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

December 28, 2011

When there is an opportunity for sign language interpreters and stakeholders to participate in creating the direction of the VRS industry, participation is critical. Brandon Arthur suggests that even more importantly, that participation should be well-informed, well-framed, and professionally presented. 

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. 1051

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.


* Interested in receiving StreetLeverage posts in your inbox? SignUp!

Stay Current

Want to be among the first to know when we publish new content?

Are you an interpreter?

We respect your privacy.
We will never share your info.


Leave a Reply

77 Comments on "FCC VRS Reform Part II – Sign Language Interpreters File Public Comment"

Notify of
Sort by:   newest | oldest | most voted
monica gallego

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


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

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… Read more »

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.

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… Read more »

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.


[…] As you consider filing comment with the FCC, please consider these suggestions. […]


[…] is important that every sign language interpreter file comment with the FCC. In my post, FCC VRS Reform Part II: Sign Language Interpreters File Public Comment, I offered detailed instruction on how to post comment to the FCC.  We need to do this more now […]

Stephanie Robinson

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!

Forward-looking organizations committed to retelling the story of the interpreter.



(New York)