Consumer groups for people with speaking disabilities supported stricter rules for speech-to-speech telecom relay services, in comments last week on an FCC notice of proposed rulemaking. Relay providers resisted some of the changes being considered. The sides agreed that Internet-based STS service should get Interstate TRS Fund support.

Clarification: AT&T only rejected slamming and additional privacy rules for TRS (CD Aug 27 p3).

The FCC shouldn’t allow relay providers to forward 911 calls to other providers, Sorenson and other Internet relay providers said in reply comments. Earlier this month, in initial comments on a rulemaking about the FCC 10-digit numbering plan for Internet relay, the National Emergency Number Association said the FCC should require relay providers to forward 911 calls to other providers if they don’t answer in a set period (CD Aug 12 p6). In a reply, AT&T opposed imposing slamming and other new customer privacy rules on relay providers.

The FCC need not clarify the default provider rule in its order to implement a 10-digit numbering plan for Internet-based relay services, relay provider Sorenson said. In a Monday filing, Sorenson opposed a request by CSDVRS. CSDVRS had said the order could be read as empowering relay providers to complicate consumers’ efforts to access alternate providers by dialing around (CD Aug 19 p8). “The Commission should decline CSDVRS’s invitation to establish a lengthy and complex set of situation-specific rules that would effectively freeze TRS technology and innovation, to the detriment of users,” the company said. “CSDVRS’s proposal would undermine the progress toward functional equivalency that will be achieved by implementation of the FCC’s uniform numbering system.” The default provider selection requirement won’t give relay providers the wrong idea, because the FCC said “nothing” in the order “detracts from a TRS provider’s interoperability obligations,” Sorenson said. Giving relay users 10-digit numbers “will necessarily change the manner in which the end user experiences interoperability,” it said. Interoperability mechanisms will “evolve,” but users’ “freedom of choice” will remain, it said.

The FCC need not clarify the default provider rule in its order to implement a 10-digit numbering plan for Internet-based relay services, relay provider Sorenson said. In a Monday filing, Sorenson opposed a request by CSDVRS. CSDVRS had said the order could be read as empowering relay providers to complicate consumers’ efforts to access alternate providers by dialing around. “The Commission should decline CSDVRS’s invitation to establish a lengthy and complex set of situation-specific rules that would effectively freeze TRS technology and innovation, to the detriment of users,” the company said. “CSDVRS’s proposal would undermine the progress toward functional equivalency that will be achieved by implementation of the FCC’s uniform numbering system.” The default provider selection requirement won’t give relay providers the wrong idea, because the FCC said “nothing” in the order “detracts from a TRS provider’s interoperability obligations,” Sorenson said. Giving relay users 10-digit numbers “will necessarily change the manner in which the end user experiences interoperability,” it said. Interoperability mechanisms will “evolve,” but users’ “freedom of choice” will remain, it said.

The FCC shouldn’t allow relay providers to forward 911 calls to other providers, Sorenson and other Internet relay providers said in reply comments. Earlier this month, in initial comments on a rulemaking about the FCC 10-digit numbering plan for Internet relay, the National Emergency Number Association said the FCC should require relay providers to forward 911 calls to other providers if they don’t answer in a set period. A forwarding requirement would “absolve” understaffed providers “of any responsibility for complying with the rules, and could result in a ‘round robin’ where 911 calls are shuttled multiple times to different providers before being processed,” Sorenson said. Forwarding “goes beyond functional equivalency” required by the Americans with Disabilities Act, GoAmerica said. AT&T opposed a forwarding obligation, too, but for technical reasons. To implement the process, providers “would need to develop a system to exchange information in real-time that will assess the CA [communications assistant] availability of each provider,” the carrier said. “While such a system may be technically feasible, it would be difficult to develop, test, and implement the system” by Dec. 31, the date by which providers must implement the 10-digit numbering system, it said. Meanwhile, AT&T opposed adoption of slamming rules for Internet relay. The rules, endorsed only in initial comments, would protect relay users from unauthorized default provider changes. The FCC didn’t adopt slamming rules on voice carriers until it developed a “substantial record of complaints from consumers,” AT&T said. The FCC hasn’t done the same for Internet relay, it said. “Extending all of the slamming rules to Internet-based TRS providers would be a solution without a problem to resolve.”

No relay provider should read the FCC order on a 10- digit numbering plan for Internet-based telecom relay services (CD Aug 18 p8) as empowering to complicate consumers’ efforts to access alternative providers by dialing around, TRS provider CSDVRS said. In a petition for clarification, CSDVRS said it fears that relay providers might get the wrong idea from “the FCC’s new emphasis on having a default provider” handling nearly all inbound and outbound calls for registered users. The FCC should clarify that no default provider is allowed to “create barriers that would impede or discourage a user” from dialing around, including “pop-up screens or warning messages, or degradation of the TRS call, video quality or video interpreter capabilities,” it said. The default provider rule is “flawed because of two fundamental differences” between relay services and regular switched-based or VoIP voice calls, CSDVRS said. The required speed of answer for relay services is “not at all functionally equivalent to the dial tone enjoyed by voice telephone users,” and “there is no fiduciary relationship” between a relay user and default provider, it said. The differences “raise questions about having to rely on the default provider for all incoming and outgoing calls, and make all the more critical the need for clear FCC guidance requiring all providers to facilitate calls to competing providers.”

Deaf interest groups, telecom relay providers and others argued details on an FCC plan to give 10-digit phone numbers to deaf people using Internet-based TRS services. They filed comments Friday on a rulemaking (CD June 26 p2) on the 10-digit numbering plan. The FCC sought comment on 911 and other issues, as well as how it might apply customer proprietary network information (CPNI), slamming and other customer privacy rules to relay providers. Relay providers have until Dec. 31 to implement a 10-digit plan.

Sorenson will ask a federal court to stay part of an FCC order on marketing rules for telecom relay service providers unless the FCC does so by July 24, Sorenson said Monday. Sorenson disputes rules adopted last November that ban TRS providers from contacting customers to “attempt to influence … [consumer] use of relay service” or encourage participation in lobbying (CD July 3 p6). Last month, Sorenson sought review in the 10th U.S. Circuit Court of Appeals in Denver. A late May FCC order intended to clarify limits only “made things worse -- not better -- exacerbating the conflict” with the Constitution, Communications Act and Administrative Procedure Act, Sorenson said.

Rules to protect deaf consumers from unwanted marketing and lobbying have created a double standard for how the FCC regulates telecom relay service providers and dial-tone carriers, said relay providers and others. But advocates for deaf people said marketing is one issue for which the FCC should treat TRS providers differently. “If we get abused, the fundamental principles of relay service will not meet its full potential,” said Claude Stout, executive director of Telecommunications for the Deaf and Hard of Hearing (TDI). If TRS users believe their call is being monitored or their data will be used for other purposes, they will be “less confident” to use relay service, he said. “We need to make sure that doesn’t happen.”