A provider should care about consumers of its service and do everything to service their consumers. If a consumer decides to go to another provider, it is the consumer’s right to do so and the provider giving up the service needs to make it as seamless and not problematic for the consumer who makes this choice. Unfortunately, this has not been happening of late. It has occurred enough times in order for CSDVRS (ZVRS) to file a Petition of Expedited Declaratory Ruling with the FCC. In addition, a letter on this matter was sent to Joel Gurin, Chief of the Consumer and Governmental Affairs Bureau at the FCC.

When a consumer decides to port (or move) his phone number from the old provider to a new provider, he/she is required to fill out a LOA (Letter of Authorization) to make this possible. The VRS company (the new provider) submits this LOA to a servicing company who handles the porting. The servicing company then issues a FOC Date (Firm Order Commitment) to the old provider and the new provider informing them when the port is to take place. On that date, the old provider disables the number, and the new provider activates the number. In normal circumstances, it can take several days to a week or more for this to happen. What has seemed to happen is that when Sorenson as the old provider somehow finds out about the planned port well before the FOC Date, it immediately shuts down the VP-200 before the FOC Date, leaving the deaf/hard of hearing person stuck without a videophone. In recent days, when this has happened, the deaf/hard of hearing person contacts Sorenson to ask them to hold off the deactivation until the FOC Date. Sorenson has refused to comply with their requests. This means Sorenson is leaving the deaf/hard of hearing person without access to 911 service. CSDVRS feels this is wrong, like anybody with a heart and mind out there–you can’t take away a person’s lifeline to the world, thus submitting this petition and letter.

This is not functionally equivalent—hearing people, when they switch cellphone providers go through the same thing and the providers comply with the process, including honoring the FOC Date.

This is the link to the petition: Petition for Expedited Declaratory Ruling

This is the link to the FCC letter: Letter to Joel Gurin, FCC Chief of Consumer and Governmental Affairs Bureau

Dr. Z cares about your communication access.