Draft regulations regarding government's 112 Public Emergency Communications Centres (PECs) will place onerous financial burdens and only work after some tough decisions are made, say telecommunications service providers.
Vodacom, Cell C, MTN, Telkom and others this week responded to the proposals published by the Independent Communications Authority of SA (ICASA) late last year. Public hearings were held on the issue at ICASA's Pinmill Farm offices, in Sandton, yesterday and the day before.
All seem to support the adoption of 112 as an exclusive national public emergency number and agree electronic communication network service licensees should have an obligation to provide gratis access to emergency services via a 112 number. But all ask: "At whose cost?"
Vodacom spokesperson Dot Field says the draft regulations will impose new requirements with regards to technical standards and obligations on telecoms providers, which in turn will require infrastructure investment.
These new requirements include:
* That licensees ensure inter-operability of their networks to ensure efficient and effective provision of emergency services.
* That networks must have diversity and redundancy to meet the requirements of emergency services.
* With each emergency call, the licensees must provide caller line identity (CLI), subscriber name (including street name, house number, area or town and postal code), subscriber location, latitude, longitude or altitude of subscriber equipment, direction of travel of subscriber and "any other information that may be determined by ICASA to the public emergency communication centre which will then forward this information to the relevant emergency organisation".
Field adds that the Electronic Communications Act of 2005 requires that the 112 emergency call service must be provided at no charge to the customers. "In compliance with the law, Vodacom will not charge (and has in the past not charged) subscribers for this service," she says.
As the service is free for the subscriber, Telkom has also historically not charged any interconnection in respect of 112 calls originating from mobiles and terminating on the fixed network, she adds. "Vodacom's view - shared by others in the industry - is that this position should be retained under the new regulations."
Who pays?
Field further adds that compliance to the regulations will require additional investment costs for, inter alia, systems integration and development. Vodacom, therefore, argued that the technical requirements and obligations would result in an undue cost burden for the industry.
"In particular, the obligations and technical requirements imposed must be limited to those that are necessary and relevant to enable emergency organisations to respond to the emergency," she says.
"Vodacom currently provides CLI and base station coordinates with each emergency call and the emergency organisations have been able to effectively respond to emergency calls using this information as provided.
"It is, therefore, not necessary, in Vodacom's view, to impose additional obligations with regards to latitude, longitude or altitude of subscriber equipment, direction of travel of subscriber, etcetera, as these are not critical to enable emergency organisations to respond to emergencies. With regard to automatic caller identity and location information, Vodacom has suggested that only CLI and subscriber location information (based on base station coordinates) be mandated under the regulations," Field says.
Technicalities
Cell C communicator Shenanda Janse van Rensburg says her company raised a number of practicalities in its submission.
"Cell C is concerned that the draft regulations call for requirements that would be impractical to satisfy without proper industry agreement on technical standards, for example, automatic location identity," Janse van Rensburg says.
"Automatic location identity is constrained by the unavailability of handsets with integrated global positioning system capability, as stipulated in Section 79.1 of the Electronic Communications Act. Licensees would, therefore, have to engage as a forum to determine an interim location identity solution," she says.
Another constraint identified is that an SMS cannot be sent from a SIM-less device, as required by the draft ICASA regulations. A further concern relates to calls made from SIM-less handsets. "While an emergency number can be accessed even on a SIM-less device, such a device cannot be called back if the call is dropped," she cautions.
Janse van Rensburg adds that, to keep costs down, Cell C also believes that the cost of carrying a 112 call should be minimised through waiver of interconnect charges.
MTN spokesperson Ntombi Mhangwani says MTN is still trying to get an understanding of how this new service, to be provided by the national Department of Communications, will impact on the current 112 service provided by MTN - "and how the new service will work".
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