The letter summarizes a tragic event where a woman was murdered in a Texas hotel room in front of her children. When the children called 9-1-1 from the hotel room phone for help, no one answered. The letter argues that multiline telephone systems like those in hotels often require dialing 9 first to access an outside line, but callers in emergencies may not know this. The letter urges the FCC to require that 9-1-1 calls from any phone be connected to emergency services without needing an access code, that 9-1-1 calls not be intercepted by on-site staff, and that on-site notification be provided when an emergency call is made. This would help address situations like the family

1.
December
27,
2013
The
Honorable
Tom
Wheeler,
Chairman
Federal
Communications
Commission
445
12th
Street
SW
Washington,
DC
20554
Chairman
Wheeler,
On
December
1,
2013
a
tragic
event
took
place
when
Kari
Rene
Hunt
was
murdered
in
Marshall,
Texas.
The
murder
took
place
in
a
hotel
room
at
the
Baymont
Inn
and
Suites.
One
of
the
most
tragic
elements
of
this
horrible
event
is
the
fact
that
the
attack
on
Ms.
Hunt
was
witnessed
by
her
children.
Seeing
their
mother
in
grave
danger,
they
did
exactly
as
they
were
instructed
to
do-­‐-­‐they
grabbed
the
telephone
in
the
hotel
room,
and
dialed
9-­‐1-­‐1,
yet
no
one
answered
that
desperate
call
for
help.
The
National
Emergency
Number
Association,
representing
more
than
7000
members
dedicated
to
saving
lives,
promotes
the
simple
concept
of
“One
Number,
Any
Device,
Anywhere.”
This
phrase,
however,
is
far
more
than
a
tagline.
The
fact
is
that
while
this
instructional
message
is
accurate
with
personal
communications
devices
like
mobile
phones
and
our
home
landlines,
this
is
not
always
the
case
for
telephones
serviced
by
multiline
telephone
systems
(MLTS/PBX),
such
as
those
that
exist
in
hotels,
hospitals,
schools
and
many
other
large
commercial
buildings.
Multiline
systems
often
require
a
special
access
code
(in
most
cases
a
dialed
“9”)
that
is
necessary
for
the
caller
to
reach
an
outside
line.
Because
of
the
need
for
the
extra
digit
to
be
dialed,
in
many
cases,
an
individual
who
is
situated
“behind”
an
MLTS/PBX
is
required
to
dial
9
9-­‐1-­‐1
in
the
event
of
an
emergency,
and
may
not
be
aware
that
the
extra
digit
is
necessary.
According
to
the
family,
this
is
precisely
what
happened
in
Marshall,
Texas
in
December
2013.
As
technology
has
become
increasingly
sophisticated
in
communications
systems,
the
conflict
of
dialing
9-­‐1-­‐1
vs.
dialing
9-­‐9-­‐1-­‐1
has
been
recognized
and
addressed
by
most
vendors
in
ways
that
are
internal
to
the
MLTS/PBX
through
programming,
and
at
no
additional
cost
to
the
MLTS/PBX
owner/operator.
Many
corporate
consumers,
including
those
previously
mentioned,
just
don’t
recognize
the
critical
nature
of
this
“add-­‐on”
and
its
marginal—if
any—cost.
On
January
13,
2011,
the
Federal
Communications
Commission
Public
Safety
and
Homeland
Security
Bureau
sought
out
comments
from
the
industry
regarding
multiline
telephone
systems
pursuant
to
the
Next
Generation
9-­‐1-­‐1
Act
of
2012.1
Comments
on
various
elements
of
the
feasibility
for
precise
9-­‐1-­‐1
location
information,
as
well
as
comments
on
the
NENA
model
legislation,
were
requested.
1
https://www.federalregister.gov/articles/2011/01/13/2011-565/framework-for-next-
generation-911-deployment
Mark J. Fletcher, ENP
Chief Architect
WW Public Safety Solutions
211 Mt. Airy Road
Basking Ridge, NJ 07920
908.848.2602 voice
FletcherM@avaya.com

2. 9-1-1 Access from MLTS - 2
The
response
by
NENA,
APCO,
Avaya
and
others
was
clear.
There
is
no
technology
gap.
There
is
no
financial
barrier.
Affordable
and
easily
implementable
solutions
exist
in
most
environments
today,
and
it
is
merely
the
lack
of
public
education
and
awareness
that
remains
as
a
barrier
between
MLTS/PBX
users
and
this
element
of
public
safety.
There
are
three
simple
steps,
if
addressed
from
a
legislation
perspective
that
will
go
a
long
way
to
remediate
this
problem
to
ensure
that
the
number
of
tragedies
such
as
the
one
that
took
the
life
of
Kari
Hunt
will
be
significantly
diminished
if
not
entirely
eliminated.
• 9-­‐1-­‐1
dialing
from
any
telephone
device,
without
the
need
for
an
access
code
While
dialing
an
access
code
(such
as
9-­‐9-­‐1-­‐1)
should
also
be
recognized,
a
requirement
should
be
in
place
so
that
the
dialed
digits
of
9-­‐1-­‐1
are
recognized
and
properly
routed
to
emergency
services.
• Immediate
routing
to
9-­‐1-­‐1
The
interception
of
a
9-­‐1-­‐1
call
event,
and
local
answering
by
non-­‐certified
and/or
untrained
on-­‐
site
personnel
has
become
a
dangerous
and
alarming
trend.
This
practice
jeopardizes
the
safety
of
callers
with
emergencies
by
allowing
untrained
individuals
to
answer
emergency
calls.
This
delays
the
response
by
trained
and
appropriate
public
safety
officials
at
a
point
in
time
where
seconds
count
in
an
emergency.
This
sub-­‐optimal
practice
must
be
curtailed
and
rectified.
• On-­‐site
notification
or
alerting
that
an
emergency
call
has
been
initiated
Access
to
large
buildings
and
facilities
can
be
complicated.
Internally-­‐
trained
responders
can
be
of
great
assistance
to
public
safety
officials
in
an
emergency.
On-­‐site
notification
can
ensure
those
in-­‐house
personnel
that
"need
to
know"
have
the
appropriate
information
to
both
expedite
an
internal
response
and
be
prepared
for
first
responders
when
they
arrive
at
the
building.
When
implementing
new
technology,
many
customers
inquire
"what
is
the
law
for
E9-­‐1-­‐1
and
MLTS/PBX?”
Unfortunately,
that
answer
becomes
increasingly
unclear,
especially
when
an
entity
has
locations
in
multiple
states
where
rules
addressing
E9-­‐1-­‐1
and
MLTS
are
inconsistent,
or
where
there
is
no
legislation
at
all.
For
this
reason,
a
common
policy,
or
a
stronger
federal
mandate
is
critical
to
minimize
confusion
and
save
lives.
Finally,
this
issue
is
very
personal
for
me.
In
2009,
I
suffered
a
brain
aneurysm
in
my
New
Jersey
home.
As
I
was
collapsing
to
the
floor,
my
last
words
to
my
daughter
were
“Call
9-­‐1-­‐1.”
She
grabbed
the
closest
phone
to
her
and
dialed
those
digits.
The
phone
she
used
was
an
IP
phone
connected
to
a
PBX
in
Texas.
While
the
MLTS/PBX
was
programmed
properly
to
understand
9-­‐1-­‐1,
it
had
no
idea
I
was
in
New
Jersey,
and
my
call
was
routed
to
a
local
Dallas,
Texas
trunk.
The
9-­‐1-­‐1
call
taker
realized
there
was
a
problem,
and
directed
my
daughter
to
find
another
phone
and
call
9-­‐1-­‐1.
The
bottom
line
is
that
I
know,
both
personally
and
professionally,
how
lucky
I
am.
I
greatly
appreciate
your
support
on
this
important
issue,
and
request
that
the
Federal
Communications
Commission
makes
this
initiative
a
priority
for
its
2014
agenda.
I
would
be
happy
to
meet
with
you
personally
to
discuss
this
issue
in
Washington
whenever
your
schedule
permits.
Respectfully
submitted,
Mark
J
Fletcher,
ENP
Chief
Architect
Avaya
Public
Safety
Solutions