COLORDO DEPARTMENT OF REGULATORY AGENCIES Public Utilities Commission

Denver, Colorado In the matter of: 911 RULEMAKING WORKSHOP AND ) REQUEST FOR COMMENTS: ) ) ACCESSING 9-1-1 SERVICE VIA A ) MULTI-LINE TELEPHONE SYSTEM )

COMMENTS OF AVAYA, INC. AVAYA, Inc. respectfully submits the following written comments and requests that they be read into the record in response to the Commission’s Request for Comments in the above-referenced proceeding.

COMMENTS

As a leading global manufacturer of multiline telephone systems (MLTS), AVAYA is

pleased to provide input to the Colorado Public Utilities Commission (CPUC) regarding the

creation and enhancement of E9-1-1 functionality and requirements for MLTS systems deployed

in the State of Colorado. AVAYA believes strongly that there are simple, cost efficient solutions

that need to be implemented to address the inability of current analog-based E9-1-1 networks to

pass real-time information and that continuing public education on E9-1-1 is critical in

addressing the problems that arise from inaccurate or otherwise inadequate information derived

from existing MLTS systems.

The inability to report the specific location of MLTS telephone endpoints has been an

ongoing problem since the inception of E9-1-1 networks, and has gotten more complex with the

device mobility that current technologies allow. There remains clear and present evidence that

state legislation, where it exists at all, has not been effective in safeguarding—let alone

compelling—remediationandcompliance.Todate (December,2015),only24stateshave

anyMLTSlegislationpendingorinplace1.WiththeexceptionofMichigan2,thereisalsoa

glaring omission of penalties for non-compliance, eliminating any incentive for MLTS

managersoroperatorstoimplementcorrectiveactions.

Inaddition,currentMLTSstatelegislativerequirementsvarygreatly,inbothscope

andcontext,and thisvariancealoneposesasignificantchallenge toMLTSoperatorsand

managersastheystruggletocomplywithapatchworkofregionaldirectivesacrosslarge

corporateenterprisenetworks,oftenspanningmultipleE9-1-1jurisdictions.

While AVAYA continues to support implementation of appropriate guidance and

enforcementatthefederalleveltoensurethatthepublicisproperlyprotected,thereisno

reason that state agencies cannot immediately advance legislation of their own.

Organizations such as the National Emergency Number Association (NENA) 3 , the

Association forPublicSafetyCommunicationsOfficials(APCO)4andevenagenciesabroad

such as the European Emergency Number Association (EENA) have excellent published

guidanceregardingacceptedbestpractices 5.

Employees,customers,andguestsatpublic facilitiesdonothave the luxury of waiting for

the Federal Communications Commission to establish mandates that maximizes their

safetyintheseareas.Preciousliveshavebeen—andwillcontinuetobelost--wheresimple

and cost-effective steps could—and should have been—undertaken, to mitigate and1CurrentPS/ALILegislationinplaceorpending,http://www.911etc.com/legislation,lastvisitedNovember23,20152 Michigan Public Service Commission, Order and Notice of Hearing, Exhibit A, Page 3, R 484.906 Penalties, (Last visited July 20, 2014), http://www.dleg.state.mi.us/mpsc/orders/comm/2011/u-16439_02-25-2011.pdf 2 Michigan Public Service Commission, Order and Notice of Hearing, Exhibit A, Page 3, R 484.906 Penalties, (Last visited July 20, 2014), http://www.dleg.state.mi.us/mpsc/orders/comm/2011/u-16439_02-25-2011.pdf 3NENAwebsite,http://nena.org4APCOInternationalwebsite,http://apcointl.org5EENAwebsite,http://eena.org

potentially avert the tragic outcomes that have filled the news.6AVAYA applauds the

Colorado Department of Regulatory Agencies and the Public Utilities Commission, for its

continued efforts and looks forward to providing input and assistance on this matter.

RESPONSES TO INQUIRIES

I. Should multi-line telephone systems be required to allow direct dialing of 9-1-1, without the requirement to dial “9” or another digit first?

AVAYA maintains, and has demonstrated7, that direct access to 9-1-1 from any telephone device

is an easily provisioned capability on most, if not all, modern MLTS Solutions commercially

available today. This premise was further endorsed during a recent workshop held by the Texas

CSEC, based on comments of the Texas Hotel and Lodging Association (THLA) where they

stated that “[T]he lodging industry has found that the vast majority of equipment can be

reprogrammed to directly dial 9-1-1 without substantial cost involved”.8

II. Should multi-line telephone systems be required to provide ALI information sufficiently specific for emergency responders to locate the end user?

Automatic Location Information (ALI) is intended to provide public safety dispatchers with

sufficient and credible information to dispatch emergency responders to the dispatch-able

address of the incident, and potentially indicate an appropriate building entrance or zone, if

applicable. This provides responders with sufficient information to respond to an incident, where

on-site staff or other in-place mechanisms can then be utilized to ascertain the additional location

6AVAYAINNOVATIONS,Issue12014,Smallchangein9-1-1LawsCanSaveLives,(LastvisitedJuly20,2014),http://www.AVAYA.com/usa/campaign/magazine/2014/1/small-change-in-911-laws-can-save-lives.html7ExpartefiledviaECFS,http://apps.fcc.gov/ecfs/document/view?id=7521065479,LastAccessed,November24,20158CommentsbytheTexasHotelandLodgingAssociation,https://www.csec.texas.gov/images/911_Docs/2015_HLA_Comments.pdf,lastaccessedNovember23,2015

information that is more specific and relevant. Notwithstanding, AVAYA does not believe that

specific location information beyond that level is either necessary or relevant on the initial

dispatch or that more detailed information can be efficiently conveyed to 9-1-1 call takers and

emergency responders at the time of the call for several reasons:

1. Locked or access controlled facilities force emergency responders to physically interact

with local on-site staff to gain access to the facility, and even with explicit details of

the callers location, the absence of internal plans available for cross referencing often

makes that information immaterial.

2. Managing the ALI database in the manner suggested requires that a unique public

telephone number (with recurring monthly costs) be established for each endpoint, as

well as a management solution to track and submit any updates and changes to the

associated ALI records, while causing a delay in their availability.

3. The ALI database record holding the information only provides limited storage space for

conveying information; specifically it is limited to only 30 characters, as defined in

the NENA II ALI Record formats9. Comments by PSAP Managers include, “these

fields are insufficient in length, are blank on most calls, or where data exists;

information is obsolete or inarticulate”. While descriptions such as “Cubicle 2C-231”

postulates the illusion of detailed accuracy, in reality the information is not relevant

to anyone who is unfamiliar with a facility’s layout.

4. Based on AVAYA’s experience and interaction with customers globally, enhancing the

level of detail in an ALI record provides nothing more than a false sense of security

9AsdefinedintheNENARecommendedFormats&ProtocolsForALIDataExchange,ALIResponse&GISMapping–NENA02-010

since the location of the incident may change, or responders may be distracted by

information that is not inevitably relevant to the event.

III. Should on-site notification be required, when available? Example: Should the multi-line telephone system be required to notify the front desk clerk of a hotel that a guest has dialed 9-1-1 and which room they are in so they can guide emergency responders to the room when they arrive?

The immediate generation of On-Site Notification (OSN) is extremely valuable during an

emergent event. In addition to providing detailed location information that directly corresponds

to the device making an emergency call, these systems can provide location details in a multi-

modal fashion, distributing that information to interested parties based on the origination location

of an emergency call event. This can provide valuable information to on-site personnel, such as:

1. Fostering the immediate coordination of assistance

2. Coordinated communications with 9-1-1 dispatchers, and clarifying incident details

through the establishment of a central point of contact

3. Enhancing service while reducing costs by eliminating the need to call back the

originating station directly, as a pre-designated station, with explicit details of the

incident, can be reached. This is critical as a caller may be incapacitated, unable to

speak, or no longer present in the area where the initial call was made due to safety

concerns.

IV. Should multi-line telephone systems be prohibited from terminating 9-1-1 calls internally without prior agreement from the PSAP that services the address? Example: A hospital may wish their 9-1-1 calls to terminate at an internal security office rather than sending them to the PSAP.

While often tempting to those outside of the PSAP community, the practice of intercepting

emergency calls by a Private Emergency Answer Position (PEAP) is not often considered to be a

best practice, unless specific contingencies are satisfied. Facilities that choose to operate a PEAP

must be able to demonstrate capabilities such as:

1.) Proper training and certification of staff

2.) Failover ability in the event the local PEAP is offline

3.) An operations plan in place that has been reviewed and approved by local Public Safety

officials

In the State of Maine, guidance is provided for those interested in operating a PEAP, and codifies

the specific requirements for interested parties.10

V. Should multi-line telephone system providers be prohibited from routing 9-1-1 calls to call centers outside the United States if they cannot route them to the appropriate PSAP?

Avaya believes that addressing the inability of the current analog-based E9-1-1 network to pass real-time information and the resolution of the issues associated with inaccurate or inadequate information is much more important than whether the terminating 9-1-1 call center is located outside the borders of the United States. The underlying issue is the accuracy of the information that is being transmitted in the first instance rather than the location of the 9-1-1 call center.

10PublicUtilitiesCommission625EmergencyServicesCommunicationsBureau-Chapter11:PBX/MULTILINETELEPHONESYSTEM(MLTS)REQUIREMENTS§12.PrivateEmergencyAnsweringPoint,www.maine.gov/sos/cec/rules/65/625/625c011.doc,LastAccessedNovember24,2015

CONCLUSION

WiththecurrentvoidofactionfromtheFederalCommunicationsCommission,and

thedesperateneedfordecisivedirectionforMLTSownersandoperators,AVAYAurgesthe

ColoradoDepartmentofRegulatoryAgenciesandtheColoradoPublicUtilitiesCommission

tomove forward as expeditiously as possiblewith the adoption of legislation andhopes

thatthesecommentsassistyouinyourdecisionmakingprocess.. Ifwemaybeof further

assistance,pleasedonothesitatetocontacttheundersigned.

Respectfullysubmitted, AVAYA,INC. By:/S/MarkJ.Fletcher,ENP ChiefArchitect–WorldwidePublicSafety

AVAYA, INC. 211 MOUNT AIRY ROAD BASKING RIDGE, NJ 07920 (908) 848-2602