FCC Filing: Consumer Groups and Accessibility Researchers Respond to FCC’s Proposed Rulemaking on IP CTS Metrics

TDI FCC Filing

TELECOMMUNICATIONS

CG 03-123 — Telecommunication Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities;
CG 10-51 — Structure and Practices of the Video Relay Service Program;
CG 13-24 — Misuse of Internet Protocol (IP) Captioned Telephone Service;

COMMENTS

Hearing Loss Association of America (HLAA), with the assistance of TDI’s legal representation, filed comments to the Federal Communications Commission’s Further Notice of Proposed Rulemaking on adopting measurable standards and metrics for IP-Captioning Telephone Services.

[see below, under Tags: for full list of signatories]

URL below is linked to the actual filing document on FCC’s Electronic Comment Filing System 

Special Thanks to:  SAMUELSON-GLUSHKO TECHNOLOGY LAW & POLICY CLINIC

We welcomed and applaud the Commission’s commitment to properly fund and regulate IP Captioning Telephone Services, and we agree with the Commission that all Captioning Telephone Services, whether provided by automated speech recognition (ASR) or Communication Assistants (CAs), must have quantifiable measurement of the quality of service.

We urge the Commission to use an independent American National Standard Institute (ANSI) accredited body to determine the metrics, measurement methodology, and performance criteria for IP CTS services. Representation from all stakeholders, including consumers and providers should contribute to the development of these metrics. Once implemented, ongoing testing should be done by an independent entity to ensure impartiality, accuracy, and transparency.

We recognize and appreciate the providers’ time and efforts in developing a measurement methodology for performance standards. While commendable, we are concerned other stakeholders were not involved in the process. An open process ANSI standards will ensure all stakeholders are involved, their concerns fairly addressed, and prevent metrics from being skewed by a single party’s influence.

We suggest the Commission to adopt additional metrics regarding speed of answer, dropped/disconnected calls, and service outages. Additionally we implore the Commission to strengthen it’s speed-of-answer standards. The current rule is 85% of all calls being answered within 10 seconds. Although the Commission has relaxed this rule in response to COVID-19’s impact on operational efficiency, we now have d/hh captioned phone users waiting more than a minute to connect to a provider. This is unacceptable and life-threatening when callers are trying to reach emergency support. We ask the Commission to revise the ruling, requiring response time to the maximum speed allowable with available call support and routing technology.

Further in our filing, we asked to restrict dropped or disconnected calls, testing methodology using reasonable sample size, use of service, natural phone conversational scripts, varying audio levels and conditions, and finally that testing should not be identifiable testing calls. The final adopted metric methodology and testing should be required for all IP-CTS providers, regardless if they use Communication Assistants or automated speech recognition. An independent body should conduct all the tests to ensure fair and unbiased results. Results should be publicly posted on the Commission’s site.