Compliance, E911, MLTS, and Phase 2 of RAY BAUM’S

Compliance, E911, MLTS, and Phase 2 of RAY BAUM’S

Phase 2 of Ray Baums

Phase 2 of RAY BAUM’S law is now in effect leaving many to ask, would first responders be able to find me in my office if I needed help?

Back in 2018, the House of Representatives passed a $1.3 Million omnibus appropriations bill that incorporated HR4986, or RAY BAUM’S (Repack Airwaves Yielding Better Access for Users of Modern Services) act into law.  The act, specifically section 506, required “dispatchable location” information to be passed along to first responders in the event of a 911 call being made from a business, specifically for multi-line telephone systems, fixed telephone services, interconnected VoIP services, telecommunications relay services, and mobile texting services.  There were two phases to the act with the first phase requiring the compliance of all fixed multi-line services and the second for non-fixed multi-line services.

Phase 2 of RAY BAUM’S Law Goes into Effect

As of January 6, 2022, the second and final phase of RAY BAUM’S went into effect and now includes non-fixed on-premise and off-premise phones as well.  This includes devices such as mobile phones, laptops, or tablets that have a mobile or softphone application that connects through the PBX to make and receive phone calls as well as the traditional desktop phone.  All PBX solutions must now be compliant with this law.

RAY BAUM’S Law Phase 2 and Compliance for MLTS

According to the law, the FCC must conclude their proceedings evaluating rules to ensure that the dispatchable location information of the caller (e.g. office number, suite number, room number, etc.) including multi-line telephone systems (MLTS), regardless of which technology platform the system utilizes.  All nomadic and non-fixed calling services must have established E911 compliance and due to the unique nature of these devices, they usually require a “dynamic location routing and additional provisioning of network elements such as a WiFi access point, switch, ports, and subnets to allow for the network to “know” where the phone is within the network as the device moves.”

The FCC breaks down the requirements on their site here.

  1. On-premises, non-fixed devices associated attached to an MLTS must automatically update the dispatchable location to the appropriate PSAP when this is technically feasible.  If not, the dispatchable location will be based on an end-user manual update.
  2. Alternative location information also may be coordinate-based, but it must be specific enough 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.)
  3. For off-premises devices associated with an MLTS, the network must automatically update the dispatchable location to the PSAP when technically feasible. If not, then the location must be updated based on the end-users manual update or coordinate-based with the best available location that can be provided.

Phase 2 of Ray Baums

MIX Networks Helps You Maintain Compliance With RAY BAUM’S Act

E911 Compliance can be complicated, but having a trusted advisor at your side can be the difference between staying compliant and not.  MIX Networks Hosted PBX and Unified Communications solution can assign a DID down to the room number, suite number, conference room, etc, to help your business meet the compliance needs for RAY BAUM.   Easy to use online dashboards can facilitate quick changes in E911 locations on the go.  Contact a specialist today and ensure your compliance now!

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