BT s response to Ofcom Consultation Document Regulation of VoIP Services: Access to the Emergency Services

Transcription

1 BT s response to Ofcom Consultation Document Regulation of VoIP Services: Access to the Emergency Services 20 September 2007 BT welcomes any comments on its position as laid out in this document, which will be available electronically at

2 Comments should be addressed to Stephen Dean, BT, Newcastle Telephone Exchange, Carliol Square, Newcastle upon Tyne, NE1 1BB.or by to 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

3 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. As at 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

4 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

5 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 endusers. 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 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 ) 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.

6 3. Consultation Questions. Q.1 Do you consider Ofcom should consider any other policy options? Please describe your proposed option(s) and explain what you consider would be the advantages and any disadvantages. We do not believe Ofcom should consider other significant policy options, but that Option 2 and the proposed modification to GC4 will require amendment. For example; a) recognise the class of VoIP products which are sold to corporate customers and for which 999 access is provided through PSTN on the host s existing telecoms equipment eg their PBX. b) to lengthen the implementation period to six months. c) to remove any 999 mandate from click to call type services. As the consultation is focused on provision of 999, the two policy options of 1) not mandating 999 and 2) mandating 999 for type 2 and type 4 services reflect the main alternatives.

7 Q.2 Do you have any comments on Ofcom s evaluation of policy Option 1, which is to not require VoIP services to allow 999 calls? Ofcom s evaluation of the free rider concept is particularly relevant to BT Retail s PSTN service. BT Retail s PSTN service, by providing 999, is paying for the free ride available to customers of many non BT VoIP services. Ofcom have correctly stated that Option 1 does not have benefits for the consumer, or costs for the VoIP provider. However for a PSTN provider like BT Retail, there is call revenue loss to some VoIP providers, but no reduction in our infrastructure costs of providing 999 to non BT VoIP customers who have a BT landline. Thus in the medium term, Option 1 incurs a cost to the PSTN provider.

8 Q.3 Do you consider Ofcom should adopt policy Option 1? Please give your reasons. We do not believe Ofcom should adopt Option 1. We believe it is good for the public and for the VoIP industry, that customers can dial 999 from consumer and SME VoIP services.

9 Q.4 Do you have any comments on Ofcom s evaluation of policy Option 2, which is to require VoIP services that allow calls out to ordinary numbers to allow 999 calls? Evaluation of Ofcom s policy Option 2 essentially involves offsetting the benefit of saving human lives against increased compliance costs and their negative impact on new market entry, innovation and market efficiency. This cost-benefit analysis is complex, requiring a value to be put on saving a human life and many assumptions regarding factors like levels of regulatory compliance costs, VoIP adoption, and the number of lifethreatening calls to the ambulance service. In view of this, BT welcomes the cautious, conservative, approach Ofcom has taken to its assumptions, using input data from the lower end of available ranges for market data and using a credible third party source (Department for Transport) for data on valuing/avoiding the loss of life. We believe this approach gives the results of a complex analysis more credibility. This credibility is underscored by the fact that the net benefit is based on only a very small proportion of 999 calls, excludes non-life saving benefits, and is robust across a range of sensitivities.

10 Q.5 Do you consider Ofcom should adopt policy Option 2? Please give your reasons. We agree that Ofcom should adopt policy Option 2 but as discussed previously, with amendments to recognise corporate VoIP products, the implementation period and click to call products. Our reasons for supporting Option 2 are;. Consumers will benefit from the assurance that their VoIP service will connect to the emergency services. We agree that the linking of 999 provision to consumer and SME VoIP services with breakout to PSTN is sensible.. It provides clarity on the regulatory position for VoIP providers who supply services to UK customers, regardless as to whether they are based in the UK or not. Our proposed amendment to Option 2 to reflect corporate products, is to create a new type of VoIP product, eg Type 5, which covers products for large businesses and in which there is a clear requirement to interface with PBX s which already provide 999 over PSTN. As a consequence there is no need for the product to provide 999 on the IP Overlay. We would also repeat our previous point that there are provisions for 999 access to PSTN from large private networks that extend across several sites. We suggest Ofcom refresh guidance previously published as the Code of Practice for Private Telecommunication Networks to cover this situation, as at

11 Q.6 Ofcom invites information on (a) the current means, future possibilities and limitations for providing caller location information; (b) how long it is likely to take a VoIP provider to meet current requirements on caller location information, in the event that Option 2 is adopted. Current means in use in BT s emergency call handling centres (CHAs) for the UK, rely on VoIP callers being able to either verbally confirm their registered location, or to verbally provide a new temporary location. BT s emergency services database (ESDB) is pre-loaded (updated at least once every 24 hours) with the registered name/address of the VoIP customer for most BT VoIP products, and both the calls and the address records within ESDB are flagged as needing confirmation. Communication Providers (CP s) that use BT for 999 call handling can download name and address data up to four times each day to ESDB and can flag an address as VoIP. The 999/112 operator answers the call as normal and will see that it is VoIP originated. Calls emerge from an IP environment to the PSTN at a PSTN - IP Gateway (PIG). At this interface BT requests the CP providing the PIG (which may be the original VoIP CP or an aggregator providing the PIG for a number of VoIP CPs) to tag the calls as VoIP originated. The CLI, or E164 telephone number allocated to the user by the VoIP CP, is also carried into what is now the PSTN leg of the call. Calls arrive at the 999 BT Operator Centre and are flagged to operators as a VoIP Emergency call. The 999/112 operator asks the caller to verbally confirm that their location is as displayed. The 999/112 operator then either connects as normal using an automatically displayed registered address, or in the currently unlikely event that caller has moved their phone, changes the screen address details to search again for Emergency Authority information (which EA Control Room to route call to) - which is determined from the town name/county verbally given by caller. Future Possibilities : on location information, the NICC Task Group is establishing an architecture and interfaces to allow the location of a VoIP originated call to be automatically established without relying on a caller verbally giving details (since their ability to do so cannot always be assumed). We note that the NICC approach :- - assumes VoIP Service Provider, ISP and Access Provider can all be different commercial organisations - has so far only considered ADSL access networks though is looking to tackle Cable, Fibre, WiFI and GSM scenarios - is making use of International Standards, though these are still developing (NICC will use these wherever possible in it s recommended approach) - understands there is an International dimension, in that VoIP users registered in the UK, could be overseas and using their service. - Does not recommend reliance on end user input that depended on a user constantly updating their location as they moved around (and also on users knowing their location sufficiently well to enter it in a meaningful way). This has also been shown to be unreliable in USA where it has been tried - Does not rely on a device establishing its own location through GPS or other methods (at least for next 2/3 years) We also note the initial NICC conclusion that automated routing and location provision is technically possible for ADSL case but requires:- Increased co-op between CHA and VSP, ISP and Access networks

12 New network entities to be developed/deployed by these parties : Location Information Server and VoIP Positioning Centre New interfaces for all : Http/Https and XML New requirements on all organisations (systems development) More details and some specific recommendations are expected for ADSL and Cable cases by end of this year (12/2007), with further work beyond this for other scenarios such as Wi-Fi access. The IETF is also expected to have made some recommendations on International Standards by December 07. Finally the NICC work will be including IP calls end-to-end as NGN and device capabilities become clear. On a practical note, BT notes that the above status of methods to derive location information for VoIP originated 999s, means that though possible, they are still unproven and rely on commercial cooperation as well as technical development. Although we would look to provide such information for our own VoIP products, we are not yet clear on how soon that would be possible for even limited cases (eg ADSL with ISP and VoIP provider both situated in the UK). We would expect it to be at least 6 months before the situation was more clearly known, and even just technical feasibility clarified with our suppliers, yet alone implemented which would be likely to be another 6-12 months. Limitations: the biggest concern would still be around unavailability of reliable, automatically provided location information, which currently means there is an inability to provide 999 support for nomadic callers unable to speak. This is especially challenging for international situations (overseas use of UK registered end users that access PSTN in the UK with overseas Access Network and ISP and overseas citizens with a foreign VoIP CP using UK access and ISP networks). The NICC work for future options is noted above. The limitations for users of Corporate VoIP networks are also noted, where emergency service provision guidelines for anyone deploying a private network extending over several sites (which with VoIP can be even more widespread and include single remote, nomadic workers) need emphasis and development and we suggest Ofcom make some exceptions in it's characterisation of VoIP types for these products. Concerns on reliability of VoIP networks, VoIP applications and need for mains power are already well known and discussed elsewhere.. 6(b) Time for VoIP CPs to adapt to option 2 In the event that Option 2 is adopted, it would be expected that VoIP CPs would take a range of times to be able to comply with current 999 Product Requirements. With PSTN access already present, the steps involved are (i) network changes to flag such emergency calls as from each VoIP CP, (ii) development of data transfer systems for transferring name and address information to the CHA's 999 Database from the CP's own systems, (iii) collection of name and address data from new and existing customers, (iv) commercial contracts to be agreed for 999 call handling, (v) more complex network changes needed if the VoIP CP's application does not currently provide a standard PSTN telephone number as a network CLI for VoIP end-users. There would also be additional complications 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. For BT s VoIP 999 call handling product we have already noted in the introduction the challenges faced to assist VoIP CPs adapt to Option 2. These challenges could affect

13 the time to adapt of an individual VoIP CP. For example, since rate at which steps that are joint tasks (such as step (ii) above) can be achieved is limited, then if many VoIP CPs apply at the same time, the necessary work would have to be programmed and CPs processed in turn. We also note that steps (i), (iii) and (v) could take several months to complete dependant on factors such as (respectively) systems expertise available to VoIP CPs of varying sizes, numbers of existing VoIP CP customers without accurate registered addresses, and method for allocation and insertion of meaningful telephone numbers into PSTN call set-up and associated customer records. For BT s own mass market VoIP products, we have already noted above that we believe our PlusNet VoIP application could take approximately 6 months to meet all requirements associated with Option 2. BT s other VoIP products are generally ready but a small number of PC-based calling applications for residential and business users would require some changes, expected to approximately 3 months.

14 Q.7 Ofcom invites information on (a) the current means, future possibilities and limitations for providing network integrity and service reliability; (b) how long it is likely to take a VoIP provider to meet current requirements on network integrity and service reliability, in the event that Option 2 is adopted. Current means : It is our understanding from Ofcom s Regulation of VoIP Statement of March 2007, ( A5.66 ) that both type 2 and type 4 VoIP providers will be required to carry out a risk assessment. We believe this is a sensible position as it provides a degree of reassurance to customers of type 2 providers. So even though type2 providers are not subject to the PATS only General Condition 3 (network integrity), they still have to consider network integrity issues for 999 provision. As mentioned previously, BT has a wide range of VoIP products, from corporate multi media solutions to downloadable clients for PC s and other devices. There are a range of measures currently employed by BT to ensure network integrity and service reliability. It is important to note that not all our products include all these measures and in particular PlusNet s network architecture and service delivery are different from that of BT. The network design has degrees of resilience built into key components. Customer CPE has fallback to PSTN (if correctly set up by the customer). BT Retail has an SLA with BT Wholesale for supply of IPStream. This includes performance measures for repair. Internal BT processes include real time system monitoring and incident analysis. Future Possibities. BT has an ongoing programme of improvements to its VoIP services. This includes higher service availability in general and specific measures for 999 call handling. For example; Location information for VoIP emergency calls - Work is in progress to allow a 999 operator to see the geographic location of a customer making an emergency call using most BT VoIP services over a BT-provided access network such as BT Broadband or BT Openzone. Allow emergency calls to be returned to outbound-call-only customers - Work is also in progress to allow a user of BT's pre-paid outbound-call-only VoIP service (Softphone Callout) to receive an incoming call from a 999 operator. VoIP access network products - BT Openreach/Wholesale are proposing VoIP access products which will provide prioritisation of emergency calls during network congestion and manual hold for 999 operators. Improved platform integrity - BT is implementing a more robust mechanism to protect the consumer VoIP platform from traffic that could be detrimental to service performance. It is important to note that the above may not apply to PlusNet. Limitations

15 The major limitations on network integrity and service reliability are ; Local power failure affecting the broadband router and any associated VoIP hardware. Local equipment failure eg the broadband router. Congestion on customer s WAN / LAN. Poor performance on customers Broadband service Problems on call server platform Problems with PSTN gateways Problems with peering between BT and other providers Depending on cost, technology and network design, there are mitigation strategies available to reduce the impact of these problems. Meeting current requirements on Network Integrity and Service Reliability In terms of meeting the various elements of GC4, most of BT s consumer and SME products are already PATS and therefore already subject to GC4. For those products that now have to meet this condition, the areas that are likely to cause difficulties are; Risk assessment: Although in general we support risk assessments, BT s experience of carrying them out and then subsequently looking to mitigate weak areas, is that it is a complex task. It took over three months to complete this work and it generated both commercial and technical problems as there is a finite availability of resources to make networks more reliable. Caller Location Information: The Ofcom Guidelines on the application of PATS obligations to VoIP service providers is helpful and our current approach of including a flag to alert the operator of a VoIP call, was relatively simple to provide

16 Q.8 Do you have any comments on complying with the other PATS General Conditions, in the event that Option 2 is adopted? BT s portfolio of VoIP services for Consumer and SME is mainly PATS already. There are two services, Softphone Callout and PlusNet s Broadband phone which are not. Softphone Callout already provides 999. PlusNet s Broadband Phone is likely to become PATS, as it is a type 4 service. See also our answer to question 10. If Ofcom were to require Corporate products such as BT s overlay services to have their own 999 access, then this would be a substantial piece of work and could take longer than six months. See also our answer to question 10.

17 Q.9 Referring to the full Impact Assessment in Annex 5, do you agree with Ofcom s approach to assessing the potential costs and benefits of policy Options 1 and 2? Introduction BT believes Ofcom has produced a very detailed and reasonably cautious impact assessment of the costs and benefits of its Option 2 for provision of VoIP services. Under this option, Ofcom proposes to mandate access to 999 for both type 2 services (VoIP Out) and type 4 services (VoIP In and Out). This option has a net present value of 13.6m, assuming VoIP is used by 25% of households by 2011/12. Its alternative, Option 1, is do nothing, under there are no additional costs and no additional benefits in terms of lives saved, and which therefore has a zero net benefit. Methodology Number of Users According to Ofcom, the number of households potentially subject to confusion regarding 999 access lies between 1.53m (ie the 64% of the 2.4m households who have a VoIP service that Ofcom knows does not offer 999 access) and 1.19m (ie the 78% of VoIP users whose service did not provide 999 access who incorrectly thought their service did provide access or did not know if they had access). Ofcom has used the lower, more cautious, number in its analysis. Types of VoIP Supplier Ofcom distinguishes two types of VoIP supply stand alone Internet-based VoIP (eg Skype, Vonage, Viatel) and on-net VoIP (eg BT, Orange, Tiscali), which is bundled with Internet access. There are 27 of the former in the base year of analysis and 4 of the latter. Discount Period and Discount Rate Ofcom uses a 5 year discount period (2007/ /12) and uses the 3.5% discount rate recommended by HM Treasury. Benefits Benefits are assessed in terms of lives saved. Lives are saved by avoiding the critical delays that may arise from consumers being unaware that their VoIP provider does not offer 999 access. Ofcom has taken a very cautious approach to the potential number of lives saved, by restricting its analysis to only life-threatening 999 calls to ambulance services (because accurate date is unavailable for other emergency services). These form less than 5% of all calls to emergency services. This means that, to the extent there are any benefits in terms of lives saved from using other emergency services, and any benefits from preventing delays that would have resulted in worse injury, harm or damage to property, the gross benefits assessed by Ofcom will be understated. This is a powerful point in favour of accepting any positive net benefit. Ofcom calculates the probability of a life being at risk from not being aware 999 access is not provided at 1 in 10,000 calls and that, assuming VoIP reaches 25% of UK

18 households by 2011/12 (compared to 10% today), this will result in 18 lives saved. It makes various reasonable adjustments to Department for Transport methodology for valuing / avoiding loss of life from road traffic accidents to arrive at 1.43m as the value of a statistical life in 2007/08 prices for the purpose of estimating benefits of saving lives by mandating access to 999 over VoIP. These include excluding hospitalisation costs and applying a GDP deflator to 2004 prices). It also makes a downward adjustment for the higher failure rate of 999 access over VoIP compared to the PSTN. The discounted value of costs assuming 25% VoIP penetration of households is 23.8m. Costs Ofcom views the incremental costs associated with Option 2 as being primarily regulatory compliance costs to set up and comply with additional general conditions. Ofcom has undertaken a two step process to measure costs. First, it has identified new areas of compliance for type 2 and type 4 VoIP providers. Provision of access to 999 makes VoIP suppliers obliged to comply with additional general conditions (GCs) to those they have to meet as either ECSs or public ECSs they have to comply with GC4 and the PATS GCs.. Second, Ofcom has used VoIP providers own estimates of their compliance costs from a survey by Intercai. These costs were grouped into three categories. For medium and high cost categories, Ofcom takes the mid-point of the cost range given by each provider to represent their cost of complying with a particular GC. Low cost categories were seen by providers as business as usual and are treated by Ofcom as being zero. We also noted that no costs were allocated for location determination. To reflect industry structure, Ofcom takes a weighted average of these costs, using type of VoIP supplier as weights. Discounted costs amounted to 10.2m. Sensitivity Testing Ofcom tests the robustness of its basic result for net benefit m - under a number of different scenarios for costs and benefits. Under each the NPV is positive. Conclusion BT believes Ofcom s assessment of the costs and benefits of Option 2 is reasonable in its assumptions, cautious in its approach and fairly robust in its results.

19 Q.10 Do you agree that 3 months would be a suitable compliance period, taking into account the steps VoIP providers would have to take to comply with the modification to General Condition 4 and any additional General Conditions and the need to reduce the risk of harm to consumers and citizens? Please give detailed calculations and reasoning to support your response. BT and PlusNet s Consumer and SME products not currently PATS: We believe that three months would be sufficient for any consumer or SME VoIP products that did not currently provide 999 to do so. However we expect that to meet all the relevant PATs General Conditions will take up to six months. The General Conditions that we anticipate may take longer than three months are as follows; GC4 (Network Integrity ) Based on our previous experience, we expect the completion of a risk assessment and subsequent follow up actions may take longer than three months. GC15 (Special Measures for end users with disabilities) This wide ranging condition contains (amongst others) specific requirements for a text relay interface and arrangements for directory enquiries for visually impaired customers. While we will endeavour to make as many modifications to the VoIP service as possible, we anticipate that development to meet this requirement may take three months or longer. GC 18 (Number Portability ) This is discussed in more detail in BT s response to Ofcom s consultation Arrangements for Porting Phone Numbers when customers switch suppliers. BT s Corporate VoIP Products. As explained previously, some of our corporate VoIP products do not support 999 via VoIP, they use the client s existing PBX and PSTN capability to route 999 and other call types direct to the PSTN. If Ofcom were to mandate 999 for this type of product, we would need to review the existing client locations and to design an interface for these products to include a 999 gateway, in addition to the existing 999 capability in the PBX. In conjunction with the requirement to provide location information and meet the other PAT s conditions, this is a significant piece of work. Unfortunately we are unable to give a precise estimate for it s completion but it could be longer than six months.

20 Q.11 Do you have any comments on Ofcom s proposed approach to monitoring, review and enforcement? We are keen to ensure that a level playing field exists for all VoIP providers who sell to customers in the UK, regardless as to whether the VoIP provider is based in the UK or overseas. If Ofcom mandate 999 provision, as suggested in Option 2, then we would expect their compliance and enforcement activities to be applied equally to both UK and extra territorial providers.

21 Annex A Corporate Products OFCOM need to differentiate between the residential and small business market and the large business/enterprise market. For years corporations have had customized toll bypass voice networks that allowed enterprises to increase functionality and lower costs on voice communications amongst corporate sites and offices globally. Such private networks were overlay networks i.e. they rode on top of existing PSTN services subscribed to by corporate customers. These private overlay voice networks would also typically allow outbound PSTN calling but would be used by corporations only for outbound international PSTN calls because this was a cost-effective use of such a service. It was not cost effective to make local PSTN calls using a corporate toll bypass voice network plan. Instead a PBX at a corporate site would route local calls over an office s existing PSTN connection. These corporate voice networks that allowed international toll bypass did not and still do not have emergency access capability built into the platforms because it was unnecessary. Emergency access calls were routed by a PBX at the corporate site over an existing PSTN line(s) to an emergency service responder. Many of the corporate toll bypass voice network services are being converted to IP based toll bypass services. These services continue to be overlay services. Many of BT s overlay IP voice VPN services do not allow corporate customers offices to receive calls from the PSTN (i.e. are Type II services). Corporations therefore maintain their existing PSTN services which will be used by a corporate PBX to continue to route emergency calls to responders. Furthermore, BT stresses to its corporate customers the need to maintain a PSTN connection. In addition, with some corporate IP voice products, nomadic use of the service is not permitted, there is a registered location for a particular corporate extension and when an employee moves location there is a formal change process that is triggered. Corporate service providers are also working with equipment manufacturers to develop standardized solutions that can be deployed globally, uniformly and seamlessly for each IP corporate voice service launched by service providers. For example, BT is inputting into Cisco s development of emergency access technology that would allow Cisco s call manager to identify the address of the LAN port into which an enterprise s employee has plugged in. The Cisco call manager would indicate, for example, that the user is plugged into a LAN port at the northeast corner of 10 th Floor, 52 East Temple Street. While this technology is still in development and addresses only VOIP services accessed by wired means and not via wireless technologies, this is an example of how equipment manufacturers and enterprise service providers are working together to develop enterprise grade solutions for their products that can be launched efficiently instead of bolting on piecemeal and varied fixes onto corporate IP voice platforms globally to satisfy infinitely varying local regulations on emergency access. Large corporate customers employees are inherently mobile they travel nationally and internationally. The cost would be prohibitive to comply with infinitely varying regulations from one country to the next. Would employees of a corporation visiting jurisdiction A which required that stickers be placed on all corporate users equipment also be required to have stickers on their equipment? What if the employees visited another jurisdiction B which required that all products have an interface allowing the corporate user to constantly update his or her location? Add on a third jurisdiction C s requirement for

22 autolocation technology on handsets would this mean the visiting employees would also have to have autolocation technology on their handsets. It would kill the viability of launching a global product because of the technical, administrative and cost hurdles. Not to mention that it would prevent a corporate user s experience of the product from having the same look and feel in every country. In summary, there are a variety of ways in which enterprise service providers, corporate customers and equipment manufacturers are handling emergency access issues for enterprise grade IP voice services as providers and equipment manufacturers work towards permanent solutions. There is no data showing regulatory intervention is required in the enterprise space. Corporate customers have CIOs and CTOs that are experienced and are well able to understand the limitations of the technologies they are buying, understand the work-arounds proposed by service providers, and negotiate and protect the interests of their employee user communities. Finally there is more of a danger in the enterprise IP voice space that a multiplicity of differing regulations would kill global product deployments that deliver a seamless uniform experience for corporate customers. For these reasons, Ofcom and indeed other regulators should recognise the different regulatory requirements of the large corporate communications market as opposed to mass market products for smaller scale consumers.