Issued October 20, 2011
Ofcom has made a number of proposals to upgrade the existing text relay services and introduce video relay services. We understand that, in doing so, Ofcom’s primary objective is to achieve greater equivalence of access for hearing and speech impaired end users. Whilst we agree customer experience could be improved with new relay services, BT believes that equivalence can only be achieved by enabling the same person-to-person communication experience for all telephone users without the need for an interpreter. To achieve this, all businesses and services would have to take corporate responsibility to ensure their services are fully accessible, and we believe this will not happen without government intervention to change the Equality Act 2010. Therefore, whilst BT is supportive of Ofcom’s proposals in the round, our response should be viewed in light of this over-arching comment.
We welcome Ofcom’s decision to revoke BT’s Universal Service Obligation (USO) to fund text relay. Under existing regulation, all UK Communications Providers1 (CPs) must provide text relay to customers that need it. In BT’s view, retaining the USO unnecessarily gold plates this regulation and delivers no additional customer benefit. Moreover, its removal should encourage innovation as CPs look to new ways to meet the more specialised needs of hearing and speech impaired end users.
Under Ofcom’s proposals, the General Conditions would continue to require all CPs, including BT, to provide access to a text relay service for hearing and speech impaired users; and, if the USO were to be removed, BT would continue to supply the existing text relay service during any agreed transitional period.
We believe the range of text relay improvements set out by Ofcom address the customer issues and concerns identified in Ofcom’s market research. We anticipate that additional choices in person-to-person communication2 would be forthcoming, provided Ofcom’s proposals also helped to encourage access to the internet for hearing and speech impaired end users. However, we believe that Ofcom has significantly underestimated the implementation costs, which we estimate to be in the region of £2 million depending on the required development.
We do not, however, support Ofcom’s proposals for a CP funded Video Relay service for British Sign Language (BSL) users because the implementation costs are significantly disproportionate to the benefits that might be delivered to end users. Moreover, these costs cannot be sufficiently reduced by Ofcom’s proposals to restrict the service as they only limit the ongoing operational overhead. Whilst we are supportive of Ofcom’s aim to ensure greater equivalence, BT continues to hold the view that access to services for hearing and speech impaired end users is the responsibility of UK business as a whole and should not rest with the communications industry alone.