5. EXPERIENCIAS INTERNACIONALES Y LOS LÍMITES AL MOVIMIENTO INTERNACIONAL DE CAPITALES EN EL FUTURO.
5.3. Limites a los movimientos de capital en el futuro.
8.1 Access to the emergency call service
Under the Telecommunications (Consumer Protection and Service Standards) Act 1999
(TCPSS Act), a carriage service provider that supplies an STS should provide each end-user of that service with access to the emergency call service, unless the ACA considers that it would be unreasonable for such access to be provided—subsection147(2)(a). Accordingly, the access obligations under the Telecommunications (Emergency Call Service) Determination 200212 apply to carriage service providers supplying an STS that an end-user would reasonably choose, as a first choice, to make an emergency call.
The reason for stipulating ‘as a first choice’ was to avoid placing obligations on carriage service providers that offer services such as long distance or international services and did not offer a local access service. It was not intended to enable services providers supplying an STS to avoid providing users with emergency call access simply because they were using a different access technique. It would not appear ‘unreasonable’ for access to the emergency call services to be provided from VoIP services that fall within the definition of an STS. Accordingly, the ACA may need to consider amending the Emergency Call Service Determination to ensure that the objective of the TCPSS Act is fulfilled.
Question 8.1: What are the implications of requiring all VoIP services to meet emergency call services calling obligations? What are the limitations?
Question 8.2: What information do consumers need about the emergency call capabilities of a VoIP service they may use or intend to use?
8.2 Location information
The Emergency Call Service Determination also sets out requirements for providing information to the IPND about the location of the STS. This information is used in the routing of emergency calls to the emergency service organisation’s answering point that is the closest to the caller. For services that originate calls through a fixed network, service providers are required to supply the IPND with:
•
correct information about the location of the service if the service is supplied to residential customers as a single line service; or•
if the service falls within the definition of a ‘fixed local service’:i. correct information about the current location of the service, to the extent that the provider knows the location; and
ii. advice that the service may not be at that location or that an emergency call using the service may be of uncertain origin.
The latter category recognises that the location of some services may be affected by actions taken by the end-user without reference to the service provider, for example, through the programming of a PABX system. In such circumstances, service providers are able to indicate that the location of a ‘fixed local service’ is uncertain by setting the Alternate Address flag to ‘true’ in the record for that telephone service that is supplied to the IPND.
For services that originate through a mobile network, the service provider must supply the emergency call person with information about the caller’s location in accordance with the ACIF guideline ACIF G530:1999 Mobile Location Indicator for Emergency Services—Stage 1 Service Description Interim Mobile Location Indicator. This involves appending a three-digit location indicator code, representing a standardised mobile service area, to the dialled digits in the destination number field in the relevant signalling scheme.
In the short term, it is likely that some VoIP services will fall into the categories of ‘residential single line service’ or ‘fixed local service’. In such cases, the existing provisions in the Emergency Call Service Determination would provide for appropriate information about the
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location of the service, and an indication of the reliability of that information, to be included in the IPND. However, because of the potential for end-users of VoIP services to be nomadic, without any reference to the service provider, the Emergency Call Service Determination would need to be amended to accommodate such services. The amendment would need to require VoIP service providers to indicate in the IPND that the actual service may not be at the recorded address and could relate specifically to services of type ‘nomadic’ as nominated by the provider and discussed elsewhere in this paper.
A location indicator code might also be provided to the emergency call person in conjunction with any emergency calls from nominated VoIP services similar to the indicator codes that accompany emergency calls from mobile phones. The ACIF G557:2002 Standardised Mobile Service Area Register contains a list of eight three-digit codes for use in conjunction with VoIP calls to the emergency call service.
For example, as happens currently with 000 calls from cellular services, appending the code ‘982’ to the dialled digits in the destination number field in the relevant signalling scheme may indicate to the emergency call person that the call originated from a VoIP service in part of New South Wales. This type of information would be useful to the emergency call person because it would indicate that the location information recorded in the IPND may be unreliable and would prompt the emergency call-taker to ask the caller to identify their location. This is common practice for emergency calls from cellular services.
Any amendment to the Emergency Call Service Determination to better accommodate VoIP services could make it mandatory that VoIP service providers use the appropriate location indicator code to indicate when an emergency call has originated from a VoIP service. Combined with the inclusion of appropriate information in the IPND, such a measure might satisfactorily address the need of emergency service organisations for information about the location of emergency callers until such time as the broader issue of locating VoIP callers is resolved internationally.
Question 8.3: What are the implications of requiring VoIP services to provide location information to the emergency call person?
Question 8.4: What is the future outlook for the provision of location information for emergency access calls?
8.3 Calling line identification
The Emergency Call Service Determination also requires service providers to ensure that, ‘as far as practicable’, calling line identification (CLI) is provided to the emergency call person in conjunction with emergency calls. The purpose is to assist the emergency service person to direct the emergency response efficiently. Specific exemptions exist for circumstances where the service provider cannot identify the caller’s CLI—mobile calls from SIM-less GSM mobiles phones and mobile calls from domestic or international roamers.
Question 8.6: What are the implications of requiring that VoIP services provide CLI to the emergency call person?
Question 8.7: What other issues arise in the presentation of VoIP calling line information to the emergency call person, to other end-users and to other network operators?
8.4 Origin-dependent routed calls
Services offered on 13/1300 and 1800 numbers may also use location information to route the calls in accordance with the wishes of the customer of the 13/1300 or 1800 service, for
example, to a particular retail outlet. These call services could use either the real-time location of the A-party or the nominal/usual location of the VoIP service to route that call.
Question 8.8: What are the service options and the implications for the A and B parties when 1800 or 13/1300 calls originate from VoIP services?
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