Ed’s Telecom Alert

All..

As promised, here is another VRS Provider’s ex-parte comments.

Check out CSDVRS’s comments.  Cousin Vinny complained about bending his neck to read powerpoint.   I had to bend my neck to read the powerpoint as well.  Thanks, Cousin Vinny, for alerting me of CSDVRS’s comments.     

CSDVRS Comments

First of all "Secure Virtual Call Center" is nice way of saying this is for Interpreters interpreting from home in a secure way.  CSDVRS shares its "Share Case Study" and offers recommendations. CSDVRS is making its case of "disaster recovery" and to supplement main CSDVRS call centers.  Several redacted slides, but one slide that was interesting was "Schedule Impact" slide; look at its "recoup" data by using home interpreters. 

Quotable quotes:

"Ability to recover staff losses"

"Secure at-home-interpreting should be permissable under Commission rules"

"Must be supplement to provider’s existing Call Center"

There are more quotable quotes, but my neck can’t stand it anymore  ;-] so I’ll just let y’all get ur necks do a 90% degree turn to read rest of them.  

Once a long time ago, we had discussed this on this edsalert; wow, it was controversial at the time.   I’m curious.  Is it still controversial after you read CSDVRS’s position?  

Let us know ur thoughts.  

eyes open & thumbs up,

Ed

Long Link:

https://prodnet.www.neca.org/publicationsdocs/wwpdf/21811csdvrs.pdf

All..

I will try to start posting more VRS provider’s ex parte comments bit more as the comments are revealing and helps us to understand their point of views.  

I chose comments that I know are controversial among providers, regulators, and deaf pundit so I suggest you click and read rest of comments that seem to be on par for the course.  

Hamilton Comments

Quotable quotes:

"The Commission should not require providers to submit any user data to the TRS Fund Administrator that would violate a user’s privacy or any data that could be construed as Customer Proprietary Network Information or its equivalent."

CPNI is often enforced in regular telephone industry.   However, because of frauds from VRS, it is getting harder for regulator to keep the blinders on. 

"The Commission should not require the public disclosure of any TRS provider cost or demand data due to the sensitive financial nature of such data and the potentially severe competitive impact that the release of such data may cause."

This is understandable, but my personal belief is that the FCC can and should be able to get any financial information as long as the FCC agrees not to divulge the information to the public which includes other competitors.  I believe that is how it is done now, though.  

"Hamilton supports a rule that restricts Communications Assistants (“CAs”) from working in unmonitored workspaces, and such a rule should apply to TRS providers generally."

Above presumably meant working from home, but it also could mean from call centers that are not fully protected from peering eyes.  

FYI: Hamilton is one of the traditional TTY relay service that is slowly gaining on Sprint on number of states it services (Sprint still has the larger number of states it services, though).

eyes open & thumbs up,

Ed

Long LInk:

https://prodnet.www.neca.org/publicationsdocs/wwpdf/21611hr.pdf

Folks…

Let me know what you think of this different way of sharing information. 

Hope that works.

When I uploaded this to youtube, transitions were lost, but still presentable. 

eyes open & thumbs up,

Ed

Folks…

Hey, the FCC presents its fiscal year 2012 budget request to the Congress.   About $354 million.

FCC Proposed Fiscal Budget

"..funding to: (1) support the Commission’s cyber-security role; (2) implement the Broadband Plan; (3) overhaul the Commission’s data systems and processes; and (4) modernize and reform the FCC by ushering in 21st century communications tools and expertise."

"We project we will require 1980 full-time equivalents (FTEs) from all available resources to carry out our mission for the American people."

FCC listed goals: I will just highlight a few.  

On Broadband: "..the Commission has brought on close to 54 data experts, statisticians, econometricians, economists, and other expertise.."  FCC wants to continue that.

On Consumers: "Among the Commission’s most important responsibilities is protecting and empowering consumers. As communications networks and technologies become increasingly complex and essential to Americans’ everyday lives, the Commission must be a vigilant watchdog for the consumer."

On Competition and Innovation: "In FY 2012, the FCC will continue its important work of supporting and enhancing the Nation’s economy by implementing the investment and competition-enhancing provisions of national telecommunications laws."

hmmm – worthy goals to be sure.  How will the budget impact TRS/VRS?  This is what I found:

"Travel in Support of Audits and Investigations ($77.5K): The addition of OIG FTE provides the OIG the capability to expand audit and investigation oversight of the Universal Service Fund, TRS, and Broadband initiatives. The additional staff and mission load requires additional travel funding necessary to accomplish audit and investigation oversight."

"Training ($56.5K): The addition of OIG FTE provides the OIG the capability to expand audit and investigation oversight of the Universal Service Fund, TRS, and Broadband initiatives. The additional staff and mission load requires additional training funding necessary to accomplish audit and investigation oversight."

"The OIG case load is expected to continue increasing for several years. Litigation support is necessary for presenting evidence to be used before the grand jury and at trial."

Above did not specify TRS/VRS, but I would imagine that include some of TRS/VRS issues as well.   

What is OIG?   Office of Inspector General.

http://www.fcc.gov/oig/   If you click on this link, scroll down, you will see VRS issues listed there.   OIG is what keeps telecommunications industry honest.

Keep in mind the document is about budget for whole FCC.   If you like fiscal stuff, it is a good reading.     

eyes open & thumbs up,

Ed

Long Link:

http://www.fcc.gov/Daily_Releases/Daily_Business/2011/db0214/DOC-304636A1.pdf