Sorry I don’t have time to do summarization of each, but thought I’ll list that posted to the FCC on NOI.   

Here are the links to various VRS providers…average is 50 pages long.    I hope I matched the link to right provider right.  ;-]

Those of you with brave soul willing to read all, let me know what you think of them.   

ATT Comment

Purple Comment

Sprint Comment

SVRS Comment

ZVRS Comment

This one is from a collective national organizations: TDI, ALDA, NAD, DHOHCAN, and AADB.

Coalition Comments

RID Comment

eyes open & thumbs up,

Ed

Long Links:

Purple Comment: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708990

SVRS: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708951

ZVRS Comment: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708904

Coalition: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708952

RID: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708856

Sprint: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708932

ATT: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708928

Normally I would quote statements or offer a brief summary, but the NOI has well over 150 questions.   So you all will need to read them.   Some comments are easy to understand and some are not.    There are little over 50 pages.  

Convo Comments

As soon as other VRS providers submit their NOI comments, I will post them as well. 

eyes open & thumbs up,

Ed

Long Link:  http://fjallfoss.fcc.gov/ecfs/document/view?id=7020708312

Here are misc news of happenings recently – short ones.

4 Petitioners Motion

"An extension of time is necessary and in the public interest to allow interested parties to gather information, conduct meaningful dialogue concerning the intertwined and dynamic issues presented with respect to video relay service (“VRS”), and to allow commenter to develop meaningful in-depth positions concerning this critical proceeding."

"Such an extension is particularly warranted in light of the Commission’s desire for input on so many varying critical questions relating to the VRS program’s effectiveness, efficiency and sustainability, as is the case here.
Petitioners therefore submit that a reasonably moderate extension of the comment deadline will enable stakeholders to more thoroughly evaluate and respond to the NOI and thus provide more substantive, thorough and thoughtful comments."

FCC Denies SVRS’s Stay Motion

Basically FCC denies SVRS’s Stay Motion.  Here is a quote:

"Although Sorenson nominally seeks a "stay," it asks not just that we stay the interim rates, but also that we take affirmative steps to re-institute the former VRS rate that expired on June 30, 2010. For the reasons set forth below, we deny the request."

As result, SVRS now seeks court to overturn the FCC’s decision.    

Contribution Factor

Contribution factor simply means when National Exchange Carrier Association "collects" from all telephone companies, etc. to "contribute" to Interstate TRS Fund.  Interstate TRS Fund is what reimburses all relay providers.

The pertinent quote that basically address the main issue:

"Based on the adoption of these rates and NECA’s proposals, the Commission hereby adopts a carrier contribution factor of 0.00585, and a funding requirement of $433,990,484.98 for the 2010-2011 Fund year.11    The Commission adopts these rates, and this contribution factor and funding requirement, for a period of one year, except as otherwise provided herein."

eyes open & thumbs up,

Ed

Long Links:

4 Petitioners – http://fjallfoss.fcc.gov/ecfs/document/view?id=7020550986
FCC Denies – http://fjallfoss.fcc.gov/ecfs/document/view?id=7020549754
Contribution – https://prodnet.www.neca.org/publicationsdocs/wwpdf/fcc10115.pdf

Ladies and Gentlemen, this NOI is very important and MOST certainly will have a far-reaching impact on defining exactly what VRS is and the rationale for compensation rates for VRS providers.   This NOI will be exhausitive undertaking for sure.

FCC quote:

"In this Notice of Inquiry (NOI), we take a fresh look at the Commission’s video relay service (VRS) rules so that we can ensure that this vital program is effective, efficient, and sustainable in the future."

"..a fresh look.." certainly is an understatement of the century!  The FCC is taking a bold steps to of possibly overhauling the infrastructure of VRS. Is that good?  Yes, I believe so, but this is where critical comments are critical.  We – by "we" I mean ALL of us – need to respond to let the FCC know what we think VRS ought to be and how VRS providers should be handled.  

FCC presents NOI in two parts:

Part One: basically seeks whether multiple VRS providers, one or a few should be adopted and why, etc.  

Part Two:  basically asking to whether VRS should be re-defined or not.   If so, how so and in what way, etc.  

Caveat here: above summarization does not tell whole story of the NOI.

The whole purpose of NOI is to gather information from all concerned, and then the FCC will make its final decisions.   Click to the link, and be prepared to cultivate patience as it is a long reading.  

FCC Notice Of Inquiry

Since this is long NOI, best way to show items is via the table of contents which I typed briefly below.

Part I Adjustments and Modifications to Improve the Current VRS
Compensation Methodology
1. Accounting Issues
2. Company-Specific Compensation
3. Outreach and Marketing Costs
4. Research and Development Costs
5. Videophone Equipment
6. Protection of Providers from Under-Compensation and Avoidance of Over-compensation
7. Certification

Part II – Broader and Economic Issues Concerning VRS
1. The Components of VRS
2. The Demand for VRS
3. The Supply of VRS
4. The Regulation of VRS
5. The Incentives of Providers
6. The Incentives and Needs of VRS Users
7. Other Regulations Affecting VRS Communications

Just by looking at the terms used for table of contents, one could say that the FCC is going to collect lot of comments from VRS Industry as well as the movers and shakers of the TRS world.  Again, I cannot stress strongly enough that this is very important NOI and possibly the most important ever in the history of TRS. 

eyes open & thumbs up,

Ed

Long Link: http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-10-111A1.pdf

The Interim Rates for VRS are finally out…

Basically the FCC Order rejected the NECA’s proposed rates and adopted the following interim rates for VRS. 

Rates

New Tiered Rates:

Tier I      $6.24
Tier II     $6.23
Tier III    $5.07

Past (current) Tiered Rates were:

Tier I    $6.70
Tier II   $6.43
Tier III  $6.24

NECA’s proposed rates were:

Tier I     $5.78
Tier II    $6.03
Tier III   $3.90

Interim means temporary.   This is for one year.    The final rates will be decided after all the comments based on past and future comments from all the comments that have and will address VRS rates. 

At any rate, these rates seem to be reasonable for all concerned – they’re what I would call "workable rates" pending future rates.  

Side note: according to the DebtWire, this seems to be reasonable even for SorensonVRS at Tier III rate as DebtWire indicated that if rates are above $4.90, SVRS will be able to pay its debt obligations and still reap about 140 Million Dollars a year as profit.  

eyes open & thumbs up,

Ed

Long Link: http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-10-115A1.pdf

CAD – not unlike NAD – submit its comments along with Sign Relay Canada on FCC’s ruling that no call centers outside of USA shall provide VRS for USA.  

CAD Comments

Comments indicate that despite more than 8 years of lobbying by CAD, and other organizations as well as individual, Canada still does not have VRS.   I sincerely hope that Canada government ultimately understand the underlying needs of deaf-hoh in telecommunications access and realize that VRS is the best service for the deaf-hoh.  I feel the pain of deaf Canadians as I went thru first 20 years of my life with no TTYs let alone relay service (no, I am not that old

Quotes: 

"..recently cracked-down on ineligible calls originating in Canada, there is little consistency or clarity in the implementation of the relevant rules; for example, some providers still accept calls originating in Canada as long as the callee is located in the U.S., other providers do not. Thus, the Commission needs to set and enforce a more comprehensive policy regarding the eligibility of VRS calls that originate outside the U.S."

Below is reference to establishing call centers in Canada.  

"..there has been an immediate siphoning of the available pool of interpreters in the affected community as these skilled professionals are attracted to the salaries, security, and other benefits offered by VRS providers. Hundreds of requests for community interpreting services must be turned down each year as a consequence of this drain upon the supply of interpreters. We know of dozens of cases in which Deaf Canadians have been forced to leave school and post-secondary institutions, have lost jobs or job interviews, have been denied important medical services including mental health or substance abuse treatments, and have missed out on meetings relating to vital social supports, because interpreters are no longer available once VRS call centres have been established in their region."

Wow – these are very strong words, indeed.   In the early years of VRS, USA experienced the same thing – but not anymore now – well – at least not as much anymore.  

"As it stands now, American VRS is a predator that is doing profound damage to the lives of Deaf Canadians without any offsetting benefits to us."

Now that is generalizing and not fair to VRS industry.  To my knowledge, only one VRS provider have call centers in Canada and that’s SorensonVRS.   SVRS although the largest VRS provider is most certainly not representing USA in VRS industry.  I wish CAD comments would list the VRS providers that have call centers in Canada so other VRS providers who do not have call centers in Canada will not be damaged by this generic accusation.  

Finally this quote:

"For the above reasons, the CAD and SRC recommend that either American providers of VRS be required to locate all of their call centres in the U.S., or that the Commission permit the extension of reimbursable VRS calls to include calls originating and terminating in Canada that are made through the providers that have established call centres in this country."

I agree with CAD that American Providers be required to locate all the call centers.   Indeed, VRS providers should report to the FCC all listed call centers.  

Where CAD says FCC should permit extension of reimbursable VRS calls to originating and terminating in Canada? What this is saying is USA should permit USA funds to pay for Canada VRS.  Oh,that can amount to many millions of dollars annually!   Even though Canada is friend of ours, I think Canada should pay for its own VRS, not USA.

However, I can say that America VRS providers would be happy to provide VRS if Canada is willing to pay for the service.  

eyes open & thumbs up..

Ed

Long Link:  http://www.prodnet.www.neca.org/publicationsdocs/wwpdf/6410cad.pdf

Check this out.    Got this letter from an aide of a congressman of which I appreciate.  

29 HR Reps Letter

Quotable Quotes:

"We note with concern that the Commission intends to shift from the long-term compensation method it adopted unanimously to a "cost plus" method which may not account for the real costs of providing VRS.  It is also troubling that the proposed compensation rate structure could result in certain VRS providers being paid as much as 50% more than others for the same service."

"We do not see a connection, however, between fraud issues and the rate structure. If the Commission does see a connection, we would be interested to hear how the Commission believes the proposed rate changes address that problem."

I am puzzled by the first paragraph.    FCC released the cost rates and asked for comments which means the FCC wants to hear from commentators so the decision has not yet been made.   I believe FCC allows profit margin of about 11.25%. 

On the last paragraph, there is, to my best of my knowledge, no FCC public notice that ties fraud to rates.   The only thing I can recall is the farewell letter from Tom Chandler (he left FCC to join DOJ) which mentioned that.  If I am wrong, kindly correct me on this.  

One other observation is that first two signatures were from Utah.  

At any rate, FCC will have to respond to that; especially with 29 HR Reps.

eyes open & thumbs up,

Ed

Long Link:  www.edsalert.com/wp-content/uploads/2010/06/Signed-Chaffetz-Bishop-Ltr-29-total-signers-2.pdf

Basically, FCC wants to clarify and explore few issues.   FCC wants to address whether reimbursable rates should apply for certain types of calls using VRS or not.

Before I go on and outline, I want to point out one interesting interpretation by the FCC that – frankly I find the statement somewhat offending.

"The statute and regulations provide that TRS users cannot be required to pay for the costs associated with relaying a call.  Therefore, TRS users are not strictly "consumers" or purchasers of a service; rather they are the principal beneficiaries of a federal program that gives access to the telephone system." 

Hey, that sounds like welfare. Does not meet the definition of ADA which Title IV (relay regulations) is part of.  Anyway, this one I will have to chew on.  Remember TTY relay service was based on using existing telephone network; VRS uses Internet (not unlike VoIP using Internet).  Does that make difference, I think it does, but will discuss this particular issue at another time.     

Order:  adopt the interim rule "to make providers more accountable by requiring senior executives to certify compliance with our regulations under penalty of perjury."  

Good rule, but I thought that was already done.  I will have to chew on this as well.  This interim rule, however, is NOT asking for comments, and basically said will enforce it without due process.   "We adopt this interim rule without notice and comment, pursuant to 5 U.S.C. § 553(b)(3)(B)."  

D.  FCC is asking for comments on these type of calls.

• International calls
• Caller’s Face does not appear on screen; use of privacy screen or Idle calls.  If VRS caller does not want to show his/her face, use TTY relay service is what I think.  
  
• Calls that involve remote training.  Ongoing discussion on this; should it be VRI, not VRS and the one providing remote service should pay for that?  Same old argument where if Title I or II fails, then should Title IV take over, or go thru due process of complaining to DOJ which has historically not taken high priority on telecommunication issues that fall under DOJ.
  

E.  Procedures in detecting and stopping the billings of illegitimate calls

As always, feel free to comment.   This is an important notice from FCC. 

eyes open & thumbs up,

Long Link: http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-10-88A1.doc

I am not sure what type of report it is; looks like a report analyzed and submitted to debt holders by Debtwire company.  

Ed B

Here are more comments from other VRS providers.

It is interesting to see how several VRS providers differ in their analysis of NECA rates.    Keep in mind, however, that FCC has listed what are allowables and not allowable cost items for estimating reimbursement rates.    I will just list just a few not allowable cost items (not all comprehensive, though):  training of interpreters, video phones, cost of installing (such as installers), and limited R&D. Because of that, it affects the reimbursement rate calculation.   

Happy reading   ;-]

PAHVRS Comments

Purple Comments

SVRS Comments

eyes open & thumbs up,

Ed

Long LInk:

PAH:  http://fjallfoss.fcc.gov/ecfs/document/view?id=7020458106
Purple: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020459147
SorensonVRS: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020459335