FCC Asks Which ‘Off The Shelf’ Technologies Have VRS Applications

The deadline for comments is Apr. 1.
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In an effort to reform the corruption plagued “Video Relay Service” (VRS), the federal government wants to know what “new and emerging technologies” might be used to access VRS.

On March 2, 2011, the Federal Communications Commission (FCC) posted a Federal Register notice—Consumer and Governmental Affairs Bureau Seeks Comment on Application of New and Emerging Technologies for Video Relay Service Use—requesting comment on “off the shelf” video equipment that is being used by consumers for VRS.

VRS is a form of telecommunications relay service (TRS) designed to allow persons with hearing disabilities to use “American Sign Language” to communicate with voice telephone users through video equipment, rather than through typed text, the FCC says. Video equipment links the VRS user with a TRS operator allowing the user to communicate with the operator using sign language. The operator then relays what the user has communicated to the non-hearing impaired phone caller.

However, the “explosive growth” of the VRS has attracted fraudulent claims for services filed “as evidenced by recent indictments and guilty pleas from call center managers and employees admitting to defrauding the (TRS) fund of tens of millions of dollars,” the FCC says.

As a result of the losses, the FCC had “to take immediate steps in preserving the fund to ensure the continued availability of TRS,” and on Feb. 15, 2011, the White Office of Management and Budget approved the FCC’s request to collect more data from VRS providers to prevent fraud by providers and keep the service fiscally solvent.

The latest FCC move on VRS says, “As part of ongoing VRS reform efforts associated with the VRS structure and practices” the bureau “seeks additional comment and information regarding new and emerging technologies that may be used to access VRS.”

However, the latest Federal Register notice is not the FCC’s first to seek comment on ways to improve the troubled program. In July 2010, the FCC sought comments on VRS “to ensure that it is available to and used by the full spectrum of eligible users, encourages innovation, and is provided efficiently so as to be less susceptible to the waste, fraud, and abuse that plague the current program and threaten its long- term viability.”

In the March 2 notice, the agency seeks “comment on a number of issues concerning the provision of off-the-shelf video equipment, including the extent to which such equipment is available and affordable to VRS consumers, the extent to which this equipment can serve as an acceptable substitute for videophone equipment and software specifically designed for VRS users, and the extent to which changes in the VRS program are needed to allow consumers to use such equipment for VRS calls.

“Given the recent proliferation of these video technologies, the bureau now requests that interested parties provide additional information and comment on the specific functionalities of these devices as they relate to the provision and use of VRS as follows: What specific features or functions of off-the-shelf equipment, services, and software are needed to effectively use VRS?” In addition, the FCC seeks answers on several specific questions. Those questions are:

  • •What broadband speeds and frames-per-second transmission rates are necessary for acceptable video quality?
  • •What lux (lx) level ratings are required for a camera to produce acceptable images in low light settings? What other features must a camera have (e.g., pan, zoom, tilt)?
  • •How much jitter (lateral and angular) is tolerable?
  • •To what extent are consumers currently using off-the-shelf video communication software and/or platforms in connection with VRS?
  • •How often do consumers use these technologies (e.g., Skype, Apple FaceTime) as compared to equipment and software issued by VRS providers for point-to-point communications?
  • •What are the advantages and disadvantages of the off-the-shelf technologies compared to technologies provided by VRS-providers?
  • •What are the current limitations of such technologies (e.g., with respect to interoperability, numbering, emergency services) and to what extent do such limitations impede their use by persons who rely on VRS?
  • •Do such off-the-shelf technologies comply with the commission’s current rules? If they do not comply, in what ways do they not comply?

The deadline for comments is April 1, 2011, and the deadline for reply comments is April 18, 2011.

Send comments to FCC Headquarters at 445 12th Street, SW., Room TW-A325, Washington, DC 20554. Comments must include the CG Docket No. 10-51, and can be filed electronically, or in paper form.

Electronic Filers: Comments may be filed electronically using the Internet by accessing the commission’s “Electronic Comment Filing System” (ECFS) or the Federal eRulemaking Portal.

Filers should follow the instructions provided on the website for submitting comments and transmit a single electronic copy of the filing to each docket number referenced (CG Docket No. 10-51). For those using ECFS, in completing the transmittal screen, filers should include their full name, U.S. Postal Service mailing address, and the applicable docket number.

Parties may also submit an electronic comment by e-mail. To get filing instructions, filers should send an e-mail to ecfs@fcc.gov, and include the following words in the body of the message, “get form,” which is your e-mail address. A sample form and directions will be sent in response.

Paper Filers: Parties who choose to file by paper must file an original and four copies of each filing. In addition, parties must send one copy to the FCC’s duplicating contractor, Best Copy and Printing, Inc., 445 12th Street, SW., Washington, D.C. 20554, or via e-mail to fcc@bcpiweb.com.

Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission’s Secretary, Office of the Secretary, FCC.

All hand-delivered or messenger-delivered paper filings for the commission’s secretary must be delivered to FCC Headquarters at 445 12th Street, SW., Room TW-A325, Washington, DC 20554. All hand deliveries must be held together with rubber bands or fasteners. Envelopes must be disposed of before entering the building. The filing hours are 8 a.m. to 7 p.m.

Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, Md. 20743. U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th Street, SW., Washington, D.C. 20554.