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2008 CALLS Nomination

PBX/MLTS Committee Announcement
The APCO International PBX/MLTS Committee is pleased to announce we have launched a new initiative to recognize those organizations who have made an effort to provide 9-1-1 centers with accurate location information from a PBX/MLTS. Please take a few minutes of your time to read the attached announcement. Please respond to our request by providing us with names of organizations who deserve appreciation recognition for their efforts to enhance public safety in response to PBX/MLTS challenges for 9-1-1 PSAP's by introducing solutions to their own telecom systems.

PBX/MLTS... Another challenge for public safety communications.

Public Information on PBX

A public information brochure that outlines the PBX/MLTS location issue in plain English.

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The needs of public safety transcend the issues.

The business community and public safety should work together to address the needs of public safety.

Location information is one of the most critical components of information that can assist in appropriate response to a request for service.

In many instances today, the specific location information of a 9-1-1 call is not being provided from business systems due to their inability to transmit this information to the 9-1-1 system.

By effectively addressing this issue, lives and property can be better protected and public expectations regarding 9-1-1 response can be met.

It is incumbent upon the public safety community to heighten the awareness of these issues and work toward effective resolution to the problem.

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ISSUE IDENTIFICATION
The digits 9-1-1 are designated as the national emergency telephone number. Basic 9-1-1 service simply directs the caller dialing 9-1-1 to a public safety answering point on a plain old telephone set (POTS) without any pertinent information about the caller. Enhancements to the 9-1-1 system typically enables the caller's telephone number and location for the Public Safety Answering Point (PSAP). It is this telephone number that is used to retrieve address related information which is also displayed for the PSAP.As a result, when the caller is calling from a single-line telephone or a Multi-line Telephone System (MLTS) serving a small, compact area, the address associated with the caller's telephone number can be retrieved and usually provides a reasonably precise identification of the caller's location.

Public safety agencies increasingly rely on the Enhanced 9-1-1 system to provide dependable and precise information about the caller's location and a reliable number to call back in order to reach the caller in the event that the call was terminated.In some cases, however, 9-1-1 calls made from telephones connected to Multi-Line Telephone Systems, such as those in large businesses or campus environments, may not be precisely located by the 9-1-1 system, eliminating some of the crucial benefits of Enhanced 9-1-1.This lack of adequate location information can be life threatening if the caller cannot verbally supply the correct location information.The nature of 9-1-1 calls is such that the likelihood for the need to respond directly to the caller with minimal delay increases with the type of calls where the caller for some reason cannot verbally relate critical information to the PSAP.Related problems occur when the caller is remote from the location supplied automatically to the 9-1-1 system because it is imprecise or associated with a main number rather than the specific location from which the caller is calling.In these instances, not only is the response delayed, but also limited public safety resources may be dispatched to an inappropriate location and unable to respond properly.There also may be considerable disruption in business operations as the response units attempt to locate the source of the problem.

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PUBLIC EXPECTATIONS
The public expects and demands high quality 911 service.They expect that no matter where they are, the 911 system is going to work, is going to produce consistent results when they call for assistance, and will obtain the desired response to urgent situations.They expect that the 911 system will work essentially the same way whether they are calling from their home, their business or their car.

BACKGROUND
In 1994, the FCC issued Report and Order, 94-102, a part of which addressed issues related to PBX systems and their implications with 911 and enhanced 911 services. The Commission's Common Carrier Bureau and representatives of public safety communications organizations (PSCs) met with representatives of Multi-line Telephone Systems (MLTS) manufacturers and business owners/users of MLTS met to discuss the problem.From September 1996 to February of 1997 representatives of public safety communications organizations (PSCs) continued to meet with representatives of Multi-line Telephone Systems (MLTS) manufacturers and business owners/users of MLTS to examine possible areas of agreement on MLTS E-911 issues raised in FCC Docket 94-102.The representative organizations--the Association of Public-Safety Communications Officials - International, Inc. (APCO), the National Emergency Number Association (NENA), the National Association of State Nine One One Administrators (NASNA), the Ad Hoc Telecommunications Users Committee (Ad Hoc) and MultiMedia Telecommunications Association (MMTA)-- all have participated in the above-referenced docket through comments and reply comments.The following consensus statement covers issues on which substantial agreement was reached.

Public Safety Communications emphasized the particular difficulties for prompt emergency response arising from: (1) the relative isolation of residential units in apartments, condominiums, colleges and boarding schools, etc.; and (2) the occasionally wide dispersion of businesses or schools served by a common MLTS far removed from any of the user locations.Examples of emergency responses that failed or were delayed by blocked 9-1-1 calls or dispatch of help to the wrong address are prevalent.

MLTS manufacturers, distributors and commercial users cautioned that:(1) notwithstanding the examples regarding specific types of isolated or dispersed locations, the types of locations most commonly served by MLTS are more compact business settings that do not appear to have occasioned substantial, documented emergency response problems; (2) the significant equipment modification, telephone service and database costs of separately identifying and locating calls from MLTS -- which typically forward only the singular number and billing address of the private switch or key system -- may not be warranted by the relatively low volume of 9-1-1 calls from businesses; and (3) employers must be given the flexibility to use adequate alternative means of signaling and responding to emergency situations.

Both PSCs and MLTS providers and users recognized potential benefits in FCC action to address MLTS/E-9-1-1 issues, but from different perspectives.For PSCs, calls from telephone stations served by MLTS should result in Automatic Number Identification (ANI) and Automatic Location Information (ALI) that approximates the information given to Public Safety Answering Points (PSAPs) and emergency responders by single-line residential and business telephone service.Only the FCC is able to order such an outcome nationally.For MLTS providers and users, whatever reasonable approximations of ANI and ALI -- or their functional alternatives -- are adopted by the FCC, the solution should be national and should preclude inconsistent state and local regulation.

This consensus agreement, which would significantly resolve the issue, was submitted to the Commission's Common Carrier Bureau in April, 1997.Despite repeated reminders and questions on its progress, public safety and the publichas been waiting Federal Communication Commission action for nearly four years to resolve this issue.In the meantime, E911 PSAP operators all across the nation are forced to continue to deal with the problems on a daily basis and in doing so, hope that despite the demands of their workload or the stress of the emergency they are trying to handle, that they will not forget to verify the location of each and every call, whenever possible, rather than simply relying on the information being displayed in front of them--the consequences of which may well be fatal to those they are trying to help.

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RECENT ACTIVITIES RELATED TO THE ISSUE
On April 18, 2000 the National Emergency Number Association (NENA) published a PBX/MLTS E9-1-1 Model Legislation document on the NENA web site for review and comment.This Model Legislation document development was the result of a specially appointed study group assigned to work on a national level with the NENA PBX/ALEC Technical Committee.It is the intent of NENA to forward the final version of theModel to the FCC for their use and, hopefully, incorporation into the MLTS section of Report and Order 94-102.States would be able to use the NENA Model Legislation in development of state PBX/911 related legislation drafting.

The anticipated outcome is to recommend that the FCC also take action to incorporate into Part 68, requirements for Mulit-line Telephone Systems that will facilitate the implementation of Enhanced 9-1-1 on PBX, Key, hybrid and Centrex telephone systems.

Several states have already adopted legislative action to address the issue. Washington legislation is specific to certain situations and includes residential and business tenant service as well as school environments. Illinois legislation addresses all types of PBX services. Texas legislation cites residential services only.Several other states are in the development stages for legislation on this issue.

APCO and NENA have filed joint comments with the FCC on Part 64 and Part 68 of docket 94-102.This joint filing urges action by the FCC on the manufacture of multi-line telephone systems and telephone network compatibility with providing location information on systems.

The APCO Board of Officers at their June, 2001 Board meeting held in conjunction with the NENA/APCO Joint Board meeting has indicated their support of efforts to raise the level of action on the PBX issue and has directed the 911 Committee and Executive Director Ramsey to meet with NENA officials to develop a strategic plan of action to effectively address the problems.

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