Correspondence from Lee Loevinger, FCC
to
The White House

[all correspondence from the archives of the LBJ Library, Austin, Tex.]

March 7, 1968

Honorable Joseph A. Califano, Jr.
Special Assistant to the President
The White House Office
Washington, D.C.

Dear Mr. Califano:

In view of your discussion with Chairman Hyde of the FCC concerning the establishment of a universal emergency telephone calling number you may be interested in a memorandum which has been prepared on the subject. A copy is enclosed for your information. Also enclosed as a matter of interest is a copy of a recent editorial in LIFE Magzine relating to this.

Sincerely yours,

Lee Loevinger
Defense Commissioner


LIFE Editorials [clipping]

March 1, 1968

007 done in by 911? It's almost a certainty. It won't be long before 911 takes over as the most memorable trio of digits in American culture. The telephone industry, led by the American Telephone and Telegraph Company, has announced that it is ready to start converting its phones tooa single emergency number that could summon police, fire or ambulance help in any city in the country.

The wonder of it all is that it took the nation with half the phones in the world until 1968 to decide that the traditional means for reporting emergencies are close to anarchy. In Los Angeles County there are 50 different numbers for the police. In the St. Louis area there ar 32 police numbers and 57 for fire emergencies. The number themselves, each with a different mind-cracking combination of seven digits, are a guarantee that nobody will be able to remember them when they need them most.

To make full use of the 911 system, cities will have to set up central dispatchers for their emergency services--a process that fortunately is already under way in some areas. And for those citizens stranded with an emergency to report and nothing but folding money in their pockets, AT&T to the rescue again.

As the 911 system goes into effect, the company proposes changing all its pay phones so that emergency calls--or those to "O" for operator--will not require a dime to go through. In effect, the nation's 1,363,000 public booths will become direct emergency phones.

The speed with which the new system goes into operation now depends on the cities agreeing to install it. They should regard it as a 911 situation.


The Universal Emergency Service Number
- The Problems and Some Answers -

The means of calling for help in an emergency are limited in nearly all situations faced by modern man to the range of the human voice and the telephone. In the United States thousands of people daily meet emergencies such as burglary, fire, injury, illness and the multitude of other unforeseen threats to life, health, safety and property that occur in modern society. In most of these situations the range of the hi-An voice is inadequate to reach others who are able to help. The one universal method of summoning help is the telephone. Use of the telephone, however, involves problems. First, you must know whom to call. Second, you must know the proper number. Third, you must find a phone and, if it is in a public place, must have the proper coins to activate a pay phone.

These problems have existed for decades and have given rise to much discussion as to means of simplifying and expediting the process. One obvious solution, or at least improvement, is the establishment of a simple universal telephone number to summon aid. A system of this kind has been used in England for about 30 years. In case of emergency you can dial number 999 anywhere in England. This number flashes a special light on the switchboard at the telephone exchange and is answered quickly by the operator. The caller then requests police, fire or ambulance and the operator routes the call to the appropriate emergency agency.

The possibility of devising some similar system for the United. States has been under discussion for many years. The staff of the FCC, of AT&T, of independent telephone companies, and of other agencies have at various times been involved in discussion of this subject. Formidable difficulties, arising in part out of the size and complexity of the United States, have prevented action. To begin with, the problem of finding a single number that would be compatible with the increasingly complex and automatic dial system of our numerous telephone companies has been difficult. A second problem has been the fact that political boundaries within which emergency agencies are organized do not correspond to boundaries of the telephone exchanges. A third difficulty arises because there are many conflicts and overlapping areas in the jurisdiction of our numerous emergency agencies, especially police agencies. In each metropolitan area there are municipal police, county sheriffs, and state police, and in many areas there are also federal agencies such as the FBI and the Secret Service as well as numerous other agencies having emergency functions. Fourth, there is a fear that any change in existing communications systems will be too costly.

In recent years there have been efforts and experiments in the United States to solve these problems. Throughout the country, telephone companies have advertised that the regular operator may be called for assistance in an emergency by dialing tie figure "O". For a number of years a large part of Los Angeles has had a system similar to the English system by which the number 116 could be used to flash a special signal on the switchboard of the telephone company operator. Minneapolis successfully used a single switchboard for its emergency agencies which could be called by a seven digit number. In several communities Bell system companies have wired pay telephones so that the operator can be called without inserting a coin.

Although telephone company operators have rendered outstanding service in securing assistance in numerous emergency situations, reliance on telephone company operators acting as an emergency service bureau has inherent limitations which make it inadequate as a general system for modern metropolitan areas. Operators are necessarily chosen and trained primarily to handle ordinary telephone traffic, such as person-to-person long distance calls. Emergency calls constitute a minor fraction of 1% of their work—about 40,000 out of some 14 million calls daily. General service telephone company operators cannot be expected to have the same background and training in handling emergency calls as attendants at a specialized emergency switchboard might have. Any emergency call to a telephone company operator requires a second call by the operator to an emergency agency, and this involves unavoidable delay. Finally, fluctuations in the volume of traffic handled by operators are such that calls to the operators are sometimes subject to much longer delay than is acceptable in emergency situations.

Demands for improvement in the method of using the telephone to summon help in an emergency have been increasing recently. The President’s Commission on Law Enforcement made a recommendation that there be a universal emergency number. A number of Senators and Congressmen have spoken and written to the same effect and have offered resolutions in Congress on the subject. The President's Commission on Civil Disorders communicated with the Chairman of the FCC on this subject in October 1967 and the matter was referred to the Defense Commissioner of the FCC. In discussion between the Defense Commissioner and the staff of that Commission it developed that there was evidence that dialing "O" for the operator was not always effective and sometimes resulted in intolerably long delays in summoning emergency assistance.

As a result of these conversations the Defense Commissioner got in touch with the top officials of AT&T. About the first of November the Defense Commissioner conferred with the President of AT&T on this matter. During the months of November and December 1967, the Defense Commissioner had a number of communications and conferences with top officials of AT&T, including the Chairman of the Board, the President, and Vice presidents involved in this aspect of the company’s operations. The Defense Commissioner, as a representative of the FCC, strongly urged AT&T to make every effort to find a means of establishing a universal emergency number that could be put into effect as quickly as possible and then take steps to see that this was done. The discussions encompassed virtually all of the problems and objections, and numerous proposed methods of accomplishing the objective were considered. The top officials of AT&T assured the Defense Commissioner that they would make every effort to devise a practical system and implement it as promptly as possible, and that they would keep the FCC informed.

On January 11, 1968, a Vice President of AT&T came to the Defense Commissioner and reported that the company had worked out and was ready to offer a universal emergency calling system. This system would use the number 911 as an emergency number throughout the United States. The company had determined that 911 is compatible with the dialing system of all telephone companies in the United States and Canada, and will be usable even when automatic dialing has been established from the United States to other parts of the world. All Bell System companies will be prepared to establish circuits that will bring 911 calls directly to a central emergency switchboard. The switchboard will be staffed and controlled by the local emergency agencies which will be responsible for making whatever response is required or appropriate to the calls. Ultimately all pay phones will be wired so that 911 may be called from any pay phone without charge and without putting in a coin. The 911 System will be supplementary to existing telephone systems, and will not supplant either the individual telephone numbers of the various local agencies or the service of telephone company operators when they are called upon for help in an emergency. It will take several years to change all switching offices in all Bell System exchanges to conform to this plan and the company estimates that the cost to it will exceed $50 million. Bell System operating companies are ready to begin working with emergency agencies and municipalities throughout the country to establish the 911 System, and they will give special attention and priority to large metropolitan areas. The plan can be made available in a number of large cities during 1968.

The Defense Commissioner and the Chairman of the FCC discussed this matter thoroughly with telephone company representatives and advised other government officials. A public announcement was made on January 12th and was widely reported in the press.

Following the public announcement there have been a number of comments by various parties. The general reaction has been highly favorable. However, a number of those who may be directly involved have voiced objections to the proposal. A spokesman for the International Association of Chiefs of Police has noted the multiple police forces and conflicting jurisdictions in many communities and stated that the proposal would present "a hatful of snakes.” The United States Independent Telephone Association circulated a letter stating, inter alia:

"In most of our communities there is no such organization as a single public safety agency. It may therefore be a problem to form such an agency and provide the funds necessary for the rental of switchboards and other necessary telephone equipment. There may be differences of opinion as to who should operate such an agency because of jurisdictional conflicts between state police, sheriffs and local police. In addition there will be the responsibility of handling fire calls and ambulance calls, perhaps from volunteer organizations which are not tied in with the police."

It appears from these and other similar communications and discussions with representatives of interested parties, particularly the police forces, that there are these objections to the plan;

(A) The Bell System did not consult with the various police organizations, independent companies, and others about this specific proposal prior to its announcement.

(B) There may be better methods of accomplishing the same objective. There may even be sophisticated techniques of electronic switching, which will be available in a few years and which will be more efficient than the proposed system.

(C) Use of a single emergency number may bring calls to the police which do not involve the detection and apprehension of criminals and may involve putting emergency calls through to other switchboards. These problems may cause some delay and police experience is that effectiveness in apprehending criminals is directly related to the speed of response.

(D) The new system may be expensive.

(E) There are numerous police agencies and other emergency services in each community, and there are jurisdictional problems involved in having a single number for these numerous, and often rival, organizations.

There is some basis for each of these objections but none of them appears sufficiently important or valid to warrant denying the public the benefits of the proposed new system.

(A) It is apparently true that AT&T did not consult the numerous organizations of emergencies agencies, various government units, and the independent telephone companies about this specific proposal before making its announcement. However, this subject has been under consideration for many years and the viewpoints, including the objections that have been voiced, have been well known. In any event, the question of who was consulted is not the basis of a substantial objection to the plan.

(B) It is conceded that there may very well be better systems developed in the future, and new techniques and new equipment may permit means of employing the telephone which are not now practical. However, the 911 plan has been devised and offered by the Bell System as a plan that is practical and immediate, and that can be put into operation quickly. It is not offered as a final and unchangeable system. On the contrary, AT&T officials have stated explicitly that they are prepared at any time to discuss the development or better systems with any interested parties. But they point out that the employment of sophisticated new equipment and techniques means the establishment of a system a decade or two from now, not immediately. For example, one possibility considered was that of simply putting an emergency button on each telephone. However, the Bell System alone has some 85 million telephones in the United States. Consequently, any system. that involves changing the telephones now installed will be both immensely expensive and take a very long time to put into operation. The 911 System does not preclude either the consideration or adoption of alternative systems but is offered as a system that can be put into use quickly while discussion and development of other systems is taking .

(C) The objection that the use of a single emergency number and a unified emergency switchboard will delay police response to criminal calls overlooks the practical alternatives. The choice is not between a system which might be ideally designed to serve only the needs of the police and the 911 System, but between the 911 System and the present system or some practical variant of the present system. Of the 40,000 emergency calls of all kinds received by Bell System operators each day it is estimated that 80% are routed to the police. AT&T advises that, at present, a substantial proportion of police emergency calls go through the Bell System operator, who is dialed by the "O" number. This proportion varies considerably from city to city (some estimates put it as high as 70% in a typical large city). In any event, many emergency calls to police now go through two switchboards, one of which is not an emergency switchboard and so will often be slower than an emergency switchboard should be. Any discussion of speed of response must take into account the fact that the significant response time is not the period between the flashing of the signal on the switchboard and the dispatching of a police car or other response. The significant response time—for any emergency—is the period between the occurrence of the event involving the emergency and the dispatching of responsive assistance. So far as analysis and investigation can ascertain, the proposed 911 System will be far faster in this respect than any practical alternative. Experience indicates that one of the principle difficulties in summoning aid is that people simply do not know what number to call. Even where there is a simple 7-digit number (as there is in Washington and New York), or where there is a single emergency number which is 7 digits long (as in Minneapolis), the public forgets, and gets confused, as to the number. Experience further shows that the public generally will not remember more than one emergency number and has difficulty with a number as long as 7 digits. The time lapse caused by indecision, wrong numbers, or the need to look up an emergency number is far longer than any time lapse that might occur in an emergency agency answering service, even if calls were routed through two switchboards. The important fact is that by providing the public with a single and easily remembered number the telephone call is made quickly and easily after the emergency has occurred, and that the speed of response is a matter which is subject to control of the emergency agencies. Any number of systems can be devised for expediting police and other response from the point of the emergency switchboard. Since about 80% of emergency calls are for police the attendants at the emergency switchboard can be equipped to dispatch the police response, as they are on many police switchboards. As the speed of response from the emergency switchboard is a matter of engineering and subject to control, it can be reduced to an absolute minimum. On the other hand, any alternative system which imposes the necessity of choosing among numbers or remembering some more complex number imposes a time delay that is not subject to control and that is most likely to be far longer than any delay under the 911 System. It therefore appears that the 911 System will in practice give a more rapid response in the overwhelming majority of police cases than any practical alternative.

(D) With respect to expense, it is not possible to make precise projections. A major expense of the proposed system will be to the telephone companies in making modifications in equipment of the telephone exchanges. For the Bell System this is estimated at more than $50 million. However, this expense will be borne by the Bell System companies and absorbed in the overall operations of the companies. (The potential expense to the telephone companies is the principal basis for objection by the independent companies.) Bell- System companies operate the telephones in most of the largest cities of the country and the problem is most acute in these metropolitan areas. It is proposed that conversion to the new system will take place in these areas first, so there will be an opportunity to gain experience with it before it is extended to the smaller communities. Costs to police and other emergencies (sic) agencies will depend upon their present communications and emergency call-handling facilities and those that they decide to use with the 911 System. Operating costs may be less for a consolidated 911 System than for today's operation of a number of separate switchboards. There may be some expense to emergency agencies in changing from separate communications systems to a unified emergency switchboard. Whether this will be substantial, and if so how much, cannot be established on a national scale, and will vary from city to city depending on local situations. AT&T will provide engineering assistance in each community to establish the most efficient and economical means of adapting to the 911 System.

(E) The most difficult problem undoubtedly is that of reconciling jurisdictional differences between and among the emergency agencies. The state, county, and municipal police departments are apparently not anxious to have a single number, and there is reluctance to establish such cooperation between police and fire departments and other agencies. No doubt there are genuine problems presented to the agencies. Several points require consideration in respect to this, however. First, the 911 System is not intended as a replacement for existing facilities or any system needed by individual agencies. It is neither required nor expected that the several agencies shall have a single telephone number. Each police department, each fire department and each emergency agency is expected to continue to have its own separate listing and telephone number and to transact the major part of its business through its own separate telephone. The 911 System is simply a means of summoning help in an emergency, and it is offered only as a means of furnishing the public a quick and easy way of calling for emergency assistance. AT&T will not discontinue the routing of emergency calls through its own operators if someone should call the operator. The emergency agencies will be free to handle any emergency calls on their own separate telephone numbers to whatever degree they desire. The 911 System is offered as the easiest, most convenient and most efficient system to the public, but it is not an exclusive system that precludes the use of other numbers.

It is important to remember that AT&T plans ultimately to change all pay telephones so that number “911” may be dialed without a coin and without cost to the person making the call. Thus, every pay phone wherever located becomes a means of summoning emergency help without charge or necessity of fumbling for a coin. On the other hand, as a practical matter, the company cannot have many numbers that can be called from pay phones without a coin. If each emergency agency should insist on having its own separate number this advantage to the public would be lost, as well as other benefits.

The most important point, however, is that the jurisdictional objection is based upon the viewpoint of the emergency agencies and not of the public. It might be somewhat more convenient for the emergency agencies to have separate numbers, although this aspect of the matter is probably exaggerated. However, from the viewpoint of the individual in distress there simply cannot be the slightest question as to both his convenience and dire need. The Washington Post recently published in its magazine section a list of emergency phone numbers in the Washington area. (Washington Post, Potomac, January 28, 1968. Copy attached thereto.) This listing shows 19 emergency telephone number for the metropolitan area. Furthermore, even this listing is incomplete. For example, there is no listing for the Coast Guard or any indication of the number that should be called if a boat in distress on the Potomac is observed. Even assuming that a substantial number of people would clip out these several pages and manage to preserve them by their telephone until an emergency occurs, it would be most difficult and impractical for an ordinary citizen to thumb through this list in order to find the appropriate number to call in many emergency situations. Consider some of the common emergency situations:

In all of the foregoing situations, and innumerable others that may and do occur daily (tens of thousands times each day nationally), it is plain that the endangered and panic-stricken citizen is not in a position to undertake even a hurried examination of reference sources, such as telephone books or lists of emergency numbers, even if they are available. Particularly under stress of emergency most people are unlikely to call some seldom-used 7 digit number. A universal 3 digit number ñ such as 911 becomes part of the language and common knowledge, just as almost everyone knows what SOS means although virtually no one actually uses it for a distress call. Thus having 911 as a universal emergency number will make it possible for many people to call for help by telephone in situations in which they would be wholly helpless otherwise. In virtually all other situations the universal emergency number will save precious minutes of indecision and anxious search for numbers, or of waiting for the telephone exchange operator to answer and then transfer the call.

Further, the existence of such specialized emergency aids as poison centers and pulmotor squads is unknown to most ordinary people The establishment and operation of a unified emergency agency switchboard center with trained attendants shifts the problem of knowing what facilities are available and of determining which agencies are best able to provide help from the panic-stricken, helpless citizens to the experienced, informed and presumably skilled attendants. As changes occur in facilities or jurisdiction among emergency agencies, the attendants at that emergency switchboard center can be kept fully informed. To the degree that specialized agencies or other emergency agencies find it inappropriate to participate in operating a central emergency switchboard, they can nevertheless be connected to the switchboard so that the attendant can communicate quickly with them. In situations in which there is a limited number of personnel qualified to aid in special kinds of emergencies (such as specifying antidotes for poison) a central emergency switchboard can be kept currently informed of the means of communicating with such personnel.

In short, it is literally impossible to inform the public in a large metropolitan area of all the emergency agencies and the facilities available or to teach it several ordinary but seldom-used telephone numbers. However, one 3 digit number is remembered and known, and the small cadre of professional attendants of an emergency switchboard can be kept fully informed and in a position to make a calm and skilled judgment as to the appropriate emergency agency for virtually any kind of an emergency. Further, the attendants will learn by experience in handle emergencies how best to deal with them. The public, on the other hand, does not have any such experience, as most people are confronted with emergencies only rarely.

Thus, the real issue involved in utilization of the 911 emergency calling system is whether the burden of coping with emergencies and the threats to life and safety posed by emergencies and with the confusing and conflicting complexity of government agencies shall be imposed upon the public, or whether the various agencies established to serve the public will assume the burden of cooperating among themselves to resolve such problems and to provide assistance to the public in emergencies as quickly and efficiently as possible. The 911 emergency calling system is not mandatory. It has been offered by the Bell System to all communities served by the Bell System at the request of the FCC and the United States Government. The system will be implemented where the emergency agencies in a community are willing to cooperate with each other to establish a single switchboard in order to expedite and facilitate assistance to the public in emergencies.

Conceivably a single agency, such as police, might want to preempt the emergency calling number for itself. However, this would merely result in all (or nearly all ) of the emergency calls coming to the police in the first instance. They would then have the responsibility either of directing calls to other agencies in whatever fashion they might devise, or of simply refusing to offer any information or assistance except in situations which were thought to come within their limited jurisdiction. The latter alternative is certainly so unattractive that it cannot be seriously entertained. Consequently, the issue simply resolves itself into the question of how the emergency switchboard is to be established and by who it is to be operated. This is a question .on which must be decided by the communities and agencies involved.

The various Federal Government agencies concerned with communications, law enforcement, and other aspects of these problems should not attempt to dictate to local agencies in these matters but stand ready to offer leadership and cooperation in dealing with these problems to whatever decree such assistance may be useful to the communities that desire to employ the new universal emergency service number.

Lee Loevinger
Defense Commissioner
Federal Communications Commission
February 27, 1968


[this letter was sent to Loevinger in response]

March 12, 1968

Mr. Lee Loevinger
Defense Commissioner
Federal Communications Commission
Post Office Dept. Building
Washington, D.C.

Dear Commissioner Loevinger,

Many thanks for letter of March, 7, enclosing your paper on the establishment of a universal telephone number.

As you know, this project is of great interest to us, and we are very grateful for your efforts in this area. I look forward to reading your material.

Sincerely,

Joseph A. Califano, Jr.
Special Assistant to the President

[Lee Loevinger died on April 27, 2004 at age 91. He was Defense Commissioner of the FCC when this correspondence was written, but he also had a long career a private practice attorney in Minnesota, and as an Associate Justice of the Minnesota Supreme Court. He left the state during the Kennedy Administration in 1961 to serve as Assistant Attorney General in charge of the Antitrust Division for the U.S. Department of Justice. He was appointed to be a Commissioner at the FCC in 1963 by President Kennedy to complete the term of well-known FCC Commissioner Newton Minow. He served five years on the FCC, and then joined the Hogan & Hartson in 1968, where he continued to practice until 2003.] 
In addition to his long and distinguished legal career, Lee had a life-long interest in science, and helped to found the ABA Section of Science and Technology and its Jurimetrics Journal. In recent years, he also wrote science articles for Nature and other science journals and studied astrophysics. Lee is survived by three children, Dr. Barbara Loevinger of Madison, WI, Dr. Eric Loevinger of Tallahassee, FL, and Peter Loevinger of Middletown, MD; and two granddaughters.

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