On August 1, 2019, the Commission adopted rules under Section 506 of RAY BAUM’S Act to ensure that “dispatchable location” information is conveyed with 911 calls so that first responders can more quickly locate the caller. Dispatchable location information includes the street address of the caller and additional information, such as room or floor number, necessary to adequately locate the caller.

These rules apply to the following 911-capable services: fixed telephony, interconnected Voice over Internet Protocol (VoIP) services, Internet-based Telecommunications Relay Services (TRS), and mobile text service.  The dispatchable location requirements for multi-line telephone systems (MLTS) and the 911 direct dialing and notification requirements for MLTS can be found on the MLTS web page.

These rules do not apply to wireless providers, who are subject to separate location accuracy requirements and benchmarks. Information on wireless 911 location accuracy requirements can be accessed on the Location Accuracy web page.

Dispatchable Location Requirements

The dispatchable location rules and compliance deadlines for fixed telephony, VoIP, TRS, and mobile text differ depending on the particular service and whether the device used to make the call is fixed or non-fixed. Fixed devices (e.g., wired telephones) cannot be readily moved from one location to another by the user, while non-fixed devices (also described as mobile or nomadic devices) can readily be moved by the user for use at multiple locations or while in motion.

Fixed devices The rules for fixed devices operating on fixed telephony, VoIP, or TRS require provision of automated dispatchable location with each 911 call, which means that the location information is generated automatically, without any action by the 911 caller when placing the call.

Non-fixed devices The rules for non-fixed VoIP, TRS, and mobile text devices require provision of automated dispatchable location with each 911 call if it is technically feasible.& If providing automated dispatchable location with a 911 call from a non-fixed device is not feasible, the rules allow provision of alternative location information. The requirements for alternative location information vary depending on the particular service:

  • For VoIP and TRS, 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.  These services also may provide the caller's Registered Location undder some circumstances."
  • Mobile text, enhanced location information also 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.

Compliance Deadlines

The effective date for the dispatchable location rules implementing Section 506 of RAY BAUM’S Act is January 6, 2020.  These rules establish different compliance deadlines for meeting the applicable dispatchable location requirements depending on whether the device originating the 911 call is fixed or non-fixed. Some of the rules implementing RAY BAUM’s Act contain information collection requirements that must be approved by the Office of Management and Budget (OMB).**  Once the Commission obtains OMB approval, the Commission will announce compliance dates for the information collection requirements and will provide updates on this web page.  To help regulated entities comply with the rules, the Public Safety and Homeland Security Bureau provides the following summary timeline of compliance deadlines for these requirements.***

Fixed Telephony Compliance Date

2021

  • Jan. 6, 2021
    • Providers of fixed telephony service must provide automated dispatchable location with 911 calls. 47 CFR § 9.8(a).)

Mobile Text Compliance Date

2022

  • Jan. 6, 2022
    • Covered text providers must provide automated dispatchable location with all 911 text messages routed to a public safety answering point (PSAP) if technically feasible; otherwise they must provide either end-user manual provision of location information, or enhanced location information that meets the requirements below.
      • Enhanced location:
        • 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 § 9.10(q)(10)(v).)

Interconnected VoIP Compliance Dates

2020

  • Jan. 6, 2020
    • Interconnected VoIP service providers (excluding outbound-only interconnected VoIP service providers) have the option of meeting the customer notification requirement at section 9.11(a)(5)(iii) of the rules by notifying existing subscribers, and each new subscriber prior to the initiation of that subscriber’s service, by conspicuous means other than warning stickers or labels if E911 service may be limited or not available. (47 CFR § 9.11(a)(5)(iii)(B).)

2021

  • Jan. 6, 2021
    • Providers of fixed interconnected VoIP services must provide automated dispatchable location with each 911 call.(47 CFR § 9.11(b)(4)(i).)

2022

  • Jan. 6, 2022
    • Providers of non-fixed interconnected VoIP services and providers of all outbound-only interconnected VoIP services must provide automated dispatchable location if technically feasible.  Otherwise, they must provide either Registered Location information or alternative location information that meets the requirements below. As a last resort, providers also may route the caller to a national emergency call center, so long as the provider has made a good-faith effort to obtain location data from all available alternative location sources. (47 CFR § 9.11(b)(4)(ii); see also Report and Order at paras. 182)
      • Registered Location:
        • The service provider has obtained from the customer, prior to the initiation of service, the Registered Location (as defined in section 9.3 of the rules) at which the service will first be used;
        • The service provider has provided end users one or more methods of updating their Registered Location, including at least one option that requires use only of the CPE necessary to access the interconnected VoIP service.  Any method used must allow an end user to update the Registered Location at will and in a timely manner; and
        • The service provider must identify whether the service is being used to call 911 from a different location than the Registered Location and, if so, either: (i) prompt the customer to provide a new Registered Location; or (ii) update the Registered Location without requiring additional action by the customer. (47 CFR § 9.11(b)(4)(ii)(B).)
      • Alternative location:
        • 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 §§ 9.11(b)(4)(ii)(C) and 9.3)
    • In addition to providing the location information above, providers of outbound-only interconnected VoIP must comply with all other 911 rules for interconnected VoIP providers as stated in section 9.11(b) of the rules.(47 CFR § 9.11(b).)

Telecommunications Relay Services (TRS) Compliance Dates

2021

  • Jan. 6, 2021
    • Providers of fixed Video Relay Service (VRS), Internet Protocol Relay Service (IP Relay), and Internet Protocol Captioned Telephone Service (IP CTS) must provide automated dispatchable location with each 911 call. (47 CFR §§ 9.14(d)(4)(i) and 9.14(e)(4)(i).)

2022

  • Jan. 6, 2022
    • Providers of non-fixed VRS and IP Relay must provide automated dispatchable location if technically feasible.  Otherwise, they must provide either Registered Location information or alternative location information that meets the requirements below.  As a last resort, providers also may route the caller to a call center, so long as the provider has made a good-faith effort to obtain location data from all available alternative location sources. (47 CFR § 9.14(d)(4)(ii); see also Report and Order at para. 215.)
      • Registered Location:
        • The service provider has obtained from the customer, prior to the initiation of service, the Registered Location (as defined in section 9.3 of the rules) at which the service will first be used;
        • The service provider has provided end users one or more methods of updating their Registered Location, including at least one option that requires use only of the Internet-based TRS access technology necessary to access the VRS or IP Relay.  Any method used must allow an end user to update the Registered Location at will and in a timely manner; and
        • If the VRS or IP Relay is capable of being used from more than one location and it is not possible to automatically determine the user’s location at the time of the initiation of an emergency call, the service provider must verify the current location with the user at the beginning of an emergency call. (47 CFR § 9.14(d)(4)(ii)(B).)
      • Alternative location:
        • 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 §§ 9.14(d)(4)(ii)(C) and 9.3)
           
    • Providers of non-fixed IP CTS must provide automated dispatchable location if technically feasible.  Otherwise, they must provide either Registered Location information or alternative location information that meets the requirements below, or they must route the caller to a call center. (47 CFR § 9.14(e)(4)(ii).)
      • Registered Location option for IP CTS:
        • The service provider has obtained from the customer, prior to the initiation of service, the Registered Location (as defined in section 9.3 of the rules) at which the service will first be used; and
        • The service provider has provided end users one or more methods of updating their Registered Location, including at least one option that requires use only of the Internet-based TRS access technology necessary to access the IP CTS.  Any method used must allow an end user to update the Registered Location at will and in a timely manner. (47 CFR § 9.14(e)(4)(ii)(B).)
      • Alternative location option for IP CTS:
        • 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 §§ 9.14(e)(4)(ii)(C) and 9.3.)

*This timeline does not reference all of the relevant rules, does not include the full text of the rules, and does not replace or supersede the rules.  Although the Bureau has attempted to cover all parts of the rules that might be relevant, the coverage may not be exhaustive, and the timeline may not anticipate all situations in which the rules apply.  The timeline represents the Bureau’s interpretation of the rules and is not legally binding on the Commission.  Furthermore, 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 full text of the 911 rules can be found here.

**The new rules became effective on January 6, 2020, although the compliance deadlines for the rules vary.  In addition, Sections 9.8(a); 9.10(q)(10)(v); 9.11(b)(2)(ii), (iv); 9.11(b)(4); 9.11(b)(5)(ii), (iii); 9.14(d)(2)(ii), (iii), and (v); 9.14(d)(4); 9.14(e)(2)(ii), (iv); 9.14(e)(4) 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.

***For Multi-Line Telephone System (MLTS) direct dialing and notification rules, see the MLTS web page.

Resources

911 Regulations 47 C.F.R. Part 9

911 Dispatchable Location Rules

Fixed telephony – 47 C.F.R. § 9.8

Mobile text – 47 C.F.R. § 9.10(q)

Interconnected VoIP – 47 C.F.R. §§ 9.11, 9.12

TRS – 47 C.F.R. §§ 9.13, 9.14

MLTS – 47 C.F.R. §§ 9.15, 9.16, 9.17

Small Entity Compliance Guidehttps://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 the Bureau of problems or issues affecting the provision of emergency services through the Public Safety Support Center.

 

Archive

Report and Order – Implementing Kari’s Law and Section 506 of RAY BAUM’S Act (Aug. 1, 2019)

Erratum – Implementing Kari's Law and Section 506 of RAY BAUM'S Act (PSHSB Dec. 2, 2019)

Public Notice – Announcing Jan. 6, 2020 Effective Date for Rules Implementing Kari’s Law and Section 506 of RAY BAUM’S Act (PSHSB Dec. 5, 2019)

Notice of Proposed Rulemaking – Implementing Kari’s Law and Section 506 of RAY BAUM’S Act (Oct. 26, 2018)

Notice of Inquiry – FCC to Examine 911 Capabilities of Enterprise Communications Systems (Sept. 26, 2017)

 

Updated: 
Wednesday, April 22, 2020