Canada Assoc of the Deaf Submits Comments

8 06 2010

Folks…

CAD – not unlike NAD – submit its comments along with Sign Relay Canada on FCC’s ruling that no call centers outside of USA shall provide VRS for USA.  

CAD Comments

Comments indicate that despite more than 8 years of lobbying by CAD, and other organizations as well as individual, Canada still does not have VRS.   I sincerely hope that Canada government ultimately understand the underlying needs of deaf-hoh in telecommunications access and realize that VRS is the best service for the deaf-hoh.  I feel the pain of deaf Canadians as I went thru first 20 years of my life with no TTYs let alone relay service (no, I am not that old ;-)

Quotes: 

"..recently cracked-down on ineligible calls originating in Canada, there is little consistency or clarity in the implementation of the relevant rules; for example, some providers still accept calls originating in Canada as long as the callee is located in the U.S., other providers do not. Thus, the Commission needs to set and enforce a more comprehensive policy regarding the eligibility of VRS calls that originate outside the U.S."

Below is reference to establishing call centers in Canada.  

"..there has been an immediate siphoning of the available pool of interpreters in the affected community as these skilled professionals are attracted to the salaries, security, and other benefits offered by VRS providers. Hundreds of requests for community interpreting services must be turned down each year as a consequence of this drain upon the supply of interpreters. We know of dozens of cases in which Deaf Canadians have been forced to leave school and post-secondary institutions, have lost jobs or job interviews, have been denied important medical services including mental health or substance abuse treatments, and have missed out on meetings relating to vital social supports, because interpreters are no longer available once VRS call centres have been established in their region."

Wow – these are very strong words, indeed.   In the early years of VRS, USA experienced the same thing – but not anymore now – well – at least not as much anymore.  

"As it stands now, American VRS is a predator that is doing profound damage to the lives of Deaf Canadians without any offsetting benefits to us."

Now that is generalizing and not fair to VRS industry.  To my knowledge, only one VRS provider have call centers in Canada and that’s SorensonVRS.   SVRS although the largest VRS provider is most certainly not representing USA in VRS industry.  I wish CAD comments would list the VRS providers that have call centers in Canada so other VRS providers who do not have call centers in Canada will not be damaged by this generic accusation.  

Finally this quote:

"For the above reasons, the CAD and SRC recommend that either American providers of VRS be required to locate all of their call centres in the U.S., or that the Commission permit the extension of reimbursable VRS calls to include calls originating and terminating in Canada that are made through the providers that have established call centres in this country."

I agree with CAD that American Providers be required to locate all the call centers.   Indeed, VRS providers should report to the FCC all listed call centers.  

Where CAD says FCC should permit extension of reimbursable VRS calls to originating and terminating in Canada? What this is saying is USA should permit USA funds to pay for Canada VRS.  Oh,that can amount to many millions of dollars annually!   Even though Canada is friend of ours, I think Canada should pay for its own VRS, not USA.

However, I can say that America VRS providers would be happy to provide VRS if Canada is willing to pay for the service.  

eyes open & thumbs up..

Ed

Long Link:  http://www.prodnet.www.neca.org/publicationsdocs/wwpdf/6410cad.pdf


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38 responses to “Canada Assoc of the Deaf Submits Comments”

8 06 2010
Jack Higgins (09:16:08) :

Isn’t it amazing that the FCC can spend so much time investigating fraudulent VRS billing. Maybe if they spent a little more time drafting clear and concise rules for TRS service providers most of this ” fraudulent ” billing would disappear. When you combine ambiguous rules with government employee interpretation you get the current mess

8 06 2010
Live Free or Die (09:20:05) :

FCC funds should stay in America. Keep jobs for the Americans! I do understand the concept of globalization but we are already doing that heavily with a lot of other things such as TV’s, phones, electronics, coffee, food, and so on. Preserve what we have in America and keep something that we are good at too!

8 06 2010
Phil (09:21:07) :

SORENSON abuses the system! FCC, wake up and smell the coffee.

8 06 2010
Andy (09:38:05) :

What took FCC so long to act? Our deaf friends in Canada have been taking advantage of our VRS at our expense for years and there’s no secrets about this if you ask them.

Unfortunately my American parents live in Canada for 5 months so it means I can not call them using VRS from here USA where I live if the rules go into effect. There has to be a better way such as requiring verification instead of just signing up for ten digit numbers online.

8 06 2010
Kelley (09:46:27) :

If text relay is allowed to operate in other countries and VRS is under the same structure, shouldn’t VRS be allowed to operate in other countries too?

8 06 2010
Canadian Association of the Deaf's comments on FCC Declaratory Rulings of rulemaking - AllDeaf.com (10:43:11) :

[...] Way to go, Canadian Association of the Deaf! Ed’s Telecom Alert Canada Assoc of the Deaf Submits Comments Ed Bosson's thoughts on their [...]

8 06 2010
Warren (11:07:05) :

that’s where all VP100s are in Canada. WE as taxpayers pay the fees for using VRS. If Canada wants the VRS, VRS can either bill them or have taxpayers in Canada to pay for the VRS.

8 06 2010
Nick Vera (11:16:56) :

Truly appreciated very much with Deaf Canadians to fight for VRS system in their country as follow our models of using VRS/VP system in our country. I am hoping that in the globalization for the deaf community should receive the VRS/VP in their country to access the equal communication in workplace, home, and other places to useful.

When I was in London staying with my deaf couples in 1998, I am longstanding members of AOL with the whole package of IM, e-mail, and website navigations. I learned that the deaf guy explained me how to use the e-mail where the message sent out as the same as you call in per minute in according of the telephone bills in charges that you made. Surprisingly enough, we have the different approaches between the charges of e-mails and our unlimited e-mail uses in the U.S. and U.K.

8 06 2010
edsalert (11:50:06) :

Kelly,

Text relay – if you meant Internet text relay more commonly known as IP Relay then IP Relay is NOT allowed outside of USA if provided by USA providers. In fact, IP Relay service providers are not allowed to process ANY IP Relay calls to outside of USA even if one originate in USA and other terminate in other countries.

Only traditional TTY relay service and VRS are allowed to make relay calls that originate/terminate in USA and the other outside of USA.

NONE of USA relay service providers process entirely non-USA to non-USA.

eyes open & thumbs up…

8 06 2010
Terpgirl (13:40:41) :

I heard TTY relay has some centers in Phillpines but CALLERS are in U.S., labor in Phillpines. Is that a rumor?

8 06 2010
Anon (14:08:55) :

VRS IS NOT PAID FOR BY TAX PAYERS.

VRS is paid for by people who have phone bills.

This cannot be stated enough times.

8 06 2010
edsalert (14:13:17) :

Anon,

You are right about that.

The fee or surcharge, however, is hidden from the phone bills because relay regulation does not allow that to be shown on phone bill.

Terpgirl,

On the call centers in Philippines, I heard the same thing, too. I know in the past there were other countries providing text relay service. I am not sure if that is still true now, though.

eyes open & thumbs up..

8 06 2010
ProCanadaTerp (14:54:55) :

The question posed by the ruling about centers in other countries is about whether or not there can be adequate supervision if the center is in another county… And they propose in the same ruling that there somehow can be adequate supervision if a VI is working from home without a supervisor?! That doesn’t make any sense. I would rather have a center in Canada where there is a supervisor than terps at home intheir PJs with their kids watching just out of camera shot!

Also – I’m with Kelley – if text relay can operate centers in other countries, why can’t VRS have centers in other countries? There is no rule prohibiting text relay centers from operating in other countries.

Anon – whether you call it a fee or a tax or surcharge – it is still subsidized by people who aren’t actually using the service. That type of money needs to be used very carefully.

8 06 2010
DeafWarrior (15:38:39) :

Ed, thanks again for keeping us informed. I see clearly how addicted we are to VRS. We are truly spoiled. Although the TRS fund is paid by telephone users, I propose again that it is time that we defray some of the cost for our conforts. There are some serious changes coming and we will feel the pain of those changes. The FCC will drop the rates, no doubt about it, it is time that some of the so called deaf friendly providers start to look at ways to become not only totally legal in their management but also innovative in ways to provide the service. Again I am all for equality, but lets be real, there are a lot fo deaf and hoh that simply are complaining because they are taking advantage of the service without giving anything back. Canadians use other methods that are still suitable for communication. If the FCC would truly send investigators to each VRS provider they will see the truth about where all the money goes to. Management greed!!!

8 06 2010
Adam (17:00:35) :

@deafWarrior – the FCC does know exactly how much each person at each VRS company makes. They just don’t disclose that to the public.

8 06 2010
arpy (17:35:22) :

Anyone have any idea how much Telus and Bell Canada have agreed to pay Sorenson for providing VRS service? This would make for a very interesting comparison between what the company says and what they do. It may be that Canada has agreed to pay Sorenson $5+ per minute. If so, good for them. If it is much less than that, though, it will call into question much of what we have been told about “bankruptcy” won’t it?

Does anyone have this information?

8 06 2010
edsalert (18:00:36) :

Adam,

No the FCC does NOT know how much each person makes in VRS providers. That information is not shared with FCC.

Arpy,

Telus and Bell Cnada are NOT paying Sorenson for providing VRS Service. What is happening is Sorenson created Call Centers in Canada to provide VRS to Americans, not to Canadians. US pays for that. Apparently, not any more.

ProCanadaTerp,

Recent FCC Public Notice indicate interpreting from home is frowned upon. Really, there is already regulation – not necessarily relay regulation, but telephone regulation that requires call centers be operated from company, not from home.

Text relay from other countries if FCC knew about these, FCC will not reimburse these services which is why FCC is requiring all relay providers to give location lists of all their call centers.

eyes open & thumbs up…

8 06 2010
Terpgirl (18:10:57) :

“On the call centers in Philippines, I heard the same thing, too.”

I heard it’s Hamilton. Let me check with my text relay sources.

9 06 2010
Henry (00:00:41) :

I am often the lawyer for CAD in CRTC – same function as FCC in USA – matters so know of what I speak.

Telus has a contract with Sorenson to provide a trial of VRS in BC and Alberta. It is scheduled to start July 1st. We do not know how much Telus will be paying Sorenson. This is confidential information that may be reported to CRTC but is not shared with anyone else. I am sure Sorenson will be making a profit and so there will be no subsidizing it by you USAers.

Bell will be doing a trial of VRS in Ontario and Quebec but has decided to do research first and is working on that research now. Then the trial. No announcement as to who will be conducting the trial – could be Sorenson again or could be someone else (Convo going to bid to do it?)

Sorenson has quite a few – 6 last time I was told a number but could be more now – VRS centers up here in Canada to serve the USA. These do not serve Canadian callers. ASL in Canada and USA are pretty much the same and interpreter training and standards and all that are also very similar so most likely you USA VRS users will not be able to identify if it is a Canadian interpreter handling the call.

9 06 2010
Terpgirl (02:28:26) :

I’m happy for Canada and I hope it will spread to all provinces and territories very soon.

9 06 2010
arpy (03:27:07) :

Henry,

Thanks for the info. I had read that like Telus, Bell Canada contracted with Sorenson. I must have gotten it wrong and appreciate the clarification. One comment on “standards” of interpreting– AVLIC’s standards for certification are far more stringent than RID’s. Too strict, some say, but then many here in the States think that RID’s standards are too low, so there you have it.

9 06 2010
edsalert (07:11:30) :

Henry,

Likewise glad u clarified as I was not aware of the pending contracts.

Arpy,

I get recurring messages that oftentimes state’s certifications are better than RID’s. I know that many interpreters in Texas that failed Texas’s evaluation were able to pass RID’s evaluation. But to be fair, I also have heard interpreters failing RID and passing Texas; however, so far based on feedback the number of failures is greater on Texas’s side and passing with RID’s side.

I think this will be a good post in edsalert in the near future as I am curious about other states. Now with this AVLIC’s adding to the pot on quality of interpreters as well.

eyes open & thumbs up..

9 06 2010
Henry (09:57:11) :

AVLIC – Canada’s equivalent to RID – has only one certificate. Either you are competent or you are not! And yes, very few get the certificate – last number I had was just 101 for all of Canada. But COI (certificate of interpreting) from AVLIC is not a requirement very often and certainly not for VRS interpreting. Sorenson is going to require AVLIC membership – which is completely different! – for the interpreters in the trial.

9 06 2010
Henry (10:09:59) :

Went to avlic website at http://www.avlic.ca/store/directory.php and checked their membership list. There are only 52 COI listed in Canada!

9 06 2010
Telus has contracted Sorenson VRS to provide a limited VRS service on trial basis. - AllDeaf.com (12:54:01) :

[...] has contracted Sorenson VRS to provide a limited VRS service on trial basis. Ed’s Telecom Alert Canada Assoc of the Deaf Submits Comments You come to check one of Henry who happens to be Henry Vlug, a well known Deaf lawyer in Canada. [...]

9 06 2010
Terpgirl (12:59:21) :

I think I remember that at CSD, if you wanted to make an international call, fine, but you had to give us your credit card number. We were required to provide the interpreter for free, but not the international call from the United States to the other country. Other places I have worked have done the call for free. I’m not sure if CSD still does it that way. Does anybody know?

9 06 2010
arpy (16:56:27) :

Ed,

Yes, it is true that some states have standards that are more rigorous than RID’s. National standards have been an elusive dream for RID for at least 40 years.Years ago interpreters would flock to certain places to take the test, because those places were known to have more lenient scoring. That changed a little bit over time as RID tried to be more righteous in the way they conducted the testing, but it has taken a huge step backwards in the last couple of years as the pass rate for the exam has almost doubled. Some people blame the newly minted NIC test-prep industry for “teaching the test” but the fact is that as long as RID insists on using point-in-time testing (one chance at the written, then one chance at the interview and one chance at the skills part) the results will be compromised. There are other external factors that play into this. Language testing in general has moved away from point-in-time testing to portfolio assessment, which looks at a variety of samples and evidence. RID will, too, sooner or later. Until then, though, states and local agencies will have better tests because they are more familiar with both local custom and local standards.

10 06 2010
Lee (09:49:15) :

@Adam – I’m thinking that you’re referring to the companies that were audited by the FCC, though I don’t think they know specifically people’s salarys, just departmental salary/benefit expenses.

10 06 2010
Betty Boop (16:48:26) :

Andy, you can call your parents while they are in canada under current fcc rules. Regulations that all calls must either begin or terminate in USA. So if they reside in America and you are in Canada you can call them through VRS. However if both are located in Canada it cannot be done. But i know that people are actively trying to persuade the Canadian goverment to get on board.

10 06 2010
Henry (17:37:47) :

Right, Betty. Technically that is what can happen. But unfortunately in real life there is a very good chance – my estimate is at least 75% – that the VRS interpreter will not know the technical rule and will refuse to make the call! And it takes some technical expertise to make the call from Canada to a VRS provider!

11 06 2010
Terpgirl (00:43:37) :

I interpret calls to and from Canada all the time. I have no problem with it. I think it’s what we’re supposed to do. If it’s Canada to Canada, yes, I have to turn it down. I don’t feel good about it, and I’m hoping Canada gets their own service soon. After all, most calls are not international. People have a need to call others in their own country on a far more regular basis than they do to call out of the country. Canada has a lot of cool things that the United States does not have. I guess video relay is the grand exception, but the sooner that changes, the better.

11 06 2010
DeafWarrior (09:49:44) :

Adam,
You must work for a provider. As you do write like you have internal knowledge. Nevertheless, I am still stating that we do ask for a lot and we are a spoiled group. It is time that we do get off our victimized position and move on to the real issues. Why would everyone that has a phone bill pay for these services. To be equal we must then bear some of the cost. Again, if the FCC or the goverment were to actually go to each provider and see and evaluate their practices I am sure they will find that a lot fo these providers are using the deaf and hoh to their advantage. Someone that worked at one of the providers told me that the upper management portray themselves as deaf friendly, then behind their backs they talk about how the deaf and hoh are nothing but cheap labor. This person told me that in 3 years he never got a pay raise, even though management did “promise’ him one. At any rate, lets get moving forward, I know that technology is developing at a very fast pace. I am wondering how the video technology is overseas.

11 06 2010
Betty Boop (12:16:18) :

Adam, i think i missed something: You state:
VRS IS NOT PAID FOR BY TAX PAYERS.
VRS is paid for by people who have phone bills.
Are not people who have phone bills also taxpayers? I know I fit into both those categories.
Essentially, the government doesn’t pay for anything because they don’t produce anything that produces money, except, of course, taxes.

13 06 2010
Terpgirl (13:44:50) :

Everyone who has a phone bill has to pay tax on the phone bill, but that is separate, I guess. Basically, from what I’m understanding, the phone companies just pay for this as an expense. How do they afford it? They raise the bill. That’s why Ed says it is hidden. They pass the cost on to us. Then they use that money to pay for it. Yes, there is a universal fund that we also all pay into if we have phones, actually clearly listed on the bill, but that just goes to a portion of the TTY relay service and certain other services. Another portion of the TTY relay service, IP relay and VRS come from the part of the phone bill that you CANNOT see. Did I finally get it right? I think the reason that we’re supposed to think of this is coming from people who pay fees on the phone bill instead of pay taxes is because taxes were there before relay existed, ages ago, but the fees were not. (There are always taxes.) This includes both the hidden fee and the fee that you see. Please tell me if I got it wrong again.

14 06 2010
edsalert (07:05:37) :

Terpgirl,

You got the right idea. A couple clarifications:

One: None of federal USF goes to relay service. Only Interstate TRS Fund pays for all of relay service. USF goes to LifeLInk, making sure schools have internet access, etc. Check out http://en.wikipedia.org/wiki/Universal_Service_Fund

Two: The purpose of hiding the fee is FCC wanted to treat relay service as part of the total telephone package which is to provide telephone services for all people including telecommunications challenged people.

We all can SEE the USF fee in the telephone bill, but not Interstate TRS Fund.

I hope this is clearer now?

eyes open & thumbs up..

14 06 2010
DeafWarrior (09:58:45) :

Thanks for clearing that up Ed. Now if every phone user would happen to see this in their bills, would they be able to contact their public officials and complaint? I am sure that some of my family would. Again, I think it is time that we bear the cost for the services and all part being equal, no more handouts.

14 06 2010
edsalert (11:13:36) :

DeafWarrior,

Not sure what you meant by your question. You may see TRS in your telephone bill, but that is likely for state relay service. In Texas and many other states as well will see a “surcharge” for TRS, relay service, whatever label they chose to call it – even State USF, but they are for state relay services only. No one will see federal Interstate TRS fund in telephone bill.

I hope I did not muddle things up, but some states use USF to pay for relay service, but again that is for state’s relay service only. Federal USF does not pay for any national relay service.

Now to muddle things up even more. There has been instances where Interstate TRS Fund fee showed up on telephone bill. This is not allowed and telephone companies probably did not know about that regulation of no info on telephone bill.

eyes open & thumbs up…

14 06 2010
DeafWarrior (12:12:49) :

Thanks Ed, now I understand it a bit better. As always thenks for keeping things clear and easy to understand. There is so much to learn and at times we can get a bit off track with some of the subjects. I think you should be running these programs..lol.

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