FCC Filing: A Response to Sorenson’s Comment on Convo’s Petition on Proposing Changes to Certain Video Relay Service (“VRS”) Service Rules

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

COMMENTS

TDI, along with the tagged consumer groups filed reply comments to the Federal Communications Commission, about Sorenson’s comment on Convo’s Request for changes to certain VRS rules. 

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

We responded to Sorenson’s comments urging the Commission not to implement a cap on the percentage of VRS minutes relayed through remote workstations on a monthly basis. 

As mentioned in our initial comments, we do not oppose having an increase of the percentage of VRS minutes relayed through remote workstations of up to 80% – as long as additional safeguards are in place.

However, we opposed having no cap on VRS minutes relayed through at-home workstations until clear and proper policies and procedures are made. It is very important that the FCC take measures to ensure that at-home networks are secure, reliable, and redundant. Privacy is paramount and additional oversight must be exercised to ensure that Communication Assistants (CAs) take appropriate steps to ensure the privacy of calls relayed through their remote workstations.

Also, Commission should require VRS providers to implement appropriate measures to provide a call-back option and connectivity to the next available CA in case if a problem arises. VRS providers must ensure remote workstations have the same reliability and redundancy that dedicated call centers enjoy including measures to reroute a call or reconnect for any dropped calls.

Thus, the FCC should not set any unlimited cap on minutes until it establishes clear and proper policies and procedures in place.

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

https://ecfsapi.fcc.gov/file/108031065709708/TDI%20et%20al.%20Reply%20to%20Comments%20on%20Convo%20Petition.pdf