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FCC Public Notice on New VRS Rates, NAD to File Comments


FCC Public Notice on New VRS Rates, NAD to File Comments

To view two-part vlog by NAD President Bobbie Beth Scoggins, visit


The Federal Communications Commission (FCC) recently received video relay
service (VRS) rates for July 2010 to June 2011 from the National Exchange
Carrier Association (NECA). The FCC is asking for comments about the
proposed VRS rates. The National Association of the Deaf (NAD) learned that
some people are saying that the proposed rates will tear down VRS. These
claims have not been supported. The FCC has said many times that it supports
VRS and recognizes the value, importance, and functional equivalency that
VRS provides to people who use American Sign Language (ASL). We encourage
consumers to turn to consumer organizations, such as the NAD, to learn about
the issues and how to protect their civil, human, and linguistic rights
through public comments and action.

The NAD, along with other consumer groups, will file comments for the first
round of comments due May 14, 2010. The NAD will urge the FCC to consider
the quality of relay services, achieving functionally equivalent
telecommunications, and other principles and objectives such as
transparency, interoperability, innovation, and competitive markets when
setting the rates. The NAD will then inform the community early next week
about its position and provide consumers with a sample comment to file with
the FCC for the second, and final, round of comments due May 21, 2010. At
this time, the NAD wants to share some background on the VRS rates so
consumers can be better informed.

Background on New VRS Rates

While we are pleased that the FCC finally issued a notice for proposed
rulemaking on VRS rates for 2010-2011, we are dismayed that the FCC did not
heed our request from June 2009 to conduct a comprehensive review that
considers alternative approaches to setting VRS rates. We want the FCC to
consider reasonable costs for marketing and outreach, research and
development, and equipment costs. The NAD will continue to urge the FCC to
conduct a detailed analysis of its VRS rate-setting methodology.

The FCC proposes to continue the tiered rate structure, which started in
2007. This structure generally reflects economies of scale (the more minutes
of service you provide, the less it costs per minute to provide the
service). Although the FCC seems to plan to continue a multi-year rate
structure in the future, the FCC is proposing these new rates for an
“interim” one-year period for 2010-2011:

Tier I: 0-50,000 minutes per month – $5.7754 per minute
Tier II: 50,001-500,000 minutes per month – $6.0318 per minute
Tier III: 500,001 or more minutes per month – $3.8963 per minute

These VRS rates were computed by the National Exchange Carrier Association
(NECA), which administers the Telecommunications Relay Service Fund. These
rates are one of four rates discussed in their submission to the FCC.
According to the FCC, the proposed rates are based on the 2009 average
actual historical cost data submitted to NECA by VRS providers. The FCC also
said that, in setting past rates, it relied on projected costs to determine
the VRS rate.

Consumer Comments

The NAD will post another blog/vlog early next week to provide consumers
with filing instructions and a sample comment to file with the FCC to
protect their right to functionally equivalent telecommunications. Please
turn in your comments by May 21st.


A Message from the FCC’s Consumer and Governmental Affairs Bureau to the VRS

You may have seen claims that the video relay service (VRS) program is
threatened. This is not true. The FCC is committed to ensuring the provision
of high quality VRS to all individuals who need this service. The Americans
with Disabilities Act (ADA) requires telecommunications access that is
functionally equivalent to voice telephone services for people who are deaf,
hard of hearing, or have speech disabilities. The FCC continues to believe
that VRS is the most functionally equivalent form of relay for people who
communicate using American Sign Language (ASL). We stand ready to meet our
obligation to preserve and protect the VRS program so that ASL users and
hearing people can communicate with each other over distances. This was the
goal of Congress in passing the ADA and it continues to be our goal.

Here are the facts: On April 30th, the FCC released a Public Notice
(DA-10-761A1.doc) asking the general public for feedback on what VRS
providers should be paid to handle VRS calls for the next year. The Public
Notice seeks comment on reimbursing providers based on the actual costs that
VRS providers themselves claim to have incurred over the past few years to
provide VRS. The only way to safeguard the VRS program is to adopt
reasonable rates for all forms of relay services. Thus, it is our goal to
adopt rates that are rationally based on the reasonable costs of actually
providing VRS. We welcome all comments on our Public Notice, and will take
all feedback into account to determine the next VRS rates. The VRS program
will continue to provide the excellent communication service that you need.

Joel Gurin, Bureau Chief
Karen Peltz Strauss, Deputy Bureau Chief

Source: http://bit.ly/ckoyNN

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