Sending location automatically for 911 calls – January 2022 deadline

If you sell UCaaS / Hosted PBX services there’s an important deadline coming up in about 6 weeks. By January 6, 2022 all 911 calls (including those from software-based SIP clients), need to have accurate location information – even if someone picks up their laptop, walks to Starbucks, then dials 911 on their laptop’s software client.

Are you ready?

Ray Baum’s Act Requirements

Before, we start, I should emphasize that I’m not a lawyer. The advice in this article is based on information gathered from a range of other sources (mostly linked below), and you should do your own research to make sure you comply with the regulations.

You may be familiar with Kari’s Law, which aimed to make it easier for 911 calls to be completed from offices and hotels, and included changes to dial plans and notifications to the security desk if someone dialed 911.

Ray Baum’s Act also aims to reduce the risk of ineffective 911 responses with a focus on dispatchable location – i.e. making sure that the 911 dispatcher has location information that is specific enough to get help.

Dispatchable location is defined 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.”

There’s a full list of the FCC requirements here, but starting January 6, 2021 (last year) service providers needed to be able to provide a dispatchable location for “on-premise, fixed devices” (i.e. physical phones). From what I’ve seen, most people handled this as a database exercise – making sure that businesses had the ability to update their 911 ALI database locations with specific locations, and encouraging them to do so.

Obviously that deadline has already passed, and hopefully anyone impacted has already addressed those requirements. So why are we talking about this again now?

Starting January 6, 2022, the regulations are expanded to “non-fixed” devices – both on-premise and off-premise. That same FCC link provides more details, but in general terms that means that any phone client (including a soft-phone) must provide automated dispatchable location when a 911 call is made – or else must provide dispatchable location by prompting the user to enter their location.

You would be forgiven for asking, “How on earth are we supposed to do that?!”

Automated Dispatchable Location – how could it work?

I’m first going to lay out where we’re headed from an technical architecture point-of-view, and then we’ll talk about today’s reality.

At a high-level, for automated dispatchable location to work, we need a few things:

• Next Generation 911 (NG911) infrastructure where the PSAPs can process dispatchable locations and cope with locations outside their immediate service area. Most of our clients who are selling UCaaS as a CLEC are integrated with someone like Intrado, Bandwidth or Inteliquent for 911. These providers can typically accept a 911 call for any US location, and deliver the call to the appropriate PSAP based on the location information they have on file.
• Core network infrastructure that can process the new SIP headers for emergency calls, including the XML-based PIDF-LO information from RFC 3693.
• Software based SIP clients that can either discover their location automatically, or else prompt the user to enter it manually.
• Some kind of infrastructure to help the SIP clients automatically discover their location.

How close are we to having this working today?

We work mostly with service providers running Metaswitch products, so I’m going to focus on that scenario – and actually we’re pretty close to meeting the requirements, although the timeline is very tight. Let’s look at each of the pieces in turn.

1. The big nationwide 911 SIP providers already provide the ability for the location (ALI) database to be updated. Metaswitch has an integration with Intrado built into CommPortal for end-users, and it’s possible to do a similar integration with Bandwidth using their APIs. You can read more about the offerings from Intrado and Inteliquent and Bandwidth recently presented a webinar on this topic.
2. Metaswitch recently announced support for PIDF-LO (passing the correct SIP headers, and interop settings to configure whether geo-location can be trusted from different end-points) in V9.6.30 of the CFS. If you have access to their private Metaswitch Communities website you can read more here.
3. If you’re offering the Metaswitch MaxUC clients (desktop or tablet/mobile) to your subscribers, I’m reliably informed that there’s a software update coming soon (January 4, 2022) that will gather the location information from the network where possible, and will prompt the user if they move their client to an unrecognized location.
4. There are a variety of different ways that location information could be provided to the SIP clients. Metaswitch is planning to allow Business Group Administrators (end-user admins) to associate IP address ranges with dispatchable locations through CommPortal – which will allow automatic location discovery when the soft-client is on-premise. (This can also be done by the service provider through MetaView Web.) I know that there are also technologies that allow software to identify location from WiFi access points (e.g. a DHCP option that allows an IT administrator to configure locations into the IP network and then allow devices to find it through DHCP).

While the focus for the January 6, 2022 deadline is on non-fixed devices, it’s obviously possible for IP business phones to move location too, and I know that Poly (for example) supports a variety of methods for allowing the phones to automatically determine their dispatchable location (including LLDP-MED, DHCP Option 99, manual phone configuration and RFC 5985 based LIS/HELD databases).

Automated Dispatchable Location – Next Steps

I know that’s a lot of information, so let’s try to summarize the key steps you need to take.

1. Make sure that the 911 ALI (Automatic Location Information) database has specific dispatchable locations for each of the DNs you provide – and make sure you have a way for subscribers to update that information if they could move their phones around.
2. Make sure you’re talking to your vendors about the necessary software upgrades to support passing the location information to the SIP 911 trunks AND for finding the information in the first place (on the SIP endpoints).
3. Make sure you have a plan in place where your business customers can administer their dispatchable locations – ideally in a way that allows the SIP endpoints to automatically identify their location and signal it on the SIP INVITE.

Further Information

• FCC Report and Order on Ray Baum’s Act.
• Cloud Communications Alliance webinar (with Mark Lindsey of ECG): video and slides
• Metaswitch Communities article on Kari’s Law and Ray Baum’s Act.