UKCoD writes to BT, MGB and UKCTA in response to their reply to signatories to the open letter published in the Times. The letter reads…
“Thank you for your letter dated 24th May which was sent to the signatories to the open letter published in the Times. I am responding on behalf of those signatories representing deaf people.
The letter in the Times, was a result of our frustration at the lack of positive reaction from you and your members to the Ministers specific request made in public ‘to go away and come up with a solution’ – it was the failure to do this that the letter was highlighting. The Minister was clearly encouraging us all not to “sit around and do nothing until the Ofcom report was published”!
Whilst appreciating your comments your letter is notable for its failure to mention equivalence; the point of reference for the deaf sector when considering the issue of access to telecommunications. Under the Universal Service Directive, EU member states are required to ensure that access to, and affordability of, voice telephony for end-users with disabilities is equivalent to that enjoyed by the majority of end-users. For deaf people, only modern relay services can deliver such functional equivalence. Business textphones and LiveChat– mentioned in your letter – are not viable alternatives to the telephone.
Your letter states that “….wherever possible people should be able to communicate without the need of a relay operator”. This statement ignores the fact that equivalence for deaf people can only be achieved through a fully operational and universally available modern relay service that allows communication at speeds close to normal conversation such as Video Relay Service (VRS) or Captioned Telephony (CT). Currently deaf people have no choice but to accept a relay operator to be able to have a telephone conversation as close as the hearing community.
A functionally equivalent service will provide for deaf people who wish to make calls to major companies, small business, families and friends. Your focus on the role of “banks, government departments, doctors and so on” fails to take this into account. The suggestion that deaf people’s frustrations with the text relay service can be attributed to the lack of engagement by major businesses is disingenuous. One of the major problems with the text relay service is the lack of competition and incentive to improve service, ensure customer satisfaction or invest in new technologies. As you will be aware users continue to complain about lack of functionality in the current service, examples being relay
assistants not being available to take the call and calls being terminated by the hearing user, as was previously reported in the Opinion Leader research. This is a direct result of the model of provision which does not encourage competition or innovation, with the result being underinvestment, low standards of quality and lack of choice.
Given this inferior service, we are unable to share your view of the “very positive communications developments made in recent years” and would welcome the opportunity to understand exactly what these are before we are prepared to share these with our members.
It is important that businesses accept their responsibility for enabling customers to contact them in a way of their choice and we do believe that the business sector has a role to play in paying for their use of next generation relay services when it enables them to meet their responsibilities, but we acknowledge the limitations on Ofcom remit in this area.
However, as you know, we have proposed that a central fund be established and funded by a levy on the business customers of telecommunications companies. This fund could then be drawn on to pay for the costs of relay services provision, including universal VRS, ensuring that the burden was shared fairly across society. We believe that this model deserves further discussion. I therefore welcome your commitment to engage with all stakeholders on the issue of access to telecommunications.
We look forward to constructive discussions on this topic which include representatives of the deaf community, VRS and captioned relay providers and the telecommunications industry and would welcome a proposal of a date.
Please be aware that, given the representative role of the signatories to the open letter, we intend to publish this correspondence on our respective websites.
UK Council on Deafness”…..