FCC Filing: Accessibility Coalition Carceral Comms Fifth FNPRM

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OTHER

         WC 12-375 — Rates for Interstate Inmate Calling Services;

COMMENTS

HEARD, with the assistance of TDI’s legal representation, filed a Comment to the Federal Communications Commission concerning the communication accessibility for the Deaf and other incarcerated people with disabilities in correctional facilities. 

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

We asked the FCC to require the inmate calling service (ICS) providers to provide modern communication services such as TTY (text telephone devices)-based telecommunications relay services, the Video Relay Services (VRS), Internet Protocol captioned telephone service (IP CTS) or captioned telephone service (CTS), Internet Protocol relay service (IP Relay), and speech-to-speech relay service (STS), as well as direct video and text communications services, including direct video calling and real-time text (RTT) in all correctional facilities for Deaf individuals. 

According to certain provisions under Communication Acts and the FCC’s legal authority under certain provisions under that Act as well, the FCC has the authority to require the ICS providers to provide access to TRS services. Also, the FCC should require these providers not to charge for any TRS calls including the provision of direct video and text communication with no charge. 

Therefore, the correctional facilities must provide modern and updated communication services for these incarcerated individuals with disabilities to have equal and proper communication access, in addition, to reintegrate them successfully back into society. Not only that, the proper and equitable communication services will ensure that Deaf individuals have an improved quality of life, mental and physical well-being, and access to information.

Finally, the FCC should expand the annual reporting requirements to include all TRS and direct video and text communications. The FCC acknowledges that it previously “found the burdens of reporting TTY-based calls to be far outweighed by the benefits of greater transparency and heightened accountability on the part of inmate calling services providers.”

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

https://ecfsapi.fcc.gov/file/10927245844157/2021.09.27%20Accessibility%20Coalition%20Carceral%20Comms%20Fifth%20FNPRM%20Comments%20final.pdf

Special Thanks to:  Samuelson-Glushko Technology Law & Policy Clinic (TLPC), Colorado Law