February 14, 2017–The Association of Public-Safety Communications Officials-International says the FCC’s Public Safety and Homeland Security Bureau should collect additional information for its annual 911 fee diversion reports. The data should focus on next-generation 911 (NG-911), cybersecurity, text to 911, and governance, APCO said. APCO submitted comments in PS docket 09-14 in response to a report released last month by the Public Safety Bureau that concluded that eight states and Puerto Rico diverted 911 or enhanced 911 (E911) fees for other purposes during 2015 (TRDaily, Jan. 13).
“The Commission should clearly define NG9-1-1 as part of the information collection on NG9-1-1 expenditures,” APCO said. “Full implementation of NG9-1-1 should be defined as end-to-end (from the caller to the telecommunicator) IP connectivity enabling current voice communications, future multimedia, and other data capabilities to flow from the 9-1-1 caller to the PSAP and be properly reported, archived, and further transmitted between the PSAP and first responders. With a comprehensive and clear definition, the reports will more accurately represent deployments, plans, and expenditures, and thereby become more useful planning and advocacy tools.
“The Commission should also request information about how states and their vendors are ensuring NG9-1-1 components are fully interoperable,” APCO added. “A fully functional NG9-1-1 system requires completion of consensus-based, accredited standards and must include fully interoperable IP-based connectivity as well as other data capabilities and equipment within the PSAP to seamlessly report, archive, and further transmit data between the PSAP and first responders. The Commission’s information collection presents an opportunity to identify gaps and determine whether standards are incomplete or require modification.”
APCO also urged the FCC to “provide guidance about what constitutes a ‘cybersecurity program’ and seek additional information about the types of cybersecurity programs states and PSAPs are participating in and implementing. ‘Cybersecurity programs’ may be interpreted to encompass a vast array of practices and initiatives: cyber hygiene, workforce training, employing cybersecurity consultants, etc. Having a clear understanding of the efforts underway will assist with the development of much-needed cybersecurity plans to achieve effective security, economies of scale, real-time capabilities, operational efficiencies, and increased awareness among public safety stakeholders.”
APCO also suggested “that the Commission ask for the number of texts received, broken down by emergency and non-emergency, as well as the methods PSAPs use to receive texts. Data on how text-to-911 is being used and implemented nationwide – particularly in IP-capable PSAPs – will inform educational efforts and implementation considerations.” The group also noted that the Public Safety Bureau’s report “indicates that in some states the ‘funding mechanism does not allow for the use of 911 funds for NG911 implementation.’ To the extent practical, the Commission should seek additional information to better understand how laws and regulations impede the deployment of NG9-1-1. This data could help states identify optimal governance structures, enact laws that protect 9-1-1 fees, expand permissible expenditures for NG9-1-1, and ensure sustainable and sufficient funding going forward.”
Joe Barrows, the executive director of the Kentucky 911 Services Board, said, “After eight reports it’s now clear that diversion of 911 fees by states is not pervasive and is not a major contributing factor to the lack of available funds for providing 911 services (except in the very few states that do it consistently in large sums). Eliminating fee diversion does nothing to address 911 funding issues in the vast majority of states nor does it impact the provision of 911 services in those states.” However, Mr. Barrows said that the Commission “should continue to monitor fee diversion in its survey because there is almost unanimous agreement among 911 advocates and providers that fee diversion is ‘wrong’ which can sway policy makers. Federal legislators and agencies should encourage ‘no diversions’ by making it a condition for receiving federal grants. Otherwise, it’s time to look for other factors which have a much greater impact on 911 funding.”
Mr. Barrows also said the Commission’s “survey should continue to collect data on the total cost for 911 services in each state counting both state and local expenditures; the revenue sources that pay for 911 services from all sources; and the relative contributions from each source to the total cost of providing 911 services.”
The filing also said that “it will be difficult to get solid data on whether local jurisdictions engage in fee diversion in those states that have local or hybrid fee collection programs without getting others to respond to the survey.” It also said that carriers should have to break out the number of prepaid customers, which “would enable states to better monitor the collection of 911 fees on prepaid services.”
The Washington State Military Department said it “disagrees with the placement of Washington State in the category of ‘states having diverted 911 funds’, and requests that the FCC remove Washington from the list of ‘states having 911 diverted funds’” in the report.
“The Washington Military Department (WMD) operates as the state 911 administrator, and responded to question G.1 as issued in the Report in the ‘affirmative’ to indicate that all funds were solely used for the purpose designated by the funding mechanism. WMD explained in the comments block of that section that due to a lack of distinct federal definitions of diversion and funding mechanisms, and what the ambiguous term ‘E911 purposes’ means, the individual states are left to determine what constitutes ‘E911 purposes’.
“In Washington State, the purpose of the 911 ‘funding mechanism’ is defined by the Revised Code of Washington (RCW) which is Washington State Law. In 2015, the Washington state legislature wrote into RCW that a small amount of 911 funding was to be used for ‘other public safety purposes.’”
The WMD said it “supports the recommendations proposed in the FCC’s own Task Force on Optimal PSAP Architecture (TFOPA) regarding diversion practices across the nation and would support FCC actions and recommendations to assure consistency in both measure, definition, and education.”
“Guidance from the Federal Communications Commission (FCC) and clarification on what is considered ‘diversion’ or what constitutes ‘E911 purposes’ would be beneficial and timely,” it added. – Paul Kirby, firstname.lastname@example.org