Neutral and Reference Platforms Clarification

8 05 2014


After getting feedback from FaceBook and emails, etc.   I’ve decided to try again to explain the concept of Neutral Platform (NP) and Reference Platform (RP).  

Let’s focus on ACD first as this term ACD is the key in understanding what NP is.  ACD means Auto Call Distributor.  ACD is the brain/heart of all Call Centers.  Without ACD, VRS cannot be provided.  

So Neutral Platform is an ACD.  Referral Platform is not an ACD.  I think confusion came from the fact both use the term “platform”. 

RP is just a required software specification that requires providers to use to ensure interoperability among the providers. Once video conference software is adopted by the FCC, all existing VRS providers MUST ensure that their proprietary video conference products are interoperable with the required video conference software to ensure interoperability. By the way, government-run NP is required to use the required standard video conference software from RP.

RP is the benchmark test for interoperability.   Pass the RP test, then can provide VRS.  Fail the test, can’t provide VRS.

RP guarantees interoperability.     

More on NP: FCC released Request For Proposal (RFP) that made a list of features to create a Neutral Platform which is an ACD.  Features include: Video Mail; Call Forward; Verification of required procedures such as: address, name, etc; Speed Answer, Security Check, any other desired telecommunication features, etc.

Existing VRS providers ALREADY have ACD as that was a required item to be certified as VRS Providers.  Existing VRS providers already have the features of which current VRS users utilize and enjoy.

The difference between NP and ACD from VRS providers is this:   NP is a government-run ACD whereas ACDs from VRS providers are privately-run.  This is a very important point.  

Stand Alone CA providers can only use NP (ACD); FCC rules will not allow Stand Alone CA providers to have its own proprietary ACD. Existing VRS Providers have two choices: they can use their own proprietary ACD (at their own expense), or change over to government-run NP and give up their proprietary ACD (in other words, become interpreting service provider). 



Neutral Platform

Reference Platform

See # For Further Explanation

Development of Video Conference Software




Creation of ACD

Yes, but restricted to RFP specs



#1 Video Conference Software:  Only RP develops video conference software that is “standard” and will be required for all providers to use.  #2 ACD (Auto Call Distributor): NP is an ACD.  Stand Alone CA or VRS providers who chose NP route has to use ACD system from NP. 

Additional notes:

Existing VRS providers ALREADY have ACD (required by original VRS regulation to begin with) and they can choose to keep their own ACDs if they so choose.  

VRS providers who incorporate the required software (RP) into their products can use their own ACDs and can be creative and come up with new features not available by other providers (that’s competitive right there).  But only if the reimbursement rates include reasonable R & D expenses for VRS providers then the competitiveness will be lively.

Can NP providers get new features?  Yes, but remember that any new features added to NP will require complicated government procedures to approve the funds and the decision likely will be a political one. It is a foregone conclusion that federal government processing anything will be slower than snail to get anything approved especially if it entails additional costs.  In other words, once the first new features are approved for NP, then VRS users will see same old features for a long time before any new features become available.

Stand Alone CA providers and VRS providers who chose NP will only become interpreting service providers.  Nice new features offered by existing VRS providers will be GONE or replaced with NP features if they are forced to use NP because that may be the only way for existing VRS providers to make profit. 

The marketing strategy for NP providers likely will be based on “our interpreters are better than theirs” and that’s it.  Because of NP, all features are same by providers who use NP so no sense to advertise that their “features” are better than others.  All are the same for NP providers.

Remember FCC already reduced funds for R & D for new features/products costs on reimbursement rate for existing VRS providers.  That reduction of rate may be a way for FCC to force existing VRS providers to change over to use NP and abandon their own proprietary ACD and any future new features in order to stay afloat financially.  

Possible scenario for NP:  VRS will be run/controlled 100% by government if ALL existing VRS providers change over to NP because of forced economic reasons. VRS could ultimately become a government-run nationalized service. I don’t think we want that.

Again, the choice is clear.  With NP, VRS will go downhill on quality just like the text IP Relay did.  A little bit history here: IP Relay had 4 or 5 providers. FCC started reducing the reimbursement rates, and now there are only 2 IP Relay Providers.   Sprint recently submitted comments that if reimbursement rate continue to be reduced, Sprint will get out of the business as the company said can’t provide quality service with low reimbursement rate.      

Better solution: Remove NP, and keep RP, and ensure reimbursement rate is reasonable then the lively competition will continue and new products/features will keep coming up as fast as the VRS industry can create them.  

Any questions, please feel free to ask.  Feel free to comment as well.   If I made mistake, please point them out.  I will be happy to clarify or correct them. 

eyes open & thumbs up,      


VRS Stand Alone CA

16 04 2014

Stand Alone VRS CA


In the past posts, I focused on Neutral Platform; that is, NP is a government-developed platform that has all the “features” and is available for free for any VRS providers and any interpreting service that wants to turn their services into Stand Alone VRS CA. In this post, I want to focus on Stand Alone VRS CA.  What is “CA”?  That is Communication Assistant which in this case, same as interpreter in relay environment.  


Stand Alone VRS Ca basically means any interpreter service provider can apply to the FCC for certification as Stand Alone VRS CA provider.   The catch?  Have to use/download government-developed Neutral Platform and become “VRS provider”.   


For example, Texas has like 30 to 40  Interpreter Services so theoretically all of them can become Stand Alone VRS CA providers to say nothing of hundreds if not thousands of interpreter services providers nationwide that can apply.  


Can you imagine maybe 50 or more applications from Interpreter Services nationwide and that FCC has to review them?   Of course, those who applied will have to meet the FCC certification requirements, but it will not be the same strict rules as what certified VRS providers had to go through as VRS Stand Alone CA providers are not allowed to have their own video conference, and they just only have to download the one that government created. So that’s a freebie for interpreting service providers. Remember existing VRS providers spent million of dollars developing their own unique platforms which VRS users now enjoy.


Anyway this Stand Alone VRS CA is basically opening up same can of worms all over again and allowing Interpreter providers join in becoming VRS providers, but with much less stringent cost requirements: just download from NP at no cost.  


FCC just went through whittling down VRS providers from 52 down to 6 providers.  I generally support that as VRS providers need to meet highest possible standard VRS regulations.    However, with this allowance of Interpreter services tag on to NP will cause increased number of VRS providers. FCC will have lot more on its headache in monitoring all these and will less likely catch criminal actions (just like they missed a quite a few with the old 52 VRS providers).  Same thing will happen with Stand Alone VRS CA if there are too many of them. 


At any rate, it does make me wonder if FCC is discriminating against deaf/hh and allowing services run mostly by hearing persons become VRS providers.   These old 52 VRS providers, I believe, majority of them were either deaf-owned or deaf-run and they were cut off by the FCC. Most of interpreting services are run by hearing persons and the FCC will allow these to become “VRS providers”.   


FCC could have found ways to allow deaf-owned VRS providers to continue somehow perhaps by modifying regulation; FCC did not do that, but the FCC sure did for interpreting service providers. Perhaps the FCC is profiling to the extreme based on past bad experience?  hmmm  Based on the logic in this paragraph, it appears the FCC is discriminating against the deaf/hh.


Another issue: The FCC will not require certification of Interpreters simply because they knew it would raise reimbursement rates. I would be very interested how the FCC team will evaluate quality of interpreters without requiring certification? More likely the FCC will say “let the VRS Users decide which of the Stand Alone VRS CA offer high quality interpreters”.   Wow, if that being the case, deaf/hh will have a frustrating of time finding a good quality service provider if there are many of them out there; makes me wonder if the FCC really cares for VRS users anymore? They used to.  I guess nowadays cost is the bottom line for the bureaucratic and political FCC staff.  


Current VRS providers do have their own unique evaluation procedures for hiring interpreters simply because VRS is different than regular community interpreting. These Research & Development in understanding VRS interpreting environments costs hundred thousands of dollars. At any rate, without having R&D which requires lot of money and the FCC will not subsidize that, Stand Alone VRS CA providers may have some difficulty adjusting to that.      


It is very likely that the Stand Alone VRS CA providers will be paid at a much lower rate than VRS providers. Although FCC says that it will continue to support VRS providers so that deaf people can still use their products and services, but we know that over long run, hearing controlled economics will put pressure on phasing out VRS providers for cheaper Stand Alone VRS CA. How will FCC do that? By removing the outreach, R&D, marketing and the cost of interpreters (at decent salaries) expenses out of reimbursement rates, FCC is effectively forcing the current VRS providers to either get out or take on the standard Neutral Platform and provide inferior services.  


Bottom line is that NP, FCC’s restricting guidelines, and reducing reimbursements will force all VRS providers to become Interpreting agencies. Existing VRS providers may be forced to jump to NP, abandon their platforms, and just become interpreting services and lose all the wonderful features existing VRS providers now offer.   Switching to NP platform will offer inferior services. 


This is not idle threat.  Possible of that happening is real.


Once again, the FCC failed to understand tremendous economic benefits from high quality VRS providers.  


 Is that the path towards Functional Equivalence? I think NOT..hmm.. I take it back I know NOT


eyes open & thumbs up,



Clarification: Neutral Platform & Reference Platform

7 04 2014

Hullo Savvy Readers,


In reviewing past posts on Neutral Platform (NP) I realized further clarification is needed on NP.  


What FCC did was release two separate RFPs (request for proposals):   One for Neutral Video Communication Service Platform (let’s call that “NP”) and one for VRS Access Technology Reference Platform (Reference Platform: “RP”).   


Big Difference!      


Partial modified quote by FCC the RFP on NP:  


The functions provided by the NP include the provision of :

  • a video link, 
  • user registration and validation, 
  • authentication, 
  • authorization, 
  • ACD platform functions, 
  • routing, 
  • call setup, 
  • mapping, 
  • call features (such as call forwarding and video mail), and 
  • such other features and functions.


In other words, RFP wants only the platform itself. FCC wants contract on a company that will develop the mechanism to make the platform to do these listed features.  


Now on partial modified quote by the FCC on RP:


A software product procured by or on behalf of the Commission that provides VRS functionality: 

  • including the ability to make and receive VRS and point-to-point calls, 
  • dial-around functionality, and 
  • the ability to update user registration location, and 
  • against which providers may test their own VRS access technology and
  • platforms for compliance with the Commission's interoperability and portability rules.


In this RP: Basically it seems to mean that FCC wants a software that has video codec that is “standard” and also allow VRS providers to make its own video codec as long as ALL of video products are interoperable with NP and other VRS Providers’s products (if they chose RP over NP).  Meaning, for example: Convo can make its own unique video codec that can only be used for Convo products and Convo VRS and at the same time these same products by using “standard” video codec can communicate with NP and other VRS Providers’s video products that also use “standard” video codec.  Other VRS providers can develop its own video codec to be used only among their video products if they wish.   At the same time ALL video products must use “standard” video codec (developed by RP RFP) to talk with other VRS Providers’s products.   


I hope I make sense.  


Most of VRS providers do NOT support NP, and they DO support RP.   


On the NP if developed and available, VRS providers only have one choice out of two possible options:   


First option: use the NP as provided by FCC. 




Second option: use their own platform (by using RP).    


VRS providers cannot use both at the same time. If use FCC’s NP, VRS providers become glorified interpreter services and give up their own platform.   


If VRS providers provide their own platform (which includes capability to connect with NP), creativity and competition lives on.  This is ideal.  


Sad to say, the catch?   If VRS providers use their own platform, it will have to be on their own cost or minimal allowance of cost to be part of reimbursement rate.  To have its own platform is not cheap and requires R & D and creative people and funds to make high quality products.  With NP, providers are “locked-in” to only what FCC’s NP provides.  FCC wants to push out creativity and innovative ideas by not funding providers who want to develop their own platforms and limit them to what features NP provide.  


RP is good because it allows competition among the VRS providers and they can develop new and better features.  Competition is alive in RP and not so in NP.    


The choice is clear. NP? nope, not good, really a bad idea. Monopolistic! RP? yes, a very good compromise.   Competition is fair for all involved providers.  


VRS industry does not need NP and the industry will do fine with RP only. 


eyes open & thumbs up,




PS:  By the way, some of you may be asking what the heck is Video Codec?   Oh, hard to explain, but basically it is code of logistics that will compress video to language that computer understands and is able to display video.  There are many different ways to compress video codes.   There is a standard video codec called H.264 that many VRS providers use.  There is a special video codec developed or bought or leased by other companies that can be exclusively used by one VRS providers.


David Bahar’s Video Clip on Neutral Platform

24 03 2014



I saw video clip by David Bahar on Neutral Platform and liked what I saw so I asked David for permission to post his video clip. He gave me a hearty go ahead.  So here it is…

For those who do not know sign language, the "CC" will show up once you start the video clip.  I am not sure why it does that, but it is now capioned.     David has good perspective; it is worth viewing.  

eyes open & thumbs up,