IP CTS Policy Gets Scrutiny at State, Federal Levels

Friday, FCC commissioners will vote on a draft order to expand the contribution base to include intrastate phone calls (see 1910290041). The period for lobbying on that and other items ended this past Friday.

ITTA supports the FCC draft order, Vice President-Regulatory Affairs Michael Jacobs told us. The document "lays out the case that this will help stabilize the IP-CTS funding base and more properly align the costs." Though "it's of a very limited scope, it's meaningful change," Jacobs said. He noted the FCC took comment on a wider range of issues last year (see 1809180048) and has been addressing them piecemeal.

USTelecom met Tuesday with an aide to Chairman Ajit Pai and in the Consumer and Government Affairs Bureau to support the draft order. The association wants an edit clarifying the agency won't impose new state-level obligations on cost recovery for the program, it said in docket 13-24.

NARUC's resolution seeks a requirement providers show ASR works as well as a human call taker in emergency situations. It says user privacy should be protected just as in a human-assisted call.

State Concerns

State officials have concerns.

They don't know how many minutes of IP CTS are used intra- rather than interstate, said Nathan Gomme, New Mexico Commission for Deaf and Hard of Hearing executive director. He said problems could emerge if states are asked to detail intrastate usage and questions arise over how many funded minutes each state must report or whether intrastate contributions would go into one large national pile of money or be distributed based on state-level contributions. Such questions make the order more complicated than the drafters likely thought it was, he said.

Holly Bise, Colorado relay service administrator, would like more IP CTS and ASR quality metrics in place before the FCC addresses changes to the funding mechanism. Until ASR is 100 percent accurate, incorrect information translated during a 911 call is "literally a matter of life and death," she said. Bise cited miscommunication of a house number's misdirecting emergency services.

In areas where broadband access is limited and mobile signals are spotty, traditional relay services will be needed, Gomme said. He noted the move to ASR largely depends on reliable broadband. He said capabilities may vary on the type of device ASR is delivered over. He questioned whether mobile devices would have machine learning functionalities that would allow ASR to improve over time.

NARUC

NARUC members will deliberate this week. Separately, the FCC may address other NARUC concerns about Lifeline, though not completely, with an action possibly being released this week (see 1911150062).

The FCC has interstate jurisdiction to set standards for ASR in IP CTS to ensure those services convey communications as effectively as human-interpreted calls, and to protect user privacy and prevent identity theft, said Nebraska Public Service Commissioner Tim Schram (R), sponsor of the resolution. "We're all for better technology." But "there just needs to be some safeguards." The existing program has standards, he said. Human call takers are highly skilled at interpreting voices, and Schram worries what will happen if ASR can't transcribe certain dialects. Correct interpretations are especially critical for emergency calls, he said. If the relay service fails during an emergency call, "what's the remedy or recourse?"

Schram hasn't received feedback from industry. Vermont Public Utility Commissioner Sarah Hofmann plans to present the resolution in San Antonio because Schram can't attend, he said.

Telecommunications for the Deaf and Hard of Hearing Inc. and other consumer groups for the hearing impaired shared concerns with NARUC about three companies that have applications before the FCC for ASR, said TDI Executive Director Claude Stout. He said ASR must go through extensive testing before it's ready to be deployed. "We don't know what the error rate is with ASR and how that compares" with the error rates with human-generated captions currently done in IP-CTS.

ASR Coming

Stout couldn't predict how soon ASR will be ready: "It could be a month, or it could be a matter of a few years."

The TDI official acknowledged the technology is better than three or four years ago. Cost should be considered, but quality of care and support should come first, Stout said. TDI and other advocates are open to working with ASR applicants to ensure a smooth transition, first to include ASR in addition to human assistance in IP CTS and eventually to automated only, if the tech is proven, Stout said. TDI has been working with one of the three companies with an application for ASR before the FCC.

MachineGenius applied for OK of a mobile-based IP CTS service using ASR-only two years ago. President Erik Strand hopes it will eventually make the market more cost-effective. Strand said the FCC is probably right to pass its rulemaking to include intrastate contributions, but such funding issues could become less important over time as ASR technologies trim call expenses. Meantime, he said, some might rightfully argue that states can't accurately assess intrastate calls, but providers should contribute more or less equally to the fund.

Strand's company did extensive testing, like simulated 911 calls. Strand said because emergency operators are trained to communicate clearly, ASR should operate at least as well during emergency calls as in other situations. As long as vendors' terms of service don't allow saving and storing the audio used during an IP-CTS call, by definition calls would be more private and secure than those using human calling assistants, the executive said.

"There's a possibility the industry as a whole will never transition to ASR exclusively," Strand said. He predicted ASR for IP-CTS could be widely adopted within about three years.