IP CTS Providers Disagree on Need for Communications Assistant Mandate Request

Some IP-captioned telephone service (IP CTS) providers welcomed an accessibility coalition's petition asking the FCC to require that all IP CTS providers using automated speech recognition (ASR) as the sole means of transcribing speech also provide users the option of requesting a communications assistant (CA) at the start or any point during an IP CTS call (see 2408010057). The coalition also sought quality metrics for the service and asked that the commission not certify new IP CTS providers until its petition is addressed.

Automated captions "presently cannot meet the communication needs of IP CTS users on all calls under the full range of real-world circumstances," said Ultratec and Captel in joint comments. "While the accuracy of captions generated automatically has improved over the past several years, extensive research shows that this technology continues to have shortcomings that compromise effective communication for users in a host of real-life calling conditions," they said. The companies also backed pausing new certifications for ASR-only providers until a decision is made on the petition.

Sorenson affiliate CaptionCall agreed, saying ASR "does not adequately serve" all IP CTS users and a CA is sometimes necessary for a "more functionally equivalent experience." It asked the FCC to allow flexibility in how providers implement new requirements rather than "mandate a specific technical solution, presentation, or placement." CaptionCall also offered to "determine the necessary technology investments and commercial arrangements required to provide wholesale CA-based captioned services" to other certified providers that lack CAs.

A "failure to preserve CAs is a failure to preserve functional equivalency," said provider Hamilton Relay. CAs are "essential" to handling calls where ASR cannot transcribe particular types of speech, Hamilton said. ASR technology "continues to suffer major difficulties in achieving accuracy" for calls made by IP CTS users, "particularly with calls involving individuals whose dialect, accent or speech patterns diverge from the norms of standard American English." Hamilton also urged the FCC to adopt quality metrics for IP CTS, calling them a "fundamental prerequisite to developing a rational cost methodology and providing compliant IP CTS."

ClearCaptions opposed the petition, calling it an "untimely request" and arguing it "does not demonstrate that customers self-selecting between CA and [ASR] captions is desired by all customers." ClearCaptions warned a "mandated choice in captioning delivery" could confuse users. It asked the FCC to instead open a notice of inquiry to gather more information before determining "if such a feature is in the best interest of IP CTS customers" and the Telecom Relay Service Fund.

Nagish also opposed the accessibility coalition's main request but agreed that the FCC should adopt metrics for IP CTS. The service framework "not only gives choice of providers, but choices of technology that meet or exceed the functionally equivalent mandate," Nagish said, adding that "an increasing number of IP CTS users are showing a preference for ASR-only services." It disagreed with claims that CAs offer more accurate transcriptions than ASR. "CAs can and do make mistakes."