The Search for a Uniform 911 System

In a letter sent to major hotel chains, FCC Commissioner Ajit Pai urged hotels to program their telephones to be able to dial 911 without first dialing 9. The motivation behind this initiative is the death of Kari Hunt Dunn, who was stabbed to death at the Baymont Inn in Marshall, Texas this past December, while her daughter unsuccessfully attempted to dial 911 for help.   The Baymont Inn’s phone system required all guests to dial 9 before dialing 911.  As a result, the daughter was unable to reach emergency services.

Commissioner Pai proposes a uniform 911 system:  “when consumers dial 911, they need to reach emergency personnel; it shouldn’t matter…whether they are using a phone at a hotel, motel, or office building.  If you dial 911 in a large building, you need to reach someone qualified to help.”  Commissioner Pai’s letter asks hotel owners to answer the following questions by February 14, 2014:

  1. How many hotel and motel properties in the United States does your company own?
  2. In how many of those properties would a guest dialing 911 from the phone in his or her room reach a Public Safety Answering Point or 911 call center? In such cases, does the phone system also alert a hotel employee that an emergency call has been placed?
  3. In how many of those properties would a guest dialing 911 from the phone in his or her room reach a hotel employee? In those cases, have hotel employees answering such calls received appropriate training in how to respond to emergency calls?
  4. In how many of those properties would a guest dialing 911 from the phone in his or her room not complete a call to anyone?
  5. If your company has any properties where a guest dialing 911 from the phone in his or her room does not reach emergency personnel, what is your company’s plan for remedying this situation? If you do not have a plan, why not?

In response to Commissioner Pai’s letter and media attention given to the issue, the American Hotel & Lodging Association (“AHLA”) has created a task force to develop recommendations on how this problem could be addressed.  Commissioner Pai responded favorably to the proposed AHLA task force in a statement last Friday, saying that he was “pleased” and that he “urge[s] the task force to work with dispatch to find simple solutions” to the issue.  AHLA President, Katherine Lugar, noted however that there might not be a simple fix in all cases because hotels must “take into consideration a variety of factors, both internal, including operational challenges, and external, including municipal, county, and state requirements.”

Originally published on Duff on Hospitality.

Colin Andrews

Admitted in Maryland, but not yet admitted in the District of Columbia. Practicing under the supervision of John Crigler, a member of the District of Columbia Bar. Colin Andrews' practice focuses primarily in Federal Regulatory Law, focusing on Telecommunications and Government Procurement. He is particularly knowledgeable in Administrative and Regulatory law as it pertains to communications, government contract and financial regulatory law. He has worked on responses to Federal Communications Commission's actions against Radio and Television stations, and drafted replies to Enforcement Bureau letters of inquiry. He's also familiar with Tribal Sovereignty law and has drafted briefs to advocate keeping tribal-owned stations exempt from certain Federal regulations. Most recently, Colin has aided numerous Tribal, Religious, Educational and other nonprofit clients to participate in the FCC's auction window to receive permits to construct Low Power FM stations to better serve their committees. While in law school, Colin worked as a legal clerk in our DC office. Prior to starting at GSB, he was also a legal clerk at The White House, U.S. Securities and Exchange Commission, and Bloomberg/Bureau of National Affairs.

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