Ofcom’s Proposals for Emergency Video Relay Service
Alex Kinch is a 20+ year veteran of the UK internet and telecoms industry, holding positions including Group CTO of TelcoSwitch (January-December 2020), CEO and founder of Ziron (exited to TelcoSwitch in January 2020), as well as several consulting roles for companies such as Jersey Telecom (JT), Nexmo (Vonage), Sky, HSBC, and Infobip. Until recently, Alex was also a long-standing Council Member and Deputy Head of Industry Developments Committee for the Internet Telephony Services Providers Association (ITSPA), and in 1997 co-founded the London internet exchange point LONAP.
Ofcom’s Proposals for Emergency Video Relay Service
There’s an emergency that requires a police, ambulance, fire service or coastguard response — what do you do? We all get taught from an early age that you reach for the phone and dial 999 (or 112). Whilst this may seem straightforward and almost second nature, it’s a little more complicated if you are disabled and unable to place a regular phone call.
In December 2019, the UK’s communications regulator Ofcom published proposals to require communication providers — including Ciptex — to make available, at no charge, a 24/7 video relay service for deaf British Sign Language (BSL) users to enable them to communicate with the emergency services. Such a service would allow a video call to be made on a supported device to an interpreter in a call centre. The interpreter would translate what the deaf user is signing into spoken English for the emergency call handler to hear, and vice versa.
Whilst the initial consultation received generally broad support from the industry, and several questions were raised — including how such a service would be paid for, who would operate the service, and who would be obligated to provide it. These questions were the subject of a second consultation, which closed just a few days ago.
Before we go into the detail, it’s probably quickly recapping what happens when you dial 999 (or 112) in the UK. Since 2014 emergency calls made on any network, whether on a fixed line or mobile device, have been handled only by BT. An operator based at one of six BT centres in the UK will answer the call, and on ascertaining which emergency service is required, will transfer the call to the appropriate service (police, ambulance, fire, HM Coastguard etc.) to provide further assistance to the caller.
At present, access to the 999/112 service for hearing-impaired users is via a textphone and through the use of BT’s Text Relay service (formerly known as RNID TypeTalk). From mobile devices, access is also available via SMS for pre-registered users.
Who would operate this service? Although BT (who we established above operate the existing emergency call handling service for 999 calls) has indicated it would be interested in taking on that responsibility, it’s not a given at this point. It would be cost-prohibitive for all but the largest communications providers to provide this in-house, so if not BT, then another third party would be required. Virgin operate BSL customer services for its hearing-impaired customers, so they may throw their ring in the hat, but the scale and responsibility of such an operation are likely to turn most off.
How would it be accessed? Ofcom appears to be minded that it would be via a free to download of the application. However, unlike the existing SMS 999 service, no pre-registration would be required. This could open up the service to abuse, and the relatively small number of genuine calls placed daily could overwhelm it quite quickly.
An alternative approach would be to mandate that Apple and Google provide support and/or interoperability with such a service in their phone operating systems. If this was the case, would this mandate be extended to Over the Top (OTT) video calling services such as Facebook (WhatsApp, Portal, Facebook Messenger)? It’s worth noting at this point that both Apple and Google support the UK-developed Advanced Mobile Location (AML) emergency location-based service on recent Android and iPhone devices, so it wouldn’t be an unusual request. However, Ofcom had also previously excluded such OTT providers from being mandated to provide emergency calling facilities — so this could create somewhat of a regulatory contradiction.
About charging, questions remain as to who would pick up the cost of handling this call. If the call was placed from your mobile phone, you would expect that your mobile provider is responsible — however, what would happen if your phone were also connected to a public Wi-Fi provider such as The Cloud, or is using Wi-Fi at home or a place of work? In that situation, would the call — and therefore the resulting charge — be the responsibility of the Wi-Fi or broadband provider? What happens if you walk out of range of Wi-Fi and start using 4G — would the charge be split?
Lastly, could (and should) video emergency calling be extended beyond deaf users? For example, in a situation where a non-medically trained person is the first on the scene of a road traffic collision, the emergency call handler could see the situation first-hand and provide advice in advance of the arrival of first responders. Whilst Ofcom has stressed in the consultation that it does not have power over the emergency services to mandate this, we feel that there is a missed opportunity to extend this service to provide further benefit (and hopefully a reduction in fatalities) to non-deaf users.
At the time of writing, Ofcom is aiming to publish a final statement by the end of June 2021 — and whilst we are (along with the rest of the industry) generally supportive of any advancements to help disabled users communicate more efficiently and effectively, it will be interesting to see whether any of the above points we’ve raised here are covered in Ofcom’s response.
