Misc FCC News
29 07 2010All..
Here are misc news of happenings recently – short ones.
"An extension of time is necessary and in the public interest to allow interested parties to gather information, conduct meaningful dialogue concerning the intertwined and dynamic issues presented with respect to video relay service (“VRS”), and to allow commenter to develop meaningful in-depth positions concerning this critical proceeding."
"Such an extension is particularly warranted in light of the Commission’s desire for input on so many varying critical questions relating to the VRS program’s effectiveness, efficiency and sustainability, as is the case here.
Petitioners therefore submit that a reasonably moderate extension of the comment deadline will enable stakeholders to more thoroughly evaluate and respond to the NOI and thus provide more substantive, thorough and thoughtful comments."
Basically FCC denies SVRS’s Stay Motion. Here is a quote:
"Although Sorenson nominally seeks a "stay," it asks not just that we stay the interim rates, but also that we take affirmative steps to re-institute the former VRS rate that expired on June 30, 2010. For the reasons set forth below, we deny the request."
As result, SVRS now seeks court to overturn the FCC’s decision.
Contribution factor simply means when National Exchange Carrier Association "collects" from all telephone companies, etc. to "contribute" to Interstate TRS Fund. Interstate TRS Fund is what reimburses all relay providers.
The pertinent quote that basically address the main issue:
"Based on the adoption of these rates and NECA’s proposals, the Commission hereby adopts a carrier contribution factor of 0.00585, and a funding requirement of $433,990,484.98 for the 2010-2011 Fund year.11 The Commission adopts these rates, and this contribution factor and funding requirement, for a period of one year, except as otherwise provided herein."
eyes open & thumbs up,
Ed
Long Links:
4 Petitioners – http://fjallfoss.fcc.gov/ecfs/document/view?id=7020550986
FCC Denies – http://fjallfoss.fcc.gov/ecfs/document/view?id=7020549754
Contribution – https://prodnet.www.neca.org/publicationsdocs/wwpdf/fcc10115.pdf
I’m wondering if anyone can explain how Purple was able to throw lavish parties at both NAD in Philly and Deaf Expo in LV when their $20 million bill is coming due from the FCC shortly, they owe many more millions to their investors, and they’ve been laying off employees left and right for the last year. Where did the money for these parties come from? Kind of undercuts your position when you claim poverty to the FCC at the same time pictures are being splashed all over Facebook of your alcohol-fueled lavish celebrations. Not to mention what your laid-off employees must think…
Now, I am not interesting in Purple as we are thinking about joining. Those people are not careful. I am still an old fashion spender. It means as we try not to spend money too much.
@anon,
I wondered the same thing. In between the lavish parties at NAD and Las Vegas. With no advance notice, the interpreters on site at the Minnesota Call Center was told to pack their things and leave. The interpreters asked why, the response they got was that they’re broke and they’ll be closed for a while.
A party or two that assists with customer retention and recruitment is different than running a technology based call center. The parties were single expenditures whereas keeping a call center running requires ongoing capital.
I’m with Longtime Lurker on this. We could ask ourselves how Snap was forced to close down its flagship center for financial reasons and bought Viable a year later. Gallaudet University has had to lay people off and cancel raises for the rest, but a department in the university is a platinum sponsor for one of the RID conferences. When the CSD budget was cut deeply by the FCC in 2003, they bought Camp Lakodia the following month. When a personal budget gets tight, the usual response is to look at luxuries and reduce or eliminate them. The same should NOT be done with a business, unless you plan to liquidate, in which case there is no point in anything except saying goodbye and paying off debtors. But at this point, Purple is still playing the role of The Little Engine That Could from the children’s storybooks. As long as they are in “I think I can” mode, they cannot afford to appear as if they are falling apart any more than necessary, and in the grand scheme of things, it’s not that expensive. There are some intrinsic costs in deciding to keep your company going, and one of those costs is to continue with public events at pretty much the same rate you would have if your company were not suffering. (Although I’m betting they would ask the employees who host the events to volunteer their time. It’s always the employees who get the shaft on these things.) Parties like this are not going to make or break them paying their bills. If it were an ongoing expense, such as a party every week, I could see it making a difference. If I thought for a minute that they could rehire anybody or give the 5% of pay back to their current employees by not doing these things, or better pay their debts, I’d be shouting the same sentiments. In the meantime, the real problem with Purple isn’t a party that probably doesn’t even constitute a teeny fraction of 1% of their budget. The real problem with Purple is, party or not, how in the world is it going to survive on an ongoing basis? If they couldn’t make a profit on pumped minutes, how in the world are they going to make money without it? Won’t their police contract anger the FCC? Should really be getting the FCC any madder at us at this point? And I agree – - how will they pay back that bill to the government?
tg
PS-I heard they also closed Long Beach. Anyone hear that? I haven’t had confirmation yet so I’m not sure. I hope I’m wrong. But I’m afraid I’m right.
Correction: “Should WE be getting the FCC any madder?” is what I meant to ask. Are people aware of the police contract? Does anyone know if this is being used for VRS or for VRI? I am not just slightly in favor, but DESPERATELY in favor of having on-the-spot communications with police. But that is my personal opinion. I just don’t want to get the FCC all angry at us. It seems that they’re always mad. This was true even before the fraud thing. And then the fraud happened, which would make anybody mad. Why make it worse?
tg
Lurker and Terpgirl make good points, but it still LOOKS BAD. It’s one thing to have a booth at NAD and Vegas and demonstrate your wares and services. It’s quite another to throw alcohol-soaked “VIP parties” barely six months after essentially getting busted for fraud by the Feds. Maybe they don’t care how it looks. But isn’t that how they got in trouble in the first place?
Yes, it looks bad to the affected employees. I wanted CSD to cancel the purchase of Camp L, just for the sake of impression. But that’s not how it works. They were going to go through with it, regardless. I don’t know if Purple actually got busted for fraud so much as they got told not to process the kinds of calls that they were processing on a daily basis, at least on the weekdays, because those types of calls are fraud even though they are not run calls. I’ll tell you how they got in trouble in the first place – - “Go into the other room and call me!” is how they got in trouble. So my question remains, isn’t the police contract the same thing? The deaf person and the police officer would be standing next to each other. Isn’t that VRI? Or isn’t it supposed to be?
Yes, that’s how they got in trouble, but what led to their actions was an attitude of “nobody’s watching, and even if they are, we’re going to do it anyway. Wink, wink.” That’s the same attitude that led to the parties.
As far as I know, Sorenson didn’t throw any parties at NAD or DNWE, or if they did they were extremely low-key. Probably because someone there said, “um, hey, it would look pretty stupid if we did this while we were telling the FCC their rates were going to make us go broke.” I guess Purple didn’t have anyone in management to say that to the partiers.
“um, hey, it would look pretty stupid if we did this while we were telling the FCC their rates were going to make us go broke”
ha ha i guess it would look bad!
Well, there are a lot of Sorenson employees being laid off right now. It’s not a rumor. I just had a friend in Tech Support get laid off. Apparently Sorenson is blaming the FCC rates for it and others are blaming Sorenson’s financial practices. It will be interesting to see how this affects our service.
I heard 5 centers closed and tech layoffs, too.
@Anon..
Sorenson did throw party at DNWE, they were the BIGGEST sponsor of DNWE and also threw a party at treasure island hotel for 1,000 people on thursday night.
Apparently you did not go to DNWE, Sorenson’s name was EVERYWHERE, you would think Sorenson owned Deafnation World Expo…
@TERPgirl;
it is to my understanding that the police contract in DC is a complicated issue, if its used to interpret with the police then its a VRI bill to DC, but if the Deaf person used the police P3 to make calls to someone else then it can be as a VRS so its complicated!
_______________________-
Sorenson has laid 300-400 people off yesterday and shut down couple call centers.
Purple’s Long beach call center is been suspended (not shut down) for time being..
@ CR,
As for the layoffs by Sorenson, I fully BLAME Sorenson for that because Sorenson has tried to convince FCC to allow their investors bill of $130 MILLION dollars a year to be part of the allowed costs and FCC has said NO…
If you do not realize the impact of $130 MILLION dollars, Let me put in this way 2.1 million minutes of VRS calls every MONTH goes to investors ALONE before any other expenses. That is almost 1/4 of Sorenson’s estimated 8 million minutes a month going to investors alone…..
Sorenson do not have any rights to blame FCC when they took out loans to make the owners even richer back in January, $180 million dollars cash just for the Owners of Sorenson was borrowed and Sorensonvrs is stuck paying the bill. In other words, Sorenson Gambled back in January and it is coming back to BITE Sorenson major time! That is why others are blaming Sorenson’s financial practices.
By its own admission by how they set the rate structure, FCC believes that Sorenson is most efficient VRS company. So it cut the rate by 20%, while others only cut <6% to put smaller companies where tier 3 was on June 30. While Sorenson certainly anticipated rate cut at end of 3-year rate, what for profit company anticipates that large a cut for being the best with the least overhead? Now if Sorenson does lose customers to smaller companies, it just means that FCC will pay those companies more money to serve same people that Sorenson did at a lower rate. "We're from the government and we're here to help!"
Betty Boop –
Interesting point of view. Here’s another perspective:
“Or we want a level playing field. More competitors ensure higher quality of service for the users.”
I often try out our competitors’ products or services for the sake of evaluating them. It’s quite interesting to see how the service or products vary a great deal among them. Personally I’m thrilled with the concept of having “choices” to make.
Robin
It is most unfortunate that Sorenson was forced by the FCC to lay off employees. I do not blame Sorenson as they have consistently and on daily basis, fought with FCC. They’ve opened up their fiancial data to FCC to help them understand what are the necessary rate to help Sorenson survive and continue to provide superb services to the deaf community, much like the other VRS Providers as well.
The one thing you need to understand is that Sorenson is such a large company and well run, making Sorenson the most efficient VRS company. Therefore, logic dictates that it is in the FCC’s best interest to work with Sorenson to save ratepayer money, which translates to Tier III rate. HOWEVER, at this present time, the course of action adopted by FCC has forced Sorenson to lay off employees and restructure their operations, which means that Sorenson could lose some customers to other VRS Provider. This is okay but here lies the problem…
The problem is that FCC most likely made a horrible mistake by paying more as there are no other VRS Providers that are Tier III, meaning they’re either Tier I or II. Therefore, these Tier I and II VRS Providers are billing FCC for more money that forces FCC to pay MORE for these services, which they could have pay LESS if Sorenson didn’t suffer a drastic cut in Tier III rate. If FCC goal was to save ratepayer money and be an efficient steward of the TRS funds, they are FAILING in this role.
Moreover, FCC still has FAILED to explain why Tier I and II didn’t suffer more than a dollar cut in their rate while Tier III suffered an dollar and 10 cent rate cut. This appears as a intentional attack on Sorenson by FCC as Sorenson is the only known Tier III provider.
Therefore, think about how FCC is “saving money” and being efficient with the TRS funds. Additionally, why is only Sorenson suffering the drastic cut in rate, when others VRS Providers don’t have to suffer that drastic cut in their respective tier? Admittedly, FCC has some valid points but in this case, the points they make are far too few to the points that Sorenson makes.
Lastly, do not cite the debt that Sorenson has accumulated or how much they paid their investors and such. This is a business for profit and Sorenson became the leading VRS Provider because of these business decision they made. Hence, none of you have the knowledge nor the understanding about Sorenson’s finacial structure or debt load. Even FCC doesn’t state that they have the full knowledge of their finacial structure as they cited Debtwire as their source about Sorenson’s debt.
Just think about what FCC should be doing and what their role are supposed to be. They are failing in every aspect of their role to protect the VRS Industry.
So are the other providers just going to take on the people who got laid off? There are interpreters, managers, tech support people, and others available. I am sure that they would like to work for a profitable company that can afford to hang onto them. Is there one? I’m not so sure. I don’t think that video relay is a profitable venture. I don’t know a lot about running a business, but I know what I keep seeing and have seen consistently since 2003.
Sargares,
Actually there are two VRS providers at Tier III and one very close to Tier II if not already so there are three.
eyes open & thumbs up..
The tier discussion is interesting but misleading. According to the FCC, the total usage rate is 8.5 million minutes per month.
Estimates of Sorenson’s market share range from 75% to 85%, somewhere around 7 million minutes per month. So, approximately 90% of their minutes would be at tier 3 – yielding approximately $5.19 per minute. Effectively the rate they get is the tier 3 rate.
Now, that leaves 1.5 million minutes that the other providers process. Ed says that one other provider gets tier 3 minutes and another is close to it. Assume that the total minutes processed by all but the top 3 providers is 200,000 minutes. That would leave around 1.3 million between provider 2 & 3. Since provider #3 is only approaching tier 3, their effective rate is a combination of tier 1 & 2 – approximately $6.24 per minute.
That leaves provider number 2 with 800,000 minutes tops. If that’s the case, the second provider’s minutes break down to approximately: 6% tier 1, 56% tier 2, and 38% tier 3 – approximately $5.80 per minute. The majority of their minutes are in tier 2, so the effective rate for the second provider is substantially higher. [It's far more likely that provider 2 is getting in the neighborhood of 600,000 minutes and getting a rate around $6.05.]
I think Sargares’ point about the interim rate being disproportionately punitive towards Sorenson is valid.
This must be one of the reasons they made us study percentages in school.
From the FCC perspective, all providers should be getting the same profit, no matter which Tier they are in. Therefore profit is not to be a driving force in running one’s business. The Tier structure is set up to reduce the profitability of higher production, thus making efficiency of production less profitable. If a company can delay hitting the Tier three threshold until the end of the month they will do better for themselves. But that means at some point you stop picking up the calls. But the company that stops picking up the phone will be punished by losing their certification. Thus one becomes too big, too popular with the customers to succeed.
And if you think this isn’t the FCC’s retaliation for
losing previous court battles, on what do you base that opinion?
It should also be pointed out that even with the higher rates, Tier I and II companies still cannot generate profits and that’s somewhat surprising given the fact its been acknowledged by the FCC that VRS providers have been overpaid since the inception of the TRS Fund.
Another issue that hasn’t been addressed is that NECA only reimburses for intepreted minutes, those minutes that an interpreter is connected to 2 callers. They don’t pay for interpreters waiting for calls. If a company has too many interpreters waiting for calls, that is inefficient. If they don’t have enough or any waiting for calls, wait times go up and customers (including FCC) are unhappy. Only about half an interpreters paid time is actually billable time. So if the cost of a minute seems high, remember that the company must pay for all their time. It is a continuing balancing act to remain profitable while making sure that are enough interpreters to handle the calls and take care of themselves so they can remain healthy, but not too many to tip the scale in the other direction. Some calls require more than one intepreter (legal, conference call) , but reimbursement rate doesn’t change. Cost of interpreters is the largest part of the equation because of limited pool of interpreters in any one area and the special skills they bring to the job. That cost doesn’t go down after 500,000th minute.
Maybe it is time for the providers to not view the TRS Fund as the only source of income. Providers should start monthly subscription services for extra features not covered by ADA’s mandate. And this way, customer tie-ins should be viewed as acceptable. After all, we do have monthly plans for our pager services. Why shouldn’t we not expect the same for our telephony needs as well?
This is why I think the interoperability rule has stunted the innovation and introduction of new products in the VRS industry (with a few exceptions). Instead of developing their own products, many providers are piggy-backing on Sorenson’s VPs. Competition and all of these pie in the sky justifications re: interoperability did not come to fruition and we do not really have any viable VRS products other than the VP-200 and laptops/netbooks.
Customer choice is really a myth. Yes, we have the right to choose our own providers, but the providers also have the right to demand that customers sign a contract agreeing to fork over $ every month. It’s a joke for them to call the ability to use any VRS provider without any obligations at all as customer choice. This ‘customer choice’ yields no positive benefits for the providers. They do not have an expected stream of income from its subscribers. That is not how the telecommunications industry works. And this certainly isn’t competition. It’s an 100% (or even maybe up to 200%) subsidization scheme with nothing much to show for it.
We as customers have the choice to choose our own providers but we must also start acting like customers, not welfare recipients in order for the VRS industry to thrive.
“extra features not covered by ADA’s mandate”
Can you give examples? VIU tried this, with both Deaf and VI input, and it blew up in their faces.
I also find the whole discussion about SVRS’ debt load irrelevant since that expense is not a part of the “allowable expenses” that FCC considers when setting rates. The money that SVRS paid to its investors is considered Return On Investment, a common business financing concept and undoubtedly required by the terms of the initial investment. Private investors invest money in a business with the expectation that that money will be returned with interest on a schedule. So the company fulfilled its business agreements. It also took out a loan to take advantage of lower interest rates, thereby saving money. Apparently it was pretty smart to do so when it did because at that time SVRS was deemed by it’s creditors to be worthy of the risk. And assuming normal business conditions, like the FCC won’t punish a company for doing the most with the least amount of reimbursement. Be assured that investors knew that the end of the 3-year rate was coming mid-2010 and the rate would be adjusted. If they didn’t then they have no one but themselves to blame since it was public record.
CSDVRS’s recent petition brings up another cost. They’re petitioning the FCC to force VRS companies that provide videophone equipment to continue to maintain and add enhancements even when the VP user ports the phone number to another provider.
That sounds fine and all butmeans that those companies will be taking on an expense and receiving no income related to it. The FCC needs to address this in their next rate structure.
Betty Boop,
I must say I enjoy reading your commentary, even though I usually disagree with the conclusions you draw. In particular, when you say that VRS companies must do this and that to “remain profitable”. Using publicly available data, it is possible to determine that last year the TRS fund paid out about $624 million on about 100 million minutes. The data provided by industry showed that the cost per minute amounted to about $380 million, meaning that companies “remained profitable” to the tune of $244 million dollars. I guess we can agree that that taken as a whole, industry has done quite well at “remaining profitable.”
And, no, the $3.80 a minute doesn’t account for all of the costs entailed. It does, however, account for all the costs companies agree to before being certified to offer VRS service. If companies don’t find these expenses acceptable, they shouldn’t offer the service. I think the only reason that debt maintenance came up was because Sorenson cited it as one of the reasons that the $3.80 figure was misleading. I do agree with the general principle you express that this figure should neither be considered nor reimbursed.
However, there is another, deeper issue here, and that is one of basic fairness. I first became involved in VRS as an interpreter in 2003. Back then it was understood that interpreters would have to make some very serious compromises to our professional practice in order to get this service running. We did so because we cared about it. In the time since we have sacrificed discretion, teaming, professional judgment and integrity, and safe working conditions, just to name a few things. We did that willingly, for the sake of realizing the possibilities that VRS afforded our deaf families and friends. No wonder that so many of us feel like chumps today to find out that those enormous sacrifices weren’t made for the sake of making the service possible. No, they were made for the sake of allowing a very few people to earn a profit of $240 million dollars. From the perspective of today, it’s hard to see this as anything other than a massive sellout on the part of interpreters.
If you had asked in 2003 if interpreters would put a price tag on things like professional judgment, teaming, discretion, working conditions and the like, I doubt that anyone would have said yes. Today we have data showing that interpreters earned about $200 million dollars working in VRS last year alone. I guess there was a price tag after all.
Arpy (still waiting for props for Espagna as Campeones del Mundo…)
CSDVRS’ recent petition is a joke and very much anti-competitive. This brings to TerpGirl’s question about costs not covered by the ADA mandate. My answer is that the ADA says that the TRS Fund is to pay for the costs of accommodating relay users as they converse with a non-Deaf phone user. Simply put, that’s basically the costs for the interpreters and the calls needed to complete the 2nd leg of the relay call. Everything else that does not contribute to the accommodation should not be covered. And that includes call forwarding, contact list information, and the like. While they are features we take for granted, they do not contribute to the accommodation.
So, this is where the relay user comes in as a customer. Perhaps there could be a monthly subscription fee (and tying down the customer to a provider for a specific period of time) and that would go towards all of those features we take for granted (and any new innovative ones) and perhaps the videophones could be ‘leased’ at a cost to cover maintenance and replacement costs, etc. There is no reason using VRS has to be absolutely free for us, just that it has to be at a rate no greater than the equivalent for non-deaf phone users…
Also, has any VRS provider considered promotional plans working with internet providers to come up with a plan that provides internet and VRS service at one monthly rate? Like Comcast’s $99 a month for phone, cable, and internet…
I just don’t think it will work. Once something is free, it just doesn’t ‘go over’ to start charging for it unless you announced that it was only temporarily free from the beginning. Just ask Video Interpreters United if you don’t believe me. Naturally, there would be no cost to having the interpreter. Part of the issue is that people are spending a fortune on high-speed Internet. Yes, many of them have cut off their house phones and are using their TTY’s as paperweights to do it. However, in most cases, high-speed costs a lot more than basic phone service would, especially if you don’t tend to use long distance. Most states offer a very cheap phone plan for the poor, but there is no such offer for Internet. So this is already costing them more to have for “free” if they were the kind of person who did not use long distance or if they had an unlimited long distance plan in their home. I’m not disagreeing with your ideas. I just don’t think they’ll work any better than the last time it was suggested. However, if we can come up with some kind of NEW offer to add on, and charge for that, and it’s valuable enough to pay for, maybe it could work. Yes, consumers control a lot more about their lives than recipients do. Or, in the words of the FCC, ” beneficiaries.” I just don’t see how it would work this time. It nearly exploded the last time.
Terpgirl,
I guess I’ve been living in a cave. What are you referring to regarding “fees and VIU” and it “nearly exploding last time…”??
Thanks.
arpino
Back in January or something, a new group formed called Video Interpreters United. It’s a good group, I joined them in real life and on Facebook, I’m not putting them down, but they kind of came on the scene and instantly sent the community into an uproar, because they created an FCC filing in which they recommended the very thing you state. No, you would not have to pay for an interpreter to interpret your phone calls (nobody ever suggested paying for TTY relay operators to relay your phone calls), but in order to control the development of different types of video phones and drive the industry and have some say in a better-developing market, they recommended that people pay for their point to point calls. In other words, if you called another Deaf person or a hearing friend who signs, without an interpreter, you would pay for that service, either per minute, per call, or with a monthly unlimited fee. I don’t know where the money was supposed to go, but the idea was to create a market similar to (or parallel to) all the different telephones we see on the market today and have seen since the invention of the telephone. There are so many different types and each have their own features that different people prefer, and the idea was to replicate that for the Deaf community. The group was made up of VI’s and Deaf people. The leader of the group is Gina, who has commented on here in past months, because she was the person who originally turned in Viable (and later, Purple) and she felt that if EVERYTHING remains free, development will be stifled or at least very limited, and VERY low tech. They made a good point, but the idea of charging money for something that is already free, and the idea that if you’re paying upwards of $49.99 per month for high-speed Internet, it’s hard to call something free in the first place, the filing and the ideas in it actually offended people and turned them off to VIU. The group then changed their tune and said that they would instead focus on their other ideas that were also in the filing but that nobody noticed, a safe work environment and the idea of having Deaf interpreters. Unfortunately, we can barely get them to pay for HEARING interpreters in an UNsafe environment, as reality would have it.
Ahhh, thanks for the explanation. I joined this group online, too, but never heard another word from them. I read their ex parte filing, and thought it made a lot of sense in a lot of ways.
For what it’s worth, I think the “functional equivalence” battle is going to heat up sooner or later, in terms of access and quality. As costs skyrocket and abuse persists, it’s only a matter of time before people try to define what we have now as “functional super-equivalence.” Personally I have no gripe with the offer of unlimited worldwide long distance calling to deaf people. Just as I have no gripe with massive cradle to grave support for education for deaf people, since the quality of deaf ed in general is pathetic and the least we can do as a society is to provide for the education of our citizens.
Still, it’s hard to see VRS as currently offered as “equivalent” to the dial tone that I (and I would guess, most hearing people) have. Beyond baseline service, that is the best dial tone that I can afford or choose to pay for. As it stands now with VRS, as long as you have access to a computer and videophone, you have access to the same level and quality of service no matter who you are. Not everyone has access to a computer, but not all hearing people have access to phones, either. Access to better quality service for wealthy deaf users than poor deaf users? That’s functional equivalence to reality.
So you get better interpreters for more money? How would it actually work? That’s the problem.
No, not necessarily better interpreters, but better interpreters might be part of a package of better access.
The current rumble about net neutrality is, I think, a bellwether. If the FCC allows ISPs to expedite preferred internet traffic based on financial relationships with private industry, then who is going to pay and how much will they pay to establish an acceptable level of quality for VRS service in this new internet environment? And how much will people be willing to pay to upgrade from service that may be lower in quality / slower in speed than what we now have?
If this does happen, it could be a gold mine for small, nimble VRS companies with gold-plated interpreters. Of course, it could also be a real boon to companies with very deep pockets. But then there are no such companies. They are all teetering on the brink of bankruptcy. Smile.
Time will tell.
By the way, the petition by the 4 VRS companies referenced above in the blog post has been denied by the FCC last week.
But they’ll be paying the ISP’s, not us. Even more. How will that help VRS survive?
tg
I recently posted a comment to the FCC’s NOI in the ECFS docket 10-51. When it appears there, I’ll post a link.
While my comment was 4 pages long, I did bring up the issue that Deaf/HH consumers may have to begin paying a monthly charge for using the VP network and equipment. Might as well as don a flame-retardant suit now…
BTW, the deadline in commenting on the FCC’s NOI is tomorrow! Do your part and comment. The FCC would love to hear from VRS consumers.
TerpGirl,
I guess I was talking more about the “evolution” of VRS than I was about its “survival”. The survival of VRS is not really in question. I honestly don’t believe that the only way VRS can continue is if income exceeds costs by at least 33% each year. The technology now exists. Moving forward if some refuse to engage in innovation because they can’t reap huge profits, so be it. We have long suspected that some were in this just for the money. VRS will still be fine. I don’t believe the ADA requires state of the art technology in either video or interpreting. Qualified, they say, not certified. It’s been nice to have it, but we can do without. We’ve already seen that we don’t need topnotch quality interpreters. There is no reason to think that we can’t also do without cutting edge technology.
But more to the point, I think the ONLY way VRS can survive is if it evolves. The early days of easy profits and lax oversight are over. They brought us a long way, but they can’t take us much further. If nothing else, the economic and regulatory environments are just too different now to think that we will keep paying at minimum 33% above the agreed-upon reimbursable costs. The “function” to which we seek equivalence is a moving target. Scaling the level of service by the ability to pay is standard practice. Paying the ISPs to upgrade quality is a given, in the absence of net neutrality. In this model, VRS survives by adapting to the environment. Companies that can offer consistent high-quality interpreting service will find a market. Everyone else can shop at CallMart, where they will find easy access to the possibility of communication, which is the way it is now (minus a probable downgrade in internet quality) and is, after all, the most basic functional equivalence to a dial tone.
VRS is offered in different ways in other countries around the world. We seem to be the only country that believes that VRS can only be done for (considerable, in some cases) private profit. Maybe we can learn a little bit from the way it is done other places. Heck, we’ve tried it as big business. Maybe we should also try it as big interpreting and then compare the costs and benefits. That would be interesting.
That was fast. My comment can be found here at FCC’s ECFS site.
BTW, Convo just submitted a very comprehensive comment on FCC’s NOI. Go look for it in ECFS in docket 10-51. Just read it, and it’s a very good start on the NOI process.
Is there still time?
Terpgirl-
Yes. The deadline is tomorrow. I dunno what time tomorrow (EST), specifically, when the NOI comment period is ‘officially’ over.
“if its used to interpret with the police then its a VRI bill to DC”
One of the employees from Purple sent me the announcement, and it said that the whole police thing was free of charge. If they aren’t charging the police officers anything, I fear that they are using video relay service. If the government wants to allow it in the case of police officers only, I am certainly in favor. But was the government consulted? I may never know. I hope so. And if they’re running it through the Federal relay, they will REALLY make a fortune. Then they would be reimbursed for session time, not just connected minutes. And the Park Police of DC is Federal, I think. I’m not sure.
“We’ve already seen that we don’t need topnotch quality interpreters. There is no reason to think that we can’t also do without cutting edge technology.”
I won’t touch the first statement right now, because it would take me forever. Don’t get me started on having the least skilled interpreters do this. To very, very briefly explain, the second statement actually touches on safety and overuse, as if we don’t already have enough trouble with the upper body issues. If you don’t have SIP technology, you are unfortunately ruining the vision of the interpreters. RID warned the FCC sternly against eyestrain in their 2003 comments if the interpreters were not allowed sufficient rotational breaks, and my optician husband said you can’t strain your eyes like that and expect anything but a bad result. Sure, you can make out what somebody is signing, but at what price? A lot of it depends on what kind of picture you happen to get, and sending out with a T1 line is a lot clearer than coming in with a cable or DSL line most of the time. It does things to your eye that you don’t realize are happening until it’s too late. Flip books, underwater, pixilated, wavy, darkness, too much light, fog, polka dots, and a million other things we cannot control for without better equipment, are too far from ideal to be doing for an entire shift. We just need clear pictures. Most companies cannot afford SIP in light of the budget cuts. Technically speaking, we are using the Internet for something it is not fully ready for. It takes a lot of money to create a scenario in which very few pictures strain the eye muscles, and most are smooth enough not to do so. I have only seen one company that can afford to do this, or rather, probably cannot afford it but did so anyway. I worked there until they laid us off.
tg
“Some calls require more than one intepreter (legal, conference call) , but reimbursement rate doesn’t change.”
Janet Bailey asked us for comments, and I told her to tell NENA (Apparently, it’s not NECA in this case) that 911 calls should automatically be paid double for a team. They are rare enough, they don’t usually run for hours and hours, and most of all, the FCC can trace the call to a legitimate emergency response unit so there would be no fraudulent billing in this matter. The comments were presented in a meeting that she attended, it was not done in written form. I sure hope they listen, because if nothing else can get two interpreters paid for, at the very least, we should be able to do it for the emergency calls.
tg