STATEMENT OF
COMMISSIONER JESSICA ROSENWORCEL
CONCURRING

Re:	Misuse of Internet Protocol (IP) Captioned Telephone Service, CG Docket No. 13-24; Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123

	Under the Americans with Disabilities Act, functional equivalency has been at the heart of our telecommunications relay service policies.  Functional equivalency may sound like the kind of regulatory lingo that only a lawyer could love.  But for millions of Americans with hearing and speech impairments it means they have the right and ability to pick up the phone, reach out and connect, and participate more fully in the world.

	In the United States, the ranks of the hard-of-hearing are growing.  This country’s Baby Boomers began to reach 65 in 2011.  As a result, the total estimate of those with hearing loss nationwide is now nearly 50 million.

	For those Americans with hearing difficulties, the FCC’s Internet Protocol Captioned Telephone Service (IP CTS) can make a big difference.  It allows those with some residual hearing to use their own voice to speak during a call but then read captions on their device when the called party responds.  This means that people with hearing loss can do the things that so many of us take for granted—picking up the phone and seeking emergency help; securing a job; making a doctor’s appointment; following up with a child’s teacher; and connecting with family and friends.

	But the IP CTS program is under stress.  It is growing fast and needs attention.  It needs a smart pathway forward.  

	For these reasons, this rulemaking is timely.  But the approach here is backwards.  It puts the cart before the horse by introducing automatic speech recognition into the IP CTS program before we address our most basic regulatory responsibilities.  

I believe it makes sense to include automatic speech recognition in our framework under the Americans with Disabilities Act.  Technology has advanced and it may be possible for automated systems to substitute for traditional IP CTS, which requires human intervention through communications assistants.  This is exciting.  It may yield an experience for users that is comparable to older forms of IP CTS and delivers true functional equivalency under the law.  But inexplicably, the FCC authorizes automatic speech recognition today but puts off for the future figuring out at what rate providers will be compensated and what service quality standards hard-of-hearing users can expect.  Can we acknowledge that if functional equivalency is our mandate, we should be doing these things right here and now at the same time that we authorize the service? 

While I support the outcome here, I believe our analysis comes up short.  I concur.