IP Captioned Telephone Service: Rogervoice’s Application for Certification
Hearing Loss of America (HLAA), with the assistance of TDI’s legal representation, filed a comment to the Federal Communications Commission about Rogervoice’s application for certification as an IP Captioned Telephone Service.
We are still concerned with the Commission’s approach to reviewing and approving the ASR-based provider certifications without first creating the technology-neutral minimum standards and ensuring that sufficient information is available to the public regarding each provider’s ASR offerings. That also applies to similar applications like Rogervoice.
We expressed our concerns that the cheap ASR solutions will overtake the human captioners without the Commission making sure that all requirements are met in the ASR offerings. Still, we repeatedly stated that we did not oppose the Commission’s approval of the applications that have a similar quality to the ones already certified. However, we urged the Commission to consider Rogervoice’s application and the quality it offers such as speech-to-text functionality. In addition, we noticed that Rogervoice offers CA-assisted services in France but only seeks conditional certification for ASR-only calls. The Commission should carefully look over Rogervoice’s application and redacted parts to ensure it meets the standards.
We again urge the Commission to adopt a robust policy to ensure that diverse modes of delivering IP CTS, including switched, hybrid human-ASR, and other humans-in-the-loop models remain viable until the Commission ultimately adopts metrics and standards.
For more information about TDI’s filing addressing Rogervoice’s Application for Certification as a Provider of IP Captioned Telephone Service, visit the filing and full list of signatories at the following link: https://www.fcc.gov/document/comment-sought-rogervoice-application-provide-ip-cts
Filing
CG 03-123 — Telecommunication Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities
Special Thanks to:
SAMUELSON-GLUSHKO TECHNOLOGY LAW & POLICY CLINIC
Certification as a Provider of IP Captioned Telephone Service Co-Signatories:
TDI. Hearing Loss Association of America (HLAA). National Association of the Deaf (NAD). Rehabilitation Engineering Research Center on Technology for the Deaf and Hard of Hearing (DHH-RERC).
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