A Dataset Can Pass NG9-1-1 Validation with Every Subaddress Field Blank 

At a glance 

• FCC rules implementing Section 506 of RAY BAUM’s Act require 9-1-1 calls to carry a dispatchable location: the validated street address plus additional information such as floor, suite, or room. 
• On-premises fixed MLTS phones had to comply by January 6, 2021. Non-fixed and off-premises devices followed a year later. 

• Federal guidance directs enterprises to confirm the address validates in the jurisdiction’s GIS. The county dataset is the validation target. 

• NENA-STA-006.2-2022 gives the Site/Structure Address Point layer six subaddress fields: Building, Floor, Unit, Room, Seat, and Additional Location Information. 

• FCC live call data show dispatchable location accompanies roughly 0.9 percent of wireless 9-1-1 calls. In March 2025 the Commission opened a proceeding asking how to raise that share. 

What RAY BAUM’s Act requires, and of whom 

Section 506 of RAY BAUM’s Act directed the FCC to consider rules for conveying dispatchable location with 9-1-1 calls, and the Commission adopted them in a Report and Order on August 1, 2019 (FCC MLTS 911 requirements). The codified rule at 47 CFR 9.16 set three dates: 

• Every obligation in the subpart took effect February 16, 2020, and reaches only systems manufactured, imported, offered for first sale or lease, first sold or leased, or installed after that date. A phone system installed on February 15, 2020 and left alone since carries none of these duties.
• On-premises fixed telephones associated with a multi-line telephone system had to provide automated dispatchable location by January 6, 2021. 
• On-premises non-fixed devices and off-premises devices followed on January 6, 2022. Where automation is not technically feasible, on-premises non-fixed devices fall back to end user manual update or alternative location information, and off-premises devices fall back to manual update or enhanced location information, which may be coordinate-based. 

The obligation runs to MLTS manufacturers, operators, and the enterprises that install them. None of it lands on a county addressing authority. A GIS manager who reads the rule by itself can reasonably file it as “someone else’s compliance problem”. 

Where the obligation meets the county dataset 

The National 911 Program’s guidance on Kari’s Law and RAY BAUM’s Act is specific about what an enterprise does with the address it intends to deliver. It directs them to make sure addresses are “formatted correctly and validated for errors in a master street address guide (MSAG) format, or through geospatial routing,” and that “the address validates in their geographic information system (GIS).” 

That GIS belongs to the jurisdiction. The same guidance tells PSAPs to make sure call-taker screens and CAD transfers preserve the floor, room, and zone information that comes with a dispatchable location.

An enterprise that reports Suite 410 in a building whose address point holds no unit information has delivered a location the receiving systems can’t fully resolve. The federal rule governs the sending side, but the data that determines whether it works is located in a county office. 

The NENA model has the fields 

NENA’s Standard for NG9-1-1 GIS Data Model, NENA-STA-006.2-2022, was approved September 23, 2022. Its Site/Structure Address Point layer includes six fields for subaddress information: Building, Floor, Unit, Room, Seat, and Additional Location Information, stored as Addtl_Loc. The first version of the standard was released in 2018, so the schema has supported this information for years. 

Whether the fields actually hold anything is a separate matter, and one that’s less examined. For orientation on how the standards fit together, see Navigating NENA Standards. 

Conditional means blank is valid 

NG9-1-1 GIS fields have different requirements. A required field must contain a value and can’t be blank. A conditional field must contain a value when one is known; otherwise, it remains blank. Subaddress fields are conditional.  

A county that hasn’t surveyed units in its multi-tenant buildings can leave Unit blank on every record and still pass validation. Those blanks show only that the dataset contains no unit values; they don’t show that the buildings have no units.  

Validation checks whether the data is correctly formatted, not whether it’s complete. A dataset can therefore pass validation while omitting existing subaddresses. 

NG9-1-1 GIS standards and the broader pattern

Many NG9-1-1 GIS data standards treat subaddress elements such as building, floor, unit, room, and seat information as optional attributes. While these standards often provide guidance on how to represent multiple units within a structure, they typically allow local jurisdictions to determine the level of subaddress detail they collect and maintain.

Requiring every jurisdiction to capture complete subaddress data would effectively require a large-scale field survey and ongoing maintenance effort, making optional treatment a practical choice. The tradeoff is clear: local governments must decide whether to invest limited resources in collecting and maintaining this information, and many defer the work in favor of higher-priority initiatives. 

The number the FCC published 

In a Sixth Further Notice of Proposed Rulemaking adopted March 27, 2025, the Commission reported that dispatchable location data accompanies about 0.9 percent of wireless 911 calls (Wireless E911 Location Accuracy Requirements).  

The notice says dispatchable location—the “street address of the calling party, plus additional information such as suite, apartment or similar information”—is more useful than coordinates alone and asks how to increase its availability. It also proposes converting vertical location from height above ellipsoid to height above ground level and seeks comment on floor-level estimates. Those rules remained pending as of this writing.  

Wireless and MLTS calls are separate categories, so the 0.9 percent figure applies only to wireless calls. Even so, it shows how rarely PSAPs receive the most useful location data. Increasing that share—including by providing floor-level estimates—depends on address records that identify a building’s floors. 

What jurisdictions find when they look 

One U.S. county, had 74,207 residents in the 2020 census. After comparing its master address point dataset with supplemental sources, the county added 150 primary addresses and 300 subaddresses to its GIS. The review found twice as many missing subaddresses as primary addresses, even though the county has no large city.  

The county’s Land Records Coordinator and GIS Specialist, said the work also changed how its addressing offices collaborate. Finding subaddresses requires records from several departments: utility accounts, permits, and assessments are stored in separate systems managed by different staff. 

The structures driving this gap are usually new. A new apartment complex, a mixed-use block, a senior living facility or a corporate campus each arrives as a single address point that contains dozens of unrecorded units, but one point is how it reaches a responder. This is a reason for treating address points as more than points. 

Finding the units already in your records

You can identify subaddresses without a field survey. The units already appear in jurisdiction records: utility bills list apartment numbers; permits and business licences list suites; and assessment records and commercial address data provide much of the remaining detail.  

DATAMARK Technologies’ Address Comparison Evaluation compares the master address point dataset with those sources. It normalizes subaddress components, scores each candidate, and lets reviewers start with the strongest evidence. See what ACE finds for the terminology used in the process and Outsmart Sub-Addressing for guidance on structuring the data.  

Start with two questions: How many units are in the multi-tenant structures already represented by address points, and which department has the records needed to identify them? Offices that want those counts measured can start with the questions addressing offices ask before commissioning an ACE comparison.