Hamilton Relay Hits FCC IP CTS Draft Automated Speech Recognition Authorization, Rate Cuts
Hamilton Relay objected to planned FCC authorization of automated speech recognition (ASR) as a reimbursable form of IP captioned telephone service (CTS) in a draft ruling on the tentative agenda for the June 7 FCC open meeting, which could draw…
Sign up for a free preview to unlock the rest of this article
Export Compliance Daily combines U.S. export control news, foreign border import regulation and policy developments into a single daily information service that reliably informs its trade professional readers about important current issues affecting their operations.
further provider concerns, given their past advocacy (see 1805240010). "To make such a profound change, in the absence of appropriate notice and comment, not only violates the Administrative Procedure Act ... but amounts to an abrupt and unexplained departure from its prior practice and frankly could cause harm to the users of IP CTS," said a filing by the IP CTS provider posted Friday in docket 13-24. The FCC "did not seek comment on whether to authorize ASR as a compensable form of TRS [telecommunication relay service] in the 2013 [Further NPRM] or elsewhere. Moreover, although the Declaratory Ruling discusses the process for applying for certification to provide IP CTS by means of ASR, it appears to authorize currently certified providers of IP CTS to begin offering ASR services without subjecting such services to oversight ... This poses a risk of harm to users of IP CTS. For example, the draft item does not even acknowledge that 911 calls using ASR are an untested and potentially unreliable means of communicating with emergency officials." ASR "has much potential," but it needs more study and the FCC needs more data, the company said. Hamilton also criticized a draft order's proposed reduction in the IP CTS compensation rate from $1.95 per minute to $1.75 starting July 1. "An arbitrary 10% cut is very difficult for any industry to manage, especially in this situation given the very short nature in which this particular change will take place," it said, suggesting the FCC lacked adequate cost data. The provider "continues to favor competitively-based rates instead of the cost-based methodology" that it believes doesn't capture true service costs. Hamilton said a July 1, 2019 "rate cut to $1.58 per minute, as proposed in the draft item, would create serious market disruption and likely would adversely affect quality and availability of service." It urged the FCC "to establish a two-year interim rate of $1.75 per minute from July 1, 2018 to June 30, 2020, or until a permanent rate methodology has been implemented." Hamilton also filed opposition in docket 03-123 to an FCC public notice seeking modification or clarification of a protective order, and suggested its own changes.