NAD E-NEWS<\/p>\n
FCC Public Notice on New VRS Rates, NAD to File Comments<\/strong><\/p>\n To view two-part vlog by NAD President Bobbie Beth Scoggins, visit<\/p>\n http:\/\/www.nad.org\/sites\/all\/modules\/civicrm\/extern\/url.php?u=294&qid=783468<\/a><\/p>\n The Federal Communications Commission (FCC) recently received video relay The NAD, along with other consumer groups, will file comments for the first Background on New VRS Rates<\/p>\n While we are pleased that the FCC finally issued a notice for proposed The FCC proposes to continue the tiered rate structure, which started in Tier I: 0-50,000 minutes per month – $5.7754 per minute These VRS rates were computed by the National Exchange Carrier Association Consumer Comments<\/p>\n The NAD will post another blog\/vlog early next week to provide consumers UPDATE FROM THE FEDERAL COMMUNICATIONS COMMISSION:<\/p>\n A Message from the FCC\u2019s Consumer and Governmental Affairs Bureau to the VRS You may have seen claims that the video relay service (VRS) program is Here are the facts: On April 30th, the FCC released a Public Notice Joel Gurin, Bureau Chief
\nservice (VRS) rates for July 2010 to June 2011 from the National Exchange
\nCarrier Association (NECA). The FCC is asking for comments about the
\nproposed VRS rates. The National Association of the Deaf (NAD) learned that
\nsome people are saying that the proposed rates will tear down VRS. These
\nclaims have not been supported. The FCC has said many times that it supports
\nVRS and recognizes the value, importance, and functional equivalency that
\nVRS provides to people who use American Sign Language (ASL). We encourage
\nconsumers to turn to consumer organizations, such as the NAD, to learn about
\nthe issues and how to protect their civil, human, and linguistic rights
\nthrough public comments and action.<\/p>\n
\nround of comments due May 14, 2010. The NAD will urge the FCC to consider
\nthe quality of relay services, achieving functionally equivalent
\ntelecommunications, and other principles and objectives such as
\ntransparency, interoperability, innovation, and competitive markets when
\nsetting the rates. The NAD will then inform the community early next week
\nabout its position and provide consumers with a sample comment to file with
\nthe FCC for the second, and final, round of comments due May 21, 2010. At
\nthis time, the NAD wants to share some background on the VRS rates so
\nconsumers can be better informed.<\/p>\n
\nrulemaking on VRS rates for 2010-2011, we are dismayed that the FCC did not
\nheed our request from June 2009 to conduct a comprehensive review that
\nconsiders alternative approaches to setting VRS rates. We want the FCC to
\nconsider reasonable costs for marketing and outreach, research and
\ndevelopment, and equipment costs. The NAD will continue to urge the FCC to
\nconduct a detailed analysis of its VRS rate-setting methodology.<\/p>\n
\n2007. This structure generally reflects economies of scale (the more minutes
\nof service you provide, the less it costs per minute to provide the
\nservice). Although the FCC seems to plan to continue a multi-year rate
\nstructure in the future, the FCC is proposing these new rates for an
\n\u201cinterim\u201d one-year period for 2010-2011:<\/p>\n
\nTier II: 50,001-500,000 minutes per month – $6.0318 per minute
\nTier III: 500,001 or more minutes per month – $3.8963 per minute<\/p>\n
\n(NECA), which administers the Telecommunications Relay Service Fund. These
\nrates are one of four rates discussed in their submission to the FCC.
\nAccording to the FCC, the proposed rates are based on the 2009 average
\nactual historical cost data submitted to NECA by VRS providers. The FCC also
\nsaid that, in setting past rates, it relied on projected costs to determine
\nthe VRS rate.<\/p>\n
\nwith filing instructions and a sample comment to file with the FCC to
\nprotect their right to functionally equivalent telecommunications. Please
\nturn in your comments by May 21st.<\/p>\n
\nCommunity<\/p>\n
\nthreatened. This is not true. The FCC is committed to ensuring the provision
\nof high quality VRS to all individuals who need this service. The Americans
\nwith Disabilities Act (ADA) requires telecommunications access that is
\nfunctionally equivalent to voice telephone services for people who are deaf,
\nhard of hearing, or have speech disabilities. The FCC continues to believe
\nthat VRS is the most functionally equivalent form of relay for people who
\ncommunicate using American Sign Language (ASL). We stand ready to meet our
\nobligation to preserve and protect the VRS program so that ASL users and
\nhearing people can communicate with each other over distances. This was the
\ngoal of Congress in passing the ADA and it continues to be our goal.<\/p>\n
\n(DA-10-761A1.doc) asking the general public for feedback on what VRS
\nproviders should be paid to handle VRS calls for the next year. The Public
\nNotice seeks comment on reimbursing providers based on the actual costs that
\nVRS providers themselves claim to have incurred over the past few years to
\nprovide VRS. The only way to safeguard the VRS program is to adopt
\nreasonable rates for all forms of relay services. Thus, it is our goal to
\nadopt rates that are rationally based on the reasonable costs of actually
\nproviding VRS. We welcome all comments on our Public Notice, and will take
\nall feedback into account to determine the next VRS rates. The VRS program
\nwill continue to provide the excellent communication service that you need.<\/p>\n
\nKaren Peltz Strauss, Deputy Bureau Chief<\/p>\n