The FCC seeks comment on Hamilton Relay's petition to reconsider exogenous cost recovery guidelines when IP captioned telephone service providers collect funds from the interstate telecom relay service (see 1902080054) 15 days after Federal Register publication, replies 10 days later in docket 13-24, said a Consumer and Governmental Affairs Bureau public notice Wednesday. Thursday, a FR notice is to say TRS numbering directory rules take effect July 8 (see in this issue 1906050015).

The deadline is July 1 for states and providers of interstate telecommunications relay services (TRS) to submit their annual consumer complaint log summaries for the June 1, 2018-May 31 period, reminded an FCC Consumer and Governmental Affairs Bureau public notice in Monday's Daily Digest and on docket 03-123. Complaint log summaries must include total number of interstate relay calls by type of TRS, the number of complaints alleging a violation of federal TRS mandatory minimum standards, complaint date and nature, date of the complaint’s resolution and an explanation of that resolution, it said.

ITTA shot back at Enterprise Users Commenters’ criticism (see 1905300053) of ITTA’s FCC petition for a declaratory ruling that carriers are permitted to recover telecom relay service (TRS) fund contributions through a cost recovery fee line item on consumer bills. Kairos represents Enterprise Users Commenters, which includes dozens of companies. “Kairos Partners’ mission is to ‘identif[y] telecom tax reduction opportunities ... resulting in significant cost savings to [its] clients,’” emailed ITTA Vice President-Regulatory Affairs Michael Jacobs Thursday. “This begs the question of what the Kairos Partners is seeking to achieve ... specifically, whether, contrary to the specific provisions of the [Americans with Disabilities Act] they are attempting to evade contributing to the TRS Fund.” The proceeding is in docket 03-123. Kairos didn't comment Friday.

Enterprise Users Commenters, representing dozens of companies, met with staff from the FCC Wireline and Consumer and Governmental Affairs bureaus to oppose ITTA’s petition for a declaratory ruling, said a posting Thursday in docket 03-123. ITTA seeks a ruling that carriers are permitted to recover telecom relay service fund contributions through a cost recovery fee line item on consumer bills (see 1905070038). The companies said it would be an “egregious violation” of the Americans with Disabilities Act “to stigmatize disabled individuals as a ‘cost burden’ to society by identifying or referencing the cost of any ADA service on consumers’ bills.” They objected to ITTA’s use of the term “non-specific line items,” saying the FCC doesn’t differentiate between specific and non-specific line items. Collectively called Enterprise Users Commenters, the companies include 3M, MasterCard Technologies and MediaNews Group. The group in the docket also reported other FCC meetings, including with Commissioner Mike O'Reilly and Travis Litman, chief of staff to Commissioner Jessica Rosenworcel. ITTA didn't comment right away.

Hamilton Relay supports for traditional telephone relay service, captioned telephone service and speech-to-speech services the provider compensation rates that the interstate TRS fund administrator’s proposed for the July 1-June 30 period. The FCC Consumer and Governmental Affairs Bureau sought comment on proposed per-minute compensation rates for certain forms of TRS subject to the multistate average rate structure plan methodology. Hamilton also wants the FCC to compensate IP CTS providers “at a rate that, at minimum, represents their reasonable costs of providing the service,” it commented, posted Wednesday in docket 03-123. CaptionCall and Sorenson Communications urged the FCC to revisit the rate for IP CTS, saying it “suffers from vulnerabilities and deficiencies.” USTelecom applauded the FCC for “taking steps to be fiscally responsible” but urged the agency to establish a longer time frame “between when the final rates and budget size are announced and the effective date.” Replies are due June 7.

The FCC is looking at revoking Communications Act Section 214 certifications of China Unicom and China Telecom, Chairman Ajit Pai said after the commissioners’ meeting Thursday. Commissioners voted 5-0 to deny China Mobile’s long-standing Section 214 application. Commissioners Jessica Rosenworcel and Geoffrey Starks, as expected (see 1905060057), said the FCC is going too little to shore up 5G security.

ITTA representatives and CenturyLink said submissions opposing the association’s petition (see 1905010181) mischaracterize the declaratory ruling it seeks. The petition, they told the FCC Wireline and Consumer and Governmental Affairs bureaus, seeks a ruling that “it is and always has been permissible for a carrier recovering [Telecommunications Relay Service] TRS Fund contributions via an end user cost recovery fee line item (or the like) on customers’ bills to include TRS, among other references, in the line item description,” said a filing posted Tuesday in docket 03-123. It said an order should make clear that carriers “should not double recover their TRS costs through both rates and non-specific line items” but they could recover some costs through rates and some through a non-specific line item.

The FCC should disregard Sorenson’s rule modification proposals related to equipment for the video relay service, ZVRS filed, posted Monday in docket 10-51. Sorensonwantslanguage that “would collect in one place various disparate statements the Commission has made in TRS orders over the years,” said a filing posted Friday. ZVRS responded that the proposals would negatively affect VRS users and providers and the commission shouldn’t consider them because “stakeholders have had no opportunity to consider and evaluate them” due to the “imminent sunshine period.” Revised VRS rules are to get a vote at Thursday's FCC meeting (see 1904170049).

Consumer groups for the hearing impaired repeated opposition to carriers listing telecom relay services along with other regulatory fees in a line item on customer bills. The groups, meeting Monday with staff from the FCC Consumer and Governmental Affairs Bureau’s front office and Consumer Policy Division Disability Rights Office, said TRS is an “accessibility mandate” and for carriers “should be a cost of doing business, not a separate fee,” said a posting Wednesday in docket 03-123. The National Association of the Deaf, Hearing Loss Association of America, Telecommunications for the Deaf and Hard of Hearing and others responded to an ITTA petition seeking a declaratory ruling (see 1902210053).

House Communications Subcommittee Chairman Mike Doyle, D-Pa., and Sen. Ed Markey, D-Mass., urged the FCC Wednesday to deny an ITTA petition for a declaratory ruling to clarify that carrier telecom relay service fund contribution costs can be passed on to consumers in express line-item fees on phone bills (see 1805090021). ITTA resisted the lawmakers' characterization of the group's petition. “To specifically identify the cost of any [Americans with Disabilities Act] service (whether it be for a handicap accessible ramp or TRS) on any consumer or corporate bill in the form of a surcharge, fee, or any other form of a line-item discriminates against and ostracizes people with disabilities,” Markey and Doyle said in a letter to FCC Chairman Ajit Pai. “Highlighting such costs creates an unacceptable environment where individuals with disabilities are seen as a ‘cost burden’ to society. This is exactly what the passage of the ADA attempted to prevent.” ITTA in February slammed a Kairos Partners filing on behalf of enterprise users that claimed the petition aimed to “stigmatize disabled individuals,” saying the claims were “red herrings” (see 1902210053). The Doyle/Markey letter “misrepresents” ITTA's petition, the group said in a statement. “ITTA’s petition would allow carriers to continue to include their TRS contributions among other references in a general line item on consumers’ bills. Doing so provides the transparency for consumers that lies at the heart of the FCC’s truth-in-billing rules. It also has no effect on the TRS Fund recoveries from consumers.” The FCC didn't comment.