Ed’s Telecom Alert

Folks,

As I get ready to go to Ark for a 50 year high school class reunion, noticed a letter to the FCC and thought I'll post that before the trip. 

It is a letter to the FCC from TDI, NAD, ALDA and, CCASDHH on following up on a meeting with the FCC expressing caution to the FCC to make the right decision on VRS reimbursement.

LETTER

Quotable quotes:

"..to discuss a likely Notice of Proposed Rulemaking (“NPRM”) that may include proposed changes to the per-minute rate of compensation mechanism for Video Relay Service (“VRS”)."

"..For example, the Commission’s NPRM should include questions about how to provide incentives for VRS providers to engage further in technological innovation, research and development, outreach and education, etc. Whatever compensation methodology the Commission adopts for VRS should support these incentives in a substantial way."

"The Consumer Groups expressed concerns that a per-user system would create incentives for providers to avoid high volume customers, that providers may game the system to reduce the number or length of calls from customers (i.e. longer answer times), and that consumers need the ability to change service providers if service quality deteriorates, just as hearing users have the ability to switch telephone providers (e.g., wireline to cable)."

It is good that the Consumer Group and the FCC are communicating on this very important issue.   Remember this is a letter reporting on a meeting that the Consumer Group had with the FCC so not everything is reported in the letter.  If you want to understand this more, contact the FCC or the Consumer Group.  

eyes open & thumbs up,

Ed Bosson

Long Link: 

http://fjallfoss.fcc.gov/ecfs/document/view?id=7021712351

Folks,

A combined telephone representatives expressed a concern in their letter that I agree.

USF DEBT

I know Congress is desperate to find additional funds to pay off the debt, but this quote scares me.

"Our concern first materialized upon seeing the flawed recommendation in the December 1, 2010 report of the National Commission on Fiscal Responsibility and Reform that identified the private Universal Service Fund (USF) as a source of public debt reduction."

"And in recent days our unease has grown as we have learned that the Joint Select Committee on Deficit Reduction may also be focusing on this ill-advised proposal."

Basically this is saying why not use USF to pay off federal debt.   

"Throughout its long history, the USF has always been maintained outside the U. S. Treasury and managed by a non-governmental entity."

The above quote, I agree.   The sticky problem is whether the USF is a public fund or private fund?   This group responded to this with the following quote:

"..legal precedents and guidance definitively confirm that the USF monies do not constitute “public monies” that are received for the use of the United States, but rather are private funds that are merely derived and distributed at the direction of federal statute. "

Now I admit I am at dilemma.  In this very edsalert, I have maintained that TRS Fund is a public fund.  What I believe is that any private funds contributed into a "public" service now becomes public fund.  However, I am of the opinion that even though TRS Fund is public fund, it is used only for TRS alone and cannot be used for other.  I see the same thing for the USF.   However, I see that this group is concerned that Congress looks for loopholes to use "public fund" to pay off the federal debt.   Their worrisome concern is valid, I think.  

Let me know what you think?  

eyes open & thumbs up..

Ed Bosson

Long Link: https://prodnet.www.neca.org/publicationsdocs/wwpdf/92611ntca.pdf

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