"Science fiction does not remain fiction for long. And certainly not on the Internet" - Vinton Cerf, Internet Pioneer.

"Science fiction does not remain fiction for long. And certainly not on the Internet" - Vinton Cerf, Internet Pioneer VoIP and 000 An overview of what the Emergency Call Service, Police and Emergency Service Communications Centres need to know about calls from the public and use of IP technology. Version 1.0 April 24, 2008 Written by: James P. Cavanagh APCOA Member Knowledge Transfer Agent, Training Institute for Public Safety (TIPS) jpc@911tip.org P.J. Ferguson APCOA Member Inspector, Victoria Police Specialist Support Portfolio Police Communications (D24) Division peter.ferguson@police.vic.gov.au APCO AUSTRALASIA (APCOA) www.apcoaust.com.au 2008 APCOA All rights reserved.

Table of Contents OVERVIEW... 1 The Advancement of Technology... 1 What is VoIP?... 2 Why should the Emergency Call Service, police and emergency services care about VoIP?... 2 RISK TO THE PUBLIC... 4 Lack of Hand-Offs to the Emergency Call Service when 000 is dialed.... 5 VoIP is not Traditional Telephony, Just Cheaper... 5 Inconsistent Call Routing and Hand-Offs... 6 Missing or Inaccurate Location Information... 7 VoIP Quality... 7 VoIP, Whispers, Soft Sounds and Background Noise... 8 VoIP Transmission of Non-human Sounds... 9 VoIP Fairness in Heavy Call Volumes... 9 Evidentiary Issues Related to 000 Recordings of VoIP Calls... 9 VoIP Power Issues... 10 Wireless VoIP... 10 Bombing and SWATing... 11 Lack of Clarity in VoIP Standards for 000... 11 Training, Best Practices and Standard Operating Procedures (SOPs)... 12 IP/VOIP BENEFITS... 13 LEGAL, REGULATORY & FUNDING UNCERTAINTY... 14 Legal & Regulatory... 14 Funding... 14 CONCLUSION... 15 ABOUT THE AUTHORS... 16 2008 Association of Public Safety Communications Officials Australasia. All rights reserved

Overview Since the very beginning of the 000, the Emergency Call Service, police and emergency services communications centres have experienced the pains associated with managing emergency calls in an environment of evolving technology. But as technology has advanced so has 000 functionality. The basic 000 service saw the Emergency Call Service routing emergency calls to the proper police or emergency service communications centre based on the geographic location of the calling party s telephone line. This included data providing the calling party s phone number as well as the address of the caller from the Integrated Public Number Database (IPND). In the public switched telephone network this allowed a high standard of response because the actual physical location of the telephone line was static and known. With the advent of mobile telephony the challenge to supply location data arose. The data supplied for mobiles includes the billing address however that cannot be relied upon for an emergency response due to the nature of mobile telephony s intended use: mobility. To assist during mobile emergency calls, data with the cell location and state are provided. When the Emergency Call Service answers an emergency call from a mobile it also asks the caller for the location where police or emergency services are required to respond. The data and questioning by the Emergency Call Service ensure that the mobile emergency call is routed to the appropriate police or emergency services communications centre. Where communications cannot be established with the caller and circumstances indicate an emergency is in progress the Emergency Call Service is able to transfer the call to the most appropriate state based on the location of the cell tower and phone. The third generation of mobile telephony will provide even more enhancements to determine handset location and in due course this will flow through from the commercial market. The next challenge, now and for the future is VOIP on both fixed and mobile networks. Over time the Emergency Call Service, Police and emergency services communications centres have adapted and with each advance in technology have been able to offer the community the best emergency services possible. The Advancement of Technology Technology advancements continue to create new twists and challenges for the Emergency Call Service and police and emergency services communications centres. The first challenge was the shift from analog telephones to digital systems followed a decade or so later by the introduction of cell phones. The latest technology twist is Voice over Internet Protocol (VoIP). As was the case with cellular the new service providers did not consider the implications for emergency calls. The Emergency Call Service and police and emergency services communications centres nationwide are now facing numerous challenges with this new technology. 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 1

Within a decade or so VoIP will be the predominant method for placing emergency calls to 000. VoIP is generally viewed by the public as a mature technology that is the clear next generation of both wireline, and increasingly, wireless, telephony. VoIP is assumed to include 000 and other traditional capabilities though this is not always the case. The Emergency Call Service, police and emergency services must approach VoIP from three distinct angles: 1) inform and educate the public on the possible limitations in some VoIP offerings and advocate careful consumer awareness on 000 functionality. 2) take advantage of the substantial capabilities of VoIP and IP technology in and between the Emergency Call Service and other public safety, law enforcement and homeland security agencies. 3) assure that the funding is in place to continue and enhance the Emergency Call Service and police and emergency services communications centre operations in view of the decline in traditional wireline revenues and increased use of wireless and VoIP services. The Emergency Call Service and police and emergency services are used to working on many fronts to ease the transition to newer technologies while mitigating risks and increasing benefits to our community. However, this is a tough task and requires not only commitment but resourcing and funding - but it has been done before. Hopefully our experience with wireless and the technology transitions that came before it will make this newest step in technology easier and less risky. What is VoIP? VoIP - Voice over Internet Protocol - is a new way of making telephone calls. VoIP calls are routed over the Internet and Internet-like networks, and often through the Public Switched Telephone Network (PSTN) as well, and will soon surpass the use of traditional telephone networks, both for regular and 000 calls: Instead of making calls over a reliable, dedicated, secure telephone network, VoIP sends calls on the unreliable, non-dedicated Internet. Instead of sending voice and sounds in a constant, unbroken stream, VoIP sends voice and some sounds in small groups called packets Instead of delivering Caller Line Identification (CLI) when 000 is dialed VoIP performs in a variety of ways depending upon which VoIP service is used. Why should the Emergency Call Service, police and emergency services care about VoIP? The real heart of the question for the Emergency Call Service generally and police and emergency services individually is What is the impact of VoIP on their emergency calls? and What will the impact be one year, two years, three years and more down the road? In their April 2007 research report Telecommunications Usage and Expectations, Woolcott Research surveyed 1600 Australian 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 2

respondents in a variety of demographic categories and determined that overall 15% of Australians in the randomly chosen sample use VoIP services. While this overall percentage has been deemed relatively limited 1 it still represents about 1 out of every 7 telephony subscribers 2 and the number is growing. Even at a low of 9%, the VoIP penetration rate for non-broadband subscribers, and growing, there is no ignoring the fact that VoIP is here today and is here to stay. Based on traditional examples of new technology deployment the telecommunications industry has developed a conservative formula to estimate the rate of adoption of new technologies which takes into account a full range of technology, business, market and human factors. This rule is called the 80/20 rule and it states that it takes 20 years to replace 80% of old technology infrastructure, if we count 1994, the year VoIP was first introduced, as the beginning of the VoIP era 80% of calls to the Emergency Call Service will be VoIP, or its replacement technology, by 2014, which is only a few years away. In fact, after 50% of calls are VoIP we still must support the older technology in parallel with the new for years into the future, a situation not addressed further in this document. From the viewpoint of the Emergency Call Service, police and emergency service communications centres VoIP is only one of many issues but it is becoming one of the most important for three reasons: 1) Risk to the Public: VoIP services can place the public at risk because they provide inconsistent, inferior and often non-existent 3 000 service. Even though the risks inherent in VoIP are being addressed this problem is far from solved and impacts the Emergency Call Service and every police and emergency services communications centre in the country. It is also true that some VoIP services used in Australia are hosted outside of Australia and, therefore, outside of the Australian technical and regulatory framework. 2) Emergency Call Service and public safety agencies benefits: VoIP infrastructures within and between the Emergency Call Service and public safety agencies can bring many benefits including reduced costs, increased resistance to failures and outages, including those caused by both terrorists and Mother Nature, greater flexibility in operations and enhanced security through the use of encryption and Virtual Private Networks (VPNs). 3) Legal, Regulatory and Funding Uncertainty: VoIP funding issues going forward are unclear. At present the Emergency Call Person (ECP) for 000 4, specifically Telstra, is handling 000 calls from both fixed line telephone customers from whom they derive revenue and from an undisclosed number of callers from VoIP services who are obliged to provide 000 access to their users but from whom Telstra derives no revenue. (continued) 1 Australian Communications and Media Authority, The Australian VoIP Market, page 1, http://www.acma.gov.au/webwr/_assets/main/lib310210/aus_voip_market_apr_08.pdf 2 Though none but anecdotal evidence is currently available it is the opinion of the authors, due to the variety of VoIP services, including peer-to-peer services that do not use the PSTN, as well as the number of subscribers who have maintained their traditional phone line that VoIP calls in actuality represent about one in 12 or so 000 calls placed today. 3 From 2 November 2007, providers of voice over internet protocol (VoIP) two-way services are obliged to provide free-of-charge calls to emergency call service numbers. (http://www.acma.gov.au/web/standard/pc=pc_310866#4) The Australian Government s current policy on voice over internet protocol (VoIP) is that if you can call a fixed or mobile phone from a VoIP service, the VoIP service must be able to call the Emergency Call Services. This policy is still in the process of being implemented and not all VoIP service providers are able to guarantee that their service can access the Emergency Call Services. http://www.acma.gov.au/web/standard/pc=pc_1695. 4 The Australian Communications and Media Authority (ACMA) Telecommunications (Emergency Call Person) Determination 1999 identifies Telstra as the responsible party for initial handling of calls placed to the 000 emergency number. 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 3

At the present time there is no mechanism to compensate Telstra for these additional calls which fall beyond their regulatory burden. Telstra has costs but derives no compensation from the handling of those calls and, it can be argued, in the large majority of the cases not only does Telstra not derive revenue but that the VoIP caller is a person who used to be a Telstra fixed line customer and, therefore, represents a revenue reduction. The remainder of this white paper will address these three areas in more depth. Risk to the Public VoIP is neither all good nor all bad. The problem with VoIP generally, and as it relates to 000 specifically, is that it is inconsistent. Traditional telephony was implemented to a rigid set of national and international standards and even so there are still minor local interpretations and variations. VoIP, on the other hand, has dozens of possible variations which are used by over 250 companies 5 offering VoIP service in Australia. The inconsistencies of VoIP service implementation, in terms of the risks they present to the public from a 000 perspective, are easily identified and listed. The highest risk items are: Lack of hand-offs to the Emergency Call Service when the subscriber dials 000. The public s incorrect assumption that VoIP is traditional telephony, just cheaper. Inconsistent routing and hand-offs of VoIP calls to the Emergency Call Service. Missing or inaccurate location information VoIP voice quality ranges substantially. 6 VoIP may misinterpret whispers, soft sound and background noise as no sound and not transmit them or not transmit them properly. VoIP may grossly misinterpret non-human sounds and generate completely different sounds such as misinterpreting a gunshot as a human sound. VoIP degrades uniformly across all calls during heavy call volumes. Evidentiary issues related to 000 recordings of VoIP calls. VoIP service, unless provided with a battery-backup option, does not work during power outages. Increasing use of wireless VoIP which further exacerbates the location issue. The relative ease with which VoIP can be hacked and fake calls sent to the Emergency Call Service. (Bombing and SWATing) Lack of clarity in VoIP 000 Standards 000 training on IP, VoIP and related technologies Each of these areas will be addressed briefly in the following sections. 5 The Australian VoIP market is growing rapidly. Between April and September 2007 the number of VoIP providers increased by 27 to 269. Australian Communications and Media Authority, The Australian VoIP Market, April 2008. http://www.acma.gov.au/webwr/_assets/main/lib310210/aus_voip_market_apr_08.pdf 6 VoIP can be better than wireline quality or can be very poor and may drop syllables or complete words. The full range of quality and problems can be experienced during the same call. 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 4

Lack of Hand-Offs to the Emergency Call Service when 000 is dialed. At present in Australia the decision on how a VoIP service will handle a call when 000 is dialed is left largely up to the VoIP service provider even though the Australian Communications and Media Authority (ACMA) has obliged service providers to provide no-cost 000 dialing for subscribers of all but peer-to-peer services 7. A legal and regulatory framework, which certainly must be anticipated as VoIP matures and is taken up by a growing percentage of the population, will provide a solution for Australia-based VoIP providers but will not be binding on VoIP providers located outside of Australia which are accessed via international Internet connections. VoIP is not Traditional Telephony, Just Cheaper To save a nominal amount per month on their phone bills citizens sign up for VoIP services being offered by traditional phone companies, cable companies, satellite service providers and independent organizations who exist for the sole purpose of offering VoIP service. Regardless of the source these new services use the Internet and VoIP protocols plus the traditional phone network, rather than exclusively using the traditional dedicated Public Switched Telephone Network (PSTN), to connect telephone calls. But in their excitement and eagerness to save money many citizens fail to read the fine print even though ACMA requires all VoIP providers under their jurisdiction to notify prospective subscribers about the differences between VoIP and traditional telephone service. As a tool for service providers and consumers the Communications Alliance has made an excellent booklet available in both online 8 and print formats entitled So you want a VoIP phone service? which provides clear, non-technical guidance on the seven areas a consumer needs to consider in the move to VoIP service: 1. Why do you want a VoIP phone service? - are you looking for cost savings? - need more phone lines? - interested in more telephone features? 2. Do you understand the differences between your traditional telephone service and a VoIP service? - how does it fit in with your existing phone setup? - what happens to your phone number? - 000 fire brigade, police, ambulance? - what about contracts and phone bills? - what is the voice quality like? 3. Ensuring that your broadband is up to it - if you do not have broadband, then you need to get it. - to help you decide, shop around. Ask friends about their experiences. Check out a few websites. - if you already have broadband, then you need to make sure that it is suitable for VoIP. 4. Deciding on a VoIP service provider - again you need to shop around. Ask friends about their experiences and check out the websites. - maybe you want a bundled package where the broadband and VoIP services are supplied from the same provider. 5. Connecting it all up 7 A peer-to-peer service is a connection between VoIP users and does not connect to the Public Switched Telephone Network and, therefore, is considered to be free of traditional telephony regulation. This approach is consistent with the approach taken in other countries. 8 http://www.commsalliance.com.au/ data/page/13230/voip_booklet_jun07.pdf 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 5

- there are a few options in setting up a VoIP service. You can use your current phone or purchase a new VoIP phone. VoIP services can be used on wireless and cordless phones. 6. Using your VoIP service - currently there isn t a centralised directory for all VoIP numbers or centralised directory assistance for those using VoIP services. - making and receiving calls will be very familiar. As with cordless phones and some other phones, you need power for the service to work. - if you have a problem with the VoIP service, there are few more issues to consider. 7. Customer service and your rights - like all phone services you need to know who to contact for customer service. - in Australia, consumers have certain rights when using a telephone. The Communications Alliance also has a companion guide for the service providers entitled VoIP Service Provider Guide. 9 Inconsistent Call Routing and Hand-Offs When a traditional phone services subscriber dials 000, the Emergency Calls Service receives CLI information, in case the caller hangs up for some reason or is unable to speak, and this allows the call to be forwarded to the appropriate public safety agency for the location, which allows assistance to be dispatched to the proper location. This is not the case for many VoIP 000 calls because instead of coming into the Emergency Call Service with accurate and properly formatted CLI information the information provided by the VoIP service provider is either improperly formatted, inaccurate, or both. In fact, this problem is so widespread that ACMA recommends that phone numbers assigned to VoIP users be flagged as such in the Integrated Public Number Database (IPND) and deemed unusable for purposes of 000 call handling. Instead, time is lost in getting the call-back number and location of the caller - a problem further complicated when the caller is not at their own phone, such as in the case of baby sitters and business employees. Further difficulties arise if, as often happens, callers are not able to speak due to their medical condition or the close proximity of an intruder. And though this issue is being addressed by the largest providers of VoIP services it is still fraught with problems. Some VoIP services also allow users to choose the area codes to which their phone numbers are assigned, as opposed to the rigid geographically based assignments of the traditional phone network. As with a wireless call even if someone calls for help from a phone number assigned to area code 123, they may physically be anywhere in the country or in the world. 9 http://www.commsalliance.com.au/ data/page/13230/service_provider_guide_to_the_voip_customer_booklet.pdf 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 6

Missing or Inaccurate Location Information For traditional telephony subscribers CLI information is tied statically to the subscriber s location information because the service address of the subscriber cannot change. VoIP service, except that provided by most cable companies is different in that service is not tied to a postal address and physical location but, rather, to a small interface device that can be relocated dynamically and reconnected to an Internet connection to provide service in a different location. And, in the case of the nascent mobile VoIP service it is not even necessary to relocate a small interface device, but rather to simply move the mobile phone device. The vulnerability this creates for 000 is that while the Calling Line Information itself may be accurate the physical location to which it points may be of no use for public safety dispatch purposes. VoIP Quality Voice over Internet Protocol was never designed to replace traditional telephone systems, rather, VoIP was designed to send human speech between computers. This is a fundamentally different task than replacing the telephone network. The treatment of whispers, soft sounds and nonhuman sounds are specifically discussed in the following sections but one issue complicates the transmission of voice generally, in addition to whispers, soft sounds and non-human sounds and that is the use of packets for transmission of speech. Traditional telephony systems transmit speech as a constant stream of information over a pathway that is established between speaker (in this case a 000 caller) and listener (initially Emergency Call Service and then police and emergency services communications centre call takers) at the time the call is placed. Once the call path is set up it is reserved for the exclusive use of the two communicating parties. By contrast Voice over IP uses packages of information, called packets, to send the voice information over a shared network. Just like an individual letter moving through the post the packet containing speech is subject to delay, delay variation and potentially discarding as it finds its way through the open, public Internet and any private internets needed to connect the callers. Considering that a VoIP voice packet can contain several syllables of speech this is very problematic because the loss of a single packet not only alters the speech quality it can also alter the meaning. Consider a caller who says their address is 4108 Ashley Way and the packets containing the 08 and ley are deleted. The police and emergency services call taker hears 41 Ash Way and it sounds very accurate 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 7

VoIP, Whispers, Soft Sounds and Background Noise There are additional problems. Traditional telephony measures the incoming signal at the speakers end and does a very good job of rebuilding that signal at the listener s end without embellishment or interpretation. For traditional telephony the objective is a single interoperable global standard where sounds in = sounds out. VoIP systems, on the other hand, are optimized for voice and there are many options available but all of them share the same formula: voice in = voice out. If voice is not coming in then it is highly likely that the sound will not come out at all or, possibly, will not come out as it went in. The first area where this matters in is the transmission of whispers, soft sounds and background noise, all of which are critical to the 000 call taker s ability to determine what is happening on the other end of the telephone line and determining a proper response. This point is discussed further in this sub-section. The second area where this matters is in the area of non-human sounds such as alarms, babies crying and gun shots. That subtopic is covered in the next sub-section. The quality of a VoIP call from the general public to the police and emergency services call takers is inherently lower than that of a traditional phone line, from a 000 point of view, because the VoIP call often eliminates or modifies background noises, whispers or soft sounds making it difficult for police and emergency services call takers to determine what actually is happening at the other end of the line. While traditional calls are sent over dedicated pathways the VoIP voice packets are sent over shared connections whose performance, and the resulting call quality of the VoIP call, vary as demand for the shared connection rises and falls, often during a call. Think of a shared highway system in which certain vehicles (packets) can be delayed, rerouted, misrouted or may crash and never get to their destination at all. Now consider that these vehicles (packets) are delivery vehicles carrying parts of a voice conversation. One special accommodation of VoIP is called silence suppression 10. VoIP designers determined that it was possible not to send VoIP voice packets containing silence, which has an overall benefit in most cases because there are fewer vehicles (packets) on the highway and silence can be reinjected, if desirable, at the destination without using highway (network) capacity. From a 000 standpoint, though, this is problematic because voice packets containing vital whispers and soft sounds are often classified, at their source, as silence packets and are not, therefore, transmitted at all. The upside is that VoIP technology allows this feature to be disabled on a call-by-call basis. It is hoped that VoIP service providers can and will be compelled to do so for 000 calls, possibly by regulation or legislation. 10 Silence suppression is often known as Voice Activity Detection (VAD) 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 8

VoIP Transmission of Non-human Sounds While preliminary tests have shown that VoIP will transmit certain non-human sounds, such as gun shots at close range, with reasonable accuracy VoIP was never designed to transmit non-human sounds at all and any transmission of non-human sounds is due solely to the similarity, at a very elemental level, of a non-human sound to a human sound. In any case, VoIP call takers cannot rely on VoIP for accurate transmission of non-human sounds except in the case where the traditional method of voice encoding 11 or advanced wideband speech coding is employed. Like the transmission of silence this feature, too, can be controlled on a call-by-call basis and it is hoped that VoIP providers will also be compelled to turn the voice-only feature off for 000 calls thus bringing the quality of VoIP much closer to the quality of a traditional telephone call. Both transmission of whispers and soft sounds and transmission of non-human sounds are closely interwoven and can be controlled with a high degree of accuracy within the VoIP system but VoIP providers tend to opt for the more bandwidth efficient, and therefore less accurate, transmission options. VoIP Fairness in Heavy Call Volumes The Internet was designed to be an efficient, egalitarian system using a method of resource sharing referred to as best effort. Under a best effort system a surplus of resources, such as transmission capacity, is shared equally among all users with the benefits of faster transmission and less loss of quality. The same methodology degrades all users equally when the demand placed on the system is greater than the ability of the system to meet the demand. This will be the same when VoIP call volumes increase sharply during a major catastrophe. This is another example of the differences in system performance between traditional and VoIP systems caused by the use of a shared network by VoIP versus the dedicated communication paths used by traditional telephony. Evidentiary Issues Related to 000 Recordings of VoIP Calls In the foregoing subsections we have established that VoIP: Is inconsistent in quality during a call and from call-to-call. May misinterpret or completely eliminate whispers, soft sounds and background noise. May misinterpret or not transmit non-human sounds such as gunshots, fire alarms and other critical sounds. Degrades quality evenly across all calls during times of heavy call volumes. From a call taker s perspective, when seconds can mean the difference between success and disaster, attempting to guess what sound should have been heard as opposed to reacting to what they are actually hearing can lead to incorrect decisions and place the call taker and their agency in the dubious position of being second-guessed after the fact. Only training and certain specific technical solutions discussed elsewhere can mitigate this risk. 11 Called Pulse Code Modulation (PCM) 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 9

Not only do these problems pose an immediate, and potentially life threatening problem for the 000 call taker but also for the subsequent use of the master recordings at police, fire or ambulance. What this means is that down the track at some court proceedings - criminal or civil trial or inquest into death - a recording will be played and the court, jury, barristers and witnesses will hear something which is not representative of the actual event. The problem that this will present is clear: in most cases no amount of expert testimony into the technical implications of VoIP implementation will counteract what was recorded and what was heard. VoIP Power Issues The electrical power in a traditional telephone network that causes dial tone and ringing comes from the telephone company Central Office (CO). The CO provides reliable power from the power grid but with battery back-up and often with hot standby generators. This is why there is a very high likelihood that there will be telephone service during a power outage. The power to run VoIP devices, with the rare exception of systems being provided by some cable companies in limited, high-risk markets, comes from the wall power in the residence or business. If the lights are out chances are that VoIP is out of service and, therefore, so is the ability of a VoIP subscriber to reach 000. This fundamental difference has not seemed to have an impact on VoIP subscribers willingness to sign up for VoIP service, perhaps due to lack of knowledge on the part of the subscriber even though this topic is covered in the Communications Alliance s literature referenced earlier: So you want a VoIP phone service?. Anecdotal evidence suggests that many of the VoIP subscribers view their cellular phone as a backup method to reach 000 and to allow them to be located accurately by emergency services personnel. The cellular back up method to reach 000 was recommended, though not prominently, on one VoIP providers web site 12 of 25 randomly reviewed from the list provided by ACMA. Wireless VoIP It should be clear by this point that wireline VoIP is a market favorite for the next generation of telephone system but that VoIP was offered to the public, as was cellular, before all of the necessary capabilities of the service, such as 000, were worked out and put in place. Just as the Emergency Call Service, police and emergency services communications centres are beginning to struggle with wireline VoIP, users are beginning to test drive VoIP over wireless systems, such as WiFi hot spots and private Wireless Access Points that allow phones that look like cellular phones to operate either in exclusively WiFi mode or, increasingly, to switch back and forth between WiFi/wireless LAN mode and cellular. This represents another dimension to the concern that Emergency Call Service should have regarding the growing use of VoIP technology by the public because the use of accurate location technologies is way out in the future and 000 will be plagued by the inconsistencies and unlocatability of these type of subscribers for many years to come. 12 https://www.mynetfone.com.au/support/faq/about-mynetfone/mynetfone-voip-service-81/can-i-dial-000- for-emergency-calls/, 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 10

Other issues related to wireless VoIP are similar to those encountered with cell phones. One dimension of the problem is that valid 000 callers cannot be located but a second dimension is that the lack of proper and accurate caller location can also be utilized to hide and mislead public safety and law enforcement relative to the location of a caller. This is just one more nuance of the wireless VoIP issue. Bombing and SWATing The practice of placing fictitious, or hoax, calls to the Emergency Call Service is referred to as bombing if it is done in such a way as to present false electronic credentials and SWATing 13 if it is done to elicit a response from certain response forces such as Special Weapons And Tactics, this the term SWATing. While this practice is not new and has been observed on both traditional wireline and wireless calls, it has been rendered somewhat more effective in its VoIP incarnation. While there have been few reports of VoIP bombing, and those there have been have been of the prank rather than criminal or terrorist variety, the practice is on the rise and the Emergency Call Service needs to be aware that the authenticity of a VoIP call should always be questioned. At this point ACMA recommended practices call for the verification of address, phone number and identity information with the caller but the true identity and objectives of the caller have not been called into question. The practices of bombing and SWATing require additional skepticism when dispatching from VoIP-originated 000 calls. Lack of Clarity in VoIP Standards for 000 While numerous emerging standards contain valuable information about how the Emergency Call Service should deal with VoIP and other IP-related issues it is left to the Emergency Call Service to interpret the standards for their own needs. In many cases the only guidance received is from the vendor community and, while usually well-meaning, the vendor s interpretations are admittedly selfserving and often conflict with other vendor s interpretations. This is not the fault of the current crop of standards-creators, but rather a problem inherent in standards work since the first standard was drafted, but remains a problem for the Emergency Call Service. One reason why this is especially problematic is that traditional telecom and networking standards have been interpreted and put to use largely by enterprises and organizations with the resources to reconcile the various vendor approaches with their own needs and applications. 13 Ppackets containing VoIP information are easily traceable for those high school pranksters who use fairly unsophisticated programs and who have been so naïve as to think their tracks were covered by the use of the anonymous Internet. These pranksters have been unpleasantly surprised when law enforcement catches up with them within hours of their misdeeds. More sophisticated approaches, however, are available to criminals, hackers and terrorists. Using intermediate systems, often in other countries to hide their tracks, and often employing voice modification/hiding software the professional criminal can reek more havoc on the Emergency Call Service though no reports on this type of attack has yet been made public. 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 11

Training, Best Practices and Standard Operating Procedures (SOPs) The lack of standardized, certified training, best practices and Standard Operating Procedures for VoIP 000 call taking also places a burden, and undue liability, on the Emergency Call Service and police and emergency services communications centres trainers and management and is a key are that must be addressed. 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 12

IP/VoIP Benefits VoIP and 000 The benefits of VoIP can be very profound when a single organization, such as the Emergency Call Service or government, controls both ends of the VoIP connection and preferably the network in between. In this case the Emergency Call Service can ensure that the software settings at both ends are compatible, that there is sufficient network capacity and that the calls are very close in quality to, and can often be better than, traditional calls between the Emergency Call Service and the police and emergency services communications centres. Additional efficiencies, and cost savings, are derived from the fact that the network is shared by voice, data and increasingly video, allowing more capacity than any would have separate. VoIP also benefits greatly by using the underlying network infrastructure that is common to both the global commercial Internet and private, secure networks called intranets. While the VoIP calls from the public are subject to hackers, spam, viruses and denial-of-service attacks that can shut down a network and make it unusable - all problems that occur routinely on the global Internet - the Emergency Call Service and police and emergency services communications centres operating on private public safety IP networks are safe because, although their network uses the same software and hardware as the Internet, it is completely separate from and unconnected to the Internet. The Emergency Call Service and police and emergency services, therefore, get all of the benefits with a greatly reduced risk. 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 13

Legal, Regulatory & Funding Uncertainty The widely held belief that VoIP and the Emergency Call Service are technically incompatible is incorrect. The issues are not technical, but legal, regulatory and financial. As the role of VoIP becomes more clear and as everyone, including regulators, begin to understand that VoIP is here to stay and that it represents the next generation of public telephone service the providers are increasingly being forced to adhere to regulations and abide by rules to which they heretofore were allowed to ignore based upon their regulatory classification. Legal & Regulatory National regulation and legislation in most countries, Australia included, is beginning to catch up with the Internet. Many VoIP Service Providers, however, continue to resist all efforts to get them to comply even with voluntary measures, let alone regulatory obligations. A large number of VoIP service providers simply don t want the costs, difficulties and liabilities of supporting 000 even though ACMA continues to clarify regulations and obligations. Funding 000 emergency calls are handled through a centralised national centre operated by Telstra. The 000 calls handled by Telstra are from two sources: Telstra customers who pay Telstra a fee for the use of their service and 000 calls handed off by non-telstra carriers and service providers. As the percentage of users in Australia inches its way up from 15% to higher numbers a process must be devised and a mechanism put in place to offset the cost of calls from non-telstra callers. Telstra has historically maintained a very high standard in the speed and accuracy of emergency call distribution and there have been no complaints from Telstra or indications that this will not be the case in the future but fairness and good business practice mandates that this funding discrepancy be anticipated and addressed before it becomes an issue of its own volition. 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 14

Conclusion VoIP and 000 The reader will note, with some unavoidable exceptions, that this VoIP and 000 white paper, is informational in nature and has attempted to avoid being a call to action though action certainly is needed. The authors have attempted to provide a comprehensive overview of VoIP issues as they relate to 000 in the hope that the reader will seek other current sources of information, including Association of Public safety Communications Officials Australasia (APCOA), Australian Communications and Media Authority (ACMA), the Department of Broadband, Communications and the Digital Economy (DBCDE), public safety and VoIP trade press, training, consulting and, most importantly, collaboration and debate through forums both formal and informal, local and national. VoIP and the use of IP technologies for calls from the public and in and between the Emergency Call Service and police and emergency services are the most current technological changes to 000, the most recent twist, in an ongoing technological evolution that is both exciting and frustrating. This newest technological step can offer increased public safety, police and emergency services operational benefits and flexibility and the next step in the Emergency Call Service capabilities but we must also assure a safe transition and that funding exists to assure a smooth migration with minimal loss to life and property. 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 15

About the Authors VoIP and 000 James P. Cavanagh jpc@911tips.com James P. Cavanagh is an APCOA member and a Knowledge Transfer Agent and Dean of Faculty for the Training Institute for Public Safety (www.000tips.org). Jim is a consultant, author and lecturer on telecommunications, networking, security and public safety topics and founder of The Consultant Registry. Jim appears frequently at APCOA, NENA and APCO national, state and regional events and is a frequent contributor to The APCO Bulletin: Public Safety Communications, Public Safety Communications and other trade journals. Peter J. Ferguson peter.ferguson@police.vic.gov.au Peter Ferguson is an APCOA member and Inspector with Victoria Police. Peter is the Officer in Charge of Police Communications D24 and represents Victoria Police on the National Emergency Communications Working Group, the Emergency Call Service Advisory Committee and a number of other state and national committees. Peter holds Bachelor of Arts (Police Studies) and a Graduate Certificate in Public Sector Management. 2008 Association of Public Safety Communications Officials Australasia. All rights reserved. Page 16