A new 911 funding model—likely including assessments charged to broadband connections—is needed to ensure that public-safety answering points (PSAPs) have the financial resources necessary to pay for the migration from legacy 911 to next-generation 911 (NG911) technology nationwide, members of a FCC Task Force on Optimal PSAP Architecture (TFOPA) working group said last week.

Funding 911 has been an issue for years, which is why some areas of the country still do not have emergency-calling service or utilize outdated technologies that cannot provide location information when 911 calls are made from wireless phones. With this in mind, it is important to simplify the “very complicated system of fees and reimbursements for PSAPS” in any new funding model, according to Phil Jones, chairman of the TFOPA working group exploring funding options and commissioner for the Washington State Utilities and Transportation Commission.

A draft of the working group’s report—subject to further review and a vote of approval later this year—states that 911 fees should be assessed in a “competitively neutral manner on all technologies utilized to place a 911 emergency request for assistance to a PSAP through an emergency communications device.”

This proposal is different than the existing funding models, which historically have not anticipated the adoption of new technologies being used to access 911. As a result, new technologies often are not included in the 911 fee structure, resulting in the model not being “technology neutral.”

One example of the current lack of that neutrality in the 911-funding model is disparity in collecting 911 fees from pre-paid wireless plans versus post-pay wireless plans. While 36 states have assessed a fee of typically 75 cents or $1 on prepaid wireless plans, the other 14 states have not resolved collection fee issues with pre-paid wireless plans at the point of sale (POS), Jones said.

“There’s an alleged under-recovery in the amount of $275 million from pre-paid plans as opposed to post-pay plans,” Jones said during the TFOPA meeting, which was webcast. “It’s a pretty serious allegation that several, if not many, 911 administrators believe they are being ‘shortchanged.’”

The working group recommends those select state’s rectify the pre-paid issue through new legislation.

To avoid other forms of fee-collection disparities, the TFOPA working group’s primary recommendation calls for a network connection fee to be assessed on upstream bandwidth connections through cell-phone carriers and broadband providers.

About 70% of calls to 911 centers are from wireless phones, Jones said. In an increasing number of cases, those calls are made using Wi-Fi rather than the cell-phone service—this is particularly common with “over-the-top” voice-over-IP (VoIP) offerings that have escaped 911 fees in the past. By assessing the fee to the underlying broadband connection, 911 fee collection can be equitable, broad-based and reflective of evolving technology, Jones said.

Jason Jackson, member of the working group and executive director of the Alabama 9-1-1 Board, explained the challenge of assessing 911 fees when a growing number of residents are utilizing their home broadband connections for making 911 calls instead of their cell-phone plans, where those fees are assessed.

“We made the assumptions, if the FCC continues down the path of possibly requiring over-the-top apps to connect to 911 services, [if other web-based services, like video messaging] are mandated to connect to 911, how do we assess fees?” Jackson said.

Since it would be challenging to broadly assess fees on over-the-top apps, Jackson suggests the broadband network fee as a way to more effectively collect 911 fees. The legalities and details on how to quantify the exact fee have not been finalized, but Jackson’s research found that the Internet Tax Freedom Act includes a clause that would allow 911 to collect a fee for 911 purposes only.

Anthony Montani, E911 engineering and operations director for Verizon, applauded the working group’s efforts to find a technology-neutral option for funding 911, but he questioned the feasibility of the plan. In particular, a proposal increasing the 911 fee as a customer increases bandwidth may not reflect greater usage of the emergency-calling system, so it may not be considered fair.

“I think the trick is how do you do that right,” Montani said. “I look at bandwidth, from a carrier perspective, and I think that’s evolving as fast as the applications that are arriving on top of it. I just question whether that’s a right approach.”

FCC task force suggests NG911 funding model that includes fees for broadband connections

Alabama is making efforts to implement the fee, Jackson said. Placing the fee on broadband connections would simplify the enforcement of fees for the state, reducing the number of broadband and wireless networks assessed a 911 fee from 185 to about 20.

“It is different, but, at the end of the day, as technology advances, this is the one thing that remains neutral, simplifies it and works across all boards,” Jackson said. “We’re trying to collect 911 fees by throwing a fishing rod out and trying to catch every line. For the first time, we’re going to throw a net.”

Jones also addressed the widespread concern of 911 fee diversion. Though certain states have been identified by the FCC as having appropriated 911 funds for other uses, Jones and the funding group uncovered several instances of diversion that have not formally been recognized.

“There should be transparency regarding decisions legislators and officials make on priorities among projects in a difficult budget environment,” Jones said. “I have learned a great deal more about state budget practices—that are going on both transparently and not transparently—that take 911 funds and use them for other purposes … If this diversion and sweeping continues, or if the states do not have adequate resources to build out NG911 in a timely way, the nation is going to be stuck with two systems for a very long time.”

The working group recommends that the 911 funds be sustained in a fund outside of state general funds. Additionally, the working group recommends that the matter be reviewed by a new joint advisory committee of officials from the state, local and federal levels.

David Simpson, chief of the FCC’s public-safety and homeland-security bureau, said multiple times that the completed migration to NG911 must include the retirement of legacy 911, so PSAPs do not have fund and operate separate systems long term.

National Emergency Number Association (NENA) CEO Brian Fontes echoed this sentiment, proposing that a “line in the sand” deadline be established for PSAPs to complete the migration to next-gen 911 technology. Without such a deadline, officials may lack the incentives necessary to complete the migration in a timely manner, resulting in patchwork service offerings and financial resources being spent unnecessarily to accommodate legacy 911 systems for too long.

When TFOPA was created, FCC Commissioner Michael O’Rielly asked the task force to examine the notion of PSAP consolidation, noting that some experts believe that the entire nation could be served with as few as three PSAPs, instead of the more than 6,000 emergency call centers that exist today.

Jones said that his working group looked at PSAP consolidation, which already is happening in many parts of the country. Although there are benefits to PSAPs sharing resources—sometimes on a virtual basis—the working group’s final report will not include a recommendation about physical consolidation, he said.

 “We concluded that just talking about PSAP consolidation is not constructive,” Jones said. “We believe in a cooperative federalist approach that involves state and local government that have primary jurisdiction over 911…We’ve received evidence that PSAP consolidations do not translate into efficiencies and cost savings.”

This article first appeared in sister publication Urgent Communications here.

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