Ed’s Telecom Alert

All..

These links basically are the instructions from the FCC to NECA of the pending transfer of data of TRS from NECA to RLSA.   

TRANSFER 1

Payment for Close-Out Activities of Telecommunications Relay Service Program Administration for the National Exchange Carrier Association

TRANSFER 2

Telecommunications Relay Service Fund Financial Statements and Reports

TRANSFER 3

Instructions for Transfer of Telecommunications Relay Service Program Records

I did not quote as this is pretty much self-explanatory.  

As always I look for the issues that impact deaf/hoh.   For example, where are the instruction for the transfer of TRS Fund Council from NECA to RLSA?  I see none.   The underlying question that many of the deaf/hoh leaders as well as sophisticated users are seeking is what kind of role will TRS Council play in RLSA?    More of rubber stamping and accept the report on faith without having an opportunity to really audit and analyze?   Or will the Council have increased oversight?     How will RLSA utilize the Council?      

More specifically, how did the FCC cite in its Request for Proposal on the TRS Fund Council?   What kind of role did the FCC define for the RFP on TRS Fund Council?   How did RLSA submit its proposal on TRS Fund Council role?   

These are important questions that the deaf communities would like answered.  I would not be surprised if the members of the Council want the answers as well as they would want to know exactly what role they will have.   

eyes open & thumbs up,

Ed B

Folks, 

When the FCC released the order (a couple posts back on Edsalert), the FCC had in mind a way to minimize number of non-certified VRS providers down to manageable size.  However, there is a clause where it indicate those already providing VRS, but not certified may submit waiver if the non-certified providers show that they will be in compliance with the TRS regulations.    The deadline to submit that was May 31.  

Basically the order said:

"A company requesting a waiver of the rules adopted in this Order will have the burden of showing that the waiver is in the public interest, that grant of the waiver request will not undermine the purposes of the rules that we adopt today, and that it will come into compliance with those rules within a short period of time."

Okay.

A few non-certified providers including Convo submitted waiver reports to the FCC.  Quite a few of them.  

On May 31, the FCC releases a suspension of the Waiver clause and render the waiver requests as moot.  All the work that non-certified providers did are now "moot".  Ouch! It meant lot of times and funds spend on that may now go down the drain.  

The link below is about the suspension of the order.  

Suspension

The FCC's rationale is: 

"We find good cause to stay the effective date of this rule because the Commission is undergoing a review of the certification requirements for IP-enabled TRS providers."

and

"We anticipate releasing an order adopting a new certification process for Internet-based TRS services based on the record in the FNRPM within the stay period. Entities will be then given the opportunity to apply for certification prior to the expiration of the stay on October 1, 2011, in order to become eligible for compensation from the Interstate TRS Fund under the new process."

It does beg a question what will the non-certified providers do in the meantime?   Are there options?  Yes, a few but not to the best interest of non-certified providers themselves.  Perhaps that is what the FCC wants. 

Your thoughts, Readers?

eyes open & thumbs up,

Ed Bosson