TDI and Consumer Groups Respond to FCC’s NPRM on VRS Reform

TDI eNote: TDI and Consumer Groups Respond to FCC’s NPRM on VRS Reform

Thanks to TDI’s pro-bono attorneys at Bingham McCutchen, TDI and its sister consumer groups such as AGBell, ALDA, CCASDHH, CPADO, DHHCAN, DSA, NAD, and NBDA and were able to articulate the perspective of end-users who rely on various relay services to the FCC about it’s proposed changes to video relay services in its recent filing with the FCC. Please be aware that any rules adopted for video relay services can have an impact on other forms of Internet based relay such as IP-Relay, IP-Captioned Telephone Services (IP-CTS). The bottom line is that TDI and its sister consumer groups want maximum access to the technology as well as optimal user experiences of all types of relay services. Near the bottom of this TDI eNote are instructions on how you can file your own comments to the FCC. The deadline to file comments is on November 29, 2012.

Thank you.

Federal Communication Commission


TDI and Consumer Groups Respond to FCC’s NPRM on VRS Reform

On October 15, 2012, the Federal Communications Commission (FCC) issued a Public Notice seeking feedback on several proposals that can change Video Relay Services (VRS) and wants to know what your ideas are to improve this vital service in the future.

The FCC asks us three major questions.

1. Should the FCC require the use of a single software program or app for all VRS calls through any certified provider?
2. Should the FCC require the use of a central database for telephone numbers and other information about us?
3. Should the FCC adopt a proposal that reduces reimbursement rates for VRS providers?

Last week, on November 14, 2012, TDI and eight sister Consumer Groups such as as Alexander Graham Bell Association of the Deaf and Hard of Hearing (AGBell), Association of Late Deafened Adults (ALDA), California Coalition of Agencies Serving the Deaf and Hard of Hearing (CCASDHH), Cerebral Palsy and Deaf Organization (CPADO), Deaf and Hard of Hearing Consumer Advocacy Network (DHHCAN), Deaf Seniors of America (DSA), National Association of the Deaf (NAD), and National Black Deaf Advocates (NBDA) responded to these important questions by filing comments with the FCC. While we offer some excerpts below, you may read the entire comments online at

At the end of this eNote, we will tell you how to file your own comments or tell the FCC that you support our comments.

Functional Equivalency Mandate

In April 2011, the TDI and other consumer groups filed a Telecommunications Relay Service (TRS) policy statement with the FCC outlining the following core principles for functional equivalency in any form of relay services.

* TRS must provide full benefit to all parties on a call, regardless of the complexity and/or cost
* The TRS experience for an individual who is deaf, hard of hearing, deaf-blind or speech-disabled must, at the minimum, be equivalent to that of a call between two hearing persons on the telephone network or over the Internet.
* TRS users must be offered the ability to enjoy high quality relay services using mainstream products and services.
* TRS equipment and services must be accessible and address the diverse needs of individuals who are deaf, hard of hearing, deaf-blind or speech-disabled.
* Interoperable communication must be readily available and achieved with anyone, anytime, anywhere.
* Vendors must be motivated to bring products to market that keep pace with mainstream technological advancements, and are continually improving the relay experience.
* TRS users must have a wide selection of choices regarding equipment and software interfaces as well as hardware options, TRS program services and methods of making or receiving relay calls.
* Emergency calls made through TRS must fully satisfy the safety and security needs of TRS users.
* TRS users must receive prompt, comprehensive customer care service from their relay providers in their preferred communication modality.
* The commitment to uphold the integrity of the TRS Fund must be fully maintained.


As we answer these three fundamental questions, TDI believes that it is our civil right to experience as much as technologically possible, the full functional equivalency in using relay services as if we were hearing people picking up a regular phone and making a call without any problems. If no one answers, then we should have the capability to leave messages, no matter what devices we both use. Our contact list belongs to us and we should be able to have access to our list at all times. Our goal is to experience the ease that hearing people have when making phone calls with robust connections, clear communications and not have to worry if our devices are compatible.

1. Single VRS Software Program or Mobile Application

Do you experience clear video in every call? Do you have problems understanding the other person? Does your screen freeze up or become pixilated? Do you understand the caller ID when people call you? Are you able to leave a message when you call someone that is away from the phone? Not every call, especially those involving two different videophones are completely compatible. These problems that you experience are mostly caused by different devices with incompatible video codecs (programs), inferior line conditions and other issues that affect interoperability between the two devices at opposite ends of the call.

TDI and its sister consumer groups believe that requiring a single software program or mobile application for everyone to use as a videophone (VP) on all VRS calls with any provider will not solve these problems, and will not be a good idea for deaf and hard of hearing consumers. VRS providers compete with each other in different ways, such as offering competitive products and software/apps. As the following quotation from consumer groups says:

“VRS providers should be able to distribute equipment (proprietary and off-the-shelf) in addition to consumers being able to acquire off-the-shelf equipment. Many deaf, hard of hearing, late deafened, deaf-blind and speech disabled individuals may have difficulty purchasing off-the-shelf equipment themselves. Allowing VRS providers to distribute such equipment would help provide access to VRS services to such consumers. Further, VRS providers often provide equipment (proprietary and off-the-shelf) that are customized for VRS services or include features that are not always available with off-the-shelf equipment, such as flashing lights that indicate when a call is being received.”

We believe that allowing VRS providers to offer different products for your home, workplace or mobile device can encourage innovation and improving products to make it easier to use. If there is no competition, VRS products will not improve and technology will leave us behind once again. Deaf-blind people need the ability to change font colors and high contrast interfaces. Others with motor disabilities need easy to use controls that are adjustable to their specific capabilities. More than twenty years ago, when the Americans with Disabilities Act (ADA) was enacted, the law encouraged relay services keep pace with technological change, and we have benefited so much because of these changes. TDI understands that the FCC wants to ensure that all VPs can communicate with each other, and encourages the FCC to address interoperability problems with a reference platform managed by a neutral third-party for testing and certification of interoperability for all VRS products and videoconferencing products for.

2. Central iTRS Database

Do you wish that more people can have a video phone too such as your hearing family members, friends and interpreters? Are you confident that you will receive emergency help if you call 9-1-1?

TDI and other groups recognize some benefits in having a central Internet Telecommunications Relay Service (iTRS) database to keep track of all phone numbers for us, but we want to make sure our information is kept private and is managed well. This will ensure smooth transitions by users wanting to patronize different providers and be able to handle multiple accounts by anyone that may use one VRS provider at home and a different provider at work. It would be easier for multiple users in the same household to select their own provider. Here are two more quotes from the consumer groups:

“As the Commission is aware, the Consumer Groups support rules that would permit hearing individuals to obtain ten-digit numbers that would allow them to make point-to-point calls with VRS users. … One key advantage of the database could be to alleviate these concerns.

“Another advantage of a centralized database would be that the database administrator, rather than the VRS provider, can be the entity that maintains the user profile and thereby can ensure that it is consistent with NG911 [Next Generation 9-1-1] requirements. By making the administrator responsible for maintaining the user profile, it would eliminate the need for a consumer to establish multiple profiles with both their primary and dial-around VRS providers.”

A well-designed database can help the FCC operate the VRS/TRS system more efficiently and make sure that all people, hearing or deaf, who need the service receive the right kind of support. More importantly, during emergencies, it will be easier to handle 9-1-1 calls once the database includes more information to help locate and contact the nearest appropriate call center.

3. VRS Rate Changes

Are you experiencing longer wait times? Is the interpreter translating you correctly? If you call a doctor or a lawyer, do you have problems understanding the interpreter? Are you satisfied with your device?

None of the Consumer Groups including TDI have access to cost information from most providers to adequately comment on the impact that the proposed rate changes will have on the VRS industry. Nevertheless, TDI and other groups urge the FCC to consider all factors before they make a final decision on reimbursement rates to VRS providers. But if the Commission find that it is necessary to increase or cut rates, we ask that it keep in mind the foremost goal of functional equivalency in order to minimize any adverse impact. Here is a final quote from the Consumer Groups in their recent filing to the FCC.

“If the reimbursement rate is set below-cost, however, the Consumer Groups can apply common sense to what will happen … service quality will diminish, service improvements that bring consumers closer to functional equivalency will not be made, consumer choice will be reduced to one or two providers, and the VRS program will fail to meet the ADA mandate that all consumers have access to functionally equivalent communications services.”

All the stakeholders, including the consumer groups are concerned that cutting rates without having any minimum quality standards in place could lead to severe loss of service quality. We would rather see the FCC be able to compensate VRS providers for using up-to-date equipment, better qualified interpreters, faster speed of answer, and/or providing ways for users to be better matched with appropriate interpreters depending on the nature of the call.

How to File Comments

The FCC has gone on the record several times that VRS services will not end. Nevertheless, these proposed ideas and changes is likely to cause a drop in the quality of VRS. Some of you already have seen other messages that may carry more hype than is necessary. If you have ideas on how to improve VRS, the FCC needs to hear from you. We encourage you to submit your own comments to the FCC, or file a statement supporting the comments provided by the Consumer Groups comments or a different group.

* Visit
* Click “Submit a Filing (Express)” on the left side of the webpage.
* Then click on Proceeding #10-51, “In the Matter of Structure and Practices of the Video Relay Service Program.”
* This will take you to a web page where you can fill out your information and write your comments.
* Remember, the deadline for reply comments on this proceeding is November 29, 2012.

Thank you, and please do send us a copy of your comments to [email protected] if possible.

Leave a Reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.