The FCC on December 4th announced they will host a workshop on December 17th on VRS reform.

This is an attempt by the FCC to review all aspects of VRS as a service. It can result in some changes but the bottom line is that we won’t lose VRS service. At the workshop, we need to be sure our needs and views are heard. The workshop will cover three areas (as copied verbatim from the FCC announcement):

1) The most efficient way to deliver VRS, particularly whether the service should remain a competitive service or be provided via competitive bidding;

2) A fair, efficient, and transparent compensation methodology; and,

3) Mechanisms for combating waste, fraudand abuse, addressing service rules, and addressing technical matters such as interoperability, ten-digit numbering, and emergency call handling.

Dr. Z will comment on each of the 3 areas in editorials in the forthcoming days to come (prior to the workshop.) These issues are important and it is time for the FCC to look into this. It is Dr. Z’s hope that the end result will be a better VRS service for us all.

It will take place from 2-5 pm and will be open captioned on the web using this address http://www.fcc.gov/realaudio. You may want to test it and download your copy of Real Player to be prepared.

Dr. Z (and the FCC) cares about your communication access.

Today the FCC issued a temporary 4-month waiver for toll free numbers (including 866 numbers). This means any relay provider who has removed 866 numbers from their data base has to put them back. This includes Sorenson which is a major provider and caused gallons of Pepto Bismol to be consumed by the deaf and hard of hearing community, the VRS industry and the FCC in dealing with the 866 issue. Dr. Z tips his hat off to the FCC for listening to our concerns. While this is temporary, this gives us time to discuss our thoughts, exchange our views and come up with a resolution for toll-free numbers that works for us all. (Link to FCC order)

Dr. Z (and the FCC) cares about your communication access.

P.S. The makers of Pepto Bismol can now restock the shelves of the stores selling them.

The 866 fiasco is affecting everyone and everyone is going bonkers to the point that most of the national deaf organizations and video relay companies, except Sorenson have made their thoughts known to the FCC. You can go to the FCC website to read ex parte notices by those who met with the FCC. (Link to Postings)

Like Dr. Z said before, one needs to modify the configuration on their VP-200 by going through three screens. Our colleague, a well known blogger, Karen Putz, has written a nice post on her website on this matter. (Link to Karen’s writeup)

Dr. Z cares about your communication access.

Interoperability and Functional Equivalency

Interoperability means that any piece of equipment must be able to access other equipment.  Functional equivalence means that any service element must be equal to what hearing people have. This is a FCC mandate. (Link to FCC declaratory ruling 06-57). Paragraph 34 of that ruling defines interoperability and functional equivalency in some detail and I have quoted that below.

The 866 situation we have today is causing a lot of headache and Dr. Z feels bad about it because our deaf and hard of hearing colleagues are very confused.  Sorenson took down their 866 numbers and other deaf and hard of hearing people who do not have Sorenson units cannot call another deaf or hard of hearing people with Sorenson units while deaf and hard of hearing people with Sorenson units can still call other deaf and hard of hearing people with Sorenson units using 866 numbers. Hearing people can call Sorenson units with 866 numbers.  This is second-class treatment by Sorenson again–they are treating hearing people better than deaf people again.

Also, to further the confusion, Sorenson is using 866 numbers as the default basis for generating Caller-ID’s for all outgoing calls. If a non-Sorenson unit receives a call from a Sorenson unit, this non-Sorenson unit gets the 866 number instead of a local number and when it is used to call back, it goes instead to an interpreter because the 866 number is not registered on the national data base. This effectively blocks the non-Sorenson user from calling back to the Sorenson unit. If a local number was passed using a standard and recognizable format instead, there would not be a problem.

Text of paragraph 34 of FCC Declaratory ruling 06-57:

34.   In sum, consistent with functional equivalency, all VRS consumers must be able to place a VRS call through any of the VRS providers’ service, and all VRS providers must be able to receive calls from, and make calls to, any VRS consumer.  Therefore, a provider may not block calls so that VRS equipment cannot be used with other providers’ service.  In addition, a provider may not take other steps that restrict a consumer’s unfettered access to other providers’ service.  This includes the practice of providing degraded service quality to consumers using VRS equipment or service with another provider’s service.  Finally, new providers seeking to offer service have the burden of ensuring that their service is interoperable with existing providers’ service.

Sorenson, by doing some things with 866 numbers, does not meet this definition of interoperability, in my view.  Dr. Z is pleading with Sorenson and the FCC to reread this in light of the current situation. Comprende?

Dr. Z cares about your communication access.

For hearing people:

– Sprint cell phones can call ATT cell phones using 800/866 numbers.
– ATT cell phones can call Verizon cell phones using 800/866 numbers.
– Verizon cell phones can call Sprint cell phones using 800/866 numbers.

For deaf and hard of hearing people:

– Z-Phones (Z-150, Z-340, Z-Ojo) can call Purple devices using 800/866 numbers.
– Sorenson VP-200’s can call Z-Phones using 800/866 numbers
– Hearing people can call Z-Phones and Purple phones using 800/866 numbers
– Z-Phones, Purple units, Snap units cannot call Sorenson VP-200’s using 800/866 numbers (that is because Sorenson does not handle 800/866 calls from other providers–only from Sorenson units)
– Hearing people can call Sorenson VP-200’s using 800/866 numbers

(Sorenson is treating hearing people better than deaf people–its units are accepting 800/866 calls from all hearing people and not accepting 800/866 calls from deaf people who do not have VP-200’s.)

The FCC issued a clarification that 800/866 numbers shall not be part of the national data base and this is contributing to a functionally unequivalent system for deaf and hard of hearing people.

Is this functional equivalence? According to the Federal legal code 47 C.F.R. § 64.601, paragraph 15 which states that any TRS or VRS service elements must be equivalent (or equal) to what the hearing people have.

Is anyone listening?  There is a lot of confusion out there (this is based on a first-hand observation of Dr. Z and his colleague, who visited 21 cities in recent weeks to talk about numbering.)  Do we deserve this?

CSDVRS has filed a petition to allow 800/866 numbers to be used.  TDI has met with the FCC supporting that petition. The NAD has issued a press release on this matter.

Dr. Z cares about your communication access.

Today’s charges regarding VRS fraud is a wake up call to everyone involved in the industry–consumers, interpreters and the VRS companies. History tells us any industry in rapid growth mode usually gets slowed down with a variety of issues–the situation today is an example of this issue. The charges today are serious and if true, should be dealt with appropriately.

Some people have commented as to whether it will hurt the VRS industry. As far as I am concerned–this will not reduce our access to VRS nor communication access in general. The Chief of Staff of the FCC, Edward Lazarus made this clear in his press release when he said ” I would also emphasize that nothing we do today, or in this investigation, will prevent the processing of legitimate VRS calls. Moving forward, our goal will be simple: to ensure that the VRS program is one that the American people can be proud of, and that the deaf community can rely on.” This is relieving to know.

We deaf and hard of hearing consumers value the service as second to none–it has provided us with functionally equivalent access to communication that we didn’t have prior to 2000. We should not let today’s news reduce that access. We must work together to weed out weaknesses in the system that funds VRS and move on to greater things—even better communication access.

Dr. Z cares about your communication access.