Dispatchable location and nomadic user handling

Verified 2026-09-16 · 12 sources · tier 1–2

Also known as HELD, LLDP-MED, PIDF-LO, Wireline E911 Network, alternative location information, enhanced location information.

Dispatchable location and nomadic user handling

47 CFR 9.3 defines dispatchable location as a location delivered to the public safety answering point with a 911 call, made up of the validated street address of the calling party plus additional information such as suite, apartment or similar information needed to identify the caller's location 1. Cisco states that RAY BAUM'S Act Phase 2 requires emergency calls to send a correct dispatch address for non-fixed devices and for nomadic users, and Webex Calling names a Nomadic E911 Service in which off-premises Webex App users enter a dispatch address manually 9 10.

Regulatory definition and deadlines

The 47 CFR 9.3 definition of dispatchable location excludes commercial mobile radio service providers, which instead convey the location information required by subpart C 1.

47 CFR 9.16(b)(3) sets 3 dispatchable location deadlines for multi-line telephone systems 8:

• An on-premises fixed telephone must provide automated dispatchable location no later than 6 January 2021 8.
• An on-premises non-fixed device must, no later than 6 January 2022, provide automated dispatchable location when technically feasible, and otherwise dispatchable location based on end user manual update or alternative location information as defined in section 9.3 8.
• An off-premises device must, no later than 6 January 2022, provide automatic dispatchable location if technically feasible, and otherwise end user manual update or enhanced location information, which may be coordinate-based 8.

47 CFR 9.11(b) applies its interconnected Voice over Internet Protocol E911 requirements on or after 6 January 2021 for fixed services and on or after 6 January 2022 for non-fixed services, which are the same 2 dates the multi-line telephone system rules use 6. 47 CFR 9.11(b)(1) limits those interconnected Voice over Internet Protocol requirements to 911 calls placed by users whose dispatchable location is in a geographic area served by a Wireline E911 Network, which section 9.3 defines as including a selective router 5.

FCC 19-76 addresses dispatchable location in separate sections for 4 service classes: multi-line telephone systems, fixed telephony, interconnected Voice over Internet Protocol, and Internet-based Telecommunications Relay Services 3. The order treats mobile text separately under a more flexible standard 3. For text-to-911, the Commission concluded it would be premature to adopt requirements comparable to those for other covered services 4. Instead, it required covered text providers to provide, within 2 years of the effective date, dispatchable location if technically feasible, or otherwise end user manual provision of dispatchable location or enhanced location information, which may be coordinate-based 4.

In FCC 19-76 the Commission records that no commenter disagreed with its conclusion that fixed telephony providers already provide dispatchable location for single-family dwellings by sending validated street address information with 911 calls 2. The Commission also records that it had asked about the feasibility of providing floor level and room number for calls from multi-storey buildings 2.

In the field, the phase designations Phase 1 Phase 2 Phase I and Phase II have been counted 62 times across 47 CFR part 9, as 23 occurrences of Phase 1, 17 of Phase 2, 4 of Phase I and 18 of Phase II 7. In the field, the same count finds 0 occurrences within subpart F, the multi-line telephone system subpart, where phase language instead describes the wireless enhanced 911 location obligations of commercial mobile radio service providers 7.

See also US emergency calling regulatory requirements.

See also Meeting Kari's Law and RAY BAUM's Act on an enterprise phone system.

How Webex Calling handles nomadic users

Cisco names 2 service options 10:

• Nomadic E911 Service, in which off-premises Webex App users enter a dispatch address manually 10.
• Enhanced Location-Based E911, which determines location automatically using HELD+, LLDP-MED or caller-identity-based location 10.

Cisco also names 4 enhanced location choices for Webex Calling emergency calls 11:

All rows in this table are stated in 11.

When a nomadic Webex App user takes the app to an off-premises location, the app prompts the user for a dispatch address and uses that address for a 911 call from that location 12. The app reuses the address automatically the next time the user connects to the same off-premises network 12. The app detects network changes and prompts again only when the user connects from a different off-premises network 12.

See also Webex Calling enhanced emergency calling.

Diagnosing a nomadic address problem

Because the Webex App reuses a stored dispatch address whenever the user reconnects to the same off-premises network, the user is not prompted again on that network 12. A user who has moved to a different off-premises network should see a new prompt, since the app prompts again only in that case 12. Devices that do not support HELD, such as the named Poly and Yealink phones, fall under Caller ID-based location rather than network discovery 11.

See also Troubleshooting 911 calls that route with the wrong location.

Applicability

Applies to: Cisco Webex Calling and Federal Communications Commission multi-line telephone systems. Deployments: multi-tenant. Sources checked 2026-09-16. The interconnected Voice over Internet Protocol E911 requirements cover only 911 calls from users whose dispatchable location is in an area served by a Wireline E911 Network 5.

What remains uncertain

The dispatchable location definition lists suite, apartment or similar information 1, and FCC 19-76 records that the Commission asked about the feasibility of floor level and room number for multi-storey buildings 2. What ultimately satisfies dispatchable location in a multi-storey building is not covered by the sources below. The definition requires a validated street address 1. How an address is validated, and against what authority, is not covered by the sources below. The rules refer to both alternative location information and enhanced location information 8. The difference between alternative location information and enhanced location information is not covered by the sources below. FCC 19-76 addresses Internet-based Telecommunications Relay Services in its own section 3. The dispatchable location requirements for Internet-based Telecommunications Relay Services are not covered by the sources below. How Cisco's Webex Calling location choices correspond to the 47 CFR 9.16(b)(3) categories is not covered by the sources below.

WarmTransfer. (2026, September 16). Dispatchable location and nomadic user handling. WarmTransfer. https://warmtransfer.net/knowledge/dispatchable-location

@misc{warmtransfer-dispatchable-location,
  title  = {Dispatchable location and nomadic user handling},
  author = {{WarmTransfer}},
  year   = {2026},
  url    = {https://warmtransfer.net/knowledge/dispatchable-location},
  note   = {Verified 2026-09-16}
}