FCC Record, Volume 26, No. 20, Pages 15894 to 16757, November 14 - December 9, 2011 Page: 15,933
ix, 15894-16757 p. ; 28 cm.View a full description of this book.
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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,' 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."
Based on our review of the application submitted by BIS Relay, we conclude that the applicant
has failed to satisfy the requirements set forth in the Commission's certification rules, including but not
limited to:
1. Section 64.611 - Requiring demonstration of compliance with iTRS registration and
numbering requirements;9
2. Section 64.604(c)(5)(iii)(N)(1)(iii) - Prohibiting an eligible provider from authorizing
a non-certified third party from providing interpretation services or call center
functions;0 and
3. Section 64.606(aX2) - Requiring a detailed description of how applicant will meet
mandatory minimum operational standards."
In addition, we conclude that BIS Relay has failed to demonstrate that it will meet section
64.604(b)(4)(i) of the Commission's rules, a mandatory minimum technical standard requiring VRS
facilities to be operated every day, 24 hours a day.2 In the iTRS Certification Clarification Order, the
Commission reiterated its expectation that VRS providers would adequately staff their call centers 24/7,
and noted its obligation to ensure that all certified providers are capable of providing their own services
on a continuous basis, in a manner that meets the Commission's rules.13 BIS Relay has not demonstrated
SId at 2.
Ild.
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 ofA T& 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 1 16-20.
947 C.F.R. 64.611.
1o 47 C.F.R. 64.604(c)(5)(iii)(N)1)(iii).
" 47 C.F.R. 64.606(a)(2).
" 47 C.F.R. 64.604(b)(4)(i).
13 iTRS Certification Clarification Order at 10, 13.15933
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United States. Federal Communications Commission. FCC Record, Volume 26, No. 20, Pages 15894 to 16757, November 14 - December 9, 2011, book, December 2011; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc81370/m1/56/: accessed April 19, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.