Interoperable Video Conferencing Services

Accessibility Advocacy and Research Organizations. TDI, along with the listed consumer groups below, filed a comment to the Federal Communications Commission’s Public Notice. This filing regarding the interoperable video conferencing services (IVCS). The Commission finally addressed the issue of accessibility and usage of video conferencing services for people who are deaf, hard of hearing, or DeafBlind and those with other disabilities. Previously in 2011, Commission established the ACS rules but it was not meeting the standards for accessibility in those services. The Commission uses Congress’s statutory definition of the “service that provides real-time video communications, including audio, to enable users to share information of the user’s choosing” which ACS rules covers. As a result, the Commission may adopt the definition’s intent to encompass VRS and/or video conferencing services that can run on a variety of hardware and operating systems. The COVID-19 pandemic saw the most utilization of the range of modern video conferencing services and equipment that ACS covers. We applaud the Commission for investigating the issue and beginning the process of crafting laws to enable an accessible video conferencing ecosystem when CVAA was founded. This action is essential to fulfilling the CVAA’s overarching promise to ensure that all Americans, including Americans with disabilities, have access to what has become an indispensable mode of distance communication in the United States and worldwide.

Addressing Accessibility Barriers

So, that is why we lauded the Commission for finally addressing the most critical communication barrier that people who are deaf, hard of hearing, or DeafBlind, as well as those with other disabilities faced during the pandemic, that is, equitable access to interoperable video conferencing services (IVCS). Not only the IVCS, but it also applies to a broader array of multimodal communications services, including the need for interconnection between these systems and telecommunications relay services (TRS). We also recognized the issue of properly defining the meaning of “interoperable” so that the Commission is able to use that word properly to include the necessary communication services and equipment under the ACS rules. Nonetheless, Congress clearly explains that the ICVS means “a service that provides ‘real-time video communications, including audio, to enable users to share information of the user’s choosing.” Secondly, adopting the CVAA’s definition of “interoperable video conferencing services” is consistent with the CVAA’s goals of ensuring accessibility and usability. In another way, the Commission should use a definition of interoperable video conferencing services that ensure full access to these services under the Commission’s ACS rules. Finally, we believed that the Commission should swiftly apply the ACS rules to IVCS and implement the recommendations contained in the DAC’s TRS-Video Conferencing Report. For more information about TDI’s filing addressing IVCS, visit the filing and full list of signatories at the following link: https://www.fcc.gov/ecfs/search/search-filings/filing/106211604611836 interoperable video conferencing services

Filing:

CG 10-213 — Consumer and Governmental Affairs, Media, and Wireless Telecommunications Bureaus Seek Update on Commission’s Fulfillment of the Twenty-First Century Communications and Video Accessibility Act CG 21-140 — Implementation of Sections 716 and 717 of the Communications Act of 1934

Special Thanks to:

SAMUELSON-GLUSHKO TECHNOLOGY LAW & POLICY CLINIC

Interoperable Video Conferencing Services Co-signatories:

TDI, Alexander Graham Bell Association for the Deaf, American Association of the DeafBlind (AADB), American Deafness and Rehabilitation Association (ADARA), Association of Late Deafened Adults (ALDA), California Coalition of Agencies Serving the Deaf and Hard of Hearing (CCASDHH), Cerebral Palsy and Deaf Organization (CPADO), Communication Service for the Deaf (CSD), CueSign, Deaf Seniors of America (DSA), Global Alliance of Speech-to-Text Captioning, Hearing Loss Association of America (HLAA), Helen Keller National Center for DeafBlind Youths and Adults (HKNC), National Association of the Deaf (NAD), Northern Virginia Resource Center (NVRC), Registry of Interpreters for the Deaf (RID), Rehabilitation Engineering Research Center on Technology for the Deaf and Hard of Hearing (DHH-RERC), Rehabilitation Engineering Research Center on Universal Interface & Information Technology Access (IT-RERC)

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TDI Blue Logo TDI represents 48 million Americans who have some degree of hearing loss. We welcome all members of the deaf and hard of hearing community (DHH): deaf, hard of hearing, late-deafened, deafblind, lip-readers, cued-users, veterans with hearing loss, senior citizens, deafdisabled, and/or having additional sensory, mobility, cognitive or other communication disabilities. TDI represents the entire DHH community with one goal. To ensure every person has equitable access to the nation’s telephone, cable, television, radio, and broadband networks. Join us and become a member today: www.tdiforaccess.org/membership/
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