Regulatory Issues Associated with Provision of Voice Services Using Internet Protocol in Australia

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Submission by Emergency Communications Victoria in response to ACA Discussion Paper “Regulatory Issues Associated with Provision of Voice Services Using Internet Protocol in Australia”

Emergency Communications Victoria

Emergency Communications Victoria (ECV) is a State-owned body established in June 2002 under the State Owned Enterprises Act 1992 to provide emergency communications to Victorian Emergency Service Organisations (ESOs). ECV operates three State Emergency Communications Centres (SECC’s), two in Melbourne and a third centre in Ballarat which caters for the CFA’s regional requirements for rural Victoria.
ECV wishes to ensure that, in determining the regulatory framework that should apply to VoIP (and other voice telephony services that may become available in future), appropriate weight is applied to public interest requirements, such as Emergency Call Service (ECS) access and law enforcement. These requirements should not be diminished by the introduction of new technology.
Provision of ECS access and supply of location information may not be a primary consideration of service providers or foremost in the minds of consumers at the time of purchase; self-regulation and market forces cannot be relied upon to ensure compliance with these requirements. The regulatory environment must be designed so as to ensure continued compliance with these requirements in respect of all services, regardless of technology.

Access to Emergency Call Service

VoIP service providers are currently advertising a wide variety of service offerings, including:

  • Full outbound only services (inbound calls are carried on an existing landline). Eg Freshtel (

  • Outbound only services, specifically excluding 000 calls (000 and inbound calls are carried on an existing landline). Eg VCall (

  • Full inbound and outbound services, marketed as primary residential services. Eg Engin (

  • Full inbound and outbound services, marketed as supplementary residential services. Eg Nella Telecommunications SmartVoice (

  • Full inbound and outbound services, marketed as nomadic services (“take it anywhere in the country or in the world”) Eg Broadband Phone (

Whether or not a VoIP service provider is required to provide ECS access should depend, as with traditional services, on whether an end-user would reasonably choose the service, as a first choice, to make an emergency call. VoIP service providers whose services are clearly additional to an existing Standard Telephone Service (STS), would presumably be regarded similarly to existing long-distance service providers and would not need to provide ECS access. Full outbound services, however, particularly those that include telephones or adaptors, are likely to be used as the day-to-day telephone service of the end-user, and it would be this service to which the end-user or other person would resort to make an emergency call. Providers of these services must be required to provide ECS access of at least the same standard as would be provided by a traditional Standard Emergency Telephone Service (SETS) provider. Given the types of situations in which emergency calls may be made, access to 000 must be immediately and intuitively available, and must not require additional actions such as entering an override code or plugging a telephone into a different jack.

Location Information

The importance of Calling Line Identification (CLI) and location information is well understood and was described in some detail in the ACA discussion paper “Location, Location, Location” (January 2004). This importance is not diminished by the fact that the telephone service is provided by VoIP or some other technology.
VoIP service providers whose services are able to access the ECS must also be required to provide telephone service data to the Integrated Public Number Database (IPND) and CLI information to the Emergency Call Person (ECP). It may be that existing ECS Determination provisions require this, however there must be certainty that the provisions of the Determination will operate effectively in respect of these services. For example, the requirement for a Carriage Service Provider to ensure “as far as practicable” that the service provides CLI must not be subverted on the basis of some perceived lack of practicability in providing this information for VoIP services.
The discussion paper refers to amendment of the ECS Determination to account for the potential for VoIP service end-users to be nomadic. It is suggested that a VoIP location indicator code be used for this purpose. The use of this code assumes nomadicity for all VoIP services, and it would require that, for all emergency calls from a VoIP service, the ECP operator would need to question the caller to identify his/her location. The additional questioning would add several seconds to the duration of the emergency call, delaying the connection of that caller to the ESO. The broader impact is that, as the adoption rate of VoIP services increases, the proportion of calls requiring additional questioning will also increase. This will increase the average duration of emergency calls and could potentially reduce the call answer performance of the ECP or increase the cost of maintaining the existing performance. The ACA will need to consider whether such an amendment meets the objective that “calls made to an emergency service number are transferred to an appropriate emergency service organisation with the minimum of delay” (Telecommunications (Consumer Protection and Service Standards) Act 1999, Sec. 147.2.f). The need for additional questioning may also undermine public confidence in the ECS; even now, members of the public have expressed concern about being asked to confirm their state when making emergency calls from mobile services, and it could be expected that callers from home phones will have concerns about being asked to identify their location.
An alternative interim solution may be to require end-users to nominate whether their service is to be fixed or nomadic. A service nominated as fixed could default to the CLI of the subscriber address, and the VoIP location indicator code (and the associated additional questioning) could be used only for emergency calls from services nominated as nomadic. This would require that end-users be provided with information advising them of the consequences of their nomination and be entitled to change their nomination if required. If the IPND “Type of Service” field for VoIP services were populated with a value indicating that it was a VoIP service (in addition to the Alternate Address Flag), an ESO calltaker could be alerted to the possibility that the provided CLI was incorrect.
For VoIP services that are actually nomadic, the use of a location indicator code may be a suitable interim measure, but it should not be regarded as a permanent solution. The provision of reliable and useful location information with ECS calls must be pursued. Mark Armstrong, the director of Network Insight Institute, in “Notes on VoIP Regulatory Options” (Network Insight Institute, Sydney, 2004), says “broadly speaking, it is possible, with widespread co-operation, to devise a scheme of emergency location for VoIP services at least as good (as) that currently applying to mobile cell phones”. If this is so, then efforts need to be made to devise such a scheme.

Quality of Service

Quality of Service (QoS) is an important consideration for emergency calls – poor transmission quality can potentially lead to extended call durations, delayed/incorrect response or an inability to respond (particularly if CLI information is unavailable or incorrect). ECV is unaware of the QoS that can be expected from VoIP services, however there must be some certainty that the QoS for services that are used for emergency calls will not diminish, regardless of the underlying technology. Industry Code ACIF C519:2004 End-to-End Network Performance for the Standard Telephone Service currently does not apply to VoIP services (clause 3.2.8), so the application of the code would need to be extended to include these services.

User awareness

VoIP services are different in many ways to what most users know as a telephone service. Most web sites and newspaper advertisements for these services contain a lot of information about the ability to make free or cheap telephone calls, however few contain information relating to QoS, other service limitations or the ECS. Where this information is provided, it is often in “fine print” on a Terms and Conditions page, and it would appear there is no requirement for an end-user to read, understand or acknowledge this information prior to service commencement.
Service providers should be required to provide users with (and, as far as practicable, ensure understanding and acknowledgement of) at least the following information:

  1. Availability of the ECS (and availability and accuracy of CLI).

    The user should understand whether ECS access will be provided through the VoIP service or through an existing landline service. If the availability and accuracy of CLI is dependent on information provided by the user, the user should be advised of this and instructed how to update the information if necessary. If CLI will be unavailable from the service, the user should be informed of this and the possible impact on emergency service response.

  2. Requirement for electricity.

    If the service is dependent on an electricity supply, the user must be advised of this. A variety of circumstances may simultaneously interrupt the electricity supply and require emergency service notification, eg fire, electrocution, collision. An emergency may also occur during an unrelated power interruption. This may be obvious, however it may not occur to a user at the time of applying for or connecting a service.

  3. Dependence on Internet connection.

    A VoIP service, though provided by one service provider, may be reliant on an Internet connection provided by another provider. The user must be advised that the service is dependent on the Internet connection and will be unavailable if the Internet connection is unavailable, faulty or disconnected (eg for non-payment).

  4. QoS considerations.

    If the service has particular requirements (such as system configuration or Internet connection speed) to deliver an acceptable QoS, the user must be informed of those requirements and the effect on QoS of failing to comply with them.

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