FCC Record, Volume 26, No. 20, Pages 15894 to 16757, November 14 - December 9, 2011 Page: 15,966
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providers.' 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.b
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.
Based on our review of the application submitted by CAAG, as supplemented. we grant
conditional certification to CAAG 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.? 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."0 We grant
this certification conditionally, in part because this is the first time that CAAG will become eligible to
receive compensation directly from the Fund. While we find that CAAG's application facially meets the
certification requirements," we believe that an on-site visit is necessary to verify CAAG's ability to
provide service in compliance with the Commission's rules.'2 This grant of conditional certification is
without prejudice to the Commission's final determination of CAAG'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
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.
d. at 2.
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) (IRS 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, CO Docket No. 10-51, Memorandum Opinion and Order. Order, and Further Notice of
Proposed Rulemaking, FCC 11-155 (2011) (iTRS Certification Clarification Order).
SSee id. at 16-20.
9 47 C.F.R. 64.606(a)(3); see also ITRS Certification Order, 26 FCC Rcd at 10914, 1 37.
10 iTRS Certification Order, 26 FCC Rcd at 10914, 36.
" Id.at 37; see 47 C.F.R. 64.606(b)(2).
'2 See iTRS Certification Order. 26 FCC Red at 10914, 36.
"3 Id at 37.
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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.. (digital.library.unt.edu/ark:/67531/metadc81370/m1/89/: accessed March 27, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.