Dr. Z has been purposefully quiet the past few days. He wanted to see how things looked after the dust settled.

While it looks like things are quiet, there’s a lot of things happening behind the scenes. The FCC is hard at work reviewing the submitted costs to determine rates which must be done by June 30th. It appears most likely that the FCC will issue interim rates for just one year and go through a review process to put in place a process that will be used as the basis for determining rates in the future. This calls for more transparency in the process. The VRS providers need to show their books to justify the costs they are submitting. Now the costs being submitted have to be signed off by the CEO, CFO or a senior executive attesting to the truthfulness of such costs, otherwise they can face charges of perjury.

To people on the outside, we are in no position to say the rates are right or wrong–we do not know what the costs being submitted look like. Only the FCC (and NECA) have access to these and have the right to ask for more information.

Sorenson, in ex parte filings with the FCC recently, are posturing themselves to decide what information they can share and what they don’t need to share. Why do they need to do that? Public monies are involved and there is accountability and transparency when it comes to public money. They claim competitive information can be gleaned from this. Numbers alone do not reveal much when it comes to competition. One can speculate from numbers how things are being spent, but this does not make or break the success of a product or service.

Product excellence, product quality, product marketing are things that form the basis for the success of a product or service–not numbers alone. There is basis for confidentiality for product or service plans, but not necessarily just numbers. The VRS companies do not need to submit product plans or information to the FCC, nor is there reason to do so, except in matters of interoperability.

Open Up Your Books, You Folks! What is There to Hide?

Amen.

Dr. Z cares about your communication access and how public monies are being spent.

Disclosure: Dr. Z is a contractor working with CSDVRS on several projects.