Discussion Paper
111 Emergency Calling Review
February 2012
This paper discusses issues relating to the performance of the 111 calling system through to the point where calls are handed over to emergency services (police, fire and ambulance).
Table of Contents
1. INTRODUCTION ... 3
2. EXECUTIVE SUMMARY ... 5
3. BACKGROUND ... 11
4. THE 111 CALLING SYSTEM ... 14
5. RESILIENCE AND PERFORMANCE OF THE 111 CALLING SYSTEM ... 26
6. TECHNOLOGY TRENDS AND CHALLENGES ... 34
7. GOVERNANCE: ARE CURRENT ARRANGEMENTS SATISFACTORY? ... 41
8. ICAP: ARE CURRENT ARRANGEMENTS SATISFACTORY? ... 53
9. GLOSSARY ... 60
10. LIST OF QUESTIONS ... 61
APPENDIX 1:TERMS OF REFERENCE FOR THE EMERGENCY CALLING SERVICE REVIEW .... 63
APPENDIX 2:EMERGENCY SERVICES CALLING ADVISORY BOARD ... 65
ISBN 978-0-478-38222-8 (PDF) ISBN 978-0-478-38223-5 (Print)
1. Introduction
1. The purpose of this review is to take a high level look at the existing 111 calling service, identify its strengths and weaknesses, look at likely changes in
technology and opportunities to improve services and look at governance to ensure it is fit for purpose. While we cannot predict all the technology changes that will occur, we can ensure that organisational and governance arrangements are capable of dealing with current and future challenges and opportunities. 2. The scope of the review is limited to the 111 emergency calling service – that is
from the customer device such as a telephone handset, mobile phone or computer that originates a 111 call to the point where the call is answered by one of the emergency service providers. This part of the service operates on the public telecommunications networks of Telecom NZ, Vodafone and other
operators. The remaining part of the overall “emergency services system” is the Emergency Service Providers (ESP) call centres, despatch centres and the private wireless networks they operate to communicate with their front line officers. Those components are not included in this review.
3. The discussion paper is intended to provide information regarding the 111 emergency calling system and identify issues and options. The issues it raises are mostly directed at those who are actively engaged in providing and using the 111 system such as telephone operating companies and emergency service providers. The Government is keen to learn from them how the service can be maintained and improved.
4. Comments are also welcome from the general public.
5. Responses which are labelled confidential will be accepted. Under the Official Information Act submissions will be subject to release, but information shown to be confidential information (including commercially confidential and personal information) will be withheld.
6. Submissions should be made by 30 March 2012 to [email protected] or to:
111 Review
Ministry of Economic Development PO Box 1473
Publication and public release of submissions
7. Our intention is to publish all submissions on the Ministry website
www.med.govt.nz. Submitters will be considered to have consented to publication unless clearly specified otherwise in the submission.
8. If parties wish to make points which are commercially sensitive, these should be submitted as a suitably labelled appendix. This will assist us to easily strip out such material and enable us to upload the submissions more rapidly.
9. Submitters should also be aware that the content of submissions provided may become subject to public release under the Official Information Act 1982. Please advise if you have any objection to the release of any information contained in a submission, and in particular, which part(s) you consider should be withheld, together with the reason(s) for withholding the information. Confidential
information should be clearly marked. The Ministry will take into account all such objections when responding to requests for information on submissions to this paper under the Official Information Act 1982.
10. The Privacy Act 1993 establishes certain principles with respect to the collection, use, and disclosure of information about individuals by various agencies
including the Ministry. It also governs access by individuals to information about themselves held by agencies. Any personal information you supply to the
Ministry in the course of making a submission will be used by the Ministry only in conjunction with consideration of matters covered by this paper. Please clearly indicate in your submission if you do not wish your name to be included in any summary of submissions that the Ministry may publish.
No reliance
11. The opinions and proposals contained in this paper are for discussion purposes only and do not necessarily reflect Government policy.
12. Readers are advised to seek specific legal advice from a qualified professional person before undertaking any action in reliance on the content of this
publication. The contents of this discussion paper must not be construed as legal advice. The Ministry of Economic Development does not accept any responsibility or liability whatsoever whether in contract, tort (including
negligence) equity or otherwise for any action as a result of reading, or reliance placed on the Ministry because of having read any part, or all, of the information in this discussion paper or for any error, inadequacy, deficiency, flaw in or omission from the discussion paper.
2. Executive Summary
13. The reliability and efficiency of 111 emergency calling services is of critical importance to public safety and community well-being. Concerns were raised about the 111 service following two high profile failures in 2009/10 (in Telecom’s Papatoetoe exchange and XT network). As part of its response, the
Government announced it would undertake a strategic review of the 111 calling system to ensure it can meet community and Government expectations.
14. Accordingly, this discussion paper reviews the performance of the 111 calling service, identifies its strengths and weaknesses, looks at challenges and
opportunities arising from changes in technology, and considers whether current governance and ICAP (Initial Call Answering Platform) arrangements are
satisfactory.
Background and objectives
15. Chapter 3 provides background to the review. In response to the 111 calling failures, the Government took a number of measures, including:
• ensuring (through a MOU with Telecom) better reporting, monitoring and auditing of Telecom’s obligations to provide 111 services under its TSO (Telecommunications Service Obligations)
• encouraging the TCF (Telecommunications Carriers’ Forum) to upgrade its Emergency Calling Code to strengthen standards and compliance
• encouraging agreement between Telecom, Vodafone and 2degrees to improve the ability for mobile phones, where technically compatible, to use other networks for 111 calls in the event of a network failure (‘SOS
roaming’)
• creating a joint industry/government advisory board (the Emergency Services Calling Advisory Board or ESCAB) to oversee coordination of emergency calling service planning and development
• commencing (as noted) this review.
16. The chapter also proposes the following high-level objectives (in terms of
community and Government expectations) for the emergency calling service, for discussion purposes. The suggested objectives are that emergency calling service (that is, the ability to request assistance from police, fire and ambulance services) should:
• be available from all telecommunications devices which can originate voice calls
• be free of charge (for genuine calls)
• have a very high level of reliability under virtually all circumstances • provide clarity for voice communications
• be available for people who are hearing impaired, speech impaired or deaf.
Description of the 111 calling system including governance
17. Chapter 4 describes the 111 calling system. The system comprises two main components:
• Originating networks, operated by competing telecommunications service providers, which route 111 calls through to 29 points of interconnection with Telecom’s PSTN (Public Switched Telephone Network)
• Telecom’s PSTN, which routes 111 calls to the Initial Call Answering Platform (ICAP) where Telecom operators at two centres answer calls and transfer them to emergency services communication centres (police, fire and ambulance).
18. Approximately three million 111 calls are made each year, about 25 percent of which are transferred to emergency service communication centres (the rest are non-genuine calls). About 65 percent of calls (and increasing) are from mobile phones, 33 percent from fixed lines, and 2 percent from payphones. Of the calls transferred to the emergency services about 62 percent are for police, 30
percent for ambulance and 8 percent for fire.
19. The Telecommunications Act 2001 provides powers to regulate minimum standards for emergency call services, but no regulations are currently in place and no objectives are set in the Act for 111 calling services. Current governance arrangements can be summarised as follows:
• ESCAB (Emergency Services Calling Advisory Board), comprising
government, emergency services and industry representatives, facilitates overall coordination between government and industry parties
• The TCF takes the lead role for its members in developing the voluntary Emergency Calling Code setting out the responsibilities of voice service providers
• Telecom is responsible under the 2001 Local Service TSO
(Telecommunications Service Obligation) Deed for the ICAP. (The ICAP call centres cost about $4m a year to operate, which is met by Telecom itself and a $2.36 per 111 call interconnection charge by Telecom on other telecommunications companies)
• Overall policy advice to the Government on emergency call services, up to the point where calls are handed over to emergency service providers, is led by the Ministry of Economic Development (MED)
• The lead role on most operational matters relating to 111 services is taken by the New Zealand Police.
Accessibility, resilience and performance of the 111 calling system
20. Chapter 5 reviews the performance of the current 111 system, including
originating networks and the 111 system on Telecom’s PSTN and the ICAPs. Its overall conclusion is that there is a high level of resilience built in to the
telecommunications system generally including the 111 system. However, there are potentially some vulnerabilities, such as some single points of failure (for example some cellphone towers) and there are no set standards covering resiliency requirements.
21. The 22 February 2011 Christchurch earthquake resulted in a large spike in 111 calls at a time when 111 services were also subject to significant stress. MED has undertaken a review of the performance of the 111 system during and following the earthquake. It concludes that the system, and contingency plans, generally performed well, indicating good resilience for an earthquake of this scale.
Technology trends and challenges
22. Chapter 6 summarises the significant technological changes that are occurring in telecommunications and the challenges and opportunities arising from those changes. These include:
• The need for improved information for emergency services on the location
of callers, which is particularly important where a caller is unable to
communicate their location, for example, someone who is under duress or badly injured or sick or who does not know their specific location (for example in a traffic accident). Currently, good location information is only available for fixed lines and then only from Telecom and TelstraClear. Various technologies are available to determine, with varying degrees of accuracy, the location of mobile phone and VOIP (Voice-Over-Internet-Protocol) callers, but cost, complexity and other issues need consideration • How best to minimise non-genuine calls, which waste resources and
impact on handling of genuine emergencies. The increased use of mobile phones for 111 calls is producing more false calls. There are various measures potentially available to reduce the incidence of non-genuine calls, but again with cost, effectiveness and complexity implications • Whether new services should be provided, such as allowing wider use of
speech impaired people), and providing for broadcast messaging (such as for tsunami alerts)
• Whether independent power sources should be mandatory for VOIP devices (which cannot otherwise operate during power cuts).
23. The discussion paper does not seek to reach conclusions on any of these issues, but does conclude with a brief discussion on good processes for resolving them, which links through to the next chapter on governance.
Are current governance arrangements satisfactory?
24. Chapter 7 considers whether current governance arrangements are satisfactory, taking into account the significant structural and technology changes occurring in the telecommunications market (in particular the move to IP-based networks) and the technological challenges and opportunities noted in the previous chapter.
25. Functions that need to be performed are:
• Setting an overall strategic roadmap and end-to-end architecture and standards
• Monitoring and enforcing performance requirements
• Making decisions on, and implementing, service enhancements (such as caller location), including undertaking cost-benefit analysis.
26. A case can be made that current governance arrangements (including ESCAB and the cooperative, voluntary approach of the TCF), combined with strong commercial incentives on telecommunications service providers to provide a robust 111 emergency calling service, are satisfactory enough.
27. However, the case can also be made that while current arrangements are not “broken”, there is a clear lack of resources, capacity, powers and accountability to make decisions on emergency calling issues. ESCAB has no resources or clear decision-making powers, which creates a risk that opportunities for efficiency improvements and service enhancements will not be taken, and that public safety may be eroded over time.
28. Two alternatives to current arrangements are considered, the first comprising an ‘enhanced status quo’, and the second involving setting up a small, dedicated 111 group in a Government agency.
29. The ‘enhanced status quo’ option involves strengthening the role, structure and resources of ESCAB. An independent chair is proposed, along with balanced membership of four representatives from industry (appointed by the TCF) and
four from emergency services providers and government departments. An annual budget, funded by the Telecommunications Development Levy, of $0.25m is proposed to enable ESCAB to commission analytical work and policy advice (for example on service enhancements such as caller location) and to fund a part-time independent chair. ESCAB would report directly to the Minister for Communications and Information Technology and would be serviced by MED.
30. The second alternative to current arrangements is to set up a small, dedicated group in a Government agency with overall responsibility for ensuring a safe and effective 111 calling service. Location options are the Department of Internal Affairs, Ministry of Economic Development, the Commerce Commission or the New Zealand Police. The group would be assisted by an advisory board, which could be ESCAB. Staff of 2-3 and resources of $0.5m - $0.75m per annum are suggested. Funding could come from the baseline budget appropriation for the Telecommunications Development Levy (TDL) established under the
Telecommunications Act 2001.
31. The main differences between the options are where accountability lies (with the ESCAB committee or a Government agency) and the quantum of resources available for developing system architecture, standard setting, monitoring and enforcement, and procurement of system enhancements. Under both options, the TCF would retain primary responsibility for developing and enforcing the Emergency Services Code. As a backstop, the Minister has powers under the Telecommunications Act to recommend regulations to require compliance with the TCF Code by non-members or to set standards if the TCF Code is not satisfactory.
Are current ICAP arrangements satisfactory?
32. Chapter 8 considers whether the current ICAP arrangements provided by Telecom under the TSO are optimal, or whether alternative arrangements may facilitate efficiency gains or be more sustainable over the longer term,
particularly given the 2013 review of the TSO, and the expected replacement of the PSTN with IP-based networks.
33. The chapter notes that new technologies (such as ‘Interactive Voice Response’) may provide scope for efficiency gains. It also canvases alternatives to
continuing the requirement on Telecom to provide ICAP services, such as: • Transferring ICAP services to the NZ Police
Submissions
34. The paper invites submissions on the issues discussed in the paper and the questions at the end of each chapter. Submissions are requested by 30 March 2012.
3.
Background
Brief history of the 111 system and background to this review
35. Dialled 111 emergency calling service has been available in New Zealand from the late 1950s, superseding the previous operator dialled service. Since that time the service has evolved to meet changing technology developments, changing operational requirements and the changing expectations of consumers.
36. There have been a number of significant technological milestones since the 1950s including: conversion from manual to automatic telephone exchanges; development of cellular phone networks; digital networks; internet based
telephony; text, data and video communications; and satellite communications to mention a few. These technology changes have been driven by the commercial objectives of telecommunications companies. The 111 emergency calling
service has evolved alongside, taking the benefits that new technologies have to offer.
37. Governance and regulation of the 111 emergency calling service has also evolved over time. The most significant change occurred when Telecom
Corporation of NZ was established in 1987 to take over the telecommunications business of the New Zealand Office. Governance and control of the 111
emergency calling service was until then a direct responsibility of the
Government through the NZ Post Office. When Telecom was privatised in 1990 it agreed (under the Kiwi Share obligations) to continue to provide 111 service for residential fixed telephone lines.
38. The ability to make a 111 call on other networks has been a voluntary commercial arrangement between Telecom and other telecommunications operators, coordinated by carrier interconnection agreements. The Government has reserve powers under the Telecommunications Act 2001 to regulate
minimum requirements for emergency call services if it considers this is necessary.
39. The origins of this review were two failures in the 111 system. First, from December 2009 to February 2010, the new Telecom XT mobile network had a number of failures, the most serious of which resulted in XT customers being unable to make emergency calls. Second, in February 2010, there was a fault in one of Telecom’s main aggregation points of the dedicated 111 system at the Papatoetoe exchange. The backup systems and processes did not take over as they were intended to, resulting in a number of 111 calls being lost for a period of time.
40. In response to the XT and Papatoetoe failures the Government put in place some interim initiatives and announced its intention to undertake a review of the 111 calling system. The terms of reference of the review are in Appendix 1. The interim initiatives were:
• a memorandum of understanding (111 MOU) with Telecom regarding its delivery of the current 111 emergency calling service. The MOU included an agreement to review the 111 system
• encouraging a revision of the TCF Emergency Calling Code to strengthen standards and compliance
• an agreement between Telecom, Vodafone and 2degrees regarding the implementation and operation of capability for emergency (SOS) roaming • creation of a joint industry/government advisory board (the Emergency
Services Calling Advisory Board or ESCAB) to oversee coordination of emergency calling planning and development.
41. In September 2010 and again in February 2011 there were major earthquakes in Christchurch, putting extreme pressure on the emergency services system. A separate review has been undertaken on the 111 service performance following the 22 February earthquake.
Objectives of the 111 emergency calling system
42. The objectives of the 111 calling emergency system are not specified in
legislation or any formal documentation. A discussion paper such as this needs to articulate clear objectives for the emergency calling system. The following is an attempt to do so.
43. An effective and efficient 111 emergency calling service is of fundamental
importance for public safety and community well-being. Emergency calling (that is, the ability to request assistance from police, fire and ambulance services) should:
• be available from all telecommunications devices which can originate voice calls
• be free of charge (for genuine calls)
• have a very high level of reliability under virtually all circumstances • provide clarity of voice communications
44. Government expectations are that these objectives will be met, that the
regulatory and governance regimes will be capable of ensuring this, and that, as a function of meeting these objectives, 111 services will be capable of adapting to and making the most of opportunities afforded by changing technologies. 45. Potentially there is an issue with the first of these objectives (that emergency
calling should be available from all telecommunications devices which can originate voice calls). This objective may not be able to be met by some
services, such as Skype. Accordingly, expressing this objective in a way which potentially precludes services which offer other advantages to consumers (such as cheaper calls) may be undesirable. Some countries have dealt with this issue by requiring the providers of services which do not enable emergency calling to make that fact clear to consumers before they purchase the service. The new TCF Emergency Calling Code has similar requirements. Submissions are sought on this point.
46. The objective of ensuring that emergency calling services are available to people who are hearing impaired, speech impaired or deaf is clearly a basic right. However, ensuring ‘functionally equivalent’ service is complex, and is expected to become more complex in the new telecommunications environment, with the emergence of IP-based networks and new methods of communication. It is beyond the scope of this paper to cover the complexity of this specialist area, and it does not attempt to do so. A separate focused review of the
challenges and opportunities provided by new technologies for communications-impaired people is required. Clearly however, any statement of overall
objectives needs to include the right of everyone in the community to access and communicate with emergency services.
Questions Objectives
1. Are the objectives for 111 emergency services calling set out
4. The 111 emergency calling system
System description
47. A high-level depiction of the 111 emergency calling system is provided in Figure 1. A summary of the process for handling 111 calls is provided in Figure 2. 48. Some facts and figures on 111 calls are as follows.
• Number of 111 calls a year: approximately 3 million
o Trend: the total number of 111 calls received by the ICAP has been increasing steadily, with the volume of mobile originated calls growing faster than the volume of fixed originated calls.
o Only about 25 percent of the total 111 calls received by the ICAP are sent through to emergency service providers: the rest are
non-genuine. • Source of calls
o Mobile: 65 percent o Fixed line: 33 percent o Payphone: 2 percent
o Trend: The number of calls from mobile phones has grown
substantially over the last decade, both in absolute terms and as a proportion of total calls. This trend is expected to continue.
• Calls abandoned at or before the greeting message: about 25 percent of total calls
• Non-genuine emergency calls handled by ICAP operators: about 50 percent
o Trend: the number of non-genuine calls has steadily increased in recent years, both in absolute terms and as a proportion of total calls. Most are from mobile phones.
• Calls passed to Emergency Service Providers (ESPs) o Police: 62 percent
o Ambulance: 30 percent o Fire: 8 percent
o Trends: These proportions fluctuate slightly but are reasonably stable over time.
49. More detailed statistical and performance information on 111 calling services is available in Telecom’s quarterly reports under the 111 MOU with the
Government. These are posted on MED’s website at
http://www.med.govt.nz/templates/MultipageDocumentTOC____45622.aspx 50. Figure 2 notes that there are nine emergency service communication centres nation-wide: three for each of police, fire and ambulance, located in Auckland, Wellington and Christchurch.1 It is important to note however, that there is a
high level of integration between the centres:
• Police and fire communication centres are co-located and share the same system (but not communication centre staff). The Police use an IP-based system, so calls are handled and queued nation-wide rather than centre-by-centre
• All services and all centres are able to communicate with each other in real-time (voice and data) and ‘create tasks’ for each other in real-time • There is no ‘wrong door’ for communicating with emergency services: each
emergency service will handle calls for other services and communicate tasks to the other services in real-time
• Where an ICAP operator is unsure which service is required (for example, where there is no response from the caller to queries but the call may be genuine) the call is automatically sent to a police communications centre. 51. The 111 emergency calling system consists of two main components:
• Originating networks – that is, the fixed and mobile networks between a customer device (fixed handset, cordless, mobile phone or computer) and a local aggregation point, such as a cellular base station or cell tower region or a fixed network telephone exchange, and through to one or more of 29 interconnection points with Telecom’s PSTN
• The 111 network in Telecom’s PSTN. This routes calls to the Initial Call Answering Platform (ICAP) where they are answered by Telecom operators. Genuine calls are passed to the requested emergency service provider for response.
1
Total FTE staff numbers for emergency services communication centres, including call handling and dispatch (and supervisors/managers) 24/7 are: NZ Police 530; Ambulance New Zealand 140; and NZ Fire Service 82.. The ICAP centres have a total of 44 staff.
Figure 1
Figure 2
What happens to 111 calls?
Caller Telecom Emergency service provider
• A person dials 111 and the caller hears the 111 greeting message: “You have dialled 111 emergency, your call is being connected”. • Within 5 seconds (in 95% of cases)
the call is answered by the
Telecom ICAP operator who says: “111 Emergency, Fire, Ambulance or Police?” This question and the caller’s response are recorded. • When the ICAP operator transfers
a call to a Fire, Ambulance or Police operator, they briefly monitor the call to ensure the caller and emergency operator can
communicate with each other.
• Of the more than two million 111 calls that Telecom ICAP operators answer each year, about 50% are transferred to emergency service providers.
• The other 50% are non-genuine calls (misdials, hang-ups, children playing, and phones in bags) – which must still be answered and assessed.
• Telecom’s responsibility for delivery of 111 services ends when the call is successfully transferred to an emergency service provider’s communications centre.
• There are nine emergency service communication centres nation-wide: three for each of police, fire and ambulance, located in
Auckland, Wellington and Christchurch
• Each centre receives calls from the Telecom ICAP 111 operator and determines the appropriate emergency response
• All calls to the emergency services communications centres are
recorded by them
• The ESP asks for the name and location of the caller.
52. Individual telecommunications operators are responsible for the originating segment of 111 calls (ie from end user devices through to handover to Telecom at points of interconnection with Telecom’s PSTN). So, for example, with a 2degrees customer, 2degrees is responsible for ensuring that the handset it has sold can connect to its network, that a 111 call will take priority over other calls on its network, and that it will transport the call to the interconnection point with Telecom’s PSTN.
53. The 111 network in Telecom PSTN is the responsibility of Telecom. It begins at interconnection point(s) with the PSTN and ends at the demarcation with
emergency service provider call centres. For resilience purposes, there are multiple routes and switches for handling 111 calls. All local exchanges connect to three trunk switches (out of 6 nation-wide), including one that is “out-of-area”, for routing calls to two duplicated ICAP switches (in Palmerston North and Christchurch) to be answered at one of two ICAP centres, in Wellington and Christchurch (with Palmerston North and Rangiora as back-up).
Regulatory and institutional arrangements
54. The next section summarises the regulatory and institutional arrangements for 111 emergency calling service. It does not discuss the effectiveness and
adequacy of those arrangements. This is covered in chapter 7 of the discussion paper.
Current regulatory / legislative provisions
55. There are no legislative or regulatory requirements specific to 111 emergency calling service other than the following:
• The Telecommunications Act 2001 provides powers (section 157(ch)) to make regulations “setting out minimum standards for emergency call services and specifying which persons are subject to those requirements”. There are currently no regulations covering emergency call services.
• The Telecommunications Act 2001 provides for making, enforcing and funding Telecommunications Service Obligations (TSO) for the provision of ‘non-commercial’ services. There are currently two TSO agreements in the form of Deeds. They are:
o The 2001 Local Service TSO Deed between the Government and Telecom covering local residential telephone service. The Deed requires Telecom to provide standard residential telephone service to residential consumers including free genuine emergency calls. The service must meet a number of service performance standards with regard to 111 call answering by the ICAP.
o The Telecommunications Relay Service for meeting the functionally equivalent telephone communications needs of Deaf, deafblind, hearing impaired and speech impaired people. The Relay Service Provider is not contractually required to make available relay access to the 111 emergency calling system, and it therefore does not have a standard offering in this respect or arrangements to prioritise emergency versus non-emergency relay calls. However, relay call takers of the Relay Service Provider do sometimes facilitate calling to the 111 emergency calling system.
• The Telecommunications (TSO, Broadband and Other Matters) Amendment Act 2011 provides for the Telecommunications Development Levy to be used, among other things, for upgrades to the emergency calling system.
Governance
56. Currently, responsibility for governance of 111 calling emergency services involves both the Government and the telecommunications industry.
57. The interim governance arrangements that have been put in place since early 2010 are shown in Figure 3.
58. In summary:
• The Government has overall responsibility for policy and regulatory settings
• ESCAB facilitates overall coordination between government parties and industry parties.
• The TCF takes the lead role for its members in developing the voluntary Emergency Calling Code setting out the responsibilities of voice service providers
• Telecom is responsible for the ICAP and carrying calls through to handover points for emergency service provider communication centres
• The lead policy advisor to the Government is the Ministry of Economic Development (MED) on emergency call services up to the point where calls are handed over to ESPs
• The lead role on most operational matters relating to 111 services is taken by the NZ Police.
ESCAB (Emergency Services Calling Advisory Board)
59. ESCAB was set up in 2010 following the 111 service problems in 2009/10. Its task is to provide for better overview of 111 emergency calling services, and
coordination between Crown agencies, ESPs, and telecommunications service providers.
60. ESCAB’s Terms of Reference are provided in Appendix 2. ESCAB has no specific executive powers or dedicated resources. It is serviced by the TCF. Chairing is shared between MED and the TCF.
61. Current membership is as follows: • TCF
• Telecom • Vodafone • MED
• Department of Internal Affairs (DIA) • New Zealand Police
• New Zealand Fire Service
• Chair, Government Officials Working Party (ECSWG).
Emergency Telecommunications Services Steering Group (ETSSG)
62. The ETSSG is the coordination point for officials’ advice to Ministers and Cabinet on policy and the performance of 111 emergency services, covering both 111 emergency calling service and emergency service call response of ESP call centres. The group is chaired by the Deputy Commissioner of Police, and includes representatives from each of the Emergency Service Providers (police, fire and ambulance) and various relevant policy agencies (MED, DIA, and the Ministry of Civil Defence and Emergency Management).
Emergency Call Services Working Group (ECSWG)
63. The Emergency Call Services Working Group (ECSWG) is a committee of officials from government departments and ESPs. The group reports to the ETSSG and progresses the emergency calling component of ETSSG’s work programme.
TCF Emergency Calling Working Party
64. The Telecommunications Carriers’ Forum (TCF) is a telecommunications industry body comprising most telecommunications carriers and service providers in New Zealand. TCF membership is voluntary.
65. The TCF prepares telecommunications access codes for regulated services, and these are submitted for approval by the Commerce Commission, in accordance with the Telecommunications Act 2001. The TCF also prepares other
telecommunications codes, and facilitates dialogue on industry issues of common interest. It aims to foster cooperation among the telecommunications industry to enable the efficient provision of regulated and non-regulated
telecommunications services.
66. The TCF Emergency Calling Working Party, as implied by the name, is a working group of the TCF focusing on emergency services. Its membership, in addition to TCF members, includes representatives from NZ Police and MED, together with the Chair of the ECSWG.
TCF Emergency Calling Code
67. The TCF established an industry code of practice for emergency call services in 2009. The TCF Emergency Calling Code was upgraded in 2011 to include requirements for self-certification of compliance by code signatories.
Figure 3
worksite: 1104750111 Service Governance
Ministers Cabinet TCF Emergency Calling Working Party TCF Board Police lead (maintain documentation e.g.TESA data interface)
ECSWG
(Emergency Call Services Working Group)
Telecom lead (maintain documentation e.g.
NESA)
ETSSG
(Emergency Telecommunications Services Steering Group)
MED:
- administers MOU agreement with Telecom as the ICAP Operator
- administers 111 regulation making powers
Policy/Regulation Policy Operational Procedures Compliance Operational Procedures Strategy, Coordination & Standards
Government
Industry
Ministry of Economic Development (MED) Strategy, Coordination & StandardsEnforcement Agent for TCF Emergency Calling Code
Compliance
ESCAB
(Emergency Services Calling Advisory Board)
TCF Non-members TCF Members
68. The Code provides for:
• Minimum ‘technology-neutral’ service performance standards for signatory voice service providers (VSPs), including:
o priority handling of emergency calls o resilience and reliability
• Requirements and standards for provision of customer information (calling party number, name and location and/or registered address) to ESPs, including:
o The location type (fixed or other) for the customer’s access connection o originating cell site information for mobile phone calls
• Requirements for informing customers about the availability (and non-availability) and performance quality of emergency call services on the VSP’s network and services
• Requirements for handling customer complaints • Provisions for auditing, including:
o The ability of an ESP to request the TCF to undertake an independent audit of a voice service provider’s service performance
o Checking a voice service provider’s self-certification documentation • Enforcement processes and mechanisms, including:
o Provision for an enforcement agent to be appointed by the TCF that has the ability to issue voice service providers with caution notices, warning notices and public censure notices.
Telecommunications Emergency Service Addresses (TESA)
69. TESA contains caller name and address information to assist emergency service providers with caller identification and location. At present, only Telecom and TelstraClear provide information for TESA. Other voice service providers are in the process of implementing capabilities to also provide information to the system. The TCF Emergency Calling Code requires a voice service provider to provide this information to the extent it is known by the provider.
National Emergency Services Appreciation (NESA)
70. The National Emergency Services Appreciation (NESA) document specifies operational and technical requirements relating to 111 calls agreed between
Telecom and the ESPs. NESA details the pathways for routing calls and protocols for handing calls over from ICAP to the ESPs.
71. Telecom coordinates revision of NESA through the 111 Operational Group which meets quarterly. However, there is no formal process for proposed changes to NESA to be considered in relation to the TCF Emergency Calling Code or Telecom’s TSO emergency service requirements. There is also no formal process for approving proposed NESA changes through the ESCAB governance committee.
Monitoring and enforcement
72. Assessment of Telecom’s performance in meeting the requirements of the Local Service TSO is undertaken by the Commerce Commission.
73. Under the 2010 111 MOU between the Government and Telecom, Telecom is required to provide quarterly performance reports to MED. These are published on MED’s website. The MOU also provides for Government inspection (audit) of Telecom’s plans and processes for call taking, 111 network architecture, outage processes and Telecom’s business continuity plans relating to the 111 services. (The MOU expires 28 September 2012 unless new 111 arrangements are put in place earlier or it is extended by agreement).
74. As noted, the TCF Emergency Calling Code sets service standards for voice service providers (VSPs), powers for the TCF to audit performance, and for an escalating series of notices concerning breaches of standards by a VSP.
75. Also as noted earlier, the Government has the power to make regulations to set standards for emergency calling services, but has not to date done so.
Costs and funding
Telecom
76. The Local Service TSO is the agreement (in the form of a deed) between
Telecom and the Crown by which Telecom agrees to offer a standard residential service to residential customers, including free genuine emergency calls. The TSO regulatory framework provides for Telecom to be compensated via an industry levy if it incurs net costs from providing the TSO service, including free 111 calls for residential customers.
77. The Commerce Commission is responsible for determining whether Telecom incurs net costs from providing TSO services. The Commission has concluded in the past that the residual cost to Telecom of providing emergency call
its cost model and interconnection charges for 111 calls, was not material for the purposes of its overall TSO net cost calculation.
78. Telecom’s ICAP costs are met in part through an interconnection charge on other voice service providers of $2.36 per 111 call. This generates revenue of about $2m a year. Additionally, at an imputed cost of $2.36 per call, Telecom implicitly contributes approximately $2m a year to costs for 111 calls which are generated from its own originating networks (fixed and mobile).
TCF
79. The TCF’s operating costs are met from membership fees. The costs to parties participating in code formulation are met by those parties. The costs of code compliance by a code signatory are met by the code signatory.
Other costs, eg ESCAB
80. Other costs, for example for participation in ESCAB, are met by each party.
Description of the 111 calling system
2. Is the description of the 111 system in Chapter 4 accurate and
5. Accessibility, resilience and performance of the
111 calling system
Introduction
81. The 111 network system needs to be able to handle a wide range of situations, from normal ‘one-off’ emergencies to major events (such as a major weather event or fire) to disasters (such as the Christchurch earthquakes) where there are multiple emergencies and the 111 network itself is affected.
82. This chapter discusses access to and the resilience and performance of the current 111 network. The discussion considers:
• Originating networks
• Telecom’s PSTN and ICAP.
83. As a preliminary observation, no system or network can be guaranteed to work 100 percent of the time. However, the larger telecommunications networks tend to be more reliable than other infrastructure networks in part because of the multiplicity of alternative routes built into them at each stage.
Originating networks
84. The originating networks for 111 calls are the networks owned by various
telecommunications service providers (including Telecom) which route 111 calls from callers through to Telecom’s PSTN. As noted earlier, the networks include:
• fixed and mobile networks between a calling device (fixed, mobile or VOIP) and a local aggregation point, such as a cellular base station or cell tower region, DSLAM or a fixed network telephone exchange
• connections (fixed or wireless) from the local aggregation point to an interconnection point with Telecom’s PSTN.
85. Resilience in originating networks has multiple dimensions:
Handsets
• If a mobile phone is locked, or if it is a prepay phone that has run out of credit, it is still able to make a free 111 call
• If a fixed line telephone has been temporarily disconnected, say for non-payment or relinquishment, it is still able to make a 111 call
Cellphone towers
• If a cell tower has failed, for example because it has been hit by a vehicle, other cell towers in the same vicinity may be able to receive the 111 call because they have overlapping coverage. The fixed telephone network also acts as a backup or an alternative to failures of the cellular networks and vice versa
• If a cellular network has a major network failure, mobile phones may be able to roam on to an alternative network to make emergency calls (called ‘SOS roaming’) where the handset is technically compatible
• Telecom and Vodafone have cellular-on-wheels (COWs) apparatus that they can often bring to the site of a failure at relatively short notice
• A common fault that affects local originating networks is power failure – cell towers and exchanges have backup power supplies, generally batteries, to allow them to keep working for a period of time until power can be restored. They also have sockets on the outside of the cabinet to allow portable electricity generators to be connected to keep batteries charged
Connections
• Most networks have multiple (meshed) connections between mobile phone towers and local exchanges and the 111 system on Telecom’s PSTN
• Capacity on alternative routes is unlikely to be a major issue since 111 calls have priority
• There are four cables and therefore routes between the North and South Islands each of which has sufficient capacity to handle all 111 calls
Asset management, fault remediation and contingency planning
• All operators should have in place underlying network lifecycle maintenance and replacement plans
• All network providers maintain a constant watch on their networks, have alarm systems that inform them of any failures and have service personnel on 24/7 standby. Telecom also notifies the emergency services immediately there is a significant failure in its networks.
Potential problems in originating networks
86. Not all the resilience measures described above are consistently in place - they vary according to location, the network technology (i.e. cellular, fixed wireless, copper, fibre) and the network operator. For example:
• Overlap between cell sites of separate mobile networks is much less prevalent in rural areas
• The ability of some mobile phones to SOS roam is restricted by the frequencies they use
• The battery life of back-up power systems may vary between sites and operators
• The non-availability of local mains power will impact on service availability on:
o cordless phones attached to a fixed network
o VOIP calling devices due to local modem, wireless hub or DSLAM failure
o Mobile phones where cell sites exhaust standby power arrangements
• The average time for a technician to attend and repair a fault varies depending upon location
• There are no agreed standards for the number of routes between an originating base station and interconnection with the 111 system on Telecom’s PSTN
• The connection point between a caller and a cellular base station or a fixed telephone exchange is a potential single point of failure
• There are no standards for the level of duplication or back-up of assets that are required at interconnection points. Similarly, there are no standards for the maximum number of customers connected to a potential single point of failure.
The 111 system on Telecom’s PSTN and ICAP
87. The 111 system on Telecom’s PSTN aggregates traffic at the points of interconnection and takes calls through to the Initial Call Answering Platform (ICAP) call centres where they are answered and, if genuine, routed to the requested emergency service provider.
88. Resilience of 111 calling on the PSTN is ensured by:
• Telecom operates dedicated and triplicated 111 capacity from both its local switched network and the 29 points of interconnection with the fixed and mobile networks of other telecommunications service providers • All 111 calls enter the dedicated 111 network at one of six core
Frankton, Palmerston North, Wellington, and Riccarton). All core exchanges are capable of handling all 111 calls if necessary
• Two of the core PSTN exchanges (Palmerston North and Christchurch) route all 111 calls, through multiple dedicated lines, to ICAP call centres. Either switch is capable of handling all 111 calls
• There are ICAP call centres in Wellington and Christchurch with back-up centres in Palmerston North and Rangiora
• There are multiple dedicated lines from ICAP call centres to emergency services call centres
• The ability for calls to overflow on to the general trunk network if there is a fault or congestion on the dedicated lines
• Ability to move trained staff from other activities into ICAP positions immediately and for any ICAP centre to handle all 111 calls
• Ability to bring the Palmerston North back-up ICAP call centre “on-line” within 24 hours
• Ability to relocate, or create a new ICAP call centre relatively quickly – for example, the Christchurch ICAP was relocated within five days to Rangiora following the 22 February earthquake
• Contingency plans available to be put in place where necessary
• Deployment of the ‘Crisis IVR’ (Interactive Voice Response) in the event that neither ICAP centre is available, which allows callers to self-select an emergency service provider (through pressing a keypad number) • As with its originating networks, Telecom has maintenance programmes
and a control room managing the dedicated networks 24/7 and is able to respond to faults immediately.
Potential problems in the 111 network
89. Following the fault at Papatoetoe in February 2010 Telecom undertook a major internal review of the network. The Government also undertook a review to ascertain the cause of the failure. Following these reviews the 111 MOU was agreed which allows the Government to audit the network.
90. Telecom has also put in place a number of significant changes, including the addition of a third ‘out-of-region’ interconnection point and reviews of pre-plans and operational procedures.
• Whether two operational ICAP switches nationally is sufficient
• Whether the 111 network nationally could perform satisfactorily to ensure 111 calls are completed if a civil defence incident occurred in Auckland on a similar magnitude to the Christchurch earthquake
• Whether there is sufficient route diversity (switch and transmission) in the South Island to immediately divert 111 calls to the North Island if the 111 network in Canterbury experienced a total and prolonged outage
• Whether there is alignment across contingency plans of the telecommunications industry and emergency service providers.
Performance of the ICAP call centres
92. The 111 MOU requires Telecom to provide detailed quarterly reporting on the performance of the 111 calling system, and in particular the performance of the ICAP call centres. These reports (as noted earlier) are published on MED’s website.2 In addition, Telecom provides more detailed (unpublished) quarterly operational reports to emergency service providers.
93. By and large, these reports and the Christchurch earthquake review indicate that the ICAP call centres are performing well. Indicative information shows:
• ICAP answering times are well within the (admittedly easy) specified targets in the 2001 TSO Deed, which requires 85 percent of calls to be answered within 15 seconds
• However, in the first 6 months of 2011 the percentage of callers waiting for more than 15 seconds has steadily increased from around 1 percent of calls to 2 to 2.5% of total calls (most likely attributable to the earthquakes)
• Average handling times for calls has steadily reduced over the last year (ie calls are being passed more quickly to emergency services communication centres)
• The ICAP call centres coped well with the 22 February Christchurch earthquake. Contingency plans were activated when the ICAP call centre in central Christchurch had to be evacuated. The Wellington ICAP was able to cope with the additional load until the Palmerston North ICAP was activated (within 24 hours) and then the Christchurch ICAP was relocated to Rangiora (within 5 days).
94. An important point to note however is that ICAP call centre performance is affected by:
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• The volume of non-genuine calls, which take up operator time and resources. As noted earlier, the volume of non-genuine calls is steadily increasing
• The performance of the ESP call centres. ICAP operators stay on the line with a 111 caller until the call is satisfactorily connected to an ESP operator. Accordingly, any delays in answering by ESP operators can affect the performance of the ICAP call centres.
Christchurch earthquakes
95. The MED commissioned a study3
to investigate the impact of the 22 February 2011 Christchurch earthquakes on 111 services. The earthquake caused a large spike in the volume of 111 calls at a time when 111 services were also subject to significant stress. The Christchurch impact briefly took national volumes to a level approximately three times normal.
96. The study notes the impact of electricity outages, cable failures in liquefaction areas and congestion on the ability to make 111 and other calls immediately after the earthquake. Some physical damage to telecommunications assets occurred but the effects were secondary. Contingency plans were in place and put into operation. Faults were generally quickly repaired or temporary
alternatives put in place.
97. The 111 system on Telecom’s PSTN also showed good resilience for an earthquake event on the scale experienced in Canterbury. The Central
Christchurch ICAP call centre was evacuated within minutes of the earthquake and all calls were handled by increasing the number of operators at the
Wellington ICAP. The Palmerston North ICAP centre was activated within 24 hours and the Christchurch ICAP centre was re-established at Rangiora within 5 days.
98. The Police and Fire Emergency Services call centre in central Christchurch remained staffed throughout the earthquake period and despite a substantial amount of damage to the core network the network connections to the call centre were maintained. Business Continuity Plans were followed by the ESPs and overall these plans proved to be effective.
99. Thus, congestion and call failures largely resulted from a sudden substantial increase in call attempts rather than equipment failure. An unknown number of 111 calls failed to complete due to interconnection and exchange congestion in the immediate post-earthquake period despite buffer capacity and overflow arrangements. It seems reasonable to assume however, that most of the callers would have succeeded with redialling / retries or by using other telephones (e.g. landlines), or the emergency could have been notified by another person at the site.
3
“Emergency Telephone Call Services and the February 2011 Christchurch Earthquake” - Tony Fenwick, August 2011.
Accessibility, resilience and performance of the 111 calling system
3. Are the main risks and vulnerabilities in the 111 system
adequately covered in chapter 5? What other threats are there and how are they best managed?
4. Are the ICAP centres performing satisfactorily? If not, what are
the main problems? What needs to be done to address them?
5. Do you agree that the 111 calling system performed well during
6. Technology trends and challenges
Introduction
100. The current telecommunications sector is characterised by significant technological change. These changes have raised and are raising new challenges, and opportunities, for the provision of 111 calling services. 101. The biggest changes can be summarised as follows:
• The development of new network technologies, particularly IP (Internet Protocol). This, combined with the accelerated roll-out of fibre, including through the Government’s UFB and RBI programmes, is rapidly changing the technological and business landscape in telecommunications. Network providers are progressively converting their core networks to IP-based technologies
• The increasing ubiquity and functionality of mobile telephony
• The emergence of VOIP (Voice-Over-Internet-Protocol) devices, which provide multiple functionality, including telephony, through a single broadband connection. These devices can be taken from location to location and plugged in wherever there is internet access, including wireless access
• Changes in the way people want to access emergency calling services (mobile, VOIP, text, social media).
102. At the same time, and partly related to the changing technological
environment and the opportunities it creates, there are significant changes in the competitive landscape, with the emergence of new network and service
providers. Combined with the development of new technologies, this has resulted in a much more complicated telecommunications environment.
103. The main technology challenges and opportunities this raises for 111 services are canvassed in this chapter. The discussion does not seek to reach
conclusions on specific issues, but does conclude with a brief discussion on good processes for resolving issues, which links through to the next chapter on governance.
104. The main technological challenges and opportunities considered in this chapter to improve public safety are:
• Caller location information for mobile phones and VOIP devices • Non-genuine calls
• Powering VOIP and PC-connected devices
Caller location
105. Emergency service operators (police, fire, ambulance) answering 111 calls ask for the name and location of callers. It is important, however, for ESPs to have back-up information automatically available to them on the caller’s location, in case the caller is unable to speak or communicate effectively (for example, someone under duress or badly injured or sick) or does not know their specific address location (for example in a traffic accident). Location information is automatically available through the TESA (Telecommunications Emergency Services Addresses) database for land-lines, but this covers only about 40 percent of calls.4 TESA does not contain location data for mobile phone
customers or for fixed broadband lines which originate telephone calls by VOIP.
Mobile telephones
106. The location of callers using mobile phones is not independently available at present to emergency service providers. This is a significant public safety issue since calls from mobile phones comprise the majority of 111 calls and are steadily increasing.
107. The TCF Emergency Calling Code requires signatory VSPs to provide:
• Subscriber details to a National Locations Register (in effect TESA), and to keep it up-dated. (Currently, the location type identified in the Register for a subscriber’s access connection is at a high level – labelled either as ‘fixed’ or ‘unknown’.)
• Emergency contact numbers for VSPs so that ESPs can seek further assistance with subscriber details where up-to-date subscriber information is not available.
108. With mobile phones however, the caller is probably not calling from their subscriber address. Two technologies (cell site triangulation and GPS) have the potential to provide more accurate caller location information to ESPs.
109. Most mobile phone calls are picked up by more than one cellphone base station. This allows for the location of callers, with varying degrees of accuracy, to be determined through triangulation. Cell site triangulation is not quite as accurate as GPS (see below) but is a lot less expensive and can locate a call inside buildings. However, cell site triangulation is generally ineffective outside main centres, because of the lower density of cellphone towers. Furthermore
4
triangulation requires technical capabilities that may not be available in emergency service communication centres.
110. Where mobile phones are fitted with Global Positioning System (GPS) devices, the location of a caller can be identified from a satellite while the 111 call is in progress. Some jurisdictions, such as the USA, are making GPS
technologies mandatory in new mobile phones. This raises the issue of whether such devices should be mandatory here. Considerations include:
• GPS technology on satellites currently does not work well inside buildings
• The cost of a GPS chip in a mobile phone and the satellite-based technology is expensive although reducing over time, but the end-user will pay for both
• In some countries the cost of GPS capability can be recouped through commercial applications, for example, the technology can be used to advertise to shoppers who are identified as passing a particular shop • The cost for this technology has to be weighed against the number of
occasions where the person making the call is unable to say where they are, which is quite small. Furthermore, any mandated features which increase the cost of mobile phones may have a negative effect on public safety by reducing the uptake and availability of mobile phones (compared to otherwise).
VOIP
111. As next generation networks are deployed, traditional calls, including 111 calls, will increasingly be made using VOIP devices.5 VOIP devices are
potentially nomadic, since they can be connected wherever broadband internet access is available, including Wi-Fi hot spots. The linking of telephone numbers and IP addresses presents considerable complexity in the provision of location information. Thus, caller location information with VOIP is generally unknown or unreliable.
112. Currently, the volume of emergency calls from VOIP handsets is a small proportion of total emergency calls, but is increasing. VOIP services are multi-functional, including voice services, and can provide considerable cost savings for long-distance calling compared to traditional technologies (land-lines) and mobiles.
5
113. The technology exists to identify the source location of a VOIP call, or at least the location of the Wi-Fi hot spot, but may involve some cost for the service provider, as well as coordination between ISPs and the VOIP service provider. It has been mandated in the USA. An emerging issue will be whether VOIP service providers should be required to configure their networks to provide location information for VOIP devices.
Non-genuine calls / false calls
114. False calls are a major issue. They waste resources and result in poorer handling of genuine emergencies. Of course, false calls are not new but the incidence of false calls has increased markedly with the increased use of mobile phones for 111 calls.
115. As noted earlier, about 50 percent of 111 calls handled by ICAP operators are false calls. Much of this is made up of:
• Mobile phone users inadvertently depressing the 1 key repeatedly. Number locks do not generally prevent 111 dialling.
• Some phones have the code *111 as an internal code to allow pre-pay top-ups or voice-mail navigation. Accidental pressing of a “redial” key subsequently can initiate an emergency call
• Children playing with phones including discarded prepay phones (111 calls can be made from prepay phones which have no credit on them). 116. There are a number of options for addressing the incidence of false calls.
These include:
• undertaking public awareness programmes informing the public of the dangers and the cost of false calls. It is not clear the extent to which such campaigns are effective, and funding availability and allocation of costs would likely be an issue
• changing the 111 number to one which is less vulnerable to being inadvertently dialled such as 112.6 Changing the number would be
costly. Moreover, 111 would have to be retained as an emergency number for a long transition period
• more active use of the ability to impose penalties for false calls
6
The emergency call number recommended by the ITU (International Telecommunications Union) is 112. The EU promotes 112 as a pan-Europe emergency number. The USA uses 911. The UK uses 999 or 112 (mobile phones). Australia uses 000 or 112 (mobile phones). Most GSM mobile phones are pre-programmed with 112 as an emergency calling number.
• the allocation of alternative or additional emergency service numbers including numbers for non-emergency calls. For example, in some countries different numbers are used for police, fire and medical emergencies.
• introducing penalty interconnection charges for telecommunication service providers for non-genuine calls. This would incentivise them to take more active steps to reduce the incidence of non-genuine calls.
New services
117. New technologies have also allowed the development of new services, such as SMS texting, and broadcast warnings.
SMS texting
118. While text has become prevalent in everyday use, its usefulness for accessing emergency services is problematic. Key issues are:
• it uses “store and forward” technology so delays can occur (in the Christchurch earthquake there were reports that text messages were taking 20 minutes to get through)
• emergency services personnel need to speak to the person calling to ascertain the nature and location of the emergency
• allowing text 111 calling would have material resource and response time implications for ESP communication centres, as communicating via texting and similar media is more time consuming than voice communication.
119. The ability to text 111 is currently restricted to registered deaf and hearing impaired people. Calls from unregistered phones receive a text reply informing them that there is no general 111 text service. An issue to be considered is whether the current service for the deaf community should be made available to other people.
Broadcast text or voice messages
120. A “broadcast” SMS text or voice mail message may be useful to alert people to an emergency event such as a tsunami. The Ministry of Civil Defence and Emergency Management (MCDEM) is investigating the establishment of a system to perform this function.7 However, implementation depends on funding availability.
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Powering VOIP and cordless phones
121. Power required to make a telephone call from a copper fixed line in the traditional way is fed from the telephone exchange. VOIP phones cannot be powered in this way and therefore have to be powered at the user’s premises. Telecommunications network operators typically install back-up power supplies and alarm systems in exchanges to provide a high level of service availability such as during power outages. Consequently, the increased use of VOIP
phones without reliable power backup to protect against mains failure, especially as a replacement for a traditional fixed line phone, makes an increasing
proportion of telephone calling vulnerable to mains electricity failure.
122. The current TCF Code for house wiring refers to uninterrupted power supply (UPS) equipment as discretionary. Consideration needs to be given to whether such equipment should be made available by all telecommunications service providers supplying telephone service.8
Process requirements/considerations regarding new issues
123. The above issues need careful evaluation. The questions to be asked are: will the cost exceed the benefit? Are there alternative solutions with a better cost benefit ratio? And, who bears the cost?
124. Key process requirements include:
• the decision-making process has available all the relevant information to inform the decision, including careful cost-benefit consideration
• all affected parties are consulted, including ESPs and industry parties • decisions are made at the appropriate level and commercial
considerations are taken into account
• the introduction of new technologies and services considers the impacts on 111 emergency calling.
125. The next chapter considers whether the current governance systems are well-placed to address these issues in an effective and timely way.
8
There is an argument that the reliability of telephone calling from fixed lines for emergency purposes is not as important in areas where reliable mobile telephone service is available for emergency calling. Line powering for telephone service is also an issue raised with the migration of the Telecom PSTN from TDM (time division multiplexing) to IP technology. It may be best to consider the issue of line powering for emergency calling within the wider industry work on the migration of telephone services from TDM technology to IP based technology.
Technology challenges and opportunities
6. Are the main technology challenges and opportunities properly
identified in chapter 6?
7. Are the key process requirements for considering the issues
arising from technology challenges and opportunities properly identified in chapter 6?
