111 Emergency Calling Review

Transcription

1 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). It does not cover the response of emergency services to 111 calls.

2 Table of Contents 1. INTRODUCTION EXECUTIVE SUMMARY BACKGROUND THE 111 CALLING SYSTEM RESILIENCE AND PERFORMANCE OF THE 111 CALLING SYSTEM TECHNOLOGY TRENDS AND CHALLENGES GOVERNANCE: ARE CURRENT ARRANGEMENTS SATISFACTORY? ICAP: ARE CURRENT ARRANGEMENTS SATISFACTORY? GLOSSARY LIST OF QUESTIONS APPENDIX 1: TERMS OF REFERENCE FOR THE EMERGENCY CALLING SERVICE REVIEW APPENDIX 2: EMERGENCY SERVICES CALLING ADVISORY BOARD ISBN (PDF) ISBN (Print) 2

3 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 111review@med.govt.nz or to: 111 Review Ministry of Economic Development PO Box 1473 Wellington

4 Publication and public release of submissions 7. Our intention is to publish all submissions on the Ministry website 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 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 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. 4

5 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 5

6 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) 6

7 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 111 SMS texting (which is currently only available for registered deaf and 7

8 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 8

9 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 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 Tendering the ICAP service. 9

10 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

11 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. 11

12 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 be available for people who are hearing impaired, speech impaired or deaf. 12

13 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 communicationsimpaired 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 in paragraph 43 satisfactory? If not, what changes should be made? 13

14 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 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 nongenuine. 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 14

15 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 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 centreby-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. 15

16 Figure Emergency Call Handling 16

17 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 nationwide: 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. Adapted from Telecom s 111 MOU Schedule 2 Report (on 17

18 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. 18

19 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 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 19

20 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. 20

21 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 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 The TCF Emergency Calling Code was upgraded in 2011 to include requirements for self-certification of compliance by code signatories. 21

22 Figure 3 Government 111 Service Governance Industry Policy/Regulation Cabinet Policy Ministers Ministry of Economic Development (MED) TCF Board Strategy, Coordination & Standards Strategy, Coordination & Standards ETSSG (Emergency Telecommunications Services Steering Group) ESCAB (Emergency Services Calling Advisory Board) TCF Emergency Calling Working Party ECSWG (Emergency Call Services Working Group) TCF Members TCF Non-members Operational Procedures Police lead (maintain documentation e.g. TESA data interface) Operational Procedures Telecom lead (maintain documentation e.g. NESA) Compliance MED: - administers MOU agreement with Telecom as the ICAP Operator - administers 111 regulation making powers Compliance Enforcement Agent for TCF Emergency Calling Code worksite:

23 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 nonavailability) 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 23

24 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 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 services to TSO customers, after accounting for PSTN costs already included in 24

25 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 sufficiently comprehensive (for this paper)? 25

26 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 nonpayment or relinquishment, it is still able to make a 111 call 26

27 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: 27

28 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 inter- PSTN exchanges (located at North Shore, Papatoetoe, Hamilton, 28

29 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. 91. Further investigation and analysis may be warranted into: 29

30 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: aspx 30