Federal Communications Commission FCC 08-149
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of 
Telecommunications Relay Services
And Speech-to-Speech Services for
Individuals with Hearing and Speech
Disabilities
Speech-to-Speech and Internet Protocol (IP) 
Speech-to-Speech Telecommunications Relay 
Services
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CG Docket No. 03-123 
CG Docket No. 08-15
NOTICE OF PROPOSED RULEMAKING
Adopted:  June 11, 2008 Released:  June 24, 2008
Comment Date:  (30 days after publication in the Federal Register)
Reply Comment Date:  (45 days after publication in the Federal Register)
By the Commission:  Chairman Martin, Commissioners Copps, Adelstein and Tate issuing separate   
statements.
I. INTRODUCTION
1. In this Notice of Proposed Rulemaking (Notice), we seek comment on several issues 
concerning the provision of Speech-to-Speech (STS), a form of telecommunications relay service (TRS).1  
First, we seek comment on whether we should amend the TRS regulations to require that the CA handling 
an STS call stay with the call for a minimum of 20 minutes.2 Second, we seek comment on whether the 
Commission should amend its TRS rules to require that STS providers offer the STS user the option of 
having her or his voice muted so that the other party to the call would only hear the STS CA re-voicing 
the call, not the voice of the STS user as well.  Finally, we seek comment on ways we can ensure that STS 
users calling 711, the nationwide access code for state relay providers, will promptly reach an STS CA to 
  
1 TRS, created by Title IV of the Americans with Disabilities Act of 1990 (ADA), enables a person with a hearing or 
speech disability to access the nations telephone system to communicate with a voice telephone user through a relay 
provider and a Communications Assistant (CA).  See generally 47 U.S.C.  225; 47 C.F.R.  64.601 et seq. (the 
TRS regulations).  There are several forms of TRS, including Speech-to-Speech (STS), which we describe below.  
The Interstate TRS Fund (Fund) compensates providers for their reasonable costs of providing interstate service, and 
with some forms of TRS, both intrastate and interstate service.  See generally Telecommunications Relay Services 
and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CC Docket No. 98-67, Report 
and Order and Further Notice of Proposed Rulemaking, 15 FCC Rcd 5140, 5149, para. 15 (Mar. 6, 2000) (2000 TRS 
Report and Order) (recognizing STS as a form of TRS); Telecommunications Relay Services and Speech-to-Speech 
Services for Individuals with Hearing and Speech Disabilities, CC Dockets 90-571 and 98-67 and CG Docket 03-
123, Report and Order, Order on Reconsideration, and Further Notice of Proposed Rulemaking, 19 FCC Rcd 12475, 
12479-80, para. 3 n.18 (June 30, 2004) (2004 TRS Report and Order) (discussing how TRS works).
2 See Bob Segalman and Rebecca Ladew, Petition for Amendment to TRS rule on Speech-to-Speech Relay Service, 
CG Docket No. 03-123, filed June 26, 2006 (STS Petition).
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handle their calls, including, for example, requiring TRS providers to use an interactive menu that allows 
the user to reach an STS CA as the first option.  
2. In addition, we seek comment on various issues with respect to Internet Protocol (IP) 
STS (IP STS).  In December 2007, Hawk Relay filed a request for clarification3 that IP STS is a form of 
TRS eligible for compensation from the Fund.  We tentatively conclude that IP STS is a form of TRS 
compensable from the Fund.  We seek comment on this tentative conclusion, and related issues relevant 
to the provision, regulation, and compensation of IP STS.  
II. BACKGROUND
A. Speech-to-Speech Relay Service
3. On March 6, 2000, the Commission mandated that carriers obligated to provide TRS 
must also provide STS so that persons with speech disabilities can access the telephone system.4 STS 
relay service utilizes a specially trained CA who understands the speech patterns of persons with speech 
disabilities and can repeat the words spoken by such an individual to the other party to the call.5 As a 
general matter, a person with a speech disability initiates a STS call by calling a TRS provider on a 
standard telephone, and giving the CA the number of person he or she wishes to call.  The CA then makes 
the outbound call, and re-voices what the STS user has said to the called party.  Persons desiring to call a 
person with a speech disability via STS can also initiate an STS call.  Because STS calls are made via the 
Public Switched Telephone Network (PSTN), and therefore the geographic location of the parties to the 
call can be determined, states are responsible for compensating providers for the costs of intrastate STS, 
and the Fund compensates providers for the costs of interstate STS.6
4. The Commissions rules require STS CAs to stay with the call for at least 15 minutes 
before transferring the call to another CA.7 The Commission explained that although CAs handling text-
to-voice calls must stay with the call for at least 10 minutes, a longer minimum for STS calls was 
appropriate because changing CAs can be particularly disruptive to users with speech disabilities.8 The 
Commission noted that during the initial stages of a relay call there is a settling-in period, and that 
during this time callers with speech disabilities develop greater assurance that the CA will understand 
  
3 See Hawk Relay, Request for Expedited Clarification for the Provision and Cost Recovery of Internet Protocol 
Speech to Speech Relay Service, CG Docket No. 08-15, (filed Dec. 21, 2007) (Hawk Relay Request).  The Hawk 
Relay Request was moved from CG Docket No. 03-123 to a newly created docket for all STS (including IP STS) 
matters, CG Docket No. 08-15.  See 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, Public Notice, 23 FCC Rcd 1649, 1650, at n.7 
(Feb. 4, 2008) (IP STS PN).
4 See 2000 TRS Report and Order, 15 FCC Rcd at 5148-51, paras. 14-20.
5 See id. at 5148, para. 14; 47 C.F.R.  64.601(12).
6 See 47 U.S.C.  225(d)(3); see also 47 C.F.R.  64.604(c)(5)(i) & (ii).  No specific funding method is required for 
intrastate TRS or state TRS programs.  States generally recover the costs of intrastate TRS either through rate 
adjustments or surcharges assessed on all intrastate end users, and reimburse TRS providers directly for their 
intrastate TRS costs.  We note that in recent months interstate STS minutes of use have averaged between 13,000-
15,000 per month.  This is substantially less than the corresponding minutes of use for the other forms of TRS.  See 
www.neca.org/source/NECA_Resources_4285.asp (monthly reports indicating interstate minutes of use for all 
forms of TRS).  
7 2000 TRS Report and Order, 15 FCC Rcd at 5169-70, paras. 68-70; 47 C.F.R.  64.604(a)(1)(v).  
8 2000 TRS Report and Order, 15 FCC Rcd at 5170, para. 70.
Federal Communications Commission FCC 08-149
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them, and that [r]otation of a CA during an STS call disrupts this assurance, and may even cause the 
user to speak less clearly.9  
5. In the 2000 711 TRS Dialing Order, the Commission adopted nationwide 711 dialing 
access to allow both persons with hearing and speech disabilities and voice telephone users to initiate a 
TRS call from any telephone, anywhere in the United States, and be connected to the TRS facility serving 
that calling area.10 Subsequently, the Commission sought comment on whether it should adopt a separate 
three digit access number specifically for STS.11 In the 2003 TRS Order, the Commission declined to do 
so, concluding that calling 711 provided adequate means for STS consumers to reach an STS CA.12 The 
Commission explained that in any 711 call, the CA has to route and/or set up the call according to the 
form of TRS (i.e., STS) or type of TRS call requested, and that to the extent STS calls are not reaching 
STS CAs in an appropriate fashion, the TRS provider may have to provide additional CA training, deploy 
advanced technologies, or offer multiple dialing options.13  
6. The Commission also addressed whether access to STS could be improved by using a 
dialing menu, e.g., an Interactive Voice Response (IVR), with STS being the first option in the voiced 
dialing menu.14 The Commission noted that [i]n this way, STS users would simply need to press the 
first key indicated to make their type of call selection, such as STS.15 Although the Commission 
declined to adopt such a requirement, the Commission stated that it would continue to monitor the 
implementation of 711 dialing access for TRS calls (including STS calls) and encouraged TRS facilities 
to be innovative in finding ways to facilitate access to relay services.16
B. New STS Issues
7. On June 26, 2006, Bob Segalman and Rebecca Ladew filed a petition requesting that the 
Commission amend its rules to require an STS CA to stay with the call for a minimum of twenty minutes, 
rather than 15 minutes.17 Petitioners assert that because STS calls often last much longer than text-to-
voice calls[,] changing CAs on these calls prior to twenty minutes can seriously disrupt their flow and 
impair functionally equivalent telephone service.18 Petitioners explain that it generally takes a few 
minutes for a CA to begin to maximize his or her understanding of the speech patterns of a particular 
person with a speech disability.19 Petitioners further explain because CAs often have trouble 
understanding peoples names and unusual technical words, persons with speech disabilities have to spell 
  
9 Id.
10 Use of N11 Codes and Other Abbreviated Dialing Arrangements, CC Docket No. 92-105, Report and Order, 15 
FCC Rcd 15188 (Aug. 9, 2000) (2000 711 TRS Dialing Order).  711 dialing access for TRS became effective on 
October 1, 2001.  See id. at 15204, para. 32.
11 2000 TRS Report and Order, 15 FCC Rcd at 5192, para. 126. 
12 Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, CC Docket No. 98-67, CG Docket No. 03-123, Second Report and Order, Order on Reconsideration, 
and Notice of Proposed Rulemaking, 18 FCC Rcd 12379, 12410-11, para. 51 (June 17, 2003) (2003 TRS Order).
13 Id.  
14 Id. at 12411, para. 52.
15 Id.  
16 Id. at 12411-12, para. 53.  
17 STS Petition at 1.
18 Id. at 3.
19 Id. at 2.
Federal Communications Commission FCC 08-149
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out these words.20 Further, Petitioners note that persons with speech disabilities require a greater amount 
of time and concentration to perform the tasks of listening to the other party, thinking, forming a 
response, and then speaking.21 Given these factors, Petitioners contend that changing CAs during a call 
both disrupts the STS users concentration and requires the new CA to become familiar with the STS 
users speech pattern, thereby impeding the conversation.22 Petitioners add that because reducing the 
frequency of CA changes will result in calls being processed more efficiently, the average cost of the calls 
will be less.23
8. Petitioners also request that the Commission specify that the 20 minute period begins 
when effective communication begins between the STS user and the CA.24 Specifically, petitioners 
request that the Commission mandate that a call may not be transferred to a new CA until at least 20 
minutes have passed after the caller established effective communication with the CA.25
9. In addition, we have received anecdotal information concerning two other STS issues.  
First, we understand that some STS providers offer the STS user the option to have his or her voice muted
so that the other party to the call only hears the CA re-voicing the call.  We also understand that many 
STS users prefer that their voice not be passed through to the other party to the call because it can be 
distracting.  Second, the Commission has received several reports from STS users that they have been 
disconnected after dialing 711 when the CA attempts to transfer the caller to an STS CA.  These incidents 
may suggest that some TRS CAs are not properly trained or equipped to receive and transfer STS calls to 
an STS CA.  
C. IP STS
10. On December 21, 2007, Hawk Relay filed a request for clarification that IP STS is a form 
of TRS eligible for compensation from the Fund.  Hawk Relay describes IP STS as a type of STS that 
uses the Internet, rather than the PSTN, to connect the consumer to the relay provider.26 Hawk Relay 
explains that instead of using a standard telephone to make the relay call, an IP STS user can use a 
personal computer or personal digital assistant (PDA) device and, with the installation of softphone 
application software, can make a voice call via the Internet to the relay provider.27 As Hawk Relay 
describes an IP STS call, the call is initiated by the user clicking on an icon on his or her computer or 
PDA; the relay user is then connected to a CA over the Internet and tells the CA the number to be dialed; 
the CA then connects the IP STS user with the called party and relays the call between the two parties.28  
Hawk Relay asserts that IP STS offers several benefits over PSTN-based (or traditional) STS, including 
portability (the computer or PDA is not tied to a specific location); ease of use, particularly for persons 
  
20 Id.
21 Id.
22 Id.
23 Id.
24 Id. at 2-3.  The current rule states that the CA answering and placing an STS call must stay with the call for a 
minimum of fifteen minutes.  47 C.F.R.  64.604(a)(1)(v).    
25 STS Petition at 3.
26 Hawk Relay Request at 3 (IP STS is no different than traditional STS except  that the user connects to a relay 
provider through the Internet).
27 Id. at 2-3.  The computer or PDA must have a microphone and speaker.  Id. at 3.  
28 Id. at 3.
Federal Communications Commission FCC 08-149
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with limited dexterity (the user does not have to dial a number, but can just click on one icon, to initiate a 
call); and increased competition that will promote further innovation among relay providers.29  
11. Hawk Relay states that, as an extension of traditional STS, IP STS falls within the 
scope of TRS under Title IV because it allows persons with speech disabilities to access the telephone 
system to communicate by wire or radio.30 Hawk Relay also notes that Title IV mandates that the 
Commission ensure that it do[es] not discourage or impair the development of improved technology.31  
Hawk Relay notes that, consistent with this mandate, the Commission has previously recognized new 
forms of TRS, including other Internet-based forms of TRS  Video Relay Service,32 Internet Protocol 
(IP) Relay,33 and IP Captioned Telephone Service (IP CTS).34 Further, Hawk Relay requests that IP STS 
calls be eligible for compensation from the Fund.  Hawk Relay does not address, however, whether all IP 
STS calls should be compensated from the Fund (i.e., both interstate and intrastate), and does not suggest 
what the appropriate IP STS compensation rate should be, or whether it should be different from the 
interstate STS rate.  Finally, Hawk Relay requests that certain TRS mandatory minimum standards be 
waived for IP STS because they have been waived for STS.35  
12. The Hawk Relay Request was placed on Public Notice,36 and one comment and one reply 
comment were filed.37 Both commenters support the request that the Commission recognize IP STS as a 
form of TRS compensable from the Fund.38 In addition, both commenters agree that the Fund should 
compensate all IP STS calls because, as is the case with the other Internet-based forms of TRS, it is 
presently not technologically feasible to determine which calls are interstate and which are intrastate.39  
  
29 Id. at 3-5.
30 Id. at 5; see 47 U.S.C.  225(a)(3).
31 Hawk Relay Request at 5; see 47 U.S.C.  225(d)(2).
32 Video Relay Service (VRS) is a form of TRS that enables the VRS user and the CA to communicate via a video 
link in sign language, rather than through text.  VRS presently requires a broadband Internet connection.  See 2000 
TRS Report and Order, 15 FCC Rcd at 5152-54, paras. 21-27 (recognizing VRS as a form of TRS); 47 C.F.R.  
64.601(17) (defining VRS). 
33 IP Relay is a text-based form of TRS that uses the Internet, rather than the PSTN, for the link of the call between 
the relay user and the CA.  See Provision of Improved Telecommunications Relay Services and Speech-to-Speech 
Services for Individuals with Hearing and Speech Disabilities, CC Docket No. 98-67, Declaratory Ruling and 
Second Further Notice of Proposed Rulemaking, 17 FCC Rcd 7779 (Apr. 22, 2002) (IP Relay Declaratory Ruling).  
34 IP Captioned Telephone Service (IP CTS) is a form of CTS where the connection carrying the captions between 
the relay provider and the user is via the Internet, rather than the PSTN.  See generally Telecommunications Relay 
Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CC Docket No. 98-
67, Declaratory Ruling, 18 FCC Rcd 16121 (Aug. 1, 2003) (Captioned Telephone Declaratory Ruling); 
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities; Internet-based Captioned Telephone Service, CG Docket No. 03-123, Declaratory Ruling, 22 FCC Rcd 
379 (Jan. 11, 2007) (2007 IP CTS Declaratory Ruling). IP CTS is compensated at the same rate as CTS.  
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, CG Docket No. 03-123, Report and Order and Declaratory Ruling, 22 FCC Rcd 20140, 20158, para. 38 
(Nov. 19, 2007) (2007 TRS Cost Recovery Order).
35 Hawk Relay Request at 6; see 47 C.F.R.  64.604 (TRS mandatory minimum standards).  
36 IP STS PN. 
37 Comments were filed by Speech Communications Assistance by Telephone, Inc. (May 8, 2008) (SCAT 
Comments), and reply comments were filed by American Network, Inc. (May 22, 2008) (American Network Reply 
Comments).
38 SCAT Comments at 3; American Network Reply Comments at 2. 
39 SCAT Comments at 3-4; American Network Reply Comments at 4.
Federal Communications Commission FCC 08-149
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Speech Communications Assistance by Telephone, Inc. (SCAT) also suggests that the compensation rate 
for IP STS should be high enough to give providers the incentive to identify and recruit users, to 
reimburse providers for giving computers and other equipment to the users, and to pay for up to ten home 
visits per consumer to instruct the consumers on how to use the service.40 In addition, American Network 
agrees with Hawk Relay that certain waivers of the TRS mandatory minimum standards are appropriate.41
D. Other STS and IP STS Issues
13. SCAT asserts that STS outreach efforts have not been adequate to identify and reach all 
potential users.42 SCAT notes that the majority of STS calls are intrastate, and that state STS rates have 
generally been below cost and not adequate to support sufficient outreach.43 SCAT therefore requests that 
the Commission require states to increase their STS compensation rate to ensure that STS is made 
available to all users.44 In addition, because of the relatively low volume of STS calls, SCAT suggests 
that there should be only one national provider and one call center that serves the whole country.45  
III. DISCUSSION
A. STS Issues
14. We seek comment on whether the Commission should amend the TRS regulations to 
require that an STS CA must stay with the call for a minimum of twenty minutes, rather than the present 
minimum of fifteen minutes.  Specifically, we seek comment on the advantages and disadvantages of 
such a rule change, or whether some other minimum time period should be adopted.  We also seek 
comment on alternative approaches or additional requirements the Commission might adopt to ensure the 
effective and efficient relaying of STS calls.
15. We also seek comment on whether we should more specifically define the point at which 
the minimum time period begins to run, e.g., when effective communication takes place between the 
STS user and the CA, regardless of whether we extend the minimum time period a CA must stay with an 
STS call.  We further seek comment on what criteria should be used to determine when effective 
communication begins and who would make that determination.
16. In addition, we seek comment on whether the Commission should amend its TRS rules to 
require that STS providers offer the STS user the option of having her or his voice muted so that the other 
party to the call would only hear the STS CA re-voicing the call, not the voice of the STS user as well.  
We understand that presently some STS providers voluntarily offer this option, and that many STS users 
  
40 SCAT Comments at 4-5.  SCAT states that the rate should be possibly higher than the VRS reimbursement rate.  
Id. at 5.
41 American Network Reply Comments at 5.
42 See Ex Parte filed by SCAT (June 4, 2008) at 1 (SCAT Ex Parte).
43 See Comments of Speech Communications Assistance by Telephone, Inc. (SCAT) (May 14, 2008) (filed in 
response to the Public Notice seeking comment on proposed 2008-2009 interstate TRS compensation rates; National 
Exchange Carrier Association (NECA) Submits the Payment Formula and Fund Size Estimate for the Interstate 
Telecommunications Relay Services (TRS) Fund for the July 2008 Through June 2009 Fund Year, CG Docket No. 
03-123, Public Notice, DA 08-1055 (May 2, 2008) (SCAT Rate Comments) (asserting that providers often take a 
big loss on STS in order to obtain a statewide TRS contract). 
44 SCAT Rate Comments.
45 SCAT Comments at 6.
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prefer that their voice not be passed through to the other party to the call because it can be distracting and 
make the call flow less smoothly.
17. Finally, we seek comment on ways we can ensure that STS users calling 711 will 
promptly reach an STS CA to handle their calls.  We recognize that 711 dialing procedures vary from 
state to state, and that some relay providers use prompts so that the caller can indicate the type of call the 
caller desires to make.  We seek comment on the feasibility of requiring TRS providers to use a prompt or 
menu that would permit STS callers to indicate that they would like to reach an STS CA.  For example, 
after an STS caller dials 711 and reaches the provider, the caller could be directed to press one additional 
number on the telephone to reach an STS CA.  Although, as noted above, the Commission addressed this 
issue in the 2003 TRS Order and declined to adopt this requirement at that time, it also stated that it would 
monitor the implementation of 711 dialing access.46 Because we have received complaints that STS users 
have been disconnected after dialing 711 when the CA attempts to transfer the caller to an STS CA, we 
seek comment, first, on the scope of the problem of STS callers being disconnected before reaching an 
STS CA.  We also seek comment on ways by which we can ensure that STS users will promptly reach an 
STS CA without being disconnected, including through the use of menus or prompts that would direct 
STS callers to an STS CA.    
B. IP STS
18. We tentatively conclude that IP STS is a form of TRS compensable from the Interstate 
TRS Fund because it is an extension of STS that gives persons with speech disabilities an alternative way 
to initiate an STS call and reach a CA.47 We note that IP STS allows persons with speech disabilities to 
use a computer or PDA connected to the Internet, rather than a standard telephone connected to the 
PSTN, to initiate a call and speak with the CA.  In this regard, IP STS borrows from both the STS and IP 
Relay services that the Commission has previously recognized as forms of TRS.  Like STS, an IP STS 
CA listens to what the STS caller says and then re-voices what was said to the other party of the phone.  
Like IP Relay, the consumer is connected to the relay provider via the Internet, not the PSTN.  We seek 
comment on this tentative conclusion.  We also tentatively conclude that a service will be considered IP 
STS as long as it allows the STS user to connect to the CA via a computer, PDA, or similar device and 
the Internet, rather than by making a traditional telephone call.48 We also seek comment on these 
tentative conclusions.  
19. We also tentatively conclude that all IP STS calls may be compensated from the Fund if 
provided in compliance with the Commissions rules.49 We note that this is consistent with the present 
treatment of the other Internet-based forms of TRS  VRS, IP Relay, and IP CTS  and the fact that 
because one link of the call is made via the Internet it is generally not possible to determine if a particular 
  
46 2003 TRS Order, 18 FCC Rcd at 12411-12, paras. 52-53. Because at that time 711 dialing was relatively new, 
and some states were offering a dialing menu that facilitated access to STS, the Commission stated that as it 
continue[s] to monitor the implementation of universal nationwide 711 dialing access for all types of TRS calls, [it] 
will also monitor the utilization of dialing menus for access to STS.  Id. at para. 53.
47 See Hawk Relay Request at 5; American Network Reply Comments at 3.
48 See Captioned Telephone Declaratory Ruling, 18 FCC Rcd at 16127, para. 17 (to avoid authorizing a particular 
proprietary technology, rather than a particular functionality or service, we define the captioned telephone . . . 
service that we recognize as TRS in this Declaratory Ruling as any service that uses a device that allows the user to 
simultaneously listen to, and read the text of, what the other party has said, on one standard telephone line.  TRS 
providers, therefore, that may choose to offer captioned telephone . . . service are not bound to offer any particular 
companys service).  
49 See SCAT Comments at 4; American Network Reply Comments at 4.
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call is interstate or intrastate.50 We also believe this arrangement will be an incentive for multiple 
providers to offer this service on a nationwide basis, generating competition that will enhance consumer 
choice, service quality, and available features.51 We seek comment on this tentative conclusion.  
20. Further, we tentatively conclude that IP STS will be compensated at the same per-minute 
rate as STS, and seek comment on this tentative conclusion.52 We note that neither the Hawk Relay 
Request nor the comments specifically suggest a different rate.  Hawk Relay is silent on this issue, and 
American Network suggests that the traditional STS rate should apply.53 Although SCAT suggests that 
the rate should be possibly higher than the VRS reimbursement rate (currently ranging from $6.30 to 
$6.77 per minute) to cover the costs of consumer equipment and home visits for training,54 we note that 
the Commission has made clear that the costs of customer equipment, equipment distribution, and 
installation of the equipment or any necessary software is not compensable from the Fund.55 We also 
note that the conclusion to compensate IP STS at the STS rate is consistent with our treatment of CTS and 
IP CTS rates, which pursuant to the 2007 TRS Cost Recovery Order are the same.56 At the same time, we 
also seek comment on whether differences in the way IP STS and STS are provided or used warrants
different compensation rates for these services.
21. In the TRS Provider Certification Order, the Commission adopted a means by which 
common carriers seeking to offer IP Relay or VRS may seek Commission certification as an eligible 
provider.57 The Commission noted that the present eligibility criteria for compensation from the Fund set 
forth in the Commissions rules58 do not reflect advances in the way that TRS is offered, particularly with 
respect to the Internet-based forms of TRS.  As a result, the Commission adopted a Commission 
certification alternative that would permit common carriers desiring to offer VRS and/or IP Relay, and not 
the other forms of TRS, to receive compensation from the Fund.59 This process is described in that order 
and the Commissions rules.60  
  
50 See IP Relay Declaratory Ruling, 17 FCC Rcd at 7779, para.1; see also id. at 7786, paras. 20-22.
51 See 2007 IP CTS Declaratory Ruling, 22 FCC Rcd at 390, para. 25.
52 Pursuant to the 2007 TRS Cost Recovery Order, STS is compensated at the MARS rate applicable to both 
traditional TRS and STS based on the weighted average of state rates. 2007 TRS Cost Recovery Order, 22 FCC Rcd 
at 20165-66, paras. 57-61. The rate is presently $2.723, which applies through June 30, 2008.  
53 American Network Reply Comments at 4.
54 SCAT Comments at 4.
55 See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, CG Docket No. 03-123, Memorandum Opinion and Order, 21 FCC Rcd 8063, 8071, para. 17 (July 12, 
2006).
56 See 2007 TRS Cost Recovery Order, 22 FCC Rcd at 20158, para. 38.
57 See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, CG Docket No. 03-123, Report and Order and Order on Reconsideration, 20 FCC Rcd 20577, 20586-
90, paras. 17-26 (Dec. 12, 2005) (TRS Provider Certification Order).
58 See 47 C.F.R.  64.604(c)(5)(iii)(F)(3) (setting forth three eligibility categories for TRS providers seeking 
compensation from the Fund). As the Commission has explained, these categories include being part of a certified 
state program, contracting with an entity that is part of a certified state program, or being a common carrier 
obligated to provide TRS in a state that does not have a certified state program.  TRS Provider Certification Order, 
20 FCC Rcd at 20586-87, paras. 18-19.
59 TRS Provider Certification Order, 20 FCC Rcd at 20586, para. 17.
60 Id., 20 FCC Rcd at 20588-90, paras. 22-26; 47 C.F.R.  64.605.
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22. In the 2007 IP CTS Declaratory Ruling, we concluded that entities desiring to offer IP 
CTS could become eligible for compensation from the Fund by seeking Commission certification under 
the certification rules.61 The Commission stated that potential IP CTS providers may become eligible for 
compensation from the Fund by being accepted into a certified state TRS program or subcontracting with 
an entity that is part of a certified state program, or by seeking Commission certification.62 The 
Commission also emphasized that [p]resent eligibility to receive compensation from the Fund for the 
provision of other forms of TRS (including captioned telephone service) does not confer eligibility with 
regard to the provision of the IP CTS.63
23. We tentatively conclude that an entity desiring to provide IP STS may choose to seek 
certification from the Commission under the certification rules.  Therefore, as with IP CTS, potential IP 
STS providers could become eligible for compensation from the Fund by being accepted into a certified 
state TRS program or subcontracting with an entity that is part of a certified state program,64 or by 
seeking Commission certification.  Therefore, we also tentatively conclude that present eligibility to 
receive compensation from the Fund for the provision of other forms of TRS (including STS) would not 
confer eligibility with regard to the provision of the IP STS.   We seek comment on these tentative 
conclusions.
24. Next, we seek comment on those mandatory minimum standards that are either 
inapplicable to IP STS or should be waived for IP STS.  We tentatively conclude that providers of IP STS 
need not, at this time, meet the following requirements:  (1) competent skills in typing and spelling for 
CAs65; (2) handling calls in ASCII and Baudot formats66; (3) call release67; (4) Hearing Carry Over 
(HCO) and Voice Carry Over (VCO) services68; (5) equal access to interexchange carriers69; (6) pay-per-
  
61 2007 IP CTS Declaratory Ruling, 22 FCC Rcd at 391, para. 28; 47 C.F.R.  64.605. 
62 2007 IP CTS Declaratory Ruling, 22 FCC Rcd at 391, para. 28 (internal footnote omitted).
63 Id.; see also Consumer & Governmental Affairs Bureau Clarifies the Eligibility Requirement for Compensation
from the Interstate Telecommunications Relay Service (TRS) Fund for Providers of Internet Protocol Captioned 
Telephone Service, CG Docket No. 03-123, Public Notice, 23 FCC Rcd 2889 (Feb. 28, 2008).
64 If eligibility is established via a certified state program, the state program must notify the Commission within 60 
days of substantive changes in their program.  See 47 C.F.R.  64.605(f)(1).  
65 See 47 C.F.R.  64.604(a)(ii)& (iii).  This includes the requirement that CAs must provide a typing speed of a 
minimum of 60 words per minute, which does not apply to IP STS.  Relaying an IP STS call would not involve 
typing.
66 Providers of traditional TRS (i.e., text-based TRS calls made via a TTY and the PSTN) must ensure that the TTY 
can communicate in either the ASCII or Baudot formats.  See 47 C.F.R.  64.601(3) & (4); 64.604(b)(1).  TTYs are 
not used in STS calls.   
67 Call release is a TRS feature that allows the CA to drop from the call after the CA has set up a telephone call 
between two TTY users.  See 47 C.F.R.  64.601(5).  Call release is waived for IP Relay until January 1, 2009.  See 
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, CG Docket No. 03-123, Order, 22 FCC Rcd 21869, 21873, para. 11 (Dec. 26, 2007) (2007 Waiver 
Extension Order).
68 VCO permits a person with a hearing disability, but who is able to speak, to speak directly to the other party to the 
call (instead of typing text), but receive in return the called partys spoken words as text on the TTY.   See 47 C.F.R. 
 64.601(18).  HCO permits a person with a speech disability, but who is able to hear, to type text to the other party 
to the call (which is voiced by the CA), but listen in return to what the called party is saying.  See 47 C.F.R.  
64.601(8).  VCO and HCO services are waived for IP Relay until January 1, 2009.  See 2007 Waiver Extension 
Order, 22 FCC Rcd at 21871-73, paras. 6-9.  
69 This requirement requires providers to relay long distance calls through the consumers choice of interexchange 
carrier.  See 47 C.F.R.  64.604(b)(3).  This requirement is waived permanently for IP Relay, provided that IP Relay 
providers offer free long distance service to their customers.  See 2004 TRS Report and Order, 19 FCC Rcd at 
(continued....)
Federal Communications Commission FCC 08-149
10
call (900) service70; (7) speed dialing71; and (8) outbound 711 dialing.72 We also tentatively conclude that 
for those waivers presently contingent on annual reporting requirements, providers of IP STS must also 
file such reports.73 We seek comment on these tentative conclusions.
25. Finally, we seek comment on the emergency call handling rules that should apply to IP 
STS.  We note that in March 2008, the Commission adopted an order requiring Internet-based TRS 
providers to accept and handle such calls in accordance with the requirements outlined in that order. 74  
On June 11, 2008, however, the Commission adopted more comprehensive emergency call handling 
requirements for VRS and IP Relay.75 We seek comment on whether the requirements in the 2008 
Emergency Call Handling Order or the requirements in the 2008 TRS Numbering Order should apply to 
IP STS, or whether some other rules should apply.  Should, for example, IP STS users be required to 
register their location for purposes of emergency call handling?  Relatedly, we seek comment on whether, 
pursuant to the 2008 TRS Numbering Order, IP STS users be required to obtain a ten-digit NANP 
telephone number so that traditional telephone users can call an IP STS user by dialing that number and 
without knowing the IP STS users current IP address?  Assuming these requirements should apply to IP 
STS users, we seek comment on whether they should be modified in the context of IP STS and, if so, 
how.
C. Other STS and IP STS Issues
26. Outreach.  Comments reflect concern that outreach efforts with respect to STS have not 
been adequate to identify and reach potential STS users.76 In addition, SCAT has noted that the majority 
of STS calls are intrastate and that the state STS rates are generally below actual costs, and that therefore 
  
(...continued from previous page)
12524-25, paras. 124-27, and 12594, Appendix E (waiver chart).  We tentatively conclude that the same approach 
should apply with respect to IP STS.    
70 Pay-per-call (900) services are calls that include a charge billed to the calling party.  See 47 C.F.R.  
64.604(a)(3)(iv).  This requirement is waived for IP Relay until January 1, 2009.  See 2007 Waiver Extension Order, 
22 FCC Rcd at 21873-74, paras. 12-13. 
71 Speed dialing allows a TRS user to place a call using a stored number maintained by the TRS provider.  The TRS 
user gives the CA a short-hand name or number for the users most frequently called telephone numbers.  See 47 
C.F.R.  64.601(13).  This requirement is waived for IP Relay until January 1, 2009.  See 2007 Waiver Extension 
Order, 22 FCC Rcd at 21875-76, paras. 20-21. 
72 Outbound 711 dialing permits TRS users to dial 711 to reach a relay provider.  We tentatively conclude that to the 
extent an IP STS user initiates a call only via the Internet and a direct link to the provider, and not by dialing a 
telephone number, this requirement would be inapplicable to the service.
73 See generally 2004 TRS Report and Order, 19 FCC Rcd at 12594, Appendix E (waiver chart and also addressing 
filing of annual reports); see also id. at 12520-21, para. 111 (detailing required contents of annual report).
74 See generally Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing 
and Speech Disabilities, E911 Requirements for IP-Enabled Service Providers, CG Docket No. 03-123, WC Docket 
No. 05-196, Report and Order, 23 FCC Rcd 5255, 5259-63, paras. 8-12 (Mar. 19, 2008) (2008 Emergency Call 
Handling Order).  The Commission required the providers to, in part:  (1) accept emergency calls and deliver them 
to an appropriate PSAP that corresponds to the callers location; (2) request, at the beginning of an emergency call, 
the callers location; (3) implement a system so that incoming emergency calls are given priority handling if there is 
a queue.  Id. at 5265, para. 16.
75 See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, E911 Requirements for IP-Enabled Service Providers, Report and Order and Further Notice of 
Proposed Rulemaking, CG Docket No. 03-123, WC Docket No. 05-196, FCC 08-151 (adopted June 11, 2008)
(2008 TRS Numbering Order).  
76 See SCAT Ex Parte at 1.
Federal Communications Commission FCC 08-149
11
the intrastate providers lack sufficient funding to do the outreach that is necessary to reach the large 
number of potential STS users.77 SCAT has therefore requested that the Commission require the states to 
increase their STS compensation rates to ensure that STS is made available to all potential users.78 We 
seek comment on this request.  In particular, does the Commission have the authority to require individual
states to increase the compensation rates paid for intrastate STS?79 In addition, we seek comment on 
other steps we might take to ensure that all STS providers receive sufficient compensation to engage in 
sufficient outreach to inform new potential users of this service.
27. We also seek comment on specific outreach efforts that might extend the reach of STS 
(and possibly IP STS) to new users, and whether we should mandate such specific efforts of both 
intrastate and interstate providers.80 We also seek comment on whether use of the MARS rate for STS 
(and possibly IP STS), as currently provided, is inadequate to compensate providers for the level of 
outreach necessary to reach potential STS users.  We note that in the 2007 TRS Cost Recovery Order the 
Commission added an additional sum to the STS rate to be used by providers for outreach.81 We seek 
comment on this approach, the appropriate amount of such an additional amount, and whether such 
outreach should be funded through an adjustment to the per-minute compensation rate or in some other 
way.  More generally, we seek comment on any other issue relating to the funding of outreach for STS 
(and possibly IP STS) and specific types of outreach that would be most effective.
28. One Nationwide STS Provider.  A commenter has suggested that, given the relatively low 
usage of STS (compared to the other forms of the TRS), it might be appropriate to have a single, 
nationwide provider offer both interstate and intrastate STS.82 We seek comment on this suggestion.  As 
a threshold matter, we seek comment on whether the Commission would have the authority to mandate 
such an approach to the provision of service, given that section 225 places the obligation on carriers to 
provide TRS and on states to oversee the provision of intrastate TRS.83 If the Commission does have 
jurisdiction to adopt this approach, we seek comment on the merits of doing so as opposed to the present 
arrangement for the provision of service (i.e., each state selects one or more intrastate provider for the 
state, and that provider also offers interstate service).  In addition, how would we select such a provider?  
Finally, assuming we recognize IP STS as a form of TRS, we seek comment on whether the nationwide 
provider would offer both IP STS and STS, or just STS.
IV. PROCEDURAL MATTERS
29. Comments and Reply Comments. Pursuant to sections 1.415, 1.419, and 1.430 of the 
Commissions rules, 47 C.F.R.  1.415, 1.419, 1.430, interested parties may file comments and reply 
comments on or before the dates indicated on the first page of this document.  All filings should refer to 
CG Docket No. 03-123 and CG Docket No. 08-15.  Comments may be filed using the Commissions 
  
77 See SCAT Rate Comments.
78 See id.
79 See 47 U.S.C.  225(d)(3) (Jurisdictional separation of costs).
80 We note that to the extent specific outreach steps are mandated, providers would be entitled to compensation for 
those costs.
81 2007 TRS Cost Recovery Order, 22 FCC Rcd at 20166, para. 61.
82 See SCAT Comments at 6 (suggesting that because the STS user population is so small, there should be only one 
national provider and call center to serve the country).
83 See 47 U.S.C.  225(c); 2004 TRS Report and Order, 19 FCC Rcd at 12481, para. 6 (addressing state regulation of 
intrastate TRS).
Federal Communications Commission FCC 08-149
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Electronic Comment Filing System (ECFS) or by filing paper copies.84 For additional information on this 
proceeding, please contact Gregory Hlibok in the Consumer & Governmental Affairs Bureau, at 
Gregory.Hlibok@fcc.gov or (800) 311-4381(voice).
30. Comments filed through the ECFS can be sent as an electronic file via the Internet to 
http://www.fcc.gov/cgb/ecfs/.  Filers should follow the instructions provided on the website for 
submitting comments.  Because multiple docket numbers appear in the caption of this proceeding, 
commenters must transmit one electronic copy of the comment to each docket number referenced in the 
caption, which in this instance are CG Docket No. 03-123 and CG Docket No. 08-15.  For each 
transmittal, commenters also should include their full name and postal service mailing address.  Parties 
also may submit electronic comments by Internet e-mail.  To obtain filing instructions for e-mail 
comments, commenters should send an e-mail to ecfshelp@fcc.gov, and should include the following 
words in the body of the message:  get form <your e-mail address>.  A sample form and instructions 
will be sent in reply.  You also may obtain a copy of the ASCII Electronic Transmittal Form (FORM-ET) 
at <http://www.fcc.gov/e-file/email.html>.  Parties who choose to file by paper must file an original and 
four copies of each filing.  Filings can be sent by hand or messenger delivery, by commercial overnight 
courier, or by first-class or overnight U.S. Postal Service mail (although we continue to experience delays 
in receiving U.S. Postal Service mail).
31. For hand deliveries, the Commission's contractor, Natek, Inc., will receive hand-delivered 
or messenger-delivered paper filings 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 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 12th Street, SW, 
Washington, D.C. 20554.  All filings must be addressed to the Commissions Secretary, Office of the 
Secretary, Federal Communications Commission.
32. Comments and reply comments must include a short and concise summary of the 
substantive discussion and questions raised in the Notice.  We further direct all interested parties to 
include the name of the filing party and the date of the filing on each page of their comments and reply 
comments.  We strongly encourage that parties track the organization set forth in this Notice in order to 
facilitate our internal review process.  Comments and reply comments must otherwise comply with 
section 1.48 and all other applicable sections of the Commissions rules.85  
33. To request materials in accessible formats (such as Braille, large print, electronic files, or 
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 Notice can also be downloaded in Word and Portable 
Document Format at <http://www.fcc.gov/cgb/dro>. 
34. Ex Parte Rules. This matter shall be treated as a permit-but-disclose proceeding in 
accordance with the Commissions ex parte rules.86 Persons making oral ex parte presentations are 
reminded that memoranda summarizing the presentations must contain summaries of the substance of the 
presentations and not merely a listing of the subjects discussed.  More than a one or two sentence 
  
84 See Electronic Filing of Documents in Rulemaking Proceedings, 13 FCC Rcd 11322, 11324-26, paras. 4-9 (Apr. 
6, 1998).  
85 See 47 C.F.R.  1.48.
86 47 C.F.R.  1.1200 et seq.
Federal Communications Commission FCC 08-149
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description of the views and arguments presented is generally required.87 Other requirements pertaining 
to oral and written presentations are set forth in section 1.1206(b) of the Commissions rules.
35. Regulatory Flexibility Certification.  As required by the Regulatory Flexibility Act of 
1980 (RFA),88 the Commission has prepared an Initial Regulatory Flexibility Certification of the possible 
significant economic impact on small entities of the policies and rules addressed in this document.  The 
certification is set forth in Appendix.
36. Paperwork Reduction Act of 1995 Analysis. This document does not contain proposed 
information collection(s) subject to the Paperwork Reduction Act of 1995 (PRA), Public Law 104-13.  In 
addition, therefore, it does not contain any new or modified information collection burden for small 
business concerns with fewer than 25 employees, pursuant to the Small Business Paperwork Relief Act 
of 2002, Public Law 107-198, see 44 U.S.C.  3506(c)(4).
V. ORDERING CLAUSES
37. Accordingly, IT IS ORDERED that, pursuant to sections 1, 4(i) and (o), 225, 255, 303(r), 
403, 624(g), and 706 of the Communications Act of 1934, as amended, 47 U.S.C.  151, 154(i) and (o), 
225, 255, 303(r), 403, 554(g), and 606, this Notice of Proposed Rulemaking IS ADOPTED.
38. IT IS FURTHER ORDERED that this Notice of Proposed Rulemaking SHALL BE 
EFFECTIVE 30 days after publication in the Federal Register.
39. IT IS FURTHER ORDERED that the Commission's Consumer & Governmental Affairs 
Bureau, Reference Information Center, SHALL SEND a copy of this Notice of Proposed Rulemaking, 
including the Initial Regulatory Flexibility Certification, to the Chief Counsel for Advocacy of the Small 
Business Administration.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch  
Secretary
  
87 See 47 C.F.R.  1.1206(b)(2).
88 See 5 U.S.C.  604.
Federal Communications Commission FCC 08-149
APPENDIX
Initial Regulatory Flexibility Certification
1. The Regulatory Flexibility Act of 1980, as amended (RFA),1 requires that an initial 
regulatory flexibility analysis be prepared for notice-and-comment rulemaking proceedings, unless the 
agency certifies that the rule will not, if promulgated, have a significant economic impact on a 
substantial number of small entities.2 The RFA generally defines the term small entity as having the 
same meaning as the terms small business, small organization, and small governmental 
jurisdiction.3 In addition, the term small business has the same meaning as the term small business 
concern under the Small Business Act.4 A small business concern is one that: (1) is independently 
owned and operated; (2) is not dominant in its field of operation; and (3) satisfies any additional criteria 
established by the Small Business Administration (SBA).5
2. In the Notice of Proposed Rulemaking, the Commission seeks comment on issues 
concerning the provision of STS and IP STS.  The Commission proposes requiring an STS CA to stay 
with the call for a minimum of 20 minutes, rather that the present minimum of 15 minutes, in order to 
ensure the effective and efficient relaying of STS calls.  The Commission also proposes amending its TRS 
rules to require that STS providers offer the STS user the option of having her or his voice muted so that 
the other party to the call would only hear the STS CA re-voicing the call, not the voice of the STS user 
as well.  In this Notice, the Commission provisionally proposes that the STS provider should be required 
to utilize an interactive menu that provides, as the first option, reaching an STS CA in order to ensure that 
STS users calling 711 will promptly reach an STS CA to handle their calls.  For instance, after an STS 
caller dials 711 and reaches the provider, the caller would reach an STS CA by pressing one additional 
number on the telephone.  Finally, the Commission invites comment on its tentative conclusion that IP 
STS is a form of TRS eligible for compensation from the Interstate TRS Fund.    
3. The Commission concludes that these proposed changes may be necessary to improve the 
effectiveness and quality of STS and IP STS services so that users may receive a functionally equivalent 
telephone service, as mandated by Title IV of the Americans with Disabilities Act.  We believe that none 
of these proposed changes would impose a significant burden on providers, including small business.  
However, if the proposed changes may result in additional financial burden on the part of the affected 
providers, including small entities, the providers will be promptly reimbursed from the Interstate TRS 
Fund for the costs of complying with the proposed rules, if adopted.  Entities, especially small businesses, 
are encouraged to quantify the costs and benefits of any reporting requirement that may be established in 
this proceeding.  The modifications the Commission proposes consist of policies aimed at achieving a 
functionally equivalent telephone service for Internet-based TRS users and are not expected to have a 
substantial economic impact upon providers, including small businesses, because each small business will 
receive financial compensation for reasonable costs incurred rather than absorb an uncompensated 
financial loss or hardship.
  
1 See 5 U.S.C.  603.  The RFA, see 5 U.S.C.  601612, has been amended by the Small Business Regulatory 
Enforcement Fairness Act of 1996 (SBREFA), Pub. L. No. 104-121, Title II, 110 Stat. 857 (1996).
2 5 U.S.C.  605(b).
3 5 U.S.C.  601(6).
4 5 U.S.C.  601(3) (incorporating by reference the definition of small-business concern in the Small Business
Act, 15 U.S.C.  632).  Pursuant to 5 U.S.C.  601(3), the statutory definition of a small business applies unless an 
agency, after consultation with the Office of Advocacy of the Small Business Administration and after opportunity 
for public comment, establishes one or more definitions of such term which are appropriate to the activities of the 
agency and publishes such definition(s) in the Federal Register.
5 15 U.S.C.  632.
Federal Communications Commission FCC 08-149
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4. With regard to whether a substantial number of small entities may be affected by the 
requirements proposed in this Notice, the Commission notes that, of the 7 providers affected by the 
Notice, only one meet the definition of a small entity.  The SBA has developed a small business size 
standard for Wired Telecommunications Carriers, which consists of all such firms having 1,500 or fewer 
employees. 6 Seven providers currently receive compensation from the Interstate TRS Fund for providing 
STS:  AT&T Corp.; GoAmerica, Inc.; Hamilton Relay, Inc.; Nordia Inc.; Kansas Relay Service, Inc.; 
State of Michigan and Sprint.  Because only one of the providers would be affected by this Notice, if 
adopted, is deemed to be small entities under the SBAs small business size standard, the Commission 
concludes that the number of small entities potentially affected by our proposed rules in this Notice is not 
substantial.  Moreover, given that all providers potentially affected by the proposed rules, including the 
one that is deemed to be small entities under the SBAs standard, would be entitled to receive prompt 
reimbursement for their reasonable costs of compliance, the Commission concludes that the FNPRM, if 
adopted, will not have a significant economic impact on these small entities.
5. Therefore, we certify that the proposals in this Notice, if adopted, will not have a 
significant economic impact on a substantial number of small entities.  
6. The Commission will send a copy of the Notice, including a copy of this Initial 
Regulatory Flexibility Certification, to the Chief Counsel for Advocacy of the SBA.7 This initial 
certification will also be published in the Federal Register.8
  
6 13 C.F.R.  121.201, NAICS code 517110.  According to Census Bureau data for 1997, there were 2,225 firms in 
this category which operated for the entire year.  U.S. Census Bureau, 1997 Economic Census, Subject Series: 
Information, Establishment and Firm Size (Including Legal Form of Organization), Table 5, NAICS code 513310 
(issued Oct. 2000).  Of this total, 2,201 firms had employment of 999 or fewer employees, and an additional 24 
firms had employment of 1,000 employees or more.  Thus, under this size standard, the majority of firms can be 
considered small.  (The census data do not provide a more precise estimate of the number of firms that have 
employment of 1,500 or fewer employees; the largest category provided is Firms with 1,000 employees or more.)
7 5 U.S.C.  605(b).
8 Id.
Federal Communications Commission FCC 08-149
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STATEMENT OF
CHAIRMAN KEVIN J. MARTIN
Re:  Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities; E911 Requirements for IP-Enabled Service Providers, CG Docket No. 03-123 and WC 
Docket No. 05-196, Report and Order and Further Notice of Proposed Rulemaking.
Re:  Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities; Speech-to-Speech and Internet Protocol (IP) Speech-to-Speech Telecommunications 
Relay Services, CG Docket Nos. 03-123 and 08-15, Notice of Proposed Rulemaking.
Today we take additional steps to help improve the quality of life for individuals with disabilities.  
We adopt a ten-digit numbering system for Internet-based Telecommunications Relay Services (TRS).  
We also seek comment on ways to improve Speech-to-Speech service (STS) and whether IP STS should 
be compensated from the Interstate TRS Fund.  Through these actions, we make progress in fulfilling our 
statutory goal of ensuring that every person has equal access to this nations communications services.  
We are well aware that there are many Americans with hearing or speech disabilities that depend 
on TRS services for their daily communication needs.  The Commission remains committed to improving 
the quality of life for individuals with disabilities by ensuring that they have the same access to 
communication technologies as people without such disabilities.  
In March, the Commission committed to adopt an order providing a ten-digit numbering system 
for Internet-based TRS by the end of June and to require that the ten-digit numbering system be 
implemented no later than December 31, 2008.  I am pleased that we fulfill these commitments today.  
Ten-digit numbering will enable Internet-based TRS users to make and receive calls like anyone else, 
eradicating another barrier that stands in the way of functional equivalency.  Functional equivalency 
means individuals with disabilities having access to the same services as everyone else.  This equal access 
is vital to accessing jobs, education, public safety, and simple communications with family, friends, and 
neighbors.  
I also support our inquiry into ways to improve STS and our tentative conclusion that IP STS is a 
form of TRS eligible for compensation from the Interstate TRS Fund.  IP STS has the potential to allow a 
broader range of individuals to communicate.  By not being constrained to a specific piece of equipment 
that resides in a particular location, users of this service would have tremendous flexibility in how and 
where they use this service.  Moreover, individuals with disabilities would have access to new 
technologies and, specifically, be able to realize the benefits of broadband services.
I want to assure those of you with hearing or speech disabilities that we will not stop actively 
working to fulfill your need for functional equivalence.  We could not have taken todays actions without 
your valuable input.  We thank you for your participation in our proceedings and look forward to working 
with you and the service providers to implement the ten-digit numbering system and to improve speech to 
speech service.  It is by working together that we can best ensure that the tremendous advances in 
communications are enjoyed by all Americans. 
Federal Communications Commission FCC 08-149
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STATEMENT OF
COMMISSIONER MICHAEL J. COPPS
Re:  Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities; Speech-to-Speech and Internet Protocol (IP) Speech-to-Speech Telecommunications 
Relay Services, CG Docket Nos. 03-123 and 08-15, Notice of Proposed Rulemaking.
A cornerstone of the Americans with Disabilities Act is to ensure that persons with disabilities 
can access the tools they need to lead prosperous, productive and fulfilling lives.  Speech-to-Speech Relay 
is an important and underutilized service available to those with speech disabilities. The Notice of 
Proposed Rulemaking raises important questions about how to improve upon the service and how we can 
provide more information so the disability community can take advantage of it.  The NPRM also 
tentatively concludes that IP-Speech-to-Speech (IP-STS) service is eligible for compensation from the 
TRS Fund, and it seeks comment on issues related to the administration of IP-STS as a covered service.  I 
am pleased to support the requests for comment and the tentative conclusions as they shine a light on 
some very critical issues in the provision of these services.  Moreover, it is my hope that the comments 
we receive will enable the FCC to complete these proceedings quickly in order to provide those with 
speech disabilities additional tools for staying connected.  
I would like to thank the disabilities community for bringing these issues to the Commissions 
attention and my colleagues for their interest in opening a proceeding to address the specific needs of 
those with speech disabilities. 
Federal Communications Commission FCC 08-149
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STATEMENT OF
COMMISSIONER JONATHAN S. ADELSTEIN
Re:  Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities; Speech-to-Speech and Internet Protocol (IP) Speech-to-Speech Telecommunications 
Relay Services, CG Docket Nos. 03-123 and 08-15, Notice of Proposed Rulemaking.
I am pleased to support this Notice seeking comment on ways to improve Speech-to-Speech relay 
service, a vital connection for Americans with speech disabilities.  Speech-to-Speech relay service uses 
specially-trained communications assistants who understand the speech patterns of persons with speech 
disabilities and can repeat the words to the other party to the call.  By seeking comment on important 
technical aspects of our Speech-to-Speech relay service requirements -- including extending minimum 
call lengths, providing better options for voice muting, and enhancing access to 711, our nationwide code 
for access to relay services  we seek to recognize and respond to the unique needs of Speech-to-Speech 
users.  Perhaps most importantly, we tentatively conclude the Internet-based Speech-to-Speech relay 
service should be compensable from the Telecommunications Relay Service Fund.  Consumers explain 
that IP-based Speech-to-Speech relay service offers several distinct benefits, including ease of use and 
mobility, over traditional Speech-to-Speech relay services.  
Taken together, these proposals have the potential to measurably improve the services available 
to those with speech disabilities, bringing us closer to our guiding principle of functional equivalence 
under the Americans with Disabilities Act.  My thanks to the staff of the Consumer and Governmental 
Affairs Bureau for their hard work on this item, and I look forward to working with all my colleagues, 
consumers, and the Bureau as we move forward expeditiously with these proposals.
Federal Communications Commission FCC 08-149
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STATEMENT OF 
COMMISSIONER DEBORAH TAYLOR TATE
Re:  Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities; Speech-to-Speech and Internet Protocol (IP) Speech-to-Speech Telecommunications 
Relay Services, CG Docket Nos. 03-123 and 08-15, Notice of Proposed Rulemaking.
Today we continue to recognize our responsibilities to insure all our citizens have access to 
communications services by issuing this NPRM.  We seek comment regarding the TRS regulations and 
specifically whether or not the Commission should amend specific regulations applicable to Speech-to-
Speech (STS) services including whether to require that the Communications Assistant (CA) remain with 
the call for a minimum of 20 minutes, and that providers offer the STS user the option of having her or 
his voice muted so that the other party to the call would only hear the STS CA re-voicing the call (and not 
also the voice of the STS user).  The draft NPRM also seeks comment regarding ways in which the 
Commission can ensure that STS users calling 711 (the nationwide access code for state relay providers) 
may promptly reach an STS assistant (CA) to handle their calls, including, for example, requiring TRS 
providers to use an interactive menu that allows the STS user to reach an STS CA as the first option.  
These are important issues for STS users, and the changes proposed will likely result in the more 
efficient handling of STS calls.  As the Commission continues to consider the needs of all our consumers 
in this digital age, I especially value the input of those who know first-hand what rules will most 
effectively serve those consumers who will benefit most.