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Sprint Petition On IP Relay Rates - Comments Requested

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Released: November 25, 2013


Federal Communications Commission

News Media Information 202 / 418-0500


445 12th St., S.W.

TTY: 1-888-835-5322

Washington, D.C. 20554

DA 13-2258

Released: November 25, 2013




CG Docket Nos. 03-123 & 10-51

Comments: December 5, 2013

Reply Comments: December 12, 2013

On July 31, 2013, Sprint Corporation (Sprint) filed a petition (Sprint Reconsideration Petition)1
requesting reconsideration of the 2013 Rate Order,2 including a request for immediate suspension of the
Internet Protocol Relay (IP Relay) compensation rate adopted in the 2013 Rate Order.3 Specifically,
Sprint claims that the rates established by the 2013 Rate Order are too low to ensure high quality service.4
Additionally, Sprint contends that the rapid exodus of three of the five IP Relay providers from the
marketplace appears to be evidence of inadequate compensation of providers for their provision of IP
Relay services, and argues that the departure of these providers renders the Commission’s rate
calculations obsolete.5 Sprint further expresses concern that only an adequate compensation rate will
retain the two remaining providers, that the consumer benefits of competition would be lost if one of the
providers withdraws,6 and that if both providers left the market, consumers would be deprived of
important IP Relay services completely.7

1 Petition for Reconsideration of Sprint Corporation, CG Docket Nos. 03-123 and 10-51 (filed July 31, 2013) (Sprint
Reconsideration Petition).
2 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. 03-133 and 10-51,
Order, 28 FCC Rcd 9220 (July 1, 2013) (2013 Rate Order).
3 Similar concerns were previously discussed by Sprint in two Ex Parte submissions, which were submitted on July
26, 2013 and November 8, 2013. See Ex Parte Submissions of Sprint Corporation on filed July 26, 2013 at page 1
and filed on November 8, 2013).
4 Sprint Reconsideration Petition at 8-9.
5 Sprint Reconsideration Petition at 2, 3-6.
6 Sprint Reconsideration Petition at 6-11.
7 Sprint Reconsideration Petition at 10-11.

Sprint asks for a rate that offers IP Relay providers reasonable regulatory certainty,8 and seeks a
reinstatement of the rate of $1.2855 per minute until the Commission is able to analyze recent
developments in the IP Relay market and adopt a rate that adequately compensates IP Relay providers.9
Pursuant to section 1.429 of the Commission’s rules, 47 C.F.R. § 1.429, we invite interested
parties to file comments on the Sprint Reconsideration Petition and to file reply comments on or before
the dates specified above. All filings must reference

CG Docket Nos. 03-123 & 10-51

. Comments may
be filed using the Commission’s Electronic Comment Filing System (ECFS) or by filing paper copies.
See Electronic Filing of Documents in Rulemaking Proceedings. 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, U.S. Postal Service mailing address, and

CG Docket Nos.
03-123 & 10-51.

Parties who choose to file by paper must file an original and one copy of each filing. If more than
one docket or rulemaking number appears in the caption of this proceeding, filers must submit one
additional copy for each additional docket or rulemaking number. 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 St., 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 Notice, the Sprint Reconsideration Petition 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 Notice, the Sprint
Reconsideration Petition and any subsequently filed documents in this matter may also be purchased from
the Commission’s duplicating contractor at its website,, or call 1-800-378-3160. A
copy of the submission may also be found by searching on ECFS (insert

CG Docket Nos. 03-123 & 10-

into the Proceeding block).
People with Disabilities: 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 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 Elaine Gardner, Consumer and Governmental Affairs
Bureau, Disability Rights Office, at (202) 418-0581 or e-mail at

8 Sprint Reconsideration Petition at 11-14.
9 Sprint Reconsideration Petition at 1, 14.

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