Federal Communications Commission FCC 15-143
STATEMENT OF
COMMISSIONER AJIT PAI
Re:   Structure and Practices of the Video Relay Service Program, CG Docket No. 10-51; 
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing 
and Speech Disabilities, CG Docket No. 03-123, Further Notice of Proposed Rulemaking
Twenty-five years ago, President George H.W. Bush signed the Americans with Disabilities Act 
(ADA), which signaled our national commitment to help individuals with a hearing or speech impairment 
benefit from communications services functionally equivalent to those that many people take for granted.
1
  
And with this item, we take another step towards following through on that commitment.
Take the issue of skills-based routing for video relay service (VRS) calls.  More than three years 
ago, organizations such as Telecommunications for the Deaf and Hard of Hearing, the National 
Association of the Deaf, Deaf Seniors of America, and the National Black Deaf Advocates told the FCC 
that “randomly placing VRS [interpreters] with callers . . . falls short of functional equivalence.”
2
  That’s 
because a typical interpreter may not be able to convey unfamiliar words or phrases like “nephrolithiasis” 
and “force majeure.”  Only specialized interpreters trained in medical or legal terminology and familiar 
with the relevant signs can easily relay conversations using these terms to VRS users. 
So when the VRS Reform Order was pending at the Commission two years ago, I proposed a trial 
of skills-based routing.  Unfortunately, I was unable to persuade my colleagues at the time.
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  But thanks to 
the tireless efforts of dedicated advocates like Claude Stout, the Executive Director of 
Telecommunications for the Deaf and Hard of Hearing, we have turned the corner.
For in this Further Notice, we seek comment on opening a skills-based routing trial.  A trial will 
give participating VRS providers the opportunity to route designated calls to specialized relay 
interpreters.  That will allow, for example, interpreters trained in medical terminology to handle calls 
made to hospitals and clinics.  I’ll bet that most VRS users will appreciate that opportunity.  And those 
who aren’t interested need not participate, since the trial will be wholly voluntary.  Moreover, this trial 
will give us the facts we need to assess the costs and benefits of skills-based routing and evaluate whether 
or not it works.
Skills-based routing is not the only quality of service improvement on the table.  We are now 
proposing to strengthen the speed-of-answer requirement for VRS, as recommended by our own 
Disability Advisory Committee.  We are seeking comment on a separate trial on the use of deaf 
interpreters.  And we are structuring these improvements so that moving forward will not require us to 
second-guess the VRS rate framework that was unanimously adopted back in 2013.
I appreciate the willingness of my colleagues to accommodate these improvements to the service.  
And I hope to see soon these long-delayed improvements for the deaf and hard-of-hearing Americans 
who use VRS.  To borrow from former Kansas Senator Bob Dole, one of my personal heroes and the 
prime force behind the ADA, this is one more step toward ending the “exclusion of persons with
disabilities from the mainstream of American life.”
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1
Americans with Disabilities Act, Pub. L. No. 101-336, § 401(a) (1990).
2
Deaf and Hard of Hearing Consumer Advocacy Network et al. Comments, CG Docket Nos. 10-51, 03-123, at 9 
(Mar. 9, 2012).
3
Structure and Practices of the Video Relay Services Program; Telecommunications Relay Services and Speech-to-
Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket Nos. 10-51, 03-123, Report and 
Order and Further Notice of Proposed Rulemaking, 28 FCC Rcd 8618, 8691, para. 180 (2013).
4
Robert Dole, Statement on the Signing of the Americans with Disabilities Act (July 16, 1990), available at
http://doleinstitute.org/about-bob-dole/a-legacy-of-leadership/disabilities/.