The FCC might look to adopt new video relay service (VRS) rates at the June 22 meeting of commissioners, industry representatives told us Tuesday. Commissioners also could address other telecom relay service (TRS) rates, including IP captioned telephone service rates for the near term, said an industry representative, who believes the agency wants to act by the end of June because the new VRS/TRS funding year begins July 1. The tentative agenda for the June meeting is due Thursday. The FCC didn't comment.
Sorenson Communications asked the FCC to extend deadlines for providers of video relay services to decide whether to participate in, and start, trials using specialized interpreters ("skills-based routing") and deaf interpreters which were authorized in March (see 1703230055). The largest VRS provider said it strongly backs the trials, but said more time is needed due to uncertainty over proposals to change compensation rates on July 1 (see 1704250057 and 1705050012). The date for providers to declare their intent to participate should be extended from June 1 to 60 days after the FCC adopts new rates, and the start date of the eight-month trial periods should be extended from Aug. 1 to 180 days after the adoption of such rates, said a Sorenson filing posted Friday in docket 10-51. Sorenson separately explained its proposals for raising the per-minute Tier III compensation rate (more than 2.5 million monthly minutes of calling under an FCC proposal) from $3.49 to $4.19, "including the cost of necessary end-user equipment," or for establishing a unified VRS rate of $3.79. The rates are justified due to increasing interpreter wage and benefit costs, affiliate intellectual property costs and the need for a "commercially reasonable operating margin," said the company's filing Thursday on a meeting with an aide to Chairman Ajit Pai. The other VRS providers urged the FCC to keep the tiered structure and to lower the Tier III rate to $2.83 per minute while raising the rates for lower-traffic tiers to account for cost differences. A filing by ZVRS, the second-largest provider, contained sensitive cost data (redacted) to "correct errors" generated by telecom relay service fund administrator Rolka Loube, support the small provider proposals and show that Sorenson claims about ZVRS overcompensation are "unfounded." A filing in docket 03-123 by Sorenson and subsidiary CaptionCall of a call with the Pai aide said they discussed a pending NPRM on IP captioned telephone service (IP CTS), and expressed appreciation the agency "will address any changes to the IP CTS rate methodology in the context of that proceeding, rather than in the abbreviated time" for commenting on Rolka Loube TRS fund estimate (see 1705030034 and 1705110023).
The FCC teed up the telecom relay service fund proposals of its administrator for the funding year starting July 1. Comments are due May 24, replies June 1 on Rolka Loube Associates' "proposed provider compensation rates, funding requirement, and carrier contribution factor," said a Consumer and Governmental Affairs Bureau public notice in docket 10-51 in Thursday's Daily Digest. Rolka Loube projected the TRS fund needs $1.25 billion for FY 2018 (up from $1.14 billion currently) and a carrier contribution factor of 2.1 percent of U.S. interstate and international telecom end-user revenue (see 1705030034). It projected the IP captioned telephone service (IP CTS) needs $735 million and video relay service needs $460 million. The PN sought comment on Rolka Loube's proposed per-minute compensation rates, including of $1.95 for interstate and intrastate IP CTS and interstate CTS, based on a multistate average rate structure. The PN noted Rolka Loube's proposals for alternative rate mechanisms, but it said it was premature to select specific recommendations for IP CTS because the FCC has an open rulemaking on the methodology for that service; instead, it may seek comment on some of the recommendations as part of that rulemaking. For VRS, Rolka Loube recommended per-minute compensation rates of $5.29 for "emergent" providers, $4.17 for proposed Tier I traffic (0-2.5 million minutes monthly) and $2.83 for proposed Tier II traffic (minutes exceeding 2.5 million monthly). That would be closer to what smaller VRS providers have proposed than what industry leader Sorenson Communications sought (see 1704250057). The PN said the comments would be incorporated into a VRS rate rulemaking (see 1703230055). Another PN said the FCC plans to place into the record summaries of VRS providers' updated cost and demand information reported in 2017 for 2015 (actual), 2016 (actual), 2017 (projected) and 2018 (projected), subject to protective order safeguards. Affected parties have until Wednesday to object.
The FCC teed up the telecom relay service fund proposals of its administrator for the funding year starting July 1. Comments are due May 24, replies June 1 on Rolka Loube Associates' "proposed provider compensation rates, funding requirement, and carrier contribution factor," said a Consumer and Governmental Affairs Bureau public notice in docket 10-51 in Thursday's Daily Digest. Rolka Loube projected the TRS fund needs $1.25 billion for FY 2018 (up from $1.14 billion currently) and a carrier contribution factor of 2.1 percent of U.S. interstate and international telecom end-user revenue (see 1705030034). It projected the IP captioned telephone service (IP CTS) needs $735 million and video relay service needs $460 million. The PN sought comment on Rolka Loube's proposed per-minute compensation rates, including of $1.95 for interstate and intrastate IP CTS and interstate CTS, based on a multistate average rate structure. The PN noted Rolka Loube's proposals for alternative rate mechanisms, but it said it was premature to select specific recommendations for IP CTS because the FCC has an open rulemaking on the methodology for that service; instead, it may seek comment on some of the recommendations as part of that rulemaking. For VRS, Rolka Loube recommended per-minute compensation rates of $5.29 for "emergent" providers, $4.17 for proposed Tier I traffic (0-2.5 million minutes monthly) and $2.83 for proposed Tier II traffic (minutes exceeding 2.5 million monthly). That would be closer to what smaller VRS providers have proposed than what industry leader Sorenson Communications sought (see 1704250057). The PN said the comments would be incorporated into a VRS rate rulemaking (see 1703230055). Another PN said the FCC plans to place into the record summaries of VRS providers' updated cost and demand information reported in 2017 for 2015 (actual), 2016 (actual), 2017 (projected) and 2018 (projected), subject to protective order safeguards. Affected parties have until Wednesday to object.
The Hawaii Public Utilities Commission chose Sprint as the state’s exclusive telecom relay service provider from July 2017 to July 2020, the commission said in an order released Friday in docket 2016-0365. Sprint has the current contract and was the sole bidder for the new one, the PUC said. “Sprint has been consistent in fulfilling the expectations of the existing contract, and by its current proposal, represented its intent to maintain the manner and quality of its provision of TRS in Hawaii.”
USTelecom asked the FCC to ensure "greater efficiencies" in the video relay service program for the deaf and hard of hearing, and to shore up "the overall sustainability" of the broader telecom relay service fund. In replies on a Further NPRM (see 1703230055), it lauded commission efforts to encourage VRS efficiencies and innovation to address cost issues, but said the agency recognized structural changes were "slow to arrive." Even with FCC 2013-2017 reductions in VRS provider compensation rates, overall TRS funding continues to increase as a "shrinking group of rate-payers" shoulder the costs, leading to a recent TRS administrator proposal to increase the industry contribution rate by 12 percent (see 1705030034), said the group Thursday in docket No. 10-51. Parties filed initial comments last month (see 1704250057). USTelecom said the FCC should reject Sorenson Communication's proposal that VRS become a "mandatory" service for common carriers. ASL Service Holdings (GlobalVRS) said it wasn't surprising Sorenson opposed rivals' VRS compensation proposal to achieve "provider diversity" and TRS stability. (The proposal would raise most rates while cutting further the traffic tier rate affecting Sorenson.) "The dominant provider seeks to solidify its virtual monopolization of the Program," replied ASL Service. "The dominant provider can trace its 'success' not to innovation, superior service, or efficiency, but rather to years of over compensation." Sorensen has concerns on the FNPRM, it replied and told Office of General Counsel officials including acting General Counsel Brendan Carr. In the meeting, it sought "equal treatment to VRS providers that provide more than 500,000 minutes per month." The path in the FNPRM would set Tier III "rates below costs," it replied, violating the Americans with Disabilities Act. "If the Commission does not adopt one of Sorenson’s proposals for market-determined rates, the only rate in the record that meets ADA requirements is a $4.19 unitary per minute rate. Even if the Commission intends to push all costs of end user devices onto deaf consumers in violation of the ADA, the only justifiable rate in the record for VRS, without necessary equipment, is $3.73 per minute."
Rolka Loube Associates projected the FCC telecom relay service fund needs $1.26 billion in net cash for FY 2018 starting July 1, up from $1.14 billion in FY 2017. The TRS fund administrator proposed an industry contribution factor of 2.1 percent of annual telecom carrier interstate and international end-user revenue, based on the most recent estimate, which was $60.2 billion. Rolka Loube's annual projections were posted Wednesday in docket 10-51. The TRS fund pays for "interstate traditional TRS, interstate captioned telephone service (CTS), interstate speech-to-speech (STS), and both intrastate and interstate video relay service (VRS), Internet Protocol (IP) Relay service, and Internet Protocol Captioned Telephone Service (IP CTS)," wrote the administrator, which "reimburses providers at compensation rates" it computes under FCC rules, after the rates are "approved or modified by the Commission."
Rolka Loube Associates projected the FCC telecom relay service fund needs $1.26 billion in net cash for FY 2018 starting July 1, up from $1.14 billion in FY 2017. The TRS fund administrator proposed an industry contribution factor of 2.1 percent of annual telecom carrier interstate and international end-user revenue, based on the most recent estimate, which was $60.2 billion. Rolka Loube's annual projections were posted Wednesday in docket 10-51. The TRS fund pays for "interstate traditional TRS, interstate captioned telephone service (CTS), interstate speech-to-speech (STS), and both intrastate and interstate video relay service (VRS), Internet Protocol (IP) Relay service, and Internet Protocol Captioned Telephone Service (IP CTS)," wrote the administrator, which "reimburses providers at compensation rates" it computes under FCC rules, after the rates are "approved or modified by the Commission."
IP Captioned Telephone Service should be migrated to automated systems over time, Sorenson Communications and its subsidiary CaptionCall told the FCC. Company officials discussed various IP CTS issues, including the FCC's pending decision on rates, eligibility standards and the development of "Automatic Speech Recognition ('ASR')," said a CaptionCall filing posted Tuesday in docket 03-123 on meetings with an aide to Chairman Ajit Pai and other commission staffers. Noting FCC concerns about growth in overall telecom relay service (TRS) funding, the filing said the company recognized that changes to the IP CTS rate methodology may be needed. "CaptionCall agrees that, over the long term, the only sustainable course is to migrate nearly all IP CTS calls to an entirely ASR-based relay service, with human communications assistants needed only in circumstances that ASR cannot adequately handle," it said. "However, it will take some years before ASR technology evolves to that point of providing functionally equivalent service on a scalable and commercially robust level." Hamilton Relay met with FCC officials to discuss methods for improving IP CTS while ensuring only eligible people use the service. "Among the options discussed were the enforcement of existing rules, reinstatement of third-party certifications with possible enhancements to those certifications, while grandfathering those users who previously obtain[ed] third party certifications during the period when such certifications were not required, and annual re-registration and self-certification renewal requirements," said a filing. Hamilton urged the FCC to issue a Further NPRM to explore the issues, voiced continued support for the multistate average rate structure (Mars) for calculating IP CTS and some other TRS rates, and said the agency's proposed Office of Economics and Data should study the effectiveness of the MARS methodology before making changes.
IP Captioned Telephone Service should be migrated to automated systems over time, Sorenson Communications and its subsidiary CaptionCall told the FCC. Company officials discussed various IP CTS issues, including the FCC's pending decision on rates, eligibility standards and the development of "Automatic Speech Recognition ('ASR')," said a CaptionCall filing posted Tuesday in docket 03-123 on meetings with an aide to Chairman Ajit Pai and other commission staffers. Noting FCC concerns about growth in overall telecom relay service (TRS) funding, the filing said the company recognized that changes to the IP CTS rate methodology may be needed. "CaptionCall agrees that, over the long term, the only sustainable course is to migrate nearly all IP CTS calls to an entirely ASR-based relay service, with human communications assistants needed only in circumstances that ASR cannot adequately handle," it said. "However, it will take some years before ASR technology evolves to that point of providing functionally equivalent service on a scalable and commercially robust level." Hamilton Relay met with FCC officials to discuss methods for improving IP CTS while ensuring only eligible people use the service. "Among the options discussed were the enforcement of existing rules, reinstatement of third-party certifications with possible enhancements to those certifications, while grandfathering those users who previously obtain[ed] third party certifications during the period when such certifications were not required, and annual re-registration and self-certification renewal requirements," said a filing. Hamilton urged the FCC to issue a Further NPRM to explore the issues, voiced continued support for the multistate average rate structure (Mars) for calculating IP CTS and some other TRS rates, and said the agency's proposed Office of Economics and Data should study the effectiveness of the MARS methodology before making changes.