FCC Filing: Consumer Groups and Accessibility Researchers Reply to Comments re: 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

REPLY COMMENTS

Hearing Loss Association of America (HLAA), with the assistance of TDI’s legal representation, filed reply 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 a full list of signatories]

We recognized that there was a consensus that all stakeholders understood the importance of the IP CTS services for all Americans. Thus, we agreed that the current rules should be amended to provide accurate measures of the quality of services. Not only that, we agreed that standards should be examined before FCC approves any metric and performance standards.

Nevertheless, we disagreed with the providers in several things that require the FCC to provide or conduct minimum standards for the services. We agreed that meticulous testings must be completed with an ANSI-accredited body, non-permitting the providers to be involved with the testings to prevent bias, having the FCC adopt the bridge policy to ensure fully functional equivalent services, and asking the FCC to set up a five-star rating system for each call.

With these requirements met, then the Americans will be able to experience fully accessible services to the IP CTS services and provide their ratings to improve the services instead of having providers to make decisions for them.

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

https://ecfsapi.fcc.gov/file/104021853125470/2021.04.02%20Consumer%20Groups%20and%20Accessibility%20Researchers%20IP%20CTS%20Metrics%20Reply%20Comment%20final.pdf

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