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.

Sorenson Communications and smaller video relay service providers disagreed on how the FCC should structure VRS compensation rates after a current four-year schedule of declining rates expires June 30. Two consumer groups said the commission should ensure deaf and hard-of-hearing VRS users receive communications service that's functionally equivalent to other consumer services. The parties filed comments posted Monday and Tuesday in response to a recent FCC Further NPRM on VRS provider compensation rates and other issues (see 1703230055).

The FCC voted 3-0 to approve an item aimed at improving video relay services (VRS) for deaf and hard-of-hearing people, as expected (see 1703220013). The item adopted at the commissioners' meeting Thursday contains orders that would authorize trials using American Sign Language (ASL) relay interpreters with specialized technical knowledge and, in some cases, deaf interpreters. It also contains a notice of inquiry (NOI) and a Further NPRM that proposed a new four-year schedule of VRS provider compensation rates and sought comment on various plans, including one offered by smaller providers to raise their rates, and alternatives. Sorenson Communications recently submitted "less regulatory" proposals, responding to a draft's inclusion of the small-provider plan which would lower its compensation (see 1703080060).

Smaller providers "applauded" the FCC's draft video relay service item tentatively set for a March 23 commissioners' vote (see 1703020070). CSDVRS (ZVRS), Purple Communications, ASL Services Holdings (GlobalVRS) and Convo Communications praised the agency for soliciting comment on their joint VRS compensation rate proposal in a draft Further NPRM, notice of inquiry and order. "Proposed reforms would greatly benefit the deaf community, protect the long term stability of the TRS [telecom relay service] Fund, relieve pressure on contributors to the Fund, help smaller providers grow to scale, and promote competition for VRS," said a joint filing posted Tuesday in docket 10-51 on a meeting with an aide to Commissioner Mike O'Rielly. "The non-dominant VRS providers’ four-year rate proposal would move each provider in the market closer to a reasonable operating margin, thereby helping the non-dominant providers remain in operation as planned competitive reforms are implemented." Their proposal would raise compensation rates for all traffic tiers, except for the highest tier covering VRS leader Sorenson Communications, which would see another rate cut. The smaller firms said they would be interested in a prohibition of "non-compete clauses" that restrict the pool of VRS interpreters and urged the FCC to adopt a new rate order by June 30, when the current schedule expires. "The proposed [Further] NPRM has broad support, reflects the hard work and thinking of the Commission and should not be undermined by last minute alternative proposals that disregard the Deaf community’s needs and consumer choice," they said in a filing on a discussion with an aide to Chairman Ajit Pai. In a meeting with the O'Rielly aide summarized in a filing, Sorenson officials discussed a previous filing, which proposed a VRS rate auction and price-cap proposal and criticized the smaller providers' proposal (see 1703080060). Sorenson's rate proposals wouldn't incorporate its historical debt levels or debt service, said the company, which also noted its role as a major employer of the deaf and developer of VRS functionalities. Hamilton Relay said it agreed with a draft order provision to direct the TRS Fund administrator not to withhold payments to a VRS provider for failing to meet a speed-of-answer standard if it has a waiver pending on "exigent circumstances." But Hamilton asked that the relief be extended to all TRS providers in a future proceeding, and proposed language, said a filing on a meeting with Consumer and Governmental Affairs Bureau staffers.

Sorenson Communications said an FCC draft Further NPRM "missed an opportunity" to explore "less regulatory" proposals for new video relay service compensation rates, though it praised agency transparency in releasing text and its effort to provide "certainty and stability." The largest VRS provider urged the FCC to seek comment on a "market-based" auction proposal for setting price caps that the company outlined this week. GlobalVRS, a smaller provider, rejected Sorenson's plan. Commissioners tentatively plan to vote March 23 on a draft VRS order, FNPRM and notice of inquiry that prominently sought comment on the proposals of smaller providers to increase rates except for the highest traffic tier covering Sorenson, which would be cut further (see 1703020070 and 1703030053).

Sorenson Communications asked the FCC to revise a waiver that gave VTCSecure, as a provider of direct video calling customer-support services, access to the telecom relay service numbering directory (see 1701190038). Three bureaus "failed to address a critical issue" raised by video relay service providers: "if VTCSecure is permitted to place the same telephone number available to hearing users into the Directory, that will cause providers to route all deaf-initiated calls to that number via a point-to-point call and will prevent deaf consumers from placing a VRS [video relay service] call to that number," said a Sorenson petition for reconsideration posted Friday in docket 10-51. "Sorenson supports and recognizes the benefits of direct sign-language customer-support services, and has no objection to dedicated numbers for point-to-point calls. It simply believes that the Waiver Order will have the unintended negative consequence of limiting options for deaf consumers if VTCSecure places general customer service numbers into the Directory. Amending the order to require that direct sign-language customer-support numbers be separate and distinct from the number used by hearing users would ensure that deaf users have the choice of using VRS or making a point-to-point call."