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How To Comply with RAY BAUM's Act

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If you are not aware already, the FCC adopted a Report and Order on August 1, 2019 that affects all businesses nationwide.  The Report and Order specifies rules for both Kari's Law and Section 506 of RAY BAUM's Act.  We discussed Kari's Law last week, which you can read about here.  This week we will delve into what actions your business must take in order to comply with the new rules outlined in Section 506 of RAY BAUM's Act.  

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The new regulations embody the original goals E911 sought to accomplish.  Primarily created in order to more accurately locate 9-1-1 callers, the FCC has been working to incorporate E911 into all communication systems nationwide.  This most recent Report and Order attempts to do exactly that by ensuring all MLTS phones automatically provide the Public Safety Answering Point with a “dispatchable location” of the caller. 

In environments such as campuses, sprawling warehouses, multi-floor buildings, and hotels it can be exceedingly difficult to find a person in distress, especially if the caller is unable to speak.  If a communication system can automatically provide the PSAP a “dispatchable location”, the dispatcher can more efficiently and effectively guide first responders to the site of emergency.  

We understand that you will have questions about what “dispatchable location” means for your enterprise, as well as how you will incorporate this ability into your existing communication system.  We are here to help, and below we will outline the highlights of what your business needs to know in order to comply with this new legislation.  


The Official Rulings

“Dispatchable Location” Definition

The official definition of “dispatchable location” reads as follows: “Section 506 of RAY BAUM'S Act defines “dispatchable location” as “the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location of the calling party ((Federal Communications Commission. (2019))”. 


Fixed MLTS Calls

Rule: “We therefore conclude that providing dispatchable location for 911 calls from fixed MLTS devices used on-premises is readily achievable.  We also conclude that dispatchable location from fixed MLTS devices should be provided automatically and that the street address associated with the fixed end-point should be validated  ((Federal Communications Commission. (2019))”.

Timeframe: “We conclude that a one-year timeframe is more reasonable to ensure timely implementation while affording affected parties reasonable time to take the necessary steps to come into compliance  ((Federal Communications Commission. (2019))”.


Non-Fixed MLTS Calls

Rule: “MLTS providers must convey automated dispatchable location for such devices when technically feasible but may rely on the MLTS end user to provide or confirm dispatchable location information manually, e.g., by responding to a system prompt ((Federal Communications Commission. (2019))”.

Timeframe: “These requirements will take effect two years from the effective date of rules adopted in this order ((Federal Communications Commission. (2019))”.


Off-Premise 911 Calls

Rule: “For off-premises 911 calls, the MLTS operator or manager must provide (1) dispatchable location, if technically feasible, or, otherwise, either 2) manually-updated dispatchable location, or (3) enhanced location information, which may be coordinate-based, consisting of the best available location that can be obtained from any available technology or combination of technologies at reasonable cost ((Federal Communications Commission. (2019))”.

Timeframe: “This requirement will take effect two years from the effective date of rules adopted by this order ((Federal Communications Commission. (2019))”. 


What Does This Mean For Me?

If you are a business, you need to begin thinking about an E911 solution that provides a “dispatchable location” to the PSAP with every 9-1-1 call.  This means that whenever someone dials 9-1-1 with any phone in your enterprise's network, whether it be from a hard or soft phone, the PSAP must automatically receive the location of that caller.  Furthermore, the location delivered to the PSAP must provide enough granularity for first responders to adequately locate the caller. Meaning, if your company is located in a multi-floor building you need an E911 solution that provides the PSAP with address, floor, suite, etc.  While the timeframe varies depending on device type, the trend toward mobility is inevitable and having a solution in place that encompasses your remote workers will keep your business compliant and future-proof. 

Where Do I Go From Here? 

We are here to help your enterprise comply with these new regulations set for RAY BAUM's Act.  Our cloud-based technology not only reduces critical time in locating a person who has dialed 9-1-1, but it also allows your enterprise to embrace mobility without risk.  Our E911 solutions provide a “dispatchable location” for all your enterprise's devices, regardless of where you travel with them.  Our technology anticipated the trend toward mobility, and we have created our solutions to automatically update a device's location.  We work to make the path to compliance and E911 as easy for your enterprise as possible.  

If you have further questions about the RAY BAUM's Act, “dispatchable location”, or cloud-based solutions for your enterprise, read more here.


Federal Communications Commission. (2019) Implementing Kari's Law and Section 506 of RAY BAUM'S Act, 911 Access, Routing, and Location in Enterprise Communications Systems, Amending the Definition of Interconnected VoIP Service in Section 9.3 of the Commission's Rules. (Report No. FCC-19-76). Retrieved from


We are not lawyers; these are our opinions.  However, we are experts in E911 and this Report and Order falls within the parameters of our expertise.  

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