# Presentation: 636358

## FCC VoIP Solutions SummitPotential Barriers of IP-Enabled ServicesAffecting People who are Deaf, Late-Deafened, or Deaf-Blind 

- Friday, May 7, 2004
- Claude L. Stout, Executive Director
- Telecommunications for the Deaf, Inc.

## Functional Equivalency

- IP-enabled services such as VRS bring us near-functional equivalency of voice calls
- Traditional TRS is based on old technology
- VRS calls are seamless and quicker
- VRS calls convey nonverbal information
- VRS should be the new standard

**Notes:**
IP-enabled services can bring us closer to functional equivalency such as Video Relay Service but the FCC says it is an added-on value service, and uses traditional TRS as the standard for functional equivalency.  
We respectfully disagree as both VRS users and the hearing community at large find VRS calls to be seamless, and normal like regular voice calls with the ability to convey nonverbal information.  
VRS should be the new standard of functional equivalency

## Policy Issues

- “255” access regulations needed even if no other regulations are used
- Broadband policy needs to account for video telephony
- Local and Interstate TRS funding mechanisms needs to be revamped to collect VoIP revenue
- VoIP does not recognize boundaries

**Notes:**
While we understand there is a critical need to let IP-enabled services take off as unregulated and untaxed, “255” access regulations should be initiated from the start for IP-enabled applications, to ensure individuals with disabilities, especially those who are deaf or hard of hearing enjoy new products and services like the rest of the community.  
Broadband policy needs to account for the enormous bandwidth requirements for video telephony that is essential for visual communications.  
The local and interstate funding mechanisms to support TRS services is in peril because funds are collected on a per-line basis in many states.
VoIP does not recognize geopolitical boundaries.

## Market Economics

- Deaf & Hard of Hearing people in all economic brackets
- Access features in all, not just high-end products and services
- We should not be stuck with old pre-IP products and services
- Access to technology means freedom for people with disabilities

**Notes:**
Deaf and hard of hearing people are found in every economic bracket.  
Access features should not be locked into “high-end” products or service plans.  
We should not pay more because we have to use old products and services, pre-IP enabled, while others pay less to use new IP-enabled products and services. 
Access to technology means freedom for people with disabilities.

## R & D Collaboration

- Our needs must be considered as part of initial research and development, not an “afterthought”
- Most companies have not contacted us consumer organizations for
- Needs assessment
- Design and development
- Marketing activities
- We can test new products and services, and help implement new ideas

**Notes:**
We ask that our needs be considered as an integral part of research and development, not as an “afterthought.”  
Most companies that engage in research and development for IP-enabled applications have not contacted us national consumer advocacy groups for needs assessment, design and development, as well as marketing participation.  
We want to be involved, as representatives of our constituency groups to identify our needs as well as to make some suggestions for new products and services.

## Feature Options

- Wide range of hearing loss and vision loss
- IP Services not limited to TTY or text
- Additional capabilities possible
- Enhanced audio and text
- Video and tactile features
- Need ability to change text display
- Type of fonts
- Font color and size
- Background color and opacity
- Peripheral devices such as Braille readers

**Notes:**
Deaf and hard of hearing people have different degrees of hearing loss, varying levels of vision loss, thus our needs vary according to how we use our hearing and vision every day.  
IP-enabled services need not be limited to having TTY or text capabilities.  We seek to have additional capabilities, such as enhanced audio and text, video, and/or tactile features. 
Also need the ability to change color, fonts, font size, background, peripheral devices such as Braille readers, etc.

## VoIP Integrity Issues

- Data is broken into packets and sent over Internet – is it always intact?
- Consumers agree to 1% error rate
- Incomplete information can be fatal
- Security concerns must be addressed
- Scams and fraudulent use
- Firewalls hinder the use of accessible technology

**Notes:**
While we look forward to participating on VoIP, we remain anxious as to what the character error rate will be as data is broken up and transmitted via packets over the Internet back and forth between both parties.  National consumer organizations of, for, and by the deaf and the hard of hearing have already made clear to the industry that we do not tolerate a character error rate greater than one percent.  Incomplete information as a result of dropped packets can lead to fatal results in emergency calls.  Security concerns must be addressed.  IP-Relay is suffering because of overseas fraud.  VRS users suffer on the job because of security barriers in the workplace such as firewalls

## 9-1-1 Technologies

- Public Safety responders must adapt to new technologies
- ADA only covers TTY and VCO calls
- Relay calls cause delays
- E-mail, pagers, instant messaging, relay and video not supported
- Location identifiers inadequate for IP technologies

**Notes:**
911 and public safety responders need to migrate to new technologies in order to process calls with individuals who are deaf and hard of hearing.  Current technologies other than TTY and VCO are not covered by the ADA regulations for emergency call-handling such as IM, email, paging, and relay services.