Wireless RERC on the Record – Video Relay Services on Public and Enterprise Video Phones

September 2019 – The Wireless RERC submitted reply comments to the FCC’s Further Notice of Proposed Rulemaking Improving Video Relay Service and Direct Video Calling [CG Docket No. s 10-51 and 03-123]. The Wireless RERC supported consumer and provider stakeholders’ opposition to requiring a log-in for users of enterprise and public videophones. As asserted by the Consumer Groups, such a requirement runs counter to functional equivalency as defined by the Section 255 of the Americans with Disabilities Act, the Telecommunications Act of 1996, and the Twenty-First Century Communications and Video Accessibility Act of 2010.  To the Wireless RERC’s knowledge, no person without a disability in the workplace or public places such as a hospital or airport is required to log-in to use a business or public telephone.

Further, as stated by the Consumer Groups, “there are some VRS users whose cognitive abilities may not be sufficient to enter their VRS telephone number on demand, much less a PIN.^[1]”  In support of this assertion, the Wireless RERC noted that approximately 2,835,949 non-institutionalized civilians are living with comorbid hearing and cognitive disabilities.^[2] Cognitive domains impacted could include memory recall and memorizing ability. Also, the Wireless RERC agreed with and supported Convo’s assertion that “The best method to ensure that these public or enterprise devices are not misused remains what is already the current standard industry practice, VIs will disconnect a call when it is clear that the caller does not use or need ASL to telecommunicate.^[3]” Not only does this practice relieve the consumer of burden, but it is also a less costly solution, in time and capital, compared to implementing a password or PIN safeguard. To read the full document, visit: https://ecfsapi.fcc.gov/file/1090478182582/Wireless%20RERC_Reply%20Comments_Improving%20VRS.pdf