American Association of the Deaf-Blind
8630 Fenton Street, Suite 121
Silver Spring, Maryland 20910-3803

June 10, 2008

Dear Chairman Martin:

On behalf of the American Association of the Deaf-Blind (“AADB”), I am writing to respectfully request that the Commission promptly convene a solutions summit consisting of all interested stakeholders to determine the best communications relay solutions for deaf-blind individuals, as AADB suggested in our response to the petition for clarification filed by Hawk Relay in this proceeding. Even more than 17 years after the Americans with Disabilities Act of 1990 became law, AADB regularly fields complaints from deaf-blind individuals who still do not have access to suitable VRS or TRS. This lack of access severely limits their methods of communicating with others and negatively affects their general quality of life, as compared to fully sighted and hearing individuals. Expedited action by the Commission is therefore necessary to determine and promote solutions for providing these critical services to the deaf-blind community.

The goal of this summit should be to discuss and identify ways to enable deaf-blind individuals to have functionally equivalent telephone services as mandated by Title IV of the Americans with Disabilities Act of 1990. As the Commission is aware, the deaf-blind community is extremely diverse -- some deaf-blind individuals were born hearing and sighted and became deaf-blind later in life, some were born deaf and became blind later, others were born blind and became deaf later, and of course, some were born fully deaf-blind. The fully deaf-blind segment of the deaf-blind community lack access to communications services that are suitable to their particular needs and, therefore, the Commission should be especially cognizant of their needs and take great care to promptly make certain that functionally equivalent telephone services are available to this segment of the deaf-blind community. Indeed, lack of suitable access to communications systems disadvantages fully deaf-blind individuals.

At a minimum, the summit should assess: (1) the need and demand for deaf-blind relay services, (2) existing and potential methods of providing such services, and (3) the feasibility of such services. Participants should include members of the deaf-blind community; TRS industry representatives, including Hawk Relay; AADB and other consumer advocacy organizations; and FCC staff.

To date, deaf and hard of hearing individuals have enjoyed access to the public switched telephone network using traditional TRS, Internet-based TRS, and VRS. These services have empowered a large percentage of the deaf and hard of hearing community. Unfortunately, none of these services are practical to those individuals who are fully deaf and blind. If a deaf-blind individual understands sign language (ASL/PSE/MCE), then they can communicate with other people using a tactile form of ASL. There, the deaf-blind individual signs normally, but when he or she wants to receive a communication, the deaf-blind individual holds the hands of the signer. Many deaf-blind individuals also do not have the skills or knowledge to call people by using computers, screen readers, note takers or other devices. Instead, they tend to rely on family and friends to assist them in using communications services, which oftentimes puts the deaf-blind individual in the awkward position of constantly needing to rely on a family member or friend, and it also impedes on a deaf-blind individual’s personal privacy in communications.

The AADB therefore supports the use of Communication Facilitators (“CFs”) to assist deaf-blind individuals access to communications systems. CFs, who are physically present with the deaf-blind user, will act as the go-between for the deaf-blind person and the person they are conversing with on the telephone. The summit should address the most efficient use of CFs. For instance, CFs may be housed at various regional centers across the nation, or could be dispatched to the deaf-blind individual’s location, whether that is the individual’s office, home, or other place. Even those with close vision or tunnel vision will benefit from having a CF to assist them with communications.

The deaf-blind community wants and needs access to communications systems so that they can manage their own lives on par with fully sighted and hearing individuals. When deaf-blind individuals are given the option to have exact and clear communication in any environment, it allows them to embrace an active lifestyle. Given the commitment of resources and effort needed to provide functionally equivalent telephone service for deaf-blind individuals, a collaborative, cooperative approach will be the most effective way to achieve the goals that both the Commission and deaf-blind individuals share. Thus, the Commission should promptly convene a deaf-blind solutions summit. The AADB is willing to assist the Commission in any way to facilitate this summit.

See Comments of the American Association of the Deaf-Blind, CG Docket No. 03-123, at 6 (filed Feb. 4, 2008).

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