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Summary of AADB’s Letter to the FCC on Hawk Relay’s Petition for Deaf–Blind Services

On February 4th, American Association of the Deaf’Blind filed comments with the Federal Communications Commission (FCC) on Hawk Relay’s petition for deaf–blind relay services. AADB’s comments were prepared with the assistance of Brett Ferenchak and Nguyen Vu, from the law firm of Bingham McCutchen. We appreciate working closely with Telecommunications for the Deaf and Hard of Hearing, Inc’s (TDI) in developing the comments. Besides TDI, National Association of the Deaf (NAD), Hearing Loss of America Association (HLAA), Deaf and Hard of Hearing Consumer Advocacy Network (DHHCAN), Association of Late-Deafened Adults (ALDA), and California Coalition of Agencies Serving the Deaf and Hard of Hearing, Inc. signed on their support.

AADB appreciates the initiative from Hawk Relay for a separate deaf-blind relay service program. However, AADB raised several key points:

  • There are some deaf-blind individuals who can use their limited vision/hearing to access today's relay services, like Video Relay Services, Internet Relay, traditional TTY-to-voice, Voice Carry Over, and Hearing Carry Over. Relay service providers can and should make adjustments to make their services accessible.
  • There is a segment of the deaf-blind population that cannot access any of today's relay services, and they will benefit from having Communication Facilitators come to their residence, work, or another place to make/receive relay calls. They are the ones that use tactile interpreting or close-up interpreting.
  • AADB expects all providers to be accessible and provide as many options as possible for deaf-blind American to access their relay services at all times. This is the same as what is available for the deaf community
  • AADB recommends that the Interstate Telecommunications Relay Service (TRS) Fund cover the cost of providing relay services for deaf-blind Americans. To require every state to provide this service could raise several important issues:
    • states tend to pick one provider, and deaf-blind Americans deserve every right to make a choice between providers,
    • some states may not be financially equipped to provide this program
    • several states that have a large number of deaf-blind residents may find costs feasible to run the program whereas other states that have low numbers would find running such a program becomes cost-prohibitive
  • AADB strongly recommends that the FCC invite a number of stakeholders to participate in its summit to address all key facets of a deaf-blind relay service. AADB contends that there are many issues to resolve, before the FCC can consider mandating this service, and authorizing reimbursement of costs from the Interstate TRS Fund.

If you would like to read the letter in its entirety, go to the FCC's website at: http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6519839414

You can also view the letter on AADB's website at: dbrs_comment.html