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:
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.
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:
- Proceeding Number (already entered if you click on the link above, if not enter 10-51)
- Name of Filer (your name if filing personal comments)
- Type of filing (‘Comment’ should already be selected)
- Upload document
- 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.