NATIONAL EXCHANGE CARRIER ASSOCATION SUBMITS PAYMENT FORMULAS AND FUNDING REQUIREMENT FOR THE INTERSTATE TELECOMMUNICATIONS RELAY SERVICES FUND FOR THE JULY 2011 THROUGH JUNE 2012 FUND YEAR
Federal Communications Commission ion
445 12th St., S.W.
News Media Information 202 / 418-0500
Washington, D.C. 20554
Released: May 4, 2011
NATIONAL EXCHANGE CARRIER ASSOCATION SUBMITS PAYMENT FORMULAS AND
FUNDING REQUIREMENT FOR THE INTERSTATE TELECOMMUNICATIONS RELAY
SERVICES FUND FOR THE JULY 2011 THROUGH JUNE 2012 FUND YEAR
CG Docket No. 03-123
Comments: May 18, 2011
Reply Comments: May 25, 2011On April 29, 2011, the National Exchange Carrier Association (NECA), the Interstate
Telecommunications Relay Services (TRS) Fund (Fund) administrator through June 30, 2011, submitted
Fund payment formulas for the period July 1, 2011, through June 30, 2012 for all forms of TRS with the
exception of video relay service (VRS).1 NECA also submitted the Fund size estimate for the same
period. NECA's submission fulfills the Fund administrator's requirement, pursuant to 47 C.F.R.
64.604(c)(5)(iii)(H), to file TRS payment formulas and revenue requirements with the Commission by
May 1 of each year, to be effective the following July 1.
On April 8, 2011, the Consumer and Governmental Affairs Bureau (Bureau) waived NECA's
obligation to file proposed rates for VRS, as well as VRS revenue requirements, for the 2011-12 Fund
year. 2 Subsequently, the Commission released a Notice of Proposed Rulemaking in which it, among
other things, sought comment on the rates and compensation for VRS for the 2011-12 Fund year, and
sought further comment on VRS market structure and VRS compensation proposals raised in a 2010
Notice of Inquiry.3 In the 2011 VRS Rates NPRM , the Commission also tentatively concluded that in the
event it is unable to fully resolve VRS compensation structure issues prior to the beginning of the 2011-
12 Fund year, extending the current interim rates and compensation structure would provide the best
means to ensure stability and certainty for VRS in the interim while the Commission continues to
evaluate the appropriate market structure and compensation methods for VRS.4
1 Telecommunications Services for Individuals with Hearing and Speech Disabilities, and the Americans with
Disabilities Act of 1990, Interstate Telecommunications Relay Services Fund Payment Formula and Fund Size
Estimate (filed April 29, 2011) (2011 TRS Rate Filing).
2 See Structure and Practices of the Video Relay Service Program; Telecommunications Relay Services and Speech-
to-Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket Nos. 10-51 and 03-123, Order,
DA 11-655 (CGB 2011) (VRS Rates Filing Order). Therefore, this year's Fund administrator filing does not contain
proposed rates for VRS; it does, however, contain an estimated VRS revenue requirement.
3 Structure and Practices of the Video Relay Service Program, CG Docket No. 10-51, Notice of Inquiry, 25 FCC
Rcd 8597 (2010) (2010 VRS NOI).
4 See Structure and Practices of the Video Relay Service Program; Telecommunications Relay Services and Speech-
to-Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket Nos. 10-51 and 03-123, Notice
NECA now proposes new per minute compensation rates for all forms of TRS except VRS based
on the rate calculation methodologies established in the 2007 TRS Rate Methodology Order as follows:5
$1.8502 for interstate traditional TRS;6 $1.8502 for interstate Speech-to-Speech (STS);7 $1.7396 for
interstate captioned telephone service (CTS) and interstate and intrastate Internet Protocol (IP) captioned
telephone service (IP CTS);8 and $1.2920 for interstate and intrastate IP Relay.9
Although NECA was not required to file proposed VRS rates and revenue requirements,10 the
Fund must include an estimate of VRS revenue requirements to ensure that the Fund administrator
collects sufficient revenues to cover all TRS for the 2011-12 Fund year. NECA therefore used the
following 2010-11 Fund year VRS rates for the 2011-12 Fund size estimate: $6.2390 for the first 50,000
monthly minutes, $6.2335 for monthly minutes between 50,001 and 500,000, and $5.0668 for minutes
above 500,000.11 Based on the new proposed rates for TRS, STS, CTS, IP CTS, and IP Relay and the
current VRS rates, and projected Fund administration expenses, NECA proposes a carrier contribution
factor of 0.01056, and a funding requirement of $739.3 million.12 The Bureau seeks comment on
NECA's proposed compensation rates for TRS, STS, CTS, IP CTS, and IP Relay, as well as the proposed
carrier contribution factor and funding requirement for the period of July 1, 2011, through June 30, 2012.
Pursuant to Sections 1.415 and 1.419 of the Commission's rules, 47 C.F.R. 1.415 and 1.419,
interested parties may file comments on or before
May 18, 2011, and reply comments on or before
filing paper copies. Comments may be filed electronically using the Internet by accessing the ECFS:
http://fjallfoss.fcc.gov/ecfs2/. Filers should follow the instructions provided on the website for submitting
of Proposed Rulemaking, FCC 11-62, 1, 5 (rel. Apr. 15, 2011) (2011 VRS Rates NPRM). See also generally 2010
5 See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech
Disabilities, CG Docket No. 03-123, Report and Order, and Declaratory Ruling, 22 FCC Rcd 20140 (Nov. 19, 2007)
(2007 TRS Rate Methodology Order).
6 The Commission adopted the Multistate Average Rate Structure (MARS) plan to calculate the annual interstate
traditional TRS rate. See 2007 TRS Rate Methodology Order, 22 FCC Rcd at 20149-57, paras. 16-35; see also 2011
TRS Rate Filing at 7-10 and Exh. 1-1.
7 The traditional TRS MARS rate also applies to interstate STS. See 2007 TRS Rate Methodology Order, 22 FCC
Rcd 20140 at 20156, para. 34. Consistent with the 2007 TRS Rate Methodology Order, however, NECA's proposed
STS rate includes an additional per-minute amount of $1.131 to be used for STS outreach. See 2007 TRS Rate
Methodology Order, 22 FCC Rcd at 20165, para. 57; see also 2011 TRS Rate Filing at 9-11 and Exh. 2.
8 The Commission also adopted the MARS Plan for interstate CTS and interstate and intrastate IP CTS. See 2007
TRS Rate Methodology Order; 22 FCC Rcd at 20157-58, paras. 36-38; see also 2011 TRS Rate Filing at 7-9, 11-12
and Exh. 1-2.
9 For interstate and intrastate IP Relay, the Commission adopted a price cap methodology. See 2007 TRS Rate
Methodology Order, 22 FCC Rcd at 20158-60, paras. 39-46; see also 2011 TRS Rate Filing at 12-14.
10 See note 2, supra.
11 2011 TRS Rate Filing at 14-15. We note that use of the current interim VRS rates to estimate the 2011-12 Fund
size is consistent with the Commission's tentative conclusion in the 2011 VRS Rates NPRM that extending the
current rates would provide the best means to ensure stability and certainty for VRS until final rules are
implemented. See 2011 VRS Rates NPRM at 1, 5.
12 See 2011 TRS Rate Filing at 19 and Exh. 2.
comments. In completing the transmittal screen, commenters should include their full name and U.S. Postal
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CG Docket No. 03-123.
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A copy of this document and any subsequently filed documents in this matter will be available during
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