Remarks by Michele C. Farquhar Chief of the Wireless Telecommunications Bureau before the Expanding and Enhancing Wireless Emergency Services Conference January 16, 1997 "Putting the Pieces Together" I appreciate the opportunity to talk to you today about the Federal Communication Commission's efforts to improve wireless access to emergency services and, more generally, about how we are working to enhance the wireless systems and services used by the Nation's public safety agencies. As you know, there is much going on at the Commission relating to public safety these days, and I think that the timing and topics of this conference are particularly appropriate as we wrestle with "Expanding and Enhancing Wireless Emergency Services." As I was thinking about my remarks, I realized that the Wireless Bureau's efforts to improve public safety wireless communications are a lot like a jigsaw puzzle. We have a number of pieces that we are working on, each of which individually is critical for ensuring that emergency services are there when and where people need them. But if you look only at the individual pieces, I think there is a tendency to lose sight of the big picture --the broader goals that we are trying to accomplish regarding public safety and emergency wireless communications. As we have been working on these issues -- putting the pieces together -- we have gotten a clearer picture of the whole range of needs and opportunities facing the public safety community. But we're not done yet. We need your help, and the help of everyone involved in public safety communications, to help us clarify our vision, prioritize our efforts, and ensure that the picture we put together of the future of public safety is clear, bright, and realistic. What I would like to do today is describe the various pieces of the puzzle, particularly our important efforts on E-911. I also want to give you a sense of the larger context of E-911 at the FCC, a context that includes our public safety rulemaking, cellular priority access, refarming, and the search for more spectrum and funding to meet public safety's interoperability and capacity needs. I'm certain that you'll gain a deeper appreciation of the critical juncture we are at right now for public safety wireless issues, and I hope you'll work with us on all these various fronts. Why Emergency Wireless Services Are Important Before I describe specific rulemakings and efforts, I think it is useful to understand why wireless emergency services are so important. The question is significant because it underlies what we are trying to accomplish with our E-911 and other proceedings -- it helps us define our goals as we think about public safety wireless communications. Basically, wireless emergency communications are important because they save lives and property. I can think of many examples that vividly demonstrate how people and organizations depend on wireless emergency services, but let me mention just one -- the bombing at the Olympics last summer. It has been reported that in the 24 hours after the bombing, over one MILLION minutes of two-way radio conversations were logged. That is roughly equivalent to 20 days worth of normal traffic in one 24-hour period. One of the local cellular operators reported that 1.5 million cellular phone calls were made in that same period. These numbers indicate the extent to which the general public and public safety agencies rely on wireless communications in emergencies. But I also think several trends are making wireless access to emergency services more important than ever. First, people are increasingly concerned about crime. Recent decreases in crime statistics around the country are heartening, but safety remains on the minds of many people. As a result, more and more people are looking for ways to make themselves and their families safer, and wireless communications fills that need for many. Safety, as I'm sure you all know, is one of the most-cited reasons that people mention for buying cellular and PCS phones. In a recent survey, a full 60% of cellular users cited safety as their main reason for purchasing their phone. In addition, as people have become more mobile in their jobs and personal lives, staying in touch has become more important, and the growth of wireless services has been phenomenal. There are currently more than 40 million cellular users in the United States, and thousands of new users are added each day. Add to that the large numbers that are just beginning to sign up for PCS and other wireless services, and you have a significant number of people who need access to emergency services. Some analysts expect the number of wireless users to exceed 100 million over the next decade, and, just this week, the Washington Post Business Section announced "Brace Yourself for the Year of the Pocket Phone." With growing use, and as wireless becomes a more ubiquitous feature of American life, expectations that wireless phones should work like regular phones will grow stronger. And there is no reason that, in most cases, the E-911 features that people have come to rely on in their homes and offices shouldn't be available to them on their cellular or PCS phones. That's what our Order was designed to do. In addition to the importance of wireless access generally, I think that E-911 is especially critical to providing the fastest response possible in emergency situations. Automatic Location Identification, or "ALI," permits rapid response in situations where callers are disoriented, disabled, unable to speak, or do not know their location. In these situations, ALI permits the immediate dispatch of emergency assistance to the user. ALI also reduces errors in reporting the location of an emergency and in forwarding accurate information to emergency personnel. Where telephone exchange boundaries extend into two or more jurisdictions, the ALI feature permits routing of calls to the appropriate authorities. A dispatcher with E-911 capability can also call back in the event the call is disconnected. Currently, almost 90% of wireline phones in the United States are served by 911, and about 85% of those include some form of E-911. WTB Efforts to Improve Public Access to Emergency Services Given the important public safety mission of 911, it is not surprising that 911 and E-911 have become such an integral part of American life. Since basic 911 service was begun in 1968, Federal, State, and local governments have expended immense effort to establish 911 as the number to call when help is needed most. Few would argue with the success of these efforts -- we are treated on a regular basis to stories of young children dialling 911 to save parents in trouble, and believe it or not, I saw a story recently about a dog who is specially trained to speed dial 911 to help his owner, who is disabled. The point is clear: 911 is relied on every day to save people's lives -- almost 100 million 911 calls come in each year. And of that number, between 15 and 20% come from wireless phones -- in 1994, for example, almost 18 million wireless calls were made to 911 and other public service numbers. As wireless services grew, however, the FCC became concerned that the benefits of 911 and E-911 -- and the BILLIONs of dollars in investments made by State and local public safety authorities in systems and education -- were not being made available to all wireless callers. As far back as 1993, in the PCS rulemaking, we urged the wireless industry and standards-setting bodies to address E-911 access, including providing location information on wireless 911 callers. We were especially concerned that the automatic location function that people and public safety agencies have come to expect in wireline phones was not available to wireless users, and we recognized that the health and safety of citizens was affected by whether wireless carriers could provide access to 911 services that is equivalent to the access provided to wireline customers. As a result of these concerns, we initiated a rulemaking proceeding in 1994 to address the issues involved. It had become clear that the Commission needed to play a more active role to ensure that the technologies necessary for wireless 911 and E-911 were deployed throughout the country in a timely fashion. Since I became Chief of the Wireless Bureau more than a year ago, I have now had the opportunity to see first-hand how important -- and complicated -- the wireless E- 911 problem really is. I've talked to carriers, administrators, and individuals involved with different parts of the issue, and I was surprised at the range of technical, social, regulatory, political, and economic issues that must all be solved for this system to work effectively. One event that really brought this into focus for me was a trip I made to New York City in December to visit their new 911 center. I also visited their old 911 center, and let me tell you, the difference was stark. The capabilities that New York City is implementing will allow call takers to access a broad range of information that operators never had before -- building plans, past histories, special medical conditions, and more. After listening to several calls, I was also struck on a very personal level by the human aspect of what E-911 is all about. It's about people in trouble -- people who come home and find their houses burglarized, people who are injured or hurt, people whose cars have disappeared. And, it's about extremely patient and sensitive people who take these very stressful calls in a calm and efficient manner. It made an impression, and strengthened my resolve to do everything I can to make sure that E-911 services become available as quickly as possible. On a much darker note, I would also like to say that I was frankly quite troubled by the situation I discovered on a trip to another major city this week. There, the public safety agencies have refused to take 911 calls directly from wireless carriers, forcing the wireless carriers to route the calls through the local telephone network. While I plan to learn more about the rationale for this type of approach, I would hope that this method would not become the norm as we try to encourage wireless access. I should also note that I am generally delighted at how the industry and the public safety community have risen to the E-911 challenge, and frankly amazed that so much has been accomplished since we adopted our Order. I have heard about the successful trial in Houston, and I know that our Chairman, Reed Hundt, will be speaking at the opening of an E-911 system in New Jersey next week. These examples show that E-911 is doable, and demonstrates what can be accomplished when carriers, equipment manufacturers, and public safety officials work together. Overall, the progress you have made is impressive by any measure, and I want to express my personal admiration for all that you have done. The E-911 Report and Order Now back to business--the E-911 Report and Order. In our original Notice of Proposed Rulemaking in 1994, we asked a series of questions about how to make 911 and E-911 services more widely available to the public. Over the next 18 months we received comments from and met with many organizations, companies, and individuals who often had very personal stakes in our decision. We also heard from members of Congress who were concerned that the benefits of 911 be made available as widely as possible. Let me especially recognize the efforts of Representative Anna Eshoo, who was instrumental in bringing the parties together and helping to build a consensus on how best to improve 911 services. And, of course, a lot of credit is due to APCO, NENA, NASNA, and the Cellular Telecommunications Industry Association for their work in forging the Consensus Agreement that was so much help as we worked to resolve the issues. Taking all these inputs, we adopted a Report and Order in June 1996 that laid out the requirements for 911 and E-911 services and established a timetable for implementing the features we thought would improve wireless access to E-911. At the same time, we also released a Further Notice of Proposed Rulemaking that asked how we might make 911 services even better in the future. Let me quickly discuss the basic requirements of the Order. -- First, by October of this year, covered carriers must process and transmit to the appropriate public safety answering point all 911 calls made from wireless handsets that have a mobile identification number or its equivalent. This requirement also includes TTY access. In the case of phones without that identification information, carriers are only required to transmit the calls if requested by the local public safety authority. This allows local authorities, who are, after all, the users of this feature, to decide if they want to accept such calls or not. Each call, including those from roamers, must be passed to the PSAP without validation. -- Second, we laid out a two-phase implementation schedule for E-911. In Phase I, by April 1998, carriers must have the ability to relay a caller's Automatic Number Identification, and the location of the base station or cell site receiving a 911 call, to the designated PSAP. These capabilities should allow the PSAP operator to call back if the 911 call is disconnected. We recognize that calling back a phone without an identification code may be difficult, and that is one issue we will address in the future. -- In Phase II, carriers are required to be able to identify the location of a 911 caller to within 125 meters 67% of the time by October 2001. As you probably know, there are two important caveats to the E-911 requirements: --First, the carrier must receive a request from the PSAP, and the PSAP must be capable of receiving and using the data to be supplied. --Second, a mechanism to recover the costs associated with providing E-911 must be in place before a carrier is required to provide the service. We did not prescribe such a mechanism because we felt that state and local authorities are in a better position to determine what will work best in their communities, especially since wireline 911 cost recovery has already been successfully addressed in this way. This approach gives a measure of flexibility that a Federal mandate would not. One issue that several commenters had been worried about--and that was left somewhat open in the Order -- is carrier liability for releasing certain information about callers. In the Order, we indicated that we had asked the Department of Justice for an opinion on whether our E-911 regulations conflicted with the Wiretap Act or other provisions of law. DOJ issued an opinion late last year that the rules we established do not violate the Wiretap Act, the Electronic Communications Act, or the Fourth Amendment. So, that issue should now be resolved. In general, the Report and Order established requirements that we believe will bring the benefits of E-911 services to wireless customers quickly and efficiently. We recognized that there are many important technical and administrative issues -- including grade of service, signalling protocols, and infrastructure upgrades -- that need to be worked out before wireless 911 and E-911 can become more widely available, but we believe it is more appropriate for us to leave the standards-setting for such features to industry working with the public safety community. Ensuring adequate mechanisms will also be an important issue as we go forward, and the FCC is willing to facilitate thoughtful discussions on this front. We will continue to keep close track of progress on wireless E-911, and we intend to stay actively involved as the various efforts continue. Further Notice In addition to the Report and Order, we simultaneously issued a Further Notice of Proposed Rulemaking designed to help us understand how to continuously improve 911 services and how to make the public better aware of the benefits and limitations of the technologies. Specifically: -- we asked for comment on whether all calls from non-identified phones should be passed to the local PSAP. -- We also asked how to ensure that the public continues to benefit from advances in location technology. We proposed a more stringent standard for location information that might be adopted after the five-year requirements are met. I understand that many carriers and manufacturers believe that the standard we proposed -- 40 meters in three dimensions with 90% accuracy -- was not realistic. We need to better understand what is realistic, and how we can keep technology advancing. -- And finally, we concluded that the public needs to be made more aware of what wireless technologies can and cannot do in relation to 911. To address these types of issues, we asked for comment in two areas -- how can consumers be better educated about the current limitations of wireless technologies, and are there technology fixes that could help alleviate some of the problems we now have. I was heartened to see that many of the commenters believe strongly that education is an important component of wireless 911 services, and I hope that public safety officials, manufacturers, as well as wireless service providers will work together to develop effective programs for informing the public what wireless phones can and cannot do. In response to our Report and Order, we received a number of Petitions for Reconsideration from people who disagreed with our requirements or who wanted some issues clarified. We are presently working on our response to these petitions, and I anticipate that we will respond to them soon. And since many of the issues in the petitions for reconsideration also relate to questions raised in the Further Notice, I suspect that we will need to finish with those petitions before we can address the comments we received in regard to the FNPRM. I should emphasize, however, that I believe that all these issues will be resolved before the October deadline for provision of basic 911 service and Phase I of the E-911 requirements. Other Issues E-911, however, is only one of the many issues that affects the public's access to emergency services and the ability of public safety providers to serve the public in the fastest and most effective way possible. Let me just briefly mention some of the other items we are working on and initiatives we have in place to address wireless public safety issues. Public Safety NPRM and PSWAC One of the most important efforts we are engaged in is the completion of the rulemaking proceeding we initiated in March 1996 to address the current and future wireless communications needs of the public safety community. Comments on our Notice of Proposed Rulemaking came in just last month, and we are now working to synthesize the ideas we received, especially from the Public Safety Wireless Advisory Committee. PSWAC identified a number of areas where FCC action could really make a difference in the ability of public safety agencies to do their job. I could talk about this at length, but I wouldn't want to steal Phil Verveer's show -- he'll be talking about PSWAC and its recommendations after I finish. But while I'm on the subject, I do want to thank Phil once again for his outstanding efforts in guiding the work of the PSWAC and his continuing efforts on behalf of the public safety community. Needless to say, the issues that Phil and PSWAC identified, including interoperability and the need for more spectrum and funding, will be carefully considered as we put together our Report and Order. I do want to take a quick minute, though, to talk about one aspect of PSWAC's recommendations: the need for more spectrum for public safety activities. I think PSWAC was right on the mark when they identified congestion and a general shortage of capacity as major problems facing the public safety community. Furthermore, I agree with the sentiments expressed in the report that additional spectrum is not a panacea that will solve all of the community's needs. Rather, I believe that a combination of approaches will best enable the current and future needs of the public safety community to be met. For example, the FCC needs to do everything we can to encourage public safety systems to be as spectrally efficient as possible -- to get more from what they've got. Our Refarming docket, which I will talk about in a minute, does that. In addition, however, I think we also need to encourage the public safety community to work with commercial providers to see how public safety can make better use of commercial services, and how the providers can more effectively address public safety's needs. Make no mistake that we are committed to finding additional spectrum for public safety, but in doing so, we need to do it right. We don't want to exacerbate existing problems resulting from the fragmentation of the spectrum. That is why UHF channels 60-69, which may be reallocated as part of the Commission's Digital Television proceeding, are particularly attractive. I anticipate that we will be working closely with the public safety community over the next several months to identify spectrum that would most effectively meet their needs. And I urge you to contact me directly if you have thoughts or ideas on how we can improve public safety communications. The other important part of the PSWAC report that I want to highlight just briefly is the need to ensure that public safety has access to the latest innovations and advanced technologies. It is interesting that the first use of mobile radios in cars was actually for the police department -- not doctors or lawyers or even plumbers. We need to strive to return public safety to that technology leadership role -- there is no good reason that our Nation's public safety agencies should be relegated to using yesterday's technology. Of course, one important issue is funding. We need to work with the public safety community to develop new sources of funding to ensure that current capacity needs can be met, that local agencies have the funds they need to buy new equipment, and that advanced technologies and applications can be introduced on a timely basis to meet an expanding set of communications requirements. The PSWAC report is a good start, but we must continue to push for more creative solutions as we move ahead. I would ask you to share with us the ideas you have on how we can improve funding for public safety, especially with the idea that we may need the help of the state legislatures and Congress to really make a dent in this problem. In the E-911 arena specifically, the start of the new state legislative sessions is just the right time for funding proposals to be made. Some states have been active in working on the funding for meeting our 911 and E-911 requirements, but others have not, and I'm afraid that if people don't focus on this quickly, that the benefits of wireless E-911 will be delayed. We will work with you however we can to make this a priority. Cellular Priority Access Service (CPAS) One problem during large-scale emergencies that public safety agencies have identified for us is that cellular channels frequently fill up as people attempt to call family members and relatives. The media is also reported to use cellular heavily in reporting on the events. The result is that public safety officials often cannot access cellular systems to help in recovery and assistance efforts. To address this problem, the National Communications System petitioned the FCC to provide "priority access" to public safety and emergency preparedness personnel. Authorized users would dial a special code to activate priority access, and would then be assigned the next channel that became available. Priority access calls would not preempt calls in progress. We appreciate the attention NCS has given to this problem, and we have met with them to help work through some of the details of their proposal. In addition, we solicited public comment on their proposal and are now evaluating the responses we received. It is my hope that we could take some action on this issue over the next few months, perhaps through the adoption of a NPRM that would allow us to explore the issues in greater detail. Refarming As most of you probably also know, the Wireless Bureau is also in the midst of developing new regulations to govern many of the private services--the so-called "Refarming" proceeding. The effects of refarming will be to foster a more efficient operating environment for all private land mobile radio users. This is accomplished in several ways. First, we have set up a channel plan based on narrowband channel spacing that provides more frequencies for systems to use, reducing congestion on the existing channels and increasing capacity on the new channels. Second, we are encouraging the transition to narrowband equipment through the type acceptance process. Manufacturers are required to produce increasingly efficient equipment over the next ten years. However, there is NO requirement on licensees to change-out their systems. This ensures that spectrally efficient equipment is available, while providing users with flexibility to make equipment choices based on their technical needs and financial objectives. Finally, we are currently considering how to consolidate the 20 existing private land mobile radio services. Consolidation would promote efficiency by distributing assignments between low-use and high-use groups more evenly, simplifying interservice sharing procedures, enabling licensees to more easily use advanced technologies, and organizing the services to achieve more efficient and flexible spectrum use. Collectively, these decisions will allow licensees to implement more efficient radio systems, easing current congestion problems and increasing the quality of their communication links. WCS Finally, we are busily working on an item, required by Congress last fall, to auction 30 MHz of spectrum at 2.3 GHz for new wireless services, while taking account of the needs of the public safety community. I will tell you in all honesty -- that this has been quite a difficult task, particularly since the auction must start by April 15. Nevertheless, we have already made progress on the tough question of how to auction the spectrum while doing something meaningful for the public safety community. While I can't divulge our internal thinking we greatly appreciate the work and fast response of members of the public safety community as we've grappled with these issues. WTB Initiatives As you can see, we have a lot on our plate these days both on the public safety front and beyond. In order to better meet the needs of the public safety community during this period of dynamic growth and change for the wireless industry as a whole, we are in the midst of several steps to improve our processes. First, as part of a larger proposal to reorganize and streamline the Wireless Bureau's functions, we plan to ask the Commission for approval to rename what is now the Private Wireless Division to become the Public Safety and Private Wireless Division. Along with that change, I anticipate that in the near future we will add a new Deputy Division Chief for this group, who will coordinate our public safety efforts internally, as well as promote our outreach efforts to State and local as well as Federal public safety agencies. In addition, this Deputy will also chair a new internal Public Safety Task Force for the Bureau, which will serve as the focal point for coordinating our efforts on all the different public safety efforts I've mentioned. And finally, we will continue to improve on the public safety homepage we recently established as part of our Wireless Bureau Web site. As I just noted, one of the important jobs this new Deputy will assume is working with the Federal public safety agencies, and especially NTIA, in developing broader solutions to the problems now confronting the public safety community; problems that cross jurisdictional as well as geographic boundaries. We think of this effort as a necessary follow-on to PSWAC; allowing us to capitalize on the momentum that PSWAC developed and continue the cooperation that, really for the first time, brought together representatives from all areas of public safety -- police, fire, EMS -- and from all levels of government. It is only through this type of inclusive effort that, I believe, the problems of the public safety community can be adequately addressed. Conclusion In conclusion, let me say that each of the efforts I have outlined this morning are important to ensuring that the public gets the emergency services it needs, when they are needed -- whether that caller is using a wired phone at home or a cellular phone on the road. As a result of our first Report and Order on E-911 and subsequent efforts, I think the FCC has made an important and needed contribution to improving the utility and effectiveness of 911 and E-911 services. Citizens will have much better access to 911 no matter where they are, and with the addition of location information in a few years, help can be speeded to all callers as quickly as possible. The wonderful story of the woman saved by her car phone from a recent South Dakota blizzard could become so commonplace that it's no longer "news." There can be no doubt that lives will be saved as a result of these improvements, and that is something to be proud of. But I think we need to keep in mind that this is only one part of the overall public safety process. Now, the Bureau faces the difficult job of putting all the different pieces of the puzzle together. And I have the utmost confidence that -- with your help -- we can do it. I appreciate the information and advice you have already given us in all our proceedings, and I look forward to working with you as we strive to solve these important problems. The citizens of this country expect and deserve no less. Thanks for your attention.