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PN on the Proposed Funding for Relay Service for the 2013-14 Period

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Released: May 17, 2013


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 13-1137

Released: May 17, 2013




CG Docket No. 03-123

CG Docket No. 10-51

Comments: May 31, 2013

Reply Comments: June 7, 2013

On May 1, 2013, Rolka Loube Saltzer Associates (RLSA), the Interstate Telecommunications
Relay Services (TRS) Fund (Fund) administrator, submitted Fund payment formulas for the period July 1,
2013 through June 30, 2014 for all forms of TRS.1 RLSA also submitted the TRS funding requirement
estimate and proposed carrier contribution factor for the same period. RLSA’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.
RLSA 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,2 as follows:
$2.1647 for interstate traditional TRS;3 $3.2957 for interstate Speech-to-Speech (STS);4 $1.7877 for

1 See Rolka Loube Saltzer Associates LLC, Interstate Telecommunications Relay Services Fund Payment
Formula and Fund Size Estimate, CG Docket Nos. 03-123 and 10-51, (filed May 1, 2013) (2013 TRS Rate
2 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 (2007) (2007 TRS Rate Methodology Order).
3 2013 TRS Rate Filing at 11-12, Exh. 1-1. The Commission adopted the Multistate Average Rate
Structure (MARS) plan methodology for calculation of the annual interstate traditional TRS rate. See
2007 TRS Rate Methodology Order
, 22 FCC Rcd at 20149-57, ¶¶ 16-35. The current compensation rate
for interstate traditional TRS is $2.0304 per minute.
4 2013 TRS Rate Filing at 12, Exh. 1-1. The traditional TRS rate also applies to interstate STS. See 2007
TRS Rate Methodology Order
, 22 FCC Rcd 20140 at 20156, ¶ 34. Consistent with the 2007 TRS Rate
Methodology Order
, however, RLSA’s proposed STS rate includes an additional per-minute amount of

interstate captioned telephone service (CTS) and interstate and intrastate Internet Protocol (IP) captioned
telephone service (IP CTS);5 and $1.0391 for interstate and intrastate IP Relay.6
For the IP Relay compensation rate, which is subject to a price cap methodology, the 2013-14
Fund year will begin a new three-year price cap period.7 Therefore, the administrator proposes a new IP
Relay base rate of $1.0391 per minute, reduced by $0.2464 from the current rate of $1.2855 per minute.
Noting that the proposed IP Relay rate is above the weighted average per-minute cost,8 the administrator
explains that the proposed rate “considers the cost differentials among the efficient providers of IP-Relay
service and allows the efficient providers to earn positive profits on a prospective basis” while
“[i]nefficient providers are provided the incentive to reduce their costs or incur losses.”9 The
Commission also proposes an efficiency factor of 6%, to be used as part of the IP Relay price cap
calculation to determine adjustments in the IP Relay rate for subsequent years of the three-year price cap
Regarding VRS compensation rates, the Commission is currently considering whether to modify
the current interim rates.11 Pending further action by the Commission, the administrator has submitted
Fund size estimates for Fund year 2013-14 that assume a further extension of the current rates, which are:
$6.2390 for Tier I (applicable to each provider’s first 50,000 monthly minutes), $6.2335 for Tier II
(applicable to monthly minutes between 50,001 and 500,000), and $5.0688 for Tier III (applicable to
monthly minutes over 500,000).
Based on RLSA’s proposed new compensation rates for TRS, STS, CTS, IP CTS, and IP Relay,
an assumed extension of the current video relay service (VRS) compensation rates, and projected Fund
administration expenses, RLSA’s 2013 Rate Filing proposes a funding requirement of $1,543.6 million
and a carrier contribution factor of 0.0233.12

$1.131 to be used for STS outreach. See 2007 TRS Rate Methodology Order, 22 FCC Rcd at 20165, ¶ 57.
The current STS compensation rate is $3.1614 per minute.
5 2013 TRS Rate Filing at 13, Exhs. 1-2, 1-4. The Commission also adopted the MARS plan
methodology for calculation of the rates for interstate CTS and interstate and intrastate IP CTS. See 2007
TRS Rate Methodology Order
, 22 FCC Rcd at 20157-58, ¶¶ 36-38. The current compensation rate for
these services is $1.773 per minute.
6 2013 TRS Rate Filing at 14-17, Exh. 1-3. 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, ¶¶
7 2013 TRS Rate Filing at 15.
8 The administrator calculates that the average projected cost per minute for IP Relay reported by
providers for 2013-14 is $0.8486. 2013 TRS Rate Filing at 16, Exh. 1-3.
9 2013 TRS Rate Filing at 16.
10 2013 TRS Rate Filing at 16-17.
11 See Structure and Practices of the Video Relay Service Program, CG Docket No. 10-51, Further Notice
of Proposed Rulemaking, 26 FCC Rcd 17367 (2011) (2011 VRS Reform FNPRM); Additional Comment
Sought on Structure and Practices of the Video Relay Service (VRS) Program and on Proposed VRS
Compensation Rates
, Public Notice, CG Docket Nos. 03-123 & 10-51, 27 FCC Rcd 12959 (2012) (VRS
Structure and Rates PN
12 See 2013 TRS Rate Filing at 34, Exh. 2.

CGB seeks comment on RLSA’s proposed carrier contribution factor and funding requirement, as
well as the proposed compensation rates, for the period of July 1, 2013 through June 30, 2014.13 In this
regard, comment is invited on the various IP CTS demand projections submitted by RLSA. Specifically,
CGB seeks comment on whether RLSA’s recommended demand projection (409 million minutes) is the
most appropriate one to use to calculate the funding requirement for the 2013-2014 TRS Fund year for IP
CTS.14 We also seek comment on how RLSA’s demand projections, which do not take into account the
effects of an emergency Order and Notice of Proposed Rulemaking that were recently adopted by the
Commission to reform the IP CTS program,15 may be affected by the adoption of those rules. In addition,
in light of the Commission’s ongoing review of comments received in response to a recent Public Notice
seeking comment on the IP CTS rate methodology, CGB proposes to adopt RLSA’s recommended IP
CTS rate as an interim rate and seeks comment on this proposal.16
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 31, 2013

, and reply comments on or before

7, 2013.

Comments may be filed using the Commission’s Electronic Comment Filing System (ECFS) or
by filing paper copies. Comments may be filed electronically using the Internet by accessing the ECFS: Filers should follow the instructions provided on the website for submitting
comments. In completing the transmittal screen, commenters should include their full name and U.S.
Postal Service mailing address. All filings must reference

CG Docket No. 03-123 and CG Docket No.

Parties who choose to file by paper must file an original and one copy of each filing. In addition,
parties must send one copy to the Commission’s duplicating contractor, Best Copy and Printing, Inc., 445
12th Street, SW, Washington, DC 20554, or via email to Filings can be sent by hand
or messenger delivery, by commercial overnight courier, or by first-class or overnight U.S. Postal Service
mail. All filings must be addressed to the Commission’s Secretary, Office of the Secretary, Federal
Communications Commission. All hand-delivered or messenger-delivered paper filings for the
Commission’s Secretary must be delivered to FCC Headquarters at 445 12th Street. SW, Room TW-A325,
Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries must be held
together with rubber bands or fasteners. Any envelopes must be disposed of before entering the building.
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must be sent
to 9300 East Hampton Drive, Capitol Heights, MD 20743. U.S. Postal Service first-class, Express, and
Priority mail must be addressed to 445 12th Street, SW, Washington DC 20554.
A copy of this document and any subsequently filed documents in this matter will be available
during regular business hours at the FCC Reference Center, Portals II, 445 12th Street, SW, Room CY-
A257, Washington, D.C. 20554, (202) 418-0270. This document and any subsequently filed documents
in this matter may also be purchased from the Commission’s duplicating contractor at its website,, or by calling 1-800-378-3160. These documents may also be found by searching
ECFS (insert

CG Docket No. 03-123 and/or CG Docket No. 10-51

into the proceeding block).
To request materials in accessible formats for people with disabilities (Braille, large print,
electronic files, audio format), send an e-mail to or call the Consumer and Governmental

13 The carrier contribution factor and funding requirement may be revised if the Commission makes
determinations that change the current VRS rates or IP CTS rates.
14 See 2013 TRS Rate Filing at 24-29.
15 Misuse of Internet Protocol (IP) Captioned Telephone Service; Telecommunications Relay Services and
Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities
, CG Dockets 13-24 &
03-123, Order and Notice of Proposed Rulemaking, 28 FCC Rcd 703 (2013).
16 See Request for Comment on Petition for Rulemaking filed by Sorenson Communications, Inc.
Regarding Cost Recovery Methodology for Internet Protocol Captioned Telephone Service
, CG Docket
No. 13-24 and 03-123, Public Notice, 28 FCC Rcd 2256 (2013).

Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (TTY). This document can also be
downloaded in Word and Portable Document Format (PDF) at:
For further information, please contact Diane Mason at (202) 418-7126 (voice) or by e-mail at

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