Kimberly Culp

Colorado Public Utilities Commission 9-1-1 Task Force Tuesday November 25th, 2008 Docket : NHTSA-2008-0142 Docket Title: E-911 Grant Program Dear Sir/Madam; I am writing to you in my capacity as Chair of the Colorado Public Utilities Commission 9-1-1 Task Force, (“the Task Force”). The Task Force is a twenty-nine member consortium representing all sectors of the 9-1-1 community in Colorado including the Colorado Office of Consumer Counsel, the Basic Emergency Service Provider, Incumbent Local Exchange Service Providers, VOIP providers, wireless providers, the Colorado Municipal League, Colorado Counties, Inc., the disabled community, and a cross-section of representatives from local government entities throughout the state. The Task Force has been very active in 9-1-1 issues in Colorado and recently spearheaded the adoption of legislation affording additional funding for 9-1-1 infrastructure in our state. In accordance with Colorado law, 9-1-1 surcharges are set and collected at the county or 9-1-1 local authority level. Colorado law does not provide for a statewide 9-1-1 coordinator. This model has worked well for our state, although as a Task Force we are always on the lookout for additional funding that would enable us to work with our Basic Emergency Service Provider to upgrade the delivery of 9-1-1 into the Public Safety Answering Points. At present, it is critical that we enhance and upgrade our outdated 9-1-1 infrastructure to a regional broadband network with Next Generation hardware and software. The Task Force believed that the adoption of the 2004 Enhanced 911 Act and the subsequent appropriation of funds to accomplish the purposes of the Act represented an opportunity to move forward with these enhancements and upgrades. Unfortunately, based on the application requirements being considered in the rule making for this E-911 Grant Program, Colorado would be unfairly excluded. Colorado does not have a statewide 911 coordinator that is appointed by the Governor, as mandated by the rules. However, as evidenced by this letter, Colorado does have a system for coordination of 9-1-1 service delivery and a mechanism for ensuring that grant applications are coordinated. It is our stance that it is inequitable to create rules that disqualify our entire state from receiving funds from the Enhanced 911 Act. The application requirements should allow all states the equal opportunity to apply, qualify, and receive funding for vital 9-1-1 infrastructure upgrades, even if their model for statewide coordination does not meet the rigid national construct in the proposed rules. To disqualify states that have developed their own locally-appropriate systems for 9-1-1 service delivery would be entirely contrary to the purposes of the 2004 act and a threat to the delivery of high quality 9-1-1 services in those states. In conclusion we urge that the rule-making procedure pursue adoption of amended rules that would allow all States that can demonstrate coordination of effort called for in the act itself, equal consideration for this critical funding for 9-1-1. Thank you for your consideration of these comments. The persons and entities set forth below join in these comments. Kimberly J. Culp Kimberly Culp, Chair 9-1-1 Task Force Executive Director, Larimer Emergency Telephone Authority – Larimer County Chris Mendez, Colorado Counties Kevin Bommer, Colorado Municipal League Joe Benedetto, Disabled Communities – Colorado Public Utilities Commission Tim Kunkleman, Qwest Muriel Haglind, Intrado Edie Ortega, CenturyTel Linda McKelvey, Qwest PB Schechter, Office of Consumer Counsel Sally Cromer, TMobile Kara Thielen, Viaero Wireless Mike Dwyer, Comcast Mike Bedwell, Aurora Police Brad Heyden, Douglas County Paula Creasy, Grand Junction/Mesa County Lonna Donin, Boulder Police Connie Johnson, Cortez Police Jim Smith, Boulder County Brian Shepherd, Adams County 911 Carl Stephens, Garfield County Jeff Irvin, Jefferson County Jim Anderson, El Paso/Teller County Terri Thornberry, LaPlata County Randy Lesher, Fremont County Ginny Bultman, Aspen/Pitkin County Dennis Tharp, Arapahoe/Adams/Jefferson County Carl Simpson, City and County of Denver Chris Olson, Citizen