On February 22nd, 2012, President Obama signed H.R. 3630, also known as the Middle-Class Tax Relief and Job Creation Act of 2012 into law. In this Act, under Section 6504 -REQUIREMENTS FOR MULTILINE TELEPHONE SYSTEMS- it states explicitly that “[T]he Administrator of General Services, in conjunction with the Office, shall issue a report to Congress identifying the 911 capabilities of the multiline telephone system in use by all federal agencies in all federal buildings and properties.” The GSA, in addition to being the purchasing arm of the US Government, is the agency responsible for constructing, managing, and preserving government buildings by leasing and managing commercial real estate. According to their website, http://gsa.gov, the agency also promotes management best practices and efficient government operations through the development of government-wide policies, and their mission is “[T]o deliver the best value in real estate, acquisition, and technology services to government and the American people.” In total, they are responsible for nearly 10,000 federally owned or leased buildings, all of which would have been covered by the aforementioned GSA report that was required by Congress. It only seems logical that the US Government, a large Enterprise in itself, would have the same concerns that commercial businesses have with proper 911 access from Federal Buildings.
The Dog Ate my Homework
As of Saturday, June 18, 2016, that report remains 1308 days (three years and seven months) past due. The Act also required that no later than 90 days after the date of enactment, a notice is issued seeking comment from MLTS manufacturers on the feasibility of including within all systems manufactured mechanisms to provide sufficiently precise indications of a 911 callers location.
MLTS manufacturers have long since responded with features and functionality to address emergency calling from these types of systems systems, and most, if not all, contain the basic capabilities to deal with the situation, requiring add-on functionality for only the more complex environments. There still remains, however, a lack of awareness and in many cases these features are not properly configured or implemented. This simple lack of awareness leaves many government employees at risk. History has proven time and time again that this problem knows no boundaries affecting schools, businesses, hotels, and any other facility where a multi-line telephone system is used. While admittedly, surveying all 9,600 properties reportedly under the control of GSA, the mandate ordered in this Law was not to remediate the problem; the mandate was to produce a report on the scope and expanse on the problem.
What You Don’t Know MAY Hurt You
It is only with the information from this report that the facts become well understood, and assessments of the risk can be made. If nothing else, awareness of the problem will be raised. Despite the current situation, has every new facility opened or upgraded in the past three years had this situation addressed? Likely not. The problem is well known, and documented, and to ignore it at this point is simply foolish and borderline egregious.
Case in point, the Federal Communications Commission headquarters building in Washington, DC itself was noncompliant and unable to dial 911 directly, as reported by FCC Commissioner Michael O’Reilly in his June 2, 2014, blog. Commissioner O’Reilly reported, “Our employees and any visitors must dial 9-911 to reach help in an emergency. I asked that the agency look into options for fixing this problem. Since then, we have learned how simple reprogramming our telephone system would be.” A short time later, Chairman Tom Wheeler ordered the system to be reprogrammed, and FCC staff are now able to dial 911 directly.
This glaring lack of compliance for basic emergency calling could have been noted on a report issued by the GSA on multiline telephone system capabilities for emergency calling, had they produced one. But unfortunately, they did not, and as of this point that report is more than a year and a half overdue. How many other buildings suffer this same ailment? Likely many if history in the Enterprise space is any indicator.
On March 11, 2015, FCC Commissioner Ajit Pai sent a letter to acting GSA Administrator Denise Turner Roth asking about the status of this report directly requested by Congress, and as part of the Law enacted with HR 3630. At the time the letter was sent, the report was 843 days overdue, yet to this date, there has been nothing but silence from the GSA. One has to wonder, if we need to wait for another tragedy to occur, and an innocent life lost before we recognize this simple problem and address it? The other burning questions are; Why is the GSA withholding this information? Have they done any work at all in the past 3 1/2 years? Are they worried that they are so out of compliance that a considerable expense would be required to correct the issue?
Is is Broken? Then FIX IT!
If the GSA is responsible for facilities and the technology, I am sure this also includes maintenance coverage for ‘break-fix’ matters that come up from time to time. I will offer the point of view that if my phone system will not dial 911 effectively and report the proper information to local emergency services personnel, then that system is broken, and should be fixed. We can no longer ignore this critical life safety issue. Additionally, how bold do you have to be to ignore a formal request by an FCC Commissioner? Obviously, brave enough to also overlook a mandated order by the U.S. Congress, as designated by Federal law.
One also has to wonder, where is the US GAO in all of this? This independent, nonpartisan agency works for Congress and is often called the “congressional watchdog,” part of their job is to investigate how the federal government spends taxpayer dollars. If MLTS systems were purchased, and not able to dial 911, I would imagine that could be argued as a point of dispute, between the US Government and the supplier. At least for any system purchased and installed after Congress passed the bill and it became law.
Who’s shoulders does this fall on? According to their web page, the head of GAO, the Comptroller General of the United States, is appointed to a 15-year term by the President from a slate of candidates Congress proposes. Gene L. Dodaro became the eighth Comptroller General of the United States and head of the U.S. Government Accountability Office (GAO) on December 22, 2010, when he was confirmed by the United States Senate. He was nominated by President Obama in September of 2010 from a list of candidates selected by a bipartisan, bicameral congressional commission. He had been serving as Acting Comptroller General since March of 2008.
Who Let the Dog Out? No One
If the GAO is the “Congressional watchdog”, shouldn’t they look into this issue? I believe so. Transparency, openly ignoring authority, and failure to perform tasks that are legally obligated seems to be something that would be right in their wheelhouse.
Mark J. Fletcher, ENP is the Chief Architect for Worldwide Public Safety Solutions at Avaya. As a seasoned professional with nearly 30 years of service, he directs the strategic roadmap for Next Generation Emergency Services in both the Enterprise and Government portfolios at Avaya. In 2014, Fletcher was made a member of the NENA Institute Board in the US, in 2014 – 2015 he served as co-chair of the EENA NG112 Committee in the European Union, providing valuable insight to State and Federal legislators globally driving forward both innovation and compliance.
The World According to Fletch . . . 