Enhanced mobile location information
for the Emergency
Call Service
ACMA consultation on a proposal to
amend the Telecommunications
(Emergency Call Service) Determination
2009
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© Commonwealth of Australia 2010
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Contents
1 Submissions
1
2 Overview
3
2.1 Scope of the consultation
3
2.2 Context
3
2.3 Regulatory framework
5
3 Proposal
8
4 Key consultation issues
11
4.1 Mandating that carriers provide the best available location
information about a mobile emergency call upon request from
an emergency service organisation
11
4.2 Operational issues
13
4.3 Temporary exemption from requirement to provide
enhanced mobile location information
14
4.4 Managing unrealistic expectations
14
1 Submissions
The Australian Communications and Media Authority (the ACMA) invites submissions from the public and industry on matters set out in this paper to assist in determining the contents of an amendment to the Telecommunications (Emergency Call Service)
Determination 2009 in relation to requirements to provide enhanced location
information for mobile callers to the Emergency Call Service. The close of submissions to this paper is 5pm on 18 June 2010.
Submissions received after this date may not be considered in preparing the draft amendments to the 2009 Emergency Call Service Determination. The ACMA encourages members of the public and industry to make submissions by email to: EmergencyCallServices@acma.gov.au
or by mail to:
Manager, National and Community Interests Australian Communications and Media Authority PO Box 13112, Law Courts
Melbourne, Victoria, 8010
Evidence-informed regulation
The ACMA has recently published a document, Evidence-informed regulation: the
ACMA approach. This is an overarching guide about how the ACMA uses evidence in
its work. It aims to improve the transparency of our decision-making and assist stakeholder involvement in regulatory issues and decisions. Evidence-informed regulation refers to regulatory processes that are informed by high quality evidence from a wide range of sources. The ACMA‘s approach to evidence-informed regulation, as well as the guide to effective consultation, are available at:
www.acma.gov.au/WEB/STANDARD/pc=PC_312051
Publication of submissions
In general, the ACMA publishes all submissions it receives.
The ACMA prefers to receive submissions which are not claimed to be confidential. However, the ACMA accepts that a submitter may sometimes wish to provide
information in confidence. In these circumstances, submitters are asked to identify the material over which confidentiality is claimed and provide a written explanation for confidentiality claims.
The ACMA will consider each claim for confidentiality on a case by case basis. If the ACMA accepts a confidentiality claim, it will not publish the confidential information unless required to do so by law.
Release of information in submissions
Submissions provided to the ACMA may be required to be released under the
Freedom of Information Act 1982. The ACMA may also be required to release
submissions for other reasons including for the purpose of parliamentary processes or where otherwise required by law (for example, a court subpoena). While the ACMA seeks to consult, and where required by law will consult, with submitters of confidential information before that information is provided to another body or agency, the ACMA cannot guarantee that confidential information will not be released through these or other legal means.
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Sharing of information
Under the Australian Communications and Media Authority Act 2005, the ACMA may disclose certain information to the Minister, the Department including authorised officials, Royal Commissions, the Telecommunications Industry Ombudsman, certain Commonwealth authorities such as the Australian Competition and Consumer
Commission and Australian Securities and Investments Commission and the authority of a foreign country responsible for regulating matters relating to communications or media.
2 Overview
2.1 Scope of the consultation
This consultation paper is concerned with amending the Telecommunications (Emergency Call Service) Determination 2009 (the 2009 Emergency Call Service Determination) to require mobile carriers to provide all location information available in association with a genuine emergency call at the request of an emergency service organisation.
It follows the ACMA‘s 2009 study into whether there is an appropriate and consistent mobile location solution for Australia‘s Emergency Call Service (ECS) that cost-effectively meets demonstrated needs. Recognising carrier innovation in mobile location-based functionality, the study found that:
> the accuracy of mobile location information available to emergency service organisations could be significantly enhanced
> action should be taken by the ACMA to exploit these developments for the benefit of the ECS.
The ACMA‘s Mobile location information - Location assisted response
alternatives April 2010 report is available on the ACMA‘s website at www.acma.gov.au.
The ACMA invites submissions on the issues raised in this paper. As an evidence-based regulator, it is vital that the ACMA is aware of evidence and information sources pertinent to the matters raised in this consultation paper, in particular those matters highlighted in boxes.
2.2 Context
Location information is a key element in facilitating a timely and accurate response to an emergency call. Unlike emergency calls made using a fixed service, the precise location of emergency callers who use mobile phones is not automatically known or conveyed to the relevant emergency service organisation—that is police, fire or ambulance organisation.
The number of calls received by emergency service organisations from mobile phones in 2008-09 (2.6 million) has doubled since 2003-04 (1.3 million). In 2008-09, calls from mobile phones to the emergency call service accounted for 63 per cent of all calls, compared to 52 per cent in 2003–04.
A number of submissions to the ACMA‘s 2008 review of the Emergency Call Service Determination argued that given the increasing use of mobile phones to the ECS, the Determination should require the provision of enhanced information about the location of a caller from a mobile service.
Expectations vary in relation to the form that such enhanced location information would take. Some of these expectations well exceed current technology and system capacity. Put simply, there is currently no single and widely available method that can accurately pinpoint a mobile phone user‘s location and then pass the information to emergency operators. Such accuracy is not expected to be made available on a reasonable cost basis for some years to come and will always be difficult in a country with the land mass and sparse population of Australia.
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For mobile calls to the ECS, the caller‘s location is provided to the level of the location of the caller‘s current standardised mobile service area (SMSA). An SMSA is a broad geographic area that can range in size from 2,000 to 500,000 square kilometres. The caller‘s phone number, current SMSA and state of origin of the mobile call are
displayed on the ECS operator‘s screen. The ECS operator is prompted by the SMSA code to query the caller for the location details and connects the call to the emergency service organisation. This system works well as in the vast majority of cases people who contact the ECS from a mobile phone are able to give accurate location details to emergency service operators.
Based on information provided by three emergency service organisations, the ACMA estimates that less than one per cent of emergency calls connected to emergency service organisations from mobile phones are from callers who are unable to communicate their location. This proportion is consistent with estimates made by emergency service community representatives in the United States.1
In areas where mobile telecommunications coverage is intermittent or not available, other forms of location identification are possible. Personal locator beacons can be used to improve the safety of people in remote areas engaging in activities that are potentially high risk.
Using the outcomes from the (then) Australian Communications Authority‘s 2004 mobile location study Location, Location, Location as a base-line (the 2004 study), the ACMA‘s 2009 study concludes that mandating a high-accuracy, ECS-specific location solution for all mobile calls to the ECS is not warranted at this point in time. There is no standard technological solution (and technologies are continuing to evolve) and there would be significant direct and indirect costs that would be incurred by mobile carriers, the emergency call person and consumers by mandating a single solution now. However, the 2009 study found that since the 2004 study, two of the three major carriers have implemented commercial location-based services and that these improvements should be exploited to assist in situations where callers have mobile coverage but are unable to communicate their location. Discussions with mobile carriers indicate that by exploiting existing location-based services, the mobile location information made available to emergency service organisations would range from 50m to several kilometres, depending on the number of mobile base stations in the vicinity of the mobile handset making the call.
The ACMA considers that emergency service organisations should;
> have access to the most accurate location information the network can provide for an emergency call (by querying the relevant network)
> benefit from carrier innovation in the area of location-based functionality. The 2009 study also found that potential sources of location information associated with an emergency call from a mobile service are moving from the network that carries the call to the user device that may operate on the network, thus diminishing the role of the carrier in delivering real-time location information. Given this on-going state of technological evolution, the ACMA considers that further review should be conducted within two years of implementing an enhanced mobile location solution to identify any practical opportunities for further enhancement.
There is also the broader policy issue of whether communications networks should automatically provide location information for VoIP and other emerging broadband-enabled services. However, any decision to require service providers to supply such information raises costs and practical implications that go well beyond the ECS and as
1
such are not discussed in this consultation paper. Advice from Telstra, in its capacity as the emergency call person for Triple Zero, indicates that the proportion of
emergency calls from VoIP services (compared with calls from fixed-line and mobile services) is very low but growing. Like mobile services, VoIP services carry an indicator that alerts ECS operators to check a caller‘s whereabouts before connecting the caller to an emergency service organisation.
Formulation of amendments to the 2009 Emergency Call Service Determination will be consistent with the principles that enhanced mobile location information will;
> be delivered through a competitively neutral common system to the emergency service organisations and the emergency call person
> be consistent with relevant privacy legislation and the disclosure provisions of the
Telecommunications Act 1997 (the Act)
> be capable of incorporating a location solution for VoIP services when identified and be adaptable to further innovations as they arise
> be forward-looking and able to accommodate developments in the approach to handling the personal and location information held within telecommunications networks, including being adaptable to a National Broadband Network (NBN) environment where the current ECS model may change
> seek a balance between minimising costs to the emergency call person, industry and emergency service organisations, and exploiting the opportunity to obtain the most accurate mobile location information available.
The outcome of this work is recognised as a logical next step in a process of
continuous improvement in the delivery of mobile location information to enhance the ECS.
2.3 Regulatory framework
The ACMA is responsible for monitoring the provision of and access to the ECS under Part 8 of the Telecommunications (Consumer Protection and Service Standards) Act
1999 (TCPSS Act). The ACMA‘s role under the TCPSS Act includes placing
obligations on carriers, carriage service providers and the emergency call persons in relation to the ECS through the 2009 Emergency Call Service Determination. Any potential solution for enhanced mobile location information must have regard to the regulatory framework that surrounds the ECS, which covers issues such as the availability and performance of the ECS and the protection of individual privacy. Telstra is currently the emergency call person responsible for providing the ECS for numbers Triple Zero and 112. The National Relay Service provider (currently the Australian Communication Exchange Limited (ACE)) is the emergency call person responsible for providing the ECS for the 106 text service for people who are deaf or have a hearing or speech impairment.2
Section 147 of the TCPSS Act requires the ACMA to make a written determination in relation to the ECS and that in making the determination the ACMA must have regard to, among others, the following objectives:
> the emergency call person should, if appropriate, give information in relation to such calls to appropriate emergency service organisations
2
As the current options available for mobile phone access to emergency services for the deaf, hearing-impaired and speech-hearing-impaired communities are limited, it is not expected that ACE (as the emergency call person for 106) will be required to upgrade its facilities to provide enhanced mobile location information as part of the current proposal.
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> that emergency service organisations should not be charged for services
provided by the emergency call person by way of giving information in relation to emergency calls to an emergency service organisation
> that carriage services used to make calls to an emergency service number should, as far as practicable, provide the emergency call person with automatic information about the location of the caller
> that, as far as practical, a common system is used to transfer calls made to an emergency service number to an emergency service organisation and give information in relation to such calls to an emergency service organisation > that calls made to an emergency service number are transferred to an
appropriate emergency service organisation with the minimum of delay. The existing regulatory framework also includes certain requirements to assist the operation of the ECS in relation to communication services that may be of uncertain location. Services such as nomadic VoIP must carry an indicator that alerts ECS operators to check a caller‘s whereabouts before connecting the caller to an emergency service organisation.
Location information is particularly sensitive and can have adverse consequences on an individual‘s privacy if misused. The privacy of customer data is governed by the
Privacy Act 1988, which covers all parties in the ECS process, and Part 13 of the Telecommunications Act 1997, which relates directly to the obligations of the
telecommunications industry.
A significant aspect of regulating for the ECS is that it is by nature a cross-jurisdictional service. While the ACMA can make regulations for industry and the emergency call person, emergency service organisations fall under state and territory jurisdiction. In terms of implementing an enhanced mobile location information solution therefore, the ACMA can regulate industry and the emergency call persons, but not emergency service organisations. Before making an Emergency Call Service Determination, the ACMA must, however, consult with emergency service organisations and consumers of standard telephone services.
The diagram below in figure 1 illustrates the operation of the ECS, showing how an emergency call flows first to the emergency call person for initial answering and is then transferred to the appropriate emergency service organisation. In this way, any calls that may be of uncertain location can be identified and transferred to the correct emergency service answering point. From a regulatory perspective, the dotted line shows the point at which the call handling process crosses the jurisdiction border.
Figure 1 Emergency Call Service call flow
More information about the legislative and regulatory framework governing the ECS is available in the ACMA‘s 2010 Mobile location Information report.
Voice Network Caller ECP operator ESO operator ECLIPS Database
“Emergency Police, Fire or Ambulance … ?”
Emergency Call Person (000, 112)
Emergency Service
Organisation
ESO Network “…Connecting you through” voice data Subject to Emergency Call Service Determination(Carriers, Carriage Service Providers, and ECP)
Not subject to ECS Determination (State and Territory ESOs)
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3 Proposal
The ACMA proposes to develop draft amendments to the 2009 Emergency Call Service Determination to mandate that mobile carriers provide the best available location information they have in association with a call to the ECS on request so that: > Innovation by carriers in the area of automated mobile location discovery provides
benefits to consumers and should be encouraged in a way that improvements in technology can also be exploited for the ECS. Accordingly, commercially deployed location services should be made available to the ECS.
> A temporary exemption process should be available for carriers that have not deployed location-based services. This process would allow carriers to apply for the time to develop an enhanced location solution for ECS calls.
> Automated location information should be delivered through a common system that has the flexibility to allow for further innovation and improvement, noting significant development will be required by carriers, the emergency call person and emergency service organisations to provide enhanced location information upon request from an emergency service organisation (i.e. a ‗pull‘ model). The proposed model is focused on delivering a solution that will improve outcomes for consumers who are unable to communicate their location when calling Triple Zero from a mobile phone. These situations are estimated to be less than one per cent of mobile calls connected to emergency service organisations each year.
Under the proposed model, mobile carriers would be required to provide the most accurate location information they have available about a mobile emergency call upon request from an emergency service organisation (the ‗pull‘ model‘). This would require, for example, the most accurate location techniques used in commercially deployed location-based services (such as Timing Advance and triangulation) to be made available to the ECS.3
The ‗pull‘ model is in contrast to a ‗push‘ model that would see the location information forwarded with every call to an emergency service organisation. The 2009 mobile location study explored a number of different options for implementing enhanced mobile location. It found that the ‗pull‘ model would provide an enhanced mobile location solution for those callers most in need of an automated system. Direct and indirect costs incurred by the emergency call person, mobile carriers and consumers would also be minimised, as in comparison to the ‗push‘ model, the proposed solution does not require significant network changes to be implemented. In addition, industry advice indicates that pushed enhanced mobile location information could result in all emergency calls from mobile phones experiencing a 20 second delay in being connected to an emergency service organisation, including those for which an automated process is not required.
The process for handling a location query under the proposed model of enhanced mobile location is depicted in figure 2. The diagram shows how enhancements to mobile location information could be achieved with existing infrastructure by channelling location queries through a common system using the emergency call person‘s data network. Location information would be obtained in response to an emergency call by querying the location server of the relevant mobile carrier.
Emergency service organisations would generate location queries via the emergency call person‘s data network, instead of requiring access to individual carrier servers. In
3
Triangulation uses location information from a number of cell towers and Timing Advance is a method for improving the precision of location data obtained through techniques such as Cell-ID.
this way, both carriers and emergency service organisations would only be required to establish one portal for location queries instead of several individual portals.
The ACMA intends the model to strike a balance between minimising the costs to the emergency call person, industry and emergency service organisations and the opportunity to obtain the most accurate location information available for callers who are unable to communicate their location from a mobile phone.
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Figure 2 Diagram of location query process under proposed model of enhanced mobile location information
4 Key consultation issues
4.1 Mandating that carriers provide the best available location
information about a mobile emergency call upon request from an
emergency service organisation
Cell identification (Cell ID) is the simplest method of mobile location. It uses the coordinates of the servicing base station and the particular serving cell to estimate the handset‘s general location. Information about the serving cell is generally available in mobile networks. The accuracy of Cell ID is dependent on the number of cells in an area and the size of the individual cells. In built up areas with a high concentration of cells, the diameter of an individual cell can be relatively small, while in remote areas with few cells, the size of an individual cell may be several square kilometres. The commercial location-based services currently available in Australia generally provide a level of accuracy above Cell ID. The location-based services offered by two major carriers typically employ network-based location techniques (Timing Advance or triangulation) to obtain location data and provide longitude/latitude coordinates. The level of accuracy for location-based services currently available in Australia can range from 50 metres to many kilometres, depending on the number of mobile base stations in the vicinity of a mobile handset making a call. These accuracy levels compare favourably with the approach adopted by the European Union where generally only Cell ID is provided.
Based on current location functionality in the major carrier networks, the best available location information (longitude/latitude co-ordinate of the mid-point of the relevant area) could be made available to an emergency service organisation through an automated process within approximately 20 seconds of a request. This is based on current service dimensioning and would be subject to reasonable usage of the service.
Under existing commercial location-based services, mobile location information is only available where the mobile service number is presented with the call. Given this limitation, the 2010 Mobile Location Information report observes that enhanced mobile location information would not be a suitable tool for validating emergency calls. More information about mobile location techniques4 and overseas approaches5 to enhanced mobile location information is contained in the ACMA‘s 2010 Mobile
Location Information report.
4
See Mobile Location Information – Location assisted response alternative, pp 7-10 5
12 | acma Question 1
> What modifications would be required to existing infrastructure to put the model into operation by:
(a) the emergency call person (b) industry
(c) emergency service organisations?
> What costs would be involved in putting the model into operation for: (a) the emergency call person
(b) industry
(c) emergency service organisations?
> Should there be a minimum level of enhanced mobile location information that carriers have to provide for an emergency call (for example, the location of the mobile cell carrying the call)?
> Within what minimum timeframe could carriers, the emergency call person and emergency service organisations put the model into operation? > Should a pilot of the proposed model be undertaken prior to nation-wide
implementation? If so, what issues should be tested or explored during a pilot phase?
Please provide evidence in support of your assessment of the effects of implementing the proposed model, such as details of the financial, technical and operational impact.
4.2 Operational issues
Operational issues for implementing an enhanced mobile location solution would need to be addressed for both the "upstream" (carriers/emergency call person) and the ―downstream‖ (emergency call person/emergency service organisations) parts of the process. These issues cover both privacy matters and those related to system technical protocols and capacity, including:
> procedures for how location queries would be processed
> what format would be used to query and transmit the location information > protocols for the common interface between emergency service organisations
and the emergency call person to allow for automated querying of enhanced mobile location information
> details for how system capacity issues would be managed in relation to issues such as the volume and frequency of location queries
> development of privacy safeguards and accountability measures.
While the ACMA can impose obligations on carriers, carriage service providers and emergency call persons in relation to the ECS, emergency service organisations operate under state government jurisdiction and are not within the ACMA‘s regulatory remit.
Question 2
> What arrangements would be appropriate to help manage access and use of the enhanced mobile location provided under the proposed model? > What arrangements would be appropriate to protect individual privacy
under the proposed model?
Please provide the reasoning behind your responses or any evidence you feel supports your submission.
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4.3 Temporary exemption from requirement to provide
enhanced mobile location information
A process should be available for carriers to apply to the ACMA for a temporary exemption if they are not technically able to provide enhanced mobile location
information via a common system or do not currently have commercial location-based services deployed. This is consistent with the principle that any mobile location information solution should seek a balance between minimising costs to the
emergency call person, industry and emergency service organisations, while exploiting the opportunity to obtain the most accurate location information available.
The purpose of a temporary exemption is to allow a carrier reasonable time to implement an enhanced mobile location solution. This must be weighed against the significance of location information to emergency response and the number of people likely to be affected by any temporary exemption.
Question 3
> Are there any factors that submitters consider would be relevant in establishing a process for a temporary exemption scheme?
> Given the importance of the ECS to community safety, should certain conditions be placed on the granting of an exemption period? For example, should a carrier have to inform its customers of the exemption and the effect of the exemption?
Please provide reasons for any views expressed.
4.4 Managing unrealistic expectations
As described in the ACMA‘s 2010 Mobile Location Information report, research commissioned by the ACMA indicates some people believe current mobile location identification techniques can provide ‗pinpoint accuracy‘ instantaneously anywhere in Australia. For example, research conducted for the ACMA by Ipsos MediaCT in 2009 found that 52 per cent of people surveyed believed they could be automatically located via a mobile phone. There is a risk that such assumptions, coupled with knowledge of new obligations to provide enhanced mobile location information to the ECS, could foster complacency about personal safety. This may encourage people to rely on mobile phones as safety devices when other forms of safety equipment may be more appropriate (such as personal locator beacons). It is therefore important that
regulatory and related initiatives are not communicated in a way that inadvertently encourages dangerous behaviours.
Question 4
> What steps should be taken to assist in managing unrealistic expectations in relation to the capabilities of mobile location technology.
4.5 Conclusion
The focus of this work is on improving emergency call outcomes for individuals going about their day-to-day lives that have reason to summon an emergency response but are unable to communicate their location.
The ACMA appreciates that the effectiveness of overall emergency response is determined by both the ECS and downstream call handling and dispatch by the various emergency service organisations. The dedicated commitment of the staff members in the relevant organisations is also recognised. The long-standing arrangements for the provision of the ECS, including those between the emergency call person and emergency service organisations and the exchange of information between the emergency call person and carriage service providers, have been integral to the way the ECS has been provided.
While this paper seeks information and comment on certain matters, it is not intended to limit comment on other issues individuals consider relevant to the paper.
