WI-NENA ISSUES WITH 5/21/01 COALITION

 

WIRELESS/LANDLINE 9-1-1 DRAFT

  

Wisconsin NENA (WI-NENA) strongly endorses the creation of wireless/landline 9-1-1 legislation in Wisconsin. This issue was established as the top priority for the organization in 2001. Approximately two years ago WI-NENA used membership funding to develop a wireless 9-1-1 draft (which did not include landline 9-1-1 considerations) for introduction into the Wisconsin legislature. Our organization was not able to gain a consensus among PSAP administrators and the initiative evaporated.

 Wisconsin NENA, by virtue of our constitution and IRS regulations, cannot legally hire lobbyists to represent our interests with legislators. As we have discussed with membership before, our organization would be best served by reaching a consensus with the majority of PSAP administrators through education and communications. To this extent we have forwarded all information on the existing landline/wireless 9-1-1 draft to representatives of the Sheriffs and Chiefs organizations within the State.

 From April of this year until 5/23/2001 I have received (3) drafts of wireless/landline legislation prepared by a coalition of the Wisconsin Alliance of Cities, Counties Association, and Ameritech/Cingular. The drafts received were not formally distributed to our organization and no input was solicited from our official representatives. I have recently learned that there may be an attempt to have the coalition’s draft legislation added to this year’s state budget bill at next week’s Joint Finance Committee by lobbyists for the coalition. The process would be through an amendment at the Joint Finance meeting, which does not allow for a public hearing.

 WI-NENA’s main issues with the coalition’s draft are listed below, but a key disappointment is the fact that PSAP practitioners throughout the state have not been asked for consulted for input into the development of this proposed wireless/landline legislation.

 

ISSUES:

·        The structure of the wireless/landline Boards does not:

 –         provide for a tie-breaking methodology in the event of a tie vote between Telco and non-Telco representatives on the Service Boards.

–         provide for a structure that guarantees a fair representation of all regions of the state.

–         provide for a structure that guarantees a fair representation for all size PSAPs.

–         allow for direct PSAP input into the recommendations of the Service Board members.

  

·        A wireless/landline Board made up of five Telco representatives could be self-serving. The Telcos, in a fashion, would be regulating their own concerns.

 ·        There is no mention of a process for determining future IP or calling cards issues.

 ·        The “Confidential and proprietary information” protection provided to the CMRS providers prevents PSAP representatives from identifying potential Service Fund funding levels. A confidential third party does not guarantee that PSAP representatives will ever be able to access this information. The draft states that confidential and proprietary information submitted by CMRS providers may not be released to a person other then to the submitting CMRS provider or telecommunications utility without the permission of the submitting CMRS provider or telecommunications utility

·        CMRS and wireline providers are guaranteed full cost recovery (even before the initiation of services to the PSAP) while the PSAPs may not recover over 50 % of their approved costs.

 ·        PSAPs must complete full implementation of wireless or basic landline 9-1-1 implementation within one year to receive reimbursement.

 ·        PSAPs must wait until the first full month after satisfying reimbursement requirements before receiving funding from the Service Fund, while CMRS providers can receive advance cost reimbursement.

 ·        The Emergency Telephone Service Fund cost reimbursements could be too broad and inclusive for the PSAPs and Telcos.  Funding for technology could be seriously diluted by the reimbursing of personnel related costs within the PSAP or the reimbursement of CMRS research and testing of systems.

 ·        No detail is provided for the distribution of the PSAP portion of the Service Fund. Questions arise as to which PSAP receives how much funding, based upon what formula. The draft only states that available funding will be prorated among the PSAPs that have submitted written requests.

         ·        The Service Boards should be responsible for establishment of an 800 number to respond to inquiries from customers and other persons concerning the Wisconsin Emergency Fund, not the Public Service Commission. This process would allow the Service Boards direct contact with its customers, not more bureaucratic levels to move through.

         ·        If the Telco is allowed 3% for administrative costs, what are the actual existing costs for landline 9-1-1 administration.

         ·        The draft states that if there is a deficiency in the CMRS provider subaccount for a period of three months, and an excess in the PSAP subaccount, the CMRS provider shall be able to draw from the PSAP subaccount to ensure full cost recovery. Why is the reverse not true for the PSAP agencies?

 The above bullets represent only the highest profile issues WI-NENA has identified to this point with the coalition draft. Members are encouraged to further research the draft and communicate their concerns to the executive committee. A decision will be made shortly on what action WI-NENA is asking its members to take at this point. It should be noted that the sections referring to APCO/NENA jointly will not appear in the draft. Wisconsin APCO has a number of concerns with the current draft,  is working with the coalition to have changes made and does feel it is in the best interest of APCO and NENA to be represented on the boards should this bill be enacted.  WI-NENA does not support the current draft and has had no opportunity to provide input.  WI-NENA finds it inappropriate to be referenced specifically in the bill when the organization has not been involved in or aware of the draft until recently.  Please note that the Service Board authority is vast, representation on the Boards is very important and WI-NENA is keenly interested in being involved in this topic.  We hope the coalition that has started this project will recognize WI-NENA as an organization that should be involved.

 The WI-NENA executive committee is monitoring this issue very closely and will be formulating an action plan based upon what happens with the coalition’s draft in the next few days.

Issued May 30,2001