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# 256049 12-Sep-2019 09:34
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Just received:

 

 

The Commerce Commission has released a consultation paper outlining its emerging views and proposed approach to establishing the 111 Contact Code.

The Government’s Ultra-Fast Broadband (UFB) programme will see 87% of homes and businesses able to connect to fibre networks by the end of 2022. The Government’s Rural Broadband Initiative is also improving broadband connections in rural areas, largely using wireless technology.

As consumers move away from using the old copper telephone network to using new technologies such as fibre, a small number may be unable to call 111 during a power cut. This is because unlike copper, newer technologies rely on electricity in the home to work.

Telecommunications Commissioner Dr Stephen Gale said the 111 Contact Code is intended to outline the steps telecommunications providers must take to ensure consumers can continue to call emergency services in a power cut when they move to new technologies.

“The transition to fibre and wireless technologies is well underway and once fibre has been rolled out in areas, and we have put a number of safeguards in place, Chorus will be able to choose to stop supplying copper services. As the copper network is gradually withdrawn there may be a small number of New Zealanders who could be left without the means to call 111 during an emergency if they have a power failure.  The 111 Contact Code we are developing is intended to put in place protections for those vulnerable consumers,” Dr Gale said.

“The consultation paper released today sets out our proposed approach to establishing the Code, including how we should determine who is vulnerable. We propose to test if a consumer is vulnerable based on the technology they have access to and whether it will work during a power cut. We also explore what some of the appropriate alternatives for consumers to contact emergency services might be. Our initial proposal is that mobile phones are provided for those who have coverage and can use one, and a battery back-up for the fixed line phone otherwise. We are keen to hear from industry and consumer groups as we begin to develop the details of the Code.”

A copy of the consultation paper and an infographic can be found on the Commission’s website. Consumers can also use the online form provided to respond to four key questions we are keen to hear from them on. Submissions close on 11 October 2019.

This is the first step in developing the 111 Contact Code. A draft Code is due to be released for consultation in February 2020, with the final Code to be published in June 2020.

Background

The Ministry of Business, Innovation and Employment's (MBIE) 2018 review of the Telecommunications Act 2001 (Act) identified that as consumers transition away from the copper network to next generation technologies, they may be unable to access emergency services during a power outage and are therefore potentially vulnerable. Parliament decided to make amendments to the Act to address access to the 111 emergency service in the event of a power failure. It tasked the Commission with creating a Code that protects consumers by imposing obligations on providers of telecommunications services. We must create the Code by no later than 1 January 2022.

 





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  # 2315456 12-Sep-2019 09:50
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Hmmm.

 

I propose the idea that, just as with copper, there should be a digital version of 111 ?

 

In other words, why are we considering alleged boundaries of technology as a dictate to public access of emergency services?

 

My thoughts would be that a condition of public broadcasting via the internet, e.g., the right to be an ISP, include a landing page with access to emergency and other public services.

 

 


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  # 2316447 12-Sep-2019 11:12
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People will need to think differently about 111 in an emergency

 

I live in Wellington, and one day the big one will hit, I have 3x USB mobile charging banks which I rotate to make sure at least 2 are fully charged, in addition I have a decent UPS on my ONT / Router / ATA

 

We need to think about the elderly tho a lot of still think 111 should always work from their corded phone. When Baseband IP comes fully on online people 2KM or more from the exchange building will have voice fed from a Cabinet rather than exchange which has little backup vs the exchange which has batteries and a diesel generator. This is because I suspect the first lot of copper that Chorus will want to retire the 2000 pair copper cables between the MDF and the Cabinets

 

No solution is perfect, when Kaikoura happened the 2000 pair cables got severed taking landline voice with it so it depends on the nature of the disaster as to what services will be available

 

 

 

 


 
 
 
 


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  # 2316488 12-Sep-2019 13:26
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I really wonder how well the mobile network would cope in a major disaster. I am assuming that not all cellsites have battery backup and satellite backhaul.


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  # 2316511 12-Sep-2019 14:22
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LFC's should simply provide every single household with battery backup for the ONT. ISP's that chose to deliver VOIP phone services through anything other than the ONT should be required to provide battery backup for the router/ATA/whatever.





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  # 2316534 12-Sep-2019 14:53
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Lias:

 

LFC's should simply provide every single household with battery backup for the ONT. ISP's that chose to deliver VOIP phone services through anything other than the ONT should be required to provide battery backup for the router/ATA/whatever.

 

 

What about the 80 something year/old (Vulnerable Population)  who still just have a corded phone connected to a copper phone line and nothing else?


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  # 2316661 12-Sep-2019 17:08
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nztim:

 

Lias:

 

LFC's should simply provide every single household with battery backup for the ONT. ISP's that chose to deliver VOIP phone services through anything other than the ONT should be required to provide battery backup for the router/ATA/whatever.

 

 

What about the 80 something year/old (Vulnerable Population)  who still just have a corded phone connected to a copper phone line and nothing else?

 

 

Unless I blinked, a big part of this is because the PSTN is being decommissioned, so they won't still have that? At best they might have POTS to a cabinet with VOIP backhaul (which won't be battery backed up at all / for long), but I'd imagine POTS will also be on the chopping block in fairly short order in any area with UFB deployed. 





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  # 2316675 12-Sep-2019 17:41
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alasta:

I really wonder how well the mobile network would cope in a major disaster. I am assuming that not all cellsites have battery backup and satellite backhaul.


If Christchurch was anything to go by all the the sites survived pretty well. The majority of Spark sites have either battery or battery plus generator as they are in an exchange. Sites also have an external power connections to allow a generator to be dropped there.
Then Spark have a stack of generators on standby and I think the airforce flew in generators during Christchurch.
I would presume the other mobile providers have the same / similar.





 
 
 
 


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  # 2316677 12-Sep-2019 17:44
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Lias:

LFC's should simply provide every single household with battery backup for the ONT. ISP's that chose to deliver VOIP phone services through anything other than the ONT should be required to provide battery backup for the router/ATA/whatever.


No. As the logistics and risk management around the battery lifecycle is *HUGE*.
What happens if a battery exploded and burnt your house down? Would the LFC be responsible?





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  # 2316687 12-Sep-2019 18:26
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Lias:

nztim:


Lias:


LFC's should simply provide every single household with battery backup for the ONT. ISP's that chose to deliver VOIP phone services through anything other than the ONT should be required to provide battery backup for the router/ATA/whatever.



What about the 80 something year/old (Vulnerable Population)  who still just have a corded phone connected to a copper phone line and nothing else?



Unless I blinked, a big part of this is because the PSTN is being decommissioned, so they won't still have that? At best they might have POTS to a cabinet with VOIP backhaul (which won't be battery backed up at all / for long), but I'd imagine POTS will also be on the chopping block in fairly short order in any area with UFB deployed. 



Baseband IP is supposed to replace/emulate the PSTN with sip and a copper feed to the closest cabinet or exchange, my problem with it is that service in a power outage if you are fed from a cabinet will last significantly shorter than if you are connected directly from to the exchange (ie you live 2km or more)

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  # 2316688 12-Sep-2019 18:29
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BarTender:
Lias:

LFC's should simply provide every single household with battery backup for the ONT. ISP's that chose to deliver VOIP phone services through anything other than the ONT should be required to provide battery backup for the router/ATA/whatever.


No. As the logistics and risk management around the battery lifecycle is *HUGE*.
What happens if a battery exploded and burnt your house down? Would the LFC be responsible?


That lesson was learnt recently with the batteries that were sent out with the wireless landline kits

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  # 2316691 12-Sep-2019 18:53
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alasta:

 

I really wonder how well the mobile network would cope in a major disaster. I am assuming that not all cellsites have battery backup and satellite backhaul.

 

 

See ChCh. Not well initially. Demand killed it.


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  # 2316735 12-Sep-2019 19:32
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BarTender:
Lias:

 

LFC's should simply provide every single household with battery backup for the ONT. ISP's that chose to deliver VOIP phone services through anything other than the ONT should be required to provide battery backup for the router/ATA/whatever.

 


No. As the logistics and risk management around the battery lifecycle is *HUGE*.
What happens if a battery exploded and burnt your house down? Would the LFC be responsible?

 

Absolutely, but I'm sure they'd have insurance against it. I have no doubt it would be expensive to maintain and replace that many UPS's, but I'm fairly sure it's cheaper than keeping the PSTN running forever. The obligation is on them to leave consumers no worse off than they are now, and if that means them having to track, maintain, and replace a million UPS's around the country, so be it. 





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  # 2316765 12-Sep-2019 20:08
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The UPS issue has already been discussed numerous times by the industry and MBIE. I'm not really sure why yet another report is needed.

 

End users don't want to pay to maintain a UPS and until that happens things will go nowhere.

 

 


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  # 2316770 12-Sep-2019 20:17
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Tracer:

 

alasta:

 

I really wonder how well the mobile network would cope in a major disaster. I am assuming that not all cellsites have battery backup and satellite backhaul.

 

 

See ChCh. Not well initially. Demand killed it.

 

 

Actually, I was in one of the worst hit areas of Chch (in terms of broken infrastructure - I was without power or sewerage for several weeks). I never lost Cell or DSL. I think all the providers not only did a spectacular job with their responses, but more importantly, with their planning beforehand.

 

Cheers - N

 

 





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Please note all comments are the product of my own brain and don't necessarily represent the position or opinions of my employer, previous employers, colleagues, friends or pets.


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  # 2316771 12-Sep-2019 20:18
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Lias:

 

BarTender:
Lias:

 

LFC's should simply provide every single household with battery backup for the ONT. ISP's that chose to deliver VOIP phone services through anything other than the ONT should be required to provide battery backup for the router/ATA/whatever.

 


No. As the logistics and risk management around the battery lifecycle is *HUGE*.
What happens if a battery exploded and burnt your house down? Would the LFC be responsible?

 

Absolutely, but I'm sure they'd have insurance against it. I have no doubt it would be expensive to maintain and replace that many UPS's, but I'm fairly sure it's cheaper than keeping the PSTN running forever. The obligation is on them to leave consumers no worse off than they are now, and if that means them having to track, maintain, and replace a million UPS's around the country, so be it. 

 

 

Presumably the cost for that massive undertaking shouldn't be borne by the consumer either?

 

N.

 

 





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Please note all comments are the product of my own brain and don't necessarily represent the position or opinions of my employer, previous employers, colleagues, friends or pets.


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