NAD Submits Comments to FCC on Deaf-Blind Telecommunication Access

The NAD submitted comments in response to a Public Notice issued by the Federal Communications Commission (FCC) covering proposed rules regarding the distribution of specialized customer premises equipment (specialized CPE) to people who are deaf-blind. This program is required by the recently enacted Twenty-First Century Communications and Video Accessibility Act of 2010, which the NAD worked hard to pass last fall.

The FCC asked for input concerning the most efficient and effective method to use the $10 million set aside annually from the telecommunications relay service fund for the distribution program, also known as the National Deaf-Blind Equipment Distribution Program (NDBEDP). Specifically, the FCC proposes to begin with an 18-24 month pilot program of the NDBEDP, with interim regulations. In its comments, the NAD discussed several points to help the FCC make certain that the pilot and permanent program ensure that telecommunications service, Internet access service, and advanced communications, including interexchange services and advanced telecommunications and information services, are accessible to low income individuals who are deaf-blind.

The NAD advocated for a more stringent set of guidelines to ensure consistency and high quality services by entities that are selected to participate in the NDBEDP in each state. The NAD also sought more fairness in the income eligibility process to include more deaf-blind individuals who otherwise would not be able to afford telecommunication equipment. Individualized assessment and training and the consideration of changing needs over time in determining how often one can get and/or exchange equipment under the program were emphasized. Finally, the NAD pointed out concerns regarding training individuals to use specialized CPEs, including inaccessible technical support, travel for deaf-blind individuals to the training site, and interpreting services for training. Finally, the NAD demanded that the Commission make sure the program covers the cost of software updates and repair of equipment within their life expectancy.