OFCOM, again, again

Now we have the location data sorted, I have been trying to work out ways to help with providing more reliable and accurate data to emergency services for calls to 999/112. This is specially important where we don't have a location for a VoIP number or the caller is using from more than one place (nomadic).

The cunning plan I came up with works because a lot of our VoIP customers are also our Internet customers, and that is likely to be common with lots of ISP+VoIP providers. Also, a lot of our Internet customers are on DSL lines.

Basically, if we have no location data but the call comes from one of our IPs that is on a broadband line - we can find the phone number of the broadband line (a BT phone number on BT exchange).

So why not send that as the calling number on the 999 call. That way they get the location spot on.

This has huge advantages over the alternative proposals for handling nomadic callers.
  • 999 service need no new protocols or systems to get the location from IP
  • End user has a typically familiar number quoted on the call to avoid any confusion
  • The area code of the number is what the 999 operator is expecting for the location (often not the case with VoIP services)
  • The VoIP+ISP provider is not having to maintain the location data
  • It can be implemented by many ISP+VoIP providers and is self contained
  • It has none of the privacy issues or feature creep of NICC ND1638
The disadvantage is that it only works for calls from our IP addresses using our VoIP service, but no solution is perfect and this covers a lot of cases I am sure.

I suggested to OFCOM. They shoot it down in flames because it means we would be relying on BT to have accurate location data and we have no way to guarantee that!

What?!?!??! This would be providing location data that is very very likely to be very accurate instead of no location data. Clearly a huge step in the right direction. And OFCOM think we should not do it.

I wonder why I bother.

P.S. More ideas: we could even have contracts with other ISPs such that we would pass the 999 call to them to pass to 999 if it is one of their IP addresses so they can insert the CLI on the way (not tell us the CLI) - as long as we have a short timeout fallback if they don't reply or reject the call so we can send on without location data anyway. Of course the call media can go direct from their IP to their 999 gateway then reducing the interdependencies.


  1. There is another down side to sending the CLI of the POTS line, in that the end user may not have an phone plugged into it, they may solely be relying on the VOIP handset (with backup being mobile), so any call backs may not get through to anyone.

    Whilst I understand the importance of location data, I don't really see why OFCOM are getting so worked up over it; at the end of the day, if I call 999 from my mobile, they're not going to have any (realtime) location data are they? (yes I know that technically the network could triangulate it, but they don't do that in real time and provide to the emergency services).

  2. They (mobile providers) do provide real time location data - they have to provide at least cell based data and their location services stuff can do closer which, AFAIK, they do provide.

    The call back issue is a fun one - yes, that is a disadvantage - but they will quote the number and if needs be ask for a contact number (if you can talk).

    What is interesting is OFCOM raise the same concern when we said we would map 0200 to some users and did not reply when I asked where exactly the "call backable" requirement was in the regs. There is no such regulation, and indeed one can have outgoing only lines which can call 999. OFCOM basically made up that requirement (even though it is a valid concern).

  3. Another problem is that AAISP IPs may appear even when the user is not actually at the address that the broadband line is on. Some people may be tunnelling the IPs. One of my IP addresses can sometimes be 120 miles away from the rest of the network...

    But OFCOM are going to have to eventually realise that you are never ever going to get 100% accurate location data with VoIP. That's just one thing of IP networks that doesn't fit on to their telephone network model.

  4. Colour me cynical... are OFCOM staffed with FaveTelco people on secondment/rotation or holding FaveTelco shares?

  5. I'm just thinking, would it not be easier to have the customer enter location data themselves? If you state it is for 999 and leave it up to the customer what's wrong with that?

  6. Sean, we do that - that is the easy bit - what we are discussing here is cases where customers have not provided details or use the service from varying locations.

  7. Just out of interest, have Ofcom given a statement of requirements, or are they refusing to tell you what they want and waiting for you to ask, "Is this OK? Is that OK? Is the other OK?"?

    It always amazes me that some organisations demand you do a thing but don't actually tell you what that thing is.

  8. They publish the general conditions - which (IMHO) is a no-brainer to comply with, but they somehow read differently.

    Usually when asked they say "seek independent legal advice" which is a cop out as they decide.

  9. RevK: So let me get this straight. You're saying that OFCOM publish the conditions, you comply with those conditions, then OFCOM turn around and say "You're not meeting our conditions." but refuse to tell you what to do to meet them and then when pressed further ask you to consult a lawyer to ensure that you meet the conditions that they themselves set out???

    Madness, utter madness.

    Do we need to be writing letters to our MP's about this? :) (I know there are "more important" things but at the end of the day, who regulates the regulators?)

  10. Also, they make up their own rules which are not in the conditions and require them to be met too. e.g. that the number we present has to be one they can call back. This clearly outlaws all "outgoing only" type lines, or indeed any sort of ACR or incoming call diversion, which someone may have on a line as they would then present a number to 999 that cannot be called back!

    Of course there is no such rule, but that does not stop OFCOM insisting.

  11. You know, I wouldn't bother. Is there anything stopping you sticking with "not intended for use with emergency services" such as

    Google Voice for UK customers (released yesterday which is what brought this to my attention)

    From http://www.google.com/intl/en-GB/googlevoice/legal-notices.html

    "You understand and agree that Google Voice is an enhanced call management application and that Google Voice is not capable of placing or receiving emergency services calls."

    or the Skype and Emergency Services page

    kype is a piece of software that enables a rich communications experience - an entirely new way to communicate online. But please remember that Skype is not intended to support any emergency calls to any type of hospitals, law enforcement agencies, medical care unit or any type of emergency services of any kind. Skype is not a traditional telephone service or a replacement for your primary telephone service (landline or mobile phone). In particular, apart from in very limited circumstances, Skype does not allow you to make emergency calls to emergency services. You must make alternative communications arrangements to ensure that you can make emergency calls if needed."

    If these guys can cop-out of it, why not you?

  12. Well, we (and they) are not allowed to opt out if we allow calls to numbers in the national dialling plan. OFCOM seemed to think skype was covered.

  13. Why not use the network number for location data, and the presentation number for the default callback number? Wouldn't that be the most sensible choice?

  14. In the VoIP headers we can sensibly only set one number I think - I am not keen on testing different ways to pass different numbers to 999 to be honest, but yes, if signally is allowing two numbers that would be a neat idea. I had pondered if that would be possible.

  15. That's funny. Why prohibit users from making emergency calls? What if they're really in a bind and the only thing they have access to is Google Voice or Skype?

    telephone recording device


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