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

Folks…

GoAmerica (The Purple folks) submitted a petition to the FCC.   See the link

GA Petition

Basically GoAmerica is asking the FCC

[Quote] "..to amend its rules (1) to prohibit the practice of providing “white label” servicesby uncertified entities receiving compensation from the Interstate TRS Fund through certified providers,and (2) to require applicants for Internet-based TRS certification to demonstrate sufficient resources and capabilities to provide an Internet-based TRS service."  [Unquote]

You need to read this to get the full story, but according to GA, a VRS provider must generate 20K VRS minutes, sufficient capital at least for one year, and other requirements.   This petition also could mean that all these domain names that are not certified by the FCC, should not allowed to participate with existing certified VRS providers.  This may include all the organizations, clubs, deaf schools, alumni associations, etc. that had signed up with a VRS providers. 

Also, these small VRS providers who has contract agreement with VRS providers who do have certification. According to the GA petition, these small VRS providers may not be qualified if the GA’s petition is accepted by the FCC.  In other words, if these small VRS providers want to participate, they would need to use domain name that is certified as VRS providers, not theirs. 

Healinc Telecom Rebuttal

The above link is a rebuttal to GA’s petition.  Healinc basically says that the real reason GoAmerica submitted the petition was to kill off competitors and prevent genuine start ups.  Healinc indicated that many of established telecommunications service providers got their start by partnering up with existing telephone companies and ultimately were able to stand on their alone.  Worth reading.  

Healinc makes a few good points, but I also think the company went to the other extreme, though.

The following link is a Public Notice from the FCC. 

FCC PN

PN lists schedules on when to respond, etc.   Remember responding before 30 days carries LOT MORE weigh than if you submit comments after the 30 days; that would become "ex parte comment".   It still carries weigh, but not as much as if you had submitted within 30 days.

My Personal Opinion.

Yes, definitely we need to minimize the ‘fly-by-night" VRS providers who do nothing but use their own sales people, contract with telemarketers to use VRS, use classroom interpreting, etc. to ramp up VRS minutes and not focused on genuine consumers who need to make VRS calls. 

This kind of criteria by GoAmereica may block genuine deaf/hoh or honest and ethical start up VRS providers from going into VRS business. On other side, Healinc may allow these fly-by-night operator "easily" become part of VRS industry.  My opinion is that both GA and Healinc are at both end of extremes; that we need balanced regulation to certify VRS providers. 

What I think should be written down is to require a VRS center, have broadband and call center resources in place, show a capacity to follow TRS rules, and, finally – especially this one - that VRS provider focus on consumers for VRS minutes; in other words, be consumer driven as TRS regulation intended it all along.   That’s it.  

One additional thought for FCC: If Internet-based Relay Services follow rule of regular TTY relay service, then there is a 5 year periodic review by the FCC for re-certification of service.  Because VRS is such an explosive industry, I would suggest that when review period for re-certification comes up, FCC asks hard questions to the VRS providers to ensure that they are following regulations to the letter.  Maybe even shorten the 5 year to 3 year review just for the startups to ensure that they’re following regulations.  Once FCC satisfied, go back to 5 years? 

If you feel strongly about this issue, please do submit!  The instruction to do that is in the link FCC PN above.  

eyes open & thumbs up,

Ed B

PS: BTW, the new FCC Chair has yet to be approved by the Senate.   So have not drafted promised sample of "congratulatory" letter yet.

Folks.. 

This is just a speculative musing with a suggestion for the FCC.   

As the VRS industry grows, and we’re seeing VRS industry testing FCC on some uncharted areas of sales, marketing and telemarketing within VRS providers. The relay regulations, for most part, are ambiguous on what relay services can be used for.  The original relay regulations seem to imply that relay services (all of them) is intended for relay users only (individuals who have communicative disabilities), and not for the relay providers to use themselves to make money.    

A couple or so of the VRS providers seems to be taking advantage of the implied allowance of marketing and taking it to the extreme that these VRS providers are making money off the marketing by utilizing many deaf/HOH employees. These VRS providers to best of my assessment either make most money out of marketing or at least sizable percentage of overall profit, not from VRS users outside of VRS employment. Whether deaf/HOH staffs succeed in their works or not seem not to matter cuz they are building up VRS minutes. 

That, to me, seems questionable or maybe even unethical? Theoretically speaking VRS providers should make most profit out of VRS users utilizing VRS for their personal and personal business uses, not from using their own employees to ramp up VRS minutes. 

 On other hand, there are remarks from decision makers that encourage relay service providers to let public know of their services (outreach and marketing).  So what if a few or many of VRS employees are deaf and they need to use VRS to do marketing/outreach for VRS providers?

If FCC prevents VRS from doing telemarketing, then that is not fair to deaf/HOH who may lose the jobs working for VRS providers.  On other hand, allowing marketing opens the door for possible abuses by VRS providers.  

Looks like a catch-22 situation.  What to do? 

Generally speaking, people who work in sales, telemarketing or marketing have to earn their keep; in other words, their work has to produce results for their companies – make money or achieve objectives.  If not, they lose the job.  

With this underlying concept; I have one suggestion.  

If VRS providers use their own people or contract out to do sales, marketing, or telemarketing services, the deaf/HOH can use VRS. However, at the break-even cost, not at the regular reimbursement rates. Any VRS minutes from deaf/HOH staff incurred from within VRS providers or telemarketeers who specifically use VRS providers that they contracted with, VRS providers should submit VRS minutes to the FCC at break-even reimbursement rates – not at $6.64 per min, but at break-even rates whatever that might be.  

In other words, VRS providers will NOT make money out of using deaf/HOH based on VRS minutes only.   That means deaf/HOH persons would have to "earn" their keep by doing their work successfully.

This effectively will not discriminate against deaf/HOH working within or who may have contract with VRS providers doing marketing work.  At the same time VRS providers do not lose lot of money or earn obscene amounts by ramping up VRS minutes at regular reimbursement rates.  Deaf/HOH persons in sales, marketing, or telemarketing would have to "earn" their salaries by achieving objectives for VRS providers. 

This, to me, seems a win-win solution between VRS providers and FCC. 

I want to see VRS industry succeed in a clean and ethical way, not dictated by greed and at the same time provide job opportunities for deaf/HOH to do work in sales, marketing or telemarketing. 

Readers, let us know if you think this is fair or not. If not, your rationale being?  

eyes open & thumbs up,

Ed

All…

I imagine many of you are wondering about portability issue regarding LN from VRS provider and VP from VRS.  Are both "portable"?  If you remember my past vlogs, right now  because of technology issues only LN is portable, not the equipment.  What does that mean?  It means you can’t port equipment to a different VRS provider.  For example, if you have – oh say – VP 200, and you like SnapVRS, you can port your LN to SnapVRS, but you cannot port VP-200 to use SnapVRS services.  

A big "but but" doesn’t Number Order require BOTH LN and Equipment be portable?  Order stipulates that, yes.  Is that a good idea?  Personally, I don’t think so.   We all know that if VRS providers are required to do that, you will lose the original features.   

CSDVRS Suggestion

CSDVRS suggests another approach which is for FCC to:

"Eliminate requirement for CPE to operate on another VRS provider’s network when the user ports his or number to a new default provider."

What this means, port only number, not the equipment to a new VRS provider of your choice.  Rationale: increase incentive for VRS provider to stay in the game and improve their features (if forced to port equipment, they may stop doing research and development for new features or worst still may abandon VP altogether), functional equivalent to VoIP and Cell phone industries (have to give up equipment to get a new equipment if you change to a new service), and other what seems to me justifable rationales.

Click and see what you think.  Let us know..

Remember this is not a rule making proposal – at least not yet.  CSDVRS will need to submit a rulemaking request to modify existing Number Order on this if the company wants to pursue it further.  

eyes open & thumbs up,

Ed

All..

Finally Obama selects a person to be the Federal Communication Commission Chair, and he is Julius Genachowski – easy to memorize the name, go like this: GENA CHOW SKI.   Here are several links to the articles:

CNET Article

CNET article focuses on Genachowski as strong advocate of Net Neutrality which in my humble opinion is a good thing.  

Info Week Article

Info Week article said that was the worst kept secret that was finally confirmed by Obama’s announcement.  Article mentioned Genachowski did a legal work for Reed Hundt (for those of who shot up balloon of question on Hundt, he used to be FCC Chair and was a strong supporter of persons with disabilities).

WJ Article

WJ article mentioned that Genachowski did fund raising event and raised $500K and was the top technology advisor to Obama during campaign event. 

I can safely say that I KNOW that deaf leaders in DC area will endeavor to have a meeting with Genachowski as soon as possible to get their congrats and try to get Genachowski’s support for persons with communicative challenges in the telecommunications world. 

What happens next is for the Senate to confirm him.  It seems very good chance of that.  

Important: Once Genachowski starts working for FCC, I urge you all to send him a congratulatory email or letter and be sure to let him know you’re deaf, hoh, speech disability, or whatever disability you have so he will know there are people with disabilities watching him closely.

eyes open & thumbs up,

Ed

Folks,

One thing that the FCC requires of VRS and Internet Relay providers is the ability of deaf/hoh users to be able to port their LN to a different provider.  Local Number is what you received from your original (default) provider.  

Porting simply means you can keep your LN when you change to a new default VRS provider.  There are several items that you all need to be aware of when porting LN to a new provider. 

If you decide that you want to change to a new VRS provider but keep your original LN, you do the following action. 

Contact the new VRS provider and tell them you want them to be your default provider and would like to port the LN.   The new VRS provider will take care of the request, and should be able to continue to use LN immediately; if not immediately, then very soon.

Many people ask this question: can you keep your original VP and be able to port to a different VRS provider? For example if you have an OJO (SnapVRS as default provider), and you want to port LN to, say, Viable as default provider and use OJO, Is this possible?

Right now the "best" answer in this particular case is no, and you would need to give up OJO, and accept VPAD from Viable, but you CAN port LN to Viable/VPAD and use same LN. 

Side note: according to the FCC rule, this porting LN to a different VRS provider and keep the original Video Phone is required by the regulation.  Unfortunately, right now this is not possible with most VRS providers.  

One issue that you all need to be aware of is that the subsequent clarification by the FCC seems to show that rule permits original VRS provider to STRIP all features except this two features: be able to call new VRS provider with the ten digit phone number; and when you type in LN to make a VRS call, VI should be able to automatically call the party of that LN you gave without you having to fingerspell the phone number you want to call. 

What about the stripped features?  Supposedly, new default VRS provider can add their new features to the original VP.  However, at this time to my understanding ALL VRS providers are not able to "add" new features to the VP that they do not distribute.  When will VRS providers be able to do that?  It won’t be right away – one or two years? Or maybe none? We’ll see how the VRS industry and the FCC work that out. 

So if you want to keep LN, a few possibilities seem to be these following items at this time: 

These require porting procedure:

1. You can port LN to new VRS provider and keep original VP and then lose the features of original VRS provider, and accept new features (see above remarks on that).
2. Or you port your original LN and give up your original VP and get a new VP from new VRS provider; that way you keep your original LN (this can be done now). 

These do not require porting procedure:

1. Stay with your original VRS provider; don’t go to another VRS provider. 
2. Or you can keep your original LN and original VP, and just add the other VRS providers to the address book (this can be done easily and most likely most people will do that).  
3. Or get multiple LN from each VP (VRS Providers) if you have several different VPs  (if you have several VPs, this is the most likely course of action that most of you will take.) (See my previous vlog on this.)

Hey, what about these VRS providers who do not distribute VP and you got LN?   I think it is gonna be a problem.  If I understand the relay rule right, you cannot get a LN with no VP.   

eyes open & thumbs up,

Ed

All..

This is another series on LN.

Let’s say you have one VP – oh let’s use VP-200 as an example because that is the VP majority of VRS users use.  You decide to have SorensonVRS as your default provider.  Can you call other VRS providers with VP-200?  Absolutely!   Just add other VRS providers to the address book.  That is one rule from the relay regulation. 

Same thing for any other VP.  Let’s say you decide to use Z-150 (CSDVRS) as your default provider, you can add other VRS providers to the address book of Z-150.  

Keep in mind that if you give the LN from default provider to businesses, relatives, hearing or deaf/hoh friends, any incoming calls will come through the default provider.  

Be aware that if you make an emergency call, use your default VRS provider to call for emergency assistance.  Why? Because the system is set up where default provider will be able to get your info immediately and share with emergency dispatcher.   If you call for emergency assistance to a non-default VRS provider, video interpreter will have to ask you lot of questions to find out where and who you are.   Takes longer.

Tip: One way to get around to this problem is to get LN from ALL of VRS providers that distributes video phones; that way, all of them will have access to your important data immediately.  See my previous email on "multiple default LN and VRS Providers".  

eyes open & thumbs up,

Ed B

All..

Based on numerous emails and video calls I’ve received, it is glaringly obvious that many deaf/hoh persons still do not understand how LN (Local Number) Procedure works out with VRS.

I will try to do series of vlogs to clarify a few of the LN issues by focusing on one or two items of particular issue.  

Here is the first one:

MULTIPLE DEFAULT LOCAL NUMBERS PERMITTED:

I am sure many of you are puzzled that you get emails, and video calls from VRS providers that you must get LN because the FCC required that and I know many of you hear from VRS Installers who tell you that you MUST choose one "default VRS Provider" to obtain ONE LN as to make the emergency procedure efficient.  

As consequence, many thought it means only you have to choose one VRS provider to obtain one LN and that you are limited to ONE VRS PROVIDER and ONE LN. 

Well, the way the regulations are written now, deaf/hoh CAN get LN for EACH video phones.  For example,  if you have OJO, Z-150, VP-200, VPAD and MVP – you can get LN from each of these VPs.  In other words, you can have FIVE (5) default local numbers and FIVE (5) default VRS providers.  The FCC regulation does NOT forbid that.   You can have more than one default VRS providers and more than one default Local Numbers; however, keep in mind that this permission may change in the future.  

Quick comment on this: my personal opinion is that in the future, I think we should be limited to ONE default LN, ONE default VRS Provider, but be able to access to all other VRS providers; however, much needs to be done on relay rules by the FCC FIRST before adopting that, though.  

eyes open & thumbs up,

Ed B