**DA 08-292**

**Released: February 4, 2008**

**CONSUMER & GOVERNMENTAL AFFAIRS BUREAU SEEKS COMMENT ON**

**REQUEST FOR CLARIFICATION THAT INTERNET PROTOCOL SPEECH TO SPEECH
SERVICE IS A FORM OF TELECOMMUNICATIONS RELAY SERVICE COMPENSABLE FROM
THE INTERSTATE TRS FUND**

**CG DOCKET NO. 08-15**

**PLEADING CYCLE ESTABLISHED**

**Comments Due: 30 days after publication in the Federal Register**

**Reply Comments Due: 45 days after publication in the Federal
Register**

On December 21, 2007, Hawk Relay, LLC (Hawk Relay) filed a request for
clarification that Internet Protocol Speech-to-Speech Relay Service (IP
STS) is a form of Telecommunications Relay Service (TRS)[^1] eligible
for compensation from the Interstate TRS Fund.[^2] In its *Request*,
Hawk Relay describes IP STS as a type of Speech-to-Speech service (STS)
that uses the Internet, rather than a traditional telephone line, to
connect the consumer to the relay provider. STS enables persons with a
speech disability to make telephone calls using their own voice through
relay centers with specially trained communications assistants who
re-voice to the calling party what the STS user says.[^3]

The Consumer & Governmental Affairs Bureau hereby seeks comment on the
*Request*. In addition, assuming that IP STS qualifies as a TRS under
section 225(a)(3) of the Communications Act of 1934,[^4] we seek comment
on the jurisdictional separation of costs,[^5] the applicability of the
TRS mandatory minimum standards,[^6] and on any other issues relevant to
the provision of IP STS.

Pursuant to sections 1.415 and 1.419 of the Commission's rules, 47
C.F.R. §§ 1.415, 1.419, interested parties may file comments in this
proceeding **30 days after publication in Federal Register and reply
comments may be filed 45 days after publication in Federal Register.**
When filing comments, please reference **CG Docket No. 08-15.**[^7]
Comments may be filed using: (1) the Commission\'s Electronic Comment
Filing System (ECFS), (2) the Federal Government's eRulemaking Portal,
or (3) by filing paper copies. *See* Electronic Filing of Documents in
Rulemaking Proceedings, 63 Fed. Reg. 24,121 (1998). Comments filed
through the ECFS can be sent as an electronic file via the Internet by
accessing the ECFS: <http://www.fcc.gov/cgb/ecfs/> or the Federal
Rulemaking Portal:
[http://www.regulations.gov](http://www.regulations.gov/). Filers should
follow the instructions provided on the website for submitting comments.
If multiple docket or rulemaking numbers appear in the caption of this
proceeding, commenters must transmit one electronic copy of the comment
to each docket or rulemaking number referenced in the caption. In
completing the transmittal screen, commenters should include their full
name, U.S. Postal Service mailing address, and the applicable docket or
rulemaking number. Parties may also submit an electronic comment by
Internet e-mail. To get filing instructions, commenters should send an
e-mail to <ecfs@fcc.gov>, and should include the following words in the
body of the message, \"get form.\" A sample form and directions will be
sent in reply.

Parties who choose to file by paper must file an original and four
copies of each filing. If more than one docket or rulemaking number
appears in the caption of this proceeding, commenters must submit two
additional copies for each additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by electronic media,
by commercial overnight courier, or by first-class or overnight U.S.
Postal Services mail (although we continue to experience delays in
receiving U.S. Postal Service mail). All filings must be addressed to
the Commission's Secretary, Office of the Secretary, Federal
Communications Commission. The Commission\'s contractor will receive
hand-delivered or messenger-delivered paper filings or electronic media
for the Commission\'s Secretary at 236 Massachusetts Avenue, NE, Suite
110, Washington, D.C. 20002. The filing hours at this location are 8:00
a.m. to 7:00 p.m. All hand deliveries must be held together with rubber
bands or fasteners. Any envelopes must be disposed of *before* entering
the building. Commercial and electronic media sent by overnight mail
(other than U.S. Postal Service Express Mail and Priority Mail) must be
sent to 9300 East Hampton Drive, Capitol Heights, MD 20743. U.S. Postal
Service first-class mail, Express Mail, and Priority Mail should be
addressed to 445 12^th^ Street, SW, Washington, D.C. 20554.

Parties who choose to file by paper should also submit their comments on
CD-Rom. The CD-Rom should be submitted, along with three paper copies,
to: Dana Wilson, Consumer & Governmental Affairs Bureau, Disability
Rights Office, 445 12^th^ Street, SW, Room 3-C418, Washington, D.C.
20554. Such a submission should be on CD-Rom formatted in an IBM
compatible format using Word 2003 or compatible software. The CD-Rom
should be accompanied by a cover letter and should be submitted in
\"read only\" mode. The CD-Rom should be clearly labeled with the
commenter\'s name, proceeding (including the lead docket number) in this
case, **CG Docket No. 08-15,** type of pleading (comment or reply
comment), date of submission, and the name of the electronic file on the
CD-Rom. The label should also include the following phrase \"CD-Rom
Copy - Not an Original.\" Each CD-Rom should contain only one party\'s
pleadings, preferably in a single electronic file. In addition,
commenters must send CD-Rom copies to the Commission\'s copy contractor,
Portals II, 445 12^th^ Street, SW, Room CY- B402, Washington, D.C.
20554.

Pursuant to section 1.1206 of the Commission's rules, 47 C.F.R. §
1.1206, this proceeding will be conducted as a permit-but-disclose
proceeding in which *ex parte* communications are subject to disclosure.

The full text of this document and copies of any subsequently filed
documents in this matter will be available for public inspection and
copying during regular business hours at the FCC Reference Information
Center, Portals II, 445 12^th^ Street, SW, Room CY-A257, Washington,
D.C. 20554. This document and copies of subsequently filed documents in
this matter may also be purchased from the Commission's duplicating
contractor at Portals II, 445 12^th^ Street, SW, Room CY-B402,
Washington, DC 20554. Customers may contact the Commission's contractor
at their web site [www.bcpiweb.com](http://www.bcpiweb.com/) or by
calling 1-800-378-3160. A copy of the Petition for Clarification may
also be found by searching ECFS at <http://www.fcc.gov/cgb/ecfs> (insert
**CG Docket No. 08-15** 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 <fcc504@fcc.gov> or call the Consumer & 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:
<http://www.fcc.gov/cgb/dro/trs.html>.

For further information, please contact Gregory Hlibok, Consumer &
Governmental Affairs Bureau, Disability Rights Office, at (800) 311-4381
(voice), (202) 418-0431 (TTY), or e-mail at <Gregory.Hlibok@fcc.gov>.

**-FCC-**

## 

[^1]: *See generally* 47 U.S.C. § 225; 47 C.F.R. §§ 64.601 *et seq.*

[^2]: *See* Hawk Relay, *Request for Expedited Clarification for the
    Provision and Cost Recovery of Internet Protocol Speech to Speech
    Relay Service*, CG Docket No. 03-123, filed December 19, 2007
    (*Request*).

[^3]: *See generally* 47 C.F.R. §§ 64.601(12) (defining STS).

[^4]: 47 U.S.C. § 225(a)(3).

[^5]: *See* 47 U.S.C. § 225(d)(3) (setting forth jurisdictional
    separation of costs requirement); *see also* *Telecommunications
    Relay Services and Speech-to-Speech Services for Individuals with
    Speech and Hearing Disabilities*, CC Docket 98--67, Declaratory
    Ruling, 18 FCC Rcd 16121 at 16128--30, paras. 18--23 (August 1,
    2003) (discussing jurisdictional separation of costs issues for
    interstate and intrastate TRS).

[^6]: *See* 47 C.F.R. § 64.604.

[^7]: This Public Notice is being released under a new docket number,
    **CG Docket No. 08-15**, which shall include all STS matters
    (including IP STS). CG Docket No. 03-123 will remain open for the
    ongoing filing of documents in proceedings under that docket number.
    This new docket number is established to further administrative
    efficiency.