Advocacy groups and some smaller providers of telecommunications relay services...

to show special circumstances and that the commission should make changes only with a formal rulemaking. Convo Communications also opposed the request and suggested a rulemaking notice as an appropriate step. Purple asked for clarification or waiver of the rule that requires the numbering directory to have records that map an Internet-based TRS user’s telephone number to the user’s Uniform Resource Identifier (URI). Instead, in order to implement its call forwarding “Follow Me” service, it asked to populate the numbering directory with URIs containing the IP address of its own servers, rather than the customer’s IP address. The request seeks to “avoid compliance with an industry-wide technical standard so that it can implement a feature that may be inconsistent with the FCC’s carefully considered numbering regime,” Sorenson said. The waiver is in Purple’s interests, but not necessarily those of the public, Sorenson said. Sorenson said Purple provided limited information and didn’t explain how a waiver would permit more effective implementation of the system. The commission shouldn’t grant either a provider-specific waiver or an industry-wide waiver, Sorenson said. Granting the request could “undermine the Commission’s comprehensive numbering regime, which involves a delicate balance between several interrelated rules,” it said. Snap Telecommunications and CSDVRS, however, said server routing would allow video phones to be fully functional behind firewalls and in secure environments. “Server routing is in widespread use and is a standard routing method for VoIP connections,” Snap said. It said it has a server routing system “ready today to provide to federal and state government agencies and businesses who have requested it as the only acceptable means of installing video phone technology.” Snap and CSDVRS said server routing would improve the interoperability problems that frustrate customers. “CSDVRS has seen this devolve into some consumers reverting to older [customer premises equipment] technology as distributed by the largest provider (Sorenson) which does not provide forward compatibility, in favor of the more technologically advanced CPE offered by CSDVRS and other providers, simply to avoid interoperability frustrations,” CSDVRS said. A group of deaf and hard-of-hearing advocacy groups also supported Purple’s petition. Hearing individuals have call forwarding services, and the Americans with Disabilities Act says those with disabilities should have the same benefits, it said. At a minimum, the commission should grant the waiver on an interim basis, it said. Convo, though, said Purple didn’t show that its method is the only way to implement call forwarding. Call forwarding is desirable, it said, but Convo and others “have already expended considerable sums in designing and implementing VRS calling and routing platforms to comply with FCC and Neustar rules.” An NPRM is the “most appropriate vehicle” for exploring how to implement call forwarding by all providers, it said. Reply comments on the petition are due July 23.