TDI Supports Change of FCC Global Travel Rules for VRS

TDI Supports Change of FCC Global Travel Rules for VRS

Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI) has filed comments with FCC requesting waiver of FCC global travel restrictions for VRS. Organizations such as the National Association of the Deaf (NAD), Deaf and Hard of Hearing Consumer Advocacy Network (DHHCAN), Hearing Loss Association of America (HLAA), Association of Late Deafened Adults, Inc. (ALDA), Cerebral Palsy and Deaf Organization (CPADO), and the California Coalition of Agencies Serving the Deaf and Hard of Hearing (CCASDHH) signed on in support of the joint filing.

In the comments, all of the organizations are referred to as the Consumer Groups. The comments effectively show the Consumer Groups as in support of the Petition for Waiver as filed by Sorenson Communications, Inc. On February 20, 2015, as well as the requests submitted by Purple Communications with respect to Video Relay Service.

The Consumer Groups support extending the modification of the Commission’s VRS rules with respect to the pre-travel registration requirement and the 28 day limitation sought by Sorenson and Purple to all VRS providers.

Currently, if you’ve left the United States of America (USA) for an international destination and you haven’t notified your Video Relay Service Provider, this would mean you’d be prohibited from using your VRS provider until you return back to the USA. People often aren’t aware of the requirement by FCC to notify their VRS provider of their intentions to travel abroad to be able to use VRS to call USA phone numbers while abroad. People should be able to still use VRS and notify VRS that they’ll be travelling abroad, even if after the fact. In fact, Sorenson estimates that only about half of all those travelling abroad remember to notify Sorenson.

By contrast, hearing consumers can make calls at any time and in almost any place where they can obtain a signal on their mobile phones throughout the world and they do not have to notify their provider before they travel of the anticipated travel plans. However, deaf and hearing persons cannot, which is inconsistent with the ADA’s functional equivalence standard. The pre-registration requirement deprives deaf and hard of hearing persons of their rights to functionally equivalent services.

In an increasingly connected world where employers, clients and business partners expect persons to be reachable nearly 24 hours per day, seven days per week, it has become essential for deaf and hard of hearing persons to have telecommunications access no matter where they are located, including international locations, just as hearing persons do. Absent such international access, deaf and hard of hearing persons are at a competitive disadvantage in the employment and business marketplaces. Moreover, it is reasonable for deaf and hard of hearing persons to be able to contact friends and family and to be able to freely communicate in the event of an emergency while on travel just as is the case for hearing persons. As with any other consumer, deaf and hard of hearing persons need to be able to reach friends and relatives in the event of an illness or injury, need to manage their travel while travelling by changing plane tickets, hotel arrangements, business appointments, or other arrangements and need to be able to discuss time critical business matters while on international travel.

If you’re an USA resident, and will be studying or working abroad for longer than 28 days, VRS providers are prohibited from continuing to give you service. Sorenson pointed out that this is untenable; Sorenson feels that the limitation of 28 days should be increased to 60 days to accommodate those studying or working abroad.

It is not unusual for deaf and hard of hearing persons to travel internationally for greater than 28 days just as is the case for hearing persons. For example, college students travelling during the three month summer break or during a semester abroad need access to modern telecommunications during their entire stay abroad, not just for 28 days. In addition, deaf and hard of hearing persons that contribute their time, energy and experience for disaster recovery efforts, community rebuilding efforts or charitable causes are likely to stay overseas and need access to VRS services for more than 28 days. In addition, as Purple notes VRS users “who are deployed abroad by our government such as military personnel, diplomats, and other government workers” should also “not lose basic civil rights granted by the Government when serving that very same government on overseas assignments.”

American consumers who are deaf and hard of hearing are unable to use VRS or other similar services in the host countries in which they are travelling because they do not contribute to these international TRS programs. Thus, deaf and hard of hearing persons who travel internationally beyond 28 days are sometimes forced to rely on the charity or forbearance of hotel staff and even strangers to make important and time critical calls. Hearing persons suffer no such detriment when they travel internationally, which is inconsistent with the functional equivalence standard.

The Consumer Groups also support extending the modification of those VRS rules to apply to all providers of VRS.

If you would like to view the filing by the Consumer Groups, it can be seen here:


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