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Good morning Mr. Chairman and members of the Subcommittee. And thank you for
giving Verizon the opportunity to testify and present its views on E911.
My name is Michael O'Connor, Director of Federal Regulatory Affairs for
Verizon. In that capacity, one of my responsibilities is managing E911 policy
issues throughout the Verizon footprint. Additionally, I am a member of the
National Emergency Number Association (NENA), and a member of the NENA Strategic
Wireless Action Team (SWAT) initiative.
As an initial matter, let me define my understanding of the term
"wireless E911". My view is that wireless E911 is the capability to
determine the location, in terms of latitude and longitude, of a caller who
dials 911 on a cellular telephone. This is sometimes referred to as wireless
Phase II capability. To make this work, the wireless provider must transmit
information sufficient to make this determination and the agency providing the
911 service must have the equipment required to use this information.
One might ask, "What is the role of a Local Exchange Carrier (LEC) in
enabling the provision of wireless E911 capabilities?" The LEC typically
provides various connections and services to get the E911 information from the
wireless provider and the government agency operating the 911 service. These
services include: 1) Links ordered by CMRS carriers to our E911 tandems
(sometimes called Selective Routers). Links ordered by Public Safety Answering
Points (PSAPs) to connect our E911 tandems to the PSAP location. 2) Customer
Premise Equipment (CPE) that allows PSAP personnel to interpret location data.
3) Connections to wireless information databases that contain location
information. The LEC can also serve as project manager for wireless E911,
coordinating and facilitating the activities of the other participants. This
coordination and facilitation is critical to the timely deployment of the
wireless E911 capability. The Verizon telephone companies have established a
reputation as an industry leader in supporting wireless E911 implementation.
This reputation was acknowledged during the recent "E911 Coordination
Initiative" hosted by the FCC. Steve Marzolf, public safety communications
coordinator for the Commonwealth of Virginia stated, "I would be remiss if
I did not also mention the support and commitment we have received from our
local exchange carriers, Verizon and Sprint. They have been proactive with
system upgrades." Steve Marzolf further stated, "They (Verizon and
Sprint) have been a strong member of the deployment team almost from the start
of the project. I know many other states and PSAPs have complained. We've heard
here today about problems with the local exchange carriers being an impediment
to progress. I'm very pleased to say that's not been the case for us."
Comments such as these are not isolated perspectives. Verizon local telephone
companies have been able to attain and maintain a leadership position in
wireless E911 deployment through several corporate policy initiatives.
Foremost among these initiatives, Verizon has created an internal wireless
implementation team that works with CMRS carriers and third-party providers in
developing, implementing and testing wireless E911. At the request of PSAPs or
state 911 boards, this team has visited and provided expertise to more than 1100
PSAPs. Verizon currently serves as the E911 coordinator for approximately 2000
PSAPs.
One of the goals of these visits is to educate PSAPs about the way in which
LEC and CMRS networks function. This education process includes providing
descriptions of the different technologies used to provide wireless E911,
reviewing call flow when the technologies are deployed, and explaining the
activities PSAPs need to undertake to accomplish wireless E911.
Additionally, the Verizon telephone companies are currently ready to meet all
regulatory deadlines for wireless E911 deployment. In 2002, then Chief of the
Wireless Telecommunications Bureau, Sugrue, requested the largest local exchange
carriers to provide information about their readiness to carry out their roles
in wireless E911 deployment. At that time, Verizon reported its ability to
handle any PSAP or wireless carrier request for wireless E911 service within the
deadlines established by the FCC's rules.
Lastly, Verizon has established a policy of safety first, tariffs later. One
of the often heard reasons for the delay in wireless E911 implementation has
been that the E911 system providers have been unwilling to deploy the technology
until state tariffs for additional services have been established. Verizon
believes that all E911 system providers must be allowed a fair return on their
investment. Nonetheless, we have established a policy that, to the extent tariff
modifications are necessary, Verizon would complete the implementation efforts
for wireless E911 deployment, whether or not the tariff changes had made their
way through the approval process.
So, that is what Verizon is doing to help deploy wireless E911. But the
salient question for this morning is "What can be done to move the process
forward and achieve the goal of universal availability of wireless E911 Verizon
suggests the following principles are fundamental to achieving that goal:
First, public funding should be used to support the universal availability of
wireless E911. E911 service is not simply a useful option for wireline and
wireless customers - it is widely acknowledged to be a public safety feature
that benefits the entire community. Customers use E911 service not only to
report their own emergencies, but also to report events that involve other
persons, such as accidents, health emergencies, crimes, and natural disasters.
In particular, all of society has an interest in a robust wireless E911 system
that is as capable as the wireline system of providing the information that
PSAPs need to respond to emergencies. As such, public monies should be used to
support the necessary infrastructure and operational expenses associated with
providing the service.
The roll-out of wireless E911 service is hindered in most areas by the lack
of adequate funding and the use, in some states, of money from E911 cost
recovery mechanisms for other public purposes. The FCC has addressed the issue
of which types of costs must be borne by wireless carriers vs. PSAPs. However,
the issue of PSAP funding has yet to be addressed. The effect of a lack of
funding cannot be ignored. The funding mechanisms for PSAPs involve local
determinations about how to develop the financial means to implement and
maintain the service. In the current economic environment, local funding for
wireless E911 is a serious concern. Taking funding out of the equation would
promote wider and faster deployment of wireless 911 service.
In most states, funding of E911 implementation costs for PSAPs, wireline
carriers and, in most cases, wireless carriers, is accomplished through
surcharges on wireless and wireline customers. This is not an optimum solution.
Such surcharges inflate the prices for telecommunications services and lower
demand.
Verizon believes that the development of public funding of E911 service
through general tax revenues rather than through telecommunications surcharges
serves the public interest.
As a second principle, Verizon advocates nationwide coordination of for
wireless E911 deployment and policy. The evolving nature of technology and new
types of communications services, such as voice over the Internet, will require
closer coordination for the efforts of government and private entities.
Verizon recommends that the Congress focus on two areas - creation of a
National 911 Program Office within the Department of Homeland Security, and
creation of a Federal advisory committee. The National 911 Program Office should
coordinate state and local emergency activities within the context of nationwide
security planning. The advisory committee should include representatives of all
stakeholders, including trade associations, carriers, vendors, and federal and
state regulatory agencies. The advisory committee would be a resource for
collecting information and providing analyses to assist the DHS in addressing
policy issues concerning the implementation of E911 services for wireline
carriers, wireless carriers, and new, emerging communications media, such as
handheld computers and voice over Internet technologies.
As a final principle, Verizon advocates that all constituencies that provide
wireless E911 functionality are allowed to recover costs. In the aforementioned
"E911 Coordination Initiative" hosted by the FCC, Chairman Powell
opened the meeting and had the following observation, " . . . we must work
together to move wireless carriers, manufacturers, consumers along the migration
trail for E911 capability while ensuring that the necessary ILEC capabilities
are made available in a timely manner on financially reasonable terms."
Verizon believes that the capital expenditures necessary to achieve the goal
of universal availability of wireless E911 will be enhanced when investors in
the technologies be allowed an expectation of a reasonable return. This
concludes my formal testimony. Thank you for giving me the opportunity today to
share Verizon's views on wireless E911. I would be happy to answer any questions
that the committee may have.
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