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• 8. TSO Local Service

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8.1 Background

178. Prior to 1987 emergency call service was supplied by the New Zealand Post Office. Telecom took over this responsibility in 1987 when the telecommunications business of the New Zealand Post Office was transferred to Telecom (as a State Owned Enterprise). The responsibility was formalised in the Kiwi Share requirements in Telecom's company constitution in 1990. The emergency call service requirements of the Kiwi Share were subsequently included in the Local Service Telecommunications Service Obligations (TSO) established in 2001 between the Crown and Telecom.

179. The national dialling code "111" has been adopted as the common dial code for the origination of emergency calls on all public telephone networks in New Zealand. Emergency calls made on non-Telecom networks are delivered to the Telecom network for transit through to emergency service providers.

180. The TSO requirements on Telecom to facilitate emergency calls are confined to calling from fixed residential telephone lines. The emergency call service requirements under the Local Service TSO broadly fall into the functions of call conveyance (based on Telecom as the telephone carrier whose network originates the most emergency calls), and call interrogation (based on Telecom as the gatekeeper determining whether calls are genuine, and forwarding calls to the appropriate emergency service).

181. The TSO review is addressing emergency call service requirements to the extent that these should be included in a revision of the existing Local Service TSO, or be the subject of a new TSO instrument. Issues regarding industry standards for emergency call service covering such areas as service availability, reliability and caller location information are to be addressed by the government inter-departmental Emergency Telecommunications Services (ETS) Steering Group.

182. Regulation making powers under section 157 of the Telecommunications Act can potentially be invoked to prescribe standards for emergency call service to be uniformly applied across the telecommunications industry.

8.2 TSO Provider Gatekeeper Role

183. Telecom, as Local Service TSO Provider, is presently the "gatekeeper" for emergency calls in New Zealand and performs the following functions:

• conveyance and interrogation of emergency calls dialled by Telecom residential subscribers with fixed telephone access (TSO);
• conveyance and interrogation of emergency calls dialled by Telecom mobile subscribers and Telecom fixed and mobile business subscribers (non-TSO); and
• conveyance (through transit) and interrogation of emergency calls dialled by non-Telecom subscribers with telephone connections on alternative fixed and mobile public telephone networks (non-TSO).

184. Telecom's call conveyance function involves carrying emergency calls from subscriber access connections, via Telecom call centres where calls are interrogated, to the communications centres of emergency service providers (Police, Fire, and Ambulance).

185. The TSO requirements for emergency calls need to be considered in the context of the multi-provider market today for telephone access services. There is arguably a need for industry wide requirements for emergency call service to ensure government objectives for public safety telecommunications can be met.

186. The call interrogation function performed by Telecom involves determining for each emergency call whether it is a genuine request for emergency assistance, and forwarding the call to the emergency service provider for responding to the caller.

187. Emergency call interrogation involves the operation of a network platform to facilitate the queuing and initial answering of emergency calls, with outward routing of genuine calls to the appropriate emergency service provider for response. The emergency call interrogation function essentially involves call centre management. Telecom no longer considers this function to be part of its core business and has outsourced the call centre operations to Sitel.

188. Going forward the basic options for the interrogation of emergency calls are to:

• Continue the key Telecom gatekeeper functions as part of the Local Service TSO requirements;
• Transfer key Telecom gatekeeper functions to a new TSO instrument specifically for emergency call services; or
• Remove some or all of the Telecom gatekeeper functions from under the TSO framework.

8.3 Emergency Call Information

189. Suitable call location information is critically important to emergency service providers so they can accurately identify where assistance is required and respond accordingly.

190. The Local Service TSO does not explicitly require that caller location information be provided for emergency calls originating at access connection points on Telecom fixed or mobile networks. However, as standard practice Telecom currently provides batch data updates (through Police) each day for emergency service providers which identifies the physical address location for subscriber telephone lines on the Telecom fixed public telephone network. Telecom also includes in these data loads the subscriber billing addresses associated with post-paid mobile network connections.

191. A common format appears to be required for consistency of supply for this information, and to so avoid having to support a variety of data interface formats between telephone service retailers and emergency service providers. The supply of caller location information can be complicated by the wholesaling of telephone access services (fixed and mobile) as the retail service providers hold and maintain subscriber information.

8.4 Availability of Emergency Call Service

192. There is a general telecommunications industry trend in telephone access technologies towards the displacement of analogue circuit switched signalling by digital packet switched signalling. Telecommunications carriers are transitioning to Internet Protocol (IP) as the emergent dominant industry technology for carrying telephone calls. The advent of Voice over Internet Protocol (VoIP) technology has also enabled broadband Internet access subscribers to make telephone calls via the Internet, for example Skype. The effectiveness of VoIP telephone service for emergency calls depends on:

• whether VoIP telephone service can be used to originate emergency calls;
• whether VoIP telephone service is facilitated through an access line circuit which is either dedicated to an individual subscriber or shared with other subscribers;
• whether VoIP telephone service is facilitated through an access line circuit which is used in parallel with other service applications for the same subscriber;
• the prioritisation for emergency calls versus non-emergency calls originating through VoIP telephone service;
• the prioritisation for telephone traffic versus non-telephone traffic carried on a subscriber access line;
• the latency or delay in conveying messages between the connecting call parties for the VoIP telephone service;
• the extent of "off-network" carriage of calls through the Internet for VoIP telephone service; and
• the dependence on the supply of mains electricity for powering the VoIP equipment sited in the subscriber's premises.

193. Two basic trends are to impact on the reliability of telephone service (and hence emergency call service) with the shift to digital access technologies:

• Households relying on telephone access facilitated through Internet access (voice over IP) without having a separate telephone circuit or dedicated telephone bitstream; and
• Telephone access for a household being dependent on the supply of electricity at the household premises to power equipment.

194. Customers will soon be able to subscribe for DSL Internet access over copper telephone cable without subscribing for telephone access service over the same cable.¹² Consequently, an increasing number of households in New Zealand are expected to become dependent on Internet access for fixed telephone access.

195. The supply of telephone access facilitated by digital technologies is commonly dependent on mains electricity to power the devices installed in the household residence. This poses a risk that emergency call service will not be available if the mains electricity connection for the household fails unless there is indefinite battery backup. A loss of fixed telephone access would not be such a serious if the household is able to use emergency call service from a mobile phone. However, cellular mobile coverage is not available to many rural communities.

8.5 Lifeline Access

196. Where local telephone service is relinquished (whether due to a subscriber cancelling service or the non-payment of bills), the access line for supplying service is normally disconnected. Keeping access lines active to enable emergency calls to be made ("lifeline calling") could be beneficial for public safety. The marginal cost to a network operator for maintaining a dormant cable access line with lifeline calling capability is considered negligible.

197. It is appropriate that any such lifeline access requirement be equally applicable to both TSO and non-TSO providers. Such a requirement would therefore need to be implemented outside the TSO framework. The reserve powers under the Telecommunications Act could potentially be used to establish such a requirement and could be supported by an industry code of practice.