Rosaline Crawford, the Director of the NAD Law and Advocacy Center filed an ex parte notice on January 13, 2010 about a meeting she had with the FCC on January 12th on VRS issues. She was representing several other consumer gropups and the link to the notice is as follows: Link to NAD Ex Parte Notice. An ex parte notice means something that is presented by one party without hearing from the other side. The FCC requires everyone to file such a notice when people meet with the FCC. This way, all parties involved will know what has been discussed. This makes the process as transparent as possible. Three (3) issues were discussed as follows:

Toll Free Numbers

It was urged that the FCC take a position on toll free numbers. In addition, toll free numbers should be made a part of the national data base. It reminded the FCC that 3 months remain before the FCC’s waiver on this ruling expires. Dr. Z agrees that 800 numbers need to be part of the national data base. This way, everything will be functionally equivalent, just like what hearing people have.

VRS Reform, Rate Methodology, and Rates

It was urged that the FCC institute a new rulemaking process to follow up on what took place at the December 17, 2009 VRS Workshop. This will allow all interested parties to make their views known. Dr. Z agrees with this, but there is also the question of whether there is enough time before July 1st (when the new rates are supposed to go into effect) for the process to run its course. It was noted that other groups should be made part of the workshops (such as interpreters) and there could be tension among the various stakeholders.

Consumer Complaints about Blocked VRS Calls

It was noted that some calls are not being connected. In addition, NECA (the organization that reimburses VRS providers for services rendered on behalf of the FCC) is denying reimbursement for certain VRS calls. (CSDVRS filed a letter recently on this issue, too Link to CSDVRS letter.) Dr. Z feels that the deaf/hard of hearing caller makes the determination as to what call he makes is legal and proper, not a 3rd party which is detached from the situation and is not in a position to assess the critical nature of such calls. Hearing people are not being penalized the same way–in this case, this is not functionally equivalent for deaf and hard of hearing people.

It is Dr. Z’s sincere hope that the FCC will listen to this ex parte notice and follow up on this.

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