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RAY BAUM'S Act – Dispatchable Location for MLTS

RAY BAUM'S Act

The RAY BAUM'S Act is named in honor of Ray Baum, a telecommunications champion and longtime friend of Energy and Commerce Committee GOP Leader Greg Walden (R-OR). Baum is an Oregon native who devoted his career to public service, serving as a commissioner and chair of the Oregon Public Utilities Commission (PUC), on the board of directors of the National Association of Regulatory Utility Commissioners (NARUC), and as chair of NARUC's Committee on Telecommunications. He joined then-Energy and Commerce Telecommunications and the Internet Subcommittee Chairman Walden's team as senior policy advisor, and then as staff director of the full committee under then-E&C Chairman Walden. He sadly lost his battle with cancer in February 2018.

RAY BAUM'S Act

Under Section 506 of RAY BAUM'S Act, the Commission has adopted rules to ensure that "dispatchable location" is conveyed with 911 calls to dispatch centers, regardless of the technological platform used, including 911 calls from MLTS. Dispatchable location means a location delivered to the PSAP with a 911 call that consists of the validated street address of the calling party, plus additional information such as suite, apartment, or similar information necessary to adequately identify the location of the calling party. (47 CFR § 9.3.) For further information on dispatchable location requirements applicable to non-MLTS, including compliance timelines, see the Dispatchable Location web page.

Compliance Dates (MLTS Dispatchable Location): The Commission's dispatchable location rules for MLTS apply to all MLTS that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020. While the dispatchable location rules apply to the same entities subject to Kari's Law, the Commission established separate deadlines for MLTS to come into compliance with the dispatchable location rules. As outlined below, MLTS are subject to compliance deadlines of January 6, 2021 and January 6, 2022, depending on the nature of the device from which the MLTS 911 call originates.*

2021

Jan. 6, 2021

Provision of dispatchable location from MLTS on-premises, fixed devices:

  • On-premises, fixed devices associated with an MLTS must provide automated dispatchable location with 911 calls. (47 CFR § 9.16(b)(3)(i).)
Dispatchable location obligations for MLTS manufacturers, importers, sellers, lessors, installers, managers, and operators:

  • MLTS manufacturers, importers, sellers, and lessors may not manufacture, import, sell, lease, or offer to sell or lease an MLTS unless the system has the capability, after proper installation in accordance with the rules, of providing the automated dispatchable location of the caller to the PSAP with 911 calls from on-premises, fixed devices. (47 CFR §§ 9.16(a)(2) and 9.16(b)(3)(i).)
  • MLTS installers may not install a system unless it is configured so that it is capable of being programmed with and conveying the automated dispatchable location of the caller to the PSAP with 911 calls from on-premises, fixed devices. (47 CFR § 9.16(b)(3)(i).)
  • MLTS managers and operators may not manage or operate a system unless it is configured so that the automated dispatchable location of the caller is conveyed to the PSAP with 911 calls from on-premises, fixed devices. (47 CFR § 9.16(b)(3)(i).)
2022

Jan. 6, 2022

Provision of dispatchable location or alternative location information from MLTS on-premises, non-fixed devices and off-premises devices:

  • On-premises, non-fixed devices associated with an MLTS must provide automated dispatchable location to the appropriate PSAP when technically feasible; otherwise they must provide either dispatchable location based on end-user manual update, or alternative location information that meets the requirements below.
Alternative location option for MLTS on-premises, non-fixed devices:

  • Alternative location information may be coordinate-based, and it must be sufficient to identify the caller's civic address and approximate in-building location, including floor level, in large buildings. (47 CFR §§ 9.16(b)(3)(ii) and 9.3.)
  • Off-premises devices associated with an MLTS must provide to the appropriate PSAP automated dispatchable location if technically feasible; otherwise, they must provide either dispatchable location based on end user manual update, or enhanced location information that meets the requirements below.
Enhanced location option for MLTS off-premises devices:

  • Enhanced location information may be coordinate-based, and it must consist of the best available location that can be obtained from any available technology or combination of technologies at reasonable cost. (47 CFR § 9.16(b)(3)(iii).)
Dispatchable location obligations for MLTS manufacturers, importers, sellers, lessors, installers, managers, and operators:

  • MLTS manufacturers, importers, sellers, and lessors may not manufacture, import, sell, lease, or offer to sell or lease an MLTS unless the system has the capability, after proper installation in accordance with the rules, of providing the dispatchable location of the caller as specified in section 9.16(b)(3)(ii) and (iii) to the PSAP with 911 calls from on-premises, non-fixed devices and from off-premises devices. (47 CFR §§ 9.16(a)(2) and 9.16(b)(3)(ii), (iii).)
  • MLTS installers may not install an MLTS unless it is configured so that it is capable of being programmed with and conveying the dispatchable location of the caller as specified in section 9.16(b)(3)(ii) and (iii) to the PSAP with 911 calls from on-premises, non-fixed devices and from off-premises devices. (47 CFR § 9.16(b)(3)(ii), (iii).)
  • MLTS managers and operators may not manage or operate an MLTS unless it is configured so that the dispatchable location of the caller as specified in section 9.16(b)(3)(ii) and (iii) is conveyed to the PSAP with 911 calls from on-premises, non-fixed devices and from off-premises devices. (47 CFR § 9.16(b)(3)(ii), (iii).)
*The Public Safety and Homeland Security Bureau is providing the above timeline to help regulated entities comply with the rules. This timeline does not reference all of the relevant rules, does not include the full text of the rules, and does not modify or supersede the specific text of any rule that is referenced. The Commission retains the discretion to adopt case-by-case approaches, where appropriate, that may differ from the approach in this timeline. Any decision regarding a particular regulated entity will be based on the statutes and any relevant rules.

**The new rules became effective on January 6, 2020, although the compliance deadlines for the rules vary. In addition, Sections 9.16(b)(3)(i), (ii), and (iii) of the rules contain information collections under the Paperwork Reduction Act (PRA). Compliance with these sections will not be required until after the relevant information collections are approved by the Office of Management and Budget. Following such approval, the Commission will publish a document in the Federal Register announcing the compliance dates for these requirements and will update this timeline as necessary to reflect these dates.

Resources

911 Requirements for MLTS – 47 C.F.R. Part 9, Subpart F

Frequently Asked Questions - MLTS FAQs

Small Entity Compliance Guide: https://www.fcc.gov/document/implementing-karis-law-and-section-506-ray-baums-act-0

The FCC will closely monitor any complaints about alleged violations of these 911 rules.

  • Public Safety Answering Points (PSAPs), also known as 911 call centers, and other public safety entities may request support from the Public Safety and Homeland Security Bureau and notify it of problems or issues affecting the provision of emergency services through the Public Safety Support Center.

Frequently Asked Questions

What is RAY BAUM'S Act?
Under Section 506 of RAY BAUM'S Act, the Commission has adopted rules to ensure that "dispatchable location" is conveyed with 911 calls to dispatch centers, regardless of the technological platform used, including 911 calls from MLTS. Dispatchable location means a location delivered to the PSAP with a 911 call that consists of the validated street address of the calling party, plus additional information such as suite, apartment, or similar information necessary to adequately identify the location of the calling party.

Compliance Dates (MLTS Dispatchable Location): The Commission's dispatchable location rules for MLTS apply to all MLTS that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020. While the dispatchable location rules apply to the same entities subject to Kari's Law, the Commission established separate deadlines for MLTS to come into compliance with the dispatchable location rules. As outlined below, MLTS are subject to compliance deadlines of January 6, 2021 and January 6, 2022, depending on the nature of the device from which the MLTS 911 call originates.*
When Does RAY BAUM'S Act Go Into Affect?
  • RAY BAUM'S compliance date started on January 6, 2021 for provision of dispatchable location from MLTS on-premises, fixed devices.
  • RAY BAUM'S compliance date starts on January 6, 2022 for provision of dispatchable location or alternative location information from MLTS on-premises, non-fixed devices and off-premises devices.

Who Does RAY BAUM'S Act Apply To?
Any large scale enterprise that utilizes a MLTS, like a public school, office building, hotel, or college campus. Telecom and VoIP companies who provide MLTS utilities to these customers also have to comply with RAY BAUM'S Act.
What RAY BAUM'S Act Affect?
Systems manufactured, imported, updated, sold or leased, or installed after February 16, 2020.
What RAY BAUM'S Act Require?
  • Provision of dispatchable location from MLTS on-premises, fixed devices by the RAY BAUM'S Act compliance date of January 6, 2021
  • Provision of dispatchable location or alternative location information from MLTS on-premises, non-fixed devices and off-premises devices by the RAY BAUM'S Act compliance date of January 6, 2022.
What Does RAY BAUM'S Act Have To Do With Call Location?
In addition to guaranteeing that anyone can direct dial 9-1-1 for help, Kari's Law, as well as the Ray Baum Act, aim to ensure that anyone calling 9-1-1 will be able to be found, no matter where they're calling from.

As we know, VoIP and mobile phones don't have a local address attached when they call 9-1-1, like a landline phone would, so it makes identifying the location of a call dependent on verbally relayed information. During an emergency, a caller might not know where they are, or be able to provide enough specific context to be easily found by first responders.

Kari's Law was passed alongside the Ray Baum Act to ensure that a dispatchable location is sent along to an Emergency Communications Center (ECC) when 9-1-1 is dialed through an MLTS, so that first responders will be better able to find callers in need.
How Will RAY BAUM'S Act Change Public Safety?
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).

Whether they're school kids, travelers, office employees, or hotel workers, Kari's Law will not only avert any confusion they might experience in an emergency, it will help send accurate location data along to first responders.

Having access to precise location data revolutionizes our approach to public safety. First responders will save time searching for callers, and can instead focus their efforts on getting to the scene as fast as possible. Considering how many lives are lost each year because first responders couldn't find who they were trying to help, having access to this data will undoubtedly cut that number down.
It's OUR business to keep YOUR 911 In Compliance.
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