Interoperability and Functional Equivalency

Interoperability means that any piece of equipment must be able to access other equipment.  Functional equivalence means that any service element must be equal to what hearing people have. This is a FCC mandate. (Link to FCC declaratory ruling 06-57). Paragraph 34 of that ruling defines interoperability and functional equivalency in some detail and I have quoted that below.

The 866 situation we have today is causing a lot of headache and Dr. Z feels bad about it because our deaf and hard of hearing colleagues are very confused.  Sorenson took down their 866 numbers and other deaf and hard of hearing people who do not have Sorenson units cannot call another deaf or hard of hearing people with Sorenson units while deaf and hard of hearing people with Sorenson units can still call other deaf and hard of hearing people with Sorenson units using 866 numbers. Hearing people can call Sorenson units with 866 numbers.  This is second-class treatment by Sorenson again–they are treating hearing people better than deaf people again.

Also, to further the confusion, Sorenson is using 866 numbers as the default basis for generating Caller-ID’s for all outgoing calls. If a non-Sorenson unit receives a call from a Sorenson unit, this non-Sorenson unit gets the 866 number instead of a local number and when it is used to call back, it goes instead to an interpreter because the 866 number is not registered on the national data base. This effectively blocks the non-Sorenson user from calling back to the Sorenson unit. If a local number was passed using a standard and recognizable format instead, there would not be a problem.

Text of paragraph 34 of FCC Declaratory ruling 06-57:

34.   In sum, consistent with functional equivalency, all VRS consumers must be able to place a VRS call through any of the VRS providers’ service, and all VRS providers must be able to receive calls from, and make calls to, any VRS consumer.  Therefore, a provider may not block calls so that VRS equipment cannot be used with other providers’ service.  In addition, a provider may not take other steps that restrict a consumer’s unfettered access to other providers’ service.  This includes the practice of providing degraded service quality to consumers using VRS equipment or service with another provider’s service.  Finally, new providers seeking to offer service have the burden of ensuring that their service is interoperable with existing providers’ service.

Sorenson, by doing some things with 866 numbers, does not meet this definition of interoperability, in my view.  Dr. Z is pleading with Sorenson and the FCC to reread this in light of the current situation. Comprende?

Dr. Z cares about your communication access.