Ed’s Telecom Alert

All..

Yuk!   This article is basically about Time Warner using a meter on customer to limit their "excessive" use of Internet network.

Meter for Internet Use Article

This is bit scary.   What about us deaf/hon who use video phones and VRS extensively?   Or for that matter those of VRS providers who employ deaf/hoh to make VRS calls to rack up VRS minutes?  Or those deaf/hoh organizations who sign up with VRS providers and then rack up VRS minutes to get their funds? 

ComCast Letter 

Read the article and the letter be concerned as it may impact us in a big way….

Will all this affect the traffic of Internet network and meters forced on us?   Let us know what you think?

eyes open & thumbs up,

Ed B

All..

Click to this link and read Writer Blum on his analysis of Viable.   Interesting perspective. 

CNN Article on Viable

Note: to any other VRS providers; if you have articles from reputable newspapers or Internet News of your company, do feel free send me an email.   It is important that I get the link cuz copy and paste is illegal.  

eyes open & thumbs up,

Ed B

PS: Writer Jonathan Blum interviewed me for 4 hours; more of collecting info from me.   That was when I was with PUC.  If he asked me after I retired, I prob would have charged him  [g]  

All..

All the hullabaloo about "earmarks" and pork barrel bills, I thought I would share a little bit of history on how Relay Texas was created in Texas. 

In 1989, Senator Chet Brooks – a veteran legislator – pushed the relay service bill . Senator Brooks got the bill into both House and Senate, and they were progressing along just fine.  Remember in Texas, legislation sessions are held once every two years and from Jan thru end of May.

There was an informal lobbying committee from Texas Assoc of the Deaf and the sole purpose of the committee was to lobby Texas Legislators to pass a relay service proposal. That was in 1989. Larry Evans who was executive director of TX Commission for the Deaf contracted with Eileen Alter (she now works at Deaf/Hard-of-Hearing Office under DARS).   Pregnant Eileen and the committee – Jerry Hassell, Julius Seeger, and myself lobbied at the Capitol.   Vaughn House (independent living service for deaf/hoh) loaned their interpreters so we deaf persons can effectively lobby legislators.   I spent an average of 15 hours a week doing that.  Eileen probably spend 40-50 hours a week doing that if I recall correctly.   A few others did lobbying as well, but not as often.  

Towards end of May (May 31 is the last day where bills can be passed) the relay bill passed thru required phases to get into the calendar to be posted to the Legislators to finally become the law, but somehow at the last stage, the relay bill was not posted.  Legislators were scrambling and trying to get all the "high priority" bills posted to calendar so neglected to include relay bill.   Senator Chet Brooks read the crystal ball and knew relay bill won’t make it.  So his political savvy and probably did a few behind the scene deals earmarked relay bill onto a major telephone bill that is already on the calendar.   I remember that time – with just a few hours before the midnight hour struck, the major telephone bill passed along with relay service bill.  So the relay service was to be implemented on Sept 1 1990.  

All the negative news about pork barrel and earmarked bills are not necessarily negative.   If not for that, Relay Texas and VRS may not be available.    It was soon after the bill was created, Relay Texas Advisory Committee was formed, and ultimately I became its first Chair.    Shortly after that, I then applied for Relay Texas Administrator and got the job.  

The morale?  Don’t be so quick and look down on earmarked bills.   If the earmarked bill is to analyze mating of salamander to the tune of 25 million bucks, then that is clearly excessive!   If the earmarked bill is to replace old bridge with a new bridge at a small town, then this is a good cause.  Often, earmarked bills are the lifeblood of small towns.  

eyes open & thumbs up,

Ed B 

All..

This one is a bit long so I will not do a vlog on this one.  

There was a lively discussion at a listserve on government models of State TRS Request for Proposal versus "Free Enterprise" of Internet-enabled relay service (IP/VRS).  I would like to share some of my musings and see what y’all have to say since there are more of you now (836 subscribers now) - I’ve discussed this before. 

Before I belabor on all this, why am I bringing that up?   The 10 digit phone number that VRS/IP users will get end of December 31, 2009 – if not sooner – will make it possible to identify originating and terminating points of a relay call.  In the past, VRS/IP use Internet Protocol so it was not possible to identify the originating or terminating points if they are at the Internet end of it.  So there is no way to know if the Internet-based relay calls are within a state or out of state so federal took the full responsibility to pay for VRS/IP.  But because now the VRS/IP calls can be determined if from within state or out of state so that means the FCC can pass responsibility of paying VRS/IP providers on to states.  When will that happen? Who knows..maybe soon after the 10 digit phone number is up and running with all bugs fixed? 

Now what are these models?  

Model #1:  State TRS RFP means state releases request for proposal (RFP) and relay providers would submit their proposals.   The best proposal – not always necessarily the lowest price reimbursement – would be chosen by state; usually by regulator, or a advisory committee or selected persons to be part of RFP committee. Few states allow state telephone association by joint agreement among telephone companies select a relay provider.    

Model #2:  "Free Enterprise" of Internet-enabled relay service is done by pre-analyzed reimbursement rates based on the cost breakdown provided by states (using MARS account methodology) and any company can be relay provider providing they met the requirements to be relay provider.  Federal decides if vendors qualify or not.  

OK?  

Now first of all let’s not kid ourselves – both models are govt subsidized – and not paid by customers like most telephone users.  We do, however, pay as ratepayers or taxpayers (all of us including hearing persons who may or may not use the service) which in turn subsidize relay service in both models.   Telephone companies collect fees from us and then they in turn pay into a fund that pays for relay service; (model #1) states usually by state regulators (PUC, PSC, etc), and (model #2) federal by federal regulator (FCC).  Both states and federal basically adopts these financial arrangements.  

There is a federal relay law that requires ALL states provide relay service with exception of Internet-enabled relay services. In other words, VRS/IP are not "required", but permitted.  There are a few federal relay regulations that list rules of what relay service must comply including Internet-enabled relay service (with some exceptions of some items being waived) to be a relay provider.  VRS/IP relay service – even though not required – must adhere to relay regulations to be reimbursed by the federal fund. 

That said, let’s muse… 

At traditional relay service level, states typically choose one provider with exception of California.  On other hand, at the federal level, Internet-enabled relay services (IP and VRS), any company with enough capital can be part of the service as long as they meet certain specifications to be relay provider.   Multi-vendors are possible with Internet-enabled relay service while with states, typically only one relay provider is selected.   As you can see obvious difference between states and federal. 

At the federal mode #2, Interstate relay service (long distance calls made out of states) and Internet-enabled relay services only have to follow federal relay regulation and its bare minimum requirements.  States, on other hand, varies from state to state on what is required.   A few states merely adopt what federal relay regulation says; in other words minimum regulations.  However, most states write their own relay regulations that often surpass what federal relay regs require.   An example is Average Speed Answer (ASA – how many calls answered within specified time frame), many states chose the more stringent criteria of 3.3 ASA (average answer time shall not exceed 3.3 seconds) than what federal require which is 85/10 (85% of calls be answered within 10 seconds be answered).  States often ask for aggressive outreach to be part of the package.  Federal will subsidize only portion of marketing or outreach.   IP/VRS model #2 have to compete for customers and outreach is paid mostly by IP/VRS providers while state model #1 and its selected relay provider often partner up and do outreach projects together.    

Reimbursement rate from federal is based on – supposedly – the "average" reimbursement rates and costs collected from all states whereas reimbursement rates from states are based on the submitted reimbursement rate by relay providers (RFP process).   So smaller states – because of its low call volume – typically pays higher reimbursement rates whereas larger states typically pays lower reimbursement rates.   One important note: national reimbursement rate is based on ALL of bid price per minutes of each state and then reimbursement rate are averaged and calculated.  

Now you understand why if federal decide to pass subsidization responsibility of Internet-enabled relay services on to states, the reimbursement rates for states will likely be much higher and states will likely choose ONE provider rather than multiple providers to keep reimbursement rates low.  If states chose three providers in that state,it means the call volume for EACH provider will be 1/3 lower than state total thus the reimbursement rate likely will be higher.  Most state governments are frugal so they will opt for one provider because one call volume for one provider will get lower reimbursement rate.  

So we prefer to keep Internet-enabled relay service at federal level to make it possible to have choices of different IP or VRS providers.   However, it seems federal is determined to pass the subsidization responsibility on to states.    Is there a win-win solution to that?   I believe so, and I hope to share with you all what the win-win solution might be.  The idea I have is a proposal I believe VRS/IP providers, and deaf/hoh communities will find attractive, but not to federal agency and possibly a few state regulators as well. 

For now, any questions/comments on this so far?  I hope I am making sense of the difference between the two models.  Feel free to ask, agree, oppose, or offer alternative ideas.  

eyes open & thumbs up,

Ed

PS: Would you have preferred this to be Vlog even though it may be more than 10 minutes long?  Let me know your thoughts…