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Summary of Declaratory Ruling on IP Captioned Telephone


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February 21, 2007


            Summary of Declaratory Ruling on Internet Protocol Captioned Telephone


            On January 11, 2007, the FCC released a Declaratory Ruling approving Internet Protocol (IP) captioned telephone service (IP CTS) as a type of telecommunications relay service approved for compensation from the Interstate TRS fund.  The ruling, which was published in the Federal Register on February 14, 2007 (72 Fed. Reg. 6960), becomes effective on April 16, 2007.  This Order was issued in response to a petition filed by numerous consumer groups on October 31, 2005, that had asked the FCC to initiate a rulemaking to (1) mandate captioned telephone relay service and (2) approve IP captioned telephone service.  After that petition was filed, Ultratec filed a request for expedited clarification on whether IP captioned telephone was a form of TRS compensable from the interstate fund, so that the FCC would not go through a long rulemaking to decide this issue.  The original petitioners (the consumers) then amended their rulemaking petition to support that request.  While this Declaratory Ruling now provides an expedited decision approving IP CTS, it does not address whether it or CTS over the public switched network should be mandatory.  The FCC states that it will consider that “at a future date.”   


            The FCC’s Order acknowledges the many benefits of IP CTS, including its portability, lower cost and easier availability, and greater accessibility for persons with multiple disabilities, noting that these represent an “important step toward functional equivalency.”  It cites back to language in its original captioned telephone declaratory ruling that broadly interpreted the phrase “telephone transmission service” to include any transmission service to the extent it provides the ability of an individual with a hearing or speech disability to communicate by wire or radio with a hearing individual that is functionally equivalent to the ability of people without disabilities to do so.  In approving the new service, the FCC goes on to explain that IP CTS merely borrows from both the IP relay and captioned telephone services that the FCC has previously approved:  the user is connected to the relay provider via the Internet, and the provider enables people to speak to the other party and simultaneously listen to what the other party is saying and read captions of what that individual is saying. 


            The main points of the Declaratory Ruling are:


  • Definition of IP CTS.  A service will be considered to be IP CTS if “it allows the user to simultaneously listen to, and read the text of, what the other party in a telephone conversation has said, and the connection carrying the captions between the service and the user is via the Internet rather than the PSTN.” 
  • Transmission Speed.  The captions must be delivered via the IP network to the user “fast enough so that they keep up with the speed of the other party’s speech.”  The FCC has declined to adopt a quantitative speed beyond the 60 words per minute that is already required of text-based TRS.  However, the Order says that if the captions are not keeping up with the speech (acknowledging that a short delay is inevitable), at some point the provider will no longer be offering relay service and the call will not be compensable.
  • Characteristics of IP CTS.
    • The service should be provided “in a way that is automated and invisible to both parties to the call.”  In the text, the FCC states that, like PSTN-based captioned telephone service, IP CTS should allow the consumer to directly dial the called party and automatically connect the CA to the calling party to deliver the captions.  It explains in a footnote, however, that it is not requiring all captioned telephone calls to be set up and handled in this manner.
    • While captioned telephone services currently use voice recognition technology without any typing, providers are not precluded from generating captions through the use of typing or other means, so long as the “captions are generated quickly to appear on the consumer’s device nearly simultaneously with the speech.”  The FCC explains that “the principle characteristic” of IP CTS is that “the consumer nearly simultaneously receives both the actual voice of the other party to the call and text of what the party is saying, not that the captions are generated by voice recognition technology or any other particular way.”
    • IP CTS may be offered as a one or two line service.
  • Compensation.  All IP captioned telephone calls will be reimbursed through the Interstate TRS Fund on an interim basis. The compensation rate will be the same as it is for regular IP relay services.  Providers of IP CTS are to submit their costs and projected minutes of use data to the Interstate TRS Fund Administrator (NECA), but this data shall not be included in determining the IP relay compensation rate.  This is because there is presently only one provider of this service, the same situation as currently exists for PSTN-based captioned telephone.  The FCC will revisit the cost methodology, including jurisdictional separation of costs, at a future date.  IP CTS providers may become eligible for compensation from the Fund by
    • being accepted into a certified state TRS program
    • subcontracting with an entity that is part of a certified state program, or
    • by seeking Commission certification.


  • Licensing.  The FCC’s grant of approval for IP CTS is conditioned on Ultratec’s representation that “it will continue to license its captioned telephone technologies, including technologies relating to IP CTS, at reasonable rates.”
  • Mandatory Minimum Standards.  Because the FCC is not mandating IP CTS, it need not be offered 24/7 at this time. Nevertheless, providers must be in compliance with all other mandatory minimum standards that are not waived.  IP CTS has the same waivers as those presently granted for IP relay.  Generally, the waivers for this new service are divided into two categories – (1) permanent waivers/waived standards that do not apply to captioned telephone and (2) temporary waivers that expire on January 1, 2008:
    • Permanent Waivers or Standards that are Not Applicable:  CA gender preference, TTY communication in the ASCII or Baudot formats, outbound 711 dialing, choice of interexchange carrier, CA competency in typewritten ASL, CA oral-to-type tests, and sequential calls.
    • Temporary Waivers:  call release, speech-to-speech services, VCO and HCO, emergency call handling, pay-per-call (900) services, three-way calling, and speed dialing.  IP CTS providers must file annual reports on these waivers by April 1 of each year, beginning April 1, 2008


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