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TRS Numbering Directory Access Waiver

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Released: June 13, 2012

Federal Communications Commission

DA 12-918

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matters of
)
)

Telecommunications Relay Services and
)
CG Docket No. 03-123
Speech-to-Speech Services for
)
Individuals with Hearing and Speech Disabilities
)
)

Structure and Practices of the Video Relay Service
)
CG Docket No. 10-51
Program
)
)

E911 Requirements for IP-Enabled Service
)
WC Docket No. 05-196
Providers
)
)

Internet-Based Telecommunications Relay Service
)
WC Docket No. 10-191
Numbering
)
)

ORDER

Adopted: June 13, 2012

Released: June 13, 2012

By the Acting Chief, Consumer and Governmental Affairs Bureau and Chief, Wireline Competition
Bureau:
1.
In this Order, the Consumer and Governmental Affairs Bureau and the Wireline
Competition Bureau (the Bureaus) sua sponte grant a waiver of Section 64.613(a)(4) of the Commission’s
rules,1 for the limited purpose of allowing the current Telecommunications Relay Services (TRS) Fund
Administrator, Rolka Loube Saltzer Associates (RLSA), “read-only” access to the TRS Numbering
Directory, administered by the TRS Numbering Administrator.2 Section 64.613(a)(4) currently allows
only iTRS providers and the TRS Numbering Administrator to access the TRS Numbering Directory.
This waiver will ensure that, in carrying out its Fund administration obligations, the TRS Fund
Administrator can effectively review call detail records (CDRs) and other information submitted by TRS
providers seeking reimbursement from the TRS Fund.
2.
Background. As TRS Fund Administrator, RLSA disburses payment to TRS providers,
on a per-minute basis, for relay services provided in accordance with the Commission’s rules.3 To
support their monthly requests for payment, TRS providers must provide call data to RLSA, including the
originating and terminating telephone numbers and/or IP addresses for each call for which compensation
is sought.4 RLSA reviews the call data and other information submitted by the provider to determine
whether the calls are compensable under the Commission’s rules.5


1 47 C.F.R. § 64.613(a)(4).
2 The current TRS Numbering Administrator is Neustar, Inc.
3 See 47 C.F.R. §§ 64.604(c)(5)(iii)(D), (L).
4 See 47 C.F.R. § 64.604(c)(5)(iii)(D)(2).
5 See 47 C.F.R. § 64.604(c)(5)(iii)(L).

Federal Communications Commission

DA 12-918

3.
To help prevent misuse of the Internet-based TRS (iTRS) program,6 it is important that
the TRS Fund Administrator have access to the data necessary to ensure that calls submitted for payment
are legitimate calls from registered users. Comparing telephone numbers and IP addresses in the call data
submitted by iTRS providers with corresponding data in the TRS Numbering Directory7 is often a
necessary step in confirming that the calls for which payments are being sought are legitimate relay calls.
4.
Discussion. The Commission may waive any provision of its rules on its own motion if
good cause is shown.8 In this instance, the Bureaus have determined that there is good cause to waive
Section 64.613(a)(4). As the entity principally tasked with ensuring that payments are disbursed only for
compensable calls, the TRS Fund Administrator must be able to assess and analyze the accuracy and
completeness of call data submitted with claims for payment. RLSA can more effectively assess and
analyze the accuracy and completeness of call data if it is able to consult the TRS Numbering Directory in
order to verify the validity of the telephone numbers and IP addresses provided in the call data.
5.
Moreover, we find that a waiver of Section 64.613(a)(4) for the purpose of facilitating
RLSA’s call data analysis does not conflict with the intent of the rule to ensure the confidentiality and
security of data in the TRS Numbering Directory.9 In addition to having a contractual obligation to
secure confidential data, such as telephone numbers and other user-related information,10 RLSA, as the
TRS Administrator, is subject to the Commission’s rule requiring confidential treatment of data obtained
from other FCC administrators.11 Thus, the grant of this waiver does not undermine the rule’s purposes.
6.
Consistent with our finding that RLSA is better able to perform a complete analysis of
call data with read-only access to the TRS Numbering Directory administered by the TRS Numbering
Administrator, we conclude that this waiver shall be in effect for the duration of the Commission’s TRS-
related contract with RLSA, including any renewals or extensions thereof, and shall expire upon the
termination of the contract. Tying the waiver to the duration of the contract with RLSA will ensure an


6 See, e.g., Consumer & Governmental Affairs Bureau Seeks to Refresh the Record Regarding Misuse of Internet
Protocol Relay Service
, CG Docket Nos. 12-38, 03-123, Public Notice, 27 FCC Rcd 1569 (CGB 2012).
7 The TRS Numbering Directory contains 10-digit telephone numbers that have been assigned to users of two types
of iTRS: Video Relay Service (VRS) and Internet Protocol Relay Service (IP Relay). In addition, the directory
contains Uniform Resource Identifiers (URIs) associated with those telephone numbers. For each VRS user’s
NANP telephone number, the URI contains the IP address of the user’s device. For each IP Relay user’s NANP
telephone number, the URI contains a text messaging account user name and domain name. See 47 C.F.R. §
64.613(a)(2).
8 See 47 C.F.R. § 1.3; Northeast Cellular Telephone Co. v. F.C.C., 897 F2d 1164, 1166 (D.C. Cir 1990) (“Northeast
Cellular“) (“[A] waiver is appropriate only if special circumstances warrant a deviation from the general rule and
such deviation will serve the public interest,” citing WAIT Radio v. F.C.C., 418 F2d 1153, 1157-59 (DC Cir 1969)).
9 See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech
Disabilities; E911 Requirements for IP-Enabled Service Providers
, CG Docket No. 03-123, WC Docket No. 05-
196, Report and Order and Further Notice of Proposed Rulemaking, 23 FCC Rcd 11591, 11617, ¶ 67 (2008).
10 The user-related information contained in the TRS Numbering Directory is described in note 7, supra. The TRS
Numbering Directory does not contain other user information, such as the names of TRS users or their registered
geographic locations.
11 See 47 C.F.R. § 64.604(c)(5)(iii)(I) (“The TRS Fund administrator shall keep confidential all data obtained from
other administrators.”). The Commission, of course, retains the ability to access such data for administration and
enforcement of the TRS rules. See 47 C.F.R. §§ 64.604(c)(5)(iii)(H), (I).
2

Federal Communications Commission

DA 12-918

appropriate limitation on the duration of the waiver.
7.
Accordingly, IT IS ORDERED, pursuant to the authority contained in sections 1, 4(i),
4(j), 225, and 251(e), of the Communications Act of 1934, as amended, 47 U.S.C. §§ 151, 154(i), 154(j),
225, and 251(e), and sections 0.91, 0.141, 0.291, 0.361, and 1.3 of the Commission’s rules, 47 C.F.R. §§
0.91, 0.141, 0.291, 0.361, 1.3, that section 64.613(a)(4) of the Commission’s rules is WAIVED as
provided herein.
8.
To request materials in accessible formats (such as Braille, large print, electronic files, or
audio format), send an e-mail to fcc504@fcc.gov or call the Consumer and Governmental Affairs Bureau
at (202) 418-0530 (voice) or (202) 418-0432 (TTY). This Order may be downloaded in Word and
Portable Document Formats (PDF) at http://www.fcc.gov/cgb/dro/trs.html#orders.
FEDERAL COMMUNICATIONS COMMISSION
Kris Anne Monteith
Acting Chief
Consumer and Governmental Affairs Bureau
Sharon E. Gillett
Chief
Wireline Competition Bureau
3

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