Petition to the FCC by Group of TRS Providers

30 01 2009

All..

You all will find this interesting!    Basically 9 TRS providers – ATT, CAC, CSDVRS, GoAmerica, LifeLinks, Snap Telecomm, Soreonson Comm, Sprint NexTel, and Viable have petitioned the FCC to clarify that multiple CAs (Communication Assistants – really same as telephone interpreters) which include video Interpreters, TTY CAs, STS CAs, IP Relay CAs, deaf blind Interpreters, Captioned Telephone Interpreters and multiple services services  and technologies (all relay features) should be reimbursable.

For example right now TTY users are not able to communicate with VRS users.  STS users not able to communicate with VRS users, Captioned Telephone users not able to communicate with VRS Users, and so on.  Petition says that combining TTY and VRS into one service should be reimbursable; in other words, when a TTY user connects to a VRS user (both deaf), petition says the fund should pay for both CA of TTY service and Video Interpreter for VRS.

The petition argues that these are necessary to achieve functionally equivalent telephone services based on their interpretation of relay regulations. 

It is obvious that the Relay providers stand to make more money to do these services if approved by the FCC.

Click to this link, and read their rationale why these type of multiple-CA services should be reimbursable.

Petition of Clarification

If the FCC does rule that these type of services are reimbursable; my personal opinion is that I think the FCC needs to be very careful; that is, they need to spell out regulation clearly and have the capacity to enforce regulations against abusing practices because I can see a few vendors would take advantage of that and ramp up the unnecessary minutes to make lot of money.   The FCC has not succeeded in clamping down unethical and illegal practices by a few VRS providers (at least so far not yet), so I would wonder how the FCC would handle abuses for the new services if the order is given to reimburse these services.  

Also, it also would mean the cost of providing relay service would go up even more, possibly passing the red flag of  1 billion dollar.  How would the decision makers (the FCC Commissioners, Congress, or even White House) feel about that?   Oh, what about state relay regulators?  In times of economic hardship nowadays, most states likely will not support that. 

Even so, the petitioners do have a case.   I think the eyes will be on the FCC now and the burden will be on them.  Personally, I kinda support the petition, but I would want to see the FCC Enforcement Bureau take actions on unethical and illegal practices of relay vendors first before approving that.  

Tell me, typically upfront Readers of Edsalert, what you think?

Ed

eyes open & thumbs up,



Ex-FCC Chair Martin Defends His Actions

22 01 2009

All..

The very first thing in his letter that he defended was his actions with telecommunications relay service.  Discussed the rates of VRS; said it was under his reign that VRS prices were lowered, and then went on to say that he defended current rates based on the deaf/hoh communities feedback.  

(Note: see how important it is to send emails/letters/faxes, etc to the FCC – they do read them even though it may "feel" like they are not.)

Martin Letter Defends His Actions

In reading his defense, it is apparent that he is a republican, and he believes that letting business industry take care of their problems are the best model.  

I will let history speak on whether this is the right decision or not.   Anyway, it is worth reading his defense, and, granted – a few remarks that was said makes sense – some I felt were based purely on political maneuvering.  

eyes open & thumbs up,

Ed



Technology – more on service than devices?

16 01 2009

All..

Interesting article which seems to re-affirm the trend we’re seeing in the VRS industry.  In the beginning, it was enough that deaf/hoh just get the "device"; that is, video phone.  Not any more.  Over the years, the trend is now we look at the quality of service and features of the Video Phone.   It seems that now most of the video phones, the video quality are all good – at least most of them so service (interpreting and support service) and features (video mail, call waiting, missing call list, etc) are now sought after and compared. 

Tech Svc vs Device

Also, in that article it mentioned 3-D as the next wave of future; Golly, can u imagine VRS using 3-D monitors and seeing Video Interpreters and friends or relatives in 3-D image?   3-D on a monitor will give the impression that the person is in the monitor instead at the studio.

eyes open & thumbs up,

Ed

 



What Can We Expect from Number Order?

6 01 2009

Happy New Year, Folks!
Here are two links to the Number Order by the FCC. First one is the “advisory comments” of the Number Order, and the second one is the Number Order in itself in its all complication splendor.
FCC Consumer Advisory (same one as the last post)
Full blown Order on Number - if you want gritty details, click to this one. 
I may need to follow up with a few Vlogs or blog or comments on the recent Number Order by the FCC. I will decide on which particular issues to cover with based on comments and video calls I will receive from some of you. At any rate, I will try to pull out information that is important to consumers, and leave out the techo-babble and cost reimbursement stuff.   
One thing is clear from the Number Order, though, is that all of us can get Local Telephone Number (abbreviated to LTN) from VRS and IP Relay Providers.   That’s GREAT news and Exciting! 
Here are the basic items:
  •  Once deaf/HOH gets LTN, the LTN can be shared with other deaf who have VP; but it cannot be just any VP, it has to be a VP that deaf/HOH got from a VRS provider.
    •  Meaning if a deaf person has a PolyCom Video Phone or pretty much any video phones that were not distributed by VRS providers, he/she would need to use an Internet Protocol Address to call other VRS users. If you did not get your video phone from a VRS Provider, you will not be able to use that video phone to call 9-1-1. Please use your TTY instead.
  • Your LTN can be shared with any hearing person. Hearing persons do not need two sets of phone numbers to contact a VRS user. Your telephone number will automatically connect to hearing through the default VRS provider that YOU chose.
  • Most VRS Providers, who gave you the equipment, may contact you to ask you to register to get a telephone number. This telephone number will be what 9-1-1 identifies when you dial 9-1-1 during times of an emergency.
  • Only VRS and IP Relay Providers can give you a new telephone number. You cannot get a telephone number from a phone company that is not associated with VRS or IP relay service (not now, maybe in the future).
  • Once you get the LNP, you can use it immediately (nice). 
  • Only deaf/HOH can get telephone number for Video Phones; hearing person at this time cannot get LNP for video phone. (The following is my comment: I was disappointed to see that, and sincerely hope that will change in the near future as many of us have hearing relatives, friends and business associates who can sign.)
  • Deaf/HOH MUST register with VRS Providers, no exceptions; this means giving your name, address, where you live, and any important information that E911 may need to know.  
  • VRS providers are allowed to verify by whatever means to ensure that deaf/HOH live at that address; not unlike credit card, bank accounts, etc.
  • In addition, VRS providers MUST verify that registrants are deaf/HOH, and allowed to employ procedures to determine that. 
  • § So if they ask you questions, these are the reasons why.
  • The FCC allows for you to use the current “fake telephone number” (alias and proxy numbers) you have been using up to 6 months. After 6 months, these numbers will not be allowed; 800/866 will be permitted only if “geographical telephone numbers” are assigned to 800/866 numbers. 
    • In other words, deaf/HOH must have registered and received your telephone number first, before you can use 800/866.  
  • First 3 months are for “eligibility period”, and the last 3 months is a “permissive calling period”.  Meaning that VRS users must register within the first three months.
  • After 3 months, VRS providers  are required to notify any VRS calls they receive that VRS users will need to register for LNP. After the cut-off time (June 30, 2009), VRS providers will not process any VRS calls if the Video Phone user is not registered with any one of VRS providers.
  • Deaf/HOH persons are allowed more than one LNP; for example, one LNP for Video Phone, and one LNP for pager/laptop. 
  • Right now, due to technical reasons, you will not be able to use the same telephone number for multiple devices in your home. Meaning, if you have an Ojo downstairs, and a Sorenson VP200 upstairs, you will need to get a separate telephone number for each.
  • Hopefully in the near future, when all the equipments are compatible with new standards in place, you will be able to have same telephone number for each device in your home even if different from each other.
  • However, if you have, for example, two VPADs in your home, i.e., downstairs and upstairs; you can use the same telephone number for both of VPADs.  
  • You will need to check with your provider first to make sure the devices they gave you can do this type of set up.
  • To have the same telephone number for VP and Cell Phone/Pager is not possible; each must be assigned a LNP separately.
  • However, VRS providers can if they have the feature of “forward call” where a VRS call can be forwarded to IP, or vice versa. That is up to VRS providers to offer that, the FCC does not disallow that. 
  • All 911 calls processed by VRS providers must have the capacity to:
  • Carry a call back number; for example if the video call got disconnected, then Video Interpreter will need to be able to call back to VRS user immediately.
  • Name of relay provider
  • Video Interpreter or IP Relay Agent identification number
  • The Caller (deaf/HOH) Registered Location (data needed for the emergency dispatcher to know where/who/what)
  • Video Interpreters during an emergency call are allowed to record everything in case the call to emergency dispatcher gets disconnected, and Video Interpreter will be able to relate to emergency dispatcher what happened.
  • VRS providers are required to put any 911 VRS call to top of its queue waiting list.
  • VRS providers CANNOT break into any VRS calls they are processing and close the regular VRS call then accept an emergency call.
  • When connecting to a 9-1-1 through VRS the Video Interpreters are allowed to identify pertinent information from viewing VP (see fire, gun waving around, etc.) that may help emergency dispatcher assess the situation realistically. 

The following issue is bit complicated; try to read this carefully. 

  •    Portability Issue:   what this means is if you are not happy with the VRS service you signed up with in the beginning and want to make a switch to a new VRS provider, all it requires is that you, the deaf/HOH person, can simply go to the new Provider and tell them you want to use their service and keep the telephone number you have. The new Provider will contact the old Provider to work it out. You do not have to talk to the old Provider at all. 
  • Important for you to know that at this time; if you switch to new VRS provider, you may not get the same features that you had with previous VRS provider. The new Provider may not have the technical standards to continue the VP’s look on your screen. So it is very important that you ask if they can do this before you make the switch. Not all Providers are up to par yet. If the new Provider cannot manage your existing videophone from their end, then you may be given a new video phone from the new Provider and you should still be able to keep your telephone number.  
 
If you have problems with above, please feel free to share with me so I can inquire with the E911 Stakeholder Council of which I am member of and working on these issues.
Well, that is about it. Do let us know what you think of this and do feel free to ask questions; I will either respond via comment or vlog.
eyes open & thumbs up,
Ed B