On February 6, 2012, representatives of TDI, NAD and ALDA met with officials at the FCC to express their thoughts about the proposed rules for VRS (NPRM), comments which are due in early March.

Here is a summary of the points brought up in the meeting, as quoted from the ex-parte filing they submitted (link). For more information, it is recommended that you read the filing in its entirety as the following summary does not cover everything:

– expressed support for a pilot program to assist deaf and hard of hearing users obtain access to broadband services
– expressed their support for proposals to achieve interoperability, the transition from H.323 to SIP, and the availability of off-the-shelf equipment for VRS users
– urged the FCC to consider ways to measure the hearing population’s use of and experience with VRS
– noted that higher quality VRS calls could reduce the time spent on a single call and also reduce the need for additional calls that are sometimes required due to poor interpreter/service quality
– expressed concerns with the proposed per user methodology
– expressed concern with the Commission’s belief that a per user compensation methodology will increase competition among VRS providers
– urged the FCC to protect consumers’ privacy when designing any VRS-related databases
– asked the FCC to consider the dilemma that consumers who are deaf or hard of hearing may experience if the FCC adopts the one provider, one customer model (in the event the default provider is not available to process the call)
– expressed concern about the sheer volume of …the NPRM, the lack of a public education campaign to inform VRS users about the proposals, and the lack of a thorough ASL version of the NPRM as well as the inability to accept video comments in ASL – the very language of the people who use VRS

It is Dr. Z’s opinion that the respective organizations will file formal comments regarding their thoughts on the NPRM. The NPRM has the potential of changing VRS as we know it–what we do not know is what it could lead to and how it could change how we use VRS.

Dr. Z cares about your communication access.

Disclaimer: Dr. Z is currently the Vice-President of Business Development and Outreach at CSDVRS, LLC.

Dr. Z is still seeing people use 866 numbers and giving them to their friends, relatives and doctors.

Dr. Z wants to remind everyone that FREE 800/866 numbers for VRS will stop on November 21, 2012. All VRS providers have been asked by the FCC to stop servicing 800/866 numbers on that date.

If you want to keep your 800/866 numbers, you will have to pay a monthly fee.

What should you do? Just give out your local number, instead of your 800/866 number. Local numbers are free.

In the next few weeks, ZVRS will make a list available of who you need to contact to service your 800/866 numbers for a monthly fee.

Here’s the link to the FCC web page on this subject.

Dr. Z cares about your communication access.

Disclaimer: Dr. Z is currently the Vice-President of Business Development and Outreach at CSDVRS, LLC.

Another proposed rule has to do with tiered rates. The FCC is asking whether tiered rates make sense. We all know that fixed costs are the same for all VRS companies which means that it costs more for smaller VRS companies to provide the service than its for larger VRS companies. That is why tiered rates allow small companies to compete on an even playing field with larger VRS companies.

What is a tiered rate? If for example a per user rate or per minutes ate would be in effect, the smaller VRS companies would get a higher rate than the larger VRS companies. This enables smaller VRS companies to provide the service. If there were one rate, it’s possible that the smaller VRS companies will drop out of the market.

Dr. Z is of the opinion that we need a number of VRS companies out there so there can be competition. If companies drop out, we will have less competition and therefore less service and features.

Here’s the link to the proposed rules.

Here’s the link to comment to the FCC on those proposed rules.

Dr. Z cares about your communication access.

Disclaimer: Dr. Z is currently the Vice-President of Business Development and Outreach at CSDVRS, LLC.

One of the proposed rules has to do with compensation–how the FCC will pay the VRS providers for doing the service. Currently, the FCC pays the providers a per-minute rate for doing the service; the longer a person uses VRS, the more the provider gets.

In the proposed rules, the FCC is proposing that the providers would be paid on a per-user basis. This means the FCC is proposing to pay a flat fee for a person using the service per month. If a person uses VRS for 5 minutes a month, or 200 minutes a month, the provider will get the same amount no matter how many minutes the user uses. Will this cause behavioral changes on the part of the provider? Will the provider worry about the small users and ignore the big users? How do we define an ‘User”? What if a husband and a wife uses the same videophone in the home? Do they count as 1 or 2 users? What about a company that employs deaf and hard of hearing people? Will the company be defined as one user or each employee defined as an user? What about a deaf child in a hearing household? The list of questions goes on and on.

Dr. Z is especially concerned as to whether they have an impact on the quality of service. If the per user compensation methodology results in less revenue for the VRS provider, will it cause them to be less innovative? Will they eliminate features we have come to benefit?

Here’s the link to the proposed rules.

Here’s the link to comment to the FCC on those proposed rules.

Dr. Z cares about your communication access.

Disclaimer: Dr. Z is currently the Vice-President of Business Development and Outreach at CSDVRS, LLC.

Dr. Z has been getting questions on the recent FCC development, especially the FNPRM.

What is a FNPRM? It is a Further Notice of Proposed Rulemaking.

The FCC has a process whereby they give the public an opportunity to read their proposed rules and comment on them before they issue an order. Very rarely, if ever does the FCC issue an order without a proposed rulemaking in process except in urgent and emergency situations.

The current FNPRM issued on December 14, 2011 is a very detailed (over 100 pages) and comprehensive proposal of new rules to be considered. Some of them are far-reaching and can change VRS as we know it today. And the comment period is 30 days from its publication in the Federal Register which is an unusually short period of time for such a big rulemaking proposal.

Dr. Z will comment on those proposed rules in the next few weeks so you can have an opportunity to send your thoughts to the FCC.

Here’s the link to the proposed rules.

Dr. Z cares about your communication access.

Disclaimer: Dr. Z is currently the Vice-President of Business Development and Outreach at CSDVRS, LLC.

There is a lot of filings and comments on the FCC website related to VRS. It is painstaking to try to read and digest all of these. All this is a result of the FCC’s attempts to reform the VRS industry and this is only the beginning. Whenever the FCC issues an order, people file requests for reconsideration, requests for extensions, requests for waivers, ex parte notices and all that to get what they think is needed.

The dust is all over and it is far from settled. This is not intended as a criticism to the FCC–reform is needed, but it is hard when there are so many players in the game. The FCC has yet to issue proposed rules for compensation of VRS service. The FCC has a full plate because it is also looking at Universal Service Fund reform and internet reform, both of which have an effect on VRS.

Bottom line–we must be vigilant to be sure that all those new rules and orders do not change the VRS experience we enjoy today.

Here are the links to the FCC website for the information mentioned above:

TRS/VRS Headlines
Filings for Proceeding 03-123
Filings for Proceeding 10-51

Dr. Z cares about your communication access.

Disclaimer: Dr. Z is currently the Vice-President of Marketing at CSDVRS, LLC.