Ed’s Telecom Alert

All..

NECA Report

Here is the National Exchange Carrier Association (NECA)  report to the Federal Communications Commission (FCC) on funding for Telecommunicaitons Relay Service (TRS). 

Basically NECA is submitting report for the FCC to approve the new funding for TRS and explains how they arrive at new rates.  Good information there, and not too hard to understand. 

Quoting NECA "..submits proposed compensation rates, demand projections, projected fund size and proposed carrier contribution factor for the period July 2009 through June 2010, in accordance with section 64.604 of the Federal Communications Commission’s (FCC or Commission) rules."
Unquote.

A few interesting tidbit of info:

• Approx 4,640 carriers contribute to Interstate TRS Fund. 
• If approved by the FCC, carriers will be charged 0.0113 of carrier’s revenue which will be added to the Interstate TRS Fund.

• Multi-state Average Rate Structure is used for TRS (accounting method)

Report explained various methods in calculating TRS reimbursement rates. 

Most of you are interested in VRS there is a chart of past and proposed new rates for VRS.  Worth checking that out.  

Tiered: Past rate was $6.7362 per min to new proposed rate of $6.7025
Tiered: Past $6.4675 to new $6.4352
Tiered3: Past $6.2685 to new $6.2372

Tiered 1 is under 50K VRS Minutes, Tiered2 is between 50K plus one to 500K, and Tiered 3 is above 500K plus one.

Report mentions "Actual weighted average costs" which I think to me means break-even cost of service.  If I’m wrong, kindly correct me.   Anyway report shows that to be:

• 2007 was $4.5568
• 2007 was $3.9950
• 2008 was $4.1393

Wow…so let’s use 2008 and tiered 2.  Theoretically speaking means profit of $2.0979 per minute.   No wonder no VRS has bankrupted – at least not yet.

Other intriguing info: Quote: "VRS providers spent over $30 million in marketing and outreach in 2008 (up from approximately $20 million in 2007). The data also reflects that that total legal and regulatory expenses for 2008 (included in the indirect cost category) were approximately $8.9 million (up $4.0 million from legal and regulatory expenses reported for 2007).
Unquote

Folks, it is worth reading through this long report; it’ll give you valuable insights of how TRS reimbursement rates are calculated.

eyes open & thumbs up,

Ed

All..

Obama nominated Mignon Clyburn to be one of the FCC Commissioner. 

WSJ Article

If you want to know what Clyburn looks like..

NJO Article

Clyburn will be replacing Jonathan Adelstein who has been known to give support to the deaf/hoh issues. 

TVB Article

eyes open & thumbs up,

Ed

Folks,

I think clarification is needed on VRS industry; that is, should or should not do regarding these phone-in situations; like on-line education, tele-seminars, getting information via phone, etc.  

First of all I like what commentators Todd and Christian said in their comments.   We have 5 Titles from ADA.  Check out an abbreviated form on ADA

ADA Titles

Basically should consider these titles of ADA as a way to meet the federal expectations.  Unfortunately, often a company or service is not willing to do make changes, then an alternative is offered.  Like one commentator sez, if not able to get Title 1 thru 3 implemented, then only alternative is Title 4 which is relay service. 

We know how difficult it is to get federal agencies to act on various issues and may take them years to resolve that.  Deaf/hoh should not have to suffer because of that.  So alternative is acceptable, but with following conditions for business ethics.  

I do feel very strongly that it is not VRS providers’ place to advertise or promote these phone-in services either via website or emails or flyers.  I feel strongly that in meeting functional equivalence, deaf/hoh – just like hearing persons – find these services on their own is the ideal way to go about it. 

VRS providers who advertise/promote these phone-in services only have one thing in their minds – "ramp up" VRS minutes – in other words, manufactured minutes (I like that term, Todd).   Same for those VRS providers who use domain whose sole purpose is to connect to phone-in services.  Or those VRS providers who pay individuals to call these those phone-in service.  Or VRS providers who pay various organizations to call VRS providers based on accumulation of VRS minutes.  

However, those deaf/hoh who simply found phone-in services from newspaper or media news, and they did NOT get info from VRS providers or from Outreach Services who have contract with VRS providers, should be allowed.   The exception, in my humble opinion, is classroom interpreting at Universities or Colleges – these I feel are verboten!   Essentially because Universities/Colleges can afford them and FCC says no.

I talked with a few ethical VRS providers and I was pleased to learn that they practice that.   They do not have any contract/behind the scene dealings/behind organizations/etc. to encourage phone-in services.   So these VRS providers allow these phone-in services to be processed as these were "found" by deaf/hoh individual.

One additional issue.  I’ve had a chance to talk with a few professional interpreters who work in VRS environment.   They said "most" video interpreters do not like to interpret these phone-in services.  Once a while, they said no problem, but on a daily basis they don’t like.  Said they lose the motivation to stay with VRS industry.   We deaf/hoh need to be sensitive to these video interpreters as well.  After all, they’re symbiote to us deaf/hoh.  We cannot live without each other.  

Anyway, the botton line is simply that VRS minutes should be purely "consumer-driven" as chosen/determined by deaf/hoh only, not manufactured VRS minutes.  

eyes open & thumbs up,

Ed

Folks..

Check this link out.  You’ll see video clips explaining all about the number rules for VRS/IP Relay.  You’ll need to download realplayer program, though.

FCC Video Clips

Kudos for FCC for doing this.  Hope they will do more of this type of educaitonal and informative video clips in the future – especially the controverisal issues and clarify them?  [hint hint ;-]

eyes open & thumbs up,

Ed