Ed’s Telecom Alert

Folks..

Don’t y’all hate these acronyms?     RERC stands for Rehabilition Engineering Research Center, and IT = Information Technology Access, and TA = Telecommunications Access

What caught my eyes is that TA is from Gallaudet University. 

RERC Link: https://prodnet.www.neca.org/publicationsdocs/wwpdf/42511rerc2.pdf

(Note: I am having problem with Word Press in adding the link to one word, so my apologies until that is fixed, you all will have to put up with long link.)

Quotable quotes:

"Gallaudet and the Trace Center have collaborated on research and development related to cross-disability access to telecommunication since 1995."

hmm – good to know. 

"We agree that the meaning of the term “manufacturer” should be the same as in the rules implementing section 255 as “an entity that makes or produces a product.” However, it should be made clear that many “products” will be software only. Such Advanced Communication software products must be clearly covered."

Uh, yeah good idea to include that.   More and more future "advanced communication software" likely will become the standard especially with advent of tablets, and mobile devices that relay on these software. 

"..if a manufacturer requires, prefers, or incentivizes (e.g., by providing increased speed) a purchaser to use a particular third-party application in order to use all the features or get all of the benefits of the device/service, then the manufacturer, rather than the user is making the choice and the manufacturer should be responsible. Finally, if the manufacturer markets its device or service in conjunction with the third-party add- on or identifies the third-party application as a reason to purchase its product, the manufacturer should be responsible."

Lot of statements similar to above quote on the responsibility of manufacturers that that they should be held responsible for full accessibility.  

The comments also indicate that ALL products/softwares should be tied to telephone number so everyone else can call each other and suggests to the FCC on wording for that. 

Comments offer rewording on various issues: one example:

"Instead of excluding “blog posts, online publishing, or messages posted on social networking websites” the commission should use language like “information that is posted to a location where it is expected to be found and read by many people over an extended period of time, rather than information directed to specific individuals or expected to be read and responded to or acted upon immediately after posting”

Now to "video conference service" comments by RERC.

"Video conferencing service should be interpreted to include the broadest range possible because none of the listed services is likely to exist in its current form in 20 years, but the legislation will still need to be meaningful. The definition should be wide in order to prevent new technologies from defining themselves out of the requirements."

AMEN!  One only have to look back at Baudot Syndrome (locked to TTY machines and not able to grow out of it to a newer technologies).

"We agree with the consumer groups that VRS services are covered – the video leg of the VRS meets the definition. Further, individuals who are deaf have unfortunately not been given a get-out-of-jail-free card for other types of disabilities, nor from the effects of aging. To say that a system for the deaf should be exempt from other types of accessibility would be to deny the human condition or to claim that deaf people are exempt from it."

YES!  In other words, VRS to be integrated into mainstream video conference for everyone including hearing persons.  

The next comment touches on "Interoperability".  RERC had right idea.  Read the following comments and breathe a sigh of relief and hope that the FCC agrees.

"The fact that video relay service wasn’t always interoperable from the beginning was an unfortunate anomaly. All progress in this area is toward interoperable VRS, including both interoperability among VRS services and interoperability with the public communication system. Purely for economic reasons, it is important that deaf people be able to make point-to-point calls with each other and with other members of the public, (rather than having to always rely on publicly funded relay services because of incompatible videophones)."

"It makes no sense to build next-generation emergency systems that need to support a variety of different incompatible video communication systems in order to be able to accept emergency calls from different deaf callers. Nor should we have an emergency system that is different from the system used for mainstream video communication calls. Videophone interoperability is particularly essential in a disaster, because the emergency systems will be overwhelmed and people who are deaf will need to turn to anyone who can help them. So their video systems need to work with mainstream video systems as well as that of other deaf people – point to point. Video communication services, therefore, should be required to be interoperable with each other and with other ACS (mainstream and special)."

Duh, that’s really no brainer.  

Other comments focused on "waiver" and how the FCC should and should not allow waiver for manufacturers/providers to "get away from it".   

One example of above is the following comment:

"We agree with the Commission that there should not be a blanket exemption for small business. There are many ways that accessibility can be incorporated even in the work of a small business."

Love that!    Often small business will try to "get away with it" by saying they’re a small company and cannot meet the disability access criteria.  Duh, with this rule if passed, they can’t use that.  

I just realized that I’m half way.    If you’re intrigued, read the link.  Sometimes not easy to read and understand, but good suggestions from RERC. 

eyes open & thumbs up,

Ed

Long Link: https://prodnet.www.neca.org/publicationsdocs/wwpdf/42511rerc2.pdf

People,

• Require that VRS providers submit a statement describing the location and staffing of their call centers twice a year, and a notification at least 30 days prior to any change in the location of such centers;
• Prohibit VRS CAs from relaying calls from their homes and prohibit VRS providers from tying minutes or calls processed by a CA to compensation provided;
• Prohibit compensation for VRS calls that originate from IP addresses that indicate the individual initiating the call is located outside of the United States, with the exception of callers who pre- register with their default provider for a specified time and location of travel;
• Prohibit compensation for VRS calls for remote training when the service provider is involved in any way with such training (e.g., sponsors, promotes or hosts such training);
• Prohibit VRS CAs from using visual privacy screens, and requires that CAs terminate a VRS call, after providing a warning announcement, if either party to the call: (1) enables a privacy screen or similar feature for more than five minutes, or (2) is unresponsive or unengaged for more than five minutes, unless the call is to 9-1-1 or one of the parties is on hold;
• Require automated recordkeeping of TRS minutes submitted to the Fund;
• Require that VRS be offered to the public only in the name of the provider eligible for compensation from the Fund and, when sub-brands are used, that these identify such eligible provider; requires that calls to any brand or sub-brand of VRS be routed through a single URL address for that brand or sub-brand;
• Prohibit revenue sharing agreements for CA or call center functions between entities eligible for compensation from the Fund and non-eligible entities;
• Prohibit compensation on a per-minute basis for marketing and outreach costs performed through a subcontractor where such services utilize VRS;
• Adopt whistleblower protection rules for current and former employees and contractors of TRS providers;

The following is from NPRM:

Mainly on certification procedure. 

• Require that all Internet-based TRS providers be certified by the Commission to become eligible to receive compensation from the TRS Fund;
• Require new and renewing certification applicant providers to provide specific documentary evidence of their ability to comply with the TRS rules; The Commission may choose to conduct on-site visits as part of the certification process;
• Revise the provider’s annual report filings to the Commission to require further documentation that providers are in compliance with the Commission’s TRS rules;
• Clarify what types of changes trigger a provider’s obligation to notify the Commission that substantive changes in its TRS program have occurred;
• Require providers to seek approval from the Commission for voluntary interruption of their Internet-enabled relay service and to promptly notify the Commission after-the-fact when unforeseen service interruptions occur.
  

The following link is the full-blown description of the above; 69 pages long.

Order and FNPRM: http://www.fcc.gov/Daily_Releases/Daily_Business/2011/db0406/FCC-11-54A1.pdf