NAD Comments on the Importance of IP Relay

On March 20, 2012, the National Association of the Deaf (NAD) took the lead, and was joined by other consumer groups, in submitting a comment in response to the Federal Communication Commission’s (FCC) Public Notice asking about the importance of IP Relay and possible measures to reduce fraud.

The FCC Public Notice asked about the extent to which IP Relay is currently being used by consumers with or without disabilities, and whether it is meeting a need that is not fulfilled by other forms of relay, or other text-based services. The FCC’s Public Notice questioned whether IP Relay continues to be legitimately used by many deaf and hard of hearing individuals. In our comments, we explained that many deaf and hard of hearing people use IP Relay and gave examples. Many deaf and hard of hearing people who don’t use ASL use IP Relay service as do those who do not have high speed Internet access and as a result are unable to use VRS. Also many people use IP Relay on their mobile phones since our wireless networks generally do not support VRS calls. In fact, we know of several situations where deaf or hard of hearing people were involved in car accidents and IP Relay was the only way for them to reach 911.

The FCC also asked about different ways to reduce fraud and explained that there is a serious problem with people overseas making calls through IP Relay to scam businesses and individuals in the United States. One question asked whether IP Relay Communications Assistants (CAs) should be allowed to screen calls for fraud and even to inform the “other” party that the CA suspects the call is a scam. While we support the FCC in its effort to reduce fraud, the IP Relay system must never be burdensome to the users or compromise their privacy. Allowing a CA discretion to terminate any call or even to let the other party know of suspected fraud, the CA would have more authority over the call than any other company or individual has over ordinary calls made between hearing people.

Our comment stressed that the FCC needs to educate the community about fraud as the better way to combat fraud. The NAD commends the FCC for seeking to combat fraud and urges them to do so without unduly burdening the rights of deaf and hard of hearing individuals to make calls through IP relay.