Notice Of Conditional Grant Of Application For CSDVRS, LLC
Federal Communications Commission
News Media Information 202 / 418-0500445 12th St., S.W.
Washington, D.C. 20554
Released: September 18, 2012
NOTICE OF CONDITIONAL GRANT OF APPLICATION OF CSDVRS, LLC. FOR
RECERTIFICATION AS A PROVIDER OF VIDEO RELAY SERVICE ELIGIBLE FOR
COMPENSATION FROM THE INTERSTATE TELECOMMUNICATIONS RELAY SERVICES(TRS) FUND
CG DOCKET NO. 10-51By the Chief, Consumer and Governmental Affairs Bureau:
On June 15, 2012, CSDVRS, LLC (CSDVRS) filed an application1 for Commission
recertification2 as a provider of video relay service (VRS) that is eligible for compensation from the
Interstate TRS Fund (Fund).3 The Consumer and Governmental Affairs Bureau (Bureau) hereby grants
the CSDVRS Recertification Application on a conditional basis for a period of sixty (60) days, pending
confirmation of CSDVRS’s compliance with all applicable rules and orders. We note that we did not
specify time limits for prior conditional certifications granted as part of the initial implementation of the
certification rules. Based on our experience, however, we believe that a more incremental approach may
1 CSDVRS, LLC., Internet-based TRS Certification Application for Renewal by CSDVRS, LLC., CG Docket Nos.
03-123 & 10-51 (filed June 15, 2012, supplemented Aug. 27, 2012) (CSDVRS Recertification Application). See 47
C.F.R. § 64.606; Structure and Practices of the Video Relay Service Program, CG Docket No. 10-51, Second
Report and Order and Order, 26 FCC Rcd 10898 (2011) (iTRS Certification Order). In its application CSDVRS
refers to itself as ZVRS, its marketing brand name.
2 The Commission granted CSDVRS certification for the provision of VRS on September 21, 2007 which is in effect
for five years until September 21, 2012. See Notice of Certification of CSDVRS Telecommunications, Inc. as a
Provider of Video Relay Service (VRS) Eligible for Compensation from the Interstate Telecommunications Relay
Service (TRS) Fund, CG Docket No. 03-123, Public Notice, 22 FCC Rcd 17014 (2007).
3 The Communications Act of 1934, as amended, defines telecommunications relay services (TRS) as:
. . . telephone transmission services that provide the ability for an individual who is deaf, hard of
hearing, deaf-blind, or who has a speech disability to engage in communication by wire or radio
with one or more individuals, in a manner that is functionally equivalent to the ability of a hearing
individual who does not have a speech disability to communicate using voice communication
services by wire or radio.
47 U.S.C. § 225(a)(3) (as amended by the Twenty-First Century Communications and Video Accessibility Act of
2010 (CVAA), Pub. L. No. 111-260, § 103(b), 124 Stat. 2751, 2755 (2010); Pub. L. No. 111-265 (technical
amendments to CVAA)). VRS is a form of Internet-based TRS (iTRS) that uses a broadband Internet connection
between the VRS user and the communications assistant (CA) to enable a person using American Sign Language to
communicate over video with another party through a CA. During a VRS call, the CA relays the communications
between the two parties, signing what the other party says to the deaf or hard of hearing user and responding in
voice to the other party to the call. The Interstate TRS Fund compensates eligible providers of VRS and other forms
of interstate TRS for their reasonable costs of providing these services. See 47 C.F.R. § 64.604(c)(5)(iii).
be warranted in situations where we find additional time is necessary to assess an applicant’s compliance
with our rules. Granting conditional certification for 60 days here will avoid service disruptions as we
continue the evaluation necessary to determine whether it is appropriate to grant five year certification, or
even indefinite conditional certification to CSDVRS. Before granting further certification, we must
determine that CSDVRS is qualified to receive compensation from the Fund and that grant of such
additional certification would be consistent with the objective of preventing waste, fraud, and abuse to the
Fund, as embodied in our VRS rules and orders.
In the iTRS Certification Order released on July 28, 2011, the Commission amended its
requirements and processes for certifying iTRS providers as eligible for compensation from the Fund, to
ensure that iTRS providers receiving certification are qualified to provide iTRS in compliance with the
Commission’s rules, and to eliminate waste, fraud, and abuse through improved oversight of such
providers.4 These rules require that all iTRS providers obtain certification from the Commission to be
eligible to receive compensation from the Fund.5 They further require that all VRS applicants for
certification lease, license or own, as well as operate, essential facilities associated with iTRS call centers
and employ their own CAs to staff those centers on the date of their application for certification.6 Each
iTRS applicant for certification is also required to submit specific types of documentary evidence that
demonstrate its compliance with Commission rules, including those adopted in the VRS Practices R&O.7
On October 17, 2011, the Commission released the iTRS Certification Clarification Order,8 clarifying
certain aspects of the certification requirements adopted in the iTRS Certification Order, and modifying
section 64.606 of the Commission’s rules to lessen the burdens on applicants for certification associated
with the submission of certain documentation to the Commission.9
Based on our review of the CSDVRS Recertification Application, we grant conditional
certification to CSDVRS to provide VRS services for a period of sixty (60) days, to terminate on
November 20, 2012, unless such certification is extended for an additional period of time. To assist our
determination as to whether to extend certification, we reserve the right to conduct one or more on-site
inspections of CSDVRS’s facilities by designated personnel, and to request additional documentation
relating to CSDVRS’s provision of VRS.10 In the iTRS Certification Order, the Commission reserved the
right, after initial review of an application, to conditionally grant certification, subject to one or more
4 iTRS Certification Order, 26 FCC Rcd at 10899, ¶ 1. The measures adopted in the iTRS Certification Order were
part of the Commission’s ongoing and transitional efforts to reform the structure and practices of the VRS program,
and the certification processes by which this grant of conditional certification is awarded may be superseded or
modified by future Commission actions on VRS reform.
5 Id., ¶ 2.
7 See, e.g., 47 C.F.R. § 64.606(a); see also Structure and Practices of the Video Relay Service Program, Report and
Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 5545 (2011) (VRS Practices R&O).
8 Structure and Practices of the Video Relay Service Program, Sprint Nextel Corporation Expedited Petition for
Clarification, Sorenson Communications, Inc. Petition for Reconsideration of Two Aspects of the Certification
Order, AT&T Services, Inc. Petition for Reconsideration of AT&T, CG Docket No. 10-51, Memorandum Opinion
and Order, Order, and Further Notice of Proposed Rulemaking, 26 FCC Rcd 14895 (2011) (iTRS Certification
9 See id. at 14902-14904, ¶¶ 16-20.
10 See 47 C.F.R. § 64.606(a)(3).
subsequent on-site visits to the applicant.11 The Commission noted that such visits would “better enable
the Commission to verify the information provided in a certification application, and help us to better
assess an applicant’s ability to provide service in compliance with our rules.”12 This grant of conditional
certification is without prejudice to the Commission’s final determination of CSDVRS’s qualifications,
and is dependent on the Commission verifying the information provided in the CSDVRS Recertification
Application, including its supplement, and on the veracity of the applicant’s representations that it will
provide service in compliance with all pertinent Commission requirements.13
Ultimate conversion to full certification will be granted if, based on on-site visits and our review
of such additional documentation, the Commission finds that CSDVRS is in compliance with the
Commission’s rules and orders, including those rules designed to ensure the accuracy and integrity of
Fund payments,14 and is qualified to receive compensation from the Fund for the provision of VRS.15 If
at any time during the period in which CSDVRS is operating pursuant to this conditional certification, the
Commission determines that CSDVRS has failed to provide sufficient supporting documentation for any
of the assertions in CSDVRS’s application or that any of those assertions cannot be supported, or finds
evidence of any apparent rule violation, fraud, waste, or abuse, the Commission will take appropriate
action, including the possible denial of the CSDVRS Recertification Application. In the event of such
denial, CSDVRS’s conditional certification will automatically terminate 35 days after such denial.16 If,
however, the Commission grants full certification, CSDVRS, like all VRS providers, must continue to
operate in compliance with all relevant Commission rules and orders.
Redacted copies of the CSDVRS Recertification Application and its supplement are available for
public inspection and copying during regular business hours at the FCC Reference Information Center,
Portals II, 445 12th Street, SW, Suite CY-A257, Washington, DC 20554, (202) 418-0270. The full text
of this Public Notice is similarly available for public inspection or copying. These documents may also
be purchased from the Commission’s duplicating contractor, Best Copy and Printing, Inc. (BCPI), Portals
II, 445 12th Street, SW, Room CY-B402, Washington, DC 20554. Customers may contact BCPI at its
web site: www.bcpiweb.com, or by calling 1-800-378-3160. Redacted copies of the CSDVRS
Recertification Application and its supplement may also be found by searching on the Commission’s
Electronic Comment Filing System (ECFS) at https://www.fcc.gov/cgb/ecfs (insert 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 firstname.lastname@example.org or call the Consumer and Governmental
Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (TTY). This Public Notice can also be
downloaded in Word or Portable Document Format (PDF) at: https://www.fcc.gov/cgb/dro.
11 47 C.F.R. § 64.606(a)(3); see also iTRS Certification Order, 26 FCC Rcd at 10914, ¶ 37.
12 Id., ¶ 36.
13 Id., ¶ 37.
14 Id., § 64.604(c)(5)(iii).
15 See iTRS Certification Order, 26 FCC Rcd at 10914, ¶ 37; 47 C.F.R. § 64.606(b)(2),(c)(2).
16 See iTRS Certification Order, 26 FCC Rcd at 10914-15, ¶ 37. If the Commission terminates a conditional
certification, the provider must give at least 30 days’ notice to its customers that it will no longer offer service.
For further information, please contact Gregory Hlibok, Consumer and Governmental Affairs
Bureau, Disability Rights Office, at (202) 559-5158 (voice/videophone), (202) 418-0431 (TTY), or e-mail
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