The ultimate technology and regulatory guide to prepare the enterprise for the FCC’s dispatchable location requirements
RAY BAUM’s Act is broad in scope, but the aspect most commonly focused on is Section 506 which refers to the rules adopted by the FCC requiring enterprises utilizing
Dispatchable location information provided to the public safety answering point (PSAP) includes a valid civic address, plus other information such as building, floor, suite, or room number “necessary to adequately identify the location of the calling party.” Dispatchable locations are required for both fixed or static phone devices as well as non-fixed, dynamic or nomadic phone devices.
Today’s enterprise and campus environments consist of large, multi-story buildings with complex layouts. A first responder arriving at one of these buildings armed only with the main street address is unlikely to quickly find a 911 caller located in a 4th floor conference room.
RAY BAUM’s Act establishes the concept of “dispatchable location” for Interconnected VoIP services and other 911-capable services. This more precise location information is critical to achieving successful emergency outcomes for calls that originate from multi-line telephone systems (MLTS).
The FCC’s new rules were published in the December 6, 2019 Federal Register. In accordance with the FCC’s order implementing RAY BAUM’S Act, the initial compliance dates for the Section 506 “dispatchable location” components of RAY BAUM’S Act can be found in the following table.
Learn the 6 steps to maintain compliance and protect users in Bandwidth’s Guide to New E911 Regulations!
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Bandwidth’s E911 for VoIP and Unified Communications and E911 Dynamic Location Routing solutions are fully-consistent with RAY BAUM’s Act requirements for providing dispatchable location.
Bandwidth’s E911 for VoIP and Unified Communications solution is designed for users with desktop and conference phones. You spend less time managing 911, less time wondering if your users are protected, and more time focused on your day job.
Supports RAY BAUM’s Act Fixed MLTS and Interconnected VoIP ServicesE911 support for non-fixed devices requires sophisticated “dynamic” solutions that protect users who frequently move around the corporate network or from remote locations. This innovative option helps enterprises answer the essential question: where are my users at the time they make a 911 call?
Supports RAY BAUM’s Act Non-fixed MLTS and Interconnected VoIP Services
E911 compliance regulations are confusing and tough to unravel. Our expert-developed resources can help you answer the most common questions about RAY BAUM’s Act.
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Kari’s Law compliance, MLTS 911, and what that means for your business
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Read More →Bandwidth is an innovator in the emergency services ecosystem and consistently meets the highest level of adherence to public safety standards. On behalf of our customers, we are an active and vocal 911 and public safety advocate within both industry groups and at the FCC.
Ray Baum described himself as “just a small-town lawyer” but he went on to serve in a number of important public roles at the state and federal levels in Oregon and in Washington D.C. over the course of his career. Ray was a Commissioner and Chairman of the Oregon Public Utilities Commission (PUC), served on the Board of Directors of the National Association of Regulatory Utility Commissioners (NARUC), and as the Chair of NARUC’s Committee on Telecommunications.
Ray Baum joined U.S. Representative Greg Walden’s staff as Staff Director on the Energy and Commerce Committee in December 2016. In this role in Congress, Ray worked closely with the FCC on telecommunications issues. Sadly, Ray Baum passed away in February of 2018 after a long battle with cancer. In recognition of his important contributions to the telecommunications industry, Representative Greg Walden arranged to have RAY BAUM’S Act named in his honor.
The language of Section 506 of RAY BAUM’S Act directed the FCC to conclude a proceeding aimed at improving MLTS dispatchable location information provided to public safety at the time of a 911 call. In the FCC’s proceeding that followed, it determined that dispatchable location includes a street address, but should also include more granular information such as building number, floor, suite, room, or other available relevant location information that can best assist emergency responders.
Both Kari’s Law and Section 506 of RAY BAUM’S Act deal with E911 regulations and MLTS. Kari’s Law has two requirements:
Kari’s Law (which went into effect on February 16, 2020) focuses on ensuring that end-users have the ability to make calls to emergency services by simply dialing the digits 9-1-1 in enterprise environments while also including a notification to the enterprise itself of the 911 emergency. Section 506 of RAY BAUM’S Act is concerned with the quality of the information that’s sent to public safety operators when the call is made. Together, they’re all about providing better, faster, more reliable access to emergency services when dialing 911.
First, we strongly urge impacted enterprises to speak with legal counsel for guidance with compliance. The best legal approach for any given enterprise may vary depending upon the nature of the services in question or the size and complexity of your organization.
Second, the provisioned emergency location information for your employees may need to be updated to include additional data such as building, floor number, suite, conference rooms, etc. to provide more granular location information. All provisioned emergency location information should be validated to ensure consistency with public safety address standards.
Third, you will need to plan for workers who may be using nomadic, non-fixed MLTS services such as softphone applications on a laptop or other mobile devices. Many companies we work with are transitioning away from traditional, fixed desktop phones. They will likely need to adjust how they manage their emergency location information to account for new nomadic communications services that commonly allow employees to work in the office and remotely.
Finally, endpoints need to be tested to ensure that the correct emergency location information will be conveyed to public safety during 911 calls. Such testing might ordinarily require contacting and coordinating with appropriate 911 call centers, but Bandwidth offers an easy to use alternative testing service (“933”). Bandwidth’s 933 testing service allows enterprises to test the emergency calling capabilities on their phones without actually dialing 911 (which may otherwise risk detracting resources from true emergencies).
Aspects of RAY BAUMS Act revolve around interconnected VoIP services. VoIP (Voice over Internet Protocol) is simply voice calling that utilizes advanced Internet Protocol technology rather than traditional analog technology and phone systems. Interconnected VoIP services are simply retail VoIP services that allow for the bidirectional exchange of voice communication traffic that includes the traditional telephone service networks (PSTN).
Fixed telephony, interconnected VoIP, Internet-based Telecommunications Relay Services (TRS), and mobile text service are all subject to FCC rules under Section 506 of RAY BAUM’s act.
