Agencies Told to Focus on NG-911 Grants but Not Exclude Deserving Areas
The 911 grant program should target funds to proofs of concept in urban, suburban and rural areas, while requiring interoperability, APCO commented this week on revised implementation rules proposed by NTIA and the National Highway Traffic Safety Administration (see 1709200043). Also in docket NTIA-2017-0002, some state and local agencies urged the agencies not to exclude certain areas from grants. The 2012 Middle Class Tax Relief and Job Creation Act made $115 million available from the Public Safety Trust Fund for the 911 grant program, which funds improvements to 911, E-911 and next-generation 911 services and applications. NTIA and NHTSA plan to award NG-911 grants in FY 2018, which started Oct. 1 (see 1701200026).
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“By focusing on model NG911 deployments for a few areas, the grant program can better serve the entire country by producing blueprints for efficiently modernizing 911 systems nationwide. This should lower costs and speed implementations,” said APCO. The agencies should require interoperability, or "deployments will be inconsistent and limited, and NG911 will be on course to repeat the challenges that have historically plagued [public safety answering points," it said. PSAP ability to dynamically share resources and reroute calls is critical in disasters and other high call-volume periods, APCO said. The group APCO supported a proposal to curb state diversion of 911 fee revenue for unrelated purposes, warning “there may be disagreement about what qualifies,” so the NTIA and NHTSA “should create a clear definition of fee diversion.”
Some protested the existing formula for determining funding, based on state population and public road mileage, as excluding areas. Many states have counties that are geographically large but have low population, commented the National Association of State 911 Administrators. "It is not possible for these extremely rural areas to generate enough revenue from 911 fees or the general tax base to pay the relatively higher costs of infrastructure and connectivity.” NASNA wouldn’t support a formula that favors states “with a large rural land mass over equally rural states with fewer square miles.”
The existing funding formula "is particularly flawed, and potentially discriminatory against mountainous states like Colorado,” said the Public Utilities Commission, proposing a formula based on population, land area and tourism rates. Many tourists frequent unpopulated mountains and forests, requiring 911 infrastructure spending not funded by surcharges on consumer phone bills, the commission said. Counting cell towers isn't a good stand-in for cell service coverage because not all towers have the same range and since 5G small-cells deployment and other developments are changing network topology, the agency said.
Large cities should be eligible for 911 grants, the Chicago Office of Emergency Management and Communications commented. It cited “expansive scope of their operations as well as their specialized requirements." Funding distribution should account for call volume, the agency added. “Population alone does not paint the entire picture … since it does not account for the added calls received by jurisdictions with a significant number of commuters" and a "significant number of tourists.”
State coordinators might not have direct authority over grant recipients’ use of 911 fees, cautioned the Texas Commission on State Emergency Communications on a proposed requirement that each state 911 coordinator certify that grant recipients don’t divert fees. Even with an agreement, the state coordinator might have to resort to litigation to enforce compliance, it said. Allowing states to collect certifications from recipients “would provide additional documentation of a direct commitment by the recipient taxing jurisdiction that the funds are not and will not be diverted, and the return thereof in the event of diversion,” it said.
NASNA and two state agencies supported an application process where an applicant first seeks certification to get a preliminary funding allocation and submits its grant application, including budget. A two-step process means applicants don’t need to develop a second project budget outside their original application and the federal agencies won’t have to solicit additional project budgets later, the Colorado PUC said.
Motorola sees a one-step process as quicker and simpler, the company commented. “Requiring 9-1-1 authorities -- many of which operate under constrained budgets with busy dockets and limited personnel -- to manage multiple deadlines with varying requirements could increase the burden on applicants, create confusion, and result in incomplete submissions.”
Some raised concerns about possible funding duplication resulting from a proposal that would allow tribes to apply directly for 911 grants. They should have that option but should be required to notify state agencies that already may be applying on their behalf, agreed NASNA and the Colorado PUC.