Ed’s Telecom Alert

All..

I guess I need to make habit of saying the following remark first.

Disclaimer:  I am owner of Edsalert, and I also am a co-founder of Convo so take this post for what it is.  

That aside. 

FCC just now released ruling on problematic issues.  

FCC Ruling

Quotable quotes:

"First, we emphasize that VRS calls made by or to a VRS provider’s employee, or the employee of a provider’s subcontractor, are not eligible for compensation from the TRS Fund on a per-minute basis from the Fund, but rather as business expenses."

At first glance, this seems to be reasonable; however, in analyzing this – maybe not.   If all VRS providers actually put in business expense of all the calls their employees made, it means NECA would need to recalculate the reimbursement rate and the rate will likely shoot up. 

Also, there are now several VRS providers who has mostly deaf employees and owned by deaf employees, does that mean they no longer can use VRS to make legitimate business calls?  For example, hearing persons in other VRS providers only pay from 1/2 cents to several cents per min while VRS provider pay full cost of video interpreter (lot more than 1.2 cents to a few cents).  Is that functionally equivalent?  

"..two categories of calls do not meet the definition of TRS or otherwise are not compensable from the Fund under plain statutory language: (1) VRS Voice Carry Over used to connect two hearing users and (2) VRS calls used to connect two users who are both outside the United States."

This one, I agree.   This is where a deaf person calls VRS and says will use VCO and once communication is connected to a hearing person – the deaf person lets his hearing friend or relative "take over" while deaf person just watch.   This is being done to avoid long distance calls.  Typically to another country.    That’s clearly cheating.  

eyes open & thumbs up,

Ed Bosson

Long Link: 
http://www.edsalert.com/wp-content/uploads/2010/02/VRS-DR.doc
or
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-10-314A1.pdf 

Yo Folks…

Check the growth, but particular pay attention to 2008 and 2009 years.   Upwards then slowly downwards.   The end of Sept 2009, according to NECA website was 7,831,011

VRS Growth

Got from NECA’s reports the following:

Projection vs Actual meaning what NECA projected based on historical data and its best analysis.  

The percentage indicate projected data is close to what was projected or not.  

October 2009 (reimbursed on Dec 2009 to vendors)

IP Relay:  -12.2%     Projected  5,665,167 down to actual 4,975,801
VRS:        -18.0%     Projected 10,333,738 down to actual 8,468,606

November 2009 (reimbursed on Jan 2010 to vendors)

IP Relay:  -23.8%    Projected 5,472,814 down to actual 4,171,883
VRS:        -20.6%    Projected 9,890,288 down to actual 7,853,287

So it seems that by basing on historical data and NECA’s analysis are not the same as actual data. Why is NECA off?  Is it because NECA did not take into account or more likely this did not expect how much the activities of FBI, FCC, and illegal/unethical actions impacted the VRS growth?

The percentage looks like a large drop, but by looking at actual calls. we see that from Sept to November show almost same data.   However, by looking at the VRS growth, we see that on March 2009, there was 9 million minutes.  So VRS did drop from 9 million to Nov 2009’s 7.8 million.  That is approx 13.3% drop.  

Is VRS industry getting to stabilizing point?  I don’t think so. Your thoughts, Readers?

eyes open & thumbs up,

Ed Bosson

Long Link:  http://www.edsalert.com/wp-content/uploads/2010/02/VRSGROWTH-5.pdf

All..

Long LInk:
http://www.fcc.gov/eb/Enforcement_Advisories/Welcome.html