NEXTEL-1] Adjunct Professor,Dale N. Hatfield- Testimony On E-911

From: "marcel_rf1" <[email-masked]>
Date: Wed, 11 Jun 2003 10:29:29 -0000

Wireless E-911 Implementation: Progress and Remaining Hurdles.
Subcommittee on Telecommunications and the Internet

June 4, 2003 10:00 AM

2123 Rayburn House Office Building

Mr. Dale N. Hatfield
Adjunct Professor Department of Interdisciplinary Telecommunications 
University of Colorado at Boulder
Engineering Center, ECOT-311
Campus Box 530
Boulder, CO, 80309-0530

Mr. Chairman and Members of the Subcommittee: thank you very much for 
the opportunity to appear before you today to discuss issues relating 
to the rollout of wireless E911 service in the United States.  As you 
may be aware, the Federal Communications Commission ("FCC" or "the 
Commission") in early 2002 retained me to conduct an independent 
inquiry and to produce an accompanying report to the agency on the 
technical and operational issues impacting on the provisioning of 
wireless E911.  In my testimony here today, I will summarize that 
report and provide some additional comments based upon developments 
that have occurred subsequent to its being released in October of last 
year.  Before I turn to the substance of my testimony, however, I want 
to emphasize that I am testifying today solely as a private citizen 
and that, consequently, the views that I express are strictly my own.
The focus of the inquiry that I undertook for the Commission was on 
the future of wireless E911 deployment, including any obstacles to 
deployment and the steps that might be taken to overcome or minimize 
them.  My inquiry began in the spring of last year with a large 
meeting of stakeholders, including service providers, technology 
manufacturers, and members of the public safety community.  Over the 
succeeding months, I participated in scores of meetings and met with 
several hundred stakeholders that are working very hard to increase 
the safety of the American public through the further development and 
deployment of wireless E911.

As I mentioned a moment ago, my report was submitted to the Commission 
in October of last year and I have been deeply gratified with the 
generally positive response it has generated.  The report - along with 
public comments on its substance - is available on the Commission's 
website (www.fcc.gov).[1]  Since the report has been available for 
some months and in the interests of time, I will not go into detail on 
my findings and recommendations.  Rather, I will first present a brief 
overview and commentaries on what I feel are the most important points 
and then offer some concluding remarks based upon more recent 
developments.

In the findings section of the report, I noted the strong federal 
interest in the nationwide availability of E911 and, on that basis, 
recommended that there be increased coordination between and among the 
relevant federal agencies.  The events of the recent past have clearly 
demonstrated that E911 is not just an issue of the safety of life and 
property on a local basis but one of critical importance to homeland 
security as well.  Given the ever increasing proportion of calls 
originating from wireless devices and the growing substitution of 
wireless phones for wireline phones, the need for a rapid deployment 
of wireless E911 becomes more obvious every day.

In the findings, I also raised concerns about the technical 
limitations associated with the existing wireline E911 infrastructure 
and - especially - with its ability to evolve smoothly and efficiently 
to address emerging requirements.  Rather than delve into these 
limitations today, I would merely stress the need for a modern 
infrastructure that is not only capable of efficiently and effectively 
handling traditional wireline and wireless E911 calls, but one who's 
overall architecture facilitates the exchange of evolving types of 
emergency communications information between and among federal, state, 
and local agencies and the public that they serve.  And, an 
architecture I might also stress that remains true to other public 
policy values such as competitive and technical neutrality and 
reliance on the competitive marketplace where possible.

This last commentary leads me to another major finding of the report. 
 When I undertook the independent inquiry on behalf of the Commission, 
I was generally aware - from my earlier tenure at the agency - of what 
was involved in rolling out wireless E911.  As I dug into it deeper 
under my new assignment, what really struck me was the overall 
complexity of the undertaking.  As I pointed out a moment ago, 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 Wireless Communications and Public Safety Act of 
1999 ("E911 Act").

The complexity is exacerbated by the fact that there is no single 
decision-maker - no master architect - for emergency communications 
systems.  Instead, decision-making of this type is spread over a large 
number of stakeholders and multiple jurisdictions.  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 concluded -not surprising perhaps 
- that an unusually high degree of coordination and cooperation among 
public and private entities will be required if this nation is going 
to have the type of modern infrastructure I described and that I 
believe the Congress envisioned in passing the 911 Act.  In the 
report, I pointed specifically to the need for coordination and 
collaboration among all stakeholders, public and private, in such 
areas as overall system engineering, project management, and the 
development and adoption of standards.

In another of the findings, I expressed concern that the rollout of 
wireless E911 service was being hampered by the lack of funding and 
other resources for Public Safety Access Providers - PSAPs - in many 
jurisdictions around the country.  I pointed specifically to the lack 
of cost recovery mechanisms in some states, the lack of a "champion" 
within the Federal government, and residual awareness and readiness 
issues within the PSAP community.  Unfortunately, perhaps, in the 
report, I used the term "PSAP fatigue" in referring to some of these 
issues and this was seen by some as a criticism of PSAP efforts.  
Exactly the opposite was true.  It was meant to point out they needed 
more support in shouldering an enormous burden.

Another of the findings in the report related to the role of Incumbent 
Local Exchange Carriers (ILECs) in the provision of E911 services.  I 
found that, despite the central role that these carriers play in some 
implementations of wireless E911 services, their responsibilities had 
not been adequately defined both in terms of their technical 
requirements and in terms of cost recovery.  As an aside, I am pleased 
to note that in the past year the Commission has acknowledged these 
concerns and has taken steps to rectify them.

Lastly, I found that there appeared to be a lack of well-accepted, 
standardized tests for determining compliance with the Commission's 
location accuracy requirements, including issues regarding geographic 
averaging.  I went on to express the concern that this uncertainty 
could ultimately prove to be an impediment to the more rapid 
deployment of wireless E911 systems.

In light of my findings, I made several recommendations to the 
Commission and I will mention them briefly here.
First, recognizing both the strong Federal interest in the nationwide 
availability of E911 and the somewhat limited scope of the 
Commission's jurisdiction, I recommended that the Commission work more 
closely with other Federal agencies to encourage a coordinated 
approach in dealing with issues associated with the deployment of 
wireless E911 systems.  More specifically, I recommended that it work 
with the Administration and, in particular, the then nascent 
Department of Homeland security to establish what I referred to as a 
"National E911 Program Office."  As I envisioned it, the office within 
DHS would serve as a resource and advocate - or champion - for the 
Nation's first responders on the issue of E911 deployment.
Second, I recommended that the Commission increase its own oversight 
efforts of E911 during this critical phase of deployment.  To that 
end, I recommended that the Commission establish a formal advisory 
Committee that would address the technical framework and longer term 
network architecture issues associated with further E911 development 
and deployment.

Third, noting that my findings suggested that, in at least some 
situations, deployment of wireless E911 may be hampered by a lack of 
coordination and dialog among the stakeholder groups, I recommended 
that the Commission establish an "information clearinghouse" - for the 
lack of a better term - that would collect and disseminate information 
critical to deployment so that the stakeholders could better 
coordinate with one another.  I also recommended that the Commission 
work with, and appropriately support, the efforts of public, private, 
and joint efforts aimed at speeding the rollout.

In March of this year, the Commission acknowledged this recommendation 
and announced its E911 Coordination Initiative to bring together 
relevant stakeholders to share experiences and devise strategies for 
expediting E911 deployment.  On April 29 - about a month ago -- I was 
pleased to participate in the first public meeting associated with 
that initiative.  I was particularly interested in an announcement 
made by the Commission at the meeting regarding E911 Tracking and 
Coordination Management.  Since this effort is likely to be described 
in other testimony here today, I will simply say that it exemplifies 
the enhanced "information clearinghouse" role that I envisioned in my 
report.

While I am on this topic, let me digress briefly to say that, since 
the publication of the report, I have been gratified to see what I 
perceive as an overall increase in such coordination and communication 
among stakeholders and an associated general increase in the level of 
priority and awareness of the importance of E911 among policy makers, 
industry and the general public.  In addition to the Commission's own 
Wireless E911 Coordination Initiative which I just mentioned, other 
activities, which I believe you will also hear more about today, 
include the Department of Transportation's Wireless E911 Steering 
Council, the Emergency Services Interconnection Forum jointly 
sponsored by the Alliance for Telecommunications Industry Solutions  - 
ATIS - and the National Emergency Number Association - NENA, the 
Association of Public Safety Communications Officers' - APCO's - 
Project Locate, and NENA's Strategic Wireless Action Team - SWAT - 
Initiative.  The latter, for example, provides a forum for 
communications among public safety organizations, wireless carriers, 
wireline carriers, state representatives and other participants.  As I 
understand it, the course of action that they are following is 
intended to build on the input of the various stakeholders and to 
develop consensus recommendations among the various parties.  
Significantly, in my mind, it includes the resources to conduct 
supporting analyses to inform and shape the process.  While I cannot - 
and should not - endorse any of the results that they are obtaining, I 
do believe that it represents the sort of collaborative process which 
is required for sustainable progress in E911 deployment to occur in an 
extremely complex environment.

Returning to my recommendations, my fourth suggestion was for the 
development of industry wide procedures for testing and certification 
of wireless E911 systems to ensure that they meet the Commission's 
accuracy requirements.  I also recommended that the Commission 
undertake to more clearly define those requirements to eliminate any 
remaining uncertainty as to what constitutes compliance.
I would like to close my testimony by making a few specific 
recommendations based upon the current situation in wireless E911 
deployment.  These concluding recommendations are not intended to be 
comprehensive; rather, they reflect some areas that I believe - based 
upon my inquiry and subsequent events - would benefit from the 
Subcommittee's attention.

First, as I noted earlier, one of the key recommendations of my report 
was that the Commission work with the Administration, and the then 
nascent Department of Homeland Security, to establish what I referred 
to as a "National E911 Program Office."  My thought was that the 
proposed office within DHS would be a focus of E911 activity in the 
Executive Branch and serve as a key resource and advocate for the 
Nation's first responders on issues related to E911 deployment.  I am 
now even more convinced of the need for such an office.  I should note 
that it was reported in the press that Chairman Powell has raised this 
issue with Secretary Ridge.  However, in all candor, I have not had 
the opportunity to follow all of the subsequent developments in this 
area nor to determine whether other institutional arrangements might 
suffice.  Because of its importance, I would further urge this 
Subcommittee in its oversight and legislative role to ensure that the 
needs I identified in my inquiry are being met within the Federal 
government.

Second, on a related topic, in passing the E911 Act, the Congress 
directed the Commission to "…encourage each state to develop and 
implement coordinated statewide deployment plans through an entity 
designated by the governor…" for the rollout of "…comprehensive 
end-to-end emergency communications infrastructure and programs…" 
There is now evidence that suggests that such a statewide and/or 
regional coordinating entity is a key indicator of success in the 
early deployments of wireless E911.  Despite the clear Congressional 
admonition and despite this increasing body of evidence, some states 
still have not created a statewide E911 coordinator or its equivalent. 
 While I am not a lawyer, it seems clear that the Commission itself 
has limited ability to require states to create such an entity and, 
hence, I would urge this Subcommittee to revisit this issue given the 
clear Congressional intent and the benefits that apparently are 
achieved where such an entity exists.  To my dismay, there have also 
been widely reported instances where state E911 cost recovery funds 
have been diverted to other, unrelated purposes.  This is apparently 
true even though customers paying the itemized charge are likely to 
believe that the service is available to them.  Again, I am unclear as 
to what jurisdiction, if any, the Commission has to deal with these 
instances but clearly it is an area that the Subcommittee may want to 
address.

Third, another of my key recommendations was that the Commission 
establish, or cause to have established, an advisory committee (under 
the Federal Advisory Committee Act) that would address the overall 
technical framework for the further development and evolution of 
wireless E911 systems.  This recommendation was a reflection of my 
finding that the responsibilities for making critical decisions 
relating to network architectures were spread over a large number of 
stakeholders and multiple jurisdictions.  While I am well aware of 
-and earlier in this testimony explicitly called attention to - other 
private and public sector coordination activities that address aspects 
of these larger, longer term network architecture issues, I still have 
serious concerns in this area.

For example, since the submission of the report, I have gained an even 
greater appreciation of the relationship of wireless E911 to not only 
homeland security but to the reliable and seamless delivery of other 
information relating to vehicular and personal emergencies to first 
responders - a point I alluded to earlier.  This includes information 
involving (a) hazardous material (hazmat) truck incidents, (b) 
automobile emergencies including, for example, information from 
automatic crash notification systems, and (c) severe weather events 
such as tornadoes and flash flooding.  The proliferation of personal 
wireless devices and services, including text messaging and personal 
digital assistants ("PDAs") with communications capabilities, adds to 
the milieu.  As another example, a product was recently described to 
me that will produce automatic notices of cardiac incidents - with 
latitude and longitude attached.  Similar devices that can be used to 
find missing children - or to help prevent them from becoming missing 
in the first place - are envisioned.

Subsequent to the publication of the report, I have sensed some 
reluctance on the part of stakeholders to embrace the notion of a 
formal advisory committee to address these longer term, over-arching 
issues.  I believe this reluctance stems more from timing, support, 
and other logistical issues associated with a formal advisory 
committee rather than on the goal that I advocated.  However, my real 
concern is not the exact form of the institutional arrangements as 
long as the decision-making takes place in an open and transparent 
process available to all stakeholders.  In any event, I would urge the 
Subcommittee to satisfy itself that the necessary institutional 
arrangements and resources are in place to address these longer term 
issues.

That, Mr. Chairman, completes my testimony and I would be happy to 
answer any questions at the appropriate time.

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