Public safety access points are selected in a wireless network for E911 calls based on ESRD substitution when ESRKs are not being used. The present invention was conceived as an ESRK workaround solution to implement Phase II of the E911 rules from the starting point of a Phase I implementation. ESRKs, ESRDs or ESRVs are initially obtained and managed for each PSAP in a particular carrier's area. Then, Phase I processes are modified to wait to see if Phase II GSM location information will be reported in a timely manner (e.g., within a second or two or so) before committing to a default selection of a particular PSAP based on information available (e.g., based on the location of a serving cell site).