In a submission responding to the Australian Communications Authority's (ACA) October public discussion paper on domestic Voice over Internet Protocol (VoIP) regulation, the Victorian State Emergency Service (VICSES) said: "It is the view of VICSES that the telecommunications industry generally only seeks solutions to the problems facing the ESOs [emergency services organisations] if it is in their interest (generally driven by economic factors)."
"If they [telcos] do not have to provide a solution to issues such as accurate caller location information," said VICSES, "then they generally will not."
And the Victorian Police echoed VICSES' sentiments in its own submission, saying: "VoIP is predominantly being driven by carriers and IT providers based on commercial factors and not necessarily in support of police and emergency services requirements nor in the interest of disadvantaged groups in the community, ie hearing/speech impaired."
Other ESOs to make submissions to the ACA's paper included St John Ambulance, the Queensland Police Service, Emergency Communications Victoria, the Fire and Emergency Services Authority of Western Australia and the Bureau of Emergency Services Telecommunications in the Victorian Department of Justice.
Without exception, all submissions by emergency services organisations to the ACA specifically mentioned the issues of consumer access to phone-based emergency services such as the well-known Emergency Call Service (ECS) reached by dialing 000.
Regulation of telephone services in Australia centers on whether or not the service is defined as a Standard Telephone Service (STS) in the Telecommunications (Consumer Protection and Service Standards) Act 1999. In general, submissions from ESOs called upon the regulator to ensure that, no matter what classification of service VoIP services fell under, the Emergency Call Service was a key part of public safety in Australia.
For example, St John Ambulance demanded that "regardless of what constitutes a Standard Telephone Service, at the very least the ACA should be working towards enforcing the same emergency service functionality on VoIP telephone services that is required on traditional telephone services."
Currently calls to the 000 network from carriers other than Telstra are forwarded through to Telstra's network. Telstra is required by the Telecommunications (Emergency Services) Act 1997 to maintain the operation of its Emergency Call Service.
Submissions from emergency service organisations also focused on the ability of VoIP services to provide them with a Calling Line Identification (CLI). The CLI is a signalling capacity within the Australian telephone network that provides the calling party's telephone number. It is used by emergency services to verify the geographic location of the call. In addition some submissions mentioned potential quality issues inherent to the provision of VoIP services.
For example, the Queensland Police Service said that any VoIP service provider must provide a service that ensures three things. Firstly, it must provide "priority routing within the VoIP network for calls to the Emergency Call Service". Secondly it must make sure that "an accurate Calling Line Identification for fixed location VoIP or nomadic VoIP is delivered through the Emergency Call Service to the relevant emergency service organisation".
Thirdly, the Queensland Police Service said, any VoIP service provider must ensure that "end users calling from VoIP services can be understood by the organisation with VoIP quality of service at levels that will provide a comprehensible voice quality for a range of voice types and accents".
But not everyone agrees with the sentiments expressed by the ESOs. In particular a submission from the Australian Privacy Foundation (APF) said: "There should be no automatic presumption that it is necessary for emergency services organisations to be able to access information about either the identity or the location of a person making a call by VoIP. Requiring VoIP service providers to provide emergency services organisations with Calling Line Identification, as suggested in section 8.3 of the ACA paper, would also be a major intrusion into the privacy of telecommunications users."
"The level of surveillance and privacy intrusion required to apply emergency service obligations to VoIP is unacceptable and unnecessary as long as users are educated not to expect the same emergency service response when using VoIP," said the APF.
And providing the information needed to supply CLIs to emergency service organisations may even be illegal for VoIP providers, according to the privacy group. "The Australian Communications Authority should be aware of the representative complaint by Electronic Frontiers Australia against several carriers for supplying Calling Line Identification, including for silent line subscribers, to internet service providers. The ACA found some aspects of this practice to be unlawful, and the matter is also currently under investigation by the Privacy Commissioner as a potential breach of the Privacy Act 1988," said the Australian Privacy Foundation.
Well, there goes any regard I have for the Australian Privacy Federation.
I have no problems at all with emergency services having my location details disclosed to them when I make a call to 000. In an emergency situation, you want help as fast as you can get it, and having good address details available is a first start.
Perhaps some people from the APF should suffer severe head injuries after tripping in their front yards, then rely on a p****er-by to notice them fallen and contact 000, unsure of the name of the street that they are driving down or the suburb that it is in.