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Notice of Petitions for Reconsideration in CG Docket No. 10-51

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Released: September 22, 2011


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 11- 1590

Released: September 22, 2011




Oppositions Due: (10 days after date of publication in the Federal Register).
Replies Due: (15 days after date of publication in the Federal Register).

By this Public Notice, the Consumer & Governmental Affairs Bureau ("CGB") provides notice that, by
petitions for reconsideration dated September 6, 2011 in CG Docket No. 10-51, Sorenson
Communications, Inc. (Sorenson) and AT&T Services, Inc. (AT&T) have each sought Commission
reconsideration of various aspects of the Commission's July 2011 Second Report and Order regarding the
Video Relay Service (VRS) and other forms of Internet-based Telecommunications Relay Services
(TRS).1 By its Petition, Sorenson asks the Commission to reconsider its recently adopted rules requiring
the submission of documentation regarding all of a provider's VRS equipment and technologies, and the
submission of documentation regarding sponsorship arrangements. AT&T seeks reconsideration of the
portions of the Second Report and Order that make the operation of call centers and the employment of
communications assistants requirements of the mandatory certification of VRS providers, and would
prohibit such providers from subcontracting the core functions of VRS to another certified provider.
Section 1.429(f) of the Commission's rules, 47 C.F.R. 1.429(f), specifies that oppositions to a petition
for reconsideration shall be filed within fifteen days after the date of public notice of the petition's filing.
Section 1.429(g), 47 C.F.R. 1.429(g), requires that replies to an opposition shall be filed within ten days
after the time for filing oppositions has expired. In this case, we find good cause to alter the periods
specified in Section 1.429 for the filing of such oppositions and replies. Providers currently eligible for
compensation from the Interstate TRS Fund (TRS Fund) via a means other than Commission certification
must apply for certification within 30 days after the rules adopted in the Second Report and Order
become effective, and providers with Commission certifications expiring November 4, 2011 must apply
for recertification after the rules become effective but at least 30 days prior to their expirations provided
that the rules are effective by that date, or risk having to shut down their operations and being denied
compensation from the TRS Fund. In light of these impending deadlines for initial and recertification
applications, and to avoid waste, fraud, and abuse in the VRS program, we find that good cause exists in
this instance to alter the comment periods specified in Section 1.429 of the Commission's rules. See 47
C.F.R. 1.3 (providing for suspension, amendment, or waiver of Commission rules, in whole or in part,
for good cause shown, and on the Commission's own motion).

1 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) (Second Report and Order).

Accordingly, oppositions to Sorenson's and/or AT&T's petitions for reconsideration of the Second Report
and Order
shall be filed no later than 10 days after Federal Register publication, and replies to
oppositions will be due no later than 15 days after Federal Register publication.

Procedural Matters

Oppositions and Replies. Pursuant to Section 1.429 of the Commission's rules,2 interested parties
may file oppositions and replies to an opposition on or before the dates indicated on the first page of this
document. Comments may be filed using: (1) the Commission's Electronic Comment Filing System
(ECFS); or (2) by filing paper copies. All filings should reference the docket number of this proceeding,
CG Docket No. 10-51.

Electronic Filers: 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, ECFS filers should
include their full name, U.S. Postal Service mailing address, and CG Docket No. 10-51.

Paper Filers: Parties who choose to file by paper must file an original and one copy of each
filing. 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 or boxes 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.
Accessibility Information. 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 & Governmental Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (TTY).
The comments and reply comments filed in response to this Public Notice will be available via
ECFS at:; you may search by docket number (CG Docket No. 10-51).
Comments are also available for public inspection and copying during business hours in the FCC
Reference Information Center, Portals II, 445 12th Street, SW, Room CY-A257, Washington, D.C. 20554.
Copies may also be purchased from Best Copy and Printing, Inc., telephone (800) 378-3160, facsimile
(202) 488-5563, e-mail
Ex Parte Rules. This proceeding shall be treated as a "permit-but-disclose" proceeding in
accordance with the Commission's ex parte rules.3 Persons making ex parte presentations must file a

2 47 C.F.R. 1.429(f), (g).
3 See 47 C.F.R. 1.1200 et seq.

copy of any written presentation or a memorandum summarizing any oral presentation within two
business days after the presentation (unless a different deadline applicable to the Sunshine period applies).
Persons making oral ex parte presentations are reminded that memoranda summarizing the presentation
must: (1) list all persons attending or otherwise participating in the meeting at which the ex parte
presentation was made; and (2) summarize all data presented and arguments made during the
presentation. If the presentation consisted in whole or in part of the presentation of data or arguments
already reflected in the presenter's written comments, memoranda or other filings in the proceeding, the
presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or
other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can be
found) in lieu of summarizing them in the memorandum. Documents shown or given to Commission
staff during ex parte meetings are deemed to be written ex parte presentations and must be filed
consistent with section 1.1206(b) of the Commission's rules. In proceedings governed by section 1.49(f)
of the rules or for which the Commission has made available a method of electronic filing, written ex
presentations and memoranda summarizing oral ex parte presentations, and all attachments thereto,
must be filed through the electronic comment filing system available for that proceeding, and must be
filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in this proceeding should
familiarize themselves with the Commission's ex parte rules.
Additional Information. For further information, contact Gregory Hlibok of the Consumer &
Governmental Affairs Bureau, at (202) 559-5158 (VP), or email at
By the Chief, Consumer & Governmental Affairs Bureau

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