Folks..

As some of my close friends know, I have a lifetime dream to start a VRS business.  Over the years, I have had a few opportunites, but the timing was not right or the vibes did not vibrate.  

Until now, that is.   The vibes vibrated!  Out of respect for you great edsalert readers, I want to announce that three partners and I have teamed up and have formed a VRS provider; name of the company is Convo.  Who are the partners?  Wayne Betts, the famous movie maker; Chad Taylor, technical wizard, and Robin Horwitz, business savvy and go getter.  All of us are deaf. 

NECA Report

Here is the National Exchange Carrier Association (NECA)  report to the Federal Communications Commission (FCC) on funding for Telecommunicaitons Relay Service (TRS). 

Basically NECA is submitting report for the FCC to approve the new funding for TRS and explains how they arrive at new rates.  Good information there, and not too hard to understand. 

Quoting NECA "..submits proposed compensation rates, demand projections, projected fund size and proposed carrier contribution factor for the period July 2009 through June 2010, in accordance with section 64.604 of the Federal Communications Commission’s (FCC or Commission) rules."
Unquote.

A few interesting tidbit of info:

• Approx 4,640 carriers contribute to Interstate TRS Fund. 
• If approved by the FCC, carriers will be charged 0.0113 of carrier’s revenue which will be added to the Interstate TRS Fund.

• Multi-state Average Rate Structure is used for TRS (accounting method)

Report explained various methods in calculating TRS reimbursement rates. 

Most of you are interested in VRS there is a chart of past and proposed new rates for VRS.  Worth checking that out.  

Tiered: Past rate was $6.7362 per min to new proposed rate of $6.7025
Tiered: Past $6.4675 to new $6.4352
Tiered3: Past $6.2685 to new $6.2372

Tiered 1 is under 50K VRS Minutes, Tiered2 is between 50K plus one to 500K, and Tiered 3 is above 500K plus one.

Report mentions "Actual weighted average costs" which I think to me means break-even cost of service.  If I’m wrong, kindly correct me.   Anyway report shows that to be:

• 2007 was $4.5568
• 2007 was $3.9950
• 2008 was $4.1393

Wow…so let’s use 2008 and tiered 2.  Theoretically speaking means profit of $2.0979 per minute.   No wonder no VRS has bankrupted – at least not yet.

Other intriguing info: Quote: "VRS providers spent over $30 million in marketing and outreach in 2008 (up from approximately $20 million in 2007). The data also reflects that that total legal and regulatory expenses for 2008 (included in the indirect cost category) were approximately $8.9 million (up $4.0 million from legal and regulatory expenses reported for 2007).
Unquote

Folks, it is worth reading through this long report; it’ll give you valuable insights of how TRS reimbursement rates are calculated.

eyes open & thumbs up,

Ed

Obama nominated Mignon Clyburn to be one of the FCC Commissioner. 

WSJ Article

If you want to know what Clyburn looks like..

NJO Article

Clyburn will be replacing Jonathan Adelstein who has been known to give support to the deaf/hoh issues. 

TVB Article

eyes open & thumbs up,

Ed

Folks,

I think clarification is needed on VRS industry; that is, should or should not do regarding these phone-in situations; like on-line education, tele-seminars, getting information via phone, etc.  

First of all I like what commentators Todd and Christian said in their comments.   We have 5 Titles from ADA.  Check out an abbreviated form on ADA

ADA Titles

Basically should consider these titles of ADA as a way to meet the federal expectations.  Unfortunately, often a company or service is not willing to do make changes, then an alternative is offered.  Like one commentator sez, if not able to get Title 1 thru 3 implemented, then only alternative is Title 4 which is relay service. 

We know how difficult it is to get federal agencies to act on various issues and may take them years to resolve that.  Deaf/hoh should not have to suffer because of that.  So alternative is acceptable, but with following conditions for business ethics.  

I do feel very strongly that it is not VRS providers’ place to advertise or promote these phone-in services either via website or emails or flyers.  I feel strongly that in meeting functional equivalence, deaf/hoh – just like hearing persons – find these services on their own is the ideal way to go about it. 

VRS providers who advertise/promote these phone-in services only have one thing in their minds – "ramp up" VRS minutes – in other words, manufactured minutes (I like that term, Todd).   Same for those VRS providers who use domain whose sole purpose is to connect to phone-in services.  Or those VRS providers who pay individuals to call these those phone-in service.  Or VRS providers who pay various organizations to call VRS providers based on accumulation of VRS minutes.  

However, those deaf/hoh who simply found phone-in services from newspaper or media news, and they did NOT get info from VRS providers or from Outreach Services who have contract with VRS providers, should be allowed.   The exception, in my humble opinion, is classroom interpreting at Universities or Colleges – these I feel are verboten!   Essentially because Universities/Colleges can afford them and FCC says no.

I talked with a few ethical VRS providers and I was pleased to learn that they practice that.   They do not have any contract/behind the scene dealings/behind organizations/etc. to encourage phone-in services.   So these VRS providers allow these phone-in services to be processed as these were "found" by deaf/hoh individual.

One additional issue.  I’ve had a chance to talk with a few professional interpreters who work in VRS environment.   They said "most" video interpreters do not like to interpret these phone-in services.  Once a while, they said no problem, but on a daily basis they don’t like.  Said they lose the motivation to stay with VRS industry.   We deaf/hoh need to be sensitive to these video interpreters as well.  After all, they’re symbiote to us deaf/hoh.  We cannot live without each other.  

Anyway, the botton line is simply that VRS minutes should be purely "consumer-driven" as chosen/determined by deaf/hoh only, not manufactured VRS minutes.  

eyes open & thumbs up,

Ed

Hey – from my friend, Debbie, who send me this link.

Sign Language Scheme

Oh, geez….as if we need more black eyes.  

eyes open & thumbs up,

Ed

Check this link out.  You’ll see video clips explaining all about the number rules for VRS/IP Relay.  You’ll need to download realplayer program, though.

FCC Video Clips

Kudos for FCC for doing this.  Hope they will do more of this type of educaitonal and informative video clips in the future – especially the controverisal issues and clarify them?  [hint hint ;-]

eyes open & thumbs up,

Ed

Folks…

A friend of mine used the term, Organic Minutes and it really hit off what I’ve been trying to say all along.   This is also to follow up on a couple comments that asked about should this and that be permitted or not; what does the FCC regulation say? and so on.

Definition of organic: Free from chemical injections or additives, such as antibiotics or hormones: organic chicken. c. Simple, healthful, and close to nature: an organic lifestyle.

This is clear enough.   I have organic vegetable garden now.  No  chemical solutions for herbicides, and pesticide are used.  Compost – healthy soil; for pesticide, I use hot pepper, insects and whip them into a solution and spray plants; for herbicide, I use my hands.  Result, healthy vegetable and delicious to boot and not have to worry about residues of sprays from chemicals used for pesticide and herbicide (Round-up, etc – horrors) affecting our health.

Same with Organic Minutes.   It means purely consumer driven minutes.  In other words, no telemarketers, no daily internal video conferences (by VRS staff), no online classroom or similar minutes are done.  This is how I view VRS industry ought to do; this is how I percieve TRS rules to mean.   TRS rules seem to be clear that any relay calls (text relay, Internet Relay, STS, VRS, and other horde features) should have two way participating parties thru relay agent/video interpreter.  In other words, both caller and called party should activately participate with each other.  So online classroom is out because this is not a true two way conversation.   The execption is answering machine and voice mails (it is in the relay rule).  Video conference calls are permitted, but it seems that a few VRS providers abuse that just to ramp up VRS minutes; not for the real reason why video conferences are held.      

Another important point to consider.  This is NOT about accessing various services available for hearing persons, this is about complying what existing federal relay rules (Title IV and subsequent Public Notices, Rule and Orders, etc from FCC) say what is permitted or what is not permitted.

So Organic Minutes means purely and clean relay calls between participating caller and called party.  Period.   I bet if VRS industry follows that, the total VRS minutes probably will be reduced maybe as much as 30% or more. 

I realize this is a very controversial issue.  I repeat, this is about what federal relay rules are about.   If you think online education should be permitted, address this with the FCC directly as FCC already said classroom interpreting is not permitted for VRS.  Same with other services that seem not to be permitted.  

eyes open & thumbs up,

Ed

Here is your chance to express your thoughts to this FCC Public Notice. 

FCC Public Notice

TDI and GoAmerica petitions for reconsideration of assigning hearing persons with video phones Telephone Number of which FCC had said is not permitted at this time.  This is one instance that I disagree with FCC on.   If you feel same as I do, tell that to the FCC!  Send email to fccinfo@fcc.gov    Be sure to include Docket 03-123 in your email. 

GA also petitoned other issues you may want to check out; has to do with call back by emergency centers.  

This is based on previous FCC Rule and Order; the following link is this:

FCC Multiple Order/Reconsideration

eyes open & thumbs up,

Ed

PS: forgive me for not going via Vlog – been busy both at home (veg gardening and teenage kids – visiting universities here and there) and office (napping – ha no just kidding – doing some contract works here and there).  

These are required reports from the FCC on why VRS providers are STILL not able to comply with the "waived" TRS rules.  The following reports by VRS providers.  I agree with VRS providers on the difficulty of meeting the "required" waived rules.   

Most of them say essentially the same thing. 

CAC

Purple

SnapVRS

ATT

Sprint

CSDVRS

I was not able to find other VRS providers; undoubtedly they will file at the last minute? 

eyes open & thumbs up,

Ed

This is good news!  Basically Time Warner decided not to do Internet metering for those who download/use Internet alot.  VRS users may or may not be hit by this, but with that..we don’t have to worry about that. 

Internet Metering Shelved

eyes open & thumbs up,

Ed