This was from an ex parte filing by Sorenson’s law firm and taken from the FCC’s website. (link to filing)

On August 24th, a meeting took place between Sorenson executives, their attorneys and a representative of their investors who sits on their board; and representatives of the FCC.

The agenda was to give the FCC an overview of VRS and Sorenson’s part in development of the service. While the meeting did not focus on the Notice of Inquiry (NOI), it did touch on several subjects addressed in the NOI. One of the issues is what Dr. Z has a concern with on reverse auctions that is shared by most of the VRS companies who filed comments with the FCC on the NOI. Sorenson feels a reverse auction (using the rate of the 2nd lowest bidder) should be used as the basis for rate setting for VRS. Dr. Z is of the opinion that this only enhances Sorenson’s position as the dominant provider and does not take tiered rates into consideration.

It is important for us in the public to file reply comments with the FCC by September 2nd to emphasize the importance and fairness of tiered rates as this takes into consideration the various sizes of companies that make up the VRS industry.

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

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

August 18th was the deadline for everyone to submit comments on the Notice of Inquiry that was issued on June 28th. All the major VRS companies responded. Dr. Z has provided links to the actual comments each has submitted to the FCC along with consumer organizations and state entities.

Be aware that most of the documents are 40-50 pages in length, some more–some less so it’s heavy reading right there. A lot of the comments are important and Dr. Z took the time to skim through all of these documents and it was interesting to note that Sorenson’s position differed from most of the other company’s comments when it came to tiered rates and reverse auctions.

A T and T

Ad Hoc Group of Sorenson Comms Bondholders

CONVO Communications LLC

CSDVRS, LLC (ZVRS)

Florida Coordinating Council for the Deaf and Hard of Hearing

Florida Public Service Commission

PAHVRS-1 -2 -3

Purple Communications

Registry of Interpreters for the Deaf (RID)

Sorenson

Sprint

Telecommunications for the Deaf and Hard of Hearing, Inc. et al.

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

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

The FCC NOI has 2 parts–the second part focuses on broader and economic issues concerning VRS..  In order to do this, they need to go over the following items.  These will be discussed individually in the weeks to come:

1. The Components of Video Relay Service
2. The Demand for Video Relay Service
3. The Supply of Video Relay Service
4. The Regulation of Video Relay Service
5. The Incentives of Providers
6. The Incentives and Needs of VRS Users
7. Other Regulations Affecting VRS Communications

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

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

The FCC NOI has 2 parts–the first part focuses on how the FCC can improve the method to decide on rates and compensation for the VRS providers.  In order to do this, they need to go over the following items.  These will be discussed individually in the weeks to come:

1. Accounting Issues
2. Company-Specific Compensation
3. Outreach and Marketing Costs
4. Research and Development Costs
5. Videophone Equipment
6. Protection of Providers from Under-Compensation and Avoidance of Over-Compensation
7. Certification

In the next vlog/blog, Dr. Z will give an overview on Broader and Economic Issues Facing VRS.

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

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

The United States Court of Appeals for the 10th Circuit on July 29th denied Sorenson’s motion for a stay on the rates that the FCC issued for 2010-2011.

The 10th Circuit said Sorenson “failed to convince us that it is likely to succeed on the merits of its petition and that the public is best served by issuance of a stay.” (Link to Court Decision)

Dr. Z cares about your communication access.

Dr. Z is beginning a series on the FCC NOI on Video Relay Service. He will do blogs and vlogs on this every week.

The FCC issued a Notice of Inquiry (NOI) on June 28th and we are still waiting for it to be published in the Federal Register to start the comment period which lasts for 30 days. After this, the Reply to Comments will go for 15 days. However, several VRS providers have asked to extend the comment period to 90 days. The FCC has not yet ruled on this.

It is a very comprehensive document–25 pages. It will ask for feedback on two basic topics: 1) Adjustments and Modifications to Improve the Video Relay Service Compensation Methodology and 2) Broad and Economic Issues Concerning Video Relay Service. In both areas, the FCC is asking a lot of questions that need to be answered by the public in the weeks to come. The Notice of Inquiry is an open process and everyone should feel free to submit comments and feedback. The FCC will take close to a year to complete this process and hopefully conclude this by July 1, 2011.

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

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

We deaf and hard of hearing people need to change our habits!

For so long, we have had to walk to our phones to make a phone call.

Prior to the advent of TTY’s in the late 1960’s, we had to walk over to our neighbors to ask them to make a call for us.

TTYs/TDDs required us to walk to wherever the TTY/TDD was attached to a hard-wired phone.

With the VP-200, we need to walk to where the TV screen is, and use 2 remote controls (one to turn on the TV and the other to operate the unit) to make a phone call.

Let’s declare our independence–with the Z4 or the iPhone 4.

With the Z4 a laptop can be anywhere you want to be, and you will no longer need to walk to make a videophone call if you choose to have your laptop right by you.

With the iPhone 4, the phone is on you–you just need to pick it up to make a videophone call!

How’s that for independence–what about changing your phone calling habits? Think about this. Take the walk out of your vocabulary when making phone calls.

Dr. Z cares about your communication access.

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

The FCC issued a Notice of Inquiry (NOI) on June 28, 2010. As Dr. Z indicated previously, this NOI is a process in which the FCC will collect information regarding rates and how the VRS service is structured before they issue new rates and rules before the 2011 rate period. The NOI has a 30-day comment period and a 15-day reply to comment period.

4 VRS Providers (CSDVRS, Convo, Purple and Snap) have filed a motion with the FCC to extend the comment period from 30 days to 90 days and the reply to comment period from 15 days to 45 days. The NOI is a very detailed and exhaustive process, raising a lot of questions and Dr. Z is in agreement with the VRS providers that 30 days is too short a time to be able to come up with comments to the questions the FCC has raised. 90 days is a reasonable time period for everyone–VRS providers, organizations and consumers to be able to review the questions and comment on them.

We will see how the FCC responds to this motion.

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

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

Sorenson Communications has filed a petition for review of the FCC’s rates with the United States Court of Appeals for the 10th Circuit.

The 10th Circuit is located in Denver and the filing states that it is an appropriate choice because it is close to Sorenson’s Headquarters in Salt Lake City.

The filing is a one page document and does not have much information.

Dr. Z will keep you posted as developments warrant in this case.

Dr. Z cares about your communication access.

The FCC on July 9, 2010 has denied Sorenson’s Rate Stay Motion. The FCC lists its reasons for such denial in the order. You can read the document using this link.

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

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