MachineGenius took issue with concerns of advocates for deaf consumers about an FCC order, declaratory ruling and notices draft on IP captioned telephone service (CTS) that seeks to authorize automated speech recognition (ASR) technology. "Many of their expressed concerns are poorly substantiated," said a filing posted Thursday in docket 13-24. Telecommunications for the Deaf and Hard of Hearing Inc. (TDI) and others had said (see 1805300048) the draft's "approach of delegating to the Bureau the responsibility of applying the existing TRS [telecommunications relay service] minimum standards to IP CTS applicants proposing to use ASR does not acknowledge that the minimum standards are replete with explicit references to human communications assistants (CAs)," said MachineGenius, which is seeking to be certified an IP CTS provider. "On the contrary, the Declaratory Ruling explicitly and extensively addresses the role of [CAs], and the fact that the CA role may be limited or nonexistent in an ASR-based IP CTS solution, concluding that 'the definition of IP CTS in our rules does not specify how captions must be generated.'" The draft "observes that 'use of [ASR] technology for IP CTS without CA involvement does not fundamentally change the functional role of the service.' ... In this context [,] the Declaratory Ruling authorizes the approval of ASR-based IP CTS applications." TDI didn't comment. Hamilton Relay pressed the FCC to move all draft ARS and notice of inquiry issues to the Further NPRM, and to freeze the IP CTS rate at $1.75 per minute for two years if the current rate methodology is junked. Hamilton is concerned about the draft declaratory ruling's "failure to address emergency call handling in an ASR environment," said a filing on a meeting with aides to Chairman Ajit Pai and Commissioners Brendan Carr and Jessica Rosenworcel. "Legal problems [are] raised by the determination in the draft Declaratory Ruling that ASR is a reimbursable form of IP CTS."

Two more IP captioned telephone service providers opposed a draft order's cuts in their compensation rate, though they suggested smaller cuts as a backup. CaptionCall said the FCC shouldn't reduce a $1.95 per minute rate by 10 percent in each of the next two funding years -- to $1.75 on July 1, and to $1.58 on July 1, 2019 -- but the Sorenson Communications subsidiary floated a $1.75 rate for two years if the agency insists on an interim rate. ClearCaptions suggested $1.85 for FY 2018-19 and $1.75 for FY 2019-20. Hamilton previously offered a $1.75 rate for both years (see 1805250056). The draft seeks to reduce IP CTS funding approaching $1 billion per year.

The World Customs Organization issued the following releases on commercial trade and related matters:​​

The World Customs Organization issued the following releases on commercial trade and related matters:​​

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 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.

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 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.

An FCC draft proposal to cut the IP captioned telephone service compensation rate on an interim basis could concern providers, based on a look at their advocacy. The commission would reduce the IP CTS rate by about 10 percent each of the next two years while it further reviews the issues under a wide-ranging draft order, declaratory ruling, Further NPRM and notice of inquiry on the tentative agenda for the June 7 monthly meeting (see 1805170060). At least three of the five IP CTS providers argued against such an approach, though none commented to us this week. Advocates for deaf consumers did say they're concerned about certain draft proposals, especially to approve use of automated speech recognition (ASR) technology without detailed service-quality safeguards.

An FCC draft proposal to cut the IP captioned telephone service compensation rate on an interim basis could concern providers, based on a look at their advocacy. The commission would reduce the IP CTS rate by about 10 percent each of the next two years while it further reviews the issues under a wide-ranging draft order, declaratory ruling, Further NPRM and notice of inquiry on the tentative agenda for the June 7 monthly meeting (see 1805170060). At least three of the five IP CTS providers argued against such an approach, though none commented to us this week. Advocates for deaf consumers did say they're concerned about certain draft proposals, especially to approve use of automated speech recognition (ASR) technology without detailed service-quality safeguards.

The FCC set pleading cycles on CenturyLink and ITTA petitions for declaratory rulings. Comments are due June 18, replies July 3 on a CenturyLink petition (see 1805150055) urging the commission to "complete the remand" from the U.S. Court of Appeals for the D.C. Circuit regarding application of a VoIP symmetry rule to long-distance providers delivering traffic by partnering with over-the-top VoIP providers lacking last-mile connections, said a Wireline Bureau public notice Friday in docket 10-90. The same deadlines apply to an ITTA petition (see 1805090021) asking the FCC to clarify that it is and has been permissible under truth-in-billing rules and Communications Act Section 225 for carriers recovering telecom relay service fund contribution costs to include TRS line-item fees on bills, said a Consumer and Governmental Affairs Bureau PN in docket 03-123.

The FCC would further streamline telecom service discontinuances and network changes under a draft wireline infrastructure order circulated by Chairman Ajit Pai for consideration at the June 7 commissioners' meeting (see 1805160051). Pai also plans votes on draft telecom items on rural telco broadband USF contribution relief, intercarrier compensation arbitrage in general, toll-free number arbitrage and fraud, IP captioned telephone service (IP CTS) rates and use, and telephone slamming and cramming.