Ed’s Telecom Alert

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