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Three petitions released for public comment: Legal Interpreting on VRS, VRS Cost Recovery, and Sprint 900 Services

To: Consumer Contact List
Karen Peltz Strauss, RERC-TA
Re: 3 Petitions Released for Public Comment

Date: August 15,2003

1. CSD Petition on Legal Interpreting

Communications Services for the Deaf has petitioned the FCC to allow VRS providers to deny VRS calls involving depositions and other legal proceedings. CSD maintains that there are several conflicts in state and federal law, as well as ethical dilemmas for interpreters with respect to handling these calls. Specifically,many state interpreting statutes prohibit the use of interpreters who do not meet specific credentials for legal interpreting in their states; yet there is no way to certify that all VRS interpreters meet the legal credentials of all state interpreting laws. In addition, although, on the one hand, FCC minimum standards require call set-up to be as expeditious as possible, state and RID standards require that parties receive full explanations about the nature of the legal proceedings at issue before commencing the interpretation of those proceedings. The provision of such explanations will extend call set up time considerably.Additionally, althoughFCC minimum standards establish strict confidentiality requirements that prohibit communication assistants from divulging the content of their interpreted conversations,state and possibly federal laws may conflict with these confidentiality mandates by requiring these interpreters to testify as to the accuracy of their interpreted conversations.

Comments on the petition are due by September 15, 2003.

Replies are due by September 30, 2003.

Here is the URL, and the Public Notice is attached:

Released: 08/13/2003. COMMUNICATION SERVICES FOR THE DEAF (CSD)
PETITION FOR LIMITED WAIVER AND REQUEST FOR EXPEDITED RELIEF REGARDING THE PROVISION OF VIDEO RELAY SERVICES (VRS) FOR DEPOSITIONS AND OTHER LEGAL PROCEEDINGS. (DA No. 03-2644). (Dkt No 98-67). Comments Due: 09/15/2003. Reply Comments Due: 09/30/2003. CGB. Contact: (202)
418-0531, TTY: (202) 418-7365 or email: FCC504@fcc.gov
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-03-2644A1.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-03-2644A1.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-03-2644A1.txt>

2. Petitions for Reconsideration of the VRS Cost Recovery Order

On June 30, 2003. the Consumer & Governmental Affairs Bureau's June 30, 2003 Order rejected a proposed NECA per minute compensation rate of $14.023 for VRS, and established instead an interim VRS rate of $7.751. OnJuly 30, 2003, AT&T, Sprint, CSD, Hands On Video Relay Services, Inc., and Sorenson Media, Inc.filed Petitions seeking reconsideration of this Interim Order. The petitioners ask the Commission to approve the NECA rate (retroactive to July 1, 2003)because they do not believe the lower rate will be sufficient to reimburse them for the provision of VRS.

Oppositions to these petitions are due by August 26, 2003. Replies to these oppositions are due by September 5, 2003.

3. Sprint Petition on 900 Service.

FCC rules require the handling of pay-per-call (e.g. 900 calls) service through TRS. In addition, FCC rules require access to all TRS services via 711.Sprint has filed a petition stating that because 711 is toll free, it cannot be used to access 900 services. Instead, Sprint requests clarification that its use of a separate 900 number provided without charge will satisfy the TRS requirement to provide access to 900 services.

Comments are due by September 10, 2003

Reply comments are due bySeptember 25, 2003

Here is the URL and the PN is attached:

Released: 08/11/2003. SPRINT PETITION FOR DECLARATORY RULING REGARDING TRS

ACCESS TO 900 PAY-PER-CALL SERVICES VIA 711. (DA No. 03-2629). (Dkt No

98-67). Comments Due: 09/10/2003. Reply Comments Due: 09/25/2003. CGB.

Contact: Erica Myers at (202) 418-2429, TTY: (202) 418-0464, or email:

Erica.Myers@fcc.gov

<http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-03-2629A1.doc

<http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-03-2629A1.doc> >

<http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-03-2629A1.pdf

<http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-03-2629A1.pdf> >

<http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-03-2629A1.txt

<http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-03-2629A1.txt> >

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