The FCC Rule & Order for TN and Emergency Access

25 06 2008

All..
The FCC has finally released a long awaited Rule and Order (R&O) regarding ten-digit telephone number - real telephone numbers, not proxy or aliases - will be assigned to VRS and IP users.   Purpose of this real TN is to make it possible for VRS and IP Users call an emergency call and the system will automatically identify the VRS or IP user who they are and where they are. Just like landline phone.  
Here is the link.  
The R&O is over 160 pages long. So I will try to have series of Vlogs to explain what the R&O is all about.
I’ll start with the obvious…and I know many of you are curious which of the proposals won out.   NeuStar with its TRU (Telephone Number for Relay User) proposal,   Joint Proposal -AT&T, HOVRS, GoAmerica, and Dash – with its ORD (Open Relay Database) proposal, and CSDVRS with its ONS (One Number System) proposal. Which of the proposals won out?    
Ferocious lobbying to the FCC Commissioners and Staff were done by many people and companies; there were lobbying efforts to deaf/hoh Mover and Shakers as well.   In the end, it is the majority of deaf/hoh who has indicated the wish for least resistance, least number of changes, and most seamless system to accommodate future upgrades be the ideal system. So the FCC listened and chose ORD as the basic building system to build from.   Congratulations to the Join Proposal team for coming up with a proposal that ultimately should be a win-win solution. 
As you know I’ve flip-flopped between TRU and ORD, but with inclination towards ORD.   The R&O from the FCC helped put weigh on ORD and so I’m now solidly behind ORD.  
Be on the lookout for subsequent Vlogs that will expand on some of the issues that will impact you all. So far what I’ve read are exciting changes. If you can’t wait, go ahead and read 160 pages and be enlighten and realize that functional equivalence concept is bit truer with the R&O.
eyes open & thumbs up,
Ed B


Telephone Number System for VRS

9 06 2008

All…

Wow - there is an intense lobbying by VRS providers and Number Service companies to the FCC that their "proposals" are best.

NeuStar #1

Interesting point by NeuStar that "path" of the video phone distributed video relay service will go thru even if another VRS provider is chosen as a default is seen as a virtue; that is, has added benefits if this is done.   NeuStar and HOVRS/GA proposals meet that.  

NeuStar #2

This is an interesting powerpoint comparison.

Sorenson PowerPoint

Makes case for NeuStar and HOVRS/GA Proposals focusing on ATIS recommendations. 

Long List of Comments 

For those who want to read long list of comments, go to this website, on right column click to "search for filed comment"  #1 type "03-123" and on #7 type dates from "03/01/2008" and type to "06/08/2008"  and you will get a long list of comments from various individuals, companies, etc. 

If you are curious which proposals I support.    What I look for is what is best for consumer; by that, I mean consumers should be able to have all the features of telephone system like video mail, caller id, etc., and after that I look for what is most seamless, least infrastructure changes, and minimum federal regulations added.  My vote would go to NeuStar and HOVRS/GA proposals.   On the paper, CSDVRS’s ONS proposal looks good, but in practice requires lot of changes -  substantive changes would be needed for VRS providers and the FCC would have to create new regulations.  In addition, I would want a system that will flow with the emerging future technologies, NeuStar best meets that need and so does HOVRS/GA. 

NeuStar proposals emulate VoIP system which is carrier-based, HOVRS/GA very similar except that one central number database service (in this case, they used DASH as an example), and ONS starts from scratch - actually the 800 number that CSDVRS give to VRS users is based on ONS technology.

Also, we would want majority of VRS providers and other number database service companies willing to cooperate, and that seems to be either NeuStar and HOVRS/GA.  

eyes open & thumbs up,

Ed B



How To File Comments to the FCC

5 04 2008

All..

This is a basic explanation on how to file comments with the FCC. 

Let’s say u read Rule and Order and it had docket 03-123 (that is TRS docket). You read the R&O, u got angry, and all flushed up and ready to file a petition for reconsideration. Or file a comments in response to PN seeking comments, NPRM or FNPRM, here is how.

Go to www.fcc.gov <http://www.fcc.gov/> then click on E-Filing on top of website Scroll down to "Electronic Comment Filing System (ECFS)"

and click to that

On very right part, click to "submit filing"

You will get an electronic form

  • On #1 "proceeding" input "03-123"
  • Fill out #3 applicantant name (yours),
  • #6 email address,
  • #7 mailing address,
  • #8 city,
  • #9 state,
  • #10 zip code

Now you have two choices:

One: Do a MS Word (or any write program) and then attach it. You can add several documents if u wish, not limited to one. For example, your document, two supporting documents, and perhaps one excel.

or Two: go down to bottom and fill out the comment area (typed in) (limited in how much u can write there)

then submit.

Note: The MS Word is probably better route but the comment area is easiest, but can’t do detailed and expanded comment. For that, you need MS Word or any write program)

eyes open & thumbs up,

Ed Bosson
RT Administrator