Executive Summary

Ofcom has put forward two options for consideration with regard to the provision of 999 access for VoIP services. Option 1 supports the status quo where 999 is not mandatory. Option 2 mandates 999 for certain types of VoIP service, specifically those with breakout to the PSTN.

BT generally supports Option 2, but with reservations. The most important of these is to recognise those corporate VoIP products which work in conjunction with existing PBX and PSTN facilities to deliver 999 calls over the PSTN. As a consequence we believe there is no need to duplicate this 999 delivery with a VoIP 999 interface.

Introduction

BT’s position in the UK Telecoms Industry has two features which are particularly relevant to this consultation.

We sell a wide range of VoIP products to individual consumers up to large multinationals and we are also a provider of the 999 services which are proposed, in the consultation, to become mandatory.

BT understands the benefits of mandating 999 to the consumer and SME segments, although we do not believe it is appropriate for corporates where bespoke products already protect 999 access. And as a provider of 999 services we have an interest in the logistics and readiness of prospective customers from the VoIP community.

In terms of BT’s view on additional Ofcom regulation, we consider that adding regulation to a relatively new and immature sector of the telecoms market has to be proportionate and deliver clear benefits. In this consultation, we are generally supportive of Ofcom’s recommendation, Option 2, to mandate access to 999 to VoIP services that have breakout capability to mobile or the PSTN.

Although we have some reservations on Option 2, (see next section ), Ofcom’s consultation document and subsequent Statement will provide some needed stability on future VoIP regulation in this area. In the medium term, we also believe that there are benefits to the VoIP Industry. These will come from greater confidence from consumers that VoIP can provide a feature that they take for granted in their PSTN and mobile phones.

We also believe that consumer confidence is a product of faith in a regulators approach to compliance and so we would expect Ofcom to ensure a level playing field for both UK and non UK based VoIP providers.

Finally BT has concerns with any assumption that the location of a VoIP user can be accurately determined. Mechanisms in place in the UK today rely on registered installation data which may not be up to date due to the inherent mobility of a VoIP Service. We would be particularly concerned about the type of location provision being mandated at this time, since standards are not yet sufficiently mature to enable this to be delivered accurately or indeed at all in some cases.

Our response is in three sections, a) comments on BT’s VoIP products, b, comments on BT’s 999 product, and c) the answers to the specific questions in the consultation.

Both BT and PlusNet are included in our analysis.

BT’s VoIP Products

BT’s VoIP portfolio covers two main sectors.

For mass market consumer and SME customers we offer BT Broadband Talk (consumer) and BT Broadband Voice (business). These volume products are supported by related products such as Softphone and PlusNet’s Broadband phone.

For the large business / enterprise customer we offer different corporate products. One of these is a national and international toll bypass system which is effectively an overlay network for specific types of calls, eg national and international. These are bespoke products and engineered to work with existing PBX and PSTN systems.

Although we generally support Ofcom’s proposal, we have important concerns as follows;

a) Corporate Customers.

At the corporate end of the business sector, BT’s products are highly sophisticated and interface with other technologies such as ISDN, PSTN and IP overlays. They are bespoke products, and engineered to work with host PSTN systems to a far greater extent than VoIP products for consumers and SME’s. Put simply, for some of these products, 999 access is provided through the host PBX via PSTN and it is not provided through the additional IP overlay. Further information is provided in annex A.

We believe the fact that corporate products, such as BT’s overlay product, use VoIP is in some ways immaterial, because the normal rules for 999 access to PSTN from large private networks that extend across several sites apply. We suggest Ofcom refresh guidance previously published as the Code of Practice for Private Telecommunication Networks to cover this situation.

Thus we consider it is not appropriate to include corporate solutions in the definition of Type 4 VoIP products. They are a type of their own and should not be covered by the changes proposed in GC4 to PECS to mandate 999 access.

b) Implementation period.

The timescales for implementation are set at 3 months from the date of the forthcoming Statement. PlusNet sell a VoIP product, which currently does not provide emergency access and which will need to comply with the appropriate PATS General Conditions, ( if Option 2 is eventually selected by Ofcom ). Our initial estimate of the time taken by BT Corporate and PlusNet to comply with the various PATS conditions is approximately 6 – 8 months, although we believe that PlusNet will be able to provide 999 access within three months. However BT does not believe at this time that it is feasible to deliver accurate network location information in any consistent, meaningful way. We will however continue to use and build on registered installation data where this is available

c) Click to call

There are many companies and organisations who provide a “click to call” button on their websites, software and other applications. This is designed to link the user to one or more contact points to provide personal assistance with the application. The call set up could be classified as a Type 2 if the party being called is terminating their calls on the PSTN. Normally the end user does not enter a number but there are variations where the call is made from the third party back to the end user. We believe to mandate 999 access for this kind of service would be inappropriate and this kind of application should be included in Type 1 or Type 3.

BT’s 999 Product

BT has a 999 service for VoIP which is regarded as a short term, tactical method for handling VoIP calls made from fixed locations, while awaiting automatic location methods for IP access environments. A fuller explanation of how emergency VoIP calls are managed now is included in annex B. This method handles a growing number of VoIP 999s each month and these will increase substantially if Option 2 is mandated. An appreciable number of nomadic VoIP applications may also be introduced..

Thus the implementation of Option 2 will bring significant challenges for the 999 call handling product to function correctly. These are as follows:-

- network changes : there will be a requirement for those organisations providing a PSTN gateway for a VoIP CP to flag such emergency calls as VoIP

- data and IT changes : each VoIP CP will need to develop the data transfer systems for transferring name and address information to BT's 999 Database from their own systems. Our experience with existing CPs is that this can take some time to set-up, test and establish. This translates into a limit on how many new CPs we can manage into service in any given period.

- each VoIP CP will have to collect name and address data from new and existing customers. Experience in the USA suggests that, especially for existing customers, this may not be straightforward and take considerable effort/time for details to be verified.

- commercial contracts will need to be agreed for 999 call handling : the logistics of signing-up a large number of VoIP CPs will by itself be time consuming.

- at present, the BT 999 product only supports provision of fixed name and address information that can be verbally confirmed at the time of the call ( see annex B ). If the VoIP CPs now requiring 999 access support a much higher proportion of nomadic users, the product may have to be further developed and a new price established. Although it is not thought worthwhile, from our understanding of practical experience in the USA, to allow real-time input by end-users of addresses as they move from place to place, we would need to assess the risks associated with our existing provision of four location updates per day to our database for CPs. We would also need to look at any mitigation on a case-by-case basis (for example a post call trace facility may be available).

- increased risk of call handling problems, such as being unable to confirm location for callers unable to speak, with consequent potential impact on caller as well as increases in stress for call handlers and risk of complaints from callers. Particular complications occur for any VoIP CP with UK PSTN breakout supporting overseas travel for their end-users. There is currently no process that could allow such calls to quickly reach the correct overseas Emergency Authority.

Our expectation, and preferred way forward, is to follow the current NICC work on Location for VoIP Emergency Calls closely and develop the 999 Product to support automated provision of location on VoIP originated emergency calls as soon as possible - at the earliest this looks like being possible to implement in late 2008. In our view it is imperative that there is a single solution implemented, and thus clarity for Emergency Services, CPs and end-users alike as to the process, rather than the possibility of a plethora of “proprietary “ solutions. If we see growing numbers of nomadic users, call handling costs would also rise along with system development costs that will need to be passed-on.

We note that Ofcom's existing Guidelines on provision of location information (paras 5.81-5.89) will need updating to reflect technical progress and practical experience, referred to above, and available in more detail from the NICC's study. As a specific example para A5.82, use of a VoIP flag, should not be seen as sufficient when other options are clearly reasonable to use to improve call handling for the caller - such as 5.83, user address information. If the guidance is left as it is, it places an unreasonable burden for supporting VoIP 999 calls on the 999 call handling agency that is more efficiently tackled at source by the VoIP CPs.

BT welcomes any comments on its position as laid out in this document, which will be available electronically at http://www.btplc.com/responses.

Comments should be addressed to Stephen Dean, BT , Newcastle Telephone Exchange, Newcastle, Carliol Square upon Tyne, NE1 1BB.or by email to stephen.h.dean@bt.com