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FCC Filings
Summary of FCC Filings

On May 1, 2007, the National Exchange Carrier Association (NECA), filed a report with the Federal Communications Commission (FCC) on proposed rates for Telecommunications Relay Services (TRS), which include Video Relay Service (VRS), TTY, IP Relay, and Speech-to-Speech (STS). NECA failed to recommend any rate for VRS, but, instead, listed various rates based on data supplied to NECA by the VRS providers. The FCC is required to establish a rate for all TRS services by July 1, 2007, for the 2007-2008 rate year, which begins July 1. In the past, NECA has recommended a rate which was the starting point for the FCC’s deliberations. Last year, the FCC did not adopt the proposed NECA rate, but, instead, froze the existing rate and suggested an overhaul of the existing rate process.

On Oct. 31, 2006, seven VRS providers filed Comments with the FCC, urging the government to create a simplified, predictable, and fair VRS rate. The VRS providers were united in advocating a "price cap" approach that would take into account cost increases as well as expected efficiency gains.

On Nov. 13, 2006, several joint VRS providers and consumer groups filed reply comments, again indicating collective support of a "price cap" approach to rate making for VRS. Sorenson Communications emphasized this approach would allow increased access to VRS, the training of more interpreters, and improvements to technology.

AT&T, instead, proposed establishing a base rate for specific VRS services for three years and making yearly adjustments for inflation and outside costs, which, they said, would encourage providers to become more efficient. NAD, TDI, and other consumer groups urged the FCC to consider concerns of the joint commenters in rate setting, price caps, and other related matters.

On Jan. 9, 2007, a letter was filed with the FCC by seven VRS providers regarding the Telecommunications Relay Service (TRS ) rate methodology issue. The letter describes the unity among VRS providers on rate methodology. The VRS providers agree on virtually everything, except what the initial rate should be. The Joint Commenters—the seven providers who filed jointly–have suggested using the existing rate of $6.644, while Verizon has suggested a higher rate of $7.01.

Both proposals would replace the current rate formula with a model that makes automatic adjustments to an initial VRS rate. The rate would be adjusted yearly for inflation and costs beyond the control of providers, with the formula in place for three years. Both proposals aim to encourage provider efficiency, enhance predictability, and simplify the rate setting process.

Summary of Last Spring's FCC Filings

On Apr. 28, 2006, National Association of the Deaf (NAD), Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), and other consumer groups that serve the Deaf and hard-of-hearing asked the FCC to ensure reimbursement rates for Telecommunications Relay Services (TRS) meet the FCC’s obligations under the Americans with Disabilities Act (ADA). The filing said these obligations included services and outreach to those who do not yet have access to all forms of TRS.

On May 17, 2006, Speech to Speech founder Bob Segalman reminded the FCC that "The ADA and the Commissions' rules require outreach and education for all forms of TRS, including STS, VRS and IP Relay." He urged the FCC to set a reimbursement rate that encourages more outreach, calling it "essential to fostering increased awareness, quality of service, and increased access to services available nationwide."