A new 911 funding model—likely including assessments charged to broadband connections—is needed to ensure that public-safety answering points (PSAPs) have the financial resources necessary to pay for the migration from legacy 911 to next-generation 911 (NG911) technology nationwide, members of a FCC Task Force on Optimal PSAP Architecture (TFOPA) working group said yesterday.

Funding 911 has been an issue for years, which is why some areas of the country still do not have emergency-calling service or utilize outdated technologies that cannot provide location information when 911 calls are made from wireless phones. With this in mind, it is important to simplify the “very complicated system of fees and reimbursements for PSAPS” in any new funding model, according to Phil Jones, chairman of the TFOPA working group exploring funding options and commissioner for the Washington State Utilities and Transportation Commission.

A draft of the working group’s report—subject to further review and a vote of approval later this year—states that 911 fees should be assessed in a “competitively neutral manner on all technologies utilized to place a 911 emergency request for assistance to a PSAP through an emergency communications device.”

This proposal is different than the existing funding models, which historically have not anticipated the adoption of new technologies being used to access 911. As a result, new technologies often are not included in the 911 fee structure, resulting in the model not being “technology neutral.”

One example of the current lack of that neutrality in the 911-funding model is disparity in collecting 911 fees from pre-paid wireless plans versus post-pay wireless plans. While 36 states have assessed a fee of typically 75 cents or $1 on prepaid wireless plans, the other 14 states have not resolved collection fee issues with pre-paid wireless plans at the point of sale (POS), Jones said.

“There’s an alleged under-recovery in the amount of $275 million from pre-paid plans as opposed to post-pay plans,” Jones said during the TFOPA meeting, which was webcast. “It’s a pretty serious allegation that several, if not many, 911 administrators believe they are being ‘shortchanged.’”

The working group recommends those select state’s rectify the pre-paid issue through new legislation.

To avoid other forms of fee-collection disparities, the TFOPA working group’s primary recommendation calls for a network connection fee to be assessed on upstream bandwidth connections through cell-phone carriers and broadband providers.

About 70% of calls to 911 centers are from wireless phones, Jones said. In an increasing number of cases, those calls are made using Wi-Fi rather than the cell-phone service—this is particularly common with “over-the-top” voice-over-IP (VoIP) offerings that have escaped 911 fees in the past. By assessing the fee to the underlying broadband connection, 911 fee collection can be equitable, broad-based and reflective of evolving technology, Jones said.

Jason Jackson, member of the working group and executive director of the Alabama 9-1-1 Board, explained the challenge of assessing 911 fees when a growing number of residents are utilizing their home broadband connections for making 911 calls instead of their cell-phone plans, where those fees are assessed.

“We made the assumptions, if the FCC continues down the path of possibly requiring over-the-top apps to connect to 911 services, [if other web-based services, like video messaging] are mandated to connect to 911, how do we assess fees?” Jackson said.

Since it would be challenging to broadly assess fees on over-the-top apps, Jackson suggests the broadband network fee as a way to more effectively collect 911 fees. The legalities and details on how to quantify the exact fee have not been finalized, but Jackson’s research found that the Internet Tax Freedom Act includes a clause that would allow 911 to collect a fee for 911 purposes only.

Anthony Montani, E911 engineering and operations director for Verizon, applauded the working group’s efforts to find a technology-neutral option for funding 911, but he questioned the feasibility of the plan. In particular, a proposal increasing the 911 fee as a customer increases bandwidth may not reflect greater usage of the emergency-calling system, so it may not be considered fair.

“I think the trick is how do you do that right,” Montani said. “I look at bandwidth, from a carrier perspective, and I think that’s evolving as fast as the applications that are arriving on top of it. I just question whether that’s a right approach.”