Ed’s Telecom Alert

Folks,

I will try to explain what the FCC terms means. This is not all comprehensive report by any accounts, tho. Just the most frequently used ones.

By the FCC: Public Notice, Notice of Proposed Rulemaking (NPRM), Further Notice of Proposed Rulemaking (FNPRM), Rule and Order, Declaratory Ruling,

By Public: Petition, Comment, Reply to Comment, and Ex Parte.

Rule and Order - basically means a decision in adopting a new rule or amending an existing rule has been made regarding an issue or several issues that were raised in the NPRM or FNPRM. THis is the final rule after reviewing comments, reply comments and ex parte presentations/letters/comments that were submitted to the Commission.

Notice of Proposed Rulemaking (NPRM) or Further Notice of Proposed Rulemaking (FNPRM) means that an issue or several issues need to be further explored - often it may focus on vendors or consumers or for everyone; depending on the issue(s). This is when the Commission invites comments and reply comments from the public. This is definitely where comments probably will make its most greatest impact.

Public Notice (PN) is the most common releases by the Commission as a way to communicate with the public. The Commission or Bureau post PN to announce on various issues and clarification on existing regulations. PN can be used to seek comments from the public on particular aspect of the regulation that requires the Commission or Bureau’s interpretation. PN is also being issued to seek comments in response to a Petition.

Declaratory Ruling means reminder for usually to specific group and sometimes for everyone on particular ruling that needs to be re-emphasized and/or clarified. A Declartory Ruling is often used in respond to a Petition for Clarification.

Petition means a person or company may petition a disagreement (Petition for Reconsideration which must be filed within a specific timeframe) or asks for change of recent or past ruling that the FCC had made; or may even petition some new idea that u feel the FCC needs to explore (Petition for Rulemaking). Petition for Clarificaiton to ask the FCC to clarify specifics from NPRM, FNPRM, Rule and Order, etc.  Petitions usually are written by lawyers hired by the companies, but I’ve seen individuals write petitions before.

"Comment" usually means responding to that was released by the FCC for first time - be it Rule and Order, and FNPRM - sometimes for Public Notice. "Reply Comments" usually means responding to the first round of comments made to the first released Rule and Order or FNPRM. Reply comments are often made in response to other comments or made to elaborate its previous comments. On a highly controversial issues, may even have third round of comments (which is usually referred as late filed comments or ex parte comments), but rare. Comments usually have between 15 to 60 day period of which to respond to. Reply comment almost always have 15 days of which to respond to.

Now if u respond after the specified period, the comments/reply comments then would be considered ex parte comments. Once a while, one does get Public Notice indicating that ex-parte comments carry as much weigh as the comments filed within specified period of time - rare, but has happened for TRS issues before.  It is vitally important that filing within the period time will get the attention of the FCC; ex-parte comments may or may not get the attention that the comments deserve. 

Now in filing comments/reply comments/ex-parte comments, always cite the Docket Number, and exact label of the issue and the date. It is always helpful to have a summary/introduction of your concern, and then follow it with expanded explanation. Try to use cites, or quotes or data, better if can use all, and try to offer ur explanation why. Lot of comments I’ve seen goes like this "I’m against [so so] because I don’t like their service" or even "I love the company, please support it" and no explanation of why. These kind of comments probably will be counted as "one" vote as pro or con. Those with detailed explanation will be analyzed and incorporated into the general recommendation - powerful impact, indeed to get to that. It would also be very helpful if you can present a solution. Its the question of "how" that the Commission is really interested in.

What role should u put in? Well, if u can safely represent an organization or club or agency (make sure u have their blessings), do so. If not, then if ure a CEO, do so. However, the FCC is particularly fond of getting comments from grassroots especially if the comments are well thought out and well presented with supporting facts along with substantive documents. Of course, just the comments with a heartfelt analysis will do. Even a pretty straightforward comments will do. Just keep in mind more info and docs one provide, the better chances of being incorporated into "recommendation" than to be just counted as one vote.

eyes open & thumbs up,

Ed Bosson
RT Administrator

Folks,

After talking with several relay veterans, I thought I’ll share our intriguing discussion regarding ten-digit ph nbr that the FCC will require come Dec 2008.   Also couple of comments to the recent vlogs will be included as well.

Obviously, we hope that the vendor workshop that the FCC mentioned in its Rule and Order would help resolve some of these following issues.  These are "what ifs" kind of thoughts. 

• If one has multiple-VP of same manufacturer in the same household, will the TN be assigned to all of the VPs?  Will all of them flash at the same time when they ring? 
• If one has multiple-VP from different manufacturers (i.e. MVP, OJO, VP-200) in same household, will it be possible to have same TN for all of the VPs, and all will flash at the same time when they ring?
• Will hearing person(s) with good signing skill that has a VP  be able to get a TN so deaf/hoh can call them?
• Will web camera with computer be assigned TN? 
• If the person has VP-200 (owned by SorensonVRS), and he/she choose, oh say, Viable, as his/her preferred VRS provider, will SorensonVRS be able to track person’s phone calls?
• If person’s preferred VRS provider is constantly busy, will other VRS providers have their own 800 number (instead of IP address) to offer? (Should be, but I ask that anyway.)
• Will Pagers/Laptop that use IP Relay get its own TN?  If so, how does it work if traveling?  How will pager/laptop access emergency center while traveling - will emergency dispatcher know where the person is?
• During a wide-spread emergency, like tornado hitting a city, or hurricane, or even - heaven forbid - terrorism, and calling the preferred VRS provider for emergency only produce busy time, can he/she call other VRS provider?  Will data or profile be shared among VRS providers so any VRS provider can handle emergency VRS calls?
• If resident only has one VP, and it breaks down, and had to wait for new replacement for weeks, and an emergency situation comes up, who should be held liable for that if any?  

Folks, if you have other issues that you feel should be considered, feel free to share.   

eyes open & thumbs up,

Ed B

Hey Folks,

This is what we’ve been waiting for.   Strongly suggest you read these links.  Good and valuable information there!  Very critical you send comments to this Rule and Order as well as the Public Notice.

FCC Rule and Order Emergency and Numbering

This one is about the FCC adopting emergency call handling requirements for Internet-based TRS providers.  What is "Internet-based TRS"?   It is Video Relay Service, IP Relay Service, and IP Captioned Telephone Relay Service.  It means that the FCC expects these Internet-based Relay Services be able to access 9-1-1 and be automatically recognized who and where the Internet-based relay user is.    Automatic Number Identification (ANI) and Automatic Location Identification (ALI) are part of regular telephone network, and the rule and order wants to see same thing for Internet Relay Services. 

The next part of Rule and Order is - ready for this? - about adopting a ten-digit numbering plan as soon as possible.   FCC wants to adopt a plan by Summer, and the ten-digit number be ready to be assigned to Internet-based relay users by December 2008.   Hurrrah!   The FCC plans to have a stakeholder workshop (mainly vendors as this will be focused on technological issues) that will focus on which and what kind of emergency plan should be adopted and implemented (I’ve send previous vlog on three proposals on this very thing). 

What does the ten-digit phone numbering system mean?  It means that any Internet-based relay users can have its own "real" phone number; not proxy phone numbers like Sorenson, SnapVRS, or CSDVRS or any others who assign proxy phone numbers.    The "real" numbers means emergency dispatchers will be able to recognize the numbers.  Also, a SorensonVRS user can call SnapVRS user with phone number instead of Internet Protocol address.    One can give the phone number to EITHER hearing persons or deaf person.  Hearing will dial the number and automatically redirect to preferred VRS provider.   VRS user can call direct to another VRS with same number. Nice! Very nice, indeed.  

 Public Notice On Numbering Issue

This is a Public Notice on establishing a global, uniform ten-digit telephone numbering system for VRS industry.  The FCC wants to address issues such as application of the "slamming", consumer protection (Consumer Proprietary Network Information - CPNI), local number portability, and number resource conservation - or for that matter any other issues you all feel may impact numbering issues.   The whole issue is to make Interned-based Relay Service a "true" interoperability. 

This is an important Public Notice that both vendors and consumers should respond.  I got one comment to other vlog about possibly applying the "universal" numbering system NOT just for VRS users, but for ALL who have video phones including hearing persons who have video phones.    This is looks like a great idea and this person who suggested that should submit that comment to this Public Notice.  

Again, strongly suggest you all submit comments to both of this Rule and Order and Public Notice.   On Rule and Order, if u have a preference of a plan to access e9-1-1 (see old vlog), express away.  Personally, I would vote for either Neustar or HOVRS/ATT proposals.   On Public Notice, you can emphasize the importance of having information of registrants be kept confidential and not use for political purpose, or share with other 3rd party, or whatever you feel should be done.   

It is a great opportunity to let the FCC know how u feel about this very very important issues that the FCC presents to the public.  

eyes open & thumbs up,

Ed B