Ed’s Telecom Alert

Folks..

There are several items for the Open Meeting on April 7, but what caught my eye was this one item.  
 

• Structure and Practices of Video Relay Service Program:  Report and Order will adopt rules to detect and prevent fraud and abuse in the provision of video relay service (“VRS”).  Also, a Further Notice of Proposed Rulemaking proposes to require all VRS providers to obtain certification from the FCC under new, tighter certification procedures in order to receive compensation from the TRS Fund.

The language on "Report and Order to adopt rules to detect and prevent fraud and abuse".   That’s simply GREAT and about time.  I am already visualizing a tall, sturdy Oak tree with strong branch, and noose hanging loose from the branch waiting for the guilty ones.  

This Open Meeting will be available for viewing via Internet.  "..

watch the live stream at www.fcc.gov/live.".  

Gentle Readers, this is one live stream I will be watching and you all should, too.   I hope it will be captioned, though.

Ed B

Folks,

As noted in "about" tab of this edsaelrt a disclaimer that I have two caps:  edsalert and Convo.   That said, here are several ex-parte comments by Convo.

List of VRS providers and their features  

It has disclaimer: "The information contained herein is the result of independent research by Convo. Although Convo believes it to be accurate in all material respects, it is not possible to guarantee its accuracy due to the nature of certain sources from which it was collected"

The spreadsheet is revealing.   Keep in mind the FCC’s basic requirements of what a business model of VRS should have: 

• Own ACD (technical platform)
• Own Call Centers (more than one for redundancy requirement)
• 24/7 Service
• Have access to 9-1-1
• Meet all the requirement of TRS Regulations

You can look at the spreadsheet, and look at each VRS providers and see which seems to meet the above requirements. 

Recommended VRS Reforms

Convo suggests these as a way to start dialogue:

• "Establish a nationwide voucher program for devices with which to use VRS software so that marginalized potential VRS users can finally access VRS;"
• "Institute an “access fee” for videophone providers if their videophones are used to facilitate calls through other VRS providers"
• "Establish a nationwide voucher program for devices with which to use VRS software so that marginalized potential VRS users can finally access VRS"
• "Implement a centralized server or servers for VRS user authentication and user data"

Convo offers thoughts on expanding VRS Access:

• Lack of VRS equipment and rationale why people may not have equipment
• State telecomm equipment distribution: examples of devices that may be eligible for vouchers
• Lack of knowledge of how to use VRS equipment
• Lack of broadband Internet Access
• Inability to afford braodband Internet access

White Papers on VRS: http://fjallfoss.fcc.gov/ecfs/document/view?id=7021031052
(note: was unable to put in short name for above link. Dunno why, sorry about that; just copy and paste)

This link on White Papers on VRS: you will need to be geek to understand this.  However, White Paper does offer explanations here and there.    

FYI:  Convo, based on historical reporting to the FCC, only one "white-label" VRS provider that has consistently submitted comments to the FCC’s NPRMs, and ex-parte comments on various issues as well as having almost monthly meetings with the FCC.  

eyes open & thumbs up,

Ed

Long Links:

List: http://fjallfoss.fcc.gov/ecfs/document/view?id=7021031050
Reforms: http://fjallfoss.fcc.gov/ecfs/document/view?id=7021031051
White Paper: http://fjallfoss.fcc.gov/ecfs/document/view?id=7021031052

All..

As promised, here is another VRS Provider’s ex-parte comments.

Check out CSDVRS’s comments.  Cousin Vinny complained about bending his neck to read powerpoint.   I had to bend my neck to read the powerpoint as well.  Thanks, Cousin Vinny, for alerting me of CSDVRS’s comments.     

CSDVRS Comments

First of all "Secure Virtual Call Center" is nice way of saying this is for Interpreters interpreting from home in a secure way.  CSDVRS shares its "Share Case Study" and offers recommendations. CSDVRS is making its case of "disaster recovery" and to supplement main CSDVRS call centers.  Several redacted slides, but one slide that was interesting was "Schedule Impact" slide; look at its "recoup" data by using home interpreters. 

Quotable quotes:

"Ability to recover staff losses"

"Secure at-home-interpreting should be permissable under Commission rules"

"Must be supplement to provider’s existing Call Center"

There are more quotable quotes, but my neck can’t stand it anymore  ;-] so I’ll just let y’all get ur necks do a 90% degree turn to read rest of them.  

Once a long time ago, we had discussed this on this edsalert; wow, it was controversial at the time.   I’m curious.  Is it still controversial after you read CSDVRS’s position?  

Let us know ur thoughts.  

eyes open & thumbs up,

Ed

Long Link:

https://prodnet.www.neca.org/publicationsdocs/wwpdf/21811csdvrs.pdf

All..

I will try to start posting more VRS provider’s ex parte comments bit more as the comments are revealing and helps us to understand their point of views.  

I chose comments that I know are controversial among providers, regulators, and deaf pundit so I suggest you click and read rest of comments that seem to be on par for the course.  

Hamilton Comments

Quotable quotes:

"The Commission should not require providers to submit any user data to the TRS Fund Administrator that would violate a user’s privacy or any data that could be construed as Customer Proprietary Network Information or its equivalent."

CPNI is often enforced in regular telephone industry.   However, because of frauds from VRS, it is getting harder for regulator to keep the blinders on. 

"The Commission should not require the public disclosure of any TRS provider cost or demand data due to the sensitive financial nature of such data and the potentially severe competitive impact that the release of such data may cause."

This is understandable, but my personal belief is that the FCC can and should be able to get any financial information as long as the FCC agrees not to divulge the information to the public which includes other competitors.  I believe that is how it is done now, though.  

"Hamilton supports a rule that restricts Communications Assistants (“CAs”) from working in unmonitored workspaces, and such a rule should apply to TRS providers generally."

Above presumably meant working from home, but it also could mean from call centers that are not fully protected from peering eyes.  

FYI: Hamilton is one of the traditional TTY relay service that is slowly gaining on Sprint on number of states it services (Sprint still has the larger number of states it services, though).

eyes open & thumbs up,

Ed

Long LInk:

https://prodnet.www.neca.org/publicationsdocs/wwpdf/21611hr.pdf