Ed’s Telecom Alert

Sorenson Comments

Long Link: FCC PN http://www.edsalert.com/wp-content/uploads/2010/05/DA-10-761A1-2.doc
NECA: hraunfoss.fcc.gov/edocs_public/attachmatch/DA-10-761A1.pdf
ZVRS: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020390383
Sorenson: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020445878

Folks..

As some of my close friends know, I have a lifetime dream to start a VRS business.  Over the years, I have had a few opportunites, but the timing was not right or the vibes did not vibrate.  

Until now, that is.   The vibes vibrated!  Out of respect for you great edsalert readers, I want to announce that three partners and I have teamed up and have formed a VRS provider; name of the company is Convo.  Who are the partners?  Wayne Betts, the famous movie maker; Chad Taylor, technical wizard, and Robin Horwitz, business savvy and go getter.  All of us are deaf. 

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…

A friend of mine used the term, Organic Minutes and it really hit off what I’ve been trying to say all along.   This is also to follow up on a couple comments that asked about should this and that be permitted or not; what does the FCC regulation say? and so on.

Definition of organic: Free from chemical injections or additives, such as antibiotics or hormones: organic chicken. c. Simple, healthful, and close to nature: an organic lifestyle.

This is clear enough.   I have organic vegetable garden now.  No  chemical solutions for herbicides, and pesticide are used.  Compost – healthy soil; for pesticide, I use hot pepper, insects and whip them into a solution and spray plants; for herbicide, I use my hands.  Result, healthy vegetable and delicious to boot and not have to worry about residues of sprays from chemicals used for pesticide and herbicide (Round-up, etc – horrors) affecting our health.

Same with Organic Minutes.   It means purely consumer driven minutes.  In other words, no telemarketers, no daily internal video conferences (by VRS staff), no online classroom or similar minutes are done.  This is how I view VRS industry ought to do; this is how I percieve TRS rules to mean.   TRS rules seem to be clear that any relay calls (text relay, Internet Relay, STS, VRS, and other horde features) should have two way participating parties thru relay agent/video interpreter.  In other words, both caller and called party should activately participate with each other.  So online classroom is out because this is not a true two way conversation.   The execption is answering machine and voice mails (it is in the relay rule).  Video conference calls are permitted, but it seems that a few VRS providers abuse that just to ramp up VRS minutes; not for the real reason why video conferences are held.      

Another important point to consider.  This is NOT about accessing various services available for hearing persons, this is about complying what existing federal relay rules (Title IV and subsequent Public Notices, Rule and Orders, etc from FCC) say what is permitted or what is not permitted.

So Organic Minutes means purely and clean relay calls between participating caller and called party.  Period.   I bet if VRS industry follows that, the total VRS minutes probably will be reduced maybe as much as 30% or more. 

I realize this is a very controversial issue.  I repeat, this is about what federal relay rules are about.   If you think online education should be permitted, address this with the FCC directly as FCC already said classroom interpreting is not permitted for VRS.  Same with other services that seem not to be permitted.  

eyes open & thumbs up,

Ed