AW: Ofcom VoIP Public Forum
- Date: Tue, 16 Mar 2004 00:36:57 +0100
Just coming back from the next public forum in Brussels, I consider
this whole dicussion very curious. Caused by a circular definition in the Universal
Service Directive (John Horrocks said this is trap laywers normally learn to avoid in the
first year of university), now whole Europe is going round in circles.
What is is even more funny is the fact, that numbers ar normally used to be called, and not to
call somebody (except for CLI). Now one can say ok, to call an emergency service you have to
display a CLI to be called back and also for identification (how many anonymous pre-paid cards
are out there? 200 million?)
So from the number you also get the location - aha that is the reason. So you get a location
on mobile calls - since when? Nobody cared 10 years ago.
But you could make emergancy calls from mobile phone from the beginning. Nobody
came up with the idea to say: You MUST NOT make emergency calls from mobile
phone until you can provide the exact location, identification and number to call back
on a mobile phone.
BTW, with mobile phones it is a REQUIREMENT to be able to make emergency calls
to 112 without a SIM card, which means without identification and also without number.
So what is a requirement in mobile phone is prohibited in VoIP.
Only because a § in a piece of paper is logically flawed..
Thats legistic logic.
IMHO we should really try to find ways to allow emergency services
for VoIP in whatever way proves possible.
I do not like babies to burn because of a piece of legal crap.
Von: Christian de Larrinaga 
Gesendet: Mo 15.03.2004 19:11
An: Conroy, Lawrence (SMTP); Kennedy, Steve
Betreff: RE: Ofcom VoIP Public Forum
> Hi Folks,
> note the amusing bit - must NOT provide Emergency service, ...
> i.e. one can't provide even a partial outgoing service - VoIP
> users MUST be left to drown/burn/... without informing anyone,
> if incoming calls to them are provided via a number in the 056x range.
> I wasn't at the meeting, and looking at the discussion document
> I hadn't realised that this was the intention of the Regulator.
> If that *was* stated at the meeting, then does this mean that,
> were it possible to connect to the emergency services centre
> by dialling out to 999 via a PSTN gateway (albeit without the
> emergency services knowing the correct geo-loc of the caller
> *automatically*), doing so would break the rules?
Ofcom is essentially asking for INPUT as to whether what they call voice
over broadband services (VoB) can be PATS compliant (they think NOT but have
said they are OPEN to being told different).
Actually the problem is the old one of the Regulator thinking about an
Internet service in terms of a telephone service and so are fixated on the
Public Access Telephony Provisions as applied to a narrow range of IP voice
services which they define as VoB. (typically a steam phone connected to an
ATA box into DSL).
It is clear that PATS provisions are regarded as inflexible and you take on
*ALL* of PATS (including those bits which are clearly specific to telecoms
QoS issues and so not a good fit for Internet services) or none.
So just setting up a number plan to route 999 to an emergency number call
centre is not enough to comply with PAT. It is not clear for instance that
provisioning 18.104.22.168.4.e164.arpa would answer the PAT's question even if it
answered a significant part of the issue of access to emergency services.
Ofcom has got very concerned for the UK's babysitters.
They have described a scenario where a babysitter discovers a fire, picks up
VoB phone dials 999, nobody answers and so the unfortunate babies burn and
Ofcom have to deal with tabloids screaming "Ofcom Internet phones kill
So the afternoon session at Ofcom concentrated entirely on taking input from
delegates how to inform consumers reliably that a phone that looks like a
phone, behaves like a phone may NOT fully behave like a phone and offer
emergency services etc.
One of the things that came out on the day is the very significant pressure
being applied on Ofcom to not only provide non geographic 056 numbers to IP
users but also full geographic numbers.
It seems that Ofcom have been approached by a significant number of telecoms
dealers trying to sign up estate agencies to VoB who apparently are
demanding they are given local telephone numbers irrespective of whether
they are using IP or PSTN devices because they wish to be known as "local"!
This issue also plays a significant part in Ofcom's consultation. So we
should expect to see a number of consultation demands for the full UK e164
geographic number range to be used for VoB numbers and not just 056 as Ofcom
> Was it also stated that a non-PACS provider must NOT provide
> any of the other services under the normal obligations?
> I had thought that the original intention was that customers
> should KNOW that they were getting a service that MIGHT not
> provide all of the good things under the obligations *as they
> are normally defined*; not that partial provision was barred.
> I do so love Regulations.
In which case you will be very pleased to learn that OFcom regard the PATS
provisions as untouchable because they form part of an EU Directive.
So it's the EU's fault :-)