Ed’s Telecom Alert

All..

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.   

ATT Comment

Purple Comment

Sprint Comment

SVRS Comment

ZVRS Comment

This one is from a collective national organizations: TDI, ALDA, NAD, DHOHCAN, and AADB.

Coalition Comments

RID Comment

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

All..

Normally I would quote statements or offer a brief summary, but the NOI has well over 150 questions.   So you all will need to read them.   Some comments are easy to understand and some are not.    There are little over 50 pages.  

Convo Comments

As soon as other VRS providers submit their NOI comments, I will post them as well. 

eyes open & thumbs up,

Ed

Long Link:  http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708312

All..

Here are misc news of happenings recently – short ones.

4 Petitioners Motion

"An extension of time is necessary and in the public interest to allow interested parties to gather information, conduct meaningful dialogue concerning the intertwined and dynamic issues presented with respect to video relay service (“VRS”), and to allow commenter to develop meaningful in-depth positions concerning this critical proceeding."

"Such an extension is particularly warranted in light of the Commission’s desire for input on so many varying critical questions relating to the VRS program’s effectiveness, efficiency and sustainability, as is the case here.
Petitioners therefore submit that a reasonably moderate extension of the comment deadline will enable stakeholders to more thoroughly evaluate and respond to the NOI and thus provide more substantive, thorough and thoughtful comments."

FCC Denies SVRS’s Stay Motion

Basically FCC denies SVRS’s Stay Motion.  Here is a quote:

"Although Sorenson nominally seeks a "stay," it asks not just that we stay the interim rates, but also that we take affirmative steps to re-institute the former VRS rate that expired on June 30, 2010. For the reasons set forth below, we deny the request."

As result, SVRS now seeks court to overturn the FCC’s decision.    

Contribution Factor

Contribution factor simply means when National Exchange Carrier Association "collects" from all telephone companies, etc. to "contribute" to Interstate TRS Fund.  Interstate TRS Fund is what reimburses all relay providers.

The pertinent quote that basically address the main issue:

"Based on the adoption of these rates and NECA’s proposals, the Commission hereby adopts a carrier contribution factor of 0.00585, and a funding requirement of $433,990,484.98 for the 2010-2011 Fund year.11    The Commission adopts these rates, and this contribution factor and funding requirement, for a period of one year, except as otherwise provided herein."

eyes open & thumbs up,

Ed

Long Links:

4 Petitioners – http://fjallfoss.fcc.gov/ecfs/document/view?id=7020550986
FCC Denies – http://fjallfoss.fcc.gov/ecfs/document/view?id=7020549754
Contribution – https://prodnet.www.neca.org/publicationsdocs/wwpdf/fcc10115.pdf

All..

Ladies and Gentlemen, this NOI is very important and MOST certainly will have a far-reaching impact on defining exactly what VRS is and the rationale for compensation rates for VRS providers.   This NOI will be exhausitive undertaking for sure.

FCC quote:

"In this Notice of Inquiry (NOI), we take a fresh look at the Commission’s video relay service (VRS) rules so that we can ensure that this vital program is effective, efficient, and sustainable in the future."

"..a fresh look.." certainly is an understatement of the century!  The FCC is taking a bold steps to of possibly overhauling the infrastructure of VRS. Is that good?  Yes, I believe so, but this is where critical comments are critical.  We – by "we" I mean ALL of us – need to respond to let the FCC know what we think VRS ought to be and how VRS providers should be handled.  

FCC presents NOI in two parts:

Part One: basically seeks whether multiple VRS providers, one or a few should be adopted and why, etc.  

Part Two:  basically asking to whether VRS should be re-defined or not.   If so, how so and in what way, etc.  

Caveat here: above summarization does not tell whole story of the NOI.

The whole purpose of NOI is to gather information from all concerned, and then the FCC will make its final decisions.   Click to the link, and be prepared to cultivate patience as it is a long reading.  

FCC Notice Of Inquiry

Since this is long NOI, best way to show items is via the table of contents which I typed briefly below.

Part I Adjustments and Modifications to Improve the Current VRS
Compensation Methodology
1. Accounting Issues
2. Company-Specific Compensation
3. Outreach and Marketing Costs
4. Research and Development Costs
5. Videophone Equipment
6. Protection of Providers from Under-Compensation and Avoidance of Over-compensation
7. Certification

Part II – Broader and Economic Issues Concerning VRS
1. The Components of VRS
2. The Demand for VRS
3. The Supply of VRS
4. The Regulation of VRS
5. The Incentives of Providers
6. The Incentives and Needs of VRS Users
7. Other Regulations Affecting VRS Communications

Just by looking at the terms used for table of contents, one could say that the FCC is going to collect lot of comments from VRS Industry as well as the movers and shakers of the TRS world.  Again, I cannot stress strongly enough that this is very important NOI and possibly the most important ever in the history of TRS. 

eyes open & thumbs up,

Ed

Long Link: http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-10-111A1.pdf