Other VRS Providers Comments to the NOI
19 08 2010All..
Sorry I don’t have time to do summarization of each, but thought I’ll list that posted to the FCC on NOI.
Here are the links to various VRS providers…average is 50 pages long. I hope I matched the link to right provider right. ;-]
Those of you with brave soul willing to read all, let me know what you think of them.
This one is from a collective national organizations: TDI, ALDA, NAD, DHOHCAN, and AADB.
eyes open & thumbs up,
Ed
Long Links:
Purple Comment: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708990
SVRS: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708951
ZVRS Comment: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708904
Coalition: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708952
RID: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708856
Sprint: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708932
ATT: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708928
Dear Ed,
Not sure if you ever posted SnapVRS’ 7/23/10 NOI comments on this fab site. For the good of the Order of the Readers of Ed’s Alert, here it is:
http://fjallfoss.fcc.gov/ecfs/document/view?id=7020550573
I plan to do a swan dive into reading the comments, since as a state TRS Administrator, I’d like to get a sense whether VRS providers relish the idea of another level of oversight, whether by state contract or by further regulation from the FCC. The rest will be interesting reading, most certainly. (“Mirror, Mirror, on the wall, who is the most “reasonable” of us all?”)
Just went into coma after reading the last NOI comment. Brain overload… One notable omission; SnapVRS! did not make a NOI comment? Or was the FCC late in posting it on ECFS?
I do have one quick comment about Sorenson’s NOI comment. It was extremely well written and prepared. However, as far as their ambitions for a reverse auction goes, this reminded me of a quote from “My Cousin Vinny” movie: (Lifted from imdb.com)
Vinny Gambini: I object to this witness being called at this time. We’ve been given no prior notice he would testify. No discovery of any tests he’s conducted or reports he’s prepared. And as the court is aware, the defense is entitled to advance notice of all witness who will testify, particularly those who will give scientific evidence, so that we can properly prepare for cross-examination, as well as give the defense an opportunity to have his reports reviewed by a defense expert, who might then be in a position to contradict the veracity of his conclusions.
Judge Chamberlain Haller: Mr. Gambini?
Vinny Gambini: Yes, sir?
Judge Chamberlain Haller: That is a lucid, intelligent, well thought-out objection.
Vinny Gambini: Thank you, sir.
Judge Chamberlain Haller: Overruled.
Reverse auctions are a non-starter in my eyes… Somehow, the FCC will probably give this some serious consideration. I do have further comments about Sorenson’s NOI comment and others as well. Just need the time to review each one of them carefully.
Pay particular attention to the very last point Purple makes in its comments, about “redefining” TRS to comport with the definition the House included in HR 3101. That definition would remove the important distinction that TRS is supposed to be between a deaf and a hearing caller. In other words, the new definition would arguably permit the use of VRS for conference calls involving only deaf callers…exactly the scam for which Purple was busted last February.
Certain “advocates” will deny it, but as much as they claim to be disappointed in the way HR 3101′s captioning provisions were ripped apart, they would gladly trade all of that for this new definition of TRS.
Hopefully, the Senate will restore the original wording before the final vote. If not, I trust that the FCC will write regulations making it clear that the law’s intent is not and was never to tolerate such scams.
“the new definition would arguably permit the use of VRS for conference calls involving only deaf callers”
good catch! i’d missed it. all that whining about sorenson clouded my view. and yes, where is snap?
tg
Snap actually posted two comments under the name “Snap Telecommunications”. I’m posting this from my phone so I couldn’t copy paste the address.
Here are SnapVRS’s two comments…
http://fjallfoss.fcc.gov/ecfs/comment/view?id=6015694245
http://fjallfoss.fcc.gov/ecfs/comment/view?id=6015691915
Bob and CR,
Uh, these files by SnapVRS was for NPRM, not for NOI.
Not all certified VRS providers had submitted comments; they do so for variety of reasons unknown to us. Cuz we do not know the reasons why, let’s not make any judgment call on that.
eyes open & thumbs up..
Thanks Ed, again, for keeping us informed. One oint that I have noted is that all of the major repondents to the NOI have made “valid” points with their interest in mind. Do not get me wrong, I am all for a business to profit, however, if you examine their responses in depth you will clearly determine that most of them are out for themselves. The level of hipocresy is alarming. I think that we should all get together and come up with one major provider that will in fact have our best interest in mind, to provide a professional, dependable and reliable service. A service that will allow us as a community to have the freedom of communication that we all deserve. Most of the management of these providers are simply greedy “top talented” flunkies that truly do not care about the deaf or hoh. Go on and see any of them, talk to many of these CEO’s and you will see that although a lot of them attempt to communicate they truly are just going through the motions.
Of course all these providers will continue to supply feedback to the government, but to simply continue to fill their pockets. Again, greed is what have driven this so called industry to divert form the true reason it was established. To provide a person with a disability the ability to effectively communicate. Although technology is great, we must look at what we truly need. COMMUNICATION!!!!! Yes it is nice to have gadgets and technology, but at the same time when you analyze the real need you will see that no matter how many cool toys you have or how many new products you can get, if you do not get the basic connection and an interpreter that can EFFECTIVELY process your call, you will end up with nothing but a bunch of useles hardware.
I am glad the governement is finally taking a good look at this thiefs for what they are.
Wow, SnapVRS talked openly about VVI. I miss Snap. Can’t help it. SIP technology. Plus health insurance! But I have to work in a center. I’m happy in my center now.
I made a (8-page, double-spaced) REPLY COMMENT to Sorenson’s NOI. I suspect they will not like it very much, despite the geniune praise and admiration I have for the company, and deep respect for their comprehensive and well written NOI comment.
If the FCC does decide to go ahead and largely adopt Sorenson’s recommendations about setting a multi-year unitary reimbursement rate for 2011 and beyond, Sorenson should just go ahead and do a Gordon Gekko speech.
When the link appears in FCC’s ECFS, I’ll put it here.
I do have some other comments about other VRS provider’s NOI comments. I’m thinking of doing an ‘omnibus’ petition which addresses some of these comments. I’m particularly interested in server-based routing solutions as proposed by some providers. (And the Consumer Groups, I believe.) Will share some thoughts later this week.
My Reply Comment to Sorenson’s NOI is now in ECFS:
Reply Comment to Sorenson’s NOI
I would strongly suggest readers to read Sorenson’s NOI in its entirety. I found it truly informative and educational, as I had little knowledge about the economics behind the VRS industry. Reading it has made me a better informed person about what the FCC is trying to do with their NOI process.
Recently I have been writting about the VRS providers greed and their hipocritical management. It is not that I am against the profit building business, it is that I am simply over the hipocresy of these companies. But that is not what I am writting about today. The sudden loss of a close person made me reflect on some things over the weekend. We spend most of the day moving so fast and overwhelmed with messages that we do not take time to reflect on what we truly need. I remember the times when people actually communicates with each other, now we alienate ourselves through the magic of technology, we are so disconnected that we can walk by a person in need and not even lift our eyes to see it. We are glued to our computers and live in the shadow of what the VRS providers want us to beleive. When was the last time you took time to even attempt to have a conversation with a hearing person? To educate them and show them that we are just as productive as them? We truly do not know how much time we will have, it is time to get back to the basics of life and respect each other. As something I read once somewhere that stated “Everything that I neede to learn about life I learned in Kindergartden”. Unplug from the machine to admire a sunset, enjoy a drink with a friend, have a comversation with a stranger and most of all enjoy everyday as if it was going to be your last one.
Finally read all NOI comments, this time with highlighter pen and selected notes, with the sole exception of Pah! Relay’s NOI comment. (Memo to Pah! Relay; learn to use the ECFS.) Hopefully I can read yet another VRS provider’s NOI comment tomorrow and wrap this up.
I do want to thank all VRS Providers that have contributed to the NOI comment process. I have found the whole process to be enlightening and educational.
I will not be making REPLY COMMENTS to every single VRS provider’s NOI comment. However, I will be making some select comments and observations here at Ed’s Alert website. I possibly may have two REPLY COMMENTS in the works, though. (Against “Consumer Groups” and CSDVRS.)
First up, is AT&T’s NOI comment. Quite succinct, and have found their comments on various issues to be quite agreeable. However, they did comment that they wanted to be able to recover VRS minutes for employee calls that do not work in, or are not related to their TRS/VRS service. (See page 13.) I don’t think this is one Pandora’s box the FCC wants to reopen, though.
Next up is Sprint’s NOI comment, and like AT&T, is succinct and to the point. I did find it interesting that Sprint proposes that stand-alone VRS providers contribute to the Fund for each consumer. (See page 15.) That could lead VRS providers in having billing relationships with their consumers, err, customers. I found it interesting that Sprint would support the idea of a competitive bidding process. (Pages 15-16.)
About Purple’s NOI comment, it was one of these rare comments in which I found many of their positions to be reasonable and agreeable. (After finding myself being largely disappointed with Purple’s petitions throught the 2009 year, I found it refreshing, indeed.) Then, Purple had to pull an “Icarus” and try to reach for something that just simply isn’t there; they wanted the FCC to redefine the definition of TRS to comport with a new definition being circulated around in the halls of Congress. (At the end of their NOI comment.)
Purple also proposes that customer support for CPE installation, training, and troubleshooting to be compensable as outreach expenses. (See footnote
I agree, but would cap such expenses and put them in the per-minute reimbursement rate. I don’t want installers/consumers doing test calls and VRS calls to corporate HQ to confirm customer information and installer number (for the commision they’ll get, I presume), as compensable per minute calls.
Odd. A smiley appeared in an inappropriate place during my Purple’s comment. I meant Footnote 8, not the smiley icon with sunglasses.
“I found it interesting that Sprint would support the idea of a competitive bidding process”
Why? TTY is all they know.
tg
“Odd. A smiley appeared in an inappropriate place during my Purple’s comment. I meant Footnote 8, not the smiley icon with sunglasses.”
Aw, let ‘em keep the smiley. Maybe they can sell it.
Pah! An appropriate name, given that I’ve finished reading the final NOI comment, by Pah! VRS. Found it to be unremarkable, but still, I thank them for contributing to the discourse on the FCC NOI.
Purple’s here today, harrassing our VI’s. It’s tacky.
tg
Just filed a REPLY COMMENT to the Consumer Groups’ NOI comment. Sorry to ‘trash’ Convo Relay’s proposed solution, but I’m thankful for the fact that they proposed the idea in the first place. We need ideas and solutions, not just talk. Oh- I may sound like a tin-foil hatter to some…
When the link appears in FCC ECFS, I’ll post it here.
The document is now on ECFS.
Click here for the REPLY COMMENT TO CONSUMER GROUPS’ NOI
In it, I discuss the benefits/drawbacks of server-based routing and CPE-based routing.
Vinny,
The definition of TRS that Purple wants isn’t just “circulating in the halls of Congress.” It was passed by the House of Representatives while no one was paying attention because of all the hoopla over the captioning provisions in HR 3101. Hopefully the Senate will take it out (and restore the internet captioning mandates) if and when it passes the bill. Purple wants to legitimize, ex post facto, its all-deaf conference calls. That’s all. Unfortunately for them, they jumped the gun by drawing attention to it in their NOI response. Now everyone knows what they’re trying to do, and the bill hasn’t even been passed by the Senate, let alone signed by the President. I wouldn’t be surprised now if that section gets revised and returned to its original language before the Senate acts.
Just read Convo Relay’s Reply Comment to the NOI process. Loved it; especially the ‘exploding cigar’ reference. Got me smiling on that one. Very good, vigorous defense of the multi-year tiered rate methodology as opposed to an unitary rate or a reverse auction. I also loved their characterization of their Provisional Certification program, offering it as a ‘defense’ against the “toxic residue” of the VRS waters.
BTW, Snap belatedly added their input in the NOI process. Better late than never, huh?
An uneventful reply comment, but they generally sided with the Consumer Groups.
Say Hey, Inc. also made a reply comment, and like Snap! VRS, an unremarkable one at that. Glad to see them contributing to the NOI discourse.
I just posted another REPLY COMMENT to docket 10-51. This one will be my last, I promise.
It’s in response to CSDVRS’ rate of return on investments, most notably their Hybrid Capital approach. When the link is in FCC ECFS, I’ll post it here.
I just hope it doesn’t get buried under the inevitable avalanche of REPLY COMMENTS that are coming down the pike tomorrow in docket 10-51. I want to thank the FCC in enabling the public at large to contribute to the NOI discourse on such a transformative industry, Video Relay Services.
You call VVI unremarkable?
TerpGirl-
By unremarkable, I mean having no ‘objections’. In fact, I find Snap! VRS’s idea of using Virtual Video Interpreters (VVI) quite innovative. Just as long as quality controls are in place, a seperate room, security and confidentiality of calls are assured, I’m okay with the idea of using VVI’s.
The link is up on ECFS;
My REPLY COMMENT to CSDVRS’ NOI COMMENT In it, I talk about CSDVRS comments on rates of return on investment, and most notably their Hybrid Capital ROI approach.
Purple made an oustanding REPLY COMMENT as well. I liked the way they went after Dr. Pelcovit’s affidavit. Props to them. Do have some thoughts, but will share them later.
CSDVRS also made another outstanding comment. They even explained Sprint’s ‘curious’ support of reverse auctions. They basically made a strong statement opposing reverse auctions and an unitary rate price scheme.
Looks like the Inter-Bureau Task Force at FCC has a lot to chew upon! Will look forward to hearing from them again and their proposed NPRM’s.
I was actually at Snap when they started the thing about working from home. It actually was great for momentary peaks in call volume. If someone is at home and not doing anything tremendously important, they don’t mind getting on the system for 1/2 hour or a couple of hours or whatever, But if they have to pack up and drive into the center, they want a full shift, whether we need them for the full shift or not. At first, I was uncomfortable with confidentiality issues. I would support a non-recording viewing window from the center to the home office, but I’m not sure there is a such thing. I think it all records. Either way, if they want us to stop doing it, they need to put the money back in for labor. And they need earmark it for labor, at least certain amount. Otherwise, companies will have to do this.