NENA News–December 1997

Does Your Agency Provide Equal Access?
by Toni D. Dunne, NENA Accessibility Issues Committee Chair

As many of you are aware, U.S. Attorney General Janet Reno has made ADA compliance for 9-1-1 centers one of her top priorities. This was recently demonstrated in her address to the 1997 Annual NENA Conference in Baltimore. Her message was clear and concise. Throughout her speech, she referenced various technical and operational issues as factors towards non-compliance and that we must work together to ensure access to telephone emergency services for all citizens. She also commended NENA for promoting compliance with the ADA.

NENA has been actively involved in accessibility issues since 1991 and continues to have a strong commitment towards equal access. The Accessibility Issues Committee was established to address a plethora of issues. The Annual Conference contains an ADA track where members can receive updates and learn more about the issues. NENA publications, such as The 9-1-1 Puzzle: Putting All the Pieces Together; Managing the 9-1-1 Center; Human Resource Management in 9-1-1; and Public Education in 9-1-1 all have vital information concerning the ADA. NENA has also incorporated TDD/TTY technical standards into its Generic Standards for E9-1-1 PSAP Equipment document. This document requires TDD/TTY capability at each answering position, a standard which was reinforced by Reno during her speech when she said, “Justice believes there must be one TDD per call taking position in most centers.”

While only a few agencies have been involved in Department of Justice (DOJ) investigations as a result of complaints, far greater numbers have been contacted by Assistant U.S. Attorneys (AUSAs) for compliance reviews. This project is being conducted in an effort to assist agencies to provide quality services to people who use TDDs/TTYs and minimize the potential for future litigation.

Are there any agencies that have “passed” the DOJ review? The answer is yes. Tulsa, Oklahoma, for example, took the steps necessary to ensure that they were where they needed to be in terms of compliance. They addressed all of the various components of compliance in their program: equipment, operations, training, and working with the Deaf community.

With all the available information, why then are some agencies finding themselves “out of compliance,” resulting in corrective action when DOJ “knocks on the door”? Good question. There may be a myriad of reasons, but as the old saying goes, “ignorance is no excuse.” It is incumbent for each center to take proactive steps and conduct self evaluations. Review programs and policies on an annual basis. There is no template that can guarantee compliance, however, the following checklist has been developed in an effort to assist you toward that end.


The TDD/TTY Accessibility Checklist can be used as a tool in the self evaluation process required of all agencies. Developed originally to assist agencies in Texas, this document incorporates requirements found within the ADA. It also includes questions to common issues addressed within settlement and compliance agreements. Once you have completed the checklist, you will have a better idea of areas that may need further attention in your agency.

Established operating procedures and a comprehensive training program are key to a successful emergency response system. It also reflects the agency’s commitment to the protection of lives and property in the community it serves. It is recommended that you maintain documentation of your evaluation process. If, at some time, your agency is contacted by the Department of Justice, you will have many answers readily available.

How to use this document: The following is provided as a sample of questions that should be asked in a self analysis of your 9-1-1 system and services. The more questions that are answered “yes,” the more likely the department will provide meaningful telephone emergency services to those using TDD/TTYs. If an answer is “no,” you may want to consider taking action and documenting a timeline.

ADA Compliance Self Evaluation

Have the current services, policies, and practices, and the effects thereof, that do not or may not meet the requirements, been evaluated and to the extent modification of any such services, policies, and practices is required, made necessary modification?

Has the opportunity been provided to interested persons, including individuals with disabilities or organizations representing individuals with disabilities, to participate in the self-evaluation process by submitting comments?

Has the public entity made available to applicants, participants, beneficiaries, and other interested persons information regarding the provisions of this part and its applicability to the services, programs, or activities of the public entity, and made such information available to them in such a manner as the head of the entity finds necessary to apprise such persons of the protections against discrimination assured to them by the ADA?

Does the entity that employs 50 or more persons have a published grievance procedure providing for prompt and equitable resolution of complaints alleging any action that would be prohibited by the ADA?


Does the telephone emergency response system provide the same level of service, i.e. Automatic Number Identification (ANI) and Automatic Location Identification (ALI), to all citizens, including those who call with a TDD/TTY?

In the event of individual line or system failure, is an alternative method of receiving emergency calls accessible to TDD/TTY callers?

Are all consoles that are available for receiving emergency calls equipped with TDD/TTY accessible equipment?

Is redundancy in the 9-1-1 equipment provided for? If the answer to the previous question is yes, is TDD/TTY accessible equipment included in the redundancy plan?

Does the equipment and method used to transfer emergency calls to other emergency services provide for accessibility with TDD/TTYs?

If your system utilizes automatic call distribution and includes an automatic recording to the citizen who may be put into a queue until there is an available telecommunicator, does the recording include a TDD/TTY recorded message?

Do equipment upgrade or expansion plans include TDD/TTY accessibility?

Does the recording equipment (which records incoming emergency lines) include recording the point of answer for TDD/TTYs?

Are the TDD/TTYs located where the call taker can switch from voice mode of communication to TDD/TTY without causing delay in answer time?

Can VCO (voice carry-over) and HCO (hearing carry-over) calls be handled with the current system?

If the TDD/TTY equipment has preprogrammed messages, have persons with hearing impairment been consulted regarding the appropriate language for TDD/TTY users?

Has the center explored the feasibility of or does it have TDD/TTY detection equipment installed?

Does the communications system have the capability to provide TDD/TTY access to alternative non-emergency numbers?

Can the call taker make a call back using a TDD/TTY?

Do you have a maintenance plan for the TDD/TTY equipment and procedures (including documentation) for such?


Has your agency developed and implemented Standard Operating Procedures (SOPs) for responding to TDD/TTY calls?

Have SOPs been written for TDD/TTY call handling and disseminated to call-taking personnel?

Do secondary PSAPs have the capability to answer TDD/TTY calls?

Is the standard time for answering voice calls comparable to that for TDD/TTY calls?

Do the call-back procedures include contingencies for reaching a citizen who uses a TDD/TTY?

Does the center keep entries or statistics of TDD/TTY calls?

Are there procedures for handling Telecommunication Relay Services (TRS) calls?

Has the agency developed and incorporated effective methods for transferring TDD/TTY calls to the fire department or EMS? (note: only applicable if voice calls are handled this way.)

Has the agency developed and implemented SOPs for processing silent open-line calls? Does the call taker interrogate the line for a possible TDD/TTY call? (see Title II Technical Assistance Manual)

Is there a program in place to test the TDD/TTY with the overall system?


Are there minimum TDD/TTY training requirements for telecommunicators?

Does the agency provide a comprehensive TDD/TTY training program for all call takers?

Are refresher classes provided at a minimum of every 6 months?

Is someone assigned to follow technological development through the various public safety associations and add these innovations into the training regiment?


Have members of the community who are disabled been consulted in the self-evaluation process, including the creation of standard operating procedures and the development of training.

Has a public awareness program been developed and implemented to notify citizens who use TDD/TTYs of the department’s accessibility and services?

Has the local telephone company been informed to provide appropriate information in the directory to indicate the availability of direct access to telephone emergency services for TDD/TTY users?

* the Americans with Disabilities Act: P.L.101-336, Title II, Section 35.162

Toni D. Dunne is Training & Access Specialist for the Texas 9-1-1 Commission. She can be reached at 512-305-6918 V/TDD Does your Agency Provide Equal Access?

Ten States Pass Legislation to Pay for Wireless Enhanced 9-1-1

XYPOINT review finds nine of ten states prefer statewide cost-recovery model.

With the 1997 legislative season complete in all but a few states, ten state legislatures have passed laws creating funding mechanisms to pay for wireless enhanced 9-1-1, according to an analysis by XYPOINT Corp.

The ten states with new wireless E9-1-1 statutes all impose a monthly surcharge on wireless customers designed to fund new E9-1-1 services mandated by the Federal Communications Commission. They are Arkansas ($.50 per customer), Arizona ($.10+), Colorado ($.70), Maine ($.20), Montana ($.25), Minnesota ($.10-$.32), New Hampshire (TBD), Texas ($.50), Rhode Island ($.47), and West Virginia ($.75).

With wireless E9-1-1, a wireless caller’s 10-digit phone number and general location, determined by the cell site that receives the call, automatically appear on an emergency dispatcher’s computer screen, much like “Enhanced 9-1-1” available on landline phones. Today, emergency dispatchers see blank screens when they receive distress calls from wireless customers.

Cost-recovery legislation is essential to the full implementation of wireless E9-1-1 because the FCC says wireless carriers are not required to provide wireless E9-1-1 service if the local public safety community doesn’t have the necessary cost-recovery mechanisms in place to reimburse carriers for the service.

“The good news is that many wireless carriers and public safety officials have indicated that crafting good wireless E9-1-1 policy was less contentious, more feasible and politically beneficial than many originally thought,” said Reuven M. Carlyle, vice president of external affairs for XYPOINT. “This is one of those instances when good public policy is also smart politics.”

The ten states with new wireless E9-1-1 laws join 10 others that already have either a surcharge on wireless customers or some authority to implement a cost-recovery mechanism to pay for wireless E9-1-1. States with existing wireless E9-1-1 statutes include: California (.72% of monthly bill), Louisiana (5% or $1-$2 in select parishes), Maryland ($.60), New York ($.70+), Oregon ($.75), South Dakota ($.75), Utah ($.50), Vermont (state appropriations), Virginia (local general taxes) and Washington ($.25).

Seven of the ten states with new wireless E9-1-1 laws also adopted immunity provisions to ensure that wireless carriers are not held liable when a wireless E9-1-1 call is mishandled except in cases of gross negligence. An eighth state also passed an immunity bill for wireless carriers but did not address the issue of cost recovery.

This brings to 16 the total number of states that offer immunity for wireless carriers for the provision of wireless E9-1-1 service. Twelve additional states provide no immunity whatsoever for wireless carriers, 21 states have statutes that need clarification and one state, Delaware, actually holds the wireless carriers liable for up to $1 million per incident in case a wireless E9-1-1 call is mishandled, according to a 50-state analysis of immunity statutes by XYPOINT. California, Massachusetts and other key states are currently considering immunity bills.

Across the nation, most wireline carriers currently enjoy broad immunity from liability for 9-1-1 services as a part of their tariffs with state regulators. While immunity is not a formal condition of the FCC mandate, it is a key issue to wireless carriers, which tend to support equal treatment between wireless and wireline carriers in this arena.

Carlyle noted that nine of the ten bills adopted created statewide cost-recovery systems. Colorado was the only locally based cost-recovery system to pass nationwide in 1997.

Bill Hinkle, NENA’s second vice president, has been leading efforts to help public safety officials better understand the legislative and regulatory issues surrounding wireless E9-1-1. Hinkle said he expects most states to introduce wireless E9-1-1 legislation during the 1998 sessions. He said negotiations are under way in many states between wireless carriers and public safety officials in the hopes of drafting bills prior to the start of next year’s legislative sessions, which traditionally begin in January.

The FCC is expected to finalize its wireless E9-1-1 mandate, Report & Order 94-102, in the coming months. The mandate requires that by April 1, 1998, wireless carriers provide public safety officials with the 10-digit phone number of customers dialing 9-1-1 from cellular, PCS and other wireless phones, as well as the address of the radio tower, or cell site, from which the wireless caller is connected. By 2001, wireless carriers must provide the call-back number and the location of the caller within half a block, or 125 meters, in 67 percent of all cases.

XYPOINT, a private Seattle-based company, designs, develops and markets wireless intelligent network service including wireless E9-1-1, providing location-related information to the wireless industry. The XYPOINT name, pronounced “zy-point,” refers to locating a point using the X and Y coordinates on a map. XYPOINT’s Web site can be reached at

King County, Washington – Regional 3-1-1 Feasibility Study
by Marlys R. Davis

King County, Washington is a large county in Washington State covering 2,200 square miles, bordered on the west by Puget Sound and on the east by the Cascade Mountains. Located within the county are the city of Seattle, 36 suburban cities, rural areas, two mountain passes, and two islands. A countywide E9-1-1 system was implemented in 1985 and includes 18 PSAPs which serve the population of over 1.6 million people.

When the FCC announced the reservation of 3-1-1 as an access number for non-emergency police or other government services, the initial reaction of the 9-1-1 service providers was that the implementation of another telephone system was not necessary. Our current system of 9-1-1 for emergencies and seven-digit telephone numbers for non-emergency assistance was working well and provided an excellent level of service. However, 3-1-1 at first glance looked very attractive, and interest in implementing this system was soon expressed by various elected officials throughout the governments in King County.

As a result, the King County E9-1-1 Program Office initiated a study to determine the feasibility of implementing a 3-1-1 system in King County. The timeline for the study was very aggressive, being initiated in May and completed in early September in order to allow the study results to be presented at the September meeting of the Regional Policy Committee. This committee includes elected officials representing all of the governments in King County.

The study produced important information about the health of the existing E9-1-1 system as well as assessing the level of interest in a 3-1-1 system. Assuming that other 9-1-1 systems throughout the nation may be conducting similar assessments and may be interested in learning about our experience, the results of our study are presented in this article.

Study Process

All of the cities, the police departments, the fire departments, the Medic One programs, and the PSAPs in King County were included in the study and given the opportunity to provide input into the results of the study. Each of these agencies was sent information to educate them on the 3-1-1 issue, and agency representatives were invited to attend one of two regional informational meetings.

Participating agencies were provided with information on the current E9-1-1 system, system statistics, PSAP profiles, and the PSAPs’ definitions of service. In addition, perceived problems with the existing approach of using 9-1-1 for emergencies and seven-digit telephone numbers for non-emergencies were discussed, and possible alternatives that could be used to address the perceived problems were presented. These alternatives included the answering of police, fire, EMS, and general government non-emergency calls on 9-1-1, seven-digit numbers, or various 3-1-1 system options.

Each agency was asked to complete a survey indicating their agency’s level of preference for the various alternatives. The survey responses were then analyzed to determine the overall preference among the various agencies for where and how non-emergency calls should be answered.

A 3-1-1 Steering Committee including representatives from police, fire, EMS, and the cities was formed to assist in directing the study.

All of the information presented to the study participants and the results of the research conducted in the study were compiled into a final report.

Perceived Problems That 3-1-1 Could Potentially Resolve

There are a variety of perceived problems with existing E9-1-1 systems that have been discussed throughout the nation that led to the reservation of 3-1-1 by the FCC. The following are the perceived problems with the system of 9-1-1 for emergencies and seven-digit telephone numbers for non-emergencies that were addressed in our study. Each issue is presented first (in italics), followed by a discussion of the research that was conducted in the study to determine the relevance of this concern in King County.

A. There is a perception that 9-1-1 call volumes in King County are continually increasing at greater rates than would be expected with the population growth. There is concern that due to this growth, the future 9-1-1 call volume will exceed the E9-1-1 system network, equipment, and staffing resources, causing delays in the handling of the 9-1-1 calls.

Included in the report are King County’s population and 9-1-1 call volumes for 1987 through 1997. This data was analyzed to determine the number of 9-1-1 calls per person for these years, and to assess the rate of change in this value from one year to the next. This information is presented in the two charts above.

When examining the “Rate of Change of 9-1-1 Calls Per Person,” it appears that the rate of change in the number of 9-1-1 calls per person per year is related to 9-1-1 public education. When King County’s E9-1-1 system was implemented in 1985, educational materials focused on announcing the availability of 9-1-1, and 9-1-1 was promoted as an emergency number. A study in 1987 indicated that only about 60% of the emergency calls answered at the PSAPs were received on 9-1-1. The remaining 40% of emergencies were still being reported to the seven-digit emergency numbers that were in use prior to the implementation of the E9-1-1 system. Due to this study, the public education message changed to encourage citizens to call 9-1-1 any time they needed police, fire, or emergency medical assistance. This corresponds to a steadily increasing rate of change in the 9-1-1 calls per person. In 1991, there was a perception among the PSAPs that the E9-1-1 system was being overused by the public, and too many non-emergency calls were made to 9-1-1 rather than the seven-digit non-emergency numbers. As a result, the message delivered in the educational materials was changed to instruct the public to call 9-1-1 if a police, fire, or emergency medical response was needed. These efforts were concurrent with the listing of the seven-digit non-emergency numbers on the front inside cover of the US West telephone directories. This appears to coincide with a shift in the rate of change from an increasing trend to a decreasing trend.

The population and 9-1-1 call data were used to project population growth and 9-1-1 call volumes into the future. It became apparent that the relationship of 9-1-1 calls to population has not been stable over the past ten years, and as a result, a predictable trend of 9-1-1 call volumes based solely on population cannot be projected into the future. It appears that there has been a dramatic drop both in the calls per person and in the rate of change, as can be seen in the two previous charts. However, it is anticipated that this decreasing rate of change is not sustainable. Using this assumption, a target has been established to maintain a level of 9-1-1 calls per person of between 1.1 and 1.3 calls per person into the future. This target range was then used to project 9-1-1 call volumes through the year 2010. At this growth rate, 9-1-1 call volumes are not expected to reach the 1994-1996 level until after 2010. This information is presented in the chart on page 23.

The configuration of the existing E9-1-1 system is outlined in the final report, and part of the discussion explains how the capacity of the E9-1-1 system is continually monitored, and as the 9-1-1 call volume changes, the network, equipment, and staffing components of the system are adjusted to accommodate the demand. Based on the information presented above, it is reasonable to assume that the projected 9-1-1 call volumes will not exceed the overall capacity of the E9-1-1 system.

B. Another perception is that too many non-emergency calls are made by the public to 9-1-1. Nationally, some anecdotal reports have estimated that up to 80% of 9-1-1 calls are for non-emergency requests. This is a local concern as well. These non-emergency calls tie up the 9-1-1 trunks and staff resources at the PSAPs, and may interfere with the ability of true emergency calls to receive the prompt assistance the E9-1-1 system was designed to deliver.

In order to assess this situation in King County, the PSAPs hand tallied inappropriate 9-1-1 calls for a two week period, since these calls are not currently electronically tracked. Prior to tracking these calls, each PSAP was asked to develop their agency’s definition of an inappropriate 9-1-1 call. In general, these definitions indicated that any 9-1-1 call that does not require a police, fire, or emergency medical response is an inappropriate 9-1-1 call. In addition to tracking these calls, the total 9-1-1 calls and total seven-digit calls, both of which are electronically tracked, were also recorded to allow for a comparison between the three statistics.

Countywide, these statistics showed that only about 6% of the 9-1-1 calls in King County were inappropriate calls, according to each PSAP’s own definition. This is far below the perceptions being made on both a local and a national level. There were a few jurisdictions in which the inappropriate 9-1-1 calls make up a much higher percentage of the total 9-1-1 calls, but in general, the percentage of these calls was consistently low. In addition, countywide, close to 50% of the total calls answered at the PSAPs were seven-digit calls. When removing the City of Seattle from the statistics, this statistic went up to 62%. In addition to indicating that the citizens of King County do not abuse 9-1-1 by making inappropriate 9-1-1 calls, the statistics also showed that half of the calls received at the PSAPs were seven-digit calls, which indicates that the public was responsibly making the decision to call seven-digit numbers when they needed information or non-emergency assistance.

C. There is also a perception that the complexity of jurisdictional boundaries in King County makes it difficult for the public to know which seven-digit numbers to call for various government services. With 37 cities, 36 police departments, including those cities which contract with the King County Department of Public Safety for service, and 36 fire departments, it is difficult for citizens to know which agency to contact when they need to call for information or non-emergency assistance. In addition, although some of the telephone companies list the seven-digit non-emergency telephone numbers for the police and fire departments on the front inside cover of the telephone directories, it may be too difficult and confusing for people to locate other seven-digit numbers in the blue and white pages of the directories. Due to this confusion about jurisdiction and the inability to locate telephone numbers, the public may call 9-1-1 as a last resort.

In addition to the fact that half of the calls received at the PSAPs are seven-digit calls, the majority of the agencies who completed their surveys indicated that listing the non-emergency telephone numbers for the police and fire departments on the front inside cover of the telephone directories, and other general government telephone numbers in the blue and white pages of the directories, was highly effective. Currently, US West is the only telephone company listing the non-emergency numbers on the front inside cover of their directories, and some of the respondents commented that these listings need to be included in the telephone directories published by all of the telephone companies. In addition, comments indicated that work needs to be done to redesign the general government listings in the blue and white pages to make these numbers more easily identifiable.

D. Another concern is that many general government offices are only open to provide service Monday through Friday during business hours, and only answer their seven-digit telephone lines during these hours. Since these lines are not answered evenings, nights, and weekends, when people need service during these times, they may call 9-1-1 because it is the only number that is answered continuously, even when they know they do not have a police, fire, or medical emergency.

In order to allow this perception to be analyzed, information was collected from each of the agencies that participated in the study regarding their business hours and the hours their public phone lines are answered. In general, the responding agencies indicated that for most cities and fire departments, the offices are staffed and the phone lines are answered Monday through Friday during general business hours. Many of the fire department business lines are forwarded to a fire station after hours, and these lines are answered when fire personnel are in the station. Approximately two-thirds of the police departments are accessible either by phone or at their department’s offices 24 hours per day, seven days per week. The remaining one-third of the police departments are only accessible for non-emergency or business service on weekdays during the business hours.

Although many general government offices are only open Monday through Friday during business hours, the fact that only 6% of the 9-1-1 calls are inappropriate indicates that this is probably not creating a great problem for the E9-1-1 system.

E. There is also a perception that the number of 9-1-1 calls drives the number of police responses, and that during peaks of multiple emergency events, delays in response times are due to the high number of 9-1-1 calls. In fact, this perception is what drove the U.S. Department of Justice to request the reservation of 3-1-1.

In actuality, the number of police responses and police response times are somewhat independent of the numbers of 9-1-1 calls. All of the PSAPs in King County who answer 9-1-1 calls for police departments have differential police response policies. Police officers are not dispatched on every 9-1-1 call. The 9-1-1 calls are screened, and most are either handled by the 9-1-1 call taker, or transferred to other more appropriate agencies or to a secondary operator, where the call is handled or a report is taken over the phone. As an example, through the use of a differential police response policy, the Seattle Police Department only dispatches police officers on 34 – 36% of their calls.

Other police departments around the country don’t necessarily use selective dispatch policies. For example, prior to the implementation of their pilot 3-1-1 system, the Baltimore Police Department has indicated that they had a policy of dispatching police officers on every 9-1-1 call in which the caller requested assistance. Statistics included in the “Baltimore Police Department Communications Division 3-1-1 Non-Emergency Telephone Number Six Month Program Evaluation” which was distributed at the 1997 national NENA conference in Baltimore showed that this department dispatched police officers on 75% of their 9-1-1 calls in 1995. These dispatch policies had a significant impact on police resources in the City of Baltimore, but that impact was attributed to the high number of 9-1-1 calls. It is important to note that it appears that simultaneously with the implementation of their 3-1-1 pilot project, the Baltimore Police Department also began using a differential police response policy.

F. The final assumption that was discussed in this report is the view that implementing a 3-1-1 system will enhance community policing efforts. In fact, it was the U.S. Department of Justice’s Office of Community Oriented Policing Services that asked the FCC to reserve 3-1-1 for this purpose.

It was very interesting to hear via the comments at the regional informational meetings held as part of this study process that the police departments in King County do not share the view that implementing a 3-1-1 system will enhance community policing efforts. The police departments who were represented at these meetings agreed that they want people to know which jurisdiction they are in. They want people to call a specific police agency when they need assistance. These departments feel that there is identity in a telephone number, and the public learns their telephone number and identifies their particular police department with that number. The police departments are concerned that 3-1-1 will make all of their departments generic. Their citizens will no longer need to know which department serves them. Therefore, our police departments see 3-1-1 as being contrary to their community policing efforts. They want their citizens to be actively involved in the community policing process, and to know their local police department, the telephone numbers to access it by, and the police officers who provide the service.

Perceived Alternatives That Could Be Used to Address the Perceived Problems

Following the discussion of the perceived problems with the existing E9-1-1 system, the following possible alternatives which could be used to address the perceived problems were presented.

One alternative would be to continue the current system, with the public calling 9-1-1 in emergency situations and seven-digit numbers when they need non-emergency assistance or information. The capacity of the E9-1-1 system would continue to be evaluated on a routine basis and network, equipment, and staffing would be adjusted to accommodate the changes in call volumes. In addition, public education on the appropriate use of 9-1-1 and the seven-digit non-emergency numbers would be continued.

Another alternative considered was to continue the current E9-1-1 system and implement an enhanced 9-1-1 public education program. Currently, the King County E9-1-1 Program Office provides public education material on the appropriate use of 9-1-1 to the local jurisdictions for their use in public education programs. Because the message is delivered at the local level, there has been no organized, county-wide effort to educate the public on the use of non-emergency seven-digit numbers for public safety agencies. In this alternative, a county-wide public education campaign would be undertaken to further expand the message of appropriate use of 9-1-1 and the seven-digit non-emergency numbers.

Another option would be to modify the existing approach and allow the public to call 9-1-1 for information or non-emergency situations, and to discontinue public education efforts regarding the appropriate use of 9-1-1 and the seven-digit non-emergency telephone numbers.

The implementation of a 3-1-1 system was presented as another alternative for solving the perceived problems. One decision that would need to be made when considering this alternative is to determine which services would be accessible through 3-1-1. Should 3-1-1 provide access to non-emergency police services only, or should fire, EMS, and/or general government services also be accessible through 3-1-1? Agencies were asked to evaluate the appropriateness of using 3-1-1 to access each of these types of services.

There are many models of 3-1-1 systems that could be implemented. The following models were considered in this study: 3-1-1 calls answered at PSAPs by 9-1-1 call takers; 3-1-1 calls answered at PSAPs by separate 3-1-1 call takers; 3-1-1 calls answered at a separate call center; 3-1-1 calls answered at multiple 3-1-1 call centers that correspond to the existing PSAPs; 3-1-1 calls answered at a local government agency; 3-1-1 calls answered by an automated answering system with information menus; and 3-1-1 calls answered by an automated answering system with menu driven routing to the appropriate seven-digit telephone numbers.

Preferred Alternatives Selected by Participating Agencies

Each of the agencies participating in the study were asked to complete a survey indicating their level of preference for where and how non-emergency calls should be answered. In analyzing the survey results, responses from police, fire/EMS, cities, and PSAPs were looked at separately and collectively. These four groups consistently responded in a similar manner, so they were discussed as one group in the study report.

The strongest preference indicated in the surveys was for non-emergency calls to continue to go to the seven-digit non-emergency telephone numbers. 86% of the responding agencies rated this alternative as their strongest preference. There were no agencies that indicated that this alternative did not meet their needs.

The second highest rated alternative was to have non-emergency calls go to 9-1-1.

None of the 3-1-1 alternatives were highly rated. The percentage of agencies indicating a strong preference for 3-1-1 ranged from 16% for the 3-1-1 option where calls are answered at the PSAPs by separate 3-1-1 call takers, to 3% for the automated answering system with information menus. In the summary ratings presented in the report, ratings of the individual 3-1-1 options showed that 57 – 77% of the responding agencies indicated that none of these 3-1-1 alternatives met their agency’s needs.

3-1-1 System Costs

Although responding agencies did not indicate strong support for any of the 3-1-1 alternatives, the 3-1-1 Steering Committee selected two alternatives to be further defined so that cost estimates could be developed.

The option where 3-1-1 calls are answered at PSAPs by separate 3-1-1 call takers was estimated at $4,593,721 for one-time installation costs, and $11,233,033 in ongoing annual operating costs.

These costs include ANI, ALI, and selective routing costs. With the complexity of PSAPs and jurisdictions in King County, and with the assumption that emergency calls would be received on 3-1-1, it was determined that these features, if legally available, would be necessary if a 3-1-1 system was to be implemented. It was also anticipated that 3-1-1 call volume would be significantly higher than existing seven-digit call volume at the PSAPs. This is due to the ease of use of 3-1-1, and due to the fact that not all of the PSAPs currently answer the seven-digit non-emergency telephone lines for the agencies they serve. In addition, the assumption that general government services would be accessible through 3-1-1 was also used. Due to the high 3-1-1 call volume that was anticipated, the number of 3-1-1 answering positions installed at the PSAPs was assumed to be equal to the existing number of 9-1-1 answering positions. The PSAP equipment costs to equip these additional positions included the expansion of the E9-1-1 and telephone equipment, but did not include the cost of Computer Aided Dispatch or other equipment expansions. PSAP staffing cost estimates for staffing the additional 3-1-1 call answering positions were also included.

The other alternative for which a cost estimate was developed was 3-1-1 calls answered by an automated answering system with menu driven routing to the appropriate seven-digit telephone numbers. The installation of this type of system would require the same components as the previously described system, without the addition of PSAP equipment and staff, and with the addition of an automated attendant system. The cost of this system was estimated at $2,080,388 for one-time installation costs, and $1,921,333 in ongoing annual operating costs. The installation of this type of system may increase the staffing needs at the agencies which the 3-1-1 calls would be transferred to. The cost of this staffing impact was not included in this cost estimate.

3-1-1 Implementation Regionally or by Individual Jurisdictions

One of the policy issues that needed to be discussed prior to the implementation of any 3-1-1 system in King County was whether the system would be implemented countywide, or whether individual jurisdictions could implement 3-1-1 within their service area only. The FCC ruling allows for the potential of individual local governments implementing 3-1-1 to provide access to different types of services. It seemed imperative that if any further consideration was given to the implementation of a 3-1-1 system, an agreement must first be reached countywide on which non-emergency services would be accessible through 3-1-1. In addition, if 3-1-1 was implemented in individual jurisdictions, challenges in the routing of the 3-1-1 calls and in public education must be overcome in advance to reduce the adverse impact this service would have on citizens outside the 3-1-1 serving area.


After reviewing the results of this study, the 3-1-1 Steering Committee recommended that a 3-1-1 system should not be implemented in King County at this time. The research showed that our E9-1-1 system is not currently overburdened with non-emergency calls, and that the public is responsibly using the system. Overall, only 6% of the 9-1-1 calls received at our PSAPs are inappropriate, and close to half of the total calls to the PSAPs are already received on the seven-digit non-emergency numbers. In addition, an analysis of 9-1-1 call volumes indicated that the rate of change in 9-1-1 calls per person has been decreasing over the past five years, and projections indicate that future 9-1-1 call volumes will grow at a manageable rate. These statistics are consistent with the assessment of the cities, the police and fire departments, and the PSAPs, that the existing E9-1-1 system, along with the use of seven-digit non-emergency numbers, works well today.

In addition, the survey results indicated that there was not strong interest in the implementation of any type of 3-1-1 system by the police departments, fire/EMS departments, cities, or the PSAPs when these agencies were analyzed as groups. There was some interest indicated by individual agencies, and the 3-1-1 Steering Committee recommended that if any of these jurisdictions decide to proceed towards the implementation of a 3-1-1 system, they do so under some form of countywide agreement regarding the services which would be accessible through 3-1-1. In addition, the impacts of this decision on surrounding jurisdictions should be addressed in a regional forum, in advance of a decision to proceed.

The survey ratings and several comments indicated that public education efforts on the appropriate use of 9-1-1 and seven-digit non-emergency numbers should be increased, and expanded to a county-wide campaign, including the use of the media. In addition, the survey comments indicated that the listing of the seven-digit non-emergency numbers should be included on the front inside cover of all of the telephone directories and that more could be done to clarify the information presented on this page. The 3-1-1 Steering Committee recommended that efforts should be made to follow through on these recommendations.

The Steering Committee also recommended that the E9-1-1 Program Office continue to monitor the 3-1-1 evaluations being conducted by others throughout the nation to determine their impact on the feasibility of a 3-1-1 system in King County. As vendors work to develop 3-1-1 technology and make this service available, it was also recommended that the E9-1-1 Program Office monitor these services to determine their viability in King County.

At the writing of this article, the final report on this study had been presented to the Regional Policy Committee in King County, and the above recommendations were approved.

I have included only the highlights from our 3-1-1 feasibility study in this article. If anyone would like further information on the study, please feel free to contact me at (206)296-3911 or by e-mail at [email protected].

Marlys R. Davis is King County E9-1-1 Program Manager.

In My Opinion: Why Three-One-One?
By Bob Oenning

The following views are expressly those of Bob Oenning. They should not be confused with nor they are representative of those of NENA or of the Washington Enhanced 9-1-1 Office.

I’ve been managing public service telecommunications for twenty years, with enhanced 9-1-1 being the focus of my life since 1984. When the President of the United States began promoting 3-1-1 to save my 9-1-1 systems, I felt personally insulted. I know 9-1-1. What does he know about 9-1-1 except how to dial it? I’m sure Bill Clinton must have heard that 9-1-1 was overloaded from somebody, possibly from one of the evening network television tabloid news programs. Like the practiced politician he is, President Clinton jumped on what was obviously a good idea. What a campaign idea, better than apple pie, goes right to the heart of concerned Americans, and the other guys hadn’t thought of it first. Be the savior of 9-1-1. It made great press, possibly even a point or two in the polls.

However, many 9-1-1 systems do not have a significant workload problem caused by inappropriate calls. Much of the nation doesn’t even have 9-1-1, let alone Enhanced 9-1-1. So what does the President’s assumption do? Unfortunately, it takes on a life of its own, including funding for 3-1-1 test systems with federal money. Major equipment suppliers jump in to show off their product. Those Justice Department funds could have been utilized to improve 9-1-1 service, to help educate citizens on the correct use of 9-1-1, or even to draft legislation that would have provided 9-1-1 with the same liability immunity that the telephone companies enjoy. No, federal funds are spent on installing a limited functionality 3-1-1 system with a major program to educate citizens on when to use 3-1-1. The publicity machine that feeds on pan flashes and sound bites gobbles it up and regurgitates it to most of the country. So now everybody knows 9-1-1 is in trouble, and 3-1-1 is on its way to save poor, old 9-1-1.

I started getting into a major huff, but after doing some checking and a lot of reflection, I’ve come to the conclusion that the President may have been partly correct. 9-1-1 does need some help to cure inappropriate use. But 3-1-1 may not be the answer. And public education programs may not be what is needed, either. The real culprit may be the phone directory.

Try to find specific government service listings in almost any urban area. You will probably strain your patience, particularly in those metropolitan areas with multiple, adjacent cities. Now try it with an excitable two year old in your arms and a screaming five-year-old who wants you to do something because she just noticed the neighbor’s Fluffy lying in the street, probably quite dead. Then, when you finally get the number for the Humane Society (who has a contract for animal control), the line is busy. When citizens cannot get a response, either because they can’t find what they want in the directory or because the service provider doesn’t answer the phone, they can hardly be faulted for dialing the number that works Ñ 9-1-1.

3-1-1 just may make sense to give the citizens a simple, easy-to-remember number for access to non-emergency services. 3-1-1, as proposed, installs a live, thinking human who can direct the call appropriately between the caller and the service provider. With automatic number identification and some computer/telephone interface equipment, a properly designed 3-1-1 system could allow the attendant answering the call, after a little interrogation to determine just what is wanted to instantly direct the call to the appropriate agency.

But it will not be easy to implement. Each local government is unique and may handle calls about a particular service in a significantly different manner. A number (3-1-1) where the attendants need to route calls for complex issues as variable as permits (parade or building), licenses, from cats to adult entertainment is not going to be easy to put into place. It will require significant resources, for which there is no funding mechanism. And once it is operational, will it become the catchall for virtually all other questions a citizen might have?

Government services should be easily accessible by simply looking them up in the phone book. A 3-1-1 system wouldn’t be needed if officials would stoop to the task, and it is a hard task, of putting in place functional coordinated service listings that permit citizens to quickly find the correct phone number and call directly to the provider responsible for service delivery.

What if the only thing that changed were those directory service listings? What if that is all it would take to direct the citizens to the correct place with no new system? That is a great place for public officials to start to solve the problem of inappropriate calls to 9-1-1. There is even a role for the President. He could mandate that the federal agencies in an area cooperate with local officials to develop integrated, functional services listings. If there is an overwhelming desire to spend federal money, why not have one of the federal agencies form a team of listing experts, backed up with Internet resources, to help local agencies develop the integrated listings which could be made available to directory publishers or even the citizens directly. Maybe even a map-based, click-and-point web page of governmental services could be designed. Once that was done, implementing 3-1-1 would be much simpler, but then it also probably wouldn’t be needed.

Bob Oenning is E9-1-1 Administrator for Washington State E9-1-1. He lives in Tacoma, Washington.

The Wireless Cost Recovery Challenge
by Jim Nixon

Even before the FCC mandate for wireless E9-1-1 was issued, industry experts were asking themselves: “Can we do it?” As a result of the numerous field tests conducted thus far, several approaches hold promise for national application as solutions to the technological implementation problems.

Another big question concerning wireless E9-1-1 is: “How will we pay for it?” This question must also be answered before widespread implementation begins. Can it be done before the April 1, 1998, Phase 1 deadline and how can we provide cost recovery for the more expensive implementation of Phase 2 by its 2001 deadline? A logical approach to any large task is to break it into smaller, more manageable pieces. In this case, establish a foundation with the Phase 1 solution and build upon it to handle the much more extensive needs of Phase 2.

General Issues

Citing the success of its decision to delegate land line 9-1-1 implementation details to the states, the FCC also left development of wireless cost recovery systems to state and local governments. As tedious as it sounds, this could mean each jurisdictional 9-1-1 manager must sit down with all of the wireless carriers in their area and develop a local cost recovery plan. This task is unpleasant when viewed from either perspective.

Carriers dread the thought of having to configure their accounting systems to handle a different set of cost recovery rules for each of the hundreds or thousands of cities and counties in which they operate. Local 9-1-1 funding methods include surcharges on telephone lines, percentages of the total telephone bill, and property tax rates among others. Each of these methods could require a unique routine within each carrier’s system.

Government managers cringe at the thought of establishing and maintaining individual agreements with the numerous carriers in their area. Each carrier could have a different set of organizational and technical needs, including vastly different accounting software capabilities and limitations. Keeping track of these agreements would further burden their already overtaxed resources.

State or regional 9-1-1 authorities, where they exist, may be able to simplify the task by establishing a single solution applicable throughout their jurisdiction. A regional cost recovery system should be attractive to carriers and government managers since it would minimize their administrative burden. A regional system could also help maintain a level playing field for all carriers.

In those areas lacking regional agencies, Ad Hoc consortiums of jurisdictional managers addressing cost recovery could be an option. By matching consortium membership to wireless market areas, interested parties throughout the area could hammer out a uniform approach to cost recovery. Although some adjustments might be necessary due to differences in fee collection legislation, this approach would significantly reduce the complexity of the overall task for both sides.

Phase 1 Equity

Regardless of the local 9-1-1 funding approach, one issue which must be addressed is fairness. Equity seems to demand that wireless carrier 9-1-1 start-up costs should be supported by public funds to the same degree we supported land line carriers. Given the sometimes vast technological differences between land line and wireless systems, determining which costs meet this criteria may not be an easy task.

In those areas where wireless is not covered by Public Service Commission type tariffs, wireless 9-1-1 price structures and rate adjustment mechanisms may also need to be developed. Industry differences will often prevent the direct application of land line pricing to wireless. For example, trunk or other charges based on the number of customers is a common land line cost recovery mechanism. In the extremely competitive wireless arena, however, customer counts are closely guarded proprietary information. Competitors could simply divide the billed amount by the price per customer and arrive at the carrier’s customer count. Without some way to screen these figures it is very doubtful wireless carriers will accept this approach.

Despite these industry differences, Phase 1 presents the most direct opportunity for equity with land line start up costs. PSAPs could pay to install and maintain any new trunks needed for wireless 9-1-1. This is generally the approach taken with land line carriers and it represents a basic PSAP operating cost. Additional revenues collected from wireless 9-1-1 fees could pay for these new expenses. Applying the wireless fees to general operating costs also makes sense because PSAPs use the same personnel, equipment, and facilities to answer 9-1-1 calls from the land line and wireless systems.

Certainly this approach to Phase 1 cost recovery must accommodate legislative differences and local precedent. It does, however, provide a basic framework for local cost recovery systems while maintaining equity between land line and wireless 9-1-1 start up cost funding. It also provides a foundation upon which Phase 2 cost recovery systems can be built.

Long Range Cost Recovery

The much higher costs anticipated for Phase 2 implementation must be addressed now if we hope to meet the 2001 deadline. Estimates of $50,000 per cell site and 20 to 30 sites per county are not uncommon today. Although these costs will probably drop as the technology is refined, it is simply not realistic to expect wireless carriers, much less government agencies, to accumulate sufficient funds unless they start planning soon. There seem to be two common opinions on this issue.

Some believe cost recovery means government reimbursement to wireless carriers for expenses incurred to provide 9-1-1 services. This means each jurisdiction must pay for all of the infrastructure required to provide its wireless 9-1-1 data. Unfortunately, radio waves do not stop at jurisdictional boundaries. To make this approach work, costs for each cell site would have to be apportioned among all jurisdictions served–40% paid by county A, 20% by county B, 25% by city C, and 15% by town D. Every time the carrier makes system adjustments the formula would have to be recalculated. Site adjustments to improve call quality, etc. are so common in the wireless industry some form of “tweaking” is performed almost daily.

This approach would also cause problems in high volume commuter or tourist areas. The heavy traffic in these areas means a larger number of wireless 9-1-1 calls and a correspondingly more robust infrastructure. The surcharges or tax rates paid by residents would never be adequate to pay all carrier costs. The cumulative result of this approach could be a budgeting nightmare for the PSAP manager, higher local taxes to pay for services primarily used by non-residents, and insufficient revenues to pay carrier costs.

The other opinion on cost recovery is that public funds should not be used for infrastructure upgrades which have obvious and substantial commercial value. The Strategis Group, which conducts market research for the wireless industry, predicts revenues from five wireless location applications could reach $8 billion per year in a mature market. Very few wireless carriers will choose to ignore this opportunity.

If public funds are used to make these upgrades, should any future commercial use of the technology require repayment of the public funds? At first this appears to be an attractive compromise. Pay for 9-1-1 location equipment now and have the public funds paid back later by commercial users. Keeping track of new carriers, mergers, name changes, and determining which have closed their doors would be a full time job. Considering the pace of innovation and the potential size of the market it will not get easier any time soon.

Are carriers willing to pay for these upgrades as an investment in future location services rather than seeking cost recovery from public funds? This could give them an opportunity to build a better commercial location service than their competitors and position themselves for market leadership. In an industry which so enthusiastically embraces the free market system this would seem to be a powerful motivation.

The logical question from a future consumer would be “How is your location service better than Brand X?” In this case the underlying product is location determination and the truly valuable differences will be in the accuracy of the location data itself. Improved accuracy will be unlikely unless a carrier builds its own infrastructure which incorporates more advanced location technology than is used by the competition. Will governments be expected to pay for these upgrades since it is their equipment? Allowing market forces to drive location technology, without forcing governments to pay for initial or future improvements, seems the only logical answer. Public safety may get the technological ball rolling but the $8 billion annual market will ensure future development.

No Easy Solution

Working out local cost recovery solutions is going to take time, commitment, and a lot of good faith on both sides. Hopefully, issues discussed here will make the process easier. Much remains to be done on cost recovery issues before we can hope to meet the FCC deadlines. More important than the deadline, however, are the additional lives we can save by working through the issues and bringing wireless E9-1-1 to the public who depend on us in their times of greatest need.

Jim Nixon is the 9-1-1 Coordinator for the State of Maryland. He has a B.A. degree in Criminology and a master’s degree in Public Administration. He can be contacted at 410-764-4009 or [email protected].

Copyright 1997–NENA News Magazine