TRS Fund administrator proposes compensation rates and funding size
Federal Communications Commission ion
445 12th St., S.W.
News Media Information 202 / 418-0500
Washington, D.C. 20554
Released: May 2, 2012
ROLKA LOUBE SALTZER ASSOCIATES SUBMITS PAYMENT FORMULAS AND FUNDING
REQUIREMENT FOR THE INTERSTATE TELECOMMUNICATIONS RELAY SERVICES
FUND FOR THE JULY 2012 THROUGH JUNE 2013 FUND YEAR
CG Docket No. 03-123
CG Docket No. 10-51
Comments: May 16, 2012
Reply Comments: May 23, 2012On May 1, 2012, Rolka Loube Saltzer Associates (RLSA), the Interstate Telecommunications
Relay Services (TRS) Fund (Fund) administrator, submitted Fund payment formulas for the period July 1,
2012, through June 30, 2013 for all forms of TRS with the exception of video relay service (VRS).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 as follows:2
$2.0304 for interstate traditional TRS;3 $3.1614 for interstate Speech-to-Speech (STS);4 $1.7730 for
1 Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech
Disabilities, Interstate Telecommunications Relay Services Fund Payment Formula and Fund Size Estimate (filed
May 1, 2012) (2012 TRS Rate Filing). On April 30, 2012, the Consumer and Governmental Affairs Bureau waived
RLSA’s obligation to file proposed rates for VRS, as well as VRS revenue requirements, for the 2012-13 Fund year,
pending further guidance. 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 12-687 (CGB 2012). As indicated in the 2011 TRS Rate Order for VRS, we anticipate
that the current interim rates will remain in place pending the completion of the current proceeding on reforming the
structure and practices in the VRS market. Telecommunications Relay Services and Speech-to-Speech Services for
Individuals with Hearing and Speech Disabilities; Structure and Practices of the Video Relay Service Program, CG
Docket Nos. 03-123 and 10-51, Order, 26 FCC Rcd 9972, 9980-81, ¶23 (2011) (2011 TRS Rate Order) (“We adopt
the current interim rates and compensation structure for VRS to be effective until the Commission completes its
review of the compensation method and market structure for VRS”).
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 (Nov. 19, 2007)
(2007 TRS Rate Methodology Order).
3 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, ¶¶ 16-35; see also 2012
TRS Rate Filing at 10 and Exh. 1-1.
interstate captioned telephone service (CTS) and interstate and intrastate Internet Protocol (IP) captioned
telephone service (IP CTS);5 and $1.2860 for interstate and intrastate IP Relay.6 In light of the pending
VRS Reform proceeding,7 the Commission anticipates continuing to extend the current VRS rates of $
6.2390 for Tier I, $6.2335 for Tier II, and $5.0668 for Tier III, until rules are adopted to reform the VRS
Although RLSA was not required to file proposed VRS rates and revenue requirements,8 an
estimate of VRS revenue requirements must be included to ensure that the Fund administrator collects
sufficient revenues to cover all TRS for the 2012-13 Fund year. RLSA therefore used the following VRS
rates (applicable to the 2010-11 and the 2011-12 Fund years) for the 2012-13 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 500,000.9 Based on RLSA’s proposed new rates for TRS, STS, CTS, IP
CTS, and IP Relay; an extension of the effectiveness of current VRS rates; and projected Fund
administration expenses, RLSA proposes a carrier contribution factor of 0.01053, and a funding
requirement of $711.4 million.10 The Consumer and Governmental Affairs Bureau seeks comment on
RLSA’s proposed compensation rates, as well as the proposed carrier contribution factor, and funding
requirement for the period of July 1, 2012 through June 30, 2013. The carrier contribution factor and
funding requirement will be revised if, within the next year, the Commission makes a determination that
changes the current VRS rates.
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 16, 2012, 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
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. 10-51.
4 The traditional TRS MARS 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 $1.131 to be used for STS outreach. See 2007 TRS Rate
Methodology Order, 22 FCC Rcd at 20165, ¶ 57; see also 2012 TRS Rate Filing at 11 and Exh. 1-1.
5 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, ¶¶ 36-38; see also 2012 TRS Rate Filing at 12 and Exh. 1-
6 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, ¶¶ 39-46; see also 2012 TRS Rate Filing at 14 and Exh. 1-3.
7 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).
8 See note 1, supra.
9 2012 TRS Rate Filing at 15. As indicated above, see n. 1, supra, the Commission anticipates that the current
interim VRS rates will remain effective pending completion of the Commission’s review of the compensation
method and market structure for VRS. The continued use of these rates to estimate the 2012-13 Fund size is
consistent with the Commission’s conclusion in the 2011 TRS Rate Order that extending the current rates would
provide the best means to ensure certainty and stability for VRS until final rules are implemented. See 2011 TRS
Rate Order, 26 FCC Rcd 9972, 9980-81, ¶ 23.
10 See 2012 TRS Rate Filing at 20 and Exh. 2.
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 firstname.lastname@example.org. 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,
www.bcpiweb.com, or by calling 1-800-378-3160. These documents may also be found by searching ECFS
CG Docket No. 03-123 and/or CG Docket No. 10-51into 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 email@example.com or call the Consumer and Governmental 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: http://www.fcc.gov/cgb/dro/trs.html.
For further information, please contact Diane Mason at (202) 418-7126 (voice) or by e-mail at
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