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