Colorado Next Generation 9 1 System Review Report Submitted August

Colorado Next Generation 9-1-1 System Review Report

Submitted August 2011 to:

Colorado 9-1-1 Resource Center

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TABLE OF CONTENTS

1. Executive Summary ................................................................................................................... 1

2. Introduction and Methodology .................................................................................................. 6

3. The State of Colorado Next Generation 9-1-1 Network Requirements and Assumptions .............. 9

3.1. Requirements ......................................................................................................................................9

3.2. Assumptions ...................................................................................................................................... 10

4. Considerations ......................................................................................................................... 11

4.1. Consumer Technology and Colorado 9-1-1 .......................................................................................... 11

4.2. Next Generation 9-1-1 ....................................................................................................................... 12

4.3. The Legacy 9-1-1 System .................................................................................................................... 13

5. Technical Architecture ............................................................................................................. 18

5.1. Network ............................................................................................................................................ 19

5.1.1. Topology ................................................................................................................................................................. 19

5.1.2. Protocols ................................................................................................................................................................. 22

5.1.3. Data Communication Technologies ........................................................................................................................ 23

5.1.4. Data Management .................................................................................................................................................. 26

5.1.5. “Last Mile” Scalability and Reliability ...................................................................................................................... 29

6. Regulation ............................................................................................................................... 34

6.1 Existing Governing Bodies ................................................................................................................... 34

6.1.1 PUC .......................................................................................................................................................................... 34

6.1.2 9-1-1 Advisory Task Force ........................................................................................................................................ 35

6.1.3 Colorado 9-1-1 Resource Center .............................................................................................................................. 35

6.1.4 9-1-1 Emergency Authority Boards .......................................................................................................................... 36

6.1.5. Interworking ........................................................................................................................................................... 37

6.2 Emergency Service Delivery ................................................................................................................ 37

6.2.1. Basic Emergency Service Delivery ........................................................................................................................... 37

6.2.2. Basic Emergency Service Infrastructure ................................................................................................................. 37

6.2.3. Review of Additional Governance Models .............................................................................................................. 38

6.2.4. Colorado NG9-1-1 Authority Committee Structure ................................................................................................ 40

6.2.4.1. Next Steps ............................................................................................................................................................ 43

7. Funding ................................................................................................................................... 44

7.1. Methodology ..................................................................................................................................... 44

7.2. Research of Funding Mechanisms ....................................................................................................... 44

7.2.1. National Emergency Number Association (NENA) .................................................................................................. 44

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7.2.2. Colorado 9-1-1 Surcharge Fees ............................................................................................................................... 44

7.2.3. Landline and Wireless Telecommunications Surcharges ........................................................................................ 44

7.2.4. Prepaid Wireless Telecommunications Service ...................................................................................................... 45

7.3. Stakeholder Comments ...................................................................................................................... 46

7.3.1. Synopsis of Funding Related Comments ................................................................................................................. 50

7.4. National NG9-1-1 Funding Discussions & Considerations ..................................................................... 51

7.4.1. Next Generation 9-1-1 Transition Policy Implementation Handbook: ................................................................... 51

7.4.2. NG9-1-1 Transition Plan: ......................................................................................................................................... 52

7.5. Funding Conclusions and Recommendations ...................................................................................... 55

7.5.1. State Level Legislation ............................................................................................................................................ 55

7.5.2. Funding and 9-1-1 Revenue Collection Options ..................................................................................................... 55

7.5.3. E9-1-1 Revenue Funding and Distribution Authority .............................................................................................. 56

7.5.4. Funding Models ...................................................................................................................................................... 57

7.6 Recommendations .............................................................................................................................. 59

7.6.1 Recommendation #1 ................................................................................................................................................ 59

7.6.2 Recommendation #2 ................................................................................................................................................ 60

7.6.3 Recommendation #3 ................................................................................................................................................ 60

7.7. Conclusion ......................................................................................................................................... 60

8. Implementation and Maintenance ........................................................................................... 61

8.1 NG9-1-1 Migration Planning ................................................................................................................ 61

8.1.1 Automatic Location Identification (ALI) Network Review ........................................................................................ 61

8.1.2 Voice Switching Component Review ....................................................................................................................... 62

8.1.3 Voice & ALI Network Summary ................................................................................................................................ 62

8.2 Migration Plan - First Steps ................................................................................................................. 62

8.2.1 Legacy Selective Router Role ................................................................................................................................... 62

8.2.2 ALI Network Migration............................................................................................................................................. 63

9. Summary of Findings ............................................................................................................... 65

10. Endnotes ................................................................................................................................. 69

11. Works Cited ............................................................................................................................. 69

APPENDIX A – §31-1- 202 C.R.S. 1997 ........................................................................................................ 70

APPENDIX B – §29-11-100.5 to §29-11-106 C.R.S 1997 ............................................................................... 71

APPENDIX C – CO 9-1-1 SURCHARGES........................................................................................................ 72

APPENDIX D – E9-1-1 SURCHARGE ............................................................................................................ 73

APPENDIX E – Non PSAP_PSAP Summary Worksheet Interviews 11FEB16 .................................................. 74

APPENDIX F – Statement of Work Index .................................................................................................... 75

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1. EXECUTIVE SUMMARY

Mission Critical Partners, Inc. (MCP) presents the Colorado Next Generation 9-1-1 (NG9-1-1) System

Review Report which identifies the technical architecture, installation and maintenance, governance

and funding recommendations of a NG9-1-1 Internet Protocol (IP)-enabled network for consideration by

the Colorado 9-1-1 Resource Center and the broader Colorado 9-1-1 Community.

According to the National Emergency Number Association (NENA), NG9-1-1 is:

“...an IP based replacement for E9-1-1 features and functions that supports all sources of emergency

access to the appropriate PSAPs, operates on reliable, secure, managed multi-purpose IP networks,

and provides expanded multimedia data capabilities for PSAPs and other emergency responders….”

As of June 2010, there were 292.8 million wireless connections in the United States which equals

approximately 93% of the population1. Communication services continue to evolve and new devices

and services are being rolled out regularly.

These rollouts include faster devices and a significant number of data services such as text messaging,

gaming, streaming video and the downloading and transferring of pictures. According to a study

conducted by the CTIA-The Wireless Association®, U.S. wireless consumers used more than 2.3 trillion

minutes during the 12 months ending June 2010 (or 6.3 billion minutes per day) and more than 1.8

trillion text messages were sent and received (or 4.9 billion text messages per day). This increasing

dependence on new communications technology is changing the consumers’ expectations of how they

communicate with 9-1-1. There is a growing expectation within our communities that they will be able to

reach 9-1-1 using something as simple as a text message.

The current 9-1-1 system in Colorado is based on a traditional Public Switched Telephone Network

(PSTN) implemented and maintained by the Basic Emergency Service Provider (BESP). The BESP

was established through the present statutory provision §29-11-100.5 to §29-11-106 C.R.S 1997, and

was designed to ensure there is a single, statewide network for 9-1-1 call routing and delivery, including

Automatic Number Information/Automatic Location Information (ANI/ALI). The BESP created a

statewide network that provides access to 9-1-1 services while distributing the costs of the network

equitably across the state.

Although extremely reliable, the current network will not support advancing technology and will

therefore be unable to provide service to emerging non-traditional communication devices. Currently,

the existing network is not directly capable of processing widely used data protocol known as Internet

Protocol (IP). IP is the base component of popular communication features such as text messaging,

pictures or video. Consumers and businesses are increasingly dependent upon these communication

technologies and devices.

This report reflects the fundamental premise that the Colorado E9-1-1 network and infrastructure must

transition to a modern IP-based network capable of meeting future public safety needs in the state.

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To this end, MCP has identified a set of requirements and assumptions that are based on the results of

an intensive data gathering process. This process involved research of industry best practices, oral

interviews with stakeholders, and a practical assimilation of the vision provided by Colorado’s public

safety communications leaders.

The following is a list of the foundational requirements of the proposed NG9-1-1 network:

The consumer must be able to access emergency services from a cell phone, landline phone,

voice over IP (VoIP) service, or any other device that the consumer could reasonably expect to

be able to access 9-1-1 services.

In the NG9-1-1 environment, any device capable of accessing 9-1-1 service must be able to

connect through the end user’s carrier or provider.

The network must be robust and designed with sufficient diversity and redundancy to ensure

survivability. No single point of failure should impact the day-to-day 9-1-1 and Public Safety

Answering Point (PSAP) operations.

The network must support all new and evolving applicable technical and operating standards as

they are developed, such as those from the National Emergency Number Association (NENA),

for IP networks and 9-1-1 call-taking equipment.

The network must have set standards and specifications for use and must be designed with

sufficient capacity to support all legacy and IP applications for statewide public safety needs.

Implementation of NG9-1-1 must support the migration to the consolidation of equipment, as

well as the sharing of equipment under a hosted model. That is, 9-1-1 ―calls‖ will continue to be

received locally, but the host equipment could be shared across multiple PSAPs or

counties. Where it makes sense, the network should be used to facilitate the pooling of

operational and capital resources.

The following is a list of the foundational assumptions relevant to the proposed NG9-1-1 network:

Local governing agencies will continue to retain control over their respective emergency

response functions, including emergency call processing. Local jurisdictions will also retain

responsibility for managing their respective daily operations.

The network will be designed with the intent to support a phased implementation starting with

the delivery of IP-ALI.

The network should be provided by a BESP, as a BESP is tasked with creating a statewide

network that provides equal access to 9-1-1 while distributing the costs of the network evenly

across the state.

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The governing authority should control which entities or organizations access the network.

The network provider should control how the network is accessed.

The network should permit connection to the existing E9-1-1 network and the PSTN.

All other service providers should connect to the BESP owned or managed IP Connection Point,

such as a legacy network gateway (LNG), which will convert the analog signal to IP.

Each service provider will have to connect to the BESP’s LNG’s, and shall have to meet state,

BESP or accepted industry standards and requirements for access. Each provider shall be

responsible for the costs of connecting and meeting the gateway requirements, including ALI

data.

All data and voice communication from the IP cloud to the PSAP will be IP-based, and delivered

via Session Initiated Protocol (SIP). PSAPs will have to meet state or accepted industry

requirements for access, firewall, level of service and Customer Premises Equipment (CPE)

capability, among others.

The network protocol should be Multiple Protocol Label Switching (MPLS).

The network architecture choice should allow a ―hybrid‖ mix of public and private network

assets.

MCP’s analysis of the current maturity stage of NG standards suggests that rapid change in these

standards should be expected. As well, a NG9-1-1 implementation must be considered a migration and

not a single event; therefore, MCP is suggesting that a phased approach is more practical.

It may also be stated that an IP network is the foundation of NG9-1-1 as it supports the interworking of

a variety of functions. Benefits such as IP-ALI and hosting applications can be gained by implementing

the IP network first.

Based on the aforementioned requirements and assumptions, MCP therefore makes the following

recommendation:

Colorado deploys a statewide IP network that allows applications to be implemented in three

phases.

The three phases include:

Phase 1 - Statewide implementation of a scalable MPLS network for transport of IP-ALI

Phase 2 - Additions of Hosted Call Center Applications such as CPE, call logging, and CAD

on the network

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Phase 3 - Migration from Legacy 9-1-1 to the features and functions of NG9-1-1

To initiate the process of this phased approach, MCP strongly recommends the development of a

detailed network plan and a conceptual network design that supports each phase of the project. This

plan, which is extremely critical to the success of the network, must include all essential elements

intended to sustain the successful migration through each of the three phases.

Regarding network traffic, MCP further recommends:

The classification of data types on the statewide network so that priorities can be assigned via

the Class of Service (CoS) mechanism.

The use of Quality of Service (QoS). QoS ensures that the bandwidth available in a path is

utilized to transfer data types based on priority.

Fiber optic cable is the media of choice for supporting the network and copper is the fallback.

Regarding Governance, Regulatory, and Funding, MCP further recommends:

A governance model consisting of an independent administrative entity, called the Colorado

NG9-1-1 Authority, be established to regulate a statewide NG9-1-1 network.

That multiple BESPs are approved and authorized to provide the service in a competitive

environment.

The previously proposed Colorado NG9-1-1 Authority is given the authority to manage funding

and revenue distribution for a NG9-1-1 network.

A hybrid averaging funding distribution model be adopted for PSAPs connecting to a NG9-1-1

network.

Network security and data integrity policies and rules are established by the governance

authority.

Regional NG9-1-1 networks, called Emergency Services IP network (ESInet), are considered.

This report further expands on the various topics that support the recommendations herein. These

topics include, but are not limited to, the following:

Research methodologies used,

State of Colorado Next Generation 9-1-1 Network Requirements and Assumptions,

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Recommendation and design considerations to include consumer technology, impact to legacy

E9-1-1 networks and the vision of Next Generation 9-1-1,

Various NG9-1-1 design approaches to a statewide network,

Elements of transport on a NG9-1-1 statewide network,

Implementation and support of a NG9-1-1 statewide network,

The regulatory aspects of a NG9-1-1 statewide network, and

Funding mechanisms of a NG9-1-1 statewide network.

MCP appreciates the opportunity to provide the Colorado public safety communications stakeholders

the information required to ensure that appropriate decisions concerning the migration towards a state-

of-the-art NG9-1-1 system.

To this end, MCP looks forward to being able to serve the greater Colorado 9-1-1 community in the

next steps toward the future roll out of NG9-1-1 throughout the state.

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2. INTRODUCTION AND METHODOLOGY

In June 2010, the Colorado 9-1-1 Resource Center released a Request for Proposal (RFP) seeking

qualified individuals or firms to assist the state of Colorado 9-1-1 community in identifying various

models for developing, implementing and maintaining an Internet Protocol (IP) based 9-1-1

communications system.

The purpose of the RFP was to establish various system models that take into account the political,

regulatory, financial and operational environments that exist within the state, as well as the existing 9-1-1

delivery system currently used throughout the state. These models are to address the technical

architecture of the system, implementation and maintenance of the system, and system governance and

funding.

Mission Critical Partners, Inc. (MCP) was contracted to facilitate and lead this process. MCP is

headquartered in State College, Pennsylvania, with offices in Harrisburg, Pennsylvania, and Southlake,

Texas (near Dallas). MCP serves clients throughout North America. MCP’s team consists of former

public safety managers, project management professionals (PMPs), and technology, forensic and

policy specialists. MCP principals have each invested more than two decades in the 9-1-1 industry and

continue to serve in key leadership roles in all the major industry organizations—National Emergency

Number Association (NENA), Association of Public-Safety Communications Officials International

(APCO), and 9-1-1 Industry Alliance (9IA)—and as advisors to key federal and state governmental

bodies. MCP’s mission is to support life safety communications clients through improved policy,

systems and processes.

A collaborative and strategic approach to the project ensured that all elements of Colorado Next

Generation 9-1-1 (NG9-1-1) System review were met. Throughout the project, the focus of improving

quality of service remained at the forefront.

The current 9-1-1 system in Colorado is based on a traditional Public Switched Telephone

Network (PSTN) implemented and maintained by the Basic Emergency Service Provider

(BESP).The BESP was established through §29-11-100.5 to §29-11-106 C.R.S 1997 and is

designed to ensure there is a single, statewide network for 9-1-1 call routing and delivery,

including Automatic Number Information/Automatic Location Information (ANI/ALI). The BESP

was tasked with creating a statewide network that provides equal access to 9-1-1 while

distributing the costs of the network equitably across the state.

The Colorado Public Utilities Commission (PUC) is the regulatory body responsible for the

oversight of the 9-1-1 network.

The current statewide legacy 9-1-1 network supports 88 primary and 8 secondary Public Safety

Answering Points (PSAPs) serving a population of 5,029,1962 citizens spanning approximately 104,100

square miles3.

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Colorado is a ―home rule‖ state whereas all decisions related to the implementation and funding of 9-1-

1 services are managed at a local level. Colorado has 98 cities and towns that are designated home

rule municipalities. Home rule is intended to prevent the state legislature from interfering in the

regulation of local matters. In short, home rule gives a city or town the right to draft and amend its own

charter and to regulate its own local issues, and to be largely self-governing. Refer to Appendix A –

§31-1- 202 C.R.S. 1997.

In order to make recommendations and support the findings of the report, data was gathered in several

fashions. Data collection methodologies included:

A survey tool, intended to gather and document raw data relating to existing network

infrastructure, PSAP equipment, existing and potential service providers, regulatory statutes and

funding sources; was developed and distributed.

Individual, on-site and telephone, interviews with follow-up conversations and/or email, as

deemed necessary.

Vendor due diligence sessions conducted requesting educational information on NG9-1-1

features and functions.

Through the due diligence process, formal requests for network designs were requested.

Internet research.

To assist in this effort, MCP enlisted various members of the Colorado public safety communications

community. The MCP interview teams were honored to have the opportunity to personally visit and

interview stakeholders at their respective worksites, as well as conduct telephone interviews with those

identified as having the expertise and experience so critical to the successful outcome of this endeavor.

Ultimately, this process ensured that the recommendations contained in this report symbolize

stakeholder opinions, current issues, yet to be developed system applications, as well as a collective

vision to be forged upon industry-accepted best practices.

The strategies and recommendations contained herein, as submitted to the Colorado 9-1-1 Resource

Center, will enable the creation of a highly reliable, secure, functional, and scalable emergency call

processing NG9-1-1 system for the citizens of Colorado.

As the system evolves, it will meet and eventually exceed the existing E9-1-1 system. In short, this will

be achieved by having the ability to effectively and consistently process emergency voice and data calls

from any device or service accessing the state’s 9-1-1 system – anytime and anywhere throughout the

state of Colorado.

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Information relating to the delivery of 9-1-1 services was obtained from the PUC website

(http://www.dora.state.co.us/puc/) and the Colorado 9-1-1 Resource Center website

(http://www.co9-1-1resourcecenter.org). This included but was not limited to information on:

§29-11-100.5 to §29-11-106 C.R.S 1997. Refer to Appendix B §29-11-100.5 through

§29-11-106 C.R.S. 1997.

The Emergency Telephone Service Charge (ETSC) tied to all phone lines that access the

system.

The 56 state implemented local E9-1-1 Authorities that determine the amount of the surcharge,

collect all remittance and distribute funds to local PSAPs.

Using the above collection methodologies as well as the gathered data, MCP compiled a

comprehensive list of Colorado NG9-1-1 network requirements and assumptions expanded upon in the

coming sections of this report.


http://www.dora.state.co.us/puc/

http://www.co9-1-1resourcecenter.org/

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3. THE STATE OF COLORADO NEXT GENERATION 9-1-1 NETWORK REQUIREMENTS

AND ASSUMPTIONS

This section captures the requirements and assumptions pertaining to the correct use of a statewide or

regional network. They represent the product of the following processes:

Comments offered by interviewees

Due diligence efforts

Follow up correspondence concerning clarification of issues

National Emergency Number Association (NENA) technical standards

(http://www.nena.org/technical-standards)

3.1. REQUIREMENTS

The determination of the various requirements provides the foundation for all aspects of the

functionality of the NG9-1-1 network. As such, a ―no stone left unturned‖ approach was needed. The

analysis of Colorado’s unique needs, NG best practices, transitional philosophies, as well as the current

and future requirements of a state-of-the-art NG9-1-1 network were foundational in determining the

following set of requirements:


voice over IP (VoIP) service, or any other device that enables access to 9-1-1 services at the

PSAPs.




survivability. No single point of failure should impact the day-to-day delivery of 9-1-1 services or

reduce the effectiveness of PSAP operations.


they become available, such as those from the National Emergency Number Association

(NENA), for IP networks and 9-1-1 call-taking equipment.

The network must have set standards and specifications for use and will be designed with


Implementation of NG9-1-1 must promote the migration to the consolidation of equipment, as


received locally, but the host equipment may be shared across multiple PSAPs or counties.

Where it makes sense, the network should be used to facilitate the pooling of operational and

capital resources.

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3.2. ASSUMPTIONS

The analysis of the governance models NG9-1-1 systems suggests that such issues are based on the

unique local jurisdictional needs. As well, NG9-1-1 must be considered a migration and not a single

event; therefore, governance models should be considered dynamic and subject to change. Perhaps

most importantly, there is a strong need to maintain local control over emergency response call

processing and operations response models. Based on the aforementioned principles and

assumptions, MCP is making the following recommendations:







The network should be provided by a BESP, since a BESP is tasked with creating a statewide

network that provides equal access to 9-1-1 while distributing the costs of the network evenly

across the state.




such as a legacy network gateway (LNG), which will convert the analog signal to IP.

Each service provider will have to connect to the BESP’s LNG’s, and shall have to meet state,

BESP or accepted industry standards and requirements for access. Each provider shall be

responsible for the costs of connecting and meeting the gateway requirements, including ALI

data.

All data and voice from the IP cloud to the PSAP will be IP-based, via Session Initiated Protocol

(SIP). PSAPs will have to meet any state requirements for access, firewall, level of service and

Customer Premises Equipment (CPE) capability, among others.


The network architecture choice should be a ―hybrid‖ mix of public and private telecommunications assets.

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4. CONSIDERATIONS

There are numerous considerations when designing and recommending an IP-based network capable

of supporting the various 9-1-1 voice and data components of NG9-1-1. The following subsections

describe considerations that affect the configuration, installation and maintenance, regulation and

ultimate funding of a regional or statewide network.

4.1. CONSUMER TECHNOLOGY AND COLORADO 9-1-1

Consumers and businesses are increasingly dependent upon new communication technologies and

devices. As of June 2010, there were 292.8 million wireless connections in the United States which

equals approximately 93% of the population1. With that is the understanding that communication

services are evolving, and new devices and services are being rolled out regularly.

These rollouts include not only faster devices but a significant number of data services such as text

messaging, gaming, streaming video and the downloading and transferring of pictures. According to a

study conducted by the CTIA-The Wireless Association®, U.S. wireless consumers used more than 2.3

trillion minutes the 12 months ending June 2010 (or 6.3 billion minutes per day) and more than 1.8

trillion text messages were sent and received (or 4.9 billion text messages per day). It is this increasing

dependence on new communications technology that is changing the consumer expectations of how

they communicate with our 9-1-1 systems. There is a growing assumption, particularly with younger

adults, that that they will be able to reach 9-1-1 using something as simple as a text message.

Most 9-1-1 systems, Colorado included, are constrained by equipment that has limited or no messaging

capability. In addition, 9-1-1 call-taking and dispatch equipment capabilities are limited to query and

response and does not support content receipt. These systems were not designed to receive calls and

data from these new technologies. 9-1-1 systems that use older technologies will be unable to

effectively process data-centric information. This will potentially have a negative effect on the overall

delivery of emergency services. It is this negative effect that will result in PSAPs not being able to meet

the needs of 9-1-1 callers and requests for emergency assistance using the advanced capabilities of

modern devices.

The growth in communications technology, providing information from a variety of sources, is forcing

Colorado 9-1-1 Authorities and PSAPs to consider changing the way they operate to provide equal

services to consumers. To support these technology growth trends, 9-1-1 Authorities and PSAPs

should evolve to platforms that enable these communications devices to access 9-1-1 service.

Platforms that are IP-based offer many opportunities to the changing landscape of consumer needs

and technologies.

IP-based platforms are used by a variety of businesses and organizations throughout the United States.

Landline and wireless service providers and many other commercial communications systems have

been using IP-based platforms for many years. For example, traditional communications companies are

transforming their circuit switched networks into packet switched networks to accommodate the

transport of voice, data, and video over IP networks.

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The evolution of communications technology to IP-based platforms provides a rare opportunity for the

Colorado 9-1-1 community of 9-1-1 Authorities, PSAPS and counties to make improvements in the

current 9-1-1 infrastructure. The 9-1-1 network and infrastructure cannot support current technology

and must transition to a modern IP-based network capable of meeting future public safety needs.

An IP-based network will allow for the delivery of additional data necessary for an effective public safety

response. Over time, an IP network will replace the existing service provider’s analog networks and

provide for the delivery of text messaging, video and other data content with the additional benefit of

providing efficiencies on optional call load distribution and host equipment sharing. The latter will allow

counties to retain local control over how 9-1-1 calls are handled and dispatched, while providing

opportunities to minimize the associated costs.

Currently there is a technological disparity between the various PSAPs across the state. NG9-1-1

provides a reasonable and practical solution, particularly through the hosted application model, to

ensure that citizens of Colorado receive the highest standard of care and practice no matter where they

may reside. A highly functional statewide NG9-1-1 network enables this opportunity.

Much work has been done in many forums to design a nationwide IP-based 9-1-1 network and system

to meet consumer expectations and improve the quality of 9-1-1 service and public safety. The

common theme among all these forums is the desire to create a vision and plan that coordinates 9-1-1

service delivery with the driving force being consistency in emergency response and maximization of

available resources using a nationwide IP-based 9-1-1 network.

4.2. NEXT GENERATION 9-1-1

The Colorado vision, as well as the national vision for public access to emergency services is for an IP-

based network where 9-1-1 ―callers‖ can use any analog or digital device to access and request

emergency assistance. A driving factor of this proposed vision is the ability for information collaboration

and connectivity of local, regional, and national agencies via interconnected IP networks that would

enable emergency communications applications to work together on a much larger scale than what

currently exists on the local level. This vision is called Next Generation 9-1-1 (NG9-1-1).

According to the National Emergency Number Association (NENA), NG9-1-1 is:

“...an IP based replacement for E9-1-1 features and functions that supports all sources of

emergency access to the appropriate PSAPs, operates on reliable, secure, managed multi-

purpose IP networks, and provides expanded multimedia data capabilities for PSAPs and other

emergency responders….”

To advance a nationwide vision of an IP-based 9-1-1 system, the U.S. Department of Transportation

(USDOT) assisted in the research and development needed to bring about a more capable IP-based

solution design. The overarching goal was to produce a system that supports all types of emergency

call delivery and maximizes service responses across a diverse stakeholder community, such as those

in Colorado. The USDOT participation in the NG9-1-1 vision and plan development resulted in several

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items of reference that included the NG9-1-1 Transition Plan version 1.0, February 2, 2009, as well as

the NENA NG9-1-1- Transition Plan Considerations Information Document (NENA 77-501), Version 1,

February 24, 2011.

The USDOT NG9-1-1 Transition Plan brings forth several key points guiding the process of evolving to

an IP-based network for emergency services that include topics involving technological, economic, and

institutional change. This is also true as it relates to 9-1-1 in Colorado; especially when one starts to

address NG9-1-1 at the technological level and the use of the BESP procurement model.

The path to NG9-1-1 implementation in Colorado will strongly depend on the underlying infrastructure

involved and the characteristics of the PSAPs and 9-1-1 Authorities in a defined geographic area. At

the same time, it is possible that Colorado’s transition to NG9-1-1 will depend on the ability of service

networks to deliver NG9-1-1 content and calls via native IP-based infrastructure to jurisdictions that are

prepared to receive it.

4.3. THE LEGACY 9-1-1 SYSTEM

The Colorado PUC created a BESP model to help facilitate the delivery of Enhanced 9-1-1 in Colorado.

Qwest currently serves as the BESP for Colorado and has developed a reliable statewide voice

network that supports the delivery of Legacy 9-1-1 calls today.

Legacy 9-1-1 Systems contain many elements that become crucial to the delivery of a 9-1-1 call. These

elements are distinct components such as the Public Switched Telephone Network (PSTN), Centralized

Automated Message Accounting (CAMA) trunks, Signaling System #7 (SS7) trunks, Central Offices,

Tandems and Local Access and Transport Areas.

Simply put the PSTN is the local, long distance and international phone system that consumers use

every day for telephone communications. It is the interconnection of phone companies using various

mediums of transport such as CAMA and SS7 trunks to deliver 9-1-1 calls.

Legacy 9-1-1 systems utilize two different and distinct trunk types identified as CAMA and SS7, when a

caller dials 9-1-1 on their telephone set (wireline, wireless, or VoIP).

A CAMA trunk is a special analog trunk type originally developed for long-distance billing, then adapted

for use in our nation’s E9-1-1 systems. CAMA trunks carry both the originating calling number as well

as the called number. This method of carrying identifying information enables the system to send a

station identification number (caller’s number) to a PSAP from a Central Office (CO). CAMA trunks can

be used to connect CO’s to 9-1-1 tandems and to connect 9-1-1 tandems to PSAPs.

SS7 is a set of telephony signaling protocols which are used to set up most of the world's public

switched telephone network telephone calls. The main purpose is to set up and tear down telephone

calls. Other uses include number translation, prepaid billing mechanisms, short message service

(SMS), and a variety of other mass market services. Basically, the SS#7 control network tells the

switching office which paths to establish over the circuit-switched network. SS7 trunks can be utilized to

http://en.wikipedia.org/wiki/Telephony

http://en.wikipedia.org/wiki/Signaling_(telecommunications)

http://en.wikipedia.org/wiki/Public_switched_telephone_network

http://en.wikipedia.org/wiki/Public_switched_telephone_network

http://en.wikipedia.org/wiki/Clearing_(telecommunications)

http://en.wikipedia.org/wiki/Telephone_call

http://en.wikipedia.org/wiki/Telephone_call

http://en.wikipedia.org/wiki/Short_message_service

14

connect CO’s to 9-1-1 tandems and to connect 9-1-1 tandems to 9-1-1 tandems. SS7 trunks are not

used to connect 9-1-1 tandems to PSAPs. The definition of a Central Office (CO) has a fairly broad

meaning, but as it relates to a 9-1-1 call it is most commonly referred to as a switching exchange. When

the CO receives the call, the digits ―9-1-1‖ are recognized and the call is passed to a 9-1-1 Tandem or a

Selective Router (SR), which in turn sends the call to the appropriate PSAP. At times this exchange

requires crossing geographical boundaries called Local Access and Transport Area (LATA).

A LATA is a geographical area that was established in August of 1982 under the terms of the

Modification of Final Judgment (MFJ) settling the United States v. AT&T antitrust suit. The Consent

Decree precipitated the breakup of the original AT&T, requiring the divestiture of the Regional Bell

Operating Companies (RBOC) from AT&T.

A LATA represents an area inside which a divested RBOC offers exchange telecommunications and

exchange access services. Under the terms of the MFJ, the RBOCs were prohibited from providing

services that originate in one LATA and terminate in another.

Since the BESP was tasked with creating a statewide network that provides equal access to 9-1-1 while

distributing the costs of the network evenly across the state, many of the typical LATA boundary issues

found in other states are not as prominent in Colorado. Star transfer codes are utilized in the 9-1-1

tandems to transfer calls across LATA boundaries using intertandem trunks. This is possible due to the

implementation of dual mated tandems and the presence of only two LATAs. The tables below depict

the Colorado Tandem placement (Figure 1), the LATA boundaries (Figure 2), and an overlay of the two

tables (Figure 3).


15

Colorado 911 Tandems

Mesa

Garfield

Rio Blanco

Moffat

La Plata

Delta

Montezuma

Dolores

San Miguel

Montrose

Larimer

Custer

Clear Creek

Gilpin

Boulder

Alamosa

Grand

Summit

Park

Fremont

Costilla

Huerfano

Chaffee

Jackson

Lake

Mineral

Saguache

Pitkin

Routt

Eagle

Rio Grande

Conejos

Ouray

San Juan

Archuleta

Hinsdale

Gunnison

Phillips

Sedgwick

Prowers

Yuma

Cheyenne

Kit Carson

Washington

Kiowa

Bent

Logan

Baca

Lincoln

Morgan

Las Animas

Pueblo

Broomfield

Denver

Arapahoe

Adams

Weld

Jefferson

Teller

Douglas

El Paso

Elbert

Otero

Crowley

Broomfield

Denver (Cap Hill)

Grand Junction

Montrose

Pueblo

Colorado Springs

MissionCriticalPartners

Colorado 911

Tandems

Figure 110-0120 F 01 042711.MAE. .V1

OFFICE All are DMS 100s SWITCH CLLI 911 TNDM CLLI

BROOMFIELD (secondary DUAL with DNVRCH) BRFDCOMADS0 BRFDCOMA1GT

CAP HILL (Primary Dual with BRFD) DNVRCOCHDS0 DNVRCOCH2GT

GRAND JUNCTION (Primary Dual with MTRS) GDJTCOMADS0 GDJTCOMA1GT

MONTROSE (secondary DUAL with GRD JCT) MTRSCOMADS0 MTRSCOMA3GT

PUEBLO MAIN (Primary Dual with CLSP [Stratmore) PUBLCOMADS0 PUBLCOMA1GT

STRATMOORE (secondary DUAL with PUBL) CLSPCOSMDS0 CLSPCOSM1GT

Figure 1: Colorado 911 Tandems

16

Mesa

Garfield

Rio Blanco

Moffat

La Plata

Delta

Montezuma

Dolores

San Miguel

Montrose

Larimer

Custer

Clear Creek

Gilpin

Boulder

Alamosa

Grand

Summit

Park

Fremont

Costilla

Huerfano

Chaffee

Jackson

Lake

Mineral

Saguache

Pitkin

Routt

Eagle

Rio Grande

Conejos

Ouray

San Juan

Archuleta

Hinsdale

Gunnison

Phillips

Sedgwick

Prowers

Yuma

Cheyenne

Kit Carson

Washington

Kiowa

Bent

Logan

Baca

Lincoln

Morgan

Las Animas

Pueblo

Broomfield

Denver

Arapahoe

Adams

Weld

Jefferson

Teller

Douglas

El Paso

Elbert

Otero

Crowley

658 LATA Colorado Springs

656 LATA Denver

Colorado

Local Access Transport Areas

Local Access Transport Area 656 – Denver

Local Access Transport Area 658 – Colorado Springs


Colorado

Local Access

Transport Areas

10-0120 F 02 042711.MAE. .V1 Figure 2

Figure 2: Colorado LATAs

17

Mesa

Garfield

Rio Blanco

Moffat

La Plata

Delta

Montezuma

Dolores

San Miguel

Montrose

Larimer

Custer

Clear Creek

Gilpin

Boulder

Alamosa

Grand

Summit

Park

Fremont

Costilla

Huerfano

Chaffee

Jackson

Lake

Mineral

Saguache

Pitkin

Routt

Eagle

Rio Grande

Conejos

Ouray

San Juan

Archuleta

Hinsdale

Gunnison

Phillips

Sedgwick

Prowers

Yuma

Cheyenne

Kit Carson

Washington

Kiowa

Bent

Logan

Baca

Lincoln

Morgan

Las Animas

Pueblo

Broomfield

Denver

Arapahoe

Adams

Weld

Jefferson

Teller

Douglas

El Paso

Elbert

Otero

Crowley

Broomfield

Denver (Cap Hill)

Grand Junction

Montrose

Pueblo

Colorado Springs

658 LATA Colorado Springs

656 LATA Denver

Colorado LATAs and 911

Tandems


Colorado LATAs

and

911 Tandems

10-0120 F 03 042711.MAE. .V3 Figure 3

OFFICE All are DMS 100s SWITCH CLLI 911 TNDM CLLI

BROOMFIELD (secondary DUAL with DNVRCH) BRFDCOMADS0 BRFDCOMA1GT

CAP HILL (Primary Dual with BRFD) DNVRCOCHDS0 DNVRCOCH2GT

GRAND JUNCTION (Primary Dual with MTRS) GDJTCOMADS0 GDJTCOMA1GT

MONTROSE (secondary DUAL with GRD JCT) MTRSCOMADS0 MTRSCOMA3GT

PUEBLO MAIN (Primary Dual with CLSP [Stratmore) PUBLCOMADS0 PUBLCOMA1GT

STRATMOORE (secondary DUAL with PUBL) CLSPCOSMDS0 CLSPCOSM1GT

Figure 3: 911 Tandems and LATAs

18

5. TECHNICAL ARCHITECTURE

There are a range of components and connections involved in the technical architecture design of any

network. As mentioned in the previous sections, the Legacy 9-1-1 network equates to physically

separate networks for CAMA trunks and ALI links. Whereas these traditionally separate networks

provide reliable 9-1-1 service, they limit the ability to maximize on technical resources, as most PSAPs

interconnect to several networks that each serves a specific purpose. A NG9-1-1 network converges

voice, video and data to a single IP-based network. This single IP-based network could be implemented

at several regional levels or as a statewide deployment. The analysis of the current maturity stage of

NG standards suggests that rapid change in these standards should be expected.

In consideration of a single cutover (i.e. ―flip the switch‖) or a phased approach, consideration must be

given to a variety of issues. For example, target PSAPs should be identified that are willing and able to

assist in NG9-1-1 deployment and implementation. There should also be coordination and

communication with the various stakeholders, as well as the development of metrics and milestones for

measuring program success. The development of a viable and practical transition model is key to

success in this regard. In other words, a migration plan that assists in assessing a viable and practical

transition model must be developed.

Such a migration plan must also include a detailed evaluation of CPE equipment and interface

availability, and any other technical or operations issues pertinent to a migration plan. Staff training as

well as emergency responder orientation must also be included.

The success of the transition includes the development of an extensive pre- and post-cut Acceptance

Test Practices (ATP). The ATP needs to be co-developed with the selected vendor to ensure that all

components and features have been included in the process.

As such, NG9-1-1 must be considered a migration and not a single event; therefore, a phased

approach is more practical. An IP network is the foundation of NG9-1-1 as it supports the interworking

of functions. Benefits (IP-ALI, hosting applications, etc.) can be gained by implementing the IP network

first. The conclusion is that a phased approach to Colorado’s vision of implementing an NG9-1-1

network is the best route. The MCP recommendation for the Colorado 9-1-1 Resource Center is the

deployment of a statewide IP network to allow for applications to be implemented across the solution in

three phases for use by the greater Colorado 9-1-1 PSAP Community.

The three phases would include the:

1. Statewide implementation of a scalable MPLS network for transport of IP-ALI.

2. Additions of Hosted Call Center Applications such as CPE, call logging, and CAD on the

network.

3. Migration from Legacy 9-1-1 to the features and functions of NG9-1-1 to include advance and

enhanced routing functionality.

19

The primary goal of the statewide IP network is to provide a standardized, secure, managed

infrastructure to interconnect multiple PSAPs without limiting any aspect of communication.

The deployment of a statewide IP network should not be seen simply as an interconnection of 9-1-1

Authorities or the PSAPs within. The Colorado 9-1-1 Community as a whole should view this network

as an opportunity to execute a comprehensive strategy to improve technology challenges and meet the

needs of all geographic areas. A comprehensive, statewide emergency communications strategy

confronts the challenges of incorporating existing equipment and practices into a constantly changing

technological environment.

5.1. NETWORK

A telecommunications network is a collection of terminals, links and nodes (using circuit switching or

message switching) which connect together to enable communication between users. In

telecommunication networks there will be many references to the topology and the messaging

protocols that are used to communicate. Therefore, it is prudent to ensure that there is a base

understanding of these two concepts.

5.1.1. Topology

Topology is usually a diagram description regarding the arrangement of the network, to include the

nodes and connecting line, and is usually defined as: physical or logical. According to the Florida

Center for Instructional Technology (FCIT), the physical topology of network is the actual geometrical

layout of network nodes; while the logical topology refers to the nature of the paths the signals follow

from node to node. There are several common physical/logical topologies, such as bus, star, ring, mesh

and tree.

5.1.1.1. Physical/Logical

In the bus network topology, every node is connected to a main transport called the bus. Therefore,

each node is directly connected to every other device in the network.

In the star network topology, there is a central node to which all other nodes are directly connected.

The result is that every node is indirectly connected to every other through the central node.

In the ring network topology, the nodes are connected in a closed loop configuration and the outcomes

are adjacent pairs of nodes that are directly connected while other pairs of nodes are indirectly

connected.

The mesh network topology uses either of two schemes, called full mesh and partial mesh. In the full

mesh topology, each node is connected directly to each of the others. In the partial mesh topology,

some nodes are connected to all the others, and some are connected only to those other nodes with

which they exchange the most data.

20

Finally, the tree network topology uses two or more star networks connected together. The central node

of the star networks are connected to a main bus. Thus, a tree network is a bus network of star

networks. All of the above mentioned configurations are depicted in Figure 4 below.


21


Common

Configurations

10-0120 F 04 042711.DJ.MAE .V4 Figure 4

Figure 4: Common Configurations

22

There are three of the configurations pictured in Figure 4 that rise to the top in any network design

conversation because they best address concerns regarding redundancy, diversity and survivability.

They are:

Star

Ring

Mesh

The most common is a star configuration (can also be referenced as spoke and hub), which often has a

service provider’s central office or PSAP as the single aggregation point (i.e., the central node).

Additionally, the ring configuration is very resilient because the network connects through facilities until

all facilities are connected in a ring. Finally the mesh configuration is the most diverse and survivable as

each node is connected directly to each of the others. Each of these network types has advantages and

disadvantages that need further explanation.

In a star network, the central node is a single point of failure. If the central node shuts down, all other

facilities lose connectivity with each another. The advantage to the star is that each facility is at most

one network away from one another, which reduces the probability of congestion.

The ring network builds in redundancy and resiliency. Failure of one facility does not affect

communication between other facilities. A disadvantage to the ring configuration is that traffic must go

through multiple facilities to get to the destination facility. A ring network must be designed such that

bottlenecks do not occur as traffic transverses the ring.

A mesh or partial mesh network structure offers the greatest level of redundancy, diversity and

survivability. This network type can be slightly more expensive; however, it can be achieved in most

examples as we analyzed each of the PSAPs in Colorado.

A mesh or partial mesh is the preferred configuration since it provides a high degree of reliability,

redundancy, diversity and survivability to each of the PSAPs. This logical configuration is important and

becomes more distinct when communication protocols are attributed to the design as well.

5.1.2. Protocols

Protocols are sets of rules that govern the communications between nodes on the network, states the

FCIT. In order for two nodes to talk to each other, they must be speaking the same language. Many

different types of network protocols and standards are required to ensure that the various nodes can

communicate with other nodes located in the next county or over five counties.

There is a model called the OSI (Open Systems Interconnection) Reference Model that defines seven

layers of networking protocols. It is a way of sub-dividing a communications system into smaller parts.

The intention is for similar communication functions to be grouped into logical layers. The complexity of

23

these layers is beyond the scope of this report; however, they can be simplified by imagining the layers

as a set of boxes stacked one upon the other. At each layer, certain things happen to the data that

prepare it for the next layer up. The seven layers can be further categorized into two sets: the

application set and the transport set as depicted in Table 1.

Table 1: OSI Reference Model

OSI Layer Name Layer Set

7 Application

Application 6 Presentation

5 Session

4 Transport

Transport

3 Network

2 Data Link

1 Physical

5.1.2.1. Layer Sets

The OSI model works data from the bottom up. It starts with the transport set working to provide

efficient and reliable transportation of the data packets from one network to another. It provides the

node-to-node connections. The application set provides services for functions such as streaming

media, user interface applications and operating systems. It translates data into the necessary format

that can be easily read by the intended application. It is important to understand that these protocol

layer standards are all applicable in an IP-based network design.

5.1.3. Data Communication Technologies

A data communications network that covers a relatively broad geographic area, such as Colorado,

often uses transmission facilities provided by common carriers, such as telephone or cable companies.

In almost all instances these facilities use switching technologies that are operating principally at layer

two of the OSI reference model. Superior throughput performance, higher port density, lower per-port

cost, and greater flexibility have contributed to the emergence of switches in data routing technology

such as:

24

Point to Point Protocol

Integrated Services Digital Network

Frame Relay

Digital Subscriber Line

Asynchronous Transfer Mode Switching (ATM)

Multiprotocol Label Switching (MPLS)

As stated previously, in a mesh network design each node is interconnected to all other nodes. To

further the objective of network provisioning that uses secure, resilient, scalable and flexible

technology, it is recommended that MPLS be the selected routing technology. MPLS provides the best

options to support a public safety grade network. The use of MPLS allows for controlling packets via

labeling upon ingress and guaranteeing Quality of Service (QoS) for the labeled packet until the packet

reaches its destination, which is paramount. Packet labeling provides more efficient use of prescribed

network bandwidth and alleviates and/or minimizes traffic congestion for packets labeled at a higher

priority.

5.1.3.1 Multiprotocol Label Switching (MPLS)

The NENA Master Glossary of 9-1-1 Terminology NENA 00-001, Version 15, March 29, 2011 defines

MPLS as ―A mechanism that allows network administrators to perform a measure of traffic engineering

within their networks‖.

MPLS is a communications methodology used in high-performance telecommunications networks that

directs and carries data from one network node to the next with the help of labels. It is a highly scalable,

protocol agnostic, data-carrying mechanism. Packet-forwarding decisions are made solely on the

contents of the label without the need to examine the packet itself. This allows the creation of end-to-

end circuits across any type of transport medium, using any protocol. The primary benefit is to eliminate

dependence on a particular Data Link Layer technology, such as ATM, frame relay, SONET or

Ethernet, and eliminate the need for multiple Layer 2 networks to satisfy different types of traffic.

Of all the various technologies that have been previously deployed with basically the same goals (i.e.

Asynchronous Transfer Mode (ATM)), the evolution of MPLS has addressed the strengths and

weaknesses of ATM. It is generally agreed that ATM should be replaced with a protocol that requires

less overhead, while providing connection-oriented services for variable-length frames. It is therefore

highly possible that MPLS will completely replace these technologies in the future, and forms the basis

for MCP’s recommendation in this regard.

In addition, MPLS engineering addresses changing traffic patterns and congestion in the network due

to events such as election news, online trading, major sports events and results in:

http://en.wikipedia.org/wiki/Telecommunications_network

http://en.wikipedia.org/wiki/Data_Link_Layer

http://en.wikipedia.org/wiki/Asynchronous_Transfer_Mode

http://en.wikipedia.org/wiki/Frame_relay

http://en.wikipedia.org/wiki/Synchronous_optical_networking

http://en.wikipedia.org/wiki/Ethernet



25

Better utilization of available bandwidth

Route on the non-shortest path

Route around failed links/nodes

Fast rerouting around failures, transparent to users

Automatic protection switching like SONET, <54ms

Build new services—virtual leased line services

VoIP toll-bypass applications, point-to-point bandwidth guarantees

Capacity planning

In short, the MPLS standard is the most appropriate protocol standard for a NG9-1-1 network.

5.1.3.2. PSAP Interoperability

PSAPs traditionally have difficulty transferring calls to other PSAPs. The limitations of the legacy

telephone system have created obstacles that NG9-1-1 will overcome. In the state of Montana, for

example, two back to back selective routers, along with an IP network, allow the seamless transfer of

9-1-1 calls to any of the state’s 54 PSAPs. Both voice and data are transferred quickly and efficiently. It

should also be noted that MCP is working with the state of Minnesota to accomplish the same goal.

Therefore, if there are any call transferring problems between the LATAs in Colorado, a statewide

NG9-1-1 solves the problem. In addition, other PSAP to PSAP data transfer technologies will further

allow PSAPs to share other related operations data including mapping information, records

management systems information, archived audio files, etc.

As NG software applications become more commercially available, the potential for information sharing

and back-up becomes limitless.

5.1.3.3 Regional Networks

Regional NG9-1-1 networks and their implementation must be considered. Traditionally, 9-1-1 services

have always evolved from the ground up, that is, 9-1-1 has always been a local service, started by local

visionaries, serving the local citizenry. As well, 9-1-1 stakeholders philosophically have always put their

local needs first. In America, it therefore stands to reason that regional networks will evolve irrespective

of state or national NG9-1-1 initiatives.

MCP staff has direct experience in the networking of PSAPs in Texas at a regional level. This enabled

PSAPs to quickly and effectively transfer 9-1-1 calls, complete with data, as well as improved the

delivery time of ALI data. As expected, it also provided the PSAPs the capability to share data more

efficiently with other PSAP systems and networks.

26

In Colorado, there are multiple high quality service providers already serving the various network needs

of the state. The ability to create local networks, particularly in urban and developed regions, will be

relatively easy insofar as telecommunications facilities is concerned; however, in order for the local

NG9-1-1 networks to evolve and be compatible with the statewide vision, the proposed governance

authority must establish policies and rules applicable to all local efforts.

5.1.4. Data Management

Secure, resilient and scalable technology is where a MPLS based IP networks provide flexibility and

increased bandwidth utilization as paths can be shared so that circuit idle time is minimized. This

flexibility comes with added responsibility to manage how the path is shared via these control

mechanisms:

Data Type Classification

Data Type Prioritization

Traffic Monitoring

5.1.4.1. Data Type Classification—Class of Service (CoS)

With the implementation of IP-converged networks, it is necessary to separate data packet types into

classifications referred to as CoS. In the 9-1-1 area, this could be voice, high priority data (e.g., ALI),

emergency text data, emergency video data and low priority map updates data. This classification must

be recognized throughout the network and, therefore, supported by the CPE manufacturers.

Classification of data types is required so that priorities can be assigned via the CoS mechanism.

5.1.4.2. Data Type Priority—Quality of Service (QoS)

In IP networks, QoS deals with ensuring that the bandwidth available in a path is utilized to transfer

data types based on priority. In the current circuit-based TDM 9-1-1 network, 9-1-1 calls have a

guaranteed QoS inherent in the technology. Every TDM call receives dedicated bandwidth (8 bits every

125 microseconds = 64kbits/sec) on a dedicated circuit. No other voice or data communication has

access to this dedicated path. The downside of TDM is that the circuit can only transport data to a fixed

destination so in periods where there are no communications over the circuit, it lays idle.

To the PSAP this means that different circuit types for different applications, such as dedicated 9-1-1

trunks, ALI links and separate IP networks for maintenance of map data, are required, all at a cost to

the PSAP.

By default, IP networks are best effort networks. All data is treated as equal and is delivered as best as

it can. With the convergence of voice, data and video onto a single network, the design is faced with

different requirements as each QoS attaches priorities to each data type based on its CoS. The IP

network routing functions then processes each packet of data using these mechanisms. In this way, for

instance, voice can be given a higher priority than data since the tolerance for such network

27

occurrences (such as delay and lost packets) are easily absorbed by data; however, if the delay

affected a voice packet, a noticeable diminished quality of the call would be evident.

Therefore, in an emergency call processing environment, the use of CoS and QoS is highly

recommended.

5.1.4.3. Traffic Monitoring

Network and traffic monitoring must be strictly coordinated, especially if regional NG9-1-1 networks are

established and interconnected to a statewide system.

MCP believes that the Information Technology Infrastructure Library version 3 (ITILv3) frame work is

the foundation of network operations and traffic monitoring. Functions identified in ITILv3 are mapped to

organizational processes, or new processes are recommended where none exists. As such, the

governance authority will need to analyze the feasibility of in-house versus outsourced models.

MCP also suggests that a network operations center (NOC) should be responsible for the coordination

of all NG9-1-1 interconnected carriers and service providers upon implementation as well as ongoing

support. It is expected that the NOC will coordinate and dispatch agency field technicians as

determined by the governance authority policies and procedures. The NOC may also serve as the

administrative authority for the authorization of new users, networks, and services—and may grant

access to the network as defined and agreed upon by the governance authority.

In addition, while Cos/QoS allows for the classification/prioritization of data types and design for the

highest quality of delivery possible, it is necessary to monitor IP traffic volume patterns to ensure that

the bandwidth that has been provisioned for each PSAP meets the individual ―busy hour‖ requirements.

Traffic monitoring is performed differently in IP networks than the current TDM 9-1-1 trunk studies;

however, the goals are similar in that any packet blockages and congestion issues should be

addressed.

5.1.4.4. Integrity of Data

The security and integrity of public safety data, particularly in law enforcement, continues to be a high

priority. Historically, public safety agencies adopt policies and procedures to maintain the preservation

of information as well as ensure that unauthorized access to such information does not occur.

In an NG9-1-1 environment, the same issues exist. These include, but are not limited to, the following:

Unauthorized data input

Hacking or unauthorized access by unauthorized agencies or individuals

Disclosure of confidential information

Altering of Records Management System data

28

Unauthorized access to public safety information systems

Accessing of investigative data

Unauthorized monitoring of 9-1-1 calls

Falsification/spoofing of 9-1-1 calls

Rules and policies pertinent to the above issues must be considered a high priority. Network security

issues and the maintaining of data integrity have developed along with the proliferation of data network

systems. In other words, checks and balances applying to all aspects of data input, processing, integrity

and security are required.

The National Emergency Number Association, in cooperation with public safety and industry experts

continues to produce recommended standards for the NG9-1-1 arena. MCP staff have participated in

the development of the NENA Functional and Interface Standards for Next Generation 9-1-1, Version

1.0 (i3), NENA 08-003. This standard is considered the de facto NG9-1-1 standard that recommends

best practices for issues such as interoperability and network security elements (such as border control

functions) for NG9-1-1 networks.

Of particular interest is NENA Security for Next-Generation 9-1-1 Standard (NG-SEC), NENA 75-001,

Version 1, published February 6, 2010.

In addition to addressing NG9-1-1 security issues, the standard states:

“Executive or other department manager ultimately responsible for the security of the

organization and may be responsible for the operation of all data processing, network, and

access to all IT operations of the NG-911 Entity. This person or their designated representative

will define security policy as it relates to all systems, networks, and data for the NG9-1-1 Entity

as a whole. Many times, this role could be defined and identified by legal statute or regulation.”

The standard also states:

“The creation of a security policy is the first step in any effective attempt at implementing a

security program. A Security Policy is a clearly documented statement of organizational goals

and intentions for security, particularly upper management’s commitment to Security. The

creation of a security policy requires an organization to recognize, identify, and document its

commitment to security. All too often organizations implement security measures without first

implementing security policies. This often results in ineffective or unfocused security controls

and ultimately leads to more vulnerability. A security policy should facilitate an environment of

secure computing and document an organization’s philosophy concerning security.”

29

In short, the governance authority must ensure that data security and integrity issues for statewide as

well as regional networks have been defined, addressed, and that checks and balances are in place to

achieve these goals.

5.1.5. “Last Mile” Scalability and Reliability

5.1.5.1. Wire Center to PSAP Media

Each PSAP is supported by a Central Office (CO), which is also commonly known as a wire center.

Wire centers are the central point where physical circuits are interconnected and, in most cases, are

owned by ILEC. Wire centers support the local dial tone access requirements and in many cases, they

support the co-location of CLECs networking access facilities.

While MCP recognizes the actual distance from the local wire center to the PSAP may be one tenth of

a mile up to fifteen miles, this last span of distance in the telecommunication network is commonly

known as the ―last mile.‖

The last mile of network facilities is commonly supported by a communication system of insulated

copper cables. While Digital Service (DS1) (aka T1) have been used successfully for years to support

broadband networks, it is more desirable to support critical public safety applications where 99.999

percent reliability is required, with the more reliable fiber optic cable last mile solution. Installing fiber

networks can be very expensive as well as it can take a relatively long time to fully deploy.

While MCP clearly recognizes that the BESP can offer IP-based service in most areas within Colorado,

it is suggested that other facilities-based CLECs and cable service providers also may have facilities

that could support the ―last mile‖ of network facilities.

5.1.5.2. IP Transport

To facilitate a common understanding, several terms are explained in the following paragraphs to

describe the types of network media that can support the connectivity requirements of an IP-based

network.

IP-based networks primarily use the following three types of media to provide the pathway over which

data can be transmitted. These are:

Metallic wires within cables (copper)

Wireless networking (radio, Wi-Fi, microwave, infrared)

Glass or plastic fibers (fiber optic cable)

Copper media in external or internal telephone cables or LAN networks within PSAP facilities utilize

unshielded twisted pairs (UTP), shielded twisted pairs (STP) or coaxial.

30

UTP cabling consists of two or more unshielded wires twisted around each other and is the least

expensive and easiest to work with of the different media; however, protection from interference and

support of high bandwidths is lacking.

STP cabling provides more protection from interference and supports higher bandwidths than UTP;

however, this is not a customary network solution for telecommunication service providers.

Coaxial cable is widely used by cable network providers for the connectivity of ―last mile‖ entertainment

video data as well as voice over Internet protocol (VoIP) telephone service. Coaxial cable is shielded

but uses a precise conductor spacing needed to function efficiently over long distances. The first cross-

country network was created using coaxial cable. While coaxial cable can support larger bandwidths,

and offers even greater protection against electromagnetic interference, it is still an aging technology

susceptible to other interference (e.g., poor grounding and seepage).

Wireless networks can be created using radio frequency communication (non-line of sight), microwave

communication to support long-/short-range line-of-sight communications via highly directional

antennas or short-range communication, or infrared (IR) short-range communication; for example, high

intensity lasers for line of site transmission. Applications may involve point-to-point communication,

point-to-multipoint communication, broadcasting, cellular networks and other wireless networks.

Both microwave and infrared require line of site between the locations. Wireless transmission

bandwidth continues to increase; however, they still lag both copper and fiber-optic connections due to

available wireless frequencies. The data transfer speed on wireless is dependent on the number of

devices connected to the transmitter, since they all share the same available bandwidth.

Fiber optic cable is the newest technology for supporting networks. Fiber optic cables can be made

from plastic, but most are made from thin strands of glass, coated with reflective material and enclosed

in a protective cable. They utilize light waves instead of electrical pulses to transfer data. Fiber optic

cables have several advantages that include high bandwidth, capacity, scalability and high reliability. A

disadvantage of fiber optics can be the cost associated with construction costs levied by the network

carriers for ―last mile‖ fiber to the PSAP facilities.

In summary:

Copper and coaxial media do not support the bandwidth, scalability and reliability required for

today’s high bandwidth requirements.

Fiber is the media of choice, and

Copper is the fallback.

The suggested media and designs will need to take into account the individual PSAP bandwidth

requirements, availability of service providers and costs.

http://en.wikipedia.org/wiki/Microwave

http://en.wikipedia.org/wiki/Infrared

http://en.wikipedia.org/wiki/Point-to-point_(telecommunications)

http://en.wikipedia.org/wiki/Point-to-multipoint_communication

http://en.wikipedia.org/wiki/Broadcasting

http://en.wikipedia.org/wiki/Cellular_network

http://en.wikipedia.org/wiki/Wireless_network

31

5.1.5.3. Private vs. Public vs. Hybrid

In an emergency communications environment, it is absolutely essential that quality voice and data

functions be maintained twenty-four hours a day, seven days a week. Issues such as network reliability

and redundancy are key to this requirement and are intended to ensure 99.999 percent reliability.

In consideration of the foregoing mandatory assumption, MCP understands that the options for network

modeling are key issues in the Colorado 9-1-1 community. Of interest in the design of an emergency

services network is the modeling of networks that reach beyond the traditional conservative approach

of publicly owned and managed closed networks.

Historically, government tends to opt for closed networks with little or no access beyond the intended

service that the network serves. In addition, most legacy public safety networks are typically used for a

specific purpose intended to serve a single operational objective. When challenged by the potential

functionality that a modern IP based public safety network could offer, it becomes very clear that the

integration of multi-function applications and other network transport methodologies, will challenge the

traditional approaches in this regard.

Conversely, the private sector takes the opposite approach. Commercial networks enable multiple

users with various applications and data coexisting in an open access environment that are limited only

by bandwidth. Also of issue are the challenges faced by network providers throughout the state.

Network facilities are directly proportional to population which results in certain areas of Colorado

having limited access to network facilities.

Urban communities and areas of prospering local industry are much better off than remote communities

with small populations; however, the public demand for broadband access is resulting in a strong effort

to satisfy this need all across America. MCP believes that broadband facilities will be available to most

citizens in the near future.

Multiple networks also present challenges. Generally they require a higher level of management, and

the new governance authority would need to address the monitoring of multiple networks to meet the

desired reliability criteria.

As stated, network reliability and redundancy is a high priority. If the desired level of reliability or

redundancy is not possible with one network, then obviously multiple networks are required. In short,

the most practical approach for consideration leans towards considering a brand new model for the

establishment of emergency services networks across the state.

Therefore, it is MCP’s belief that a balance between a private solution and public solution present a

viable option for NG9-1-1 networks in Colorado.

This hybrid approach will require a degree of research to ascertain exactly where viable and available

public and private networks exist. It is fully anticipated that situations where one or the other will be the

only option, but it can also be assumed that in other locales there will be more options available to

32

network planners. Where there are many available networks, issues of reliability and redundancy will be

more efficiently managed.

Table 2 summarizes the advantages and disadvantages of a hybrid network model:

Table 2: Hybrid Network Model- Advantages and Disadvantages

Advantages Disadvantages

More network facility choices Requires a higher level of management

Capitalizes on existing public and

private telecommunications facilities

Network operations status is more

complex

Negates the requirement to install new

public networks

The use of private network facilities will

raise concerns with Law Enforcement (e.g.

COPLINK stakeholders) regarding security

of information on a public network

Capitalizes on the investment of

government and private industry to

provide broadband telecommunications

to the public

Reliability and redundancy issues will be

raised, particularly with the private sector

telecommunications facilities

Provides a proper balance between

public and private network facilities.

Capitalizes on the assets of the public

and private sectors.

5.1.5.4. Geographic Challenges

The establishment of an NG9-1-1 network is further complicated by the diverse geography of Colorado.

As discussed in this report, there is a broad range of telecommunications facilities that have been

established to meet regional needs. Existing facilities have been established to meet the needs of an

urban population base, as well as industrial, seasonal and economical pressures.

As discussed in the preceding section of this report, urban communities and areas of prospering local

industry tend to be much better off than remote communities insofar as the availability of

telecommunications facilities is concerned. Nonetheless, it remains that significant areas of Colorado

33

face technological challenges. Remote areas with a sparse population base may continue to face a

shortage of network facilities.

Where there are no established telecommunications facilities, other options must be considered. There

are areas of North America, particularly in the remote regions of the Canadian north, where

communities have full access to the world’s communications facilities. Commercial internet is available

through WiFi networks connected by satellite. This also includes access to the public switched

telephone network. Police agencies have full access to their on-line query systems, as well as the

federal criminal records management systems.

In short, providing access to telecommunications facilities to remote regions of Colorado is achievable

through existing technologies.

Issues such as the most effective medium to use in remote locations converge to the same issues

faced in urban regions. The crucial element is the medium that connects the remote community to the

backbone network, and ultimately becomes the Achilles heel in a statewide network.

5.1.5.5. Next Steps

The suggested next steps in the development of solutions to provide network access to remote areas of

Colorado include, but are not limited to, the following:

Evaluate availability of telecommunications statewide

Identify remote areas or communities that require network access

Research facility options including satellite, WiFi or any other public or private network access

facilities

Evaluate equipment and recurring costs

Determine the most cost effective means of providing access to telecommunications facilities

34

6. REGULATION

In an effort to evaluate possible regulation models for an NG9-1-1 network, the current regulatory

structure for 9-1-1 services was reviewed, analyzed, and discussed in depth during the stakeholder

interviews.

Colorado’s collection of rules, statues, bylaws and certificates of incorporation were evaluated to gain a

basic understanding of the regulation model used in today’s environment to manage the Colorado 9-1-1

infrastructure. As mentioned in Section 2 of this report, Colorado is a ―home rule‖ state so all decisions

related to the implementation and funding of 9-1-1 services are managed at a local level; however, to

balance out the implementation of home rule decisions is the use of the Colorado PUC, which is the

regulatory body responsible for the oversight of the Colorado 9-1-1 network today.

The regulation or governance of a NG9-1-1 solution is influenced by the architecture of the network as

the discussion of regional and statewide systems has evolved. This does not mean that local control of

basic emergency service delivery is relinquished. Therefore, MCP’s recommendations in this regard are

based on the emphasis of local control, the need for an independent administrative model, and the

overall need to establish statewide regulations.

MCP recommends a governance model consisting of an independent administrative entity, called the

Colorado NG9-1-1 Authority, established to regulate a statewide NG9-1-1 network.

This includes, but is not restricted to, the following:

The authority to identify current and future statewide NG9-1-1 features

Overall NG9-1-1 functionality needs

The establishment of statewide network and equipment and connectivity standards needed to

implement the previous suggested phased technical solutions

The above recommendation aligns with and is complementary to the statewide network architecture

recommendation articulated in Section 5 of this report.

The evolution of 9-1-1 in Colorado has led to the establishment of certain entities intended to oversee

the administration and operation of the existing statewide 9-1-1 system. These are detailed in the

following sections of this report, and include:

6.1 EXISTING GOVERNING BODIES

6.1.1 PUC

The Colorado PUC regulates utilities and facilities so that the people of Colorado receive safe, reliable,

and reasonably-priced services. The Telecommunications Section of the PUC is the primary regulatory

35

body and is responsible for the oversight of the 9-1-1 network. This excerpt from the Department of

Regulatory Administration (DORA) identifies functions of the Telecommunications Section:

“These functions, performed under direction of the Commission, include: tariff administration;

certification of new providers; service quality monitoring; market observation and study;

administration of various telephone subsidy programs; and, analysis and development of

regulatory schemes which help further development of a more competitive telecommunications

market in Colorado.”

In pursuit of its mission the PUC established the 9-1-1 Advisory Task Force and the Colorado 9-1-1

Resource Center.

6.1.2 9-1-1 Advisory Task Force

The purpose of the 9-1-1 Advisory Task Force (Task Force) is to research and report on subjects

related to implementation of 9-1-1 services, database formatting standards, ALI data transfer and

related issues to assist the PUC in developing rules for emergency reporting services throughout the

State of Colorado.

The 25 members of the task force represent Colorado Counties, Inc., Colorado Municipal League,

Office of Consumer Counsel, Federal Communications Commission, the Colorado chapter of NENA

and Disabled Telephone Users, Authority Boards, PSAPs, Basic Emergency Service Providers,

Certificated Basic Local Exchange Service Providers, Wireless Providers, Resellers of Basic Service,

Competitive Access Providers, Consumers, Governing Bodies and ALI Data Base Providers.

The Task Force provides a formal communications channel to deliver consumer and operational input

to the PUC rule making process. It also provides an informal communications channel to allow

consumer and operational input on a variety of other related issues.

6.1.3 Colorado 9-1-1 Resource Center

The Colorado 9-1-1 Resource Center (Resource Center) exists to support those 9-1-1 professionals

keeping the public and public safety responders of Colorado safe. It does this by creating a statewide

information database and clearinghouse where 9-1-1 professionals can learn about current issues, how

other authorities and PSAPs do business, see sample policies and organizational documents, and

make their voices heard.

Members of the Resource Center board of directors are appointed from the membership of the Task

Force to ensure the direction is consistent with issues faced by those with a thorough understanding of

Colorado’s public safety communications.

The Resource Center also facilitates communications between 9-1-1 professionals and policy makers.

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6.1.4 9-1-1 Emergency Authority Boards

An Emergency Authority Board (Authority) is typically an independent body formed by an

intergovernmental agreement (IGA) between a county, cities, towns and fire districts within the county.

As previously defined, Colorado is a home rule state so all decisions related to the implementation and

funding of 9-1-1 services are managed at the Authority level. In Colorado there are 56 bodies (authority

boards or equivalent) that are responsible for basic emergency services within each jurisdiction.

The Authority assumes a leadership role by identifying 9-1-1 communication system needs,

establishing equipment standards, and implementing technical solutions. The boards receive their

funding from Emergency Telephone Charges (ETC) collected by local exchange carriers, wireless

carriers, and VoIP providers and remitted directly to the appropriate governing body.

The authority board’s responsibility is to the local area or areas it serves, as well as for coordination

with statewide initiatives.

Figure 5 below depicts the current governing bodies of Colorado 9-1-1.

PSAP 1

Local IP network

CPE/CAD

Std Operating Procs

Recording

PSAP n

Local IP network

CPE/CAD

Std Operating Procs

Recording

PUC

9-1-1 Advisory

Task Force Colorado

9-1-1 Resource Center

Authority Board 1

Authority Board

56

Rule making advisory

interaction

Members 9-1-1 Auth Boards

BESPs

LECs

Wireless Providers

Consumers

ALI DB Providers

Governing Bodies

MembersBoard elected from 9-1-1

Task Force members

Communications

Communications

Communications

Com

mun

icat

ions

Figure 5 - Existing Governing Bodies

37

6.1.5. Interworking

Figure 5 uses ovals to represent areas of responsibility and connecting lines to depict interworking and

information exchange among the governing bodies.

The Task Force combines the local operational management of basic emergency service delivery with

consumers, technology providers and other related government agencies to provide a two-way channel

between the Task Force and the regulatory process within the state. The combined voice of the

members establishes a more coalesced set of issues for consideration by the PUC.

The Resource Center supports the overall process by providing easy access to a repository of 9-1-1

information and distributing information to interested parties as it becomes available. Feedback is

provided to the Resource Center via board members who are also members of the Task Force.

6.2 EMERGENCY SERVICE DELIVERY

6.2.1. Basic Emergency Service Delivery

The establishment of policy (e.g. call center administration and routing), receiving calls, answering

calls, dispatching responders and final disposition are a part of, and will continue to be, the delivery of

basic emergency services. In a next generation environment these will continue to remain under the

control of local Authorities and PSAPs, and will continue to reflect the needs of the communities they

serve. A strong message throughout the interviews was that this is a requirement of a significant

majority of the stakeholders.

To that end, the recommended Colorado NG9-1-1 Authority model supports this requirement. Local

officials will continue to form cooperative bodies which control funding distribution to the mutual benefit

of the communities. Local stakeholders (e.g. sheriffs, police chiefs, fire chiefs) will also continue to

control the operation of their respective PSAPs.

The addition of this Authority to the existing arrangement is that the current Authority Boards may no

longer need to contract directly with the BESP(s) for service.

The mission and objectives of this new Authority must be established to support local requirements as

well as through the selection of BESPs. It should be noted, however, that, as with any cooperative

endeavor, some compromise should be expected.

6.2.2. Basic Emergency Service Infrastructure

As NG9-1-1 evolves, definitions are being modified to more accurately describe elements of the

solution. The NG9-1-1 infrastructure must support the features and functions locally controlled by

PSAPs, as required, to deliver services to their users. In the current BESP arrangement, a single

provider delivers transport and E9-1-1 functionality with the execution of contracts via the BESP and

the local Authority. Local community service delivery is dependent on the service provider’s capabilities.

38

This does not change in the NG9-1-1 environment; however, MCP is recommending that multiple

BESPs are approved and authorized to provide the service in a competitive environment. Although a

relatively new concept in Colorado, it must be noted that other states such as California and Texas

have been successful in embracing various ALI database models in a competitive environment.

The NG9-1-1 architecture redistributes and enhances functionality of the E9-1-1 system. It

encompasses the most common media types and robust extensibility possible by specifying open,

standards-based interfaces, publicly-available routing information, and ubiquitous methods for

accessing location information.

This is leading to the partnering of vendors to deliver the total solution. With the addition of multiple

BESPs, each vendor can focus on their particular strengths and, collectively, they produce a complete

system. This is an important note for the contracting authority as mechanisms (e.g. contracting with a

prime) may be required to reduce the contract management effort required.

In addition, there is the issue of the governance of multiple BESPs. Under the current arrangement,

governance and dialogue with the current BESP model is relatively straightforward; however the

addition of multiple BESPs functioning at a local level will change this dynamic. This challenge must be

identified and methodologies developed that ensure that coordinated regulation occurs both at the local

as well as the state level.

Multiple BESPs must function together to ensure reliable access to caller identification and related

location information. In other words, disparate and out of date ALI databases cannot be tolerated. In

order to ensure reliable call transport, there must be a backbone system of interconnection as well as

self-updating functions between all BESPs. Cost averaging formulas will need to be developed and

applied according to the evolution of BESPs and their respective coverage and service delivery areas.

This no doubt will have an effect on the current cost averaging formula; however, overall a more

efficient and equitable cost averaging model should emerge. It is anticipated that replicating the NG

architecture at the local level will be cost prohibitive and a less efficient use of public funds. The

ubiquity of access using standards based IP methods supports multiple local communities sharing

functions thereby gaining the efficiency required. This reality influences governance model selection.

6.2.3. Review of Additional Governance Models

6.2.3.1. Consolidated Communications Network of Colorado

Several stakeholders referenced the Consolidated Communications Network of Colorado (CCNC) as

an organization model currently used in the state. The CCNC website provides the following

description:

“The CCNC is the user and managing organization of the Statewide Digital Trunked Radio System

Network (DTRS).”

39

The organization is established as a non-profit 501 (c)(3) corporation managed by a board of directors

made up or representatives from users and standing members identified in the bylaws. Its purpose is to

manage, promote and propagate the statewide radio network.

The definition of membership is defined in the bylaws as:

“A User Agency is defined as Law Enforcement, Fire, School, City, County, State, Tribal and Federal

Government (a combination of all non public-safety government functions) or any agency eligible to

meet FCC regulation 90.20. For membership the agency must be using and transmitting on the

Colorado Statewide Digital Trunked Radio system (DTRS) as its primary means of voice

communications in performance of its duties or has filed a migration plan with CCNC and is in the

process of doing so.”

An Associate Member class is available for commercial organizations, data users, or interoperability

only users that are interested in the Colorado Statewide DTRS. This membership class is non-voting.

Associate members cannot hold office.

An Authority style committee structure is used to focus on two areas:

1. Technical issues

2. Operations issues

The organization operates using recognized decorum including organizational structure, regular

meetings, a quorum requirement and a majority vote decision making process.

6.2.3.2. COPLINK Consortium

Another example of a potential organizational model is the COPLINK Consortium. The State of

Colorado, through the efforts of the Colorado Information Sharing Consortium (CISC), implemented

COPLINK statewide in 2009. This system provided for comprehensive information sharing and

collaboration among local, regional, state and national law enforcement and public safety agencies

throughout Colorado.

The CISC is the governing board of the COPLINK implementation initiative, and is comprised of six

public safety organizations:

Adams County Sheriff's Office

Arapahoe County Sheriff's Office

Aurora Police Department

Colorado Bureau of Investigation

http://encyclopedia2.thefreedictionary.com/Information+sharing

http://encyclopedia2.thefreedictionary.com/CISC

40

Douglas County Sheriff's Office

Grand Junction Police Department

CISC uses Memorandums of Understanding which provide the governing guidance for all public safety

agencies that are COPLINK participants. It has also developed a conceptual business plan and

implementation strategy. A cost model pro forma was developed that reflected significant cost

efficiencies for each participating agency and the taxpayers they serve. Participating agencies are self-

funded.

Although the foregoing examples may not apply directly to the NG9-1-1 governance model, there may

be elements of both models that are worthy of consideration by the proposed new Authority.

6.2.4. Colorado NG9-1-1 Authority Committee Structure

The recommended committee structure is based on established and functioning organizations in the

State of Colorado and work previously performed by MCP with other jurisdictions contemplating NG

implementations.

Although initially viewed as a potential membership-based model for a statewide NG9-1-1 governing

authority, the CCNC model has been reported by Colorado 9-1-1 stakeholders as being potentially

problematic. While there was no outright rejection of the concept of a membership-based state-level

NG9-1-1 Authority, there was trepidation expressed over the replication of the CCNC model.

It was further suggested that while CCNC may be a reasonable model in terms of a statewide

governing authority, stakeholders expressed concerns regarding the CCNC’s long term financial

planning.

MCP researched governance models similar to the CCNC and was unable to discover any entity that

would fit the Colorado demographic.

MCP agrees that a membership based governance model must be further researched and developed,

by Colorado 9-1-1 stakeholders, that best fits the regulatory and demographic environment that is

unique to Colorado.

In short, assuming the CCNC model is viewed as problematic, particularly insofar as long range

financial planning and long term sustainability is concerned. It is absolutely imperative that in order for

the successful implementation and operation of a NG9-1-1 network, short and long term financial

planning be established as a high priority within the governing authority entity.

The recommended model is similar to those being considered in other jurisdictions and that used by the

Authority Boards. MCP is working with several jurisdictions as they define governance models. The

hierarchical structures which support local emergency service officials and managers to participate in

collaborative authorities or boards is prevalent in MCP’s experience.

41

Oversight and management is required for the new statewide NG9-1-1 based networks serving multiple

geographical areas. Figure 6 depicts the relationship of the new Colorado NG9-1-1 Authority to other

existing areas of responsibility.


42

LNG

ESRP

ECRF/LVF/

LIS ANI/ALIController

Legacy PSAP

Data CallMgmt

ANI/ALIController

I3 PSAP

Data CallMgmt

Local Exchange Carriers &

Resellers

Another BESP

Wireless Providers

9-1-1 Calls

Rules

Interoperability

(Inter-region and

inter-state)

9-1-1 Advisory

Task Force Colorado

9-1-1 Resource Center

Rule making advisory

interaction

Members 9-1-1 Auth Boards

BESPs

LECs

Wireless Providers

Consumers

ALI DB Providers

Governing Bodies

MembersBoard elected from 9-1-1

Task Force members

Public

ALI DB

Multiple

BESPs

Rules

Interconnection, call

delivery, QoS, rates,

ETC procedures, etc.

PUC

Colorado NG9-1-1 Authority Members appointed by participating

Authority Boards

Coordinates shared resources

Ensure PSAP interoperability

PSG

Authority Board 1- Y

Local IP network

CPE/CAD

Std Operating Procs

Recording

Regional

Networks (1-n)

9-1-1 Calls

With ANI

Figure 6 - Proposed Governance

The Authority may be established as a non-profit 501 (c)(3) corporation if deemed appropriate by the

founding members. Bylaws should be adopted to define membership, board presentation, officers,

voting, and other typical organizational and procedural policies.

The following paragraphs provide example wording for the bylaws’ mission and membership sections.

The mission:

Through active user participation, manage the funding, implementation and operation of the Next

Generation solution serving PSAPs within the members’ jurisdictions.

43

Membership:

Users may be any Governing Body (as defined in Code of Colorado Regulations 4 CCR 723-2-2145)

who enters into an agreement with other users and abides by the bylaws of the Authority. Each user

may designate one representative to serve as a member of the Authority.

The designated representative from each user will have one vote in the election of the Board of

Directors.

6.2.4.1. Next Steps

The suggested next steps in the development of a suitable governance model include, but are not

limited to, the following:

Evaluate governing entities and authority models in Colorado that re functioning effectively

Establish a list of priorities that align with the core values of the state 9-1-1 stakeholders

Ensure that an agreed to short and long term financial plan is established

Ensure the model adequately addresses Craft a charter that embodies regional differences

including the concept of regional networks.


44

7. FUNDING

The 9-1-1 stakeholders in the state of Colorado have come together in a collaborative effort to improve

emergency communications services to their jurisdictions.

This section of the Colorado Next Generation 9-1-1 System Review Report reflects the research into

potential funding models in support of a NG9-1-1 Internet Protocol (IP) enabled network.

The current funding model used in Colorado to support statewide 9-1-1 services has been reviewed,

and comments in this regard are included herein. In addition, other funding options are presented for

consideration.

It should be noted that, during MCP’s research efforts, no other comparable funding methodology

similar to the Colorado 9-1-1 funding model could be found.

Funding considerations as outlined by the NENA are also included.

This effort will require funding of the various network technical components as outlined in Section 4 of

this report.

7.1. METHODOLOGY

Discussions are included regarding funding models and cost distribution. This comes as part of the

identification and modeling of the regulatory structure as outlined in Section 6 of this report.

7.2. RESEARCH OF FUNDING MECHANISMS

7.2.1. National Emergency Number Association (NENA)

Cost distribution models were researched using the NENA funding model report4. This report identifies

changes that may occur, and in Colorado’s case, have occurred within the 9-1-1 industry. These

changes have, and will continue to impact the current fixed surcharge 9-1-1 funding model. The report

also suggests a number of optional funding models which could be implemented.

7.2.2. Colorado 9-1-1 Surcharge Fees

There are two funding mechanisms in the state of Colorado authorized by the Public Utilities

Commission (PUC). The current funding sources are:

9-1-1 Surcharge fees on fixed landline phones, wireless (cellular) phones, and VoIP telephone

devices

Point of Sale Prepaid Wireless 9-1-1 Service Fee

7.2.3. Landline and Wireless Telecommunications Surcharges

The PUC has established, pursuant to statute, a standard statewide 9-1-1 surcharge of up to seventy

cents per month per landline telephone, wireless telephone, and Voice over Internet Protocol (VoIP)

telephone devices or otherwise at a level above seventy cents as approved by the PUC. The 9-1-1

45

surcharge for landline telephones is collected at the local level from the respective telecommunications

service providers across the state. All landline, monthly billed wireless, and VoIP account surcharges

are remitted directly to the local 9-1-1 Authority. Prepaid wireless 9-1-1 surcharges are collected from

the retailers and remitted to the state Department of Revenue, which redistributes the funds to the local

9-1-1 authority/county for distribution based on wireless call volume.

Fifty-six governing bodies (authority boards or equivalent) receive their funding from 9-1-1 surcharges

collected by these service providers, remitted to the appropriate governing authority or county.

For landline and VoIP customers, the surcharge funds are calculated based on the percentage of ALI

records for that jurisdiction compared to the overall ALI records for the state. Logically, the bulk of the

surcharge funds are directed to areas of the state with a larger concentration of population. Likewise,

areas with sparse populations receive proportionally less surcharge funds than the urban areas.

The 9-1-1 surcharge is imposed by a local governing body, typically a 9-1-1 authority board, to pay for

costs incurred for the continued operation of emergency telephone service within that governing body's

jurisdiction. This may include equipment, installation, and other directly related emergency call

processing costs. Refer to Appendix B – §29-11-102 (1)(a), C.R.S. 1997.

If a governing body intends to increase its 9-1-1 surcharge above seventy cents it must request

approval pursuant to §29-11-102(2)(b), and must file an Application with the PUC pursuant to 4 CCR

723-2, Rules 2002. Funds collected from the charges imposed must be used for its intended purpose

pursuant to §29-11-104(2)(a)(I). Supporting documentation (cost, budget projections, audits) justifying

the proposed increase in the surcharge must be included in the Application.

Refer to Appendix C – 9-1-1 Surcharge Fee Schedule for the past and current surcharge fees for each

9-1-1 authority.

7.2.4. Prepaid Wireless Telecommunications Service

The following is an overview of the terms of the prepaid wireless telecommunications service

legislation, which was recently enacted for prepaid (point of sale) wireless devices, as well as the

recharging of pay as you go wireless devices. It went into effect on January 1, 2011.

The intent of this surcharge is to fund enhanced 9-1-1 services in Colorado.

Refer to Appendix D – Colorado Department of Revenue - Taxpayer Service Division - FYI General 21 -

E9-1-1 Surcharge for a more detailed explanation of this surcharge.

7.2.4.1 Definition

The above noted FYI General 21 – E9-1-1 Surcharge defines Prepaid Wireless Telecommunication

Service as, ―Any wireless telecommunication access that allows a caller to dial 9-1-1, is paid for in

advance, is sold in set units or dollars and decline with use is considered prepaid wireless

telecommunication service.‖

46

7.2.4.2 Rate

Prepaid wireless telecommunications service is subject to an E9-1-1 surcharge of 1.4% of the price of

the retail transaction.

7.2.4.3 Wholesale Sales of Prepaid Wireless Telecommunications Service

Wholesale sales are not subject to the E9-1-1 surcharge. Wholesale sales are reported on the Prepaid

Wireless E9-1-1 Surcharge Return (DR 0526), line 2. Taxpayers are required to keep records of such

transactions for three years [§39-26-116, C.R.S.].

7.2.4.4 Home Rule

Home rule cities and towns administer and collect their own local sales and use taxes. A retailer or

vendor within a particular home rule jurisdiction must file a local sales and use tax return within that

jurisdiction.

Colorado state sales tax is collected and remitted to the state by the retailers or vendors on a Colorado

state retail sales tax return for businesses; it is not collected and remitted to the home-rule city. This

also applies to any special district taxes if the home rule city is located within a state administered

special district area.

Equalization surcharges and wireless 9-1-1 service fees are collected on a monthly basis from the

telephone subscription customers and remitted by their service providers (e.g. AT&T, Verizon, Cricket,

Vonage, etc.). The collected fees are remitted to the Colorado Comptroller of Public Accounts

(Comptroller). Service fees for 9-1-1 are distributed back to the appropriate 9-1-1 authority or county

based on the subscribing customer’s physical and/or billing address.

7.3. STAKEHOLDER COMMENTS

This section provides an aggregate summary of the thirty-four stakeholder interviewee comments

concerning the funding issues posed to the participating entities (Refer to Appendix E – Non

PSAP_PSAP Summary Worksheet Interviews 11FEB16).

Briefly describe the 911 funding model for your area?

The majority of interviewed stakeholders were familiar with the current funding model used in

their area.

Do you feel the funds are distributed fairly?

The majority of interviewed stakeholders (22) answered in the affirmative to this question.

There were six stakeholders that answered in the negative.

There were six stakeholders that did not offer an answer or chose not to comment on this

matter.

47

Are there restrictions on how you allocate or spend your funds?

There were twelve stakeholders that reported that the interpretation for the allocation of funds

was fairly broad in nature, but managed in a discretionary manner at the local level.

There were thirteen stakeholders that reported that the interpretation for the allocation of funds

was more restrictive in nature, and managed in a discretionary manner at the local level in

accordance with statutory limitations.

There were nine stakeholders that did not offer an answer or chose not to comment on this

matter.

Are there restrictions to retaining funds across fiscal periods?

There were eight stakeholders that reported restrictions to retaining funds across fiscal periods.

There were seventeen stakeholders that reported no restrictions to retaining funds across fiscal

periods.

There were nine stakeholders that did not offer an answer or chose not to comment on this

matter.

How should the ESInet (NG9-1-1 network) be funded?

There were a broad range of answers from twenty-four stakeholders. These are listed in the following

bullet points in the language captured by the MCP interviewer. Note that letters or words appearing in

parentheses () have been inserted, where appropriate, for language clarification. There were ten

responders that did not offer an answer or chose not to comment on this matter.

―Infrastructure construction (funded) by local governments with grant assistance. Operation and

maintenance with a user fee structure that would also provide funding for those areas where it is

not practical or possible for local government to construct (fund) infrastructure‖

―Pay as part of the device service from the carriers - a new formula is derived that has fixed and

Mobil components - property tax - state take charge and make the decision and then use funds

such as the previous state property tax‖

―PSAPs should pay to replace the current network, but (this concept) will not work with (the)

current funding model today‖

―State level 9-1-1 authority independent from the state. If they were able to do that, a

membership fee along with the funds that are currently collected. State 9-1-1 surcharge (via) a

statute would have to be collected by the state. In (order)for it to be fair, all would have to pay

in‖

48

―There needs to be some additional national funding (capital grants, operating grants for

transitioning); however, would not take the place of (the) surcharge currently in place. In the

spirit of the National Broadband Plan, any federal funding mechanism should reflect the overall

goal of promoting private investment and innovation. Federal funds (grants, loans, or universal

service-like programs, etc.) should also be available to private companies as well as for public

agencies. Additionally, funding should be administered by a neutral third party‖

―We continue to chase the money, prepaid, (and services such as) magicJack, which claims not

to be a VoIP (because) of some definitions. Whatever can connect to 9-1-1 (then) that service

should have to pay a 911 service charge. (Call) volume type of funding, only prepaid wireless.

Funding (should) not (be) population based. Population is going to be closely comparable. PUC

has data on call volume‖

―Capital funding (should be provided) by private entities, BESPs and the carriers from whom

they may purchase network services, if they don't operate their own networks. Authority costs

will need to recover the amortized costs of the network plus a profit margin for the provider,

constrained by competition or PUC costing and pricing review. Other comments - re alarm and

other service providers who may reap a profit by marketing the ability to transmit additional data

to the PSAP for example, could be another funding source, although this would primarily benefit

urban areas where you are more likely to find these services. It should be funded through

charges to the Authorities, which will in turn pay them out of the Emergency Telephone

Surcharge or some future user charge which is assessed in an equitable manner. That is a

longer term issue. It could be funded out of charges on utility bills as one other state has done,

through property tax, or state income tax, although that may be difficult given the Taxpayer

Initiatives which limit the government's ability to increase tax rates, or perhaps through local

property taxes. The replacement of the surcharge with a tax would not necessarily result in a net

increase in constituent charges, but by being a tax rather than a surcharge the use of the funds

would not be so limited and there would be more competing demands for the revenues‖

―Similar to (existing) 9-1-1 (funding model). Telecommunications surcharge on the potential

users and beneficiaries of the system. ESInet (NG9-1-1 network) cannot be funded within the

same budget (Service fee); impose an amount above current surcharge‖

―Recommendations should be determined through this contract‖

―The common/shared components should be funded by all jurisdictions that are participating in

the ESInet (NG9-1-1 network). The non-shared components would be funded by the

jurisdictions individually. Company B's basic presumption is that the current level of funding

across the state is adequate to fund the evolution to NG9-1-1. It is assumed that a large, up-

front investment needs to be made by the jurisdictions. The proposed Company B Tariff

commits to this. Call volume based type of model (is) not bad – (per) PSAP – (try)

implementing‖

49

―Three responders suggested the network should be funded through ―an additional 9-1-1

surcharge‖

―Every county signing an inter-local agreement (ILA or IGA) and giving all the 9-1-1 money

collected in their area to the state. Give each entity time to accumulate funds and make sure all

equipments are upgraded and up to date before funds are given to the state‖

―Either user partners contributing, or each user lease it through a private company. (Adopt the

concept of) 9-1-1 surcharge(s), user fees, equality across the board‖

―What is allocated today for 9-1-1 trunks would move toward broadband network, distributed

based on call volume? If service fee is not going to be tax based, (then) using call volume as a

formula would work. Permanent population is low, however, during seasonal tourism 9-1-1 calls

go up. (These 9-1-1 calls from out of state subscribers are) not (revenue) generating calls.

(Need a method for generating) revenue (when) receiving (9-1-1) calls from out of town phones

would help‖

―Funding should be calculated by usage‖

―Federal Government - Development of some level of capital infusion to move things forward -

setting aside some level of authority funds to tag toward capital assets and connect some of

those agencies that are moving (things) forward at a faster rate so that the outlying areas can

be addressed in another phase - if they cannot pay in (to the system) then they use the

equipment of (an) opted-in entity - may not be able to be just E9-1-1 money - consider how to

pay based on usage of the device - "it is going to get uncomfortable" - again there needs to be a

large infusion of cash‖

―Re-allocating the funds we already expend (i.e. on QWEST) – (establishing) a public/private

partnership – (using) funds from some of the private ―for-profit‖ funds since the resources are

cost shared - prepaid resources‖

―Grants that are typically tagged for radio should be used to assist with one-time costs to lay

fiber; a portion of funds go into a pool for this network; pre-paid only is a new source‖

―The local authority board would continue with the existing revenue stream and then again buy

services - the bigger issue of funding is the potential up-front costs - does funding need a

statewide averaging to assist with the funding (similar to the tariff) - Not convinced that state

funding is not the way to go - experience in Maricopa in AZ and Long Beach in CA where

money could not be dispersed because of state budgets and allocations‖

―ESInet (NG9-1-1 network) will not come about without a tax levy of some sort ((on) property

tax)‖

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―The new pre-paid money goes to the state - it will be distributed based on volume - there is

some concern - this may also set up an opportunity for success with a state model - Endorses

the collaborative effort - but is worried about a new funding model that would compromise this

entity‖

7.3.1. Synopsis of Funding Related Comments

The following synopsis represents a summary of the feedback received from the stakeholder

interviews concerning comments specific to funding. Refer to Appendix E – Non PSAP_PSAP

Summary Worksheet Interviews 11FEB16).

The majority of 9-1-1 stakeholders understand the 9-1-1 funding model used in their area.

There is a significant split in the number of stakeholders that that feel that E9-1-1 funds are

distributed fairly.

The interpretation of the restrictions concerning the allocation of E9-1-1 funds (i.e. how

E9-1-1 funds are spent) occurs at the authority/local level.

The majority of 9-1-1 stakeholders retain funds across fiscal periods.

The following is a synopsis of opinions germane to how a NG9-1-1 network should be

funded:

o Network Infrastructure funded by local government

o Common/shared network components shared by participants

o Non-shared components funded locally

o National grants for initial capital and network roll-out costs

o Operation and maintenance funded by user fees

o All PSAPs funded in an equitable manner with ensuring a common technology platform

for all PSAPs

o New sources of revenue include property tax, sales tax, utility bills, tourism tax,

increasing the current E9-1-1 surcharge(s)

o Independent state-level 9-1-1 Authority or neutral 3rd party to manage & administer funds

o User pay membership/participation fees (includes commercial/private sector

beneficiaries)

o Pursue capital funding revenue from private sector

o Pursue non-revenue generating prepaid devices (I.e., magicJack)

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o Funding distribution model should not be solely population based but also include a call-

volume (usage) or statewide averaging formula

o Funds allocated to radio be diverted to pay for fiber upgrades

7.4. NATIONAL NG9-1-1 FUNDING DISCUSSIONS & CONSIDERATIONS

The following documents contain discussions relevant to today’s funding issues, potential NG9-1-1

funding solutions, and revenue collection options. Where appropriate, excerpts germane to this project

are provided here for easy reference and further consideration.

7.4.1. Next Generation 9-1-1 Transition Policy Implementation Handbook:

The NENA Next Generation Partner Program has released a new report entitled Next Generation 9-1-1

Transition Policy Implementation Handbook: A Guide for Identifying and Implementing Policies to

Enable NG9-1-1. This document provides an overview of the key policy, regulatory, and legislative

issues that need to be considered to facilitate the transition to NG9-1-1. The report is useful for 9-1-1

leaders and government officials responsible for ensuring that federal, state, and local 9-1-1 laws and

regulations effectively enable the implementation of NG9-1-1 systems:

http://www.nena.org/government-affairs/stories/ngpp-transition-policy-implementation-handbook

The following is an excerpt from the Handbook concerning issues germane to funding NG9-1-1, and

focuses on ensuring that sufficient resources are made available to implement and operate the NG9-1-

1 system.

7.4.1.1. Action Proposed To Resolve Issue:

State and local governments should examine funding, operations, and legislation to ensure they

promote the needed ESInets and multi-jurisdictional cooperation, including interstate ESInets

and NG9-1-1 in general.

Any fees assessed on end users or devices of any service with the ability to access 9-1-1

(potentially including fees assessed on network access providers instead of, or in addition to,

originating service providers) should be reasonable, equitable and nondiscriminatory.

Fee remittance should be made for deposit into a dedicated fund and the allowable uses should

ensure the provision of the needed services for NG9-1-1 and prohibit diversion of funds to other

non-allowable purposes.

Establish a maximum fee, providing the 9-1-1 authority with the ability to adjust the fee rate

based on the cost to provide service.

It is possible to pay for NG9-1-1 services as part of a shared NG emergency services network in

which multiple emergency services functions will pay a portion of the network costs and policy

makers should explore and examine this possibility.

http://www.nena.org/sites/default/files/NG911%20Transition%20Policy%20Implementation%20Handbook_FINAL.pdf



http://www.nena.org/government-affairs/stories/ngpp-transition-policy-implementation-handbook

52

State and federal legislation and grant programs should reflect the growing convergence and

integration of emergency response technology and agency interaction. State interoperability

plans and federal funding in support of them must be for overall next generation emergency

communications, including NG9-1-1.

Federal and state interoperability and Next Generation 9-1-1 definitions need to be more

comprehensive and inclusive (e.g., all emergency response agencies, including 9-1-1, and all

forms of emergency communications). As state and federal policy officials review and modify

current 9-1-1 related policies, all definitions should be reviewed to align with next generation

technology.

Funding legislation should encourage parity of emergency services capabilities, interoperability,

increased efficiency or cost savings within all aspects of emergency communications.

Fees should be based on sound planning that includes short- and long-term projections of

recurring and non-recurring costs and revenues.

Service provider fee remittances should be audited for accuracy, and the 9-1-1 authority or

PSAP should be audited or monitored for use of funds in compliance with legislative and

authorized intent.

7.4.2. NG9-1-1 Transition Plan:

http://www.tsag-its.org/docs/USDOT_NG911_Task_4A3_-_Transition_Plan_Final_020209.pdf

7.4.2.1. Funding Strategies and Options

7.4.2.1.1. Strategy 1: Ensure NG9-1-1 upgrades are considered a fiscal priority for states and

local jurisdictions and the Federal Government through outreach and education

Federal Government

Encourage state governments and legislatures to give fiscal priority to NG9-1-1 upgrades and

transition (based on nationally accepted standards and coherent statewide plans).

Encourage all levels of government to establish an effective mechanism for coordinating 9-1-1

services, where such a mechanism does not already exist.

Consider expanding the use of more federal public safety grant program funds for 9-1-1

services and for shared emergency services internetworks.

State Government

http://www.tsag-its.org/docs/USDOT_NG911_Task_4A3_-_Transition_Plan_Final_020209.pdf

53

Consider legislation that identifies a state agency or other effective state-level mechanism

(where one does not already exist) to be responsible for statewide 9-1-1 planning and

coordination, and granting it appropriate authority and power.

Consider coordinating the development of statewide 9-1-1 plans to justify investments for

upgrading critical emergency communications infrastructure for NG9-1-1, involving all

appropriate stakeholders required for success.

Consider establishing a statewide coordinating body (where one does not already exist) that

addresses the needs of all appropriate public and private representatives.

9-1-1 Authorities and PSAP Administrators

Support state efforts to coordinate the development of statewide 9-1-1 plans and investment

requests for upgrading critical emergency communications infrastructure for NG9-1-1.

Support state efforts to educate state and federal legislative and regulatory decision-makers on

the importance of NG9-1-1 funding.

7.4.2.1.2. Strategy 2: Transform the current funding mechanisms to address:

Diminishing revenue base

Population-based and geographical funding disparities

Funding allocation and governance models for shared resources

Service provider cost recovery

Federal Government

As possible and appropriate, provide funding for the capital costs of NG9-1-1 planning, design,

procurement, and implementation.

Consider legislation that allows use of federal funds to pay for NG9-1-1 portion and use of

underlying IP based emergency service internetworks and core services.

State Government

Consider enacting legislation that imposes a technologically neutral 9-1-1 funding mechanism

that accommodates all current and future devices and services capable of accessing 9-1-1 (e.g.,

text messaging, prepaid wireless, sensors and alarms).

54

Identify opportunities to offset the cost of NG9-1-1 by sharing infrastructure, resources, and

services with, or simply interconnecting with, other public safety, non-public safety government,

or private sector entities.

Consider enacting legislation that requires leveraging economies of scale to mitigate rural/urban

disparities, ensuring efficient use of 9-1-1 revenues, and conducting annual audits on the use of

the 9-1-1 funds.

Establish a funding mechanism or combination of funding mechanisms that best suit a state’s

needs.

Consider legislation that allows 9-1-1 fees to be used to pay for the state’s NG9-1-1 portion and

use of an IP-based emergency service internetwork.

Review how cost recovery is allocated to ensure fairness across all technologies and services,

and determine whether service provider cost recovery can and should be provided.


Work with state government to review how cost recovery is allocated to ensure fairness across

all technologies and services, and determine whether service provider cost recovery can or

should be provided.

Consider innovative funding approaches.

7.4.2.1.3. Strategy 3: Ensure 9-1-1 funds are preserved for 9-1-1 and emergency communication

systems

Federal Government

Consider expanding and strengthening existing Federal requirements that state and local 9-1-1

Authorities to use 9-1-1 funds, surcharges, and fees for costs attributable to 9-1-1 operations,

services, and equipment.

Consider providing guidance regarding what constitutes minimum 9-1-1 features and functions

that are appropriate uses of 9-1-1 revenues.

Implement and oversee existing requirements concerning eligibility for 9-1-1 grant funding to

states that do not divert 9-1-1 funds.

Consider expanding and strengthening existing statutory provisions that 9-1-1 funds be used

exclusively for the provision of 9-1-1 emergency communications services (e.g., 9-1-1, E9-1-1,

NG9-1-1, and related or future upgrades).

55

State Government

Consider requiring that 9-1-1 funds be used exclusively for the provision of 9-1-1 emergency

communications services (e.g., 9-1-1, E9-1-1, NG9-1-1, and related or future upgrades).

Review statutory provisions to ensure funding policies support next generation goals and visions

(i.e., shared infrastructure and economies of scale).

Identify the appropriate uses of 9-1-1 funds and then monitor collected funds and 9-1-1

Authorities to ensure 9-1-1 funds are used for costs solely attributable to 9-1-1.


Strengthen checks and balances to ensure funds are used only for the provision of 9-1-1

services, including shared services (e.g., 9-1-1 portion of emergency services internetwork).

Analyze current 9-1-1 system costs and determine constant costs that will continue in an NG9-

1-1 environment and new costs to assist regional or state entities responsible for NG9-1-1

funding and planning.‖

7.5. FUNDING CONCLUSIONS AND RECOMMENDATIONS

The following conclusions and recommendations are based on:

Feedback received from stakeholders

Current industry standards setting entities

Unique demographics and needs of Colorado

Economic realities currently faced by its citizens and all public entities throughout the state

7.5.1. State Level Legislation

State level legislation will need to be passed in order to change the current 9-1-1 funding model. A

review of the existing revenue streams and the distribution of 9-1-1 surcharge revenues is the first step

in the process of evaluating funding strategies for the development and implementation of a NG9-1-1

network. In short, further changes to legislation may be required that would broaden funding sources in

support of emergency communications networks and systems.

7.5.2. Funding and 9-1-1 Revenue Collection Options

In general, there are several funding options and revenue collection processes being considered

nationally for the establishment and operation of NG9-1-1 networks. As expected, existing 9-1-1

funding models vary from state to state. Researching and developing model legislation for NG9-1-1 will

56

be the next step in the establishing of uniform funding solutions across the country, and may serve as

model legislation templates for states seeking support in this regard.

Understandably, Colorado must consider the financial implications of transitioning from traditional 9-1-1

to NG9-1-1. There will be non-recurring NG9-1-1 infrastructure investment costs, as well as recurring

traditional and NG9-1-1 costs.

Recurring traditional 9-1-1 costs will continue to need to be funded until a transition to a ubiquitous fully

operational NG9-1-1 network is realized. During this transition, and until alternate funding sources are

developed, the current funding stream will need to simultaneously support both the existing system as

well as the transitional NG9-1-1 costs.

It is apparent that stakeholders see the need to pursue non-traditional sources of funding including, but

not limited to the following:

Property tax, sales tax, utility bills, tourism tax

Private sector beneficiaries such as alarm companies, telcos, etc.

Non-revenue generating prepaid devices (I.e., magicJack, etc.)

Colorado taxpayers are not amenable to any increase in service related taxes; therefore, funding

sources that do not directly impact the citizenry must be considered a high priority in the pursuit of

NG9-1-1 network funding.

7.5.3. E9-1-1 Revenue Funding and Distribution Authority

Given the regional disparities that currently exist in Colorado PSAPs, a fair and equitable distribution

model must be developed. As well, consideration must be given to the establishment of an independent

authority to oversee and administer the funding of a NG9-1-1 network.

The most significant factor driving this need is the requirement for all PSAPs to be enabled to

effectively deliver a consistent standard of care and practice across the state. In short, no matter where

a call to 9-1-1 may originate, the call processing system technology supporting the call must be the

same irrespective of the location of the PSAP.

In consideration of a new revenue distribution and system funding model, the administration and

operation model of Colorado’s Consolidated Communications Network of Colorado (CCNC) may be

worthy of consideration as a possible template.

In other words, consideration should be given to the establishment of a similar non-profit 501 (c)(3)

corporation managed by a board of NG9-1-1 stakeholders. In addition to management and

administrative responsibilities, the new organization would also be charged with fund management.

57

7.5.4. Funding Models

7.5.4.1. Local Network Costs

It is suggested that each E9-1-1 Authority be responsible for the following operating costs that are not

part of the distribution structure:

Customer Premise Equipment (CPE)

Local Network

Interconnecting to the NG9-1-1 network for each member (these costs will be based on PSAP

location, CPE, etc.)

The objective is that the capital and operating costs associated to the construction and operation of a

Colorado NG9-1-1 network be distributed evenly to all users.

7.5.4.2. Option 1 – Consumption Based Budgeting – Usage Based

System funding based on consumption is a relatively new model in 9-1-1 systems. Inasmuch as the

existing E9-1-1 surcharge system must be maintained to ensure the ongoing operation of the 9-1-1

system in Colorado, the approach to funding a NG9-1-1 system becomes a new challenge. The

approach suggested here is the consideration of a user-pay system based on consumption. In this

model, the higher call volume PSAPs would be expected to pay more towards the support of the

network infrastructure than the lower volume PSAPs.

Table 3 compares the pros and cons of a consumption based model.

58

Table 3: Consumption Based Model - Advantages and Disadvantages


Those that use the system more would

pay more than those that use the

system less

There is little experience using this method

Subscriber fees are used to offset

operations costs, however each PSAP

would be responsible to cover all local

costs

Subscriber fees are not guaranteed

Calculating budgets is more complex as

usage data may vary dramatically

Funding shortfall risks increase since the

actions of constituents is the driving factor

in the amount of money required by each

9-1-1 authority

A mechanism for normalizing significant

events would be required to prevent an

undue burden on any one 9-1-1 authority

7.5.4.3. Option 2 – Hybrid Averaging Model

System funding based on a hybrid averaging model is also a new approach 9-1-1 funding. This model

adopts an equalization of surcharge funds intended to relieve the financial burden of smaller PSAPs.

This approach is a significant departure from the current E9-1-1 funding formula and clearly will not be

acceptable to some E9-1-1/County authorities. The assumption for this model takes into account the

need to level the playing field for the delivery of PSAP services across the state. In other words, funding

based purely on ALI records and a percentage of wireless 9-1-1 calls no longer serves the collective

needs of Colorado’s citizenry.

The model establishes a statewide minimum service level for PSAPs. A baseline service level then

determines the cost of operations based on:

A 24/7 operation

Minimum staffing requirements

59

Standardized baseline system technologies

Standard of care of practice for the citizens of Colorado

Funding is provided to every PSAP to meet the basic needs of their jurisdiction. Factors such as regular

and seasonal call volume must also be considered and factored into the funding formula.

In addition, if the user pay philosophy is adopted, then the smaller PSAPs that already financially

burdened will simply be unable to participate in NG9-1-1. This fact alone may cause authorities to

consider a migration toward the establishment of ―hosted‖ PSAPs (i.e. PSAPs that operate from, and

are supported by, a remote host PSAP).

Table 4 compares the pros and cons of a Hybrid Averaging based model.

Table 4: Hybrid Averaging Based Model - Advantages and Disadvantages


Levels of service to the public are

standardized throughout the state

There is little experience using this method

PSAPs could better afford subscriber

fees as well as covering local costs

Subscriber fees are not guaranteed

The normalizing of financial support

mitigates an undue burden on any one

9-1-1 entity

Calculating budgets is more complex as

communities shrink/grow over time

There is an ongoing risk of local funding

shortfalls

Fluctuations in local economy due to

recession exacerbate financial burdens in

low population regions

7.6 RECOMMENDATIONS

7.6.1 Recommendation #1

It is recommended that previously proposed Colorado NG9-1-1 Authority is given the authority to

manage funding and revenue distribution for a NG9-1-1 network.

60


It is recommended that a hybrid averaging funding distribution model be adopted for PSAPs connecting

to a NG1-1 network.


It is recommended that a working group committee be established to pursue non-traditional sources of

revenue such as property tax, sales tax, utility bills, tourism tax, commercial/private sector benefactors,

as well as considering increasing the current E9-1-1 surcharge(s) to support an NG1-1 network.

7.7. CONCLUSION

The introduction of next generation technology is forcing new opinions at the state and national levels

regarding funding the new NG9-1-1 technology and sustaining existing emergency services.

Colorado, as a visionary leader, has risen to a daunting challenge in its efforts to establish a world class

state-of-the-art emergency communications system. The forging of new funding model never before

achieved, will ensure its success.


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8. IMPLEMENTATION AND MAINTENANCE

The following section of this report outlines MCP’s recommended NG9-1-1 migration plan.

8.1 NG9-1-1 MIGRATION PLANNING

Before a NG9-1-1 migration plan can be recommended, MCP interviewed a number of Colorado

stakeholders using a variety of questions and forums seeking to understand any PSAP operational

issues that the current 9-1-1 network solution may be hampering PSAP operations. MCP also reviewed

the design of the current 9-1-1 Voice and ALI data network in relationship to the recommendations

developed by the Network Reliability and Interoperability Council (NRIC) some years ago.

NRIC was first established by the Federal Communication Commission (FCC) as an advisory board

and charged with providing recommendations to the FCC and to the industry on specific service

reliability issues facing the communications industry. In the early years, NRIC assembled multiple

subject matter experts from the telecommunication industry and each council was charged with

addressing service objectives and asked to provide a recommendation for improvement within a

specific time frame. In the later years the role of the NRIC council was expanded to include 9-1-1 issue

and subject matter experts from the Public Safety sectors who were asked to join the council.

The council recommendations are in the form of ―Best Practices‖ and more specific information can be

found on the NRIC web site (http://www.nric.org).

8.1.1 Automatic Location Identification (ALI) Network Review

During the stakeholder interviews, MCP did not discover any PSAP operational issues with the present

ALI network that would support a recommendation of replacing the legacy ALI network as an

operational priority, and the current BESP 9-1-1 Service Provider is following NRIC ―No single point of

failure‖ Best Practice recommendations and are providing redundant ALI Links to every PSAP. In

addition the current BESP 9-1-1 Service Provider and their sub-contractor are utilized geographically

diverse and redundant data centers to process and store the ALI records.

However, the existing ALI transport components (―links‖) are very limited and are supporting an older

data encoding protocol that is known as American Standard Code for Information Interchange (ASCII).

This data encoding technology was developed from telegraphic codes that were standardized in 1963

and last updated in 1986. The CPE electrical interface that supports ACSII is a serial data transmission

protocol known as RS-232. There have been many other data communication solutions that have been

developed over the years after ASCII, but by far, the most popular today is Transmission Control

Protocol/Internet Protocol (TCP/IP), this widely used protocol supports the Internet.

At present, the majority of Colorado PSAP’s ALI interfaces are only capable of 1200 bits per second

(aka ―baud‖) which are very slow and limited, even in contrast to the smallest telephone data network

that supports 56 thousand bit per second, which is slow and limited compared to the smallest

broadband network that supports 1.54 million bits per second.

http://www.nric.org/

62

8.1.2 Voice Switching Component Review

During the stakeholder interviews, MCP did not discover any PSAP operational issues with the present

9-1-1 Tandems that would support a recommendation of replacing the legacy tandem as an operational

priority. Unlike many states or regions, the Colorado BESP model is supportive of a unified 9-1-1

network which avoids some of the common problems such as the inability of transferring 9-1-1 calls

with ANI to neighboring PSAPs.

MCP also reviewed the 9-1-1 network design utilizing the NRIC Best Practices that support the voice or

call switching components. These Best Practices addresses 9-1-1 service issues and recommend that

Selective Routers (or Tandems) be configured as mated pairs. This Best Practice recommendation is

as follows:

―Network Operators should consider deploying dual active 9-1-1 selective router architectures to enable

circuits from the caller's serving end office to be split between two selective routers in order to eliminate

single points of failure (SPOF). Diversity should also be considered on interoffice transport facilities

connecting each 9-1-1 selective router to the PSAP serving end office.‖

These NRIC Best Practices support the NENA general recommendation to minimize single points of

failure within any design. The NRIC recommendation is fully implemented in Colorado with the BESP

utilization of mated pair tandems.

8.1.3 Voice & ALI Network Summary

During the Voice and ALI network review process MCP did not discover any PSAP operational or

technical issues that would have prioritized the NG9-1-1 Network migration recommendations to solve

an immediate operational issue or support a risk mitigation requirement.

While it is clearly recognized by the industry that the current ALI network is dated and very limited and

that the current Time Division Multiplexer (TDM) Selective Routers(S/R)/9-1-1 Tandems will not support

NENA i3 recommendations and IP based NG9-1-1 traffic, it also must be recognized that a migration

plan needs to continue to support the PSAP’s day to day operational requirements.

8.2 MIGRATION PLAN - FIRST STEPS

8.2.1 Legacy Selective Router Role

The current mated tandems support the Selective Routing function and also act as concentration points

for all Telecommunication Service Providers that are required to support 9-1-1 calls in Colorado. Some

migration plans that are in the implementation phase in other states or 9-1-1 authorities continue to

utilize the legacy tandems as network aggregation solutions. The output of the S/R that would normally

be connected to the PSAP, instead connects to a NG9-1-1 IP based Legacy Network Gateway (LNG).

The introduction of a LNG can also be designed to preserve the call transferring capabilities with ANI to

all PSAPs.

63

As Colorado Telecommunication Service Provider carriers convert to IP, the legacy tandems can be

eliminated and 9-1-1 traffic can be directly connected to the ESInet. However, it should be noted that

there is no Colorado legislative or any FCC mandates that are requiring Colorado Telecommunication

Service Providers to convert to NENA i3 or any other IP based format in the foreseeable future.

Therefore conversion of voice calls to NENA i3 may not be an immediate need.

Based on MCP’s review which confirmed that the present paired tandem solution is following NRIC

Best Practices and supporting PSAP operation of statewide call transfers, MCP is recommending a

migration plan that leaves the legacy S/Rs in place for the foreseeable future. The legacy S/Rs will act

as network concentrators and will support NENA i2 or older technology interfaces.

The legacy S/Rs can be networked into an ESInet via a LNG that can be designed to support an

individual 9-1-1 Authority or multiple Authorities while preserving the functionalities of Authorities that

elect an alternate NG Service Provider in the future. This recommendation also supports the

independence of each 9-1-1 Authority and the current BESP model until the role of the legacy S/Rs is

no longer required or justified.

8.2.2 ALI Network Migration

Since MCP is recommending that the legacy S/R will continue to have a role for the foreseeable future,

then the sub-component of ALI, known as the Selective Routing Data Base (SRDB) must continue to

be available to support the S/R functions.

As MCP interviewed the various stakeholders, it was discovered that a number of 9-1-1 Authorities are

considering CPE solutions that are configured as Hosts and Remotes. In this configuration, typically all

of the Remote PSAPs use the ALI links that are connected to the Host. While MCP did not discover any

PSAP operational concerns relating to ALI during the interview process, it should be noted that when

there is a larger number of 9-1-1 workstations that are all using the same ALI links, delays in ALI data

being presented at the workstation can be forecasted since the current ALI links are very low speed.

9-1-1 Authorities that are considering Host/Remote configurations should consider a higher speed ALI

link solution.

As 9-1-1 Authorities consider ESInet solutions, one of the components of the ESInet is the Emergency

Call Routing Function (ECRF). A sub-component of the ECRF is the Location Validation Function

(LVF). Several manufactures of NG9-1-1 equipment have the ability to utilize ALI links as one of the

components in support of the LVF.

The current ALI links are outdated and can be too slow to support large CPE Host/Remote installations

or support the NG LVF.

ALI does not need to continue to be transported to the PSAP via the older ASCII/RS 232 ALI links.

Instead, ALI can be converted to utilize the newer TCP/IP data protocols. The standards for NENA XML

ALI Query Service (AQS) can be found in NENA document 04-005, and is commonly known as IP ALI.

64

While MCP recognizes that the current BESP 9-1-1 Service Provider includes the legacy ALI links as

part of the bundled tariff offering, there is a process known as an Individual Case Basis (ICB) within

CenturyLink (formerly Qwest) to offer individual 9-1-1 Authorities IP ALI. Naturally if more than a few

Authorities request this 9-1-1 service, the individual non-reoccurring costs for the Authorities can be

more evenly distributed.

IP ALI can utilize a scalable TCP/IP Cloud technology such as MPLS as discussed earlier in this report.

The MPLS Cloud technology may also be utilized to support configurations of CPE Host/Remotes or

allow other BESP approved Public Safety service providers to offer other NENA i3 applications such as

text, video, or IP 9-1-1 calls, as long as CenturyLink security and management requirements are met.

In support of this migration plan, the PSAP CPE would be required to first support IP ALI. As NG

services are available, the CPE would then need to support NENA i3 recommendations or similar

industry standardized protocols. During the migration process that could take several years, the CPE

would still be required to support legacy Voice 9-1-1 CAMA trunks from the Tandems, until the

migration process to NENA i3 is fully complete.


65

9. SUMMARY OF FINDINGS

A summary of the findings of MCP’s efforts is included this section of the report.

The Colorado E9-1-1 network and infrastructure must transition to a modern IP-based network capable

of meeting future public safety needs in the state.

The recommendations are based on a set of requirements and assumptions.

The requirements are:


voice over IP (VoIP) service, or any other device that the consumer could reasonably expect to

be able to access 9-1-1 services.




survivability. No single point of failure should impact the day-to-day 9-1-1 and Public Safety

Answering Point (PSAP) operations.


they are developed, such as those from the National Emergency Number Association (NENA),

for IP networks and 9-1-1 call-taking equipment.

The network must have set standards and specifications for use and must be designed with


Implementation of NG9-1-1 must support the migration to the consolidation of equipment, as


received locally, but the host equipment could be shared across multiple PSAPs or counties.

Where it makes sense, the network should be used to facilitate the pooling of operational and

capital resources.

The assumptions are:






66

The network should be provided by a BESP.





which will convert the analog signal to IP.

Each service provider will have to provide its own gateway to access the network, and shall

have to meet state standards and requirements for access. Each provider shall be responsible

for the costs of connecting to and meeting the gateway requirements, including ALI data.

All data and voice communication from the IP cloud to the PSAP will be IP-based, and delivered

via Session Initiated Protocol (SIP). PSAPs will have to meet state or accepted industry

requirements for access, firewall, level of service and Customer Premises Equipment (CPE)

capability, among others.


The network architecture choice should be a ―hybrid‖ mix of public and private

telecommunications assets.

NG9-1-1 must be considered a migration and not a single event; therefore, a phased approach is more

practical.

An IP network is the foundation of NG9-1-1 as it supports the interworking of functions. Benefits (IP-

ALI, hosing applications, etc.) can be gained by implementing the IP network first.

MCP’s recommendation for consideration by the Colorado 9-1-1 Resource Center is the deployment of

a statewide network to allow for applications to be implemented in three phases for use by the greater

Colorado 9-1-1 Community.

The three phases would include the:

1. Statewide implementation of a MPLS network for transport of IP-ALI

2. Additions of Hosted Call Center Applications on the network

3. Migration from Legacy 9-1-1 to the features and functions of NG9-1-1

67

Regarding the migration through the aforementioned phases, MCP strongly recommends the

development of a detailed network plan and a conceptual network design that supports each phase of

the project.

This plan, which is extremely critical to the success of the network, must include all essential elements

intended to sustain the successful migration through each of the three phases.

Regarding network traffic MCP further recommends:

The classification of data types on the statewide network so that priorities can be assigned via

the Class of Service (CoS) mechanism.

The use of Quality of Service (QoS), QoS ensures that the bandwidth available in a path is

utilized to transfer data types based on priority.

Fiber optic cable is the media of choice for supporting the network and copper is the fallback.

Regarding Governance, Regulatory, and Funding, MCP further recommends:

A governance model consisting of an independent administrative entity, called the Colorado

NG9-1-1 Authority, be established to regulate a statewide NG9-1-1 network.

That multiple BESPs are approved and authorized to provide the service in a competitive

environment.

The previously proposed Colorado NG9-1-1 Authority is given the authority to manage funding

and revenue distribution for a NG9-1-1 network.

A hybrid averaging funding distribution model be adopted for PSAPs connecting to a NG91-1

network.

Network security and data integrity policies and rules are established by the governance

authority.

Regional NG9-1-1 networks are considered.

To support the recommendations of this report, the remainder of the document expands on the topics

of:

Research methodologies used

State of Colorado Next Generation 9-1-1 Network Requirements and Assumptions

68

Recommendation and design considerations to include consumer technology, impact to legacy

E9-1-1 networks and the vision of Next Generation 9-1-1

Various design approaches to a statewide network

Elements of transport on a statewide network

Implementation and support of a statewide network

The regulatory aspects of a statewide network

Funding mechanisms of a statewide network


69

10. ENDNOTES

1. ―50 Wireless Quick Facts.‖ CTIA – Advocacy. October 2010. CTIA – The Wireless Association. 15

April 2011. http://www.ctia.org/advocacy/research/index.cfm/AID/10377

2. ―Census Press Release.‖ 2010 Census Data for Colorado. 2011. State Demography Office - Division

of Local Government. 13 April 2011. http://www.dola.colorado.gov.dlg/demog/2010censusdata.html.

3. ―The Geography of Colorado.‖ Colorado Geography from NetState. 15 February 2011.

NetState.com. 13 April 2011. http://www.netstate.com/states/geography/co_geopgraphy.htm.

4. ―Funding 9-1-1 Into the Next Generation: An Overview of NG9-1-1 Funding Model Options for

Consideration‖, March 2007, http://www.nena.org/ng-partner-program/911-funding-report.

11. WORKS CITED

―50 Wireless Quick Facts.‖ CTIA – Advocacy. October 2010. CTIA – The Wireless Association. 15 April

2011. http://www.ctia.org/advocacy/research/index.cfm/AID/10377

―Census Press Release.‖ 2010 Census Data for Colorado. 2011. State Demography Office - Division of

Local Government. 13 April 2011. http://www.dola.colorado.gov.dlg/demog/2010censusdata.html.

Hixson, Roger, Cobb, Bob, and Halley, Patrick. ―NENA’s Blueprint Steers 9-1-1 Into The Future.‖ 9-1-1

Magazine January/February 2007: 18-21.

NENA NG9-1-1- Transition Plan Considerations Information Document (NENA 77-501), Version 1,

February 24, 2011.

NENA Detailed Functional and Interface Standards for the NENA i3 Solution (NENA 08-003), Version

1, June 14, 2011

NENA Security for Next-Generation 9-1-1 Standard (NG-SEC) (NENA 75-001), Version 1, February 6,

2010

Research and Innovative Technology Administration (RITA). U.S. Department of Transportation (US

DOT). ―Next Generation 9-1-1.‖ 2011 January. Intelligent Transportation Systems Joint Program

Office. 25 March 2011. http://www.its.dot.gov/ng911/

―The Geography of Colorado. Colorado Geography from NetState. 15 February 2011. NetState.com.

13 April 2011. http://www.netstate.com/states/geography/co_geopgraphy.htm.

Winkelman, Roy Dr. An Educator’s Guide to Network, 2009. Florida Center for Instructional

Technology FCIT). University of South Florida. 4 April 2011. http://www.fcit.usf.edu/

http://www.ctia.org/advocacy/research/index.cfm/AID/10377

http://www.dola.colorado.gov.dlg/demog/2010censusdata.html

http://www.netstate.com/states/geography/co_geopgraphy.htm

http://www.nena.org/ng-partner-program/911-funding-report

http://www.ctia.org/advocacy/research/index.cfm/AID/10377

http://www.dola.colorado.gov.dlg/demog/2010censusdata.html

http://www.its.dot.gov/ng911/

http://www.netstate.com/states/geography/co_geopgraphy.htm

http://www.fcit.usf.edu/

70

APPENDIX A – §31-1- 202 C.R.S. 1997

1

Appendix A – Section 31-1- 202 C.R.S. 1997

31-1-202. Cities or towns retaining prior status

Every city or town incorporated prior to July 3, 1877, which chooses to retain such organization, in the

enforcement of the powers or the exercise of the duties conferred by the special charter or general law

under which the same is incorporated, shall proceed in all respects as provided by such special charter

or general law and shall not be affected nor the powers or duties thereof in any manner changed or

abridged by any provisions of this title.

Source: L. 75: Entire title R&RE, p. 1006, § 1, effective July 1.

Editor's note: This section is similar to former §§ 31-1-101and 31-1-202 as they existed prior to 1975.

ANNOTATION

Law reviews. For note, "The Effect of Land Use Legislation on the Common Law of Nuisance in Urban

Areas", see 36 Dicta 414 (1959).

Annotator's note. Since § 31-1-202 is similar to former §§ 31-1-101 and 31-1-202 prior to the 1975

repeal and reenactment of this title, and laws antecedent thereto, relevant cases construing those

provisions have been included in the annotations to this section.

The object of the saving clause inserted in this section is to preserve the existence of cities and

towns which had been incorporated under general laws enacted prior to, and repealed by, the act of

1877; had the saving clause not been added, such cities and towns might have gone out of existence,

as legal entities. City of Central v. Axton, 159 Colo. 69, 410 P.2d 173 (1966).

A saving clause "should be strictly construed so as not to include anything not fairly within its

terms". City of Central v. Axton, 159 Colo. 69, 410 P.2d 173 (1966).

However, this section does not freeze in perpetuity the powers and duties of that city as such

existed in 1876. City of Central v. Axton, 159 Colo. 69, 410 P.2d 173 (1966).

General laws applicable to municipalities repealed. In addition to spelling out the manner in which a

city or town could be organized and incorporated, the general assembly in 1877 repealed all general

laws providing for the organization and government of incorporated cities and towns. City of Central v.

Axton, 159 Colo. 69, 410 P.2d 173 (1966).

But the existence of cities and towns incorporated before 1877 which chose to retain their then

existing organizations should not be affected by this title and further, the powers and duties of

such a town or city are not to be changed or abridged in any manner by any provision of this act. In

other words, the injunction is that the powers and duties of a town or city which chose to retain its

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existence under its territorial charter are not to be altered by any provision of this act. City of Central v.

Axton, 159 Colo. 69, 410 P.2d 173 (1966).

But not exempt from classification of municipalities. This section, while permitting towns which

were incorporated prior to 1877 to retain their organization, and to proceed under the law under which

they were incorporated in the enforcement of the powers or the exercise of the duties conferred by such

general law, does not have the effect of exempting such towns from the operation of statutes relating to

the classification of municipal corporations. Kirkpatrick v. People, 66 Colo. 100, 179 P. 338 (1919).

There is nothing in this section which shows an intent on the part of the general assembly to exempt

such cities and towns from the operation of any statute relating to the classification of municipal

corporations. City of Central v. Axton, 159 Colo. 69, 410 P.2d 173 (1966).

All cities and towns incorporated under general laws were subject to that part of the act of 1877

which relates to the election of municipal officers, notwithstanding this section. City of Central v.

Axton, 159 Colo. 69, 410 P.2d 173 (1966).

General statute on removal of local officer inapplicable. Even if there were no ordinance dealing

with the appointment or removal of a town clerk in a special charter town which never elected to

become subject to the general laws governing municipal corporations, the general statute on the local

matter of removal of municipal officers does not apply. Glenn v. Town of Georgetown, 36 Colo. App.

431, 543 P.2d 726 (1975).

Denver not limited by title. In the area of local legislative jurisdiction, Denver is not limited by the

statutes pertaining to powers of towns and cities, § 31-1-101 et seq. Lehman v. City & County of

Denver, 144 Colo. 109, 355 P.2d 309 (1960).

Applied in Bernheimer v. City of Leadville, 14 Colo. 518, 24 P. 332 (1890).

71

APPENDIX B – §29-11-100.5 TO §29-11-106 C.R.S 1997

1

Appendix B – Sections 29-11-100.5 to 29-11-106 C.R.S. 1997

29-11-100.5. Legislative declaration - provision of emergency service to wireless and multi-line

telephone service users.

(1) The general assembly hereby finds and declares that dialing 9-1-1 is the most effective and familiar

way the public has of seeking emergency assistance. The amendments to this part 1 made in Senate Bill

97-132, enacted at the first regular session of the sixty-first general assembly, are intended to provide a

funding mechanism for 9-1-1 and enhanced 9-1-1 service for wireless service users. Enhanced 9-1-1

permits rapid response in situations where callers are unable to relay their phone number or location.

Public safety answering points will need to make extensive changes in, and additions to, existing

equipment to provide enhanced 9-1-1 service to wireless service users. To do so, public safety answering

points must have the resources to purchase and update equipment, software, and training. A mechanism

for recovery of costs reasonably incurred by wireless carriers, service suppliers, and basic emergency

service providers in the acquisition and transmission of 9-1-1 information to public safety answering

points is necessary to ensure that wireless service users receive the same level of 9-1-1 service as

wireline service users.

(2) The general assembly further finds and declares that public safety agencies increasingly rely on

enhanced 9-1-1 to provide dependable and precise information about the 9-1-1 caller's location and an

accurate telephone number to reach the caller. Many multi-line telephone systems do not provide

precise information about the 9-1-1 caller's location or telephone number. Inadequate location

information can be life threatening if the caller is unable to verbalize the correct location. Not knowing

an accurate location for a caller can result in a delay in service. In addition, many end-use customers of

multi-line telephone systems do not know how to dial a 9-1-1 call from such telephones. Disclosure

about 9-1-1 dialing and about the location identification capability of multi-line telephone systems are

necessary first steps to ensure that multi-line telephone system service users can obtain emergency

assistance by dialing 9-1-1.

(3) Nothing in this part 1 should be construed to alter the method of regulation or deregulation of

providers of telecommunications service as set forth in article 15 of title 40, C.R.S.

Source: L. 97: Entire section added, p. 571, § 1, effective April 30. L. 2001: Entire section amended, p.

64, § 1, effective August 8. L. 2004: (1) and (3) amended, p. 13, § 2, effective February 20.

29-11-101. Definitions

As used in this article, unless the context otherwise requires:

(1) "Automatic location identification" ("ALI") means the automatic display, on equipment at the PSAP,

of the location of the caller's telephone number, the address for the telephone, including nonlisted and

nonpublished numbers and addresses, and other information about the caller's precise location.

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(1.1) "Automatic number identification" ("ANI") means the automatic display, on equipment at the

PSAP, of the caller's telephone number.

(1.2) "Basic emergency service provider" ("BESP") means any person authorized by the commission to

undertake the aggregation and transportation of 9-1-1 calls to a PSAP.

(1.3) "Commission" or "public utilities commission" means the public utilities commission of the state of

Colorado, created in section 40-2-101, C.R.S.

(1.5) "Emergency notification service" means an informational service that, upon activation by a public

safety agency, uses the 9-1-1 database or a database derived from the 9-1-1 database to rapidly notify

all telephone customers within a specified geographic area of hazardous conditions or emergent events

that threaten their lives or property, including, without limitation, floods, fires, and hazardous materials

incidents.

(1.6) "Emergency service provider" means a primary provider of emergency fire fighting, law

enforcement, ambulance, emergency medical, or other emergency services.

(1.7) "Emergency telephone charge" means a charge to pay the equipment costs, the installation costs,

and the directly-related costs of the continued operation of an emergency telephone service according

to the rates and schedules filed with the public utilities commission, if applicable.

(2) "Emergency telephone service" means a telephone system utilizing the single three-digit number 9-

1-1 for reporting police, fire, medical, or other emergency situations.

(2.5) "Equipment supplier" means any person providing telephone or other equipment necessary for an

emergency telephone service to any public agency or governing body in this state, through lease or

sale.

(3) "Exchange access facilities" means the access from a specific customer's premises to the

telecommunications network to effect the transfer of information.

(4) "Governing body" means the board of county commissioners of a county or the city council or other

governing body of a city, city and county, or town or the board of directors of a special district.

(4.3) "Interconnected voice-over-internet-protocol service" means a service that:

(a) Enables real-time, two-way voice communications;

(b) Requires a broadband connection from the service user's location;

(c) Requires internet protocol-compatible customer premises equipment; and

3

(d) Permits service users generally to receive calls that originate on the public switched telephone

network and to terminate calls to the public switched telephone network.

(4.5) "MLTS operator" means the person that operates an MLTS from which an end-user may place a

9-1-1 call through the public switched network.

(4.6) "Multi-line telephone system" ("MLTS") means a system comprised of common control units,

telephones, and control hardware and software providing local telephone service to multiple end-use

customers in businesses, apartments, townhouses, condominiums, schools, dormitories, hotels,

motels, resorts, extended care facilities, or similar entities, facilities, or structures. "Multi-line telephone

system" includes:

(a) Network and premises-based systems such as centrex, pbx, and hybrid-key telephone systems;

and

(b) Systems owned or leased by governmental agencies, nonprofit entities, and for-profit businesses.

(5) "Person" means any individual, firm, partnership, copartnership, joint venture, association,

cooperative organization, corporation (municipal or private and whether organized for profit or not),

governmental agency, state, county, political subdivision, state department, commission, board, or

bureau, fraternal organization, nonprofit organization, estate, trust, business or common law trust,

receiver, assignee for the benefit of creditors, trustee, or trustee in bankruptcy or any other service

user.

(5.5) "Prepaid wireless telecommunications service" means wireless telecommunications access that

allows a caller to dial 911 to access the 911 system, is paid for in advance, and is sold in

predetermined units or dollars, of which the number of units or dollars available to the caller declines

with use in a known amount.

Editor's note: Subsection (5.5) is effective January 1, 2011.

(6) "Public agency" means any city, city and county, town, county, municipal corporation, public district,

or public authority located in whole or in part within this state which provides or has the authority to

provide fire fighting, law enforcement, ambulance, emergency medical, or other emergency services.

(6.5) "Public safety answering point" ("PSAP") means a facility equipped and staffed on a 24-hour basis

to receive and process 9-1-1 calls.

(6.7) "Rates" means the rates billed by a service supplier pursuant to tariffs, price lists, or contracts,

which rates represent the service supplier's recurring charges for exchange access facilities or their

equivalent, exclusive of all taxes, fees, licenses, or similar charges.

4

(7) "Service supplier" means a person providing exchange telephone services, a person providing

telecommunications service via wireless carrier, and a person providing interconnected voice-over-

internet-protocol service to any service user in this state, either directly or by resale.

(8) "Service user" means a person who is provided exchange telephone service, a person who is

provided telecommunications service via wireless carrier, and a person who is provided interconnected

voice-over-internet-protocol service in this state.

(9) (Deleted by amendment, L. 97, p. 572, § 2, effective April 30, 1997.)

(10) "Telecommunications service" has the meaning set forth in section 40-15-102 (29), C.R.S.

(11) "Wireless automatic location identification" ("wireless ALI") means the automatic display, on

equipment at the PSAP, of the location of the wireless service user initiating a 9-1-1 call to the PSAP.

(12) "Wireless automatic number identification" ("wireless ANI") means the mobile identification number

of the wireless service user initiating a 9-1-1 call to the PSAP.

(13) "Wireless carrier" means a cellular licensee, a personal communications service licensee, and

certain specialized mobile radio providers designated as covered carriers by the federal

communications commission in 47 CFR 20.18 and any successor to such rule.

(14) "Wireless communications access" means the radio equipment and assigned mobile identification

number used to connect a wireless customer to a wireless carrier for two-way interactive voice or voice-

capable services.

Source: L. 81: Entire article added, p. 1415, § 1, effective May 26. L. 85: (1) amended and (2.5) added,

p. 1052, § 1, effective April 17. L. 97: (1), (2), (7), (8), and (9) amended and (1.3), (1.7), (6.5), (6.7), and

(10) to (14) added, p. 572, § 2, effective April 30. L. 2001: (1) amended and (1.1), (1.2), (4.5), and (4.6)

added, p. 65, § 2, effective April 8. L. 2002: (1.5) added, p. 83, § 1, effective March 22. L. 2004: (1.6)

added, p. 1879, § 1, effective July 1; (13) and (14) amended, p. 1202, § 70, effective August 4. L. 2008:

(3), (7), and (8) amended and (4.3) added, p. 683, § 1, effective August 5. L. 2010: (5.5) added, (SB

10-120), ch. 371, p. 1739, § 1, effective January 1, 2011.

Editor's note: Section 5 of chapter 371, Session Laws of Colorado 2010, provides that the act adding

subsection (5.5) applies to sales made on or after January 1, 2011.

29-11-102. Imposition of charge - liability of user for charge - collection - uncollected amounts -

rules.

(1) (a) In addition to any other powers for the protection of the public health, a governing body may

incur any equipment, installation, and other directly related costs for the continued operation of an

emergency telephone service as further described in section 29-11-104, and may pay such costs by

imposing an emergency telephone charge for such service in those portions of the governing body's

5

jurisdiction for which emergency telephone service will be provided. The governing body may do such

other acts as may be expedient for the protection and preservation of the public health and as may be

necessary for the acquisition of equipment, for the provision of initial services, and for the operation of

the emergency telephone service.

(b) If the emergency telephone service is to be provided for territory which is included in whole or in part

in the jurisdiction of the governing bodies of two or more public agencies which are the primary

providers of emergency fire fighting, law enforcement, ambulance, emergency medical, or other

emergency services, the agreement for such service with a BESP or any equipment supplier shall be

entered into by each such governing body unless any such body expressly excludes itself therefrom.

Any such agreement shall provide that each governing body that is a customer of such service shall

make payment therefor from charges imposed under paragraph (a) of this subsection (1), unless all

such customers make payments therefor from general revenues. Nothing in this paragraph (b) shall be

construed to prevent two or more such governing bodies from entering into a contract under part 2 of

article 1 of this title and to establish a separate legal entity thereunder to enter into such an agreement

as the customer of the BESP or any equipment supplier.

(2) (a) The governing body is hereby authorized, by ordinance in the case of cities and by resolution in

the case of counties or special districts, to impose such charge in an amount not to exceed seventy

cents per month per exchange access facility, per wireless communications access, and per

interconnected voice-over-internet-protocol service in those portions of the governing body's jurisdiction

for which emergency telephone service will be provided.

(b) In the event the governing body determines that a charge in excess of seventy cents per month is

necessary in order to provide continued and adequate emergency telephone service, the governing

body shall obtain from the public utilities commission approval of such higher charge before the

imposition thereof.

(c) Regardless of the level at which the charge is set, the amount of the charge imposed per exchange

access facility, per wireless communications access, and per interconnected voice-over-internet-

protocol service shall be equal.

(d) The proceeds of the charge shall be utilized to pay for emergency telephone service, as set forth in

section 29-11-104 (2), and may be imposed at any time after the governing body requests such service

from the provider or, in the case of wireless carriers, at any time after the governing body requests

wireless ANI or wireless ALI from the wireless carrier.

(e) This subsection (2) shall not apply to prepaid wireless telecommunications services.

Editor's note: Paragraph (e) is effective January 1, 2011.

6

(3) Such charge shall be imposed only upon service users whose address is in those portions of the

governing body's jurisdiction for which emergency telephone service shall be provided; however, such

charge shall not be imposed upon any state or local governmental entity.

(4) Every billed service user shall be liable for any charge imposed under this article until it has been

paid to the service supplier.

(5) The duty to collect or pay any charge imposed under the authority of this article shall commence at

such time as may be specified by the governing body. Charges imposed under the authority of this

article and required to be collected by the service supplier shall be added to and may be stated

separately in the billings, if any, to the service user.

(6) The service supplier shall have no obligation to take any legal action to enforce the collection of any

charge imposed under the authority of this article. Such action may be brought by or in behalf of the

public agency imposing the charge or the separate legal entity formed pursuant to paragraph (b) of

subsection (1) of this section. The service supplier shall annually provide the governing body a list of

the amounts uncollected along with the names and addresses of those service users that carry a

balance that can be determined by the service supplier to be the nonpayment of any charge imposed

under the authority of this article. The service supplier shall not be held liable for such uncollected

amounts that have been billed to the service user.

(7) Any charge imposed under the authority of this article shall be collected insofar as practicable at the

same time as, and along with, the charges for the rate in accordance with the regular billing practice of

the service supplier. The rates determined by or stated on the billing of the service supplier are

presumed to be correct if such charges were made in accordance with the service supplier's business

practices. The presumption may be rebutted by evidence which establishes that an incorrect rate was

charged.

Source: L. 81: Entire article added, p. 1416, § 1, effective May 26. L. 85: (1) amended and (2.5) added,

p. 1052, § 2, effective April 17. L. 90: (2) and (3) amended, p. 1451, § 8, effective July 1. L. 97: (1)(b),

(2), (3), and (7) amended, p. 573, § 3, effective April 30. L. 2004: (1)(a) amended, p. 1879, § 2,

effective July 1. L. 2008: (2)(a), (2)(c), (5), and (6) amended, p. 684, § 2, effective August 5. L. 2010:

(2)(e) added, (SB 10-120), ch. 371, p. 1739, § 2, effective January 1, 2011.


subsection (2)(e) applies to sales made on or after January 1, 2011.

29-11-102.5. Imposition of charge on prepaid wireless - rules - prepaid wireless trust cash fund -

definitions - repeal.

(1) As used in this section:

7

(a) "Consumer" means a person who purchases prepaid wireless telecommunications service in a retail

transaction.

(b) "Department" means the department of revenue.

(c) "Prepaid wireless E911 charge" means the charge that is required to be collected by a seller from a

consumer under subsection (2) of this section.

(d) "Provider" means a person that provides prepaid wireless telecommunications service.

(e) "Retail transaction" means the purchase of prepaid wireless telecommunications service from a

seller for any purpose other than resale

(f) "Seller" means a person who sells prepaid wireless telecommunications service to another person.

(2) (a) A prepaid wireless E911 charge of one and four-tenths percent of the price of the retail

transaction is hereby imposed on each retail transaction.

(b) (I) The seller shall collect the prepaid wireless E911 charge from the consumer on each retail

transaction occurring in this state. The amount of the prepaid wireless E911 charge shall be either

disclosed to the consumer or separately stated on an invoice, receipt, or other similar document the

seller provides to the consumer. A seller shall elect to either disclose or separately state the charge and

shall not change the election without the written consent of the department.

(II) For purposes of this paragraph (b), a retail transaction occurs in Colorado if:

(A) The consumer effects the retail transaction in person at a business location in Colorado;

(B) If sub-subparagraph (A) of this subparagraph (II) does not apply, the product is delivered to the

consumer at a Colorado address provided to the seller;

(C) If sub-subparagraphs (A) and (B) of this subparagraph (II) do not apply, the seller's records,

maintained in the ordinary course of business, indicate that the consumer's address is in Colorado and

the records are not made or kept in bad faith;

(D) If sub-subparagraphs (A) to (C) of this subparagraph (II) do not apply, the consumer gives a

Colorado address during the consummation of the sale, including the consumer's payment instrument if

no other address is available, and the address is not given in bad faith; or

(E) If sub-subparagraphs (A) to (D) of this subparagraph (II) do not apply, the mobile telephone number

is associated with a Colorado location.

(c) The prepaid wireless E911 charge is the liability of the consumer and not of the seller or of any

provider; except that the seller shall be liable to remit all prepaid wireless E911 charges that the seller

8

collects from consumers as provided in subsection (3) of this section. The seller shall be deemed to

have collected the charge notwithstanding that the amount of the charge has neither been separately

disclosed nor stated on an invoice, receipt, or other similar document the seller provides to the

consumer.

(d) The amount of the prepaid wireless E911 charge that is collected by a seller from a consumer shall

not be included in the base for measuring any tax, fee, surcharge, or other charge that is imposed by

this state, any political subdivision of this state, or any intergovernmental agency.

(3) (a) The seller shall remit any collected prepaid wireless E911 charges to the department at the

times and in the manner provided in part 1 of article 26 of title 39, C.R.S. The department shall

establish, by rule, registration and payment procedures that substantially coincide with the registration

and payment procedures that apply under part 1 of article 26 of title 39, C.R.S. A seller is subject to the

penalties under part 1 of article 26 of title 39, C.R.S., for failure to collect or remit a prepaid wireless

E911 charge in accordance with this section.

(b) (I) Effective July 1, 2011, a seller may deduct and retain three and three-tenths percent of the

prepaid wireless E911 charges that are collected by the seller from consumers.

(II) (A) A seller may deduct and retain two percent of the prepaid wireless E911 charges that are

collected by the seller from consumers.

(B) This subparagraph (II) is repealed, effective July 1, 2011.

(c) The audit and appeal procedures applicable to the state sales tax under part 1 of article 26 of title

39, C.R.S., shall apply to prepaid wireless E911 charges.

(d) The department shall establish procedures by which a seller may document that a transaction is not

a retail transaction, which procedures shall substantially coincide with the procedures for documenting

that a sale was wholesale for purposes of the sales tax under part 1 of article 26 of title 39, C.R.S.

(e) (I) Remittances of prepaid wireless E911 charges received by the department are collections for the

local governing body, not general revenues of the state, and shall be held in trust in the prepaid

wireless trust cash fund, which is hereby created. Except as provided in subparagraph (II) of this

paragraph (e), the department shall transmit the moneys in the fund to each governing body within sixty

days after the department receives the money in accordance with section 29-2-106 for use by such

governing body for the purposes permitted under section 29-11-104.

(II) The department may expend an amount, not to exceed three percent of the collected charges in the

prepaid wireless trust cash fund, necessary to reimburse the department for its direct costs of

administering the collection and remittance of prepaid wireless E911 charges; except that the

department may expend up to an additional four hundred fifty thousand dollars from January 1, 2011,

through January 1, 2012, to cover the initial cost of establishing the collection and remittance process.

9

(III) The public utilities commission shall establish a formula for distribution of revenues from the

prepaid wireless E911 charge based upon the governing authority's portion of the total 911 wireless call

volume. The public utilities commission, or its designee, shall collect and transmit the percentage of

wireless calls processed by each public safety answering point to the department by November 15 of

each year. The public utilities commission may promulgate rules to implement this subparagraph (III).

(4) The prepaid wireless E911 charge imposed by this section shall be the only direct E911 funding

obligation imposed with respect to prepaid wireless telecommunications service in this state. No tax,

fee, surcharge, or other charge to fund E911 shall be imposed by this state, any political subdivision of

this state, or any intergovernmental agency upon a provider, seller, or consumer with respect to the

sale, purchase, use, or provision of prepaid wireless telecommunications service.

Editor's note: This section is effective January 1, 2011.

Source: L. 2010: Entire section added, (SB 10-120), ch. 371, p. 1739, § 3, effective January 1, 2011.


this section applies to sales made on or after January 1, 2011.

29-11-103. Remittance of charge to governing body - administrative fee - establishment of rate

of charge.

(1) Any charge imposed under the authority of this article and the amounts required to be collected or

paid are to be remitted monthly. The amount of the charge collected or paid in one month by the

service supplier shall be remitted to the governing body no later than thirty days after the close of that

month. On or before the sixtieth day of each calendar quarter, a return for the preceding quarter shall

be filed with the governing body in such form as the governing body and service supplier shall agree

upon. The service supplier required to file the return shall deliver the return, together with a remittance

of the amount of the charge payable, to the office of the governing body. The service supplier shall

maintain a record of the amount of each charge collected pursuant to this article. Such record shall be

maintained for a period of one year after the time the charge was collected.

(2) From every remittance to the governing body made on or before the date when the same becomes

due, the service supplier required to remit the same shall be entitled to deduct and retain two percent of

said remittance.

(3) (a) At least once each calendar year, the governing body shall establish a rate of charge, not to

exceed the amount authorized, that together with any surplus revenues carried forward will produce

sufficient revenues to fund the expenditures authorized by this article. Amounts collected in excess of

such necessary expenditures within a given year shall be carried forward to subsequent years and shall

be used in accordance with section 29-11-104 (2). Immediately upon determining such rate, the

governing body shall publish in its minutes the new rate, and if the rate has been changed from the

10

prior rate, it shall notify by registered mail every service supplier at least sixty days before such new

rate will become effective.

(b) The governing body may, at its own expense, require an annual audit of the service supplier's books

and records concerning the collection and remittance of the charge authorized by this article. Public

inspection of the audit and of documents reviewed in the audit shall be subject to section 24-72-204,

C.R.S.

Source: L. 81: Entire article added, p. 1417, § 1, effective May 26. L. 90: (1) and (2) amended, p. 1451,

§ 9, effective July 1. L. 97: (3) amended, p. 574, § 4, effective April 30. L. 2008: (1) and (3)(a)

amended, p. 684, § 3, effective August 5.

29-11-104. Agreements or contracts for emergency telephone service - use of funds collected.

(1) Any governing body imposing the charge authorized by this article may enter into an agreement

directly with the supplier of the emergency telephone service or may contract and cooperate with any

public agency or with other states or their political subdivisions or with any association or corporation

for their political subdivisions or with any association or corporation for the administration of emergency

telephone service as provided by law.

(2) (a) (I) Except as otherwise provided in paragraph (b) of this subsection (2), funds collected from the

charges imposed pursuant to this article shall be spent solely to pay for:

(A) Costs of equipment directly related to the receipt and routing of emergency calls and installation

thereof;

(B) Monthly recurring charges of service suppliers and basic emergency service providers (BESPs) for

the emergency telephone service, which charges shall be billed by the BESP to the governing body of

each jurisdiction in which it provides service;

(C) Reimbursement of the costs of wireless carriers and BESPs for equipment changes necessary for

the provision or transmission of wireless ANI or wireless ALI to a public safety answering point;

(D) Costs related to the provision of the emergency notification service and the emergency telephone

service, including costs associated with total implementation of both services by emergency service

providers, including costs for programming, radios, and emergency training programs; and

(E) Other costs directly related to the continued operation of the emergency telephone service and the

emergency notification service.

(II) If moneys are available after the costs and charges enumerated in subparagraph (I) of this

paragraph (a) are fully paid, such funds may be expended for emergency medical services provided by

telephone or the necessary equipment to redirect calls for nonemergency telephone services.

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(b) Funds collected from the charges imposed pursuant to this article may also be spent for personnel

expenses necessarily incurred for a public safety answering point. As used in this paragraph (b),

"personnel expenses necessarily incurred" includes only expenses incurred for:

(I) Persons employed to take emergency telephone calls and dispatch them appropriately; and

(II) Persons employed to maintain the computer data base of the public safety answering point.

(c) (Deleted by amendment, L. 2004, p. 1880, § 3, effective July 1, 2004.)

(3) Funds collected from the charges imposed pursuant to this article shall be credited to a cash fund,

apart from the general fund of the public agency, for payments pursuant to subsection (2) of this

section. Any moneys remaining in such cash fund at the end of any fiscal year shall remain therein for

payments during any succeeding year; except that, if such emergency telephone service is

discontinued, moneys remaining in the fund after all payments to the service suppliers, basic

emergency service providers, and all equipment suppliers pursuant to subsection (2) of this section

have been made shall be transferred to the general fund of the public agency or proportionately to the

general fund of each participating public agency.

(4) A wireless carrier or BESP that provides wireless ALI or wireless ANI services at the request of a

governing body, and pursuant to a contract between the wireless carrier or BESP and the governing

body, shall be reimbursed by such governing body or its designee for the costs incurred in making any

equipment changes necessary for the provision of such services.

(5) Each governing body shall include as a part of the audit required by part 6 of article 1 of this title an

audit on the use of the funds collected from the charges imposed pursuant to this article for compliance

with paragraph (a) of subsection (2) of this section. A copy of each audit report shall be made available

on the governing body's web site if the governing body has a web site.

Source: L. 81: Entire article added, p. 1418, § 1, effective May 26. L. 85: (2) and (3) amended, p.

1053, § 3, effective April 17. L. 92: (2) amended, p. 964, § 1, effective June 1. L. 95: (2) amended, p.

247, § 1, effective April 17. L. 97: (2) and (3) amended and (4) added, p. 575, § 5, effective April 30. L.

2002: (2)(a)(I)(C) and (2)(a)(I)(D) amended and (2)(a)(I)(E) added, p. 83, § 2, effective March 22. L.

2004: (2) amended, p. 1880, § 3, effective July 1. L. 2008: (5) added, p. 685, § 4, effective August 5.

29-11-105. Immunity of providers.

No basic emergency service provider or service supplier and no employee or agent thereof shall be

liable to any person or entity for infringement or invasion of the right of privacy of any person caused or

claimed to have been caused, directly or indirectly, by any act or omission in connection with the

installation, operation, maintenance, removal, presence, condition, occasion, or use of emergency

service features, automatic number identification (ANI), or automatic location identification (ALI) service

and the equipment associated therewith, including without limitation the identification of the telephone

12

number, address, or name associated with the telephone used by the party or parties accessing 9-1-1

service, wireless ANI service, or wireless ALI service, and that arise out of the negligence or other

wrongful act of the provider or supplier, the customer, the governing body or any of its users, agencies,

or municipalities, or the employee or agent of any of said persons and entities. In addition, no basic

emergency service provider or service supplier or any employee or agent thereof shall be liable for any

damages in a civil action for injuries, death, or loss to person or property incurred as a result of any act

or omission of such provider, service supplier, employee, or agent in connection with developing,

adopting, implementing, maintaining, enhancing, or operating an emergency telephone service unless

such damage or injury was intentionally caused by or resulted from gross negligence of the provider,

supplier, employee, or agent.

Source: L. 97: Entire section added, p. 576, § 6, effective April 30.

29-11-106. Disclosure of 9-1-1 dialing and calling capabilities.

(1) When the method of dialing a local call from an MLTS telephone requires the dialing of an additional

digit to access the public switched network, MLTS operators shall provide written information to their

end-users describing the proper method of dialing 9-1-1 from an MLTS telephone in an emergency.

MLTS operators that do not give the ANI, the ALI, or both shall disclose such fact in writing to their end-

users and instruct them to provide their telephone number and exact location when calling 9-1-1.

(2) (a) For purposes of this section, "end-user" means the person making telephone calls, including 9-1-

1 calls, from the MLTS providing telephone service to the person's place of employment or to the

person's permanent or temporary residence.

(3) The public utilities commission may promulgate rules to implement this section in accordance with

article 4 of title 24, C.R.S.

(4) Nothing in this section shall be construed to alter the method of regulation or deregulation of

providers of telecommunications service by the public utilities commission as set forth in article 15 of

title 40, C.R.S.

Source: L. 2001: Entire section added, p. 66, § 3, effective August 8.

http://www.michie.com/colorado/lpext.dll?f=FifLink&t=document-frame.htm&l=jump&iid=COCODE&d=t.%2024,%20art.%204&sid=7e9244a3.3403fd53.0.0#JD_t24art4

http://www.michie.com/colorado/lpext.dll?f=FifLink&t=document-frame.htm&l=jump&iid=COCODE&d=t.%2024&sid=7e9244a3.3403fd53.0.0#JD_t24

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APPENDIX C – CO 9-1-1 SURCHARGES

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APPENDIX D – E9-1-1 SURCHARGE

1

Appendix D – E9-1-1 Surcharge

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APPENDIX E – NON PSAP_PSAP SUMMARY WORKSHEET INTERVIEWS 11FEB16

1

Candidate Interviewed

Do you share systems with any other PSAP in your Region?

What are these shared systems? (i.e. CAD, Mapping, Logging, Recorders, Radio, etc.)

What 911 Tandem Mated Pair A/B serves your PSAP? (i.e. Pueblo/ Strathmoore)

Is your CPE standalone or Hosted Solution?

What type of connection between Host & Remote?

List any internet service providers

How do you think the Colorado ESInet should look? Statewide or an aggregate of regional ESInets?

Interview 1 Due to the great desire to maintain local government control in Colorado, I believe the only way the network can be constructed is by linking a series of regional networks. The State Digital Trunked Radio System (DTR) for which the Consolidated Communications Network of Colorado, Inc (CCNC - www.ccncinc.org) is the governing body, is an example of how this might be accomplished.

Interview 2 Regional - regionalization with technology - keep what you have - fear of losing of jobs - debate with consolidation vs. regionalization

Interview 3 Company A believes either a regional or statewide network would be appropriate. Company A operates in states with both scenarios. For NG, a regional network approach, with redundancy at the state or national level.

Interview 4 Statewide, the tariff is written so the larger PSAPs help smaller distant PSAPs. If it is aggregate or regional the smaller PSAPs will pay much more than today and not be able to afford NG.

Interview 5 Pros and cons on both approaches. Don’t want to get into a silo situation w/one PSAP lagging behind, easier to manage and implement if they are small groups. Rapidly growing awareness that a statewide authority is needed.

Interview 6 Whatever works best for the Authority Board. As long as it's built to standards approved by an accredited Standards Development Organization (SDO) and provides an open architecture that is contained in a managed, secured network.

2









Is statewide realistic? With a cooperative effort of all Authority Boards. Evolution to an end game.

Interview 7 Politically you will never get one Centralize 911 Authority in the state. Colorado currently has 56 autonomous Authority Boards in the state. A statewide network that works statewide w/individual Authority Boards governing their area. A concern; who gets allocated funds because someone is buddies with someone on the Authority Board and other PSAPs are left out.

Interview 8 Neither. I do not view this as a single network but as an aggregation of networks provided by different BESPs, governing bodies and vendors, where available. (1) 9-1-1 Authorities do not have the experience or expertise to design, operate or build these networks. 9-1-1 Authorities are typically comprised of public safety officials and elected officials who serve in an unpaid capacity simply to direct the collection and expenditure of the 9-1-1 surcharge. It is the PSAPs, operated by public safety agencies, which work with and deal with the 9-1-1 network on a daily basis. Their responsibilities and knowledge for handling 9-1-1 calls and emergency response is enough responsibility, and they do not generally have the money to hire people to run the network. They do not have the personnel or systems to respond to dig requests, for example; ESInet facilities can be provided much more economically by

3









commercial providers or large-scale government providers which can spread the operating and administrative costs over a much larger user base. (2) A "Colorado ESInet," a single network, particularly provided by a government agency, would more likely comprise a one-size-fits-all or a one-size-fits-many solution. With commercial vendors providing a solution there would be cost and price incentives and disincentives and no political imperatives running against building an efficient network meeting the individual requirements and funding of each Authority/PSAP. (3) Competitive commercial vendors by nature will provide more efficient solutions at lower cost, making the most efficient use of limited public funds and allowing funds not spent on an ESInet to be applied to other priorities. (4) Just as transmitter site companies sprung up to finance and develop the build out of cell towers throughout the US, capitalizing the towers so that the cell companies could wouldn't have to; using commercial vendors to capitalize the network facilities is preferable to having governmental entities capitalize the build out of the network. The money doesn't exist today for the Colorado Public Safety community to provide the capital funding for build out of the network. Allowing for private investment (by vendors) to invest the capital and take the risk to build out the network, and for the Authorities/PSAPs to use the network for a monthly fee recovered through the surcharge or other funding source, is a more affordable and efficient solution. Let the private investors make the decisions and take the risks of

4









projecting the demand for the network and/for example of how many conduit inner ducts or strands of fiber to place initially vs. having to go back and install if demand expands. (5) The public budgeting process and cost-recovery requirements may limit the intervals at which Authorities or public entities may be able to invest in upgrades or expansion of their facilities, or they may be dependent upon grants to invest in and operate facilities, when states and the Federal Government are planning on tightening their belts A commercial entity required to serve any and all Authorities under a standard, state-wide tariff, will be able subsidize improvements which individual Authorities may not be capable of funding, and as long as they project a positive cash flow the private provider should be able to raise capital for improvements. Competition and facilities sharing (such as with hosted call handling systems) can also help to lower costs for Authorities and the providers as well. (6) Government-network facilities may be used by providers or Authorities where available and adequate. Networks which may have been deployed for telemedicine applications may not have the necessary bandwidth, may not be in the right locations, and hospitals tended to deploy proprietary systems to capture the patients from the rural areas to which they provided the telemedicine services. Educational broadband networks may not be in the right areas, and may not have the required reliability or technical support available. By my experience educational organizations which have built and operate their

5









own networks are not always very sophisticated in the provision of network services, and a commercial backup is almost always necessary. Public networks, where available, may be most useful as backup facilities in case of a network outage, or when extra bandwidth is required due to transmission of video or other data. Perhaps the quality of service standards on the primary network would prioritize voice and text message traffic, and video and other large quantities of data would be delayed or routed over "less reliable" facilities. The options are best addressed on a case-by-case basis. (7) Where the network providers are separate from the BESP/Operations Center Providers, then when an Authority determines to change BESPs (a capability which assures a competitive market and better service at lower prices) the new BESP can contract with the same network provider if necessary or appropriate (if the network provider is not the reason for the switch to a different BESP), avoiding the need to build out new or additional network facilities. This will lower the barriers to entry assuring a more competitive and responsive market.

Interview 9 Centralized governing body elected by 9-1-1 Authority Boards. Commented on dash Carrier Services. - how dash may be helpful as far as competition in the state and what our report might say both technically and cost wise having two BESPs in Colorado. If dash comes in and take 10% of that service, will Qwest make up for that in cost in charging more? Will PUC

6









keep a tight rein on increases?

Interview 10 The network should be interoperable. Statewide vs. regional should be looked at based on the component parts.

Interview 11 The decision makers on this are the individual jurisdictions. I'll support what they want. The most economical approach is a statewide system with shared governance. Additional comments captured during the interview: No matter what will defer to the decision of the jurisdictions. Jurisdictions are very autonomous - certain part of ESInet that could be at the state-level and some at the jurisdictions - as long as there is not a state mandate.

Interview 12 Statewide! I believe rolling out a statewide ESInet network can occur on a regional level and probably needs to occur region by region, however, there must be a Statewide element in deploying and oversight.

7









Interview 13 Yes Regional CAD system that is shared with 3 other PSAPs (CSU, Estes, and Larimer County). On the shared Motorola State 800 MHz system Digital Trunked Radio system (DTR). Emergency Notification System is shared across all 25 government partners in Larimer County.

Cap Hill/Broomfield

Standalone N/A Left blank Statewide

Interview 14 Yes Shared Emergency notification system, and shared State Digital Trunked Radio system (DTR).

Cap Hill/Broomfield

Standalone N/A Left blank Statewide

Interview 15 Statewide coordination of project only!

Interview 16 No N/A Left blank Standalone N/A Qwest Statewide

8









Interview 17 No N/A Left blank Standalone N/A Left blank Statewide coordination of project only!

Interview 18 Yes Radio Grand Junction/Montrose

Standalone N/A NC Telecom Statewide ESInet would be more beneficial to more agencies - small agencies would lose a chunk of funding - overall state entity would be on the hook to make sure training is just as good as a larger PSAP.

Interview 19 No N/A Grand Junction/Montrose

Standalone N/A CenturyLink Regional ESInets all interconnected to a statewide ESInet. Largest PSAP in SW region as HUB, for smaller PSAPs. Smaller PSAPs would be contracting service from larger PSAPs.

Interview 20 Yes Statewide radio partnership

Grand Junction/Montrose

Standalone N/A Qwest The long term solution would be a statewide solution the regional approach may be more practical in getting things moving

Interview 21 Yes Radio Grand Junction/Montrose

Standalone N/A Valient Statewide or settle for regional

Interview 22 Yes Administrative phones

Cap Hill/Broomfield

Hosted Qwest Metro Optical Ethernet (QMEO)

Comcast/Qwest An aggregate of regional networks.

Interview 23 Yes Logging recorders and radios

Cap Hill/Broomfield

Standalone N/A Left blank Better off statewide but opportunity for Regional as well. Depending on what level of regional service each one will provide will drive the decision for a statewide network. Regional nodes (connections points) along with addressing regional problems locally would make a Statewide system work.

9









Interview 24 Yes Logging recorders and radios

Cap Hill/Broomfield

Standalone N/A Left blank Statewide may be too big of a region for Colorado's demographic? The front range has (Eastern Slope) 80 to 90% of the population - not sure of the exact percentage - so the front range may need something very different from the Western Slope or the Eastern Plains. DCETSA is Front Range as well as Eastern Plains.

Interview 25 Yes Logging recorders, Radio, DCSO and Castle Rock have same CAD - but it is not. They also have CopLink and First Watch as shared systems

Cap Hill/Broomfield

Standalone N/A State of Colorado MNT

Statewide may be too big of a region for Colorado's demographic? The front range has (Eastern Slope) 80 to 90% of the population - not sure of the exact percentage - so the front range may need something very different from the Western Slope or the Eastern Plains. DCETSA is Front Range as well as Eastern Plains.

Interview 26 No N/A Cap Hill/Broomfield

Standalone N/A Premiere Systems/ CenturyLink

Statewide -used the Statewide (DTR) digital trunked radio system and board are a great example of how the statewide ESInet should look and be governed.

Interview 27 No N/A Pueblo/Strathmore Standalone N/A Se-Com Regional networks

Interview 28 Yes call taking, CAD, Radio, Remote backup and storage, looking to be data center like in nature not just a 9-1-1 call center

Left blank Left blank Left blank Left blank Given the geopolitical environment a regional approach would be more successful - consequently more willing to partner with the other regions - technically more feasible than a single statewide due to implementation and maintained - statewide Digital Trunked Radio system (DTR) - not really a state network - it is a radio network used statewide.

10









Interview 29 Yes CAD, radio, 9-1-1 software, logging local mapping( part of CAD) - is regional from a data perspective - radio, 9-1-1 software, logging is local - radio not part of (DTR) - still on conventional system - small amount of interconnect

Left blank Hosted IP Network Eagle Net/Level3

Regional - however believes it might be difficult - likes the local control -has issues with Digital trunked Radio System (DTR) - works well with the board. Agrees with Regional deployment first and then if needed a statewide to connect

Interview 30 Yes CAD, mapping( part of CAD) - is regional from a data perspective - radio, 9-1-1 software, logging is local - radio not part of (DTR) - still on conventional system - small amount of interconnect

Cap Hill/Broomfield

Left blank Left blank Eagle Net Aggregate of regional nets - regions might be defined by Governors Office of Homeland Security Nine All Hazards Region breakdown - mentioned COPLINK Software Project - nodes would connect up at some point as needed

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Interview 31 Yes Mapping, logging recorders and radio

Pueblo/Strathmore Hosted at 8 of 10 locations (last remaining two are the largest - City of Colorado Springs and El Paso County)

T1/Qwest Metro Optical Ethernet (QMOE) (service from Qwest) - IP based service that is a step up from T1 - fiber based if available - 20 mbs / 50 mbs - 5 sites are on the (QMOE) circuits

Comcast/Qwest State wide Public Safety Network - where we move 911 data, NCIC, CCIC data, not radio

Interview 32 No N/A Grand Junction/Montrose

Standalone N/A Qwest Prefers to have statewide oversight - similar to the way Consolidated Communications Network of Colorado (CCNC) is governed (Digital Trunked Radio System (DTR). The State participates, but is not the authority.

Interview 33 Yes Radio NA NA NA NA Statewide ESInet to level out disparate technologies the state may have

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Interview 34 No NA Cap Hill/Broomfield

Standalone NA NA The project has to start at a reasonable size so we can be successful - with rural then metro - starts as a regional and then upon completions a statewide network

75

APPENDIX F – STATEMENT OF WORK INDEX

1

APPENDIX F –

STATEMENT OF WORK REFERENCE INDEX

Private vs. Public vs. Hybrid = Section 5.1.5.3. Page 31

I. Technical Architecture

What should the network look like: Address the desire to have a statewide network given the

geographic challenges of the state. What mediums will be used where (fiber, copper, wireless,

etc.)? = Section 5.1.5.2. Page 29; Section 5.1.5.4. Page 32

What should it carry: 9-1-1 calls are the primary need but can the network be designed to carry

other public safety data and communications while maintaining the integrity of each? = Section

5.1.4.3. Page 27

How do we route 9-1-1 calls: Currently the BESP is responsible for routing all 9-1-1 calls to the

proper PSAP. Should this responsibility be maintained by the BESP utilizing analog

infrastructure or are there other options? = Section 5.1.3. Page 23

PSAP Interoperability: How do we ensure all PSAPs can seamlessly communicate in both data

and voice mediums. = Section 5.1.3.2. Page 25

How do we get ALI/ANI services: As with routing, ANI/ALI services are currently provided

through the BESP. Should the state maintain this environment or do other mechanisms exist to

provide ANI/ALI services in a centralized manner? = Section 8.1. Page 61

Quality of Service issues (QoS)/Standards: What is the recommended implementation of QoS

for the various data? What standards should be implemented? = Section 5.1.3. Page 23

Regionalized Approach: Could the statewide system be a series of regional networks? =

Section 5.1.3.3. Page 25

II. Implementation and Maintenance

Should there be phased implementation or ―flip the switch‖: Can we implement the ultimate

solution in a phased approach interacting with the existing system or do we have to complete

the entire network and do a single cutover. = Section 5. Page 18

Who maintains the system: The vendor shall identify all recommended options for maintenance

of an IP 9-1-1 system. The vendor must take into consideration the current management of

2

9-1-1. If recommendations differ from this mechanism, the vendor shall also identify a migration

plan. = Section 8. Page 61

What are the standards: What are the network standards that should be applied across the IP-

based 9-1-1 network (reliability, security, etc.)? = Section 5.1.4.3 Page 27

Ongoing network monitoring: How should the network be monitored on a day-to-day basis to

ensure system reliability. = Section 5.1.4.3. Page 27; Section 5.1.4.4. Page 27

III. Governance

How to balance various regulatory and operational environments: By moving to an

IP-based system, regulatory roles become less clear. The vendor shall identify

recommendations on how to govern the regulatory issues with the network given the differences

in state and federal regulatory boundaries? = Section 6.1.4. Page 36

Currently each Authority is responsible for governing the delivery of 9-1-1 in its jurisdiction. How

do we maintain the local control of delivery but implement a statewide governance structure for

the network? = Section 6.1.4. Page 36

What should the regulatory structure look like: Currently the PUC is responsible for governing

the network through the BESP. If we maintain the BESP model, does the state PUC have the

proper authority to govern the system via private carriers? If the BESP model is abandoned or

modified, how do we govern a statewide system that is implemented at a local level? = Section

6.2.2. Page 37

What changes to the current regulatory rules and statutory environment need to be or should be

made? = Section 6. Page 34

IV. Funding

Can the current funding mechanism work: Will the current telephone surcharge model be

sufficient to fund both the capital and operational maintenance of the system? = Section 7.5.4.

Page 57

What alternatives do we have: What if any alternatives to the current model exist (e.g., grants,

bonds, etc.)? = Section 7.5.4. Page 57

How to distribute the costs: How do we distribute both capital and operational costs of the

system across the state in an equitable manner? = Section 7.5.4. Page 57

Colorado Next Generation 9 1 System Review Report Submitted August

Documents

Transcript of Colorado Next Generation 9 1 System Review Report Submitted August