Ed’s Telecom Alert

Folks,

Reason for certification is:

"On September 21, 2011, rules issued by the Federal Communications Commission (“Commission”) establishing the National Deaf-Blind Equipment Distribution Program (“NDBEDP”) pilot program became effective."

Also this:

"..the Commission established the NDBEDP as a pilot program to distribute equipment used for telecommunications services, Internet access services, and advanced communications, including interexchange services and advanced telecommunications and information services, to eligible people who are deaf-blind. The duration of this pilot program will be two years, with a Commission option to extend the program for an additional year."

Deaf Blind Certification

So that means the National Deaf Blind Equipment Distribution Program now is a reality.   This PN is to alert organizations, states, whomever is interested in setting up this very worthy program.  

Quotable quotes:

"..the Commission will certify a single program as the sole authorized entity to participate in the NDBEDP and receive reimbursement for its NDBEDP activities from the Interstate Telecommunications Relay Service Fund (“TRS Fund”).5 Such entity will have full oversight and responsibility for distributing equipment and providing related services in the state for which it is certified,6 either directly or through collaboration, partnership, or contract with other individuals or entities in-state or out-of-state, including other NDBEDP certified programs."

Who may apply?

"..Any public program or private entity may apply to the Commission for certification to become the sole authorized entity for a state to participate in the NDBEDP and receive reimbursement for NDBEDP activities from the TRS Fund.8 For example, public programs, such as state equipment distribution programs, vocational rehabilitation programs, assistive technology programs, or schools for the deaf, blind or deaf-blind may apply. Likewise, private entities, such as organizational affiliates, independent living centers, or private educational facilities, may apply. Either local or national entities may apply, so long as the application is clear as to the specific state(s) to be covered by the applicant’s proposed program(s)."

I hope that many states or organizations will apply as this is really worthy project.  Deaf Blind have too long been ignored or marginalized.  

eyes open & thumbs up,

Ed Bosson

Long Link: http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0922/DA-11-1591A1.pdf

Good People,

Click to this all important NPRM (Notice of Proposed Rule Making) on text to 911.   

Text to 911

This quote is kinda self-explanatory: 

"..we [FCC] seek to accelerate the development and deployment of Next Generation 911 (NG911) technology that will enable the public to send emergency communications to 911 Public Safety Answering Points (PSAPs) via text, photos, videos, and data and enhance the information available to PSAPs and first responders for assessing and responding to emergencies."

That, I tell you, is simply GREAT!  Text, photos, videos, and data?  Hurzzah!  

"While continuing to ensure reliable voice-based 911 service will always be essential as we migrate to NG911, adding these non-voice capabilities to our 911 system will significantly improve emergency response, save lives, and reduce property damage. "

No kidding! I know many of us can think of instances.  One example was my own experience; about 15 years ago when I lived in Austin, I witnessed a man beating up a woman on street.  I got home and called police via 911 (supposed to be available then) a few times, and gave up and went to my neighbor to make the 911 call.   By the time they got to the location, nothing there.    To this day I wondered if the woman survived or not.   

".. these 21st century communications technologies will provide PSAPs with better information that can be synthesized with existing databases to enable emergency responders to assess and respond to emergencies more quickly and effectively.  Not only will PSAPs be able to receive text messages, photos, and video clips from the public, but also NG911 can provide them with the tools they need to quickly process and analyze the incoming information." 

Good thinking; clearly this is needed.   

"In this Notice, we provide a procedural history, together with technical background, regarding three broad classes of text-capable communications, namely Short Message Service (SMS), IP-based messaging, and Real-Time Text (RTT), comparing their characteristics, strengths, and limitations in supporting emergency communications. This description relies largely on current industry standards, early prototypes, and the record in this proceeding."

"..long-term implementation of NG911, with particular focus on IP-based alternatives for delivering text, photos, videos, and other data to 911 that would leverage the increasing percentage of mobile devices that have the ability to access the Internet." 

The FCC identified problematic area with this remark:

"With over 6,800 PSAPs in the United States, spanning a wide range of sizes and resources, individual PSAPs are likely to have highly varying timetables for developing the technical and operational capability to handle incoming texts in the short term, as well as texts and other media in the longer-term implementation of NG911.  While there are significant public safety benefits to enabling the public to send texts and other media to 911 in areas where PSAPs are capable of receiving and processing them, we seek to avoid imposing unnecessary costs on providers to implement NG911 in areas where PSAPs have not yet achieved such capability."

6,800 PSAPs; whew!

"Given that text-to-911 and other NG911 capabilities will likely not be simultaneously deployed nationwide, consumers may be uncertain where non-voice communication with 911 is available.  Even where text-to-911 or other NG911 applications are available, the specific capabilities and operational characteristics of these applications may vary.  We therefore seek comment on how to best educate consumers about the availability and limitations of text-to-911 and other NG911 solutions, particularly during the transition from legacy 911 to full implementation of NG911, without imposing an undue burden on providers."

Maybe that's where we Deaf/HH can comment?

The rest of document goes into specific outline of various technical, service, operation, etc.   The very least reading all of them will certainly give you insight.  What I did was simply highlight important ones; there are more important comments so read on, dear readers.

 eyes open & thumbs up

Ed Bosson

Long Link: http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0922/FCC-11-134A1.pdf

Folks,

Check this link out.

CCInternet

The core purpose of this Notice of Proposed Rulemaking is the following quote:

"The Twenty-First Century Communications and Video Accessibility Act of 2010 (“CVAA”) requires the Federal Communications Commission (“Commission”) to revise its regulations to mandate closed captioning on certain video programming delivered using Internet protocol."

The following responsibility of the FCC I do not like because this could be a political tool as a way out of providing closed captioning because of "undue economic burdens" and this often is what I consider subtle discrimination: 

"..while ensuring that our regulations do not create undue economic burdens for the distributors, providers, and owners of online video programming."

Anyhow what is NPRM asking for?

Proposed rules:

• Requiring video programming owners to send required caption files for IP-delivered video programming to video programming distributors and video programming providers along with program files;
  
• Requiring video programming distributors and video programming providers to enable the rendering or pass through of all required captions to the end user; and
  
• Requiring the quality of all required captioning of IP-delivered video programming to be of at least the same quality as the captioning of the same programming when shown on television

Hey, these proposed rules seems to be on target for what most deaf/hoh want.   

Proposed schedule of deadlines:

• All prerecorded and unedited programming subject to the new requirements must be captioned within six months of publication of the rules in the Federal Register
  
• All live and near-live programming subject to the new requirements must be captioned within 12 months of publication of the rules in the Federal Register; and
  
• All prerecorded and edited programming subject to the new requirements must be captioned within 18 months of publication of the rules in the Federal Register;

"Craft procedures by which video programming providers and video programming owners may petition the Commission for exemptions from the new requirements based on economic burden".

On the preceding quote: I hope that the FCC will be very strict and not grant exemption all too easily; grant only when the provider will bankrupt because of CC (hell, if it were up to me, I would let them bankrupt because non-captioning videos have no value for me

I am not sure what to make out of the following quote.  Soothsayers of legal jargon, can you tell us in a layman's term what this means?

"Decline to treat a de minimis failure to comply with the new rules as a violation, and permit entities to comply with the new requirements by alternate means"

By alternate means, I hope does not apply to electronic voice to text because it is not perfect by any means.  

The following quote definitely is good; just hope that procedure to file complaints is easy and does not require first having to contact network provider or TV show, etc, before filing complaint with the FCC.  With regular TV, it is a nightmare to file complaint against TV show provider or network provider.  

"Adopt procedures for complaints alleging a violation of the new requirements."

As always your comments are most welcome if do it with respect.   

eyes open & thumbs up,

Ed Bosson

Long Link: http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0919/FCC-11-138A1.pdf

Folks,

An ongoing chronicle of certification procedure is coming to an end soon.  This post is long, but revealing!

First there is a certification procedure that dates way back to 1992.  When Internet Relay started (IP Relay and VRS), the FCC took hard look at the certification procedure and the FCC has made series of changes to the certification procedure.   I won't go into gritty detail on this, but do want to call your attention to two links and resulting decision as result of the Orders by the FCC.  It will show what is happening with those non-certified VRS providers.  

First this order:

May 31 Order

"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."

Basically that order mooted the waiver procedure which means the previous "new" rule now are no longer in effect because the FCC is reviewing certification procedure so the waivers that non-certification providers submitted are no good except for four providers that were asterisked (go to the exhibit on this link and you will see four providers with asterisk) along with LONG list of waiver requests.  It meant four asked more than one waiver so the FCC put these aside.  

If understood it right, all others that were not asterisked will not be certified. Basically the white label providers who had their waivers mooted, they did not come into compliance with other rules (the ones they did not ask for waiver on) so they failed in meeting compliance.  

Now yesterday's order was the decision making order.  

Denied 

Remember above four were asterisked, but three were denied the waiver requests.  

"In this Order, the Consumer and Governmental Affairs Bureau (Bureau), on delegated authority, denies three waiver requests filed separately by: (1) Deaf Link, Inc. (“Deaf Link”);1 (2) NorthStar Relay, LLC (“NorthStar”);2 and (3) ONE Technologies LLC (“ONE Technologies”)3 (collectively “Petitioners”)."

FCC stated: "..a waiver applicant “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.”21 In addition, the Commission required each waiver applicant “to provide, in writing, a description of the specific requirement(s) for which it is seeking a waiver, along with documentation demonstrating the applicant’s plan and ability to come into compliance with all of these requirements (other than the certification requirement)” within three months after the rules become effective, and elaborated that “[e]vidence of the applicant’s plan and ability to come into compliance with the new rules shall include the applicant’s detailed plan for modifying its business structure and operations in order to meet the new requirements."

And this: "The Commission further specified that it would grant waivers “only after a rigorous showing that the applicant has workable plans and the ability to continue providing VRS in a manner that will not undermine the measures adopted in [the VRS Practices R&O] to eliminate the fraud and abuse that have plagued the VRS program.”

Wow.   The FCC obviously meant business.  Funny Zero!

NorthStar: I know many of you want to know who each providers are:   Here is one good quote on who is involved with NorthStar:

"NorthStar was formed on May 18, 2011 as a combination of the Communications Access Center for the Deaf and Hard of Hearing (CAC), CP&J Investments, LLC d/b/a PAH! Relay (PAH), Interpretel LLC (Interpretel), Sign Language Access, Inc., d/b/a CallVRS (CallVRS), and URrelay, Inc. (URrelay)."

DeafLink:  I was given to understand that DeafLink absorbed number of white label providers, but did not mention in this order. 

One Technology:  OneVRS

All these three non-certified providers were denied the waiver means they can no longer provide VRS; more specifically they were denied waiver between June 1st and Sept 1.  

The certification procedure is by no means over; there will likely be still changes and more rule/orders from the FCC.  How many non-certified providers (white label) ultimately will be certified, I can't say, but it will be low. 

eyes open & thumbs up,

Ed Bosson

Long Link:

May 31 Order: http://fjallfoss.fcc.gov/ecfs/document/view?id=7021688064

Denied: http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0913/DA-11-1542A1.pdf