<?xml version="1.0" encoding="UTF-8"?><rss version="2.0"
	xmlns:content="http://purl.org/rss/1.0/modules/content/"
	xmlns:dc="http://purl.org/dc/elements/1.1/"
	xmlns:atom="http://www.w3.org/2005/Atom"
	xmlns:sy="http://purl.org/rss/1.0/modules/syndication/"
		>
<channel>
	<title>Comments on: Docketed Comment</title>
	<atom:link href="http://www.edsalert.com/2009/07/07/docketed-comment/feed/" rel="self" type="application/rss+xml" />
	<link>http://www.edsalert.com/2009/07/07/docketed-comment/</link>
	<description>POSTS ALERTS REGARDING TRS &#38; ITS RELATED ISSUES</description>
	<lastBuildDate>Thu, 22 Dec 2011 19:46:47 +0000</lastBuildDate>
	<sy:updatePeriod>hourly</sy:updatePeriod>
	<sy:updateFrequency>1</sy:updateFrequency>
	<generator>http://wordpress.org/?v=3.3</generator>
	<item>
		<title>By: Cousin Vinny</title>
		<link>http://www.edsalert.com/2009/07/07/docketed-comment/comment-page-1/#comment-69994</link>
		<dc:creator>Cousin Vinny</dc:creator>
		<pubDate>Wed, 15 Jul 2009 02:59:20 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/2009/07/07/docketed-comment/#comment-69994</guid>
		<description>Ed-

Your FCC comment really nailed it. Like you, I want the VRS industry to be a sustainable endeavor that will still be there for us 5, 10, 15, or 30 years down the road. All of this VRS misuse, whether fraudulent or not, jeopardizes that.

Here&#039;s the money quote; The USTA Comment had this: &quot;For the upcoming 2009-10 Fund Year, the National Exchange Carrier Association (NECA) projects VRS demand upwards of &lt;b&gt;123.8 million minutes&lt;/b&gt;, with a weighted average rate per minute of $6.2972.15&quot;

For the sake of argument, the size of the ASL-using community isn&#039;t that huge. Let&#039;s say 100,000 people at the most. People may quibble with this number. Dividing 123.8 million minutes by 100K ASL-using Deafies comes out to 1,238 minutes consumed per person per year, or 20.6 hours worth. While I am a VRS user, I cannot recall ever using more than 2-3 hours worth, if you were to aggregate all the minutes I&#039;ve used in a given year.

The sheer numbers suggest that there&#039;s misuse in VRS services, and such activities need to be curtailed if there&#039;s to be a sustainable VRS industry.</description>
		<content:encoded><![CDATA[<p>Ed-</p>
<p>Your FCC comment really nailed it. Like you, I want the VRS industry to be a sustainable endeavor that will still be there for us 5, 10, 15, or 30 years down the road. All of this VRS misuse, whether fraudulent or not, jeopardizes that.</p>
<p>Here&#8217;s the money quote; The USTA Comment had this: &#8220;For the upcoming 2009-10 Fund Year, the National Exchange Carrier Association (NECA) projects VRS demand upwards of <b>123.8 million minutes</b>, with a weighted average rate per minute of $6.2972.15&#8243;</p>
<p>For the sake of argument, the size of the ASL-using community isn&#8217;t that huge. Let&#8217;s say 100,000 people at the most. People may quibble with this number. Dividing 123.8 million minutes by 100K ASL-using Deafies comes out to 1,238 minutes consumed per person per year, or 20.6 hours worth. While I am a VRS user, I cannot recall ever using more than 2-3 hours worth, if you were to aggregate all the minutes I&#8217;ve used in a given year.</p>
<p>The sheer numbers suggest that there&#8217;s misuse in VRS services, and such activities need to be curtailed if there&#8217;s to be a sustainable VRS industry.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: edsalert</title>
		<link>http://www.edsalert.com/2009/07/07/docketed-comment/comment-page-1/#comment-69719</link>
		<dc:creator>edsalert</dc:creator>
		<pubDate>Fri, 10 Jul 2009 17:38:54 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/2009/07/07/docketed-comment/#comment-69719</guid>
		<description>Jeff,

Good point of which I used in the early days of VRS in Texas with my supervisors.</description>
		<content:encoded><![CDATA[<p>Jeff,</p>
<p>Good point of which I used in the early days of VRS in Texas with my supervisors.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Jeff</title>
		<link>http://www.edsalert.com/2009/07/07/docketed-comment/comment-page-1/#comment-69715</link>
		<dc:creator>Jeff</dc:creator>
		<pubDate>Fri, 10 Jul 2009 16:55:41 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/2009/07/07/docketed-comment/#comment-69715</guid>
		<description>Ed,  Again a well thought document but there is one element that is lacking if we are to avoid further docking of the VRS minute rate - the functional equivalency which should show a standard call made through VRS being at least four to five times faster than that for a TRS or IP-TRS - and this coupled with the wider efficiency savings for the deaf person PLUS the hearing person totalled together would show that the VRS rate is actually a bargain.

All the best

Jeff</description>
		<content:encoded><![CDATA[<p>Ed,  Again a well thought document but there is one element that is lacking if we are to avoid further docking of the VRS minute rate &#8211; the functional equivalency which should show a standard call made through VRS being at least four to five times faster than that for a TRS or IP-TRS &#8211; and this coupled with the wider efficiency savings for the deaf person PLUS the hearing person totalled together would show that the VRS rate is actually a bargain.</p>
<p>All the best</p>
<p>Jeff</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: nic terp</title>
		<link>http://www.edsalert.com/2009/07/07/docketed-comment/comment-page-1/#comment-69609</link>
		<dc:creator>nic terp</dc:creator>
		<pubDate>Thu, 09 Jul 2009 14:21:55 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/2009/07/07/docketed-comment/#comment-69609</guid>
		<description>Thank you Ed for the clarification. Your support and respect is very much appreciated.</description>
		<content:encoded><![CDATA[<p>Thank you Ed for the clarification. Your support and respect is very much appreciated.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: edsalert</title>
		<link>http://www.edsalert.com/2009/07/07/docketed-comment/comment-page-1/#comment-69606</link>
		<dc:creator>edsalert</dc:creator>
		<pubDate>Thu, 09 Jul 2009 13:49:16 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/2009/07/07/docketed-comment/#comment-69606</guid>
		<description>nic terp,

I think once that frauds are eliminated, the call volume will reduce drastically - maybe as much as 30% or more of the overall total minutes.  A couple of VRS providers earn their revenue from frauds as high as 80%; that is, manufactured minutes.  So they can afford to pay high salaries for interpreters.   So with frauds eliminated, the market realities will set in and video interpreters will earn decent and reasonable wages.   Oh, I don&#039;t expect Video Interpreters to be making in low $30K; no, they&#039;re too far valuable for low salaries; I also do not expect them to make six figures either.   For those of you interpreters who know me, know I have nothing but highest respect for quality interpreters; they&#039;re symboites.  I was going to say locked in the hip, but may give wrong impression (ha ha).  Seriously, video interpreters are very much integral part of VRS scenario and demands the highest respect.</description>
		<content:encoded><![CDATA[<p>nic terp,</p>
<p>I think once that frauds are eliminated, the call volume will reduce drastically &#8211; maybe as much as 30% or more of the overall total minutes.  A couple of VRS providers earn their revenue from frauds as high as 80%; that is, manufactured minutes.  So they can afford to pay high salaries for interpreters.   So with frauds eliminated, the market realities will set in and video interpreters will earn decent and reasonable wages.   Oh, I don&#8217;t expect Video Interpreters to be making in low $30K; no, they&#8217;re too far valuable for low salaries; I also do not expect them to make six figures either.   For those of you interpreters who know me, know I have nothing but highest respect for quality interpreters; they&#8217;re symboites.  I was going to say locked in the hip, but may give wrong impression (ha ha).  Seriously, video interpreters are very much integral part of VRS scenario and demands the highest respect.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: nic terp</title>
		<link>http://www.edsalert.com/2009/07/07/docketed-comment/comment-page-1/#comment-69603</link>
		<dc:creator>nic terp</dc:creator>
		<pubDate>Thu, 09 Jul 2009 13:10:56 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/2009/07/07/docketed-comment/#comment-69603</guid>
		<description>Ed,

My only concern is that you seem to feel that terps are over paid. I wanted to let you know that I happen to work in a state where interpreters pay has not changed in about 10 years.  For us, the fact that vrs companies are willing to pay more for quality terps has made many terps finally feel validated and respected.

Interpreters are the only professional field that are often not viewed as professionals. We are looked down on by doctors, lawyers and professors. Yet often we must have more knowledge and schooling then all of those fields combined.

I agree that changes must be made, but I do not feel that interps are overpaid.</description>
		<content:encoded><![CDATA[<p>Ed,</p>
<p>My only concern is that you seem to feel that terps are over paid. I wanted to let you know that I happen to work in a state where interpreters pay has not changed in about 10 years.  For us, the fact that vrs companies are willing to pay more for quality terps has made many terps finally feel validated and respected.</p>
<p>Interpreters are the only professional field that are often not viewed as professionals. We are looked down on by doctors, lawyers and professors. Yet often we must have more knowledge and schooling then all of those fields combined.</p>
<p>I agree that changes must be made, but I do not feel that interps are overpaid.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: edsalert</title>
		<link>http://www.edsalert.com/2009/07/07/docketed-comment/comment-page-1/#comment-69506</link>
		<dc:creator>edsalert</dc:creator>
		<pubDate>Wed, 08 Jul 2009 02:06:21 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/2009/07/07/docketed-comment/#comment-69506</guid>
		<description>May,

This is one of ongoing issue about LN and video phone and who is the primary VRS provider.  Right now it has not been worked out where a person can use - say - vp-200 and make CSDVRS the primary VRS provider.   One can use vp-200 and accept SVRS as the primary VRS provider, but you can add other VRS providers to the address book and make VRS calls through that.   

eyes open &amp; thumbs up</description>
		<content:encoded><![CDATA[<p>May,</p>
<p>This is one of ongoing issue about LN and video phone and who is the primary VRS provider.  Right now it has not been worked out where a person can use &#8211; say &#8211; vp-200 and make CSDVRS the primary VRS provider.   One can use vp-200 and accept SVRS as the primary VRS provider, but you can add other VRS providers to the address book and make VRS calls through that.   </p>
<p>eyes open &#038; thumbs up</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Robin Horwitz</title>
		<link>http://www.edsalert.com/2009/07/07/docketed-comment/comment-page-1/#comment-69494</link>
		<dc:creator>Robin Horwitz</dc:creator>
		<pubDate>Tue, 07 Jul 2009 22:27:22 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/2009/07/07/docketed-comment/#comment-69494</guid>
		<description>In California, Deaf and Disabled Telecommunications Program (DDTP) and California Public Utilities Commission had a multi-vendor relay program.

I would like to point out the pros: 

- Promotion of competition between vendors which led to greater marketing efforts. 
- A greater desire on vendors&#039; part to ensure the quality of service would be high enough. 
- Different rates to 3 vendors based on their bid price. 

The downsides were: 

- The RFP was about 400 pages thick and that meant an incredible amount of oversight had to be executed in order to justify the RFP&#039;s requirements. This meant a consulting firm was hired for this job along with DDTP&#039;s staff members - additional costs were placed to CPUC and its taxpayers. 

- Inability on the vendors&#039; part to be creative or innovative. Because RFP was generally restrictive, it did not make any business sense to develop any products or services which will be subject to approval (this means several months). To CPUC&#039;s credit, they actually had a points system for innovation but... this meant oversight. 

Robin</description>
		<content:encoded><![CDATA[<p>In California, Deaf and Disabled Telecommunications Program (DDTP) and California Public Utilities Commission had a multi-vendor relay program.</p>
<p>I would like to point out the pros: </p>
<p>- Promotion of competition between vendors which led to greater marketing efforts.<br />
- A greater desire on vendors&#8217; part to ensure the quality of service would be high enough.<br />
- Different rates to 3 vendors based on their bid price. </p>
<p>The downsides were: </p>
<p>- The RFP was about 400 pages thick and that meant an incredible amount of oversight had to be executed in order to justify the RFP&#8217;s requirements. This meant a consulting firm was hired for this job along with DDTP&#8217;s staff members &#8211; additional costs were placed to CPUC and its taxpayers. </p>
<p>- Inability on the vendors&#8217; part to be creative or innovative. Because RFP was generally restrictive, it did not make any business sense to develop any products or services which will be subject to approval (this means several months). To CPUC&#8217;s credit, they actually had a points system for innovation but&#8230; this meant oversight. </p>
<p>Robin</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: edsalert</title>
		<link>http://www.edsalert.com/2009/07/07/docketed-comment/comment-page-1/#comment-69493</link>
		<dc:creator>edsalert</dc:creator>
		<pubDate>Tue, 07 Jul 2009 22:07:43 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/2009/07/07/docketed-comment/#comment-69493</guid>
		<description>Retired State Regulator,

Point taken.  It still may happen if FCC has its way and pass on the oversight responsibility of VRS to states. 

Actually, Texas did look at multi-vendors approach in Texas, but could not find a way to make the overall cost lower than single vendor.  So stayed with RFP for one vendor.   New features only happen when RFP rolls around; a competitive environment, new features comes out right away.  So there is pro and cons to both sides. 

eyes open &amp; thumbs up...</description>
		<content:encoded><![CDATA[<p>Retired State Regulator,</p>
<p>Point taken.  It still may happen if FCC has its way and pass on the oversight responsibility of VRS to states. </p>
<p>Actually, Texas did look at multi-vendors approach in Texas, but could not find a way to make the overall cost lower than single vendor.  So stayed with RFP for one vendor.   New features only happen when RFP rolls around; a competitive environment, new features comes out right away.  So there is pro and cons to both sides. </p>
<p>eyes open &#038; thumbs up&#8230;</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Dianrez</title>
		<link>http://www.edsalert.com/2009/07/07/docketed-comment/comment-page-1/#comment-69492</link>
		<dc:creator>Dianrez</dc:creator>
		<pubDate>Tue, 07 Jul 2009 21:35:42 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/2009/07/07/docketed-comment/#comment-69492</guid>
		<description>Ed, that was a well reasoned and clearly explained position paper on VRS reimbursement. It makes a lot of sense and explains delay problems that I had seen with use of the VRS.

What I also would like to see is a separate type of reimbursement that gives VRS companies an incentive to upgrade their offerings. 

For example, addition of services designed for on the road devices such as Blackberry and p3 and MVPs, Deaf business services, fax capability, and child friendly services. Perhaps this funding could also pay for focus groups of deaf consumers to study improvements in the system.

Thanks for staying involved and looking for ways to improve the service structure.</description>
		<content:encoded><![CDATA[<p>Ed, that was a well reasoned and clearly explained position paper on VRS reimbursement. It makes a lot of sense and explains delay problems that I had seen with use of the VRS.</p>
<p>What I also would like to see is a separate type of reimbursement that gives VRS companies an incentive to upgrade their offerings. </p>
<p>For example, addition of services designed for on the road devices such as Blackberry and p3 and MVPs, Deaf business services, fax capability, and child friendly services. Perhaps this funding could also pay for focus groups of deaf consumers to study improvements in the system.</p>
<p>Thanks for staying involved and looking for ways to improve the service structure.</p>
]]></content:encoded>
	</item>
</channel>
</rss>

