911 Voice-over-IP Telephone Dispatchable Location System

The Federal Communications Commission (FCC) requires Voice-over-IP (VoIP) telephone service providers to furnish a subscriber's verified street address, known as dispatchable location to the 911 community, when activating the VoIP service for subscribers. The dispatchable location information is associated with the VoIP number whenever a subscriber places a 911 call to request for emergency services.

VoIP telephone equipment works when connected to the internet and therefore offers subscribers the flexibility to relocate their VoIP service from one address to another. Given VoIP service complements the mobile phone service, when there is a lack of cellular coverage at a home or business, VoIP can serve as an important backup to a cellphone when connecting to the 911 Emergency Call Center (ECC).
A problem arises when a VoIP subscriber moves from one locality to another and fails to update the VoIP service provider with the new physical address that is necessary for dispatching emergency personnel. Calls placed by the VoIP subscriber to 911 will be routed to the wrong 911 ECC based on the outdated address record, resulting in lost time to dispatch emergency personnel.

By one estimate, the state of California reported 1,687,529 calls were placed using VoIP to 911 ECC in 2022, or 6% of all 911 calls. Even a small fraction (assuming 5%) of the VoIP lines having issue with dispatchable location in the state of California would have resulted in tens of thousands of calls that would not be routed to the correct 911 ECC. DHS S&T has confirmed with the state of California Office of Emergency Services that VoIP 911 calls that were routed incorrectly due to lack of updated and verified dispatchable location remains an on-going challenge for 911 ECC.

VoIP vendors and public safety need a solution to address the problem of maintaining updated and verified dispatchable locations. The proposed solution should enable the VoIP service providers to address the key requirement mandated by the FCC and provide a dispatchable address for VoIP subscribers’ access to 911 services. The service provider must identify whether the service is being used to call 911 from a different location than the Registered Location and, if so, either: (i) prompt the customer to provide a new Registered Location; or (ii) update the Registered Location without requiring additional action by the customer.

The proposed solution should include the following requirements:
• Determine dispatchable location for 911 services (e.g., using caller’s current GIS location).
• Detect a change in physical location from which a subscriber's VoIP equipment is connecting to the internet for telecommunication services.
• Adhere to all relevant regulations and standards (including those referenced below).
• Privacy preserving – storing data.
• Access management that provides authorized administrators ability to perform query and collect system performance data.
• Interoperable with legacy 911 and NG911 systems for the purpose of supplying dispatchable location for the VoIP calls.
• Meet a minimum availability of 99% of up time.
• Access to the location database of the legacy 911 system, or if available, the NG911 system.