FCC Filing: Establishing Emergency Connectivity Fund to Close the Homework Gap

OTHER

WC 21-93 — Establishing Emergency Connectivity Fund to Close the Homework Gap

COMMENTS

TDI, along with the tagged consumer groups filed a comment to the Federal Communications Commission to Establishing Emergency Connectivity Fund to Close the Homework Gap 

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

As part of the American Rescue Plan Act of 2021, this fund is to help schools and libraries provide devices and connectivity to students, school staff, and library patrons during the COVID-19 pandemic. We applauded the FCC for this speedy action to ensure that Deaf, Hard of Hearing, and DeafBlind communities have access.

We supported that the FCC adopting rules to make sure the “connected devices” are accessible and usable to these communities during the pandemic, especially, the demand on the virtual video conferences. However, video conferences are not that often accessible such as having captioning services or having relay services.

We also provided resources to the FCC who need information on additional equipment or services that would be helpful for these communities. The FCC should interpret the advanced telecommunications and information services to include video devices that facilitate access to video relay services (“VRS”) and audio devices that facilitate access to Internet Protocol captioned telephone services (“IP CTS”). Otherwise, the students will be behind with homework and experience the homework gap during the pandemic.

We disagreed with the FCC’s current 25/3 broadband speed benchmark since a signing household with a student who is deaf, hard of hearing, DeafBlind, or deaf with mobility issues requires at least 50/50 broadband speed to accommodate TRS and VRS. In addition, the Commission should not impose data caps on internet service offerings for students who are deaf, hard of hearing, DeafBlind, or deaf with mobility issues. Since video conferencing platforms do not have adequate captioning capabilities, students who are deaf, hard of hearing, DeafBlind, or deaf with mobility issues need captions, ASL interpreters, CLTs, and other services to ensure e-learning classrooms are accessible. This requires additional bandwidth and uninterrupted access to these services.

We agreed that the FCC allowing schools and libraries to place Wi-Fi hotspots at various locations outside of schools and libraries. Still, the Commission should consider whether schools or libraries provide education to students with disabilities when determining Fund availability.

We appreciate the opportunity to provide input on the Commission’s questions regarding the Emergency Connectivity Fund to Close the Homework Gap and urge the Commission to take action to protect access to individuals with disabilities.

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

https://ecfsapi.fcc.gov/file/10406052369351/FINAL_TDI%20et%20al.%20Comments%20on%20Emergency%20Connectivity.pdf