Every customer a ‘vulnerable customer’ for 111 calling

ComCom works on 111 Contact Code

The Commerce Commission has issued a consultation paper on how it proposes to ensure that vulnerable people can dial 111 in the event of a power failure that disables their landline service, saying there should be no distinction between vulnerable people and the general population.

The paper is the first step in the commission’s development of a 111 Contact Code.

The issue has arisen because, absent on-premises battery backup, new fixed communications services delivered over UFB or fixed wireless will not function in the event of power failure at the customer’s premises. Copper line telephone handsets draw their power from the exchange.

The legislation requires that “vulnerable consumers, or persons on their behalf, have reasonable access to an appropriate means to contact the 111 emergency service in the event of a power failure.”

However the commission has come out against any move to identify vulnerable consumers and proposes that the code covering 111 access from fixed lines should apply to all consumers.

It says the former approach would require it to define vulnerable consumers by consulting on the potential conditions that cause a consumer to be at particular risk of requiring the 111 emergency service, and this would require a level of self-identification for consumers.

“Some consumers may not want to identify their vulnerability or give their telecommunications provider access to this information and … some vulnerability will be very difficult to know in advance,” it argues.

Further the consultation paper says: “This approach would require the ongoing maintenance of a comprehensive register of vulnerable consumers. We have concerns about the difficulty of coordinating and maintaining such a register, which would require regular updating as particular vulnerabilities were identified or resolved, as well as appropriate privacy and data protection measures.”

Instead it proposes that, with mobile networks cover 97 percent of the population, and over 75 percent of 111 calls already coming from mobile phones these provide an adequate means of contacting 111 for most consumers.

“For these vulnerable consumers, we consider that in most cases a mobile voice and/or text (SMS) connection is likely to provide an appropriate means to contact the 111 emergency service in the event of a power failure.”

In those cases where a consumer does not own a mobile phone it expects the code would require the RSP to provide only a very basic one. “It may be desirable if such a phone or device was only capable of making emergency calls, as this would reduce any risk of these devices being used for other purposes or sold between consumers.”

In the event that the consumer had no mobile coverage, or was unable to use a mobile phone because of “electromagnetic hypersensitivity,” the commission has not said definitively that battery backup for a UFB or fixed wireless service should be provided.

“We do not have a preliminary view on what the appropriate alternatives should be, and the code could provide flexibility by allowing the service providers to decide on what alternatives they offer,” it says.

“One alternative could be a battery backup that powers the CPE in the event of a power failure at the consumer’s premises.”

A copy of the consultation paper can be found on the Commission’s website. Submissions close on 11 October. A draft code is due to be released for consultation in February 2020, and  the final code is due in June 2020.

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