# Dispatchable location and nomadic user handling

Canonical: https://warmtransfer.net/knowledge/dispatchable-location

Last verified: 2026-09-16

# 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](https://warmtransfer.net/knowledge/e911-us-regulatory).

See also [Meeting Kari's Law and RAY BAUM's Act on an enterprise phone system](https://warmtransfer.net/knowledge/kari-ray-baum-compliance).

## 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]:

| Location choice | How location is determined | Devices named |
|---|---|---|
| HTTP Enabled Location Delivery and HELD+ | Dynamic location by network discovery | Cisco MPP phones and the Webex App |[^11]
| LLDP-MED | Location from network switch location type-length-values | 9800 and 8875 phones |[^11]
| Nomadic E911 Service | User-entered dispatch address | Webex App |[^11]
| Caller ID-based location | Caller ID | Non-HELD devices such as Poly and Yealink phones |[^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](https://warmtransfer.net/knowledge/webex-calling-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](https://warmtransfer.net/knowledge/e911-routing-failures).

## 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.

## Sources

[^1]: 47 CFR 9.3 defines dispatchable location as a location delivered to the public safety answering point with a 911 call consisting of the validated street address of the calling party plus additional information such as suite apartment or similar information necessary to adequately identify the location of the calling party, except for commercial mobile radio service providers which convey the location information required by subpart C. Source: [47 CFR part 9 — 911 Requirements](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9), 47 CFR 9.3, Dispatchable location definition. Checked 2026-09-16.
[^2]: In FCC 19-76 the Commission records that no commenter disagreed with its conclusion that by providing validated street address information with 911 calls fixed telephony providers are already providing dispatchable location for single-family dwellings, and that it had asked about the feasibility of also providing floor level and room number for calls from multi-storey buildings. Source: [FCC 19-76 — Implementing Kari's Law and Section 506 of RAY BAUM'S Act, Report and Order, PS Docket No. 18-261](https://docs.fcc.gov/public/attachments/FCC-19-76A1.pdf), FCC 19-76 paragraphs 170 and 171. Checked 2026-09-16.
[^3]: FCC 19-76 addresses dispatchable location in 4 service classes in separate sections: multi-line telephone systems, fixed telephony, interconnected Voice over Internet Protocol, and Internet-based Telecommunications Relay Services, with mobile text treated separately under a more flexible standard. Source: [FCC 19-76 — Implementing Kari's Law and Section 506 of RAY BAUM'S Act, Report and Order, PS Docket No. 18-261](https://docs.fcc.gov/public/attachments/FCC-19-76A1.pdf), FCC 19-76 table of contents section III.B. Checked 2026-09-16.
[^4]: In FCC 19-76 the Commission concluded it would be premature to adopt dispatchable location requirements for text-to-911 comparable to those for other covered services, and instead required covered text providers within 2 years of the effective date to provide dispatchable location if technically feasible or otherwise end user manual provision of dispatchable location or enhanced location information which may be coordinate-based. Source: [FCC 19-76 — Implementing Kari's Law and Section 506 of RAY BAUM'S Act, Report and Order, PS Docket No. 18-261](https://docs.fcc.gov/public/attachments/FCC-19-76A1.pdf), FCC 19-76 paragraph 220. Checked 2026-09-16.
[^5]: 47 CFR 9.11(b)(1) limits the interconnected Voice over Internet Protocol E911 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. Source: [47 CFR part 9 — 911 Requirements](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9), 47 CFR 9.11(b)(1) Scope. Checked 2026-09-16.
[^6]: 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, the same 2 dates the multi-line telephone system rules use for on-premises fixed telephones and for non-fixed and off-premises devices. Source: [47 CFR part 9 — 911 Requirements](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9), 47 CFR 9.11(b). Checked 2026-09-16.
[^7]: The phase designations Phase 1 Phase 2 Phase I and Phase II occur 62 times across 47 CFR part 9 in total, as 23 occurrences of Phase 1, 17 of Phase 2, 4 of Phase I and 18 of Phase II, and 0 times within subpart F, the multi-line telephone system subpart, where phase language describes the wireless enhanced 911 location obligations of commercial mobile radio service providers instead (field report). Source: [47 CFR part 9 — 911 Requirements](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9), 47 CFR part 9 subpart F compared against the rest of part 9. Checked 2026-09-16.
[^8]: 47 CFR 9.16(b)(3) sets 3 dispatchable location deadlines for multi-line telephone systems: an on-premises fixed telephone shall provide automated dispatchable location no later than 6 January 2021; an on-premises non-fixed device shall 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; and an off-premises device shall 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. Source: [47 CFR part 9 — 911 Requirements](https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-9), 47 CFR 9.16(b)(3)(i) to (iii). Checked 2026-09-16.
[^9]: Cisco states that RAY BAUM'S Act Phase 2 began in January 2022 and requires emergency calls to send a correct dispatch address for non-fixed devices and for nomadic users. Source: [Enhanced Emergency Calling for Webex Calling](https://help.webex.com/en-us/article/av6oo3/Enhanced-Emergency-Calling-for-Webex-Calling), Nomadic E911 Service. Checked 2026-09-04.
[^10]: 2 service options are named: Nomadic E911 Service, in which off-premises Webex App users enter a dispatch address manually, and Enhanced Location-Based E911, which determines location automatically using HELD+, LLDP-MED or caller-identity-based location. Source: [Enhanced Emergency Calling for Webex Calling](https://help.webex.com/en-us/article/av6oo3/Enhanced-Emergency-Calling-for-Webex-Calling), Service options. Checked 2026-09-04.
[^11]: Cisco names 4 enhanced location choices for Webex Calling emergency calls: HTTP Enabled Location Delivery and HELD+ for dynamic location by network discovery on Cisco MPP phones and the Webex App, LLDP-MED for location from network switch location type-length-values on 9800 and 8875 phones, the Nomadic E911 Service for a user-entered dispatch address on the Webex App, and Caller ID-based location for non-HELD devices such as Poly and Yealink phones. Source: [Enhanced Emergency Calling for Webex Calling](https://help.webex.com/en-us/article/av6oo3/Enhanced-Emergency-Calling-for-Webex-Calling), Enhanced Location Choices table. Checked 2026-09-16.
[^12]: When a nomadic Webex App user takes the app to an off-premises location it prompts the user for a dispatch address, uses that address for a 911 call from that location, and reuses the address automatically the next time the user connects to the same off-premises network; the app detects network changes and prompts again only when the user connects from a different off-premises network. Source: [Enhanced Emergency Calling for Webex Calling](https://help.webex.com/en-us/article/av6oo3/Enhanced-Emergency-Calling-for-Webex-Calling), Emergency services for Webex Calling, Nomadic E911 Service paragraph. Checked 2026-09-16.