In 2018, the U.S. Congress passed the Consolidated Appropriations Act in 2018 (H.R. 1625), which included an amended version of the Repack Airwaves Yielding Better Access for Users of Modern Services (RAY BAUM’S) Act of 2018 (H.R. 4986). Also, on August 2, 2019, the FCC released a report and order adopting 911 requirements for multi-line telephone systems (MLTS) related to two federal statutes, Kari’s Law and RAY BAUM’s Act.
RAY BAUM requires telecom service providers to provide their customers with the ability to update their Automatic Location Identification (ALI) street address, with enhanced location data for 911 dispatch usage. This is called dispatchable location, which is 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.
Cox Business Implementation Dates
RAY BAUM Act defines calls as falling into three types: fixed, non-fixed, and off-premise. Service providers were given the following timeline for implementation.
- January 6th, 2021: Fixed, which means calls originate from IP Centrex non-teleworker phones, VoiceManager lines, or from a customer PBX via a SIP or PRI trunk. These are services delivered by the Cox Voice access network. Cox Business has a plan in place to provide our customers with the capability to enter dispatchable location data associated with their fixed multiline service.
- January 6th, 2022: Non-fixed, which means calls originate from Teleworker IPC phones or the UC desktop and tablet applications via a WiFi or OTT connection. Cox is assessing options to comply with the non-fixed requirement and will also continue to assess industry developments to comply for non-fixed services. For off-premise calls, also known as cellular-based, Cox will rely on mobile carriers to route 911 traffic, as necessary.
Impacted Cox Business Services
In general, when an E911 call is placed by a user of a commercial Voice service, street location data is transmitted to the 911 operator, also known as the Public Safety Answering Point (PSAP). Street location data for customers is stored in industry-wide databases, known as ALI databases or ALI Records.
- All Cox Business Voice customers have 911 calling capabilities and 911 calling options included.
- Some Voice customers may subscribe to a National 911 for DIDs service to support address updates for one or more DIDs. However, this is limited to a certain population, including customers who operate their own PBX and use SIP or PRI trunking products.
- Often, the street location is not enough to find the calling party in need of emergency services. This is especially true for medium to large business environments. Emergency teams show up to the main location but must be directed further, within a building, campus, or other physical layout. This delays response to reach a 911 caller and increases risk for the business.
All Cox Business Voice customers should prioritize testing 911 call routing from all telephone numbers used at your service location.
PBX or a Phone System Users
For our customers using Cox Business SIP, PRI, or T1-CAS Trunks and using a phone or PBX system, the FCC classifies them as a Multi-Line Phone System (MLTS) owner or operator. As an MLTS owner/operations, our customers must also comply with the FCC rules for both Kari’s Law and RAY BAUM’S Act or risk possible enforcement action by the FCC.
Under Kari’s Law regulations, you must ensure the following occurs when a phone user dials 911.
- All phone users must be able to dial 911 without requiring extra digits
- A notification is sent to a central location whenever someone at your business calls 911
RAY BAUM’S Act requires that no later than January 6, 2021, you must provide the dispatchable location, also known as a verified street address, plus additional information such as floor or suite number, for fixed on-premises 911 calls. Learn more about FCC regulations at bit.ly/fccreference.
SIP or PRI Trunks Users
For our customers with SIP or PRI trunks delivered to a fixed location, update 911 ALI information directly in MyAccount, for the main phone number, also referred to as main trunk BTN. Because some of our customers may be located on a campus, spread out among several buildings, or have multiple locations, you can order a quantity of National 911 for DIDs licenses to update ALI addresses for 1 or more DIDs used on the trunk.
National 911 for DIDs Service and Capabilities
To update ALI addresses for one or more DIDs on a trunk, you should order National 911 for DIDs, which is sold at a monthly rate per DID. Learn about using National 911 for DIDs with the following example customer scenario.
- A Cox Business customer needs to update ALI address information for 20 DIDs, so the customer orders 20 licenses of National 911 for DIDs.
- After provisioning, the customer uses MyAccount to update each address individually, or to edit and upload a .CSV file of the addresses.
- After the addresses are added to the 911 databases, then the customer can test their 911 calling with their local authorities.
Note: For our customers with trunks who currently subscribe to Emergency Locator Services (ELS), Cox Business is updating you from ELS to National 911 for DIDs, with the same billed units and existing rates. You will see a line item name change on your bill and then gain access to manage 911 capabilities in MyAccount.
Managing Your 911 Features
Learn how you can update your 911 features and set up to receive 911-related notifications based on your Voice services below.
- If you use VoiceManager lines or IP Centrex seats, then you can use MyAccount to manage and update Dispatchable Location Information for your phone numbers.
- If you use SIP, PRI, or T1-CAS trunks, then you can use MyAccount to manage and update Dispatchable Location Information for a BTN of a fixed location.
- If you use SIP, PRI, or T1-CAS trunks and you need to update address information for 1 or more DIDs, then you can order National 911 for DIDs service to manage and update 911 address details for one or more trunk DIDs.
- Customers can use MyAccount to configure text and email notification for 911 calls.
For More Help With 911
Contact your Cox Business Sales Engineer with questions related to 911 services, RAY BAUM, Kari’s Law, Emergency Locator Services, or National 911 for DIDs.
For more information about the Cox Business Terms and Conditions for E911 responsibilities, usage, and operations, go to www.coxbusiness.com/e911.
