Town Hall on Advocacy

The full name of this workshop is "Town Hall on Advocacy: an Interactive Session to Address the Telecommunications Problems of Today" It was presented by Karen Pelz-Strauss of Gallaudet University at the 2003 TDI Conference in Las Vegas. She has long been involved in telecommunications issues related to hearing loss.

The workshop focused on telecommunications and television access issues that need to be addressed. Planned topics are listed below, but this workshop is intended to be very interactive, so we'll see where it takes us.

- Internet Technologies
- Interactive Voice Response Systems
- Captioning quality
- Telecommunications Relay Service (TRS)
- FCC Complaint Handling
- 911 Access

Internet Technologies

One issue that must be addressed soon is how to determine which new technologies are covered by telecommunications law. For example, VoIP (Voice over IP) telephones, instant messaging (IM), and Internet chat are all functionally similar to traditional telephone service. But they are considered to be information services, so they're not covered by telecommunications laws. We must advocate to be sure that these services remain accessible, and that accessibility is incorporated during the design stage, rather than being added on later.

Interactive Voice Response Systems

Interactive Voice Response (IVR) Systems are an example of how standards confusion can frustrate accessibility. Back in 1999, when the FCC was issuing new business rules, we said the IVR systems are not accessible to TTY users, people who are hard of hearing, etc. We asked the Department of Justice (DOJ) to ensure that these systems are accessible. The DOJ replied that this is not a DOJ Issue, but an FCC issue. But by then, IVR systems were really taking off, and it was too late to "add on" accessibility.

The IVR Accessibility Forum (ATIS) has been formed to try to resolve the IVR issues. It includes consumers, industry, and government representatives. Their goal is to design solutions for IVR systems, and they are mostly focused on technical solutions.

Section 255 does require that these systems be accessible, but if the DOJ doesn't require companies to provide accessibility, there is no pressure on manufacturers to make the systems accessible. The DOJ says that you can bypass this requirement by providing an option that allows people to access a live operator, providing direct TTY access line, etc. So the bottom line today is that the IVR systems don't need to be accessible.

Section 508 says that federal agencies must buy and use electronic and information technology that is accessible. This is a broader requirement than Section 255, because it extends to information technology. But that requirement is not being enforced.

Closed Captions and Captioning Quality

Current law requires 50% of all new programming to be captioned. It's hard to tell if that requirement is being met, because people don't watch TV all the time. In 2004, the requirement will jump to 75%, and in 2008, to 100%. The requirement for existing programming ramps up to 75% by 2010, and stays there. We hear more complaints about captioning quality than about the amount of captioning.

Note that live captioning of the news is only required for the stations in large cities. The advantage of live captioning is that the captioning includes everything said on the broadcast, not just the pre-scripted things. Current law will not change this requirement, even in 2008 when 100% of new material must be captioned.

Another captioning issue is emergency access - the requirement that emergency information provided by voice must also be accessible to people with hearing loss. The FCC has issued a ruling requiring access to all emergency programming, but not all stations are complying.

Telecommunications Relay Service (TRS)

A new Relay Order issued on June 17, 2003 raises the priority of TRS in emergency situations. This means that restoration of TRS service is high priority following an emergency.

Title 2 of the ADA requires users of TTYs to have direct 911 access to emergency personnel. This ruling has been in place since 1992. Title 4 rules require that the call be routed to the most appropriate Public Safety Answer Point (PSAP).

Wireless TRS emergency calls have limitations imposed by the cellular network - it's not always possible to locate the wireless phone. Existing law regarding emergency access haven't yet caught up to some of the new technology. This leaves the status of pagers, IM, IP-Relay, and video relay service (VRS) uncertain, undefined, or exempted.

Many people find VRS to be very effective for them. But the cost of broadband service is preventing them from being able to use VRS in their homes.

Another problem with VRS is that many people still don't know about it. When the FCC approved VRS as a reimbursable service in 2000, they asked for input regarding outreach. There has been some outreach by the service providers, but more is needed.

The Department of Housing and Urban Development (HUD) is doing a study on whether people who use relay services have a harder time getting housing than people using a standard phone.

We hear ongoing complaints about people hanging up when we use the relay service. The other common complaint is slow typing by the communications assistants (CAs). The FCC requirement is for 60 words a minute, which is pretty good.

There is currently no requirement for a voice carry over (VCO) option for IP Relay, because it's been granted an exemption. It's pretty common for new services to be granted exemptions to allow providers to get the services up and running. We saw the same thing back in 1990 when the initial relay service was set up.

When using the relay service, you may pick a man or woman to make your call, as long as the requested gender is available. There are fewer male communications assistants (CAs) than female, so you may have trouble getting a man.

Comment: I'd like to clarify the FCC requirements process with respect to new technology. As new technology is developed, the FCC must review it and determine whether it falls within their jurisdiction before they can approve it. Industry is concerned that this process takes a long time and people don't have access during that time.

Comment: We recently heard that the FCC has ruled on the issue of cell phones and hearing aid compatibility (HAC). The new order requires that some wireless phones be HAC within two years and telecoil compatible within three years.

Q: Has there been any progress in increasing the number of states that have Telecommunications Distribution Programs?
A: The number of states with these programs has stayed pretty constant for the past five years. There is no federal requirement for these programs, so it's really a state issue.

Q: Will the current economic problems have any effect on the funding of relay services?
A: There should be very little, if any effect. Each state funds its own intrastate service, and this is generally done by a small fee on everyone's phone bill. It's similar to the funding of phone service for rural customers, which is subsidized by urban consumers. Money for the interstate fund is provided by the interstate carriers, each of whom contributes a certain portion of their revenues to that fund each month. Relay is not a social service, so it's not subject to the cuts that are affecting those services.

Comment: IP Relay is currently only reimbursable for calls within the U.S. I'd really like to see this extended to include international calls. That would really open up international communications.

Comment: We need to be sure that the FCC understands and remains sensitive to our needs. The best way to do that is to continue to communicate with them. So if you have a complaint or a comment or whatever, be sure to let the FCC know. Before about 1996, people had NO access, so there was lots of passion to get access. Today we have pretty good access, so the passion is gone. We need to be careful that we don't lose what we have

Q: Are there standard codes regarding background colors and patterns for VRS interpreters' clothing?
A: There are no national standards right now. But each of the VRS providers has guidelines for this.