A coalition of advocacy and consumer groups for...

cause harm to the quality of VRS” (http://bit.ly/12mKIrd). The VRS order would reduce compensation rates to various-sized providers and created interoperability provisions to give users power to more easily choose providers and equipment. The groups said they believe there has been “no effort on the part of the Commission to compensate or reward providers for improving functional equivalency in VRS calls. The Commission needs to reward such competition-driven innovation even during any efforts to improve the efficiency of the VRS system.” The consumer groups coalition said they support overhaul of Internet-based telecommunications relay services (TRS), including decreasing the permissible wait time on Internet-based TRS services to 10 seconds. The groups support a provision in the VRS order that would allow a quarterly review of TRS Fund contribution, since that would “allow for flexibility in addressing increases or decreases in requests for reimbursement and projections of service requirements from TRS providers.” Sprint urged the FCC to consider ways to reform other forms of TRS as it did in the VRS order. The FCC’s goal of making VRS “an effective, efficient, and sustainable program for the future” applies to all forms of TRS, including IP Relay and IP Captioned Telephone Service (IP CTS), Sprint said. It urged the FCC to “consider the unique characteristics of each service and user population in determining whether a particular regulation is appropriate for a particular form of TRS,” rather than applying direct copies of the VRS rules to other TRS forms. The FCC should designate separate sections of TRS rules for each service, and avoid “overly-broad blanket regulations” by ensuring that additional rules for Internet-based TRS forms are “tailored to address demonstrated needs,” Sprint said. The FCC should not extend registration and TRS User Registration Database requirements to IP Relay and IP CTS providers, as well as exclude IP CTS from the “national outreach regime” adopted for VRS and IP Relay, the telco said. The FCC should apply non-discrimination principles to all Internet-based TRS services, Sprint said. The FCC should establish “clear guidelines” regarding data providers submit to the TRS Fund administrator, it said (http://bit.ly/12mJ60s).