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ACCAN has made a number of recommendations for changes to Communication Alliance's draft Emergency Call Service Requirements Code.

ACCAN appreciates the opportunity to respond to a public draft of the Code in addition to having input into its drafting.

We recognise that a number of our recommendations may be difficult to implement in the short term; however, they are recommended in order to ensure public safety and comfort around the use of Emergency Calls.

This submission includes the following major recommendations, as well as some minor recommendations relating to wording.

  • The Code should reflect new requirements on mobile carriers to provide the most precise location information they have available, and related new requirements.
  • It would be useful for the current Working Committee to co-opt an expert in mobile location.
  • Given that the Amendment’s Explanatory Statement states that a ‘push’ model is being explored, ACCAN believes that it would be useful for Communications Alliance to commence a Working Group or Working Committee – or an extension of the current group - to commence work on how a ‘push’ model could work, in terms of technology but also in terms of the definitions of precision of location information and related requirements for communication between carriers and ESOs.
  • Part (a) of What the Code Should Accomplish should be broadened to include VoIP and mobile phone users as well as users of a Fixed Local Service.
  • Section 4.7 should be amended to include mandatory supply of nomination contact points for both CSPs and the NRSP.
  • CSP websites (as well as Public Number directories) should be required to promote public understanding of the ECS, including appropriate use.
  • Fixed local calls to 112 should terminate on a recorded message advising the caller to call 000 in the event of an emergency.
  • Instead of being listed as notes (see page 18), the directions for Carriers and CSPs to attempt to contact customers and make information to the community should be listed as part of 4.6.1 so that they are enforceable.
  • Communications Alliance should respond to ACCAN’s queries regarding the effectiveness of the current Code Administration and Compliance Scheme to guarantee adherence by industry to the Code.
  • All calls originating in Australia – including those routed via overseas – must be able to progress to the ECP.
  • Clarification is required around a number of NRSP issues. 

Submission to: Communications Alliance

Status: Discussion paper due by 21 April.

Download: ACCAN submission - Emergency Call Service Requirements - draft for public comment [Adobe Acrobat PDF - 138.45 KB]

 

Download: ACCAN submission - Emergency Call Service Requirements - draft for public comment [Word Document - 919.5 KB]