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2010-05-06 11:49 AM
Please help if you feel so moved (or, FCC Douchebaggery Extraordinaire, The Middle Years)
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The FCC (Federal Communications Commission) may cause the bankruptcy of the company I work for by slashing the reimbursement rate for companies providing communcation services to deaf and hard-of-hearing people.
The FCC proposes a three-tier system, paying nearly the same rate as they do now to very small providers and paying almost half to larger (third-tier) providers. The company I work for is the ONLY third-tier company, with almost 80% of the market.
Imagine if 80% of all operators were out of work. Imagine if 80% of any industry suddenly lost its call processors. You know how it feels to be left on hold for nearly an hour when you call your cell-phone company, right? Now imagine you need to call 911. Imagine how long you would wait if there were 80% fewer 911 dispatchers. Get the picture?
This isn't just about my job, it's about honoring the promise of the Americans with Disabilities Act, which requires that services create "functional equivalency" for D/HH people in all publicly funded areas.
You can help prevent this by sending comments to the FCC between now and May 14th. See the information below about how to do that.
Thanks for considering emailing your concerns to the FCC on behalf of D/HH people, video interpreters, and the several thousand video relay employees who make this system work. Please insert a first paragraph that describes your affiliation with VRS workers and/or the Deaf community, if you so desire.
If you wish to express your concern in the form of comments to the FCC, here are instructions, a sample letter and some bullet points you might consider if you would like to submit your own personal comments to the FCC.
Step 1. Go to this link.
Step 2. . Complete the form with your personal information (all fields with an asterisk are required).
Step 3. Enter your comments. (You can type them in Word first and then cut and paste the comment.)
Step 4. Select the "Continue" button.
Step 5. You will be presented with a confirmation page to review your comment before submitting comment. Select the "Confirm" button and your comment will be submitted.
Sample Letter/Email of Support from Concerned Citizens to Be Filed with the FCC:
Honorable Julius Genachowski, Chairman
Commissioner Michael J. Copps
Commissioner Robert M. McDowell
Commissioner Mignon Clyburn
Commissioner Meredith Attwell Baker
Federal Communications Commission
445 Twelfth Street SW
Washington, DC 20554
Re: CG Docket Nos. 03-123 and 10-51
Dear Chairman Genachowski and Commissioners Copps, McDowell, Clyburn, and Baker,
As someone with a strong belief in equal access for disabled people, I am deeply concerned about the FCC's proposed significant reduction in TRS reimbursement rates. It is important that deaf individuals be able to communicate by videophone in American Sign Language using VRS. This life-altering broadband service is a vital link that connects deaf people to the hearing community.
Ensuring that deaf individuals have access to VRS and encouraging improvements in VRS should be a high priority for you as Chairman and Commissioners of the Federal Communications Commission (FCC). The Americans with Disabilities Act (ADA) requires the FCC to make available to all deaf individuals nationwide "functionally-equivalent" communications.
You will soon determine the future of VRS. When you set the VRS rate, you will determine whether America makes progress toward the statutory goals of functional equivalence, nationwide access and inclusion – or force deaf users to revert to TTY communications. And, you will determine whether VRS fulfills its potential to drive broadband adoption by the deaf, even in the face of poverty and isolation.
I was deeply disturbed to see the Commission's recent Public Notice on VRS rates. These proposals would put an end to VRS as we know it. One employer has already stated that if these proposed rates are adopted, the company would head into bankruptcy. This would be disastrous for deaf VRS users.
The FCC should be increasing the availability and use of VRS, not cutting back. You should adopt a rate that encourages continuing improvements in VRS technology and continues to improve services levels. Recent developments in VRS are a good example of how the service can be improved, such as enhanced 911 services, 10-digit numbering, a larger and better-trained pool of interpreters and better videophones with an array of enhanced features. Monthly payments for broadband are a big expense for many deaf people, and instead of trying to cut back on VRS, you should be exploring ways to make VRS over broadband more affordable to deaf individuals.
Progress towards functional equivalence will be destroyed if the FCC does not encourage VRS providers to improve VRS and make it more widely available. VRS is a recent and dramatic advancement that benefits those who are deaf, but so much more can be done. It would be tragic if the FCC were to destroy this broadband service that is so vital to the deaf.
Recent reports of fraud in the VRS industry are disturbing to those working for a company that has operated within current FCC guidelines and has worked to maintain the integrity of the VRS fund. The FCC must devote more of its time and energy to focusing on the elimination of fraud.
I urge you to establish a fair and predictable rate for VRS that will encourage VRS providers to invest in improving VRS and reaching more deaf individuals. The law requires it and it is the right thing to do.
Sample Bullet Points to Be Filed with the FCC
The rates for VRS proposed by the Federal Communications Commission (FCC) in its April 30 Public Notice would be a disaster for VRS because:
- The rates are so low that it would be the end of VRS as we know it today. No provider would seek to provide VRS at the low rates proposed by the FCC;
- The FCC proposes a low interim VRS rate. A better option would be a multi-year VRS rate, which would allow VRS providers to continue to invest in their offerings for the deaf.
- VRS and the improvements made to it over the years have moved us closer to the goal of “function equivalence” mandated by the Americans with Disabilities Act. The FCC rate proposal would destroy that progress and move us further from achieving the goals of the ADA;
- This rate proposal would lead at least one company into bankruptcy, leaving deaf customers without the vital VRS service they have come to expect;
- This proposal would almost certainly mean that countless jobs would be in jeopardy in an economy where finding a new job would be extremely difficult, if not impossible.
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