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Editorial #103: FCC: Deaf/HOH Organizations Meet with FCC on new NPRM (NAD, TDI, ALDA)

On February 6, 2012, representatives of TDI, NAD and ALDA met with officials at the FCC to express their thoughts about the proposed rules for VRS (NPRM), comments which are due in early March.

Here is a summary of the points brought up in the meeting, as quoted from the ex-parte filing they submitted (link). For more information, it is recommended that you read the filing in its entirety as the following summary does not cover everything:

– expressed support for a pilot program to assist deaf and hard of hearing users obtain access to broadband services
– expressed their support for proposals to achieve interoperability, the transition from H.323 to SIP, and the availability of off-the-shelf equipment for VRS users
– urged the FCC to consider ways to measure the hearing population’s use of and experience with VRS
– noted that higher quality VRS calls could reduce the time spent on a single call and also reduce the need for additional calls that are sometimes required due to poor interpreter/service quality
– expressed concerns with the proposed per user methodology
– expressed concern with the Commission’s belief that a per user compensation methodology will increase competition among VRS providers
– urged the FCC to protect consumers’ privacy when designing any VRS-related databases
– asked the FCC to consider the dilemma that consumers who are deaf or hard of hearing may experience if the FCC adopts the one provider, one customer model (in the event the default provider is not available to process the call)
– expressed concern about the sheer volume of …the NPRM, the lack of a public education campaign to inform VRS users about the proposals, and the lack of a thorough ASL version of the NPRM as well as the inability to accept video comments in ASL – the very language of the people who use VRS

It is Dr. Z’s opinion that the respective organizations will file formal comments regarding their thoughts on the NPRM. The NPRM has the potential of changing VRS as we know it–what we do not know is what it could lead to and how it could change how we use VRS.

Dr. Z cares about your communication access.

Disclaimer: Dr. Z is currently the Vice-President of Business Development and Outreach at CSDVRS, LLC.

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