February 1, 2014
via electronic filing
E. Elaine Gardner
Attorney Advisor
Disability Rights Office
Federal Communications Commission
Washington, DC 20554
Re: Feedback on FCCC Stakeholder Meeting for iTRS National Outreach Program
CG Docket No. 10-51
Dear Ms. Gardner:
On January 17, 2014, the FCC held a stakeholders’ meeting for establishing an Internet-based Telecommunications Relay Service National Outreach Program (iTRS-NOP) for video relay service (VRS) and Internet protocol relay service (IP Relay). After reviewing the content of the meeting, the Registry of Interpreters for the Deaf, Inc. (RID) submits these comments for your consideration.
RID, a national membership organization, plays a leading role in advocating for excellence in the delivery of interpretation and transliteration services among diverse users of signed and spoken languages. In collaboration with the Deaf community, RID supports our members and encourages the growth of the profession. Our Video Interpreter Member Section (VIMS) actively involves its more than 1,200 members working in video interpreting to provide support and expertise related to the video interpreting field. RID strongly believes that our mission, excellence in interpreting, makes a functionally equivalent VRS achievable by increasing the pool of qualified interpreters available to work in the field through the establishment of a national standard for qualified sign language interpreters and transliterators, ongoing professional development, and adherence to the NAD-RID Code of Professional Conduct.
The iTRS National Outreach Program is an essential component of VRS reform. It is clear from the dialogue at the meeting that there is a critical need to educate the general public about relay to reduce the number of hang-ups and enhance functional equivalence. One of the ideas suggested at the meeting was to establish a hotline for complaints. RID fully supports taking necessary measures, including creating a complaint hotline, to enhance the consumer experience in VRS. Mike Maddix of Sorenson suggested that one way to make the hotline work is to “have the interpreter who attempted to relay the call make the consumer aware of the hotline in case they want to report it.” (Page 18 of the unofficial transcript.) While we support this idea in theory, we are concerned about the impact this may have on the quality of interpreting services in VRS.
From complying with increased speed of answer (SOA) requirements to assessing whether the person placing the call is a sign language user, interpreters are at the front lines of providing a functionally equivalent VRS. Assigning the additional task of explaining the hotline and complaint process may add to the mental and physical burdens already placed on interpreters and could adversely impact the interpreting services in VRS calls. We must determine the impact on functional equivalence and the quality of interpreting services when the interpreter steps out of their role to provide customer support services. As the burden of meeting SOA requirements falls on VRS interpreters, how will this new responsibility impact SOA? What will be the extent of the interpreters’ responsibility in explaining the complaint process? How much time will the interpreter need to spend on explaining the complaint process? What are other potential issues that may arise in this new scenario? Adding this customer service component to the job function of the video interpreter has ramifications that need to be assessed before implementation. Some VRS interpreters are monitored, incentivized, and punished based on the time they spend connected to one user, so the time they are with a customer but are not “billing” any reimbursable time impacts their performance evaluation. The interpreter then balances two cultures of American productivity versus the need to bridge a cultural gap with the Deaf community. A model where the interpreter is the conduit between the consumer and the complaint hotline exacerbates these challenges and could potentially undermine the iTRS outreach program.
If the Commission decides to pursue this model further, it is imperative to involve RID and the interpreter perspective so that any impact on the quality of interpreting services in VRS is considered prior implementing job requirements beyond interpreting the call. After all, as the Commission continues to remove responsibilities from VRS providers (e.g. outreach and research and development), interpreter quality will become the distinguishing characteristic among VRS providers.
It is our goal to support a functionally equivalent VRS by ensuring that interpreters are able to support the equal participation of both parties in VRS calls. While in theory the interpreter is a transparent conduit, the Commission must recognize interpreting as the core service provided to VRS consumers and be aware of the impact its regulations have on an interpreter’s ability to provide functionally equivalent service. RID looks forward to working with the Commission on the iTRS National Outreach Program to support a functionally equivalent VRS.
Sincerely,
Shane H. Feldman
Executive Director