All…
Along the same topic on non-reimbursable minutes. Read on..
The underlying message is that the price of inaction may prove to be too great for most of VRS providers then ultimately VRS users suffer as result.
eyes open & thumbs up,
Ed
Long Links:
4 VRS
http://fjallfoss.fcc.gov/ecfs/document/view?id=7020382451
CSDVRS Ex Parte
http://fjallfoss.fcc.gov/ecfs/document/view?id=7020355243
Hello everyone
Quick disclaimer. I own edsalert and also a co-founder of Convo. So accept my vlog for what it is.
I want to share with you all of a disturbing trend that the FCC had adopted restrictions of certain VRS features without actually releasing Public Notices that restrict these features for VRS industry.
FCC is now giving directives to National Exchange Carrier Association (NECA) – NECA is the contracted account administrator who reimburses VRS providers - anyway NECA is not to reimburse any minutes by VRS providers that are processed for these following features:
These two, in my opinion, are legitimate calls. Conference calls by non-VRS employees – just regular deaf/hoh to hearing persons should be permitted, not forbidden.
The telephone support services that deaf/hoh calls to get technical help likewise should be permitted.
The largest VRS providers are able to absorb the cost of these features so they do not submit these minutes to the NECA whereas smaller VRS providers who need every minutes are forced to block these features as they cannot afford to absorb these costs. So who gets hurt are the start ups or small VRS providers.
Other non-reimbursable features are:
Podcast
online education (this one there is a FCC public notice forbidding that but specifically to “class room” situation)
some cases webinars
These three are debatable and controversial. Title III of ADA Act or Section 255 of Telecomm Access may apply on some of these “non-reimbursable” minutes.
However, I agree with not allowing class room as it really is the responsibility of educational institution to provide access for the deaf/hoh.
Strongly suggest that if you feel strongly about these non-reimbursable minutes, let FCC know. If you want to file complaint, use this link. Be sure to fill out both sections. Looks complicated, but when you read them, not too bad.
Remember FCC will typically do not act on issues unless enough deaf/hoh complains. So complain away…
eyes open & thumbs up,
Ed B
long link:
https://esupport.fcc.gov/sform2000/formC!input.action?form_page=2000C
All..
This one is an interesting letter addressed to selected powerful congress people.
NAURC is the National Association of Regulatory Utility Commissioners; in other words, Public Utility Commission, Public Service Commission, and any state regulatory agencies that overlook telephone, electricity and other utilities. Not all states agree with NARUC’s philosophy, but apparently by majority do, though.
Essentially the letter does not want Internet to become federal Jurisdiction, instead that states have jurisdiction and states reasons why.
Here are quotable quotes:
"..our strong opposition to a recent letter from discrete industry interests seeking “legislation affirming that all Internet Protocol (“IP”)-based services are subject to exclusive federal jurisdiction."
"The requested law eliminates State consumer, market, and infrastructure protections. On its face, it is anti-consumer, overbroad, biased to benefit one technology, and, if enacted, will undermine competition and likely result in other unanticipated and unfortunate consequences."
"Your State regulators know problem areas and have keen insights about communications markets and the impact of federal legislation in your State."
"..the federal government will always lack the human and fiscal resources to handle ALL customer complaints and concerns from across the U.S. State commissions handle thousands of consumer complaints every year, and generally provide individual relief in a matter of weeks.."
There are more quotable quotes, so please click and read on.
I have this to say. A big "however". However, the concept will not work with subsidized relay services (VRS, TRS, and IP) because states are likely to use RFP to choose one provider instead of allowing ALL providers compete. This letter really is about states taking over jurisdiction of IP services – but here is the key, ALL of IP services as opposed to one. States are able to do that and allow competition among providers; unfortunately, States are not able to do same thing for subsidized services like TRS, VRS, and IP (so far only California has that, and even then still limited).
So I am opposed to what NARUC wants and I understand many of you feel the same way as well.
I have nothing but high respect for NAURC. As I worked for a state regulatory agency for 19 years and have given a presentation at a NAURC convention. That said, I do not think mover and shakers of NAURC fully understands TRS issues, subsidized services, and the nature of competition among subsidized TRS service providers.
The last quote in this edsalert, unfortunately, is true. It does take federal agency a long time to resolve issues – often years. One of the exciting possibility for 2010 is a couple of congressmen are considering strengthening FCC and its oversight over TRS by giving more funds to these departments.
We must never lose the sight that to make a service nationwide, the only way to do that is create a federal law that requires that. There never has been a service that states provide without a mandated federal law; a few actually did, but not all states so it requires federal law to require ALL states to provide relay service. TRS and closed captioning are classic examples of that.
This NARUC letter’s opposition to federal jurisdiction may remove that and we cannot allow that.
eyes open & thumbs up,
Ed
Long Link:
http://www.naruc.org/Testimony/10%20%200106%20NARUC%20IP%20preemtion%20response%20%20ltr.pdf
All..
Captioned Telephony and VRS are one of the few features left that are not "required" by the TRS regulation.
The FCC Consumer Advisory Committee has released a recommendation that Captioned Telephony be required so all states will have to comply and provide this valuable service for hard of hearing persons.
If my memory serves me right, one of the reason why it has not been mandated yet is because it is a monopoly service and owned only by one company. Does that rationale still hold true, or has the importance of captioned telephone service outweigh the patent issue? Will be interesting to see how FCC responds.
eyes open & thumbs up,
Ed B
Long link:
http://www.fcc.gov/Daily_Releases/Daily_Business/2009/db1208/DOC-295070A1.pdf
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