Dr. Z has had the opportunity to go over some of the unbiased comments filed on the FCC website. He also had the opportunity to go over some of the vlogs and blogs that are out there on the web. This includes reply comments filed by VRS providers and the vlogs put up by VRS providers.
The consensus so far is obvious–the rates need to be looked at. The tiers need to be adjusted. This is part of the process that the FCC has in place. The VRS providers except for Sorenson have made sensible arguments and propositions for their respective situations, introducing formulas and other things that the NECA did not account for when they came up with their rate calculations and the subsequent recommendation to the FCC.
One of the key points is the 11.25% margin that the FCC is allowing for “profit”. The VRS providers in the weeks to come need to provide to the FCC that they need the 11.25 margin (and not more) to do the things that are necessary to provide a functionally equivalent VRS service. Some of the VRS providers in the past year have experienced less than the 11.25% margin.
What is interesting is that to date–very few are in agreement with the arguments Sorenson is putting up out there–most are disputing the facts and assertions they have put forth. This does raise a question of credibility.
The comment period and the reply to comment period has closed. The ball is now in the FCC’s hands. In the weeks to come, the FCC will consult with the VRS providers–trying to understand their respective positions and asking for more data from them.
Let us all work together to help the FCC make its determination so they can create a basis to provide a functionally equivalent service that deaf and hard of hearing consumers are privileged to use.
Dr. Z wants to set the record straight so consumers have full access to facts–not assumptions or emotions.
Dr. Z cares about your communication access.
Disclosure: Dr. Z is a contractor working with CSDVRS on several projects.