USDOT RFI Response


 Response to 
National Emergency Number Association
Thursday, April 28, 2005 

The National Emergency Number Association (NENA) represents the interests of its approximately 7,000 members whose sole responsibility is the effective and efficient delivery of Enhanced 9-1-1 service throughout the U.S. and Canada. Since its inception in 1982, NENA has become the leader in the development of 9-1-1 recommended technical standards and operational best practices. Its technical/operational conferences, Critical Issues Forums, and Annual Conference attract leading industry professionals to advance 9-1-1 concepts and practices. NENA is the certifying organization for Emergency Number Professionals (ENPs) and its many courses on 9-1-1 management and operations topics are attended by nearly 1,500 people each year.

In the past two years, NENA worked with Congress in support of the Congressional E9-1-1 Caucus and Institute and was a driving force behind the importance and need for the ENHANCE 9-1-1 Act of 2004. Today, as the National 9-1-1 Program Office moves toward becoming a reality, NENA is supporting the need for appropriations from Congress to establish the Office at authorized levels. NENA’s position paper in support of the National 9-1-1 Program Office is already helping to shape how that office will be structured and managed.

When wireless E9-1-1 became an issue in the mid-1990s, NENA called for the FCC to establish timelines for Wireless Phase I and Phase II implementation. Later, as the USDOT ITS Joint Program Office became involved in wireless implementation, NENA was awarded a three-year contract to assist with wireless implementation. That contract has been extended through December 2005 with additional scope proposed to respond to the GAO’s request for information on PSAP equipment needs. Subsequently, NENA leadership also participated in both the Expert Working Group and the Steering Council of the Secretarial Initiative related to wireless. A set of Priority Action Plans was submitted by the Steering Council to the Secretary to accelerate the rate of wireless deployment.

Beginning in 2001, NENA’s Technical Committee introduced the concept of a Future Path Plan for E9-1-1, a conceptual blueprint for bringing E9-1-1 truly into the twenty-first century That Future Path Plan has become NENA’s Next Generation E9-1-1 (NG E9-1-1) Program, a major industry-sponsored initiative to identify next generation telecommunications technologies and how the Nation’s E9-1-1 system will evolve as a result of those technological advancements.

NENA understands and appreciates the historical role that USDOT and NHTSA have played in the development of our Nation’s E9-1-1 system. We commend the Department for its vision to help foster NG 9-1-1. Having worked on wireless and similar implementation issues for a number of years, we recognize the importance and value of having all stakeholders involved in successful implementation. Perhaps the greatest contribution that USDOT can make is to apply its leadership, and bring together the various stakeholders, integrate the work that each is already doing, and develop an implementation plan that is workable and efficient. Because NENA has a continuous program of events throughout the year, we can offer excellent venues for stakeholder participation and involvement with industry leaders.

Implementing NG 9-1-1, however, is not a simple task. There are and will be many technical, operational and public policy matters that must be addressed. That, in itself, will require a strong educational component, one oriented toward PSAPs, emergency agencies, the public, and all levels of government (local, state, and federal). USDOT is in a particularly good position to help support such an effort.

NENA agrees that a key component of NG 9-1-1 is to integrate, consolidate, and build upon work already in progress. We are well represented in all current initiatives related to E9-1-1, including NRIC VII, ESIF, ITS America’s Public Safety Advisory Group (PSAG), the USDOT Secretarial Initiative, SAFECOM (DHS), the Global Justice Information Sharing Initiative, and a number of other initiatives and standards organizations—all essential to this process. The NG 9-1-1 program can serve as an integrating force, bringing together all those activities that impact 9-1-1 and tomorrow’s emergency services network.

We recognize, and advocate, that tomorrow’s emergency services network includes all emergency agencies, not just PSAPs. Unlike the past, we need policies, architectures, and standards that address the vital interplay across all emergency professions, across jurisdictional lines, and across public/private boundaries. In the past, PSAPs have been primarily call taking and dispatching centers. In the future, they should be emergency communications nerve centers for the agencies and organizations in their communities which are involved in responding to emergencies.

Public warning is an excellent example. NENA recognizes the importance of the Emergency Alert System (EAS) as a mechanism for warning the American public of an emergency. Our Emergency Telephone Notification System (ETNS) operations standard addresses local/regional products and services related to EAS, and can serve as a foundation standard to build on in IP enabled PSAPs. Similarly, many of our members are launching points for applications that can contact residents in targeted communities.

Consensus building is a key component of USDOT’s NG9-1-1 program. We have already seen that occur in NENA’s Next Generation E9-1-1 program in the first Policy Roundtable, where our Program Partners have reached consensus in a number of policy-related areas. We believe USDOT can help build consensus among stakeholders – an important ingredient to the success of NG 9-1-1.

The culmination of NG 9-1-1 is an implementation plan – a well-constructed approach to how next generation 9-1-1 systems can be developed, and how to migrate from the present system to a new IP based Enhanced 9-1-1 system as part of a broader IP based emergency communications network.

Responses to USDOT questions:

1.     What are the critical issues that need to be addressed to enable the deployment of advanced 9-1-1 capabilities?

There are a number of critical issues that need to be addressed, such as:

·       Education development and delivery to all forms of stakeholders on the limits of today’s outmoded Enhanced 9-1-1 design and need for evolution to meet current and future emergency communications challenges.

A majority of the stakeholders, at all levels of local, regional, state and federal, and among 9-1-1 and emergency response related industry parties, must first understand and accept these needs, and believe in the necessity of accomplishing them, and that this can be actualized. NENA has socialized these concepts within the Strategic Wireless Action Team (SWAT) process, and has produced numerous policies and documents such as the NENA Future Path Plan, the IP PSAP standard, IP technical documents, and IP policy statements, all related to the need for E9-1-1 evolution.

·       Accomplish full definition of enabling factors to allow NG9-1-1 to be attained.

Much of this has been identified by NENA, through NENA’s NG E9-1-1 Program, and in the NRIC 1B report (Sections 9 and 10 – significant content was led or provided by NENA staff and members). Among these are 9-1-1 funding paradigm change, public policy, governance, jurisdictional issues, regulatory change, legal issues, technical development, and IP-based E9-1-1 features and functions (both to meet current E9-1-1 requirements and future feature and function additions), NG9-1-1 system and service operations evolution into an open architecture and primarily open competition environment, emergency communications network establishment and operations, Public Safety operational, and IP-enabled PSAP equipment features and capabilities. It is generally assumed that equipment vendors will develop the needed PSAP equipment capabilities when there is a clear forward direction established, but this will need to be verified in practice.

·       Develop key Facilitation Services

While the vast majority of the applications in the future emergency networks should be fully competitive, the NRIC 1D report notes the importance of having a handful of Facilitation Services to allow secure and effective interoperability between all the emergency response agencies, data bases, and others. These services would be developed and operated on a non-profit basis by the emergency response community. The Facilitation Services recommended in that report include tools and policy processes for rights management, routing directory, authentication, security, and network configuration/diagnostics. NENA is a partner in developing the Emergency Provider Access Directory (EPAD) with COMCARE and other emergency response organizations. EPAD will provide rights management and data routing.

NENA has unique experience and results in many of the above areas, through many years of technical development, 9-1-1 center operations development, and specific program work, such as the technical cost study and estimation project for wireless E9-1-1 in the NENA SWAT project (quoted in the GAO report) and numerous educational programs through the NENA Educational Advisory Board and NENA Critical Issues Forums. NENA is the only national organization dedicated to E9-1-1 evolution and implementation, and has concentrated in these areas for over twenty years.

An additional major issue is:

·       Bring public and private parties to the evolution of E9-1-1 together, and generate a convergent effort nationally, especially among current and future service providers of the various parts of the planning, development, provisioning, implementation, and service operations involved in NG9-1-1 and related emergency response operations.

While NENA’s objectives for this process included open architecture and competition, the continued and improved integrity and dependability of NG9-1-1 requires detailed standards, both system design and operationally, and performance results. Accomplishing these goals requires a common, cooperative approach and an overall national coordination effort, particularly within the relatively short timeframe demanded by the ever accelerating technology change rate.

This convergent process is precisely the goal and related actions of the NENA NG E9-1-1 Program, identified in early 2004 and implemented in late 2004. NENA also has experience in combining work on technical and operational needs among service providers, vendors, and public entities such PSAPs and related public safety authorities.

2.     What data are currently available to quantify the expected benefits, user acceptance, and costs of providing NG9-1-1 services?  


– NG9-1-1 services are expected (and being designed by NENA development) to resolve

a number of emergency communications roadblocks, such as: access to the full range of outside data sources, from homeland security, to hazmat, to telematics data provision as part of the 9-1-1 call and data sequence

– ACN call advance via the E9-1-1 systems

– More cost efficient wireless and wireline service provider access via managed private IP

network interfaces

– Access to multiple data provider services, such as supplementary telematics data, health

information data bases, etc

– Ability to access and communicate all relevant data (whether text, data, images, or video) from originating call/message sources and other accessible data providers between PSAPs, other first responders, medical organizations, and hierarchical emergency management agencies, including national defense and Homeland Security points.

– Ability to interact at both the voice and data level with all entities related to emergency


In addition to resolving a number of roadblocks, NG 9-1-1 services will help support the kind of emergency services network infrastructure that will truly facilitate information exchange, and coordinated incident management and preparedness.

With appropriate cost data for current solutions to the above (where solutions exist) added to the base data NENA already has (noted below), NENA can play a major role in the estimation of the cost benefits to result from implementation of NG9-1-1 nationally.

Quantifying User Acceptance

NG9-1-1 is expected to be implemented in levels of functionality, from managed IP networks usable for NG9-1-1 purposes, and NG9-1-1 features and functions deployment, through application level additions. As NG9-1-1 is installed and activated, a tracking process to determine user acceptance will be needed, in similar fashion to the Wireless Deployment utilization project NENA has managed for USDOT. Tracking of both quantity of service deployment and perceived quality of service across major NG9-1- capabilities should be utilized.


Based on NENA development work to date, IP-based E9-1-1 of the future (NG9-1-1) is expected to offer added benefits to the public and to Public Safety, with a significant reduction in overall cost to provide and operate. The methods developed and used to estimate costs in the NENA SWAT project will apply to similar efforts for the Next Generation E9-1-1 system nationally, as will the base data on E9-1-1 systems across the nation. This work represents critical experience in this area, having started with `Greenfield counties’ (those with no E9-1-1) and modeled costs through full implementation of wireless E9-1-1 Phase II. NENA’s PSAP Registry data, along with data compiled under NENA’s contract with USDOT, are also sources—perhaps essential sources–of national numeric quantities applicable to the costing issue.

3. What new areas of research, development or analysis would be required to support the NG9-1-1 Initiative

Monitoring and analysis of the continuing development of new user telecommunication devices and application trends is required to ensure that NG9-1-1 requirements and design are and continue to be appropriate. Given that NG9-1-1 is a three-year program, new communications technologies will likely enter the marketplace – hence the need to continuously access information on new technologies. In some cases, such activity can assist in developer recognition that E9-1-1 supportive features are required earlier in product design. R&D efforts include the determination of NG9-1-1 requirements against IP standards and needs for modifications or additions to same, as well as definition and development of NG9-1-1 features and functions within the IP networks, servers, and physical equipment associated with 9-1-1 call, messaging, and data delivery.

Development of future E9-1-1 system service performance requirements will be required, for both Migratory (I2) and IP-based E9-1-1 (I3) – NG9-1-1. Many of the performance criteria that current and new service providers for various components and service functions need to meet are scattered at best, or incompletely defined today, although most are known `informally’ by those parties that provide the equivalent functions in today’s E9-1-1 service. Others are defined in various E9-1-1 NENA standards, including the recently consolidated E9-1-1 Requirements document available on the NENA web site.

For the future, from I2 through NG9-1-1, all potential and actual service providers supporting E9-1-1 functionality must have minimum performance definitions, in order to avoid decline in the quality of service provided, due to a lack of familiarity or knowledge of the complete requirements and current performance aspects of E9-1-1 by new entrants to what will become a much more flexible, open architecture 9-1-1 system

Another R&D item involves the trend toward integration of E9-1-1 CPE equipment and Cad and radio systems on an IP base. Analysis of both the near term standalone relationships of these systems as IP and associated changes impact them, and the considerations involved in IP integration will be required. And, the interdependencies of these systems and Emergency Alerting Systems (EAS) will also require analysis and development coordination.

4. What activities should be initiated to hasten the development and deployment of advanced 9-1-1 systems?

NENA recommends the following activities be initiated:

– wide-ranging educational efforts, at all levels of local, regional, state and federal,

 among 9-1-1 related industry parties, and to the public

– governance and public policy revisions and reform

– organized fast track national standards processes (coordinated with international


– coordinated approaches to state regulatory requirements for any portions of NG E9-1-1

 that relate to regulated carrier actions

– revision of funding mechanisms at national, state, and local levels

– development of Facilitation Services that lead to standardized emergency data communications between emergency professions

NENA, through its Technical, Operations, and Regulatory/Legislative Committees, as well as the Next Generation E9-1-1 Program, has been and will continue to be focused on these and other associated issues and activities.

5. What other significant initiatives, programs, or deployments related to NG9-1-1 warrant USDOT attention?

NENA recommends that a number of initiatives, programs and deployments deserve attention. It is important to note that NENA is already involved in most of these activities, which include:

– results of trials performed by commercial and public safety entities

– EDXL national messaging standards project, sponsored by DHS

– FCC’s NRIC 1B recommendations on future E9-1-1 requirements and NRIC 1D

 recommendations on overall emergency communications requirements

– IETF IP standards activities and results

– ESIF ANSI standards activities and results

– State and federal level planning and implementation of managed IP networks applicable

 to supporting E9-1-1 systems

– Proposed state level trials

– Proposed NENA managed trials/demos

6. What specific agencies/organizations/entities are essential to the development of a comprehensive transition and implementation plan to NG9-1-1?

Public agencies at all levels – local, state, regional – must be involved in NG 9-1-1. Also included are national associations such as International City/County Managers Association (ICMA), National Governors Association (NGA), National Council of State Legislators (NCSL), National Association of Regulatory and Utility Commissioners (NARUC), National Association of Telecommunications Officers and Agencies (NATOA), and National Association of County Officials (NACO).

Associations representing first responders (e.g. International Association of Chiefs of Police (IACP), National Sheriff’s Association (NSA), International Association of Firefighters (IAFF), National Fire Prevention Association (NFPA), National Association of EMS Physicians (NAEMSP)) and the establishment of protocols (such as National Academies of Emergency Dispatch (NAED)) also will be involved as important stakeholders.

At the federal level, DHS, USDOT, DOJ and the FCC are obvious stakeholders, as are other agencies that have a significant role to play in NG 9-1-1.

Within the 9-1-1 community, NENA, APCO, and NASNA are the leaders in promoting 9-1-1 interests. Each represent separate but overlapping constituencies, yet have demonstrated an ability to work together in areas critical to the success of 9-1-1. NENA also has important strategic alliances with a number of organizations, including COMCARE and NAED, organizations that need to be included in NG 9-1-1 because of their focus on the broader picture of integrated emergency communications.

Private companies (service providers, mapping/GIS vendors, systems providers, wireless carriers, Internet Providers) are the drivers of telecommunications services, network systems, PSAP/CPE equipment and database software. Their involvement and investment is critical to the success of NG 9-1-1.

Standards organizations and focus group activities such as NENA, IETF, ESIF, and NRIC must lead in NG 9-1-1. Uniform national standards in an open architecture framework must be developed for an efficient and timely migration to IP based 9-1-1 systems. NENA has been engaged in that exact effort since 2003.

7. What is the proper forum for carrying out the necessary engagement of the various stakeholders and how might the USDOT establish that forum?

Migration to NG 9-1-1 is a complex process. There can be no single forum for the engagement of all stakeholders – rather there will be a number of forums/avenues required to be successful.

First and foremost is the need for a single source of information – call it an NG 9-1-1 “clearinghouse” – for all interested parties to go to for detailed, well-written information on all aspects of NG 9-1-1. The NG 9-1-1 Clearinghouse would have information on 1). New technologies, 2). Standards being developed and implemented, and 3). Trials, demonstrations, and first applications, 4). Policy Issues, and 5). Operations issues, particularly those that impact PSAPs, and data to track the progress of NG 9-1-1 implementation (such as USDOT’s Wireless Implementation Profile).

USDOT should leverage all the work that is being done by every stakeholder identified in 6) above. There are many ways to share information (conference calls, meetings, web sites, intranets) among stakeholders, and NG 9-1-1 must build these into the management/implementation plan.

Critical to any forum is the ability to collect and then disseminate information to all potential users (PSAPs/private companies/public agencies). This technology transfer function, while often overlooked, is critical to the success of NG 9-1-1.

All of the above could be important components of the Implementation Coordination Office (ICO) created by the ENHANCE 9-1-1 Act of 2004.

8. Would you be interested in participating in some sort of public-private partnership for the NG9-1-1 Initiative? If yes, in what way? If not, what would encourage you to participate?

NENA has a history of leadership and involvement in 9-1-1. We know the 9-1-1 environment and have worked hard with positive results to improve the quality of 9-1-1 service to all Americans. We bring talent, expertise and commitment to 9-1-1, and are recognized nationally as the leading association in the 9-1-1 profession. We would like to be involved in NGE9-1-1 in a leadership/project management role given our long-standing involvement in providing direction to the 9-1-1 industry.

NENA is already involved in next generation E9-1-1. We have brought together 22 leading companies/organizations for an assessment of next generation 9-1-1 (NG E9-1-1 Program) and the migratory process to get there. We recently convened over 300 9-1-1 professionals at the Technical Development Conference/Operational Development Conference in San Jose, California to discuss and characterize issues related to next generation 9-1-1, and to continue work by the NENA Technical and Operations Committees on developing recommended technical and operations standards for next generation technologies.

NENA welcomes the opportunity to work with other organizations and stakeholders noted throughout this response to deliver a united, directed effort to achieve the goals of this USDOT RFI rapidly and efficiently.

Comments and questions should be directed to:

Robert L. Martin
Executive Director
National Emergency Number Association
4350 North Fairfax Drive Suite 750
Arlington, VA 22203
[email protected]