Empowering Access to Information:

TDI’s Resource Page on Emergency Communications, Policy Filing, and Captioning Technology.

TDI’s Policy involvements

Filing Policy Comments or Complaints


Emergency Communications

Telecommunications Relay Service (TRS)

Real-Time Text (RTT)

Advanced Communication Services (ACS)

Emerging Technologies


Advocacy Coalitions

Filing your policy comment or complaint

TDI is actively involved in the Federal Communications Commission’s Rulemaking Process. The Federal Communications Commission regulates interstate and international communications through cable, radio, television, satellite and wire.

To file a comment on FCC proceedings, visit the FCC consumer guide for commenting on FCC Proceedings. You can share your concerns with TDI as well, for us to consider in our comment filings.

To file complaints about communication inaccessibility, the FCC’s Disability Rights Office may be able to help. Go to the FCC’s Consumer Complaint Center to learn more.

If you want to file a complaint based on disability discrimination, go to the Department of Justice’s Civiil Rights Division for ADA-related complaints at: ADA.gov/file-a-complaint.

Emergency Communications

TDI monitors and comments on proceedings related to the nation’s Emergency Alert System (EAS), 9-1-1 Service, Wireless Emergency Alerts (WEA), and other public safety communication systems.

Ensuring continuous operation and reconstitution of these critical communication systems services, involves the work of federal agencies like the Federal Emergency Management Agency (FEMA), the FCC, Public-Safety Answering Points (PSAPs), and communication industry partners such as broadcasters, cable television operations, radio providers and other entities. 

Learn More

The Nation's 9-1-1 System

9-1-1 service is a vital part of our nation’s emergency response and disaster preparedness system.

TDI continues to advocate for DHH people’s equitable access to communication with PSAPs/9-1-1 centers. The only way DHH people will have equitable access is when PSAPs are able to accept direct video communication.

At present time, the only way for DHH people to directly contact 9-1-1 centers are:

    • Using legacy TTY.
    • Using mobile phone’s RTT. *
    • Using Text-to-911. **

All options require English language proficiency, thus preventing DHH people to communicate in sign language. 

* Requires a PSAP’s network to be upgraded to Next Gen with Core Services (NGCS). Until then, the RTT call functions like a TTY call.

** Not all PSAPs accept Text-to-911: it is up to each 911 call center and their governing bodies to decide whether and when to begin accepting texts. To see if your PSAP accepts Text-to-911, check the FCC’s Text 911 Master PSAP Registry.

Why Direct Video Connection with 9-1-1 is Important

When you contact 9-1-1 directly, your location triangulation is shared with emergency services.

If calling 9-1-1 using telecommunication relay services, your location coordinates are not automatically transmitted – DHH callers using TRS must confirm or explain their location.

TDI believes all sign language users should have the ability to call 9-1-1 directly and communicate with an agent in sign language without the assistance of a third party.

In an emergency, this will ensure that Deaf people reliant on ASL can receive immediate assistance in their preferred and often first language – truly achieving equal 911 access with voice telephone users.

Bounce-back Messages

If you attempt to send a Text-to-911 where the service is not yet available, FCC rules require all wireless carriers and other text messaging providers to send an automatic “bounce-back” message that will advise you to contact emergency services by another means, such as making a voice call or using TRS.

Emergency Alert System (EAS)

The Emergency Alert System is a national public warning system requiring broadcasters, cable television operators, satellite digital audio radio providers, and direct broadcast satellite operators to provide communications capability for the President to address the nation during a national emergency.

    Wireless Emergency Alert (WEA)

    WEA is a public safety system that allows customers who own compatible mobile devices to receive geographically targeted, text-like messages alerting them of imminent threats to safety in their area.
    To learn more about WEA, visit the FCC’s consumer guide using this link.

      Your Local Emergency Management Office

      To find out your local government’s plan, preparation and response plan to disasters, visit FEMA.gov/locations and enter your ZIP code.

        Captioning Technology

        (CC, OC, SDH, ASR)

        Captioning provide a readable text of the audio portion of a video content. There are different types of captioning, each varying in definition, technology, and rules.

        Federal laws mandate that most broadcast and cable television programming must be closed captioned, unless exempted, and  in many circumstances that televised captioning programming must continue to be captioned when shown online.

        Caption is required if:
        – video appears on TV
        – video is by the government
        – is a public entity
        – educational materials
        – Your state has accessibility laws requiring captioning

        Learn More


        Captioning should be easy to turn on and customize. Unfortunately many caption settings are buried behind layers of inscrutable menus. TDI believes to make captioning display settings readily accessible. 


        TDI has registered significant concerns with the FCC about chronic problems related with captioning quality for live programming – including with automated captioning – as well as – transmission errors and shortcomings with industry responsiveness to complaints, and believes that additional rules and enforcement are required to ensure caption quality.


        At this time, podcasts are not generally required by law to be captioned. However, podcasts are a contemporary form of entertainment and available to everyone; TDI believes they should be captioned. 


        Congress requires video programming distributors (VPDs) – cable operators, broadcasters, satellite distributors and other multi-channel video programming distributors – to close caption their TV programs.


        Captions must match the spoken words in the dialogue and convey background noises and other sounds.


        Captions must coincide with their corresponding spoken words and sounds and must be displayed on the screen at a readable speed.


        Captions must run from the beginning to the end of the program.

        Properly placed

        Captions should not block other important visual content on the screen, overlap one another or run off the edge of the video screen.


        The Twenty-First Century Communications and Video Accessibility Act (CVAA)
        The Telecommunications Act of 1996
        The Television Decoder Circuitry Act of 1990
        The Americans with Disabilities Act (ADA)
        The Rehabilitation Act


        There are two types of exemptions from the FCC’s TV closed captioning rules: self-implementing categorical exemptions and individual economically burdensome exemptions granted via petition. To see a complete list of self-implementing exemptions, visit the FCC’s website at: www.fcc.gov/general/self-implementing-exemptions-closed-captioning-rules.


        First contact your VPD, or streaming service. If you watch broadcast TV, go to the TV station’s website, at the footer you’ll find a captioning link.
        If you continue to have problems, you may file a complaint with the FCC. 

        DVDs, video games, etc.

        The FCC does not regulate captioning of home videos, DVDs or video games.

        Automatic captions, sometimes called Live Captions, use automatic speech recognition (ASR) technology to transcribe audio to create closed captions. 

        Communication Access Realtime Translation (CART) captioning is the translation of the spoken word into text using a stenotype machine, computer, and realtime software. The text appears on the viewer’s computer monitor or other display.

        CC is the visual display of the audio portion of video programming. It includes the dialogue as well as any other relevant audio. They are used to communicate all audio sounds including sound effects, speaker IDs, and other non-speech elements and can be enabled or disabled at the viewer’s option.

        Unlike closed captions, open captions are “burned in” to a video and cannot be turned off. Open captions are added directly to the video file or media player. This type of captioning is generally used in movie theatres.

        Subtitles translate video dialogue into other languages, so that audiences all over the world can watch videos, movies, and more content without needing to understand the language spoken. They communicate dialogue, but often not non-speech elements like sound effects in an audio track.

        Subtitles for the deaf and hard of hearing (SDH) are subtitles that combine the information of both captions and subtitles. They can be in the source language of the video, as they include important non-dialogue audio like sound effects and speaker identification.

        Telecommunications Relay Service (TRS)

        The nation’s TRS system was established in 1990 by the mandate of Title IV in the Americans with Disabilities Act. TRS allows DHH people to communicate using the nation’s telephone network.

        There are several forms of TRS. Each provider offers a varying degree of communication features, modalities, and technologies using audio, text and/or video. 

        TRS providers must offer service that meets certain mandatory minimum standards set by the FCC. Some of these include:

        – Available 24 hours a day, 7 days a week;
        – Calls answered within 10 seconds (120 seconds for VRS);
        – Prioritize emergency (9-1-1) calls;
        – Calls and TRS conversations are prohibited from being recorded;

        For more detailed information on TRS, visit the FCC’s TRS consumer guide.

        Learn More


        CTS involves the use of a captioned telephone with built-in screen displaying real-time text captions of the non-CTS user.  CTS refers to the telephone line; IP-CTS refers to calls using the VoIP / broadband network.


        Automated speech recognition technology, with or without the assistance of a CA, transcribes the non-IP CTS user’s words into captions for the IP CTS user to read.

        Some CTS providers only provide ASR.


        The traditional relay service uses a keyboard-to-voice approach with a Communication Assistant (CA) transcribing/voicing the call.

        Devices are typically legacy wireline TTYs or computer keyboards and mobile phones using the internet.



        IRIS enables DHH callers to use their cellular phone’s native dialer to make and accept TRS calls. The IRIS project developed by the NTID Center on Access Technology. Project release pending FCC action.


        VRS allows DHH people to communicate in sign language, using a direct video connection to CAs, who is a qualified interpreter. The CA connects to the other party’s phone and relays the conversation back and forth, in sign language and voice, between the parties.



        Direct Video Calling (DVC) is a one-to-one video communication service provided by call centers using an ASL- trained agent allow conversations to occur between two callers using sign language.

        Real-Time Text (RTT)

        RTT is an assistive technology tool that allows text to be sent from wireless handsets instantly as it is being typed.  A recipient can read the message while the sender types it, much like its predecessor– the TTY.

        A RTT user can communicate directly with a TTY user. RTT is used on wireless handsets using IP-based technology, whereas TTYs rely on the legacy telephone copper wireline.
        To activate RTT on your mobile cellular phone, you must have voice & data plan.

        RTT was developed by Gallaudet University’s Technology Access Program along with other collaborators

        Advanced Communication Services (ACS)

        Advanced communications services and equipment, such as computers, tablets and mobile phones, are required to be accessible and usable by individuals with disabilities under the Twenty-First Century Communications and Video Accessibility Act.

        To be accessible, the main functions of a product or service must be locatable, identifiable and operable by individuals with varying abilities, and all information necessary to operate and use the product or service must have an accessible output or display.

        To be usable, individuals with disabilities must be able to learn about and operate the product or service’s features, and must be able to access information and documentation for the product or service, including instructions and user guides.  In addition, companies must provide access to support services, such as technical support hotlines and databases, call centers, service centers, repair services and billing services.

        TDI routinely files comments to the FCC’s Biennal Report to Congress on the state of advance communication technologies.  

        Emerging Technologies

        Emerging technologies are technologies whose development, practical applications, or both are still largely unrealized, such that they are figuratively emerging into prominence from a background of nonexistence or obscurity. These technologies are generally new but also include older technologies.

        Although there are many examples of emerging technologies, TDI monitors those that may fall within our mission of equitable communication, such as: Artificial Intelligence, Internet of Things, Autonomous Vehicles, and wearables.

        As these emerging technologies continue to develop, TDI evaluates whether they are accessible to DHH people, and takes appropriate action to ensure accessibility.


        Video telephony is full-duplex, real-time audio-visual communication between or among end users. The videophone, as well as Zoom, FaceTime, Skype are examples of video telephony technology.

        TDI refers to these as multimodal communication services in our filings. Multi Modal Communication is simply a term for describing all the different ways we employ in communicating with each other, every day. This may be via spoken language, texting, tweeting, emailing, handwriting, body language, & gesturing, or by using a communication device.

        TDI advocates to ensure all video telephony platforms are fully accessible to DHH people. This includes, but not limited to, TRS interoperability, automated and human generated captioning,  and hearing aid compatibility. 

        Advocacy Coalitions

        TDI collaborates with many other DHH advocacy organizations and coalitions like the Deaf and Hard of Hearing Consumer Advocacy Network (DHHCAN) and the Consortium for Constituents with Disabilities (CCD).

        To see the full list of advocacy organizations TDI partners with, search for “DHH Advocacy” in TDIBlueBook.com.