NAD Submits Comments to FCC on Advanced Communications

On November 22, 2010, the NAD, along with other consumer organizations, submitted comments in response to a Public Notice issued by the Federal Communications Commission (FCC) asking questions about "advanced communications." The Twenty-first Century Communications and Video Accessibility Act of 2010 (Accessibility Act), recently passed by Congress, requires accessible advanced communications. This is a summary of the NAD comments.

The new law defines advanced communications as Voice over Internet Protocol (VoIP), electronic messaging, and interoperable video conferencing services.  "Interoperable video conferencing service" is further defined to mean real-time video communications, including audio, to enable users to share information of the user's choosing.

Video Conferencing
Deaf and hard of hearing people must be able to access a video conferencing service directly and through a video relay service (VRS).  The video conferencing service must enable the individual to see and be seen by all video conference call participants. In addition, the individual must be able to connect to and use VRS (to see and be seen by the VRS communications assistant, and for the VRS communications assistant to hear and be heard by the video conference call participants) to participate equally in the video conference call.  Split screen or multi-user video conferencing technology should be used so the individual can see both the participant(s) and the VRS communications assistant at the same time.

Video conferencing capability is not only beneficial to individuals who rely on VRS, but for millions of deaf and hard of hearing people who benefit from visual communication cues such as speech reading, facial expressions, body language, and gestures.

The North American Numbering Plan (“NANP”) 10-digit telephone number system must be adopted and/or adapted by other video conferencing equipment and service providers to make their systems interoperable with other systems and users, including VRS users. 

In addition, video conferencing equipment and services:

• must include market devices and software, as well as specialized devices (videophones) and software used by deaf or hard of hearing people;
• must enable the delivery of two-way voice communications;
• must enable the delivery of voice communications in an accessible format, through the display of real-time captioning; and
• captions, when provided, must be compatible with other technologies that convert text to Braille for access by deaf-blind people.

Hearing Aid Compatibility
Equipment with handsets (speakers typically held to the ear) that are used to access VoIP or video conferencing services must be compatible with hearing aids and cochlear implants.  This “hearing aid compatibility” must be built-in to the equipment.

Performance Objectives
Performance objectives related to accessibility, usability, and compatibility of advanced communications should be general enough to permit flexibility and innovation, but specific enough to achieve the desired outcomes. [2]

Click here to read the full comments submitted by the NAD.

Tell the FCC – Make Advanced Communications Accessible to Everyone

Deadline for comments is Tuesday, December 7, 2010

Click here [3] to submit your comments to the FCC.  Type 10-213 in the box marked “Proceeding Number.”  Type your name, contact information, and comments in the other boxes provided.  When complete, click on “Continue” to send your comment to the FCC.

Sample Comment:

I support the comments submitted by the National Association of the Deaf and other consumer groups.  Advanced communications must be made accessible to and useable by everyone, including deaf, hard of hearing, late-deafened, or deaf-blind people.

Video conferencing capability benefits people who rely on VRS.  Video conferencing also provides deaf and hard of hearing people with visual communication cues such as speech reading, facial expressions, body language, and gestures.

Video conferencing equipment and service providers must make their systems interoperable with other systems and users, including VRS users.

Video conferencing systems must also be capable of delivering captions and those captions must be compatible with other technologies that convert text to Braille for access by deaf-blind people.