HLAA, TDI and Consumer Groups Respond to FCC’s IP CTS Order

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HLAA, TDI and Consumer Groups Respond to FCC’s IP CTS Order

Oct 2 2013

HLAA, TDI, and other consumer organizations filed a Petition for Stay on September 30, 2013. Our Petition requests the Federal Communications Commission (FCC) put a hold on implementation of one section of their Internet Protocol Captioned Telephone Services (IP CTS) Order that requires all users to pay a minimum of $75 for the captioned telephones. See our Petition.

Consumer groups say in our Petition that the FCC has not made adequate provision for low income consumers who need IP CTS, particularly in states that do not have equipment distribution programs. We are concerned that consumers struggling in this economy will find the additional burden of $75 shuts them out of access to telephones. Those of us who depend on captioned phones know how important they can be: to talk to the doctor, get a job or keep a job, keep in contact with family, or get help in an emergency.

Several individuals joined our Petition with written statements about the harm that provision will do in their state. One mom from Michigan, where there is no equipment distribution program, stated that $75 equals a week’s worth of groceries for her family. She is outraged that the FCC would make her choose between access for her son or feeding her family.

In our Petition, we request the FCC wait to implement that section that impacts low income consumers until after comments have been received on their Further Notice of Proposed Rulemaking (FNPRM) and a plan is in place to provide for those consumers.

We do have more concerns with the Order, as we did with the FCC’s Interim Order. Relay services were established under the Americans with Disabilities Act (ADA). As a civil rights law, consumers are entitled to access without having to jump hurdles to establish need: we should simply have to self-identify our hearing loss to receive access to relay services; we should not have to turn on the captions for each call; and we should not have to pay $75 for software apps. All of this together adds up to hurdles the consumer must leap simply to get access to a phone call. See the FCC’s Order

HLAA did file comments with the FCC regarding these issues when the FCC opened up their interim Order for Comments earlier this year http://www.hearingloss.org/content/hlaa-advocates-access-for-captioned-phones. We also plan to respond to the FCC’s Further Notice of Proposed Rulemaking (FNPRM). You can help inform our comments by completing our survey on captioned telephone use.http://www.hearingloss.org/content/take-hlaas-ip-cts-phone-use-survey-today

If you wish to see more comments on the record, or wish to file your own comments, visit the FCC website at http://apps.fcc.gov/ecfs/proceeding/view?z=kojj2&name=13-24. However, be aware that this website will not be available during the federal government shutdown.

If you’d like to file comments, see HLAA’s step-by-step guide to filing short comments. If you need more help, contact advocacy@hearingloss.org after October 14, 2013.