Regulatory Commission of Alaska

Public Comment for TA11-750 by Anne Lazenby of Alaska Registry of Interpreters for the Deaf (AKRID)

TO: Regulatory Commission of Alaska
RE: TA11-750

The Alaska Registry of Interpreters for the Deaf (AKRID) supports the current request regarding TA11-750 to eliminate the limited forms of identification listed in the tariff and allow discretion regarding the type of proof of residency required for the TRS equipment distribution program (EDP).

AKRID is Alaska’s state affiliate chapter of the RID, the national organization of professional sign language interpreters whose mission includes advocating for quality standards in interpreting and working to ensure equal opportunity and access for all individuals.

Alaskans who are Deaf, Hard of Hearing, or experience a speech disability and could benefit from the EDP are often already facing many communication barriers.  They should not be denied access to vital telecommunications because they do not have a drivers’ license or state ID.  Although this documentation barrier may affect only a small subset of individuals, these are persons who are most likely to experience isolation and other communication challenges and could most benefit from the EDP.  

In its filing documents, Sprint provided multiple examples of individuals who are being negatively affected by the specific documentation requirement for valid reasons, but their residency is not truly in question.  These applicants could obviously benefit from the program, and it is disheartening that a technical requirement currently denies them access.  

Although Sprint did not provide specific recent examples of Deaf or Hard of Hearing individuals, we can think of situations and individuals who may face the similar barriers.  This is particularly true for Deaf individuals who are in rural/remote areas and are linguistically isolated and do not have access to interpreting in order to obtain state services, as well as many persons in assisted living facilities, hospitals, or other institutions either temporarily or permanently.  

It seems that the COVID-19 pandemic may have exacerbated this situation, but it is something that can occur at anytime and will not be resolved after the pandemic, so we believe a general tariff change is warranted.  Even without the pandemic, it can be challenging to obtain services in remote areas, and there are also times where obtaining or renewing an ID could be impractical or delayed, so having other options for proof of residency is reasonable.  This is especially true during an illness or hospitalization, which might require relocating to another community and thus having greater need for telecommunications access.  

Finally, Sprint subcontracts with a local vendor, ATLA, for their outreach program which includes the EDP.  ATLA is a trusted partner in the Alaska disability community and understands the uniques needs of Alaskans.  We expect ATLA would provide appropriate discretion and follow acceptable Alaskan standards to determine residency of applicants.  

Over the years Commissioners have often stated their desire for more equipment to be distributed to Alaskans, so granting this request would assist with that endeavor.

A copy of these comments has been sent to Sprint via email to Mary-Ellen.Hassell@T-Mobile.com.  


 Sincerely,

Anne Lazenby, President
Alaska Registry of Interpreters for the Deaf (AKRID)
PO Box 243262
Anchorage, AK 99524
www.alaskarid.org

Type

Comments

Date Filed

1/19/2021

Tracking Number

TR2100353

Filed By

Anne Lazenby

Entities

Certificate(s)

Means Received

Internet

Related Matters

TA11-750	Sprint Communications Company - General Rule Revision (Revision to Documentation Required)

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