Below is a letter outlining the concerns that Patricia Yeager, CEO of The Independence Center, has with House Bill 1328, House Bill 1329, House Bill 1330 and House Bill 1331.

RE:  Access to Telephone Services for Persons with Disabilities, Seniors Threatened

Dear Sponsor:

Below is a letter outlining the concerns that Patricia Yeager, CEO of The Independence Center, has with House Bill 1328, House Bill 1329, House Bill 1330 and House Bill 1331.

I am writing to express my deep concerns personally and professionally to the flurry of bills introduced last week that deregulate and possibly discontinue landline telephone service in Colorado.  I am a person who is hard of hearing and have worn hearing aids since I was 5.  I am also the CEO of The Independence Center located in Colorado Springs and serving an 8 county area.  We are a state certified Independent Living Center providing services and advocacy that encourage people with all disabilities to live in the community and in control of their lives.  We also run a Home Health agency that specializes in serving people with significant disabilities receiving Medicaid dollars.

The bills that I am referring to are HB-1329, HB-1330, HB-1331, all of which call for complete deregulation of the VOIP and/or Land Line telephone service.  HB -1328 calls for moving the High Cost Fund away from maintaining landlines toward expanding broadband capacity.  I want to bring to your attention several consequences that perhaps you have not given thought to.

Deregulation of an essential service

I hope we all agree that communications services in this country are an essential service.  Personally, I am concerned about leaving the quality and product effectiveness to the discretion of telecommunication companies.  Telephone services, whether it be land line or VOIP, are essential to the safety of all people in the state.  Land line services have been subsidized for decades; in the mid to late 20th century there was quite a push to ensure that all households had a landline.  In the disability and senior community there continues to be a push to ensure that we have access to telephone services and to the adaptations needed to make telephones useable given various functional limitations.  Currently all landline owners pay five cents a month per landline to the Disabled Telephone Users Fund (DTUF) that fund three projects:  Telephone Relay services for deaf and hard of hearing individuals; the Commission on the Deaf and Hard of Hearing with several important projects like courtroom access to interpreters; and the Reading Program for the Blind, using the telephone to read aloud newspapers for the blind.  All three are vital communications projects that need to be continued and the DTUF is mandated by the federal government.  How will these programs continue if there is no regulation or oversight for our communications system?

Deregulation of landlines and foregoing any regulations for VOIP deprives all residents of a way to hold the telecommunications companies accountable for their actions.  There will be no one other than the telecommunications companies to complain to and they will be focused on profits and what serves the most population, not what serves a segment such as seniors and persons with disabilities or the poor.   Taking this industry out from PUC oversight is a great way to ensure that the quality of our services decrease for our community

The question here is does the government have an interest in all people having access to telephone service or just those who can afford the VOIP communications system?  The LA Times story (December 5, 2013) indicated that in that state, telephone deregulation caused the cost of a land line to increase some 260%. A single landline with measured service went from $5.83 a month to $21.25 a month, hardly an affordable rate for people on fixed or limited incomes.  The same article also spoke to the deterioration of quality of service for landlines.  Telecommunications companies will be much less inclined to keep landlines active as the number of people needing those declines even though the new technology is either not affordable or safe during a disaster for low income, disabled or senior populations.  VOIP is actually not safe for anyone during an emergency given the inability of cell phones to go to the right tower that serves a specific address for 911 services. When one goes to buy a VOIP phone, the salesperson cautions to be sure to have another way to connect to 911.  What would that alternative method be and who would regulate and insure such access is made available?

High Cost Fund diversion

I am very concerned that the State is sanctioning the demise of landlines by moving the High Cost Fund dollars from maintaining landlines over to expanding broadband.  While the goal is laudable, it is short-sighted in a state that faces as many disasters as Colorado.  Landlines are much more reliable than cell calls in an emergency.  Too many cell calls can jam the tower and curtail all communications.  For people with hearing loss, the landline may be the only telephone service that can be heard when ringing or understanding speech if not wearing aids (such as at night).   The current 911 system does not work with texting technology so not only are deaf individuals unable to easily and quickly access that service, but cell phones cannot be relied upon to reach the right tower that serves that address’  emergency needs.  Clearly there is still a big need to maintain those landlines.  I understand there are many other funds being used to expand broadband without taking this fund away from its important service.

Personal impact

As a person with a hearing impairment, I cannot hear my cell phone at night or when it is not right next to me.  So I do not rely on it for emergency information but I know that I am safe for anyone can reach me via my landline.  Those workhorse landline telephones are crystal clear and as loud as I need it to be.  During an emergency I know I can be reached very easily and told to evacuate or what next steps to take.  I live in the Urban Wild-land Interface-at the foot of Cheyenne Mountain so I need the ability to hear the telephone when a disaster strikes.  For seniors and others like me who are hard of hearing, the landline is our lifeline.

As you debate the merits of deregulating our essential telephone services or move dollars away from supporting the landline infrastructure, give some thought to the potential loss of life as people give up their land lines and cannot use the cell phone for safety.  Having no one to ensure that the telephone service meets the need of the community or having no landlines is a recipe for disaster for people with disabilities, seniors and persons who are poor.  Finally, consider how you will continue the Disabled Telephone Users fund as it provides critical services that allow us to continue to be connected.

Sincerely,

Patricia Yeager, Ph.D.

Chief Executive Officer
The Independence Center
729 S Tejon Street
Colorado Springs, CO 80906

CC: Honorable Governor John Hickenlooper