To: Consumer Contact List
From: Karen Peltz Strauss
Re: Consumer Contact List: VRS Interoperability; IP relay/VRS Misuse; Snap Certification; NECA rates
Date: May 15, 2006

1. VRS Interoperability Order. On May 10, 2006, the FCC released an order directing all VRS providers to allow their customers to make and receive VRS calls through any VRS provider. The order was accompanied by a further notice of proposed rulemaking (FNPRM) on uniform numbering and VRS protocols. A summary of the order and FNPRM is attached.

TELECOMMUNICATIONS RELAY SERVICES AND SPEECH-TO-SPEECH SERVICES FOR INDIVIDUALS WITH HEARING AND SPEECH DISABILITIES. FCC declares VRS providers must provide interoperability with competing providers. Also asks for comment on how hearing callers can reach VRS providers and on whether speech internet protocols should be adopted for VRS equipment.
(Dkt No. 03-123). Action by: the Commission. Adopted: 05/03/2006 by
Declaratory Ruling. (FCC No. 06-57). CGB
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A1.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A2.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A3.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A4.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A5.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A1.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A2.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A3.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A4.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A5.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A1.txt>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A2.txt>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A3.txt>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A4.txt>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-57A5.txt>

2. IP Relay and VRS Misuse. The FCC has released an FNPRM seeking public comment on steps that it should take to curb harassing and fraudulent purchase calls that are conducted over IP relay services. The FNPRM also asks about actions needed to put an end to billing the Interstate Relay Fund for in-person interpreting and video remote interpreting. Neither of these types of interpreting situations are considered telephone calls and they should not billed as VRS. A summary of this order is attached.

TELECOMMUNICATIONS RELAY SERVICES AND SPEECH-TO-SPEECH SERVICES FOR INDIVIDUALS WITH HEARING AND SPEECH DISABILITIES; MISUSE OF INTERNET PROTOCOL (IP) RELAY SERVICE AND VIDEO RELAY SERVICE (VRS). The Commission addresses the misuse of the two Internet-based forms of Telecommunications Relay Service (TRS), Internet Protocol Relay Service and Video Relay Service, and seeks comment on possible changes to the TRS regulations to curtail their misuse. (Dkt No. 03-123). Action by: the Commission. Adopted: 05/03/2006 by FNPRM. (FCC No. 06-58). CGB
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-58A1.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-58A1.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-58A1.txt>

3. Snap Certification to Provide VRS. On December 12, 2005, the FCC adopted new rules that allows providers wishing to offer VRS or IP relay to seek certification directly from the FCC to do so. In order to receive certification, a provider must meet or exceed all operational technical and functional TRS standards in the FCC's TRS rules. It must also make available procedures and remedies for ensuring compliance with those rules. On January 25, 2006, Snap Telecommunications filed a certification application to become a VRS provider eligible for compensation from the Interstate TRS Fund. On May 8, 2006, the FCC issued a public notice approving this certification, but conditioning it upon Snap's ability to make its Internet protocol interoperable with videophone devices used by other VRS providers. Specifically, Snap VRS uses SIP protocol to send video transmissions over packet-switched networks, while other VRS providers currently use the H.323protocol. In order to receive compensation, Snap must comply with the FCC's new order requiring interoperability of VRS (see attached for a summary of that order) by making its protocol compatible with existing VRS protocols. .

RELEASED: 05/08/2006. NOTICE OF CERTIFICATION OF SNAP TELECOMMUNICATIONS, INC. AS A PROVIDER OF VIDEO RELAY SERVICE (VRS) ELIGIBLE FOR COMPENSATION FROM THE INTERSTATE TELECOMMUNICATIONS RELAY SERVICE (TRS) FUND. (Dkt No 03-123). (FCC No. 06-67). CGB. Contact: Gregory Hlibok at (866) 410-5787 x16757, email: Gregory.Hlibok@fcc.gov,
TTY: (202) 418-0431
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-67A1.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-67A1.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-67A1.txt>

4. New NECA Rates for TRS. On May 12, 2006, the FCC released a public notice announcing NECA's recent filing on the new rates for all types of TRS for the 2006-07 year. NECA has proposed reducing all rates since last year. Among other things, marketing costs, previously allowed, have now been excluded. The URL for the public notice is listed below.

Released: 05/12/2006. NATIONAL EXCHANGE CARRIER ASSOCIATION (NECA) SUBMITS THE PAYMENT FORMULA AND FUND SIZE ESTIMATE FOR INTERSTATE TELECOMMUNICATIONS RELAY SERVICES (TRS) FUND FOR THE JULY 2006 THROUGH JUNE 2007 FUND YEAR. (DA No. 06-1031). (Dkt No 03-123). Comments Due:
05/17/2006. Reply Comments Due: 05/24/2006. CGB. Contact: Dana Jackson at (202) 418-2247, email at Dana.Jackson@fcc.gov, TTY: (202) 418-7898
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-06-1031A1.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-06-1031A1.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-06-1031A1.txt>