VON Europe - Comments on ACMA’s Consultation on Customer Location Information and Numbering Data

8/3/2019 VON Europe - Comments on ACMA’s Consultation on Customer Location Information and Numbering Data

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VON Europe – Comments on ACMA’s Consultation on

customer location information and numbering data

1

Comments on ACMA’s Consultation on Customer Location Information and

Numbering Data

by VON Europe, March 2011

The Voice on the Net Coalition Europe (‘VON’) welcomes the opportunity to comment on ACMA’s

Consultation on customer location information and numbering data (hereafter ‘the Consultation’).

Question 3: How important is the current ability to obtain information about the location of a caller or a

called party? Will that change in the future?

Question 4: To what extent has the approach of placing responsibility on VoIP customers to record their

current location been implemented outside Australia? What lessons do any such implementations have

for Australia?

Question 5: What approaches would be required to empower end-users to provide customer location

information? What would be the practical issues involved in such an approach?

VON fully endorses the ACMA’s conclusion that telephone numbers have been, are and will continue to

play a key role in assisting public authorities to fulfil their respective policy objectives (in terms notably of

protection of consumers, enhancement of competition and the provision of security and safety).

As far as the security and safety policy objectives are concerned, and more in particular the access to

emergency services and the ability to locate the end user, VON is willing to cooperate with the ACMA to

assist in defining and implementing an adequate and sustainable solution to acquire location information

from access networks for emergency calls. Nevertheless, VON invites the ACMA to only implement feasible

solutions consistent with the state and widespread use of certain technologies.

VON agrees with ACMA’s statement in the Consultation that “the use of numbers as a way to accurately

identify the location of a caller is becoming less feasible”1.

Consumers, more than ever, are becoming nomadic and willing to move and travel at the spur of the

moment. This rise of nomadic communication and mobility combined with the gradual technological shift

to an all-IP world are eroding the linkage between telephone numbers and location.

1 See p. 35.





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VON therefore believes that ACMA should proceed cautiously in this transition to an all-IP world as not to

create new expectations that non-traditional communication tools, such as a number of Voice over IP

(VoIP) applications and services, act as a replacement for traditional phone services and can be relied upon

to access emergency services.

As the ACMA rightly pointed out, “with IP enabled services, voice is just one of many possible applications

and not always the primary means of communication for individuals”2. It is often the case that certain VoIP

devices, services, and applications are merely an incidental part of a given product, while in other case,

they are there to enhance or supplement (and not replace) consumers’ basic voice communications. This is

for example the case for products such as game consoles, music players (similar to iPods) and tablets

(similar to iPads), all of which are capable of providing a voice communication through IP built into the

device or available as a third party download, but which are not perceived by the user as a substitute for

telephone service. From a user’s expectations point of view, the functionalities of these products and

devices do not create a reasonable expectation that the user can call emergency services and artificially

creating such an expectation through policy could carry some unintended damaging consequences.

VoIP has transformed how communications take place, as it has disassociated the voice component from

the network relied upon to transfer it. People are no longer tied to telephones, locations, or service

providers. It is thus important to distinguish between fixed and nomadic VoIP, where the first is most often

part of a broadband Internet package and thus linked to a fixed internet connection, while the latter can be

used in any given location, as long as Internet access is available.3

In practice all devices with Internet access have the capabilities to make and / or receive voice

communications. Communication anytime, anywhere – as long as there is a broadband connection.

In this context, VON believes that it is premature to expand the emergency services access obligations to

require automatic location information, be it from the end-users themselves, from their devices, or from

the access network itself, especially for VoIP services and applications that do not present themselves as

telephony replacements .

Such an approach has shown its limitations in other regions of the world.

2ACMA consultation paper, page 38.

3See Moore, L. K. (2008). CRS Report for Congress. An Emergency Communications Safety Net: Integrating 911 and Other Services

[RL32939]. Washington: CRS (Congressional Research Service). Retrieved at, http://assets.opencrs.com/rpts/RL32939_

20080528.pdf . p. 10.

http://assets.opencrs.com/rpts/RL32939_%0b20080528.pdf









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In the United States providers of a (two-way) interconnected VoIP service which permit calls to be made to

and received from traditional telephone networks with a nomadic feature (allowing the VoIP services to be

used from different locations, as long as a broadband connection is available) are required to have a

mechanism in place that would allow subscribers to update and register their new location as it was

demonstrated to be impossible for the VoIP provider to otherwise know the subscriber’s location. Whilst

VON acknowledges that this interim solution may serve some policy objectives, it considers this a flawed

approach as it creates the wrong consumer expectations and does not guarantee reliable information. In

other terms, if this information would be relied upon in case a caller is unable to verbally provide their

location it could lead to inaccurate location identifications and hence pose a public safety risk.

VON would like to point out that the provision of caller location information for a network independent

VoIP service or application provider - and especially in case of nomadic use - is more difficult than for a

PSTN service provider (or a Voice over Broadband provider that both supplies the network and the voice

service) since there is no linkage between the caller’s location and the underlying physical network.

Moreover, VoIP applications in general do not have inherent location function, but rather depend on other

sources for location information including: static or dynamic IP addresses, unaffiliated network access

providers, third party location solutions providers or platform location APIs. But at the time being these

sources of location information are not well developed and face a number of challenges, including:

Existing 802.11 standards for enabling automatic location have significant practical limitations as in

requiring upgrading (or even replacing) tens of millions of Wi-Fi access points as well as hundreds of

millions of existing Wi-Fi enabled handsets and other devices that would also require the updated

hardware and chipsets.

Calculating location based on Wi-Fi signal ‘Time of Arrival’ (TOA) technologies or measuring signal

strength has significant limitations and challenges, in particular in indoor environments.

Commercially available location based services are not sufficient to support emergency location.

A more detailed analysis of these various sources of location information is provided below.

1. First, with respect to the limitations in 802.11 location standards, the IEEE 802.11 specifications4

that could enable the automatic location of an access point have not been tested or certified by the

Wi-Fi Alliance (the worldwide certification body for wireless LAN technology). Hence, these

specifications have not been implemented on a wide scale, either within access points or the

chipsets in devices communicating with those access points. As a result, even if the Wi-Fi Alliance

4IEEE 802.11k is designed to provide geospatial location of an access point and IEEE 802.11y is designed to provide civic location,

but neither of these specifications has been appropriately tested and certified – much less deployed.





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adopted and certified the 802.11 location standards these solutions could only be implemented

through physical upgrades. Thus, reliance on these 802.11 standards is not a practical solution.

2. Second, regarding the calculation of a Wi-Fi user’s location, there are significant challenges in

accurately locating the user communicating with a particular access point at any given time. In the

case of a ‘hot spot’ (i.e. a single access point as opposed to a WLAN with multiple access points),

users theoretically can be located by a civic address loaded into the ‘hot spot’ (e.g. Joe’s Coffee Shop

at 10th and L). However, given the intended propagation of a single access point (oftentimes more

than 100m) and the possibility that a device will remain connected to that access point even outside

the intended range, there can be significant uncertainty in the location information. For example, a

user who connected at the coffee shop may stay connected to the coffee shop’s ‘hot spot’ even

after the user has walked out of the store. Moreover, if that coffee shop is inside a shopping mall,

the user could be in an entirely different store inside the mall while the coffee shop’s location

information would be provided in case of emergency.

In the case of WLANs, network access providers could be able to determine a user’s location

through the access point or station measurements, e.g. signal strength or time of arrival (TOA),

rather than direct communication between the station and access point. But in general TOA

measurements require hardware support within the user’s device or the access point, and most

devices with WLAN chipsets in use do not include that supporting hardware. Therefore, the most

probable approach to calculating location would be the use of signal strength measurements.

But measuring a user’s location using the signal strength approach poses two significant

challenges.5 First, the accuracy of the location provided within a WLAN is only as good as the

location information that has been programmed into each of the wireless access points, as well as

the signal measurements and propagation model. In deployments that utilize multiple access points

(e.g. a WLAN), such as an enterprise or campus environment, companies typically do not determine

(much less record and manage) the geospatial or civic location of each access point as part of the

WLAN installation process. Therefore, significant effort would be required to determine the

geospatial and / or civic location of each access point within a WLAN to enable accurate location

calculation – using, e.g. strength of signal – to be made and provided. Second, wireless indoor

5In addition to the technical challenges described herein, there are practical limitations. In some situations, WLAN access is not

available to ‘anyone’. Many enterprise networks do not enable unauthenticated access to their networks, an d instead require some

kind of sign-up procedure for ‘guest access’. Oftentimes, this ‘guest access’ comes with restrictions on access to services such as

VoIP and/or location.





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location is particularly challenging due, among other things, to the propagation challenges

presented inside buildings. Location estimates indoors are complicated by walls, floors, metal pipes,

and ceilings, resulting in wireless devices attaching to Wi-Fi access points that are not necessarily

the nearest station. In fact, devices can remain associated with a wireless access point even though

the user may have wandered outside the range within which data can be reliably decoded.

Therefore, as noted above in the ‘hot spot’ example, a simplistic approach that assigns the user’s

location based on the location of the access point to which the device is associated can result in

location estimates that are wildly inaccurate. Similarly, the accuracy of a strength-of-signal

measurement can be negatively impacted by a bathroom wall where water pipes can interfere with

signal propagation, i.e. reduce the strength of that signal, and suggest that an access point is much

farther away from the user than it actually is. Even excluding these effects, WLAN location estimates

can have significant uncertainty regions due to the distance of an access point’s intended

propagation (e.g. 100m at 1 Mbps). Moreover, in an indoor environment this uncertainty region is

exacerbated by the fact that the 100m range can span multiple floors.

3. Third, concerning the commercial location based services, there are application programming

interfaces (APIs) that could be used with VoIP applications to enable the receipt of location

information, but it should be noted that these were not designed with emergency services purposes

in mind.

VON thus remarks that, as illustrated above, locating wireless devices will continue to present challenges

due to the nature of wireless networks and the topographies (indoor and outdoor setting) wherein these

operate. Therefore we believe that the ACMA’s efforts should be concentrated on the core communication

services to allow the ACMA to both manage consumers’ expectations and create an environment wherein

interested stakeholders can work together on solutions that will stand the test over time. Hence, VON

endorses the ACMA’s preliminary conclusion that a single integrated model for acquiring and delivering

location information that is independent of the particular network on which an emergency call originates,

and is capable of handling a range of different media as part of the call, may be a logical progression. Such

solution will notably need to support communications that use both internet names and addresses and

telephone numbers. It will also need to address the immediate technological and operational hurdles

preventing a move towards a Next Generation 9-1-1 / 0-0-0 interoperable with IP-enabled products,

services, applications and devices.

However, an integrated long term approach is not for tomorrow. VON considers it premature to issue

specific rules at this time for network independent service providers. It is interesting to note in that context





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that the Canadian regulator CRTC reached a similar conclusion as, in looking at the benefits vs. the costs of

mandating location capabilities on nomadic 911, it has decided that such a mandate is not justified.6

Imposing additional requirements in the short term on network independent VoIP service providers,

especially when their service or application includes a nomadic component, may harm public safety, stifle

innovation, stall competition, and limit access to innovative and evolving communication options. The

OECD has expressed a similar concern, after seeing what happened to the nomadic VoIP market in the

United States, stating that regulators “should always consider current technical constraints” and “while

measures should aim to guarantee the safety of users, they should not constitute an unfair burden for

providers, and stifle the evolution and development of VoIP”.7

Furthermore, because VoIP services are

global and the market for IP communications continues to develop, we believe that proscriptive rules

ultimately could cause more harm than good for all consumers and create unhelpful precedents for actions

in other countries.

In the meantime, public resources should be used to educate consumers about the appropriate services

and devices from which consumers can expect to make emergency services calls, while at the same time

setting appropriate consumer expectations, e.g. the limits of network independent VoIP’s location

capabilities. These efforts should than resolve the current misalignment and thus reinforce rather than

confuse consumers’ expectation on the providers delivering access to emergency services. If the ACMA

would consider interim alternative approaches other than the existing model and adopting measures in the

near term for the delivery of real time location information to emergency service organisations, it is of

utmost importance that any measures should be associated with and based on the principles of

technological and commercial feasibility.

Question 6

What is a transition path to an IP-based services approach for each of the three strategies to acquire

location information from:

> end-users

6 CRTC. (2010). Viability of Proposals for the Provision of E9-1-1 service for Nomadic and Fixed/Non-Native VoIP Subscribers

[Telecom Decision CRTC 2010-387]. Retrieved at, http://www.crtc.gc.ca/eng/archive/2010/2010-387.pdf . See Paragraphs 12 and

41.

7See OECD. (2008). Convergence and Next Generation Networks [DSTI/ICCP/CISP(2007)2/FINAL]. OECD: Paris. Retrieved at,

http://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=DSTI/ICCP/CISP%282007%292/FINAL&docLanguage=En.

p. 40.

http://www.crtc.gc.ca/eng/archive/2010/2010-387.pdf



http://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=DSTI/ICCP/CISP%282007%292/FINAL&docLanguage=En








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> end users’ devices

> access networks

> information updates?

What are the implications under each of these strategies for numbering administrative arrangements?

We refer to our response above to questions 3 to 5.

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We thank you in advance for taking consideration of these views. Feel free to contact Herman Rucic, VON

Europe, by phone (+ 32 (0)478 966701) or email ([email protected] ) should you need further

information.

About VON Coalition Europe

The Voice on the Net (VON) Coalition Europe was launched in December 2007 by leading Internet communications

and technology companies, on the cutting edge to create an authoritative voice for the Internet-enabled

communications industry. Its current members are iBasis, Google, Microsoft, Skype, Viber and Voxbone.

The VON Coalition Europe notably focuses on educating and informing policymakers in the European Union and

abroad in order to promote responsible government policies that enable innovation and the many benefits that

Internet voice innovations can deliver.

mailto:[email protected]




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VON Europe - Comments on ACMA’s Consultation on Customer Location Information and Numbering Data