A Professional Perspective: Kari’s Law

  critique policy telecom

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On December 1, 2013, Kari Rene Hunt was murdered by her estranged husband whom she was intending to divorce. She agreed to meet him at a local motel to leave their children with him for a short visitation while he was in town. Her estranged husband ambushed her in the motel room and cornered her in the restroom. During the struggle and resulting death of Kari, her oldest daughter, age 9, (name withheld for privacy) attempted to dial 911 from the motel room phone. She followed instructions as taught by her mother on the way to call for help but she was never instructed that in some hotels and motels you must first dial a “9” and then 911.

This is the beginning of a petition created in 2013 that petitioned the Senate and the House to enact “Kari’s Law”, which would ensure that when 9-1-1 is dialed at any hotel or motel, including Mom and Pop locations, the call is connected to 9-1-1 dispatch. This bill has been widely received, but there are fundamentals flaws with what is being advocated here.

First, consider how today’s Private Automatic Branch Exchange switching systems work. PABXs, simply PBX due to the decline of Private Manual Branch Exchanges (PMBXs), handle internal switching locally which reduces telephone costs considerably. PBXs are connected to the PSTN (Public Switched Telephone Network) using Central Office Trunk lines; there are usually considerably fewer trunk lines than the number of stations in the PBX. This is because it is very unlikely that all stations will attempt to make external calls at the same time.

The traditional way for users of a PBX to make an external call to the outside world is to dial 9, which signals to the PBX that the subscriber would like an outside line. The subscriber can then dial their number as they would on a telephone handset connected directly to the PSTN, like those in most homes and small shops.

In a traditional PBX, “Kari’s Law” would be impossible to enact. As soon as 9 is dialed for an outside line, the PBX connects the subscriber who dialed 9 to an outside line, and then pretty much steps out of the picture. From that point onwards, the Central Office is responsible for routing the call, not the PBX. VoIP implementations, which are not really telephone systems at all and suffer from poor quality and poor reliability, generally wait for the user to dial all digits before analyzing the call and routing it, but a traditional PBX will actively route the call as it is being dialed, just like standalone telephones directly connected to the PSTN.

To reach 911 Emergency, 9-9-1-1 must usually be dialed. Most newer systems may intercept the call if 9-1-1 is detected (using Automatic Route Selection), but some systems do not. There is simply no way for a PBX to know what digits are being dialed after an outside line has been grabbed. When Kari’s daughter dialed 911, what the Central Office actually “heard” was ’11’. The number 11 is actually an extremely commonly misdialed number. Most people probably never mean to dial the number 11, but simply hitting the switchhook twice is the same as dialing 11 (this is called switchhook or hookswitch dialing). Obviously, rerouting all calls to “11” to account for uneducated PBX users is not the solution, since this will cause a massive increase in accidental calls to 911 by subscribers who are not on a PBX.

Kari’s father, Hank Hunt, has continued to press this legislation. Kari’s Law, unfortunately, is now a reality in Texas. This bill has even been received favorably by the House. The sad reality is, although we believe he means well, the legislative parties involved who will hear his case have no technical expertise when it comes to the operation of a PBX and how a PBX is interconnected with the PSTN. Neither does Hank Hunt. The proposal outlined by Hunt is not an effective or enforceable solution, but there do exist several more cost-effective and actually enforceable solutions.

When AT&T introduced 9-1-1 in 1968, it did not catch on quickly. It was not until the 1990s and early 2000s that a large majority of the North American population could dial 911. Traditionally, if there was an emergency, the Operator was contacted by dialing “0”. Today, about 2% of the US population still lacks 911 service. In these areas, even today, those wishing to reach emergency services must either dial the local number for police, fire, or medical help, or dial their Operator and ask for the appropriate response team.

When 9-1-1 was introduced, PABXs did not exist. All PBXs in use at the time were PMBXs, which mean nobody in a PBX could dial their own calls. The PBX switchboard operator would have to complete a call for them. Now that PABXs have supplanted PMBXs, we have become accustomed to dialing 9 for an outside line rather than simply picking up the receiver and asking to be connected with someone.

PBXs have become much more prevalent, and will only continue to grow in popularity. Some PBXs may have as few as three stations connected; others may have thousands. So what does this all have to do with “Kari’s Law”?

We’ve already discussed how “Kari’s Law” will be impossible to implement on traditional PABXs. Enforcing this poorly designed, albeit well-meaning, law, would require all traditional PBXs to be upgraded to newer technology. Apart from incurring costs in the billions of dollars nationwide (costs which will likely drive Mom and Pop motels out of business), most newer systems are not compatible with legacy infrastructure and are not designed with quality or reliability in mind, as traditional PBX implementations are. Implementing “Kari’s Law” would require the user of dial-plans, which are usually only available on more expensive PBXs, and would also require that calls NOT be routed as they are dialed, which would significantly delay every call made through that PBX. While “Kari’s Law” is representative of the technical inexpertise that telephone experts must contend with, we would like to point out more effective ways of dealing with the problem of not being able to dial 9-1-1 from behind a PBX.

1. First of all, education is key. During the days of the Bell System, companies would have a representative from the telephone company come out to the office and go over telephone etiquette, as is depicted by both the 1940s and 1971 films released by the Bell System to educate the business world about telephone etiquette and telephone best-practices. While both of these videos feature PMBXs, the introduction of PABXs has not lessened the need for telephone education. Even in schools, many children do not know that they must dial 9 for an outside line. While those who work in an office or large building where a PBX is used are accustomed to dialing 9 for an outside line, they were likely not educated about this in childhood. Now that programs like the Bell System’s “Telezonia” no longer exist, America’s children are no longer being taught how to use the telephone. A parent simply teaching their child to dial 9-1-1 in an emergency is not enough. Children must be taught early on to dial 9 for any calls that will leave the building, including emergency calls, as the prevalence of PABXs will only continue to grow.
2. Requiring that 9-1-1 be rerouted to 9-9-1-1 is infeasible from a technical standpoint. As previously mentioned, systems that route calls as they are dialed will not be able to perform the reroute that would required by “Kari’s Law”. Secondly, who’s to say legislation will stop here? Why not ask that instead of requiring 9-4-1-1 to be dialed for Information, just 411 should be dialed? Why not ask that the use of the digit 9 for an outside line just be eliminated? Why not have two telephones – one directly connected to the PSTN and one that can only be used within the PBX? You can see that enforcing “Kari’s Law” would only open another can of worms. Those who are accustomed to using PBXs know that to dial 555-1212, they must dial 9-555-1212. 911 Emergency is just another party. 911 is just a number (although 911 sometimes maps to a regular 7-digit number associated with an area's PSAP (Public Service Answering Point), but in such cases this number is usually not made publicly available). When you make a telephone call, you don’t dial a number – you dial instructions. Think about it: you must dial differently to reach a telephone across the country than somebody living 2 miles from that telephone would have to. You both dialed the same "number", but you dialed different instructions. When you use a landline telephone, you are not dialing a number; you are dialing instructions for how to reach that number. It cannot be expected that the “instructions” to reach a number are always the same as the number itself. In fact, this is only true for local calls that are not made from behind a PBX. All other calls represent calls where the instructions are not the same as the number.
3. Hotel and motel telephones usually have signs affixed to them with dialing instructions. These signs are largely the same from hotel to motel to hotel: Dial 0 for Front Desk, Dial 0 for Emergency, Dial 9 + Number for local calls, Dial 9 + 1 + Area Code + Number for long-distance calls. Any child that can read, even if she doesn't know she must dial 9 for an outside line, should be able to make a telephone call to the intended party.
4. Children must and should still be taught how and when to dial the Operator. Calls to the number “0” are fewer than ever before, but the Operator still plays an important role in the PSTN. All collect, person-to-person, and station-to-station calls are made through the Operator, although alternative systems like 1 (800) CALLATT and 1 (800) COLLECT do exist now. Busy Line Verification and Interruption requests are made through the operator. And those who have trouble dialing or reaching a number were and should still be taught to dial the the Operator. Even if a child has not been taught to dial 9 for an outside line, they will still be able to reach someone. Although 90 must be dialed for the telephone company’s operator from a PBX, dialing 0 will still connect the calling party to the PBX’s operator. In the case of a hotel or motel, a caller will be connected with the Front Desk, which is preferable to not reaching anyone at all as is the case when 911 is dialed. In fact, most hotels and motels, as stated above, post on the telephone that guests should dial 0 in an Emergency. So if a child is taught how to dial the Operator, then she should not encounter any problems with any telephone system. If children have not been taught to dial 9911 for 911, they can simply dial 0.

The incident that inspired “Kari’s Law” was unfortunately, an accident waiting to happen in the aftermath of the Bell System Divestiture in 1984. Since, telephone training and education has suffered or been eliminated entirely. It is important that children are taught from a young age not just how to dial 911, but how to dial calls from within a PBX both internally and externally, and how to dial the Operator. As tragic as Kari’s death was, it was Kari’s daughter’s, not the PBX’s, fault that she was not able to reach anybody. She had simply not properly learned how to use the telephone – most likely because her parents had neglected to teach her properly or had assumed she would have learned in school and, unsurprisingly, did not. Most schools no longer teach children how to use the telephone. We can’t blame her parents or our education system entirely, however, because furthermore, she did not read the sign posted on the telephone. Hotels and motels do not assume their guests know how to use a telephone that is on a PBX, which is why they post signs. If someone neglects to read the sign, that’s on them.

Regardless of whether a child has been taught to dial 9 or not, they should ALWAYS be able to reach someone by dialing 0. While children should know that they must dial 9-9-1-1 in an emergency, if they don’t (and even if they can’t read), all is not lost.

Operators handled the very first telephone calls, and operators will continue to be there to handle calls for those who have difficulty reaching the party they wish to speak with.

Hopefully, you now understand that enforcing “Kari’s Law” is impractical, not cost-effective, and will not solve the problem. This problem can be solved by education, and by education alone.

Additional thanks to Shane Young for some helpful additions and corrections to this piece. Some helpful information about N11 in the US:

• Most PSAPs have a 10-digit number. Frequently this would have been the legacy police/sheriff/fire department's listed numbers that are not associated with the selective routers used with 911. However 911 is usually *not* translated to a PSTN number.
• Only 711, 811 and 911 are federally mandated numbers. 711 and 811 are typically routed to a toll-free number for the agency serving that function. With a few exceptions, there is one 711 agency and one 811 agency per state. There are a few that are split up a little more granular than that.
• There is no national coordination of 211. 311 is also really hit or miss.
• 411 *was* typically not translated, but sent directly over Operator trunks. In SxS days, you might have to dial 1-411 depending on the area you were in.
• 611 is typically translated to a PSTN number
• 511 is translated to a toll-free number in states where it is deployed. Not available everywhere either.