The FCC should define “functional equivalency” so the deaf and...

a coalition of deaf and hard-of-hearing advocates told the FCC. In the group is Telecommunications for the Deaf and Hard of Hearing, National Association of the Deaf, Association of Late-Deafened Adults, Hearing Loss Association of America, California Coalition of Agencies Serving the Deaf and Hard of Hearing, American Association of the Deaf-Blind, Speech Communication Assistance by Telephone, Communication Service for the Deaf, and Deaf Seniors of America. They laid out a 10-point platform, met with FCC staff and posted their comments in an ex parte notice in docket 10-51. The groups said telecommunications relay service (TRS) vendors “must provide full benefit to all parties on a call, regardless of the complexity and/or cost,” provide an experience that is “at the minimum … equivalent” to the experience of hearing people and use “mainstream products and services” that are “high quality.” TRS vendors also should provide equipment and services that are “accessible and address the diverse needs of” the deaf and hard of hearing, provide interoperable communications, “be motivated to bring products to market that keep up with mainstream technological advancements,” give a “wide selection of choices” for software and hardware, and allow for emergency calls that “fully satisfy the safety and security needs of” users. Customers should get “prompt, comprehensive customer care” and provider should commit “to uphold the integrity of the TRS Fund,” the groups said.