ESTA SUBMISSION to ECS DETERMINATION REVIEW July 2008

Transcription

1 ESTA SUBMISSION to ECS DETERMINATION REVIEW July 2008 The Emergency Services Telecommunications Authority (ESTA) is a Victorian statutory Authority and has legislative responsibility for handling Triple Zero calls presented by the ECP, dispatching emergency organisations and providing emergency communications for Victorian communities. ESTA currently provides call taking and dispatch services for metropolitan police, fire, ambulance and SES, and rural and regional fire (CFA) and SES. Q1. Comments to the Discussion Paper Questions. We would expect that any service provider to the ECS would be required by law to ensure that a call to the ECS could be appropriately identified by, at the very least, the subscribers billing address and any other information as relevant. Q2. As Above it should be legislated that the service providers are made responsible for technical changes and delivery of information to the ECS and to emergency services. The responsibility for this cannot be devolved to emergency service organisations. Q3. ESTA is unable to comment on future technologies in the marketplace however we would expect that the service provider to the ECS would be responsible for ensuring that all calls included voice and data. ESTA does not have the capacity for accepting other media at present. A common platform across all emergency services would be required. Q4. This would assist in removing the potential for error but is not a guarantee of an actual location. This would be seen as an interim measure. ESTA submission to ECS determination review July

2 Q5. The discussion paper states Currently it is reasonable to assume, at least for metropolitan and regional services, that the end-user will be fairly close to the point of interconnection to the internet. This assumption should not be used to base a determination ESTA is unaware of the full gamut of technical solutions for mobile, satellite and VoIP services and is unable to comment. It would be difficult to provide a commercial incentive to a service provider when they already have an obligation to provide the appropriate customer data to the ECS and, if they are not currently covered by the Determination they should be. Q6. Calls from VoIP services are treated in the same manner as all calls presented to ESTA. The CLI reference data is presented by the ECP to the call taker. After questioning the caller as to their location this CLI data may be copied into the CAD event. Location information must be provided by the caller once confirmed it is sent to a dispatcher for advice to the attending emergency service. All data (including CLI data presented) is captured. This process could be improved by the provision of the subscribers billing address (as in the case of mobile services). Q7. As commented above ESTA is unaware of current technology available to service providers however it should be a legal requirement on any service provider delivering calls to the ECS to provide the subscribers billing address. Q8. ESTA is unaware of current technology available to service providers to address these concerns however the Federal Government must mandate the provision of information to the ECS from any service provider. Q9. ESTA is unable to comment on the process for updating IPND records however more stringent quality assurance of IPND data and subsequent action on service providers should be adopted where incorrect or false data has been identified. Q10. Yes ESTA submission to ECS determination review July

3 Q11. We raise the question Is there any evidence or statistical data available on the number of private VoIP gateway users? The AAF appears to be a measure which is currently available but would not be an acceptable long term solution. Again the service providers must have a mandatory requirement to provide the most accurate location data as they can. Q12. We note that the ECS does not currently impose performance standards on the ECS. Having said that it would be more beneficial to the person calling having a location verified before presentation to ESTA. This would remove the possibility of incorrect switching of calls but would elongate the call handling time at the ECS. Q13. ESTA is unaware of the full gamut of technical solutions for mobile, satellite and VoIP services and is unable to comment Q14. (a) ESTA is unable to comment on technical solutions however the requirement on the ECS should be the provision of voice and data containing the most accurate location data to ESTA. (b) Not known (c) Yes. At a minimum the information provided in Section of the Discussion document (d) This should be driven by regulatory intervention and ACMA should take an active role in enforcing compliance. Q15. It is clear that the obligation for any service provider directing calls to the ECS be required to provide at a minimum the information contained in Section of the Discussion document. Information provided to subscribers of VoIP and all other nomadic services must be informative and the levels of service, particularly in relation to calling 000, must be acknowledged by the subscriber. ESTA submission to ECS determination review July

4 Q16. The provision of calls to 106 should mirror the requirements of calls to 000 regardless of any perceived technical or financial impediments to ensure continuity of service to the community. Q17. Any nomadic service provider must be required to provide accurate location data to the ECP for transfer to emergency services in the first instance Q18. (a) ESTA is unable to comment on technical solutions however Type 2 VoIP Out services should not have access to the ECS and subscribers advised to use alternate means to call 000 unless subscriber billing details are provided to the ECS, and an alternate call back number provided. (b) This would be best assessed by ACMA (c) We would consider this approach to be assessed in light of any revised determination. The provision of discretion by ACMA in this area has led, in the past, to indecision and extended delays in the interpretation of the Determination in light of new and emerging communications technologies. Whilst not specifying particular criteria it would be appropriate to base the criteria on the needs of the agencies involved in accepting 000 calls from the ECS. Q19. Yes. Q20. The immediate introduction on the ban to SIM-Less Calls would assist. ESTA would also recommend ongoing reviews via a consultative forum such as NECWG/ECSAC to discuss as a regular Agenda Item. Q21. None known. Q22. Ongoing public education and punitive financial measures if appropriate. ESTA submission to ECS determination review July

5 Q23. Ongoing public education and punitive financial measures if appropriate. Q24. The change to the Determination to require all service providers to provide, at a minimum, subscribers billing address would at least provide a starting point for investigation and prosecution. The service providers must also take responsibility of the quality of all information supplied to the ECS. If currently not in place, the provision of Nuisance Caller RVA for the ECS would be recommended. Q25. ESTA is unable to comment on technical solutions and any service providers who are outside of the control of the Determination should be excluded from presenting calls to the ECS. Q26. ESTA is not qualified and is unable to comment on technical solutions. Q27. No. The requirement for all service providers should be to provide accurate location information to the ECS or be excluded. Q28. Bearing in mind the number of communications options available to the public it would be reasonable to assume that the definition reflected any communications service able to be used by a member of the public. Q No comment other than any subjective statements made in the Determination can result in interpretive issues. Q37. No. Public knowledge would create confusion and dilute the Triple Zero message which has been consistently been marketed to the public. ESTA submission to ECS determination review July

6 Q38. ESTA does not support SMS to 000 as there are many issues associated with obtaining accurate location and incident information. Access to 106 via SMS would be incumbent on the National Relay Service to accept and ESTA is unable to comment further. Q39. As a general comment, simplification of the Determination may be appropriate in some areas but any subjective components should be reviewed and updated as appropriate. The process for amendments to the Determination (to take into account changing and emerging technologies) should be quicker. The fact that it has taken many years for the regulator to make a decision on SIM-less is a prime example of where the process should be more streamlined and transparent. Q40. No comment Q41. No comment Q42. Yes as per answer to Q39. Q43. The obligations should be flexible enough to accommodate changes. Q44. The arrangements should be clearly defined and agreed in writing to ensure transparency. Q45. As per above answer to Q44. ESTA submission to ECS determination review July

7 Q46. No the Determination is sufficient. Q47. ESTA receives calls from restricted services which are of either a nuisance or a non emergency nature. These people should be prosecuted and, if they continue to offend, there should be a provision within the Determination to remove service to 000 services by the carrier (subject to appropriate agreed procedures etc). Q48. No comment Q49. There appears to be no issue with the current obligations in this Section. Q50. The Determination must be flexible to accommodate changes in technology where the ECS may be threatened by external influencers or terrorist activity. In simple terms, if a call is presented to the ECP without the appropriate data protocols it should be terminated. Q51. ESTA is unable to comment on technical solutions and any service providers who are outside of the control of the Determination should be excluded from presenting calls to the ECS. Q52. As per above answer to Q51. Q53. There should be no boundary issues if the caller to the ECP has been questioned correctly by the ECP call taker. Q54. ESTA submission to ECS determination review July

8 Q55. Performance standards are an essential component for the ECS to ensure that service delivery can be measured and reported. When determining standards it is extremely difficult to take into account all the impacting factors beyond the ECP s control (such as major events where emergency services are unable to cope with demand and the ECP is unable to transfer the call and must wait for an available slot). ESTA has had similar issues with SES and Fire Services performance standards where defined high periods of activity are excluded from performance measures. Q56. Service measures are appropriate however they need to be able to take into account situations as described above. They should be drafted in consultation with the ECP and service providers, ACMA and emergency services. Q57. As a general comment any conflicts within the Determination should be amended to reflect the requirement that, as a minimum, all subscriber and relevant location information is passed to the emergency service call taker. Q58. There is a need for the Determination to include appropriate definitions that are easily understood by the affected parties. Plain English is preferred to ensure that technological definitions are clearly understood. Q59. As per answer to Q17. Q60. As per Answer to Q57. Q61. Q62. As per Answer to Q57. ESTA submission to ECS determination review July

9 General note: - Re Chapter 6 WE advise that this Section should be explored as a part of any Determination review as funding is a key issue with the ECP s capacity to move and adapt to technical advances. This should be addressed by the Authority. Q63. Q64. Q65. ESTA has no visibility of the ECP statistics. Transparency of these statistics may be useful. Q66. ESTA submission to ECS determination review July