National Association of the Deaf

The NAD has learned that a major Video Relay Service (VRS) provider removed all toll-free 800 numbers from the relay service number database to comply with a recent Public Notice issued by the Federal Communications Commission (FCC). As a result of the FCC decision, people who use videophones provided by VRS providers cannot call other people whose 800 numbers/videophones are supported by this major VRS provider.

The NAD opposes the recent FCC notice, which has resulted in a closed system. The NAD was hoping to remove such closed systems with the new 10-digit numbers. The NAD had also requested that the FCC suspend their decision and ensure full interoperability with all 10-digit phone numbers, including 800 numbers. The FCC has not responded, yet.

Background

Last year, the FCC said consumers may keep their old 800 numbers or get new 800 numbers, but all 800 numbers must be associated with local 10-digit numbers. All numbers (800 numbers and associated local 10-digit numbers) were put in the new relay service number database.

On August 11, 2009 the FCC issued a Public Notice saying 800 numbers cannot be put in the relay service number database; instead these numbers would be put in the Service Management System (SMS)/800 database. The NAD, along with other consumer groups opposed the August 11 FCC Public Notice.  Here is part of what the NAD said:

"The [August 11] Public Notice (1) adopts a new restrictive rule without a notice and comment rulemaking proceeding; (2) is inconsistent with principles of VRS interoperability adopted by the Commission and inconsistent with Commission requirements regarding point-to-point videophone calling; and (3) violates principles of functional equivalency. Implementation of the requirements set forth in the Public Notice will result in disruption of service to the severe detriment of those consumers who currently use toll free [800] numbers."

The NAD described what will happen if 800 numbers are not permitted in the relay service number database:

". . . if the two VRS customers utilize different default providers…the call will not go through...”

If 800 numbers are not allowed in the relay service number database, we will end up (again) with a closed system (like the old proxy number system) where VP users can make point-to-point 800 number video calls to the other VP users of the same provider, but cannot make point-to-point 800 number video calls to a VP user of a different provider. We warned the FCC:

"To prevent disruption and harm to consumers who rely upon toll free [800] numbers, the Consumer Groups request Commission action . . . well in advance of the November 12, 2009 deadline for removing toll free numbers from the iTRS number database."

Click here to read the Comments filed by consumer groups.

Summary

The NAD requested an "emergency stay" to suspend the August 11 FCC Public Notice and keep 800 numbers in the relay service number database until these issues are properly addressed.  The NAD continues to advocate for the FCC to suspend the August 11 Public Notice and ensure full 10-digit interoperability for all deaf and hard of hearing consumers.

How to File a Complaint

If you wish to file a complaint or comment about your experience, please use the following FCC form:
https://esupport.fcc.gov/sform2000/formC!input.action?form_page=2000C 

Tips:

• Check the first box “Telecommunications Relay Service (TRS)” on the “Disability Access Complaint” box.
• Enter the company’s name of the 800 number videophone device you are attempting to connect with.
• Enter the type of device with the 800 number you are attempting to connect with.
• In #7, describe how you attempted to connect using a 800 number