Filed a Paperwork Reduction Act comment with the United States Office of Management and Budget on the transition from TTY to real-time text

A comment on OMB Control Number 3060-1248, the information collection behind the FCC's TTY to real-time text transition and its 911 consumer notices, in CG Docket No. 16-145 and GN Docket No. 15-178. It supports approval and asks for no new report and no new filing from any provider. It makes four asks of the supporting statement rather than of respondents. The statement records that no party has sought a TTY waiver since the last approval, yet assigns the 911 customer-notice burden to all 608 wireless providers, and 37,696 of the 70,528 annual hours to a notice limb whose respondents the same statement says do not exist; both cannot describe the same population. Its accessible-format guidance names Braille and captioned, audio-described ASL video, but its estimates disaggregate not one hour for producing them. The required notice lists text-based alternatives to 911 without naming real-time text, the technology the proceeding exists to introduce. And machine-readable electronic text, compatible with screen readers and refreshable braille displays, is not among the named accessible formats, which leaves DeafBlind consumers without a route. International Deaf Emergency offered to develop a model consumer notice and accessible-format package at no cost, which any provider including a small one could adopt as it stands.

• Read the comment as submitted (PDF)
• The information collection on the federal register of regulatory review (ICR reference 202608-3060-009)