Advocacy Groups for Deaf and Blind Oppose Portions of FCC’s VRS Reform Order

A coalition of advocacy and consumer groups for deaf and blind persons opposed multiple provisions of the FCC’s June order that would institute changes to the Video Relay Service (VRS) program, saying in comments released Tuesday that the order “may cause harm to the quality of VRS” (http://bit.ly/12mKIrd). The VRS order would reduce compensation rates to various-sized providers and created interoperability provisions to give users power to more easily choose providers and equipment (CD June 11 p1). The groups said they believe there has been “no effort on the part of the Commission to compensate or reward providers for improving functional equivalency in VRS calls. The Commission needs to reward such competition-driven innovation even during any efforts to improve the efficiency of the VRS system.”

The groups oppose a provision in the order that would set the compensation benchmark for the video communication service component at the contract price a neutral video communication service provider receives “because it will inhibit innovation.” The groups “strongly oppose” the FCC’s proposal to auction a subset of VRS minutes of use over privacy and competition concerns, since “using data to determine calling pattern as the first step in an auction process goes beyond appropriate oversight and intrudes on consumers’ confidentiality rights.” The order’s proposed $3 million budget for research and development is too low, with groups proposing it should be scaled as a percentage of “all compensable and noncompensable research and development costs and that it should not expire.”

The FCC should expand and revise the composition of the existing Interstate TRS Fund Advisory Council rather than “replace it in its entirety,” with members of the council coming from the “deaf and hard of hearing and speech disability communities,” TRS users, interstate service providers, state representatives and TRS providers, the consumer and advocacy groups said. The groups said they want the FCC to allow hearing contacts who use American Sign Language to receive 10-digit numbers and have access to necessary video phone software and equipment, allowing for additional peer-to-peer calls and reduce use of VRS-compensated services. The Interstate TRS Fund Advisory Council said it wanted to see the present council retained and its mission expanded. The council recommended expanding its membership to include the Gallaudet University Technology Access Program, Gallaudet and the University of Wisconsin-Madison’s RERC-TA, the Telecommunications Equipment Distribution Program Association, a “deaf-blind representative” and the National Deaf-Blind Equipment Distribution Program (http://bit.ly/17I2dSI).

The consumer groups coalition said they support overhaul of Internet-based telecommunications relay services (TRS), including decreasing the permissible wait time on Internet-based TRS services to 10 seconds. The groups support a provision in the VRS order that would allow a quarterly review of TRS Fund contribution, since that would “allow for flexibility in addressing increases or decreases in requests for reimbursement and projections of service requirements from TRS providers."

CTIA and USTelecom urged the FCC in separate filings to drop the quarterly TRS Fund reviews in favor of an annual review. The quarterly review requirement was one of several “unnecessary changes” to the VRS service that intermingled with “positive reforms” in the VRS order, USTelecom said. The requirement “would create significant administrative costs and burdens that would adversely affect the VRS program,” possibly resulting in higher costs and unpredictable changes to consumers’ bills (http://bit.ly/1f0o6iH). Doing an annual review of those contributions will help the FCC meet its goals of “ensuring that Video Relay Service ('VRS') is available to persons with hearing disabilities while also reducing the risk of waste, fraud and abuse of the VRS program,” CTIA said. “The Commission’s steps to help curb waste, fraud and abuse in the TRS Fund can be implemented without causing consumer confusion or overburdening the FCC’s limited resources” (http://bit.ly/14YzNb3).

Sprint urged the FCC to consider ways to reform other forms of TRS as it did in the VRS order. The FCC’s goal of making VRS “an effective, efficient, and sustainable program for the future” apply to all forms of TRS, including IP Relay and IP Captioned Telephone Service (IP CTS), Sprint said. It urged the FCC to “consider the unique characteristics of each service and user population in determining whether a particular regulation is appropriate for a particular form of TRS,” rather than applying direct copies of the VRS rules to other TRS forms. The FCC should designate separate sections of TRS rules for each service, and avoid “overly-broad blanket regulations” by ensuring that additional rules for Internet-based TRS forms are “tailored to address demonstrated needs,” Sprint said. The FCC should not extend registration and TRS User Registration Database requirements to IP Relay and IP CTS providers, as well as exclude IP CTS from the “national outreach regime” adopted for VRS and IP Relay, the telco said. The FCC should apply non-discrimination principles to all Internet-based TRS services, Sprint said. The FCC should establish “clear guidelines” regarding data providers submit to the TRS Fund administrator, it said (http://bit.ly/12mJ60s).

The Communications Workers of America and the National Interpreter Action Network urged the FCC to ensure the VRS order’s policies “support condition in the call centers that allow qualified interpreters to provide quality interpretation services” (http://bit.ly/14TUZrJ).