FCC VRS Reform Part II – Sign Language Interpreters File Public Comment

Sign Language Interpreter Inviting others to join in Filing Comment at the FCC

The charge of emotion sign language interpreters received at the hand of VRS Reform, while important in prompting us to action, can be detrimental if not checked when filing comment with the FCC. Though appreciative of the sign language interpreter who overcame the inertia of apathy and filed this comment with the FCC, I believe their filing would be taken more seriously were they to have checked their emotion and considered what follows prior to submitting comment.

When Filing FCC Comment

First Things First

When filing comment with the FCC, remember you are submitting comment in a public forum. To dispense with formalities is poor form and a demonstration of one’s lack of competency related to public proceedings. Consequently, please be sure to address your comment to:

Ms. Marlene H. Dortch
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

Further, it is important to reference the docket number for which you are filing comment. The FCC and the general public need to be able to quickly reference the matter upon which you are responding. Yes, this should be a given. In this instance the docket number for the Structure and Practices of the Video Relay Service Program is:

CG Docket No. 10-51

Be Specific

When crafting your comment, please be cognizant that the readers of your submission will not have the reference points found in your head (crazy I know). Therefore, be specific in your comments and recommendations. Comment without sufficient context and specificity are of no use to FCC when considering the impact and development of their proposed rule-making.

The No-No

It is critical to remember when filing a comment that to villainize the FCC, VRS providers, your employer or any organizations is inappropriate and frankly misguided. While we may feel justified in doing so due to the negative impact a proposed rule may have on sign language interpreters, it is important that we refrain.

Callout the Benefits

It works to the merit of your comment to specifically point out the public and stakeholder benefits—which includes the FCC—in all recommendations offered. Further, it is important to consider that recommendations must work on a broad scale, which means any recommendation will inherently work to the exclusion of some.

How to File Comment

To file a formal comment via letter, you need to use the ECFS Expert Form.

The following is required:

  1. Proceeding Number (already entered if you click on the link above, if not enter 10-51)
  2. Name of Filer (your name if filing personal comments)
  3. Type of filing (‘Comment’ should already be selected)
  4. Address
  5. Upload document
  6. Review & Confirm your submission

FCC tips on how to file can be found by clicking here.

Will You Join Me?

In most grassroots attempts to persuade a public entity to adopt a certain perspective, people talk a tough game, but fail to support the effort with their time and/or resources. Well, here goes less talk and more walk.

I have drafted a both a comment to file with the FCC and talking points (at the end) that you can freely incorporate into your own FCC filing.  You can find them both here.

I am hopeful that you will join with me in filing comment on this important issue.  Remember, we only have approximately 35 days to get our comments in.

Let’s not let our careers be victimized by our own apathy.



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About the Author

Brandon is a nationally certified sign language interpreter and passionate industry entrepreneur. He has worked on both the practicing and business sides of the industry for the past 15 years. His father is deaf and his mother is a sign language interpreter. He is a devoted father and husband and enjoys the sport of triathlon.

14 Enlightened Replies

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  1. monica gallego says:

    I also want to commend the interpreter for submitting something to the FCC, this really does impact our lives and the future of our profession and we continue to allow others to speak for us. Thanks for breaking down the how-to on addressing the FCC, very helpful as someone who also wants to add her two cents but is intimidated by the language and unfamiliarity in addressing a government organization.
    Mónica Gallego
    BEI Certified
    Austin, Texas

  2. Wing B. says:

    As always very informative. Thanks for addressing the pressing issues of today’s interpreter.

  3. MGD says:

    After I read part I & II, I understand the concerns from both interpreting community and deaf community. FYI: I am profoundly deaf since birth. I still have disappointing issues with VRS industries, RID manipulated educations about deaf culture and FCC’s lack of knowledge about how to measure the ‘quality’ service the deafies desire for. Unfortunately, the level of education among the deaf customers are below the ‘expected’ level to keep up with the ‘arrogant’ attitudes from the politicians. Eventually, the small deaf community is catching up to compete against the group of intelligent, narrow-minded and deeply politically-involved people. Right now, I hope to see the flexibility from each side due to the economic crisis.

    In your quote, ‘In most grassroots attempts to persuade a public entity to adopt a certain perspective, people talk a tough game, but fail to support the effort with their time and/or resources. Well, here goes less talk and more walk.’, absolutely, I agreed with you at that point. Unfortunately, I do not have great references except my objections.

    I hope everything go well in your way, brethren.

    • Thanks for your comment, MGD.

      I agree that each of the stakeholders in the VRS arena would benefit from a more informed perspective. Unfortunately, given the climate and the pace of change, this is particularly challenging.

      I am hopeful that we can rally sufficient support over the next 30 or so days to have an impact.

      Thanks for participating!


  4. Thanks for providing a format for our comments, Brandon. I have my thoughts lined out — they are umemotional, ENTJ kinds of thoughts. However, I was struggling with how to begin. Thanks again for alerting us to the situation and its potential impact on our field.

  5. Katy Lerch says:

    Ditto, Lindsey. This is a growing experience for our profession. We tend to focus our energy on refining interpreting skills rather than developing and refining our own voice. The VRS industry presents new and broader challenges. FCC language, regulations and protocol are foreign to me. On the other hand, I’m not afraid to roll up my sleeves and learn. I believe that a good number of us are that way. We’re fortunate to have members of our profession who have ability, understanding and fortitude to forge a path for us. We have very limited opportunity to dialog effectively in settings that allow us to know the issues beyond our experiences on the VRS floor – and to know how to effectively discuss those issues. We need to create more opportunities together. Your work in these articles provides some much needed guidance. I am preparing a comment as a result of your encouragement. Hopefully it will be effective in supporting the collective voice we raise as a profession supporting this industry. Thanks again for your leadership in opening this door.

    • Katy,

      Thanks for your participation here, Katy.

      I strongly agree with your comment that, “this is a growing experience for our profession.” It is true that as a profession we have been consumed with the plight of skill development and certification, which isn’t a bad thing. Unfortunately, though, the result is that we have much to learn relative to the legal and regulatory side of the interpreting industry.

      I believe most interpreters feel the same way you do, “not afraid to roll up my sleeves and learn.” We simply need, as you stated, more opportunity to dialogue on the issues in order to organize our thoughts and determine how to best address these challenges both as individuals and as a profession.

      If money, location, and time were no object, what would you want to see relative to a process, meetings, information, etc that would assist you remaining current on the issues and understand how to effectively participate?

      I am pleased you feel that StreetLeverage is contributing in some small way.


  6. Thank you Brandon for your well-crafted message. You handled some potentially sensitive points in such a professional way, with a non-judgmental tone. I so appreciate this. We need more folks who can move us forward and upward as we grow into a respected field.

    • You are very kind, Betty. Perhaps, too kind here.

      I believe, as I am sure you do, that there are a large number of super intelligent, super qualified and incredibly articulate folks out there that can lend their perspectives and talents to move the profession forward.

      I am hopeful that they will come forward (and that you might be numbered among them (big grin)) and offer more propulsion than this fledgling little interpreting community blog. :)

      StreetLeverage stands at the ready to assist in amplifying their voices when they come forward.


  7. Stephanie Robinson says:

    Thank you for this informative piece. I have written comment and sought help uploading from their tech support. Written in Word, but when I tried to upload, it said it was an “unsupported file type”. It may be an issue because I have a Mac..? In any case, I will definitely get it posted in time one way or another even if I have to send it in. Thank you Brandon and others (I signed the petition) for taking the lead on this important issue to fight for equal access for all!

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