Consumer Groups and Industry Support FCC's Draft Item on TRS
Telecommunications relay service (TRS) companies and consumer groups are mainly supportive of the FCC’s TRS NPRM, and industry attorneys told us it's expected to receive unanimous approval at the agency’s Nov. 20 open meeting. However, consumer groups told us that any rulemaking stemming from the proceeding needs to take legacy users of analog TRS into account.
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“By and large, the FCC is asking the right questions, and we look forward to commenting on them,” emailed Christian Vogler, director of Gallaudet University’s Technology Access Program. “At the same time, we can't lose sight of the fact that, for all the improvements in accessibility that IP-based TRS services allow, and notwithstanding the hard work of many players in this arena, there are people who are at risk of being left behind in the transition.”
The draft NPRM focuses on updating the TRS rules to transition away from analog services that use legacy copper lines to IP-based services. The three forms of analog TRS currently supported in the rules are seeing declining use, while internet-based forms of TRS “continue to advance” and incorporate accessible communications functions, said an FCC fact sheet.
The draft item seeks comment on transitioning analog users to internet-based TRS services and terminating the mandatory status of the analog TTY relay for state-based programs. It also proposes recognizing IP speech-to-speech “as a compensable form of TRS” and applying minimum standards and other requirements to IP speech-to-speech. The item seeks input on deleting outdated TRS rules as well.
Companies in the TRS sphere are supportive of the draft item because analog TRS users are dwindling, and the telecom industry is itself moving away from legacy copper lines, an industry attorney told us.
Consumer and trade groups have also called out the decreasing number of analog users. A white paper published last year and authored in part by TDIforAccess and the National Association for State Relay Administrations pointed to the minutes for analog-based relay services billed to state-governed relay programs as evidence of the decline in legacy users. The paper said federal and state governments can play a big role in the transition of legacy TTY and captioned telephone service relay users to IP-based relay offerings by providing information and resources to those legacy relay users.
In a joint filing last week in docket 03-123, Communication Service for the Deaf, Deaf Equality and TDIforAccess applauded the FCC for “being proactive and exploring solutions now, while these networks are winding down, so it can be forward thinking about TRS issues to have a successful transition.”
Concerns About Legacy Users
Several consumer groups said the draft item should do more to focus on the fate of legacy users. Hearing Loss Association of America Executive Director Barbara Kelley told us that while there are many users of IP-based captioning services, others still use legacy analog TRS. There’s concern that at least some of those people might not be able to shift to an IP-based relay solution, she said, such as those who are in rural areas lacking good internet connectivity or who aren't good at tech adoption. Any FCC proceeding has to ask the right questions about who could be left out in an IP transition, she argued.
Before the FCC determines whether to phase out requirements for TTY-based TRS, it should collect data on the number of people still dependent on TTYs, said the filing from Communication Service for the Deaf, Deaf Equality and TDIforAccess. That data should include the extent to which TTY users live in rural communities without reliable high-speed internet service, depend on subsidized landlines or are unable to afford broadband. If TTY-based TRS is sunset, the FCC should also look at how TTY users who lack broadband can access 911, they said.
Vogler also cited accessibility issues, saying that “broadband availability and affordability, especially among people with disabilities, are going to remain significant concerns as we move forward.”
Some TRS companies have asked for changes to the draft NPRM. TTY service provider NexTalk Software said the notion in the draft that TTY is outdated and its use is down greatly might not take into account TTY usage from providers that aren’t state-funded. Real-time text (RTT) might also not be as widely deployed as the draft NPRM suggests, it said, urging the FCC to seek comment on the status of RTT, a realistic transition period for replacing TTY with RTT and ways to advance RTT testing and deployment.
IP captioned telephone service remains a vital service for at least 7 million Americans, and the NPRM needs to ask more questions about automatic speech recognition (ASR) functionalities on smart devices as an alternative, ClearCaptions told the offices of FCC Chairman Brendan Carr and Commissioner Anna Gomez. The provider urged the agency to add questions about monitoring ASR performance, uptime of the ASR functionality and minimum standards associated with consumers’ use of native ASR on smart devices.
In a meeting last week with Carr’s office, Sorenson Communications executives recommended that the draft NPRM seek comment on the necessity of the requirement that video relay service providers handle at least 20% of their minutes in a given month through physical call centers.