E911: Ray Baum provisions. Does anybody know if anyone checks?

Do Code Compliance Officers or anyone else check that a phone system is compliant? The penalties are steep and compliance is not that difficult but I know of resellers who do not implement whatsoever.
Just curious

Well the short answer is FAAFO(Engage in speculative ventures at your own risk)

The slightly longer answer is you don’t want to be the reason someone dies, if they dial 911 and you aren’t compliant it will become clear. It is better to be compliant.

I suppose a good question would be why wouldn’t you want to be compliant? I can’t think of a good reason to not be.


Absolutely James, but there seem to be no building codes or municipal requirements. I spoke with a Project Manager friend today about the phone system they were putting into a luxury condo development. Each of the several towers will have a phone number, but that’s all. He kind of shrugged when I asked him about 911; there was nothing in the specifications other than the elevators required copper because of the city he told me.
All that the phone provider asked for was the extension number scheme and the names to assign to each unit.

No one is doing copper anymore. The elevator needs copper is a fallacy. As for the 911 stuff, we should see new rules this year about not only notifying PSAPs you cover during an outage bit reporting to the FCC and/or other bodies for carriers.

But hey, that 10K fine to the PBX admin for not being in compliance is worth the risk, right?

First idea: take them on as a client.

Then, you might suggest something like populating the second address line with specifics eg. “Room 777” or “N Floor 2”, which is usually not that hard to do when ordering the lines but might take some persistence, multiple calls, etc. – so that is your time spent and how you organize the pricing for such consulting is up to you.

It is not clear whether this is a:

or a:

…although we should perhaps assume that by OP posting in the FreePBX forums that it is the former.

This is a requirement not a suggestion. If the condo is number 4 on floor 2, the 911 location requires that information. It’s not optional.

It’s clear, the OP made it clear in their second post. It’s a phone system for a condo complex, it 100% requires Kari’s Law/Ray Baum compliance.

That covers Registered location information but Alternative location information is also a thing. IANAL but either choice appears to be acceptable to meet the requirements.

For the simple “registered” case you describe, it is agreed that something like “FLOOR 2 UNIT 4” might be sufficient. Yet, consider the situation of a more open floor plan, where the “alternative” case allows using X-Y-Z co-ordinates eg. GPS+height/depth, which does not require any specific prior knowledge of the building by outside vendors of emergency services eg. ambulance drivers looking to park near the closest door of a city-block size complex with multiple entrances.

So “it depends” is probably the most correct answer, given the limited details provided by OP.

Clarity from OP would help in regards to who is providing telephones and outbound dial tone, if any, to the individual units. Generally, though, and again IANAL, but No tones or phones = No rules.

From OP’s second post:

Asking for names, units and extensions could be part of a scheme to allow visitors dial-by-name access via the directory system at the entrance(s) and then forwarding those buzzer-request calls to cell phones but not necessarily part of providing guests/residents/staff with PSTN access. Maybe it makes it easier for future remote programming to not have to dig back into the on-prem units by forwarding all the business logic elsewhere ? Or it could be the information that they are feeding to the telco to help with provisioning direct telco services on a unit-by-unit basis ?

Lots of questions…

Anyhow, considering the scope of “several towers” described in OP’s 2nd post, it stands to reason that there is some sort of on-site security team, probably staffed 24x7. If this is the case, then they should arguably be involved immediately in any emergency calling situation, preferably with a conference call between themselves, the original caller, and the remote dispatcher, as they are often trained (and paid!) to help and hold lots of knowledge about the local landscape. (Bringing this post back on-topic now with a slight aside/plug for the recent release of Always Be Conferencing v21n which is some free libre dial plan for Asterisk and includes examples for FreePBX to try and make these types of conference calls more accessible.)

I’m involved in a development project, there is a Master Technology Vendor and I am a vendor for something unrelated to phones. The Master Tech Vendor outsources to this phone vendor.
We have a monthly meeting of all the Tech vendors and Project Mangers to handle overlap.
During the last gathering, there was back and forth between Phone Vendor and PMs about the MLTS/VOIP System for common areas and management, etc and he didn’t want to be pinned down about extension names and numbers which I thought was strange.
Out of sheer curiosity, I asked a PM beside me how the project was handling E911 his reply was it had not been discussed.
I explained that a multi-building/multi-story project should have extensive preparation for compliance and wrote down “Kari’s Law/Ray Baum” at which point he asked about this to the whole meeting.
After a moment, the Vendor asked what did they need from him concerning Kari’s Law/Ray Baum.
The PM asked what he (the phone vendor) needed for the project to be compliant.
Below is the Vendor’s verbatim reply:
“Okay, got it. We are compliant, you can dial 911 from the phones and we will need the physical address where each phone resides.”
That’s where it ended.
My spidey sense started really tingling…
Later outside the meeting, I asked a different PM about another (smaller) project that the vendor that provides phone service to what info they had supplied for that and he told me that it had never come up.
That’s why I posted my question
Oh and each building has a single DID so unless they are using ClearlyIP’s solution I’m at a loss as to how they are handling this. @BlazeStudios You have another method, correct?

OK so we now need some more clarity. What is the phone system actually being used for? Is it to give each residence home phone service? Because a single DID per building that has multiple condos and tenants doesn’t seem right.

So is this for internal communications between condo management/staff and the residence? OR is this to supply each residence with home phone service?

This is the phone system for the operation of the building.
Management offices, Valet, Gym, Bars, Gate Etc if that answers your question

Well if the actual condo residents won’t have phone service on the PBX, that makes it a bit easer. But each phone on the PBX that can dial 911 needs proper registration.

That means if the there is a Valet station at each building and each building is just 1, 2, 3, 4 for their marker…you need to include BLDG 1 in the address. You need specific location details so that 911 can have EMS or other emergency responders can go to that location directly.

Now they could be using Dynamic Location Routing which allows for you to send location details but still use a single call back number. Traditionally you have to map an emergency location to a DID for calling back…but DLR allows you to map a unique ID to the device and location details and just map any DID as the callback, including a cell phone.

I did not know that Module existed so thanks!
Still, I dont see any evidence that the phone vendor is collecting this information.
Thats why I started this thread, what, if any, consequences (apart from the unthinkable) are there for non-compliance?
Where does enforcement happen?

It isnt a module. It is a service your voice provider would offer.

Unless your service provider provides a module :slight_smile:


That has nothing to do with E911 Dynamic Location Routing.

I realized that when I finally had a chance to look at the description.
My customers are all in locations simple enough that utilizing one or two DIDs accurately provides location info to PSAP so all this is a thought/planning exercise for if/when I acquire a customer of the complexity described at the beginning of this thread.
What Provider, other than ClearlyIP, has a system that sends accurate locations without utilizing additional DIDs?
I want to try them all before I need this capability because I try to proactively obtain all the customer’s info during onboarding.
@jfinstrom I signed up for the 30-day Trial of your Trunking; I spoke with a gentleman from your company but he never called back or emailed to follow up.

In my original posts, I described a multiple-building and multiple-story site for which the vendor has not requested any specific endpoint location info and is only providing a single DID per building as far as I can tell.
Maybe there is a PBX/Soft-Switch that has the capability of sending endpoint data without utilizing an additional DID?
If not, then I assume everyone is provisioning a ton of additional DIDs, or, they are just not providing the exact location data?

Our company, BulkVS, Bandwidth and there are others out there that offer this.

You have to register that location. As I previously said, traditionally you had to bind the location to a DID. Michigan (home state) had E911 laws before Kari’s Law/Ray Baums was introduced. We had to provide dispatchable locations for all the offices/spaces on multiple floors and buildings. We were handing out 100’s of DIDs to PRI/T1/SIP trunk users for this.

You can also use geolocation/GPS information but again, your upstream 911 provider must support these methods. You just can’t send willy nilly headers the upstream isn’t asking or looking for and expect them to pass them through.