FCC Enforcement Advisories

4 02 2010

All..

FCC is launching a new announcement regarding enforcement rules and such.

Enforcement Advisories

Quote:

"The Enforcement Bureau will periodically release Enforcement Advisories, which are designed to educate businesses about and alert consumers to what’s required by FCC rules, the purpose of those rules and why they’re important to consumers, as well as the consequences of failures to comply."

There is one regarding hearing aid compatibility.  Read on..

eyes open & thumbs up,

Ed B

Long LInk:
http://www.fcc.gov/eb/Enforcement_Advisories/Welcome.html



Consumer Group Submits Petition to the FCC

29 01 2010

Folks…

Consumer Groups – National Assoc of the Deaf, Telecomm for the Deaf and HOH, Assoc of Late-Deafened Adults, Inc., Deaf HOH Consumer Advocacy Network, Calif Coalition of Agencies Serving Deaf/HOH, Hearing Loss Associaiton of America, and America Assoc of the Deaf Blind – submits petition to the FCC.  Basically Petition is asking the FCC to issue a notice and comment rule-making proceeding on the matter of limiting or restricting certain types of Video Relay Service (VRS) calls such as conference calls, recording calls, etc.   

HURRAH!    

Looks as if the NECA and FCC are hammered from all sides now:   Consumers, VRS providers, and National Deaf/HOH groups on what all perceive to be not reasonable actions taken not to reimburse minutes of certain features.  Coming from this powerful groups have to have an impact on FCC.

Keep in mind that NECA is doing these actions under directives from FCC.  Keep in mind also, that the supporting FCC staff are issuing directives based on the 8th Floor’s decisions.  8Th Floor getting directives from (?) Congress or powerful lobbyist?   Or influenced by media?  Probably combination of several factors. 

To be sure FBI arrests, frauds, VRS providers looking for loopholes and all that created the situation.  However, I think pendulum went from one extreme side to the other extreme side.  FCC needs to find a balanced decision that is fair for all.  

Consumer Group Ex-Parte

Quotable quotes:

"..have learned that some VRS providers are either not connecting or may stop connecting certain types ofVRS calls because the National Exchange Carriers Association (NECA), the TRS Fund administrator, is withholding payment for certain types of calls."

"Not connecting certain types ofVRS calls is inconsistent with Section 64.604(a)(3) ofthe Commission’s rules, harms consumers, and is not functionally equivalent to the communication access that hearing telephone users enjoy.."

"Congress clearly expected that all types o f telecommunications services, using both existing and improved technologies, are to be made available to people with disabilities."

Consumer Group offered rationales which make sense as to why certain telephone features should be offered to the deaf/HOH.  Worth reading…

Check this link out:

NAD Comments

eyes open & thumbs up,

Ed B

Long Link:
http://fjallfoss.fcc.gov/ecfs/document/view?id=7020383912

NAD:
http://www.nad.org/news/2010/1/fcc-actions-block-consumer-vrs-calls



VRS Industry Speaks Out

21 01 2010

All…

Along the same topic on non-reimbursable minutes.   Read on..

Four VRS Provider Ex Parte

CSDVRS Ex Parte

The underlying message is that the price of inaction may prove to be too great for most of VRS providers then ultimately VRS users suffer as result.   

eyes open & thumbs up,

Ed

Long Links:
4 VRS
http://fjallfoss.fcc.gov/ecfs/document/view?id=7020382451

CSDVRS Ex Parte
http://fjallfoss.fcc.gov/ecfs/document/view?id=7020355243



Restrictions on VRS Features

20 01 2010

Hello everyone

Quick disclaimer.  I own edsalert and also a co-founder of Convo.   So accept my vlog for what it is. 

I want to share with you all of a disturbing trend that the FCC had adopted restrictions of  certain VRS features without actually releasing Public Notices that restrict these features for VRS industry. 

FCC is now giving directives to National Exchange Carrier Association (NECA) – NECA is the contracted account administrator who reimburses VRS providers -  anyway NECA is not to reimburse any minutes by VRS providers that are processed for these following features:

  • conference calls between deaf/hoh (those who do NOT work for VRS providers) and hearing persons
  • Customer support services  (for pagers, cell phones, etc from ATT, Sprint, Verizon, etc)


These two, in my opinion, are legitimate calls.   Conference calls by non-VRS employees  – just regular deaf/hoh to hearing persons should be permitted, not forbidden.  

The telephone support services that deaf/hoh calls to get technical help likewise should be permitted.  

The largest VRS providers are able to absorb the cost of these features so they do not submit these minutes to the NECA  whereas smaller VRS providers who need every minutes are forced to block these features as they cannot afford to absorb these costs.   So who gets hurt are the start ups or small VRS providers. 

Other non-reimbursable features are:

Podcast
online education (this one there is a FCC public notice forbidding that but specifically to “class room” situation)
some cases webinars

These three are debatable and controversial.   Title III of ADA Act or Section 255 of Telecomm Access may apply on some of these “non-reimbursable” minutes.  

However, I agree with not allowing class room as it really is the responsibility of educational institution to provide access for the deaf/hoh. 

Strongly suggest that if you feel strongly about these non-reimbursable minutes, let FCC know.  If you want to file complaint, use this link.  Be sure to fill out both sections.  Looks complicated, but when you read them, not too bad.  

Complaint Form

Remember FCC will typically do not act on issues unless enough deaf/hoh complains. So complain away…

eyes open & thumbs up,

Ed B

long link:
https://esupport.fcc.gov/sform2000/formC!input.action?form_page=2000C