Emergency video relay and the "999 BSL" service: an update for Internet access providers and telcos
In June 2021, Ofcom published a statement setting out its decision to require providers of fixed and mobile telephony services and providers of internet access services, to provide, or contract to provide, a free 24/7 video relay service for deaf BSL users to enable communication with the emergency services.
This caused some consternation, especially among smaller Internet access providers: surely it made no sense to require each operator - especially Internet access providers, in respect of which users have no expectation that they would provide emergency services access - to provide an emergency video relay service, but rather for there to be one single, third party, "over the top" solution?
The "999 BSL" service
That is what appears to have happened, as we now have the "999 BSL" service, which is available as an app, as well as in-browser as a WebRTC service.
It is made available by Sign Language Interactions, which Ofcom approved as the service provider in January.
Bravo. This is a sensible, practical solution.
Sign Language Interactions has published an interesting PDF of what goes on beyond the scenes.
What operators need to do
The rules relating to emergency video relay are contained GC C5.11 - C5.12.
"Provide" an emergency video relay service
Operators are required "to provide, or contract to provide" a free 24/7 emergency video relay service.
Since Sign Language Interactions is operating the 999 BSL service, it is unclear what more might be expected of all regulated providers in respect of the obligation to "provide" emergency video relay.
Since the 999 BSL service is available via the Internet, technically, no provider needs to contract with SLI (directly or via BT) to enable its end users to access it. In that regard, it is "just another" website.
However, it appears that Sign Language Interactions has a relationship with BT, and that BT intends to be the onwards provider of the service to communications providers.
In its proposal to wholesale emergency video relay to "industry", BT said:
We are investigating charging Providers using BT as the EVR wholesaler, at least partly based on their recent share of voice 999 emergency calls. There may also be a minimum fee.
The reference to a "minimum fee" sounds ominous for smaller providers, who might reasonably expect to pay close to nothing, based on the traffic volume their end users are likely to originate.
The final line of BT's proposal is interesting:
please let us know whether, in principle, you intend to contract with BT for EVR or if you intend to make alternative arrangements for provision of access to the EVR service.
This suggests that, unless a provider is paying BT or SLI, they are not "providing" the emergency video relay service, even if the service is available to their end users.
Ofcom has said:
We are aware that not all regulated providers have an existing billing relationship with BT, and have ensured that information about BT’s proposal has been shared with trade bodies representing many of these providers.
Whether Ofcom expects all ISPs to volunteer money to BT or SLI, and will seek to investigate / enforce against providers which do not do so, is unclear.
Zero rate data to the 999 BSL service where technically feasible
GC C5.12(a) requires that providers must provide the service free of charge, and C5.12(b) requires that they must, where technically feasible, apply an incremental price of zero to data associated with the use of the service.
In other words, to zero rate data used for the service, if they can.
Sign Language Interactions has published information about the IP ranges, ports, and host names associated with 999 BSL service, to assist with zero rating, for those providers for which this is technically feasible.
Relatedly, for corporate networks (and perhaps for more technical users and their home networks), the 999 BSL service provider has published information about IP ranges and ports which should be permitted.
Promote the 999 BSL service
In addition to the specific GC requirements relating to emergency video relay, there is a more general requirement of publicity in GC C5.6:
Regulated Providers must take the measures needed to meet the needs of End-Users with disabilities set out in Conditions C5.7 to C5.16 and take all reasonable steps to ensure that such measures are widely publicised, taking into consideration the need to disseminate information in appropriate formats through appropriate channels for End-Users with disabilities.
As such, providers should already have information readily available for customers and end users with disabilities, and might want to consider adding information relating to the 999 BSL service to that.
Sign Language Interactions has made available some free marketing collateral.