RAY BAUM’s Act Compliance

Ray Baum described himself as “just a small-town lawyer” but he went on to serve in a number of important public roles at the state and federal levels in Oregon and in Washington D.C. over the course of his career. Ray was a Commissioner and Chairman of the Oregon Public Utilities Commission (PUC), served on the Board of Directors of the National Association of Regulatory Utility Commissioners (NARUC), and as the Chair of NARUC’s Committee on Telecommunications.

Ray Baum joined U.S. Representative Greg Walden’s staff as Staff Director on the Energy and Commerce Committee in December 2016. In this role in Congress, Ray worked closely with the FCC on telecommunications issues. Sadly, Ray Baum passed away in February of 2018 after a long battle with cancer. In recognition of his important contributions to the telecommunications industry, Representative Greg Walden arranged to have RAY BAUM’S Act named in his honor.

The language of Section 506 of RAY BAUM’S Act directed the FCC to conclude a proceeding aimed at improving MLTS dispatchable location information provided to public safety at the time of a 911 call. In the FCC’s proceeding that followed, it determined that dispatchable location includes a street address, but should also include more granular information such as building number, floor, suite, room, or other available relevant location information that can best assist emergency responders.

Both Kari’s Law and Section 506 of RAY BAUM’S Act deal with E911 regulations and MLTS. Kari’s Law has two requirements:

Eliminates any requirement that a prefix or digit (such as 8 or 9) be used to access an outside line allowing for direct dialing of 911.
Designated personnel (e.g., a security team or front desk attendant) must be notified that a 911 call has been placed.
Kari’s Law (which went into effect on February 16, 2020) focuses on ensuring that end-users have the ability to make calls to emergency services by simply dialing the digits 9-1-1 in enterprise environments while also including a notification to the enterprise itself of the 911 emergency. Section 506 of RAY BAUM’S Act is concerned with the quality of the information that’s sent to public safety operators when the call is made. Together, they’re all about providing better, faster, more reliable access to emergency services when dialing 911.

First, we strongly urge impacted enterprises to speak with legal counsel for guidance with compliance. The best legal approach for any given enterprise may vary depending upon the nature of the services in question or the size and complexity of your organization.

Second, the provisioned emergency location information for your employees may need to be updated to include additional data such as building, floor number, suite, conference rooms, etc. to provide more granular location information. All provisioned emergency location information should be validated to ensure consistency with public safety address standards.

Third, you will need to plan for workers who may be using nomadic, non-fixed MLTS services such as softphone applications on a laptop or other mobile devices. Many companies we work with are transitioning away from traditional, fixed desktop phones. They will likely need to adjust how they manage their emergency location information to account for new nomadic communications services that commonly allow employees to work in the office and remotely.

Finally, endpoints need to be tested to ensure that the correct emergency location information will be conveyed to public safety during 911 calls. Such testing might ordinarily require contacting and coordinating with appropriate 911 call centers, but Bandwidth offers an easy to use alternative testing service (“933”). Bandwidth’s 933 testing service allows enterprises to test the emergency calling capabilities on their phones without actually dialing 911 (which may otherwise risk detracting resources from true emergencies).

Aspects of RAY BAUMS Act revolve around interconnected VoIP services. VoIP (Voice over Internet Protocol) is simply voice calling that utilizes advanced Internet Protocol technology rather than traditional analog technology and phone systems. Interconnected VoIP services are simply retail VoIP services that allow for the bidirectional exchange of voice communication traffic that includes the traditional telephone service networks (PSTN).

Fixed telephony, interconnected VoIP, Internet-based Telecommunications Relay Services (TRS), and mobile text service are all subject to FCC rules under Section 506 of RAY BAUM’s act.