It is obvious that VoIP will become a major player in the way we communicate in the future. IBM already made a public announcement that they will be using VoIP for all company communication. And with less expensive offerings such as that from Vonage of 500 minutes of local and long distance for $14.99, which includes caller id, call waiting, call forwarding, voice mail, call transferring, and many other useful services, there is no doubt that many consumers will be adopting VoIP services.
Accessibility:
SHHH’s main concern is that people with hearing loss and other disabilities not get forgotten as VoIP is shaped for the future. People with hearing loss still don’t have full access and functional equivalence to the wireline and wireless networks. Now the sand is shifting under our feet once again. The telecommunications environment is so fluid that it is hard to keep pace and especially in the area of accessibility for people with disabilities. Innovation is geared to profit and not to the public good.
VoIP is complex and SHHH is not prepared in these comments to get into the details of what it should look like. Our main aim here is to urge all who are involved in the development of VoIP, and particularly the FCC, to be sure to take into consideration how people with disabilities are going to use it. SHHH is concerned that of all the comments submitted to this electronic forum only one mentions access for people with disabilities and that was a brief reference to using TTYs.
Currently VoIP services are not regulated and not required to be accessible to people with disabilities, though they would probably fall under the Section 508 regulations should the Federal government start to use VoIP. For people with hearing loss, VoIP has the potential to provide excellent communication access with the simultaneous voice and data, with or without automatic speech recognition. But unless innovation takes this into consideration and developers build in access, we will be forced to try to make existing TTY, relay services, fit with VoIP and in the long run that might not be the best or most cost effective solution.
Further, SHHH agrees with the Association of Public-Safety Communications Officials International, Inc. in their conclusion that the FCC can and must require VoIP services to provide full access to 9-1-1. Access to 9-1-1 will be an issue for people with disabilities as much, if not more so, than for everyone else.
Funding:
Some commenters to the VoIP Forum stated that if subscribing to a VoIP service, it makes sense for that service to be regulated just like any other phone service. VoIP may not be regulated and therefore may not contribute to Universal or relay service funds. In this case, an overhaul of how universal service is funded should be conducted and at the same time review disability needs and how to ensure that people with disabilities get the telecommunications equipment and services that they need.
SHHH Recommendations:
SHHH strongly recommends that the FCC convene a Forum to focus on disability access to VoIP both in terms of accessibility and funding, and/or how to forge accessible telecommunications in the future.
SHHH urges that there be representation from the disability community on Chairman Powell’s Internet Policy Working Group.
Thank you for the opportunity to comment
Brenda Battat
Director of Public Policy and State Development
SHHH
December 15, 2003
* Self Help for Hard of Hearing People, SHHH, is the nation’s foremost consumer organization representing people with hearing loss. SHHH’s national support network includes an office in the Washington D.C. area, 13 state organizations, and 250 local chapters. The SHHH mission is to open the world of communication to people with hearing loss through information, education, advocacy, and support. SHHH provides cutting edge information to consumers, professionals and family members through their website, hearingloss.org, their award -winning publication, Hearing Loss, and hearing accessible national and regional conventions. SHHH impacts accessibility, public policy, research, public awareness, and service delivery related to hearing loss on a national and global level.