April 7, 2014 Ms. Marlene Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 RE:
Notice of Ex Parte Meeting Structure and Practice of Video Relay Service Program, GC Docket No. 10-51; Telecommunications Relay Service and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CG No. 03-123
Dear Ms. Dortch: On April 4, 2014, Shane H. Feldman, Executive Director and Julie Anne Schafer, Director of Public Policy and Advocacy from the Registry of Interpreters for the Deaf, Inc. (RID) met with Gregory Hlibok, Chief, Disability Rights Office (DRO), Karen Peltz Strauss, Deputy Bureau Chief, Consumer and Governmental Affairs Bureau, Elaine Gardner, DRO attorney advisor, Roger Holberg, DRO attorney advisor, Eliot Greenwald, DRO attorney advisor, Caitlin Vogus, DRO attorney advisor, David Schmidt, TRS Fund Program Administrator, Office of Managing Director, and Andrew Mulitz, attorney advisor, Office of Managing Director. We discussed how our mission, excellence in interpreting, is one of the most important elements of achieving a functionally equivalent VRS. RID increases 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. RID has a Video Interpreter Member Section (VIMS), which actively involves over 1,200 members working in video interpreting to provide support and expertise related to the video interpreting field. We addressed and clarified our comments related to the reduced speed of answer (SoA) requirements set forth by the Commission. RID recognizes that a reduced SoA will bring the FCC closer to realizing its mandate to achieve a functionally equivalent VRS and supports the efforts of the Commission to address Consumer Groups’ recommendations in this area. However, we are concerned about the potential impact a reduced SoA could have on interpreters’ ability to provide functionally equivalent interpreting services, including the ability to effectively interpret the call, the availability of a qualified pool of interpreters, and the degradation of the consumer experience without the necessary planning and protections. Specifically, RID echoes Consumer Groups’ qualified support of the Collective Providers’ Letter requesting a temporary, one-year waiver of the daily measurement of the speed of answer requirement and associated penalties for noncompliance for VRS providers. Recent research conducted by Kathryn Bower as a part of her Master's thesis project at Gallaudet University found that one of the top five stressors that leads to burnout for video relay interpreters is the rate at which calls come in. Without appropriate time to assess necessary staffing to meet reduced SoA, we are concerned that video interpreters will face increased risk of injury and burn out, thereby shrinking the pool of qualified video 333 Commerce St., Alexandria, VA 22314 ■ 703.838.0030 V ■ 703.838.0459 TTY ■ 703.838.0454 Fax ■ www.rid.org
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interpreters available to work in VRS. We expressed support for the Commission taking a proactive role to measure the rate of turn over in VRS call centers, particularly in regards to increases in turnover subsequent to new or amended regulations. We discussed the Commission’s role in monitoring the quality of interpreting service, noting that functional equivalency depends on both innovative technology and quality interpreting. RID expressed support for the Commission taking a more active role in measuring the quality of interpreting in VRS calls. Specifically, we would strongly support the Commission measuring and publishing reports on the quality of VRS calls. We also discussed the dearth of research being conducted about the work of video interpreters. Traditionally, research and development funds have been allocated for technological research and innovation; however, we urge the Commission to broaden the scope to include research related to the work of video interpreters in VRS. We recognize the importance of research and development around the technological aspects of VRS, however, since the inception of VRS just over a decade ago, research about the work interpreters perform has been scarce. Furthermore, there has been limited research on the mental, physical, and emotional impact working in a VRS call center has on interpreters. In light of new requirements, such as reduced SoA requirements, there is a dire need for research to understand the impact of these regulations on the ability of an interpreter to support a functionally equivalent VRS through the provision of effective communication. We also discussed the impact the professionalism and ethics of an interpreter has on the VRS industry, interpreters, and the Deaf community. We specifically addressed the barriers RID faces in enforcing the Nation Association of the Deaf–RID Code of Professional conduct when grievances are filed against video interpreters. These complaints are not possible to investigate because of alleged rules against disclosing a video interpreter’s identity. We urged the Commission to clarify these rules and hold providers accountable for the unprofessional and unethical conduct of their employees. Respectfully Submitted,
Shane H. Feldman Executive Director CC:
Gregory Hlibok Karen Peltz Strauss Elaine Gardner Roger Holberg Eliot Greenwald Caitlin Vogus David Schmidt Andrew Mulitz
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