Bennet & Bennet, PLLC

Posts Tagged ‘TRS

IP Relay Comments Due by March 20

Posted on February 29, 2012

Comments on a recent IP Relay Public Notice released by the FCC’s Consumer and Governmental Affairs Bureau (CGB) are due by March 20, 2012.  In the Public Notice, the CGB sought to refresh the record on several issues pertaining to misuse of IP Relay.  IP Relay is a form of text-based telecommunications relay service (TRS) that uses the Internet to allow individuals with hearing and/or speech disabilities to communicate with other individuals.   The CGB remains concerned about fraudulent and abusive practices occurring over IP Relay systems, and it believes a refreshed record on issues including verification and registration processes can help the FCC take timely and appropriate action.

FCC Issues Citations For VRS Rule Violations

Posted on October 3, 2011

The FCC has issued citations to nearly two dozen companies that have provided Video Relay Services (VRS) in violation of the Communications Act and FCC rules. Section 64.601 et seq. of the FCC’s rules establishes requirements for entities participating in the Telecommunications Relay Services (TRS) program, including VRS, an Internet-based form of TRS.  These rules state that VRS can only be offered to the public in the name of a provider eligible to receive reimbursements directly from the TRS Fund (Eligible Providers).  In each case cited by the Commission,  the party to whom the citation was issued was found to have: (i) held itself out to the public as offering VRS when the company was not an Eligible Provider; (ii) failed to clearly identify an Eligible Provider as the entity that a VRS user was using when the company handled a VRS call initiated through the company’s URL; and (iii) routed calls through the company’s URL rather than through a URL of an Eligible Provider.  The FCC citations warned the companies that any further violations would be subject to forfeitures in the amount of $16,000 per violation.  The Commission also indicated that it would be seeking reimbursement and recovery of any funds disbursed from the TRS Fund that were associated with the cited violations.

Comment Sought on TRS Payment Formulas and Funding Requirements

Posted on May 5, 2011

The FCC’s Consumer and Governmental Affairs Bureau (Bureau) has released a Public Notice seeking comment on the National Exchange Carrier Association’s (NECA) proposed compensation rates for all forms of telecommunications relay services (TRS), except video relay service (VRS), for the period of July 1, 2011, through June 30, 2012.  The Bureau is also seeking comment on NECA’s proposed carrier contribution factor and total funding requirement.

NECA has proposed the following per minute compensation rates: $1.8502 for interstate traditional TRS; $1.8502 for interstate Speech-to-Speech (STS); $1.7396 for interstate captioned telephone service (CTS) and interstate and intrastate Internet Protocol (IP) captioned telephone service (IP CTS); and $1.2920 for interstate and intrastate IP Relay.  The proposed per minute compensation rates are based on the rate calculation methodologies established in the 2007 TRS Rate Methodology Order.  Additionally, NECA has proposed a carrier contribution factor of 0.01056, and a funding requirement of $739.3 million.  Parties may file comments on or before May 18, 2011, and reply comments on or before May 25, 2011.

Comment Sought on Proposed Changes to TRS Fund Contribution Rules

Posted on March 7, 2011

The FCC has issued a Notice of Proposed Rulemaking (NPRM) that would modify  its Telecommunications Relay Services (TRS) Fund contribution rules.  Currently, providers of interstate and international telecommunications services and interconnected voice over Internet protocol (VoIP) service contribute to the TRS Fund.  A new requirement set forth in the Twenty-First Century Communications and Video Accessibility Act of 2010 (Accessibility Act) requires providers of “non-interconnected VoIP service” (e.g., one-way VoIP services and IP-based voice services that do not require a broadband connection) to contribute to the TRS Fund.  Among other things, the NPRM proposes to conform the definition of “interconnected VoIP service” to the definition in the Accessibility Act, amend the FCC’s TRS Fund contribution rules and apply the $25 per year minimum contribution requirement only to contributors who have subject revenues.  Comment is sought on numerous related issues, including free services, providers’ administrative costs, possible zero and de minimis contributions, FCC Form 499-A, a possible interim safe harbor percentage for calculating interstate end-user revenues and the implementation deadline.   Comments on this NPRM will be due 30 days after date of publication in the Federal Register, which has not yet occurred.  Reply comments will be due 15 days thereafter.

FCC Issues Enforcement Advisory For Internet-Based TRS Providers

Posted on February 17, 2011

The FCC’s Enforcement Bureau has issued an enforcement advisory to remind Internet-based telecommunications relay service (TRS) providers of 911 emergency call handling requirements.  Specifically, the advisory is meant to remind Internet Protocol Relay (IP Relay) and Video Relay Service (VRS) that 911 emergency call handling requirements apply regardless of the equipment or software used by consumers seeking to contact emergency assistance.  Among other requirements, 911 emergency call handling rules demand that IP Relay and VRS providers answer incoming emergency calls before any non-emergency calls, and transmit all 911 calls—including automatic number identification, the caller’s registered location, the name of the Internet-based TRS provider—to the public safety answering point or other appropriate local emergency entity.  Violation of Commission rules and orders may subject an Internet-based TRS provider to penalties, including monetary forfeitures.

iTRS Directory Waiver Extended Again to August 2011

Posted on February 7, 2011

Another six-month extension has been granted by the FCC’s Consumer and Governmental Affairs Bureau and the Wireline Competition Bureau (Bureaus) regarding a waiver on treatment of toll free numbers in the Internet-based Telecommunications Relay Service (iTRS) numbering directory (iTRS Directory).  The extension, which was requested by the TDI Coalition, is intended to ensure that calls to users of Video Relay Service (VRS) and Internet Protocol (IP) Relay continue to be routed without disruption while the FCC  considers the record in an ongoing iTRS numbering rulemaking proceeding.  The new extended deadline for toll free numbers and ten-digit geographic numbers to be directed to the same uniform resource identifier in the iTRS Directory is now August 4, 2011.

FCC Proposes Accessibility Pilot Program; Comment Sought on Interim Rules

Posted on January 18, 2011

The FCC proposes to implement and adopt interim rules for an 18-to-24-month pilot program of a National Deaf-Blind Equipment Distribution Program (Program), which would implement Section 105 of the Twenty-First Century Communications and Video Accessibility Act of 2010.  The Program would make telecommunications service, Internet access service, and advanced communications accessible to low income, deaf-blind individuals who cannot afford the specialized communications equipment needed to access these services.  The proposed pilot program would rely primarily on existing, state-run equipment distribution programs (EDPs), but would also fill the gap in equipment distribution in states that lack EDPs.  Comments on the pilot program and its interim rules are due by February 4, 2011, and reply comments are due by February 14, 2011.