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Video Relay Service Certification Conditional Grant

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Released: November 15, 2011


Federal Communications Commission

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DA 11-1901

Released: November 15, 2011





By the Chief, Consumer and Governmental Affairs Bureau:
On November 4, 2011, Convo Communications, LLC (Convo) filed an application to be certified1
as a provider of video relay service (VRS) that is eligible for compensation from the Interstate TRS Fund
(Fund).2 For the reasons discussed below, the Consumer and Governmental Affairs Bureau (Bureau)
hereby grants Convo’s application on a conditional basis, pending inspection of Convo’s facilities and
confirmation of Convo’s compliance with all applicable 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

1 Convo Communications, LLC, Amended and Restated Video Relay Service Certification Application, CG Docket
No. 10-51 (filed Nov. 4, 2011) (Convo 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).
2 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).

providers.3 These new rules require that all iTRS providers obtain certification from the Commission to
be eligible to receive compensation from the Fund.4 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.5 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.6
On October 17, 2011, the Commission released the iTRS Certification Clarification Order,7 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 and
providers associated with providing certain documentation to the Commission.8
Based on our review of the Convo Application, we grant conditional certification to Convo to
provide VRS service. In the iTRS Certification Order, the Commission reserved the right, after initial
review of the application, to conditionally grant certification subject to one or more subsequent on-site
visits of the applicant.9 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.”10 We grant this certification conditionally, in
part because this is the first time that Convo will become eligible to receive compensation directly from
the Fund. While we find that Convo’s application facially meets the certification requirements,11 we
believe that an on-site visit is necessary to verify Convo’s ability to provide service in compliance with
the Commission’s rules.12 This grant of conditional certification is without prejudice to the
Commission’s final determination of Convo’s qualifications, and is dependent on the Commission
verifying the information provided in the application for certification, and the veracity of the applicant’s
representations that it will provide service in compliance with all pertinent Commission requirements.13

3 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 new certification processes by which this grant of conditional certification is awarded may be superseded or
modified by future Commission actions on VRS reform.
4 Id. at ¶ 2.
5 Id.
6 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).
7 Structure and Practices of the Video Relay Service Program, Sprint Nextel Corporation Expedited Petition for
Clarification, Sorenson Communications, Inc. Petition for Clarification, 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, FCC 11-155 (2011) (iTRS Certification Clarification Order).
8 See id. at ¶¶ 16-20.
9 47 C.F.R. § 64.606(a)(3); see also iTRS Certification Order, 26 FCC Rcd at 10914, ¶ 37.
10 iTRS Certification Order, 26 FCC Rcd at 10914, ¶ 36.
11 ¶ 37; see 47 C.F.R. § 64.606(b)(2).
12 See iTRS Certification Order, 26 FCC Rcd at 10914, ¶ 36.
13 Id. at ¶ 37.

The Bureau notes an inaccuracy in Convo’s application. Specifically, Convo states in its
application that its automatic call distribution system will be able to access certain information from “the
Neustar Registered Location database.”14 We remind Convo that providers do not obtain registered
location information from the TRS Numbering Directory, which is maintained by its administrator,
Neustar. The primary purpose of this directory is to record the mapping of the North America Numbering
Plan telephone number of each registered iTRS user to a unique Uniform Resource Identifier (URI).15
Because this directory does not maintain a list of registered location information for VRS users, we
remind Convo that it must maintain its own database of such registered location information in order to
comply with the numbering requirements.
Our grant of certification to Convo is contingent on verification of information provided in its
application. The Commission reserves the right to conduct one or more on-site inspections of Convo’s
facilities by designated personnel, and to request additional documentation relating to Convo’s provision
of VRS. Ultimate conversion to full certification will be granted if and when, based on on-site visits
and/or the review of additional documentation, the Commission finds that Convo is in compliance with its
rules and orders, including the 24/7 rule and the E911 rules, and is accordingly qualified to receive
compensation from the Fund for the provision of VRS.16 If at any time during the period in which Convo
is operating pursuant to this conditional certification, the Commission determines that the assertions in
Convo’s application cannot be supported, or finds evidence of apparent rule violations, fraud, waste, or
abuse, it will terminate Convo’s conditional certification. In such case, Convo’s application will be
denied and its conditional certification will automatically terminate 35 days after denial.17 If, however,
the Commission grants full certification, Convo, like all VRS providers, will be expected to operate in
compliance with all relevant Commission rules and orders.
We understand that once certified, Convo will require a limited period of time to transition to
providing stand-alone VRS as a conditionally certified provider. Specifically, as a conditionally certified
provider, Convo may need to interconnect with the TRS Numbering Directory in order to register ten-
digit telephone numbers for their new customers, establish coordination with the TRS Fund
Administrator, reroute IP addresses relevant to the provision of VRS, and make other arrangements
necessary to register users and handle their calls as a stand-alone provider.18 Accordingly, we grant
Convo a waiver of section 64.604(c)(5)(iii)(N)(1)(iii) of the Commission’s rules19 until November 30,
2011, in order to facilitate such a transition.20 Because the stay of effectiveness of section

14 Convo Application at 28.
15 See 47 C.F.R. § 64.613.
16 See iTRS Certification Order, 26 FCC Rcd at 10914, ¶ 37; 47 C.F.R. § 64.606(b)(2),(c)(2).
17 See iTRS Certification Order, 26 FCC Rcd at 10914, ¶ 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.
18 See, e.g., Letter from David J. Bahar, Vice President of Government and Regulatory Affairs, Convo, to Marlene
H. Dortch, Secretary, FCC (filed Nov. 8, 2011), at 1 (describing steps required to transition from VRS subcontractor
to stand-alone VRS provider, and asserting that it will take Convo between two weeks and one month to commence
independent VRS operations).
19 47 C.F.R. § 64.604(c)(5)(iii)(N)(1)(iii).
20 See 47 C.F.R. § 1.3 (Commission may waive its rules on its own motion if good cause therefor is shown). This
transition period is consistent with the Commission’s objective to provide subcontractors to eligible VRS providers
with “the opportunity to apply for certification prior to the expiration of the stay and…the opportunity to seek to
transition to eligibility in a seamless manner, without any interruption in providing service.” Structure and

64.604(c)(5)(iii)(N)(1)(iii) expires on November 15, 2011, we find that this additional time will be
necessary and sufficient to enable Convo to transition to providing stand-alone VRS on a conditional
basis, and will serve the public interest. We thus find good cause for granting this waiver.21
A copy of Convo’s redacted application is 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:, or by calling 1-800-378-3160. A copy of Convo’s redacted application may also be
found by searching on the Commission’s Electronic Comment Filing System (ECFS) at (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 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:
For further information, please contact Gregory Hlibok, Consumer and Governmental Affairs
Bureau, Disability Rights Office, at (866) 954-4053 (voice/videophone), (202) 418-0431 (TTY), or e-mail
- FCC -

Practices of the Video Relay Service Program, Order Extending Suspension of Effective Date, 26 FCC Rcd 13820,
13821, ¶ 4 (2011).
21 We distinguish this grant of a brief waiver of section 64.604(c)(5)(iii)(N)(1)(iii) to Convo from our decision on
November 8, 2011 denying a request filed by Gallaudet University to extend the stay of effective date of that rule.
See Structure and Practices of the Video Relay Service Program, CG Docket No. 10-51, Public Notice, DA 11-1868
(CGB rel. Nov. 8, 2011) (VRS Stay Extension Denial Order). We did not find good cause to extend the stay of the
effective date of section 64.604(c)(5)(iii)(N)(1)(iii) in the VRS Stay Extension Denial Order because we concluded
that Gallaudet had adequate time and notice to apply for certification as a stand-alone provider of VRS that would
not require such an extension. In contrast, here Convo has timely filed an application for certification, which the
Bureau has conditionally granted. A limited waiver of section 64.604(c)(5)(iii)(N)(1)(iii) thus is necessary to allow
Convo to transition from a subcontracting entity to a stand-alone VRS provider.

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