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The FCC has asked for public comment on a proposal to reduce the rate provided for VRS for 2009 – 2010; unfortunately if the FCC reneges on its promise to provide a fair, stable and predictable rate, VRS will be hurt. Based on the promise of a three-year rate, investments have been made that have improved VRS – more and better interpreters, new technology, local numbers, 911 emergency service, and more. Now the FCC is threatening to cut the third year of the rate, which will inevitably force VRS providers to cut back on VRS.
If the FCC reneges on its promise to provide a fair, stable and predictable rate for three years, it could have a devastating effect of VRS. Improvements in VRS have come about because of investments made on the promise of a three year rate plan. If the rate is cut now, providers will be extremely reluctant to invest in improvements to VRS, and VRS will suffer, with fewer Deaf having access to VRS and fewer improvements to VRS.
If the FCC cuts the rate drastically, providers will have no choice but to reduce the number of interpreters, lengthening hold times, cut back on installers, and stop investing in research and development. These cutbacks will result in VRS service that is not as good as the service that is available today, which would be a tragedy. A drastic cut in the rate could also put some providers out of business, again reducing options for the Deaf. Outreach efforts to provide access to VRS to more Deaf people would be undercut. Development of new and better videophones would be undercut.
The FCC should not renege on its promise to provide a fair, stable and predictable rate for three years. Instead of threatening to hurt VRS, the FCC should be looking for ways to improve VRS. President Obama has announced that broadband for vulnerable populations is a national priority; the FCC should be doing the same, not threatening to cut back on VRS.
This email includes FCC email addresses and sample email text you can use.
You can write your own message or just copy and paste the text below —insert your own name:
RE: CG Docket No. 03-123
Federal Communications Commission (FCC)
445 Twelfth Street SW
Washington, DC 20554
Dear Chairman Genachowski, Commissioners Copps, McDowell, Baker and Clyburn:
Video Relay Service has improved greatly because the FCC initiated a stable, predictable and fair three-year rate plan fifteen months ago. We understand that the FCC is inexplicably considering abruptly changing the VRS rate for the 2009 – 2010 rate year.
The FCC adopted the three-year rate methodology after 16 months of deliberation and considering thousands of pages of comments. Now, the FCC is proposing to change the rate with just weeks for public comment.
VRS is succeeding – it is available to more in the Deaf community, service quality has improved, hold times have dropped, interpreter training and recruitment have expanded, and new videophones have been developed. The stable, fair and predictable three-year rate plan is critical to improving VRS and moving towards functionally equivalent telecommunications for the Deaf. The Deaf still do not have the functional equivalence mandated by the Americans with Disabilities Act, but every improvement in VRS moves the Deaf closer to the fulfillment of that mandate. Why would the FCC suddenly, with virtually no notice, and only weeks for comment, undermine what has been working?
President Obama has correctly emphasized the importance of making broadband available to vulnerable populations like the Deaf community. Is it possible that the FCC at the same time, in defiance of the President’s leadership on this issue, will undercut this vital broadband-based service to the Deaf?
I strongly urge the FCC to focus on how to improve VRS, not destroy it. It is simply not right to crush progress towards functional equivalence and tell Deaf people they deserve only second class telecommunications.
[Insert Your Name Here]
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