Otis Elevator Company - Department of Communications

Otis Elevator Company Pty Ltd
A.B.N. 56 002 873 065
HEAD OFFICE
5-9 Ricketty Street, Mascot NSW 2020, Australia
P O Box 6022, Alexandria NSW 2015, Australia
Telephone 61 2 8338 2700 Facsimile 61 2 8338 2301
OTIS
24 Hour Service: 1800 626 847
www.otis.com
OTIS ELEVATOR COMPANY Submission to
Implementation of the National Broadband Network
Migration Assurance Policy Consultation Paper September 2014
About OTIS ELEVATOR COMPANY
OTIS ELEVATOR COMPANY is the largest provider of lift maintenance services in
the Australian market.
Otis estimates that there are over 100,000 lifts in the Australian market and each one
of these is required by the Australian lift code and the Australian Building code to
have a means of voice communication from the lift car to a call centre. This lift phone
is essential to passengers being able to raise an alarm whenever a lift malfunctions
and entraps them.
Otis also employs back to base technology that enables the remote monitor of lift
operation and interrogate and reinstate lifts to service under certain conditions.
Lift phones and back to base lift monitoring utilise phone line.
Responsibility for the phone line cabling and connections within the confines of the lift
equipment (from lift controller to lift car) is the responsibility of the incumbent lift
service provider, all other line and connection responsibility outside these areas is
the responsibility of others (premises owner, communications service provider).
For reliable communication lift phones and lift monitoring systems require a PSTN
quality phone line. This can be achieved through the NBN Uni_V connection yet our
experience is that there are limited ‘Retail Service Providers’ (RSP) capable of
providing this type of connection.
Otis view on Department of Communication Questions
What do you see as being the most significant barrier to migrating your
customers to the NBN?
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what role do you think you can play in breaking down this barrier?
what approaches would you encourage the Communications Alliance to
pursue?
Otis sees the biggest barrier to migrating customers to NBN, aside from costs, is a
lack of knowledge and understanding of RSP’s to the requirements for lift equipment
communication connections.
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The role Otis play in breaking down this barrier includes notifying customers of
impending transition to NBN for their equipment and providing testing support
to RSP’s.
We encourage Communication Alliance to:
o mandate requirement that lift phones connected via Uni_V port
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o
o
provide easily accessible educational and guidance material to RSP’s
including lift communication competence to RSP licensing requirements
What role do you think you should play in the migration of your customers to
the NBN?
Where do you think you can value-add the most to the migration process?
The role Otis play in migration of customers includes proactively notifying customers
of impending transition to NBN for their equipment and providing testing support to
RSP’s.
Otis customers require a reliable lift compliant service with minimal downtime at the
point of transition.
NBN to proactively provide complete and concise information to the customer
regarding lift industry compliance.
Are there any incentives, outside of government finding, that would encourage
greater industry engagement and cooperation in the NBN migration process?
Otis has worked on a number of fronts with NBN from the outset.
Otis believes that greater marketing of the benefits of NBN combined with concerted
educational programs will increase industry engagement. Otis believes the greatest
barriers to engagement are a lack of knowledge on what is required and what needs
to be done to seamlessly implement NBN.
Are there any processes or solutions that, if implemented, would discourage
industry from engaging and cooperating fully in the NBN migration process?
Reduction of UNI-V service provisions and the current limited RSP support for quality
analogue phones lines is discouraging industry participation.
NBN requirement is that lift phone cabling must meet current industry standards. The
cabling compliance inside the lift confines is lift contractors responsibility but the
building cabling is the building owner’s responsibility. NBN must clearly define to the
customer whose responsibility this is and for existing installation the requirements
and options to make the cabling comply.
Otis has maintained that a necessary requirement, in order to properly protect Otis
customers and to meet lift code requirements and client expectations, is to provide a
battery back-up for all customer equipment and critical network components.
Otis customers require a UNI-V TC1 voice grade service with optional battery backup as part of the NBN solution going forward.
What is your vision for the migration of services to the NBN? What should the
migration arrangements look like in 2015?
Otis support the continuation of the UNI-V service and battery backup installations.
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Certification of RSP’s to full suite of essential services NBN supports, supported by
legislating UNI_V connection.
Educational programs and industry forums to assist and guide the RSP industry.
How do we best integrate and leverage the lessons learned from the migration
experience in the initial fibre rollout regions into a long-term migration model.
Clear and concise communication sharing the lessons learned.
How do Communications Alliance best connect with industry stakeholders
including retail service providers and application service providers in
developing processes and solutions for supporting successful migration?
Otis believes best means on connecting with industry stakeholders is through
industry bodies. In the case of lifts this is through the Australian Elevator
Association.
What performance targets should the Australian Government set for the
migration of services to the NBN?
Performance targets need to be balanced between conversion rate and customer
and industry satisfaction. Understanding the impact to all stakeholders in the
process will assist in making the roll out more successful through greater
engagement and expediting the addressing barriers to introduction.
How can we best protect and support consumers telecommunications services
when migrating to the NBN?
NBN is required to inform the customer of the option of the surge protection device in
the case of existing non-compliant cabling.
Ensure that all customer equipment and any associated node has a battery back-up
facility.
Ensure that any client premises equipment supplied by NBN Co or an RSP is fully
compatible with existing customer equipment such as lift monitoring equipment and
voice services.
Otis believes the migration to the NBN has the potential to disadvantage our
customers, especially as we require a reliable voice telephone service and a lesser
requirement on a fast data/internet service.
What steps should we be taking to encourage a concerted effort by industry to
improve the migration arrangements to the NBN?
Improving communication and ensuring that no out of pocket costs are borne by
either the ASP or the client.
Provide technological certainty to industry.
What characteristics of the proposed Migration Assurance Policy Framework
could work well and what areas require further consideration and
development?
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Effective communication to our customers and RSP’s of their responsibilities in the
rollout.
The extent to which companies will need to make preparations for the NBN including
new Customer Equipment or existing physical cabling.
Do you have any views on the roles and responsibilities for the parties
involved in the migration process?
Otis sees a lack of clarity on roles and responsibilities as one of the key barriers to
the NBN roll out. Otis suggests the following areas need to be considered:
1. ASP’s and NBN to educate consumers and RSP’s about the requirements of lift
communications
2. Require RSPs to perform a survey of existing telephone equipment in a prospective
client’s premises.
3. Require RSPs to properly inform potential client’s about the compatibility of their
service offering with equipment identified in point 1 above.
4. Require RSPs to include information about service compatibility with lift
communications equipment in their product sales information.
5. Place a list of RSP’s who support existing lift communications through the UNI-V port
in a prominent position on the NBN website.
How can we better coordinate and plan the migration of services to the NBN
across industry boundaries?
Otis believes greater industry consultation coordinating with all the key stakeholders
will improve collaboration across industry boundaries. Further greater education and
guidance material will enhance technical understanding and assist in ensuring
continuity of service to key communication devices.
Should you have any questions or would like to discuss any of the responses raised
in this submission we make ourselves available. Please contact Anthony Seddon
on the undersigned.
Regards,
ANTHONY SEDDON
Director Field Operations
Otis Elevator Company Pty Ltd
Australasia
UTC Building & Industrial Systems
Unit 1, 5-9 Ricketty Street
Mascot NSW 2020, Australia
Tel.: (61) 2 8338 2701
[email protected]

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