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<title>Federal Register, Volume 91 Issue 1 (Friday, January 2, 2026)</title>
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[Federal Register Volume 91, Number 1 (Friday, January 2, 2026)]
[Proposed Rules]
[Pages 104-115]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-24210]
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FEDERAL COMMUNICATIONS COMMISSION
47 CFR Part 64
[CG Docket Nos. 03-123, 08-15; FCC 25-79; FR ID 324556]
Analog Telecommunications Relay Service Modernization
AGENCY: Federal Communications Commission.
ACTION: Proposed rule.
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SUMMARY: In this document, the Federal Communications Commission
(Commission) proposes to modernize its telecommunications relay
services (TRS) rules and seeks comment on phasing out the mandatory
status of traditional TTY-based relay services (TTY Relay) under state
TRS programs; recognizing additional forms of internet-based TRS, such
as internet Protocol Speech-to-Speech (IP STS) and real-time text
(RTT)-based relay as compensable forms of TRS; establishing a
temporary, national certification process for analog relay providers
and user registration and verification requirements; and updating or
eliminating obsolete rules to all forms of TRS. Through these
proposals, the Commission aims to align TRS with today's communications
landscape, better serve the needs of relay users, ensure the continued
availability of TRS through the transition from legacy communications
network, to modern, IP-based networks, and continue to protect the
integrity of the TRS program through the prevention of waste, fraud,
and abuse.
DATES: Comments are due on or before February 2, 2026. Reply comments
are due on or before March 3, 2026.
ADDRESSES: Pursuant to Sec. Sec. 1.415 and 1.419 of the Commission's
rules, 47 CFR 1.415, 1.419, interested parties may file comments and
reply comments. Comments may be filed using ECFS. You may submit
comments, identified by CG Docket No. 03-123, by the following method:
<bullet> Electronic Filers. Comments may be filed electronically
using the internet by accessing the ECFS: <a href="https://www.fcc.gov/ecfs">https://www.fcc.gov/ecfs</a>.
<bullet> Paper Filers. Parties who choose to file by paper must
file an original and one copy of each filing.
<bullet> Filings can be sent by hand or messenger delivery, by
commercial courier, or by the U.S. Postal Service. All filings must be
addressed to the Secretary, Federal Communications Commission.
<bullet> Hand-delivered or messenger-delivered paper filings for
the Commission's Secretary are accepted between 8:00 a.m. and 4:00 p.m.
by the FCC's mailing contractor at 9050 Junction Drive, Annapolis
Junction, MD 20701. All hand deliveries must be held together with
rubber bands or fasteners. Any envelopes and boxes must be disposed of
before entering the building.
<bullet> Commercial courier deliveries (any deliveries not by the
U.S. Postal Service) must be sent to 9050 Junction Drive, Annapolis
Junction, MD 20701. Filings sent by U.S. Postal Service First-Class
Mail, Priority Mail, and Priority Mail Express must be sent to 45 L
Street NE, Washington, DC 20554.
<bullet> People with Disabilities. To request materials in
accessible formats for people with disabilities (Braille, large print,
electronic files, audio format), send an email to <a href="/cdn-cgi/l/email-protection#93f5f0f0a6a3a7d3f5f0f0bdf4fce5"><span class="__cf_email__" data-cfemail="3f595c5c0a0f0b7f595c5c11585049">[email protected]</span></a> or
call the Consumer and Governmental Affairs Bureau at (202) 418-0530.
FOR FURTHER INFORMATION CONTACT: Joshua Mendelsohn, Disability Rights
Office, Consumer and Governmental Affairs Bureau, at 202-559-7304, or
<a href="/cdn-cgi/l/email-protection#89c3e6fae1fce8a7c4ece7edece5fae6e1e7c9efeaeaa7eee6ff"><span class="__cf_email__" data-cfemail="1e54716d766b7f30537b707a7b726d7176705e787d7d30797168">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION: This is a summary of the Commission's Notice
of Proposed Rulemaking (NPRM), in CG Docket Nos. 03-123 and 08-15, FCC
25-79, adopted on November 20, 2025, and released on November 21,
2025,. The full text of this document can be accessed electronically
via the Commission's Electronic Document Manage System website at
<a href="https://docs.fcc.gov/public/attachments/FCC-25-79A1.pdf">https://docs.fcc.gov/public/attachments/FCC-25-79A1.pdf</a>, or via the
Commission's Electronic Comment Filing System (ECFS) website at <a href="https://www.fcc.gov/ecfs">https://www.fcc.gov/ecfs</a>.
Ex Parte Rules. This proceeding shall be treated as a permit-but-
disclose proceeding in accordance with the Commission's ex parte rules.
47 CFR 1.1200 et seq. Persons making ex parte presentations must file a
copy of any written presentation or a memorandum summarizing any oral
presentation within two business days after the presentation (unless a
different deadline applicable to the Sunshine period applies). Persons
making oral ex parte presentations are reminded that memoranda
summarizing the presentation must (1) list all persons attending or
otherwise participating in the meeting at which the ex parte
presentation was made, and (2) summarize all data presented and
arguments made during the presentation. If the presentation consisted
in whole or in part of the presentation of data or arguments already
reflected in the presenter's written comments, memoranda, or other
filings in the proceeding, the presenter may provide citations to such
data or arguments in his or her prior comments, memoranda, or other
filings (specifying the relevant page and/or paragraph numbers where
such data or arguments can be found) in lieu of summarizing them in the
memorandum. Documents shown or given to Commission staff during ex
parte meetings are deemed to be written ex parte presentations and must
be filed consistent with Sec. 1.1206(b) of the Commission's rules. In
proceedings governed by Sec. 1.49(f) of the Commission's rules or for
which the Commission has made available a method of electronic filing,
written ex parte presentations and memoranda summarizing oral ex parte
presentations, and all attachments thereto, must be filed through the
electronic comment filing system available for that proceeding, and
must be filed in their native format (e.g., .doc, .xml, .ppt,
searchable .pdf). Participants in this proceeding should familiarize
themselves with the Commission's ex parte rules.
Providing Accountability Through Transparency Act. The Providing
Accountability Through Transparency Act, Public Law 118-9, requires
each agency, in providing notice of a rulemaking, to post online a
brief plain-language summary of the proposed rule. The required summary
of the Notice is available at <a href="https://www.fcc.gov/proposed-rulemakings">https://www.fcc.gov/proposed-rulemakings</a>.
Paperwork Reduction Act. The NPRM may contain proposed new or
modified information collection requirements. The Commission, as part
of its
[[Page 105]]
continuing effort to reduce paperwork burdens, invites the general
public and the Office of Management and Budget (OMB) to comment on the
information collection requirements contained in the NPRM, as required
by the Paperwork Reduction Act of 1995, Public Law 104-13. In addition,
pursuant to the Small Business Paperwork Relief Act of 2002, Public Law
107-198, see 44 U.S.C. 3506(c)(4), the Commission seeks specific
comment on how it might further reduce the information collection
burden for small business concerns with fewer than 25 employees.
Synopsis
1. Title IV of the Americans with Disabilities Act of 1990 (ADA),
which added section 225 to the Communications Act of 1934, as amended
(the Act), directs the Commission to ensure that TRS are available, to
the extent possible and in the most efficient manner, to individuals
with hearing or speech disabilities in the United States.
2. The Act requires common carriers provide TRS throughout the
areas in which they offer service. The Act directs the Commission to
adopt, administer, and enforce regulations governing the provision of
interstate and intrastate TRS. Section 225 of the Act also authorizes,
but does not require, states to establish their own TRS programs,
subject to Commission approval and certification. In states with
certified TRS programs, carriers may fulfill their obligation to
provide intrastate TRS by participating in the state program. If a
state does not have a Commission-certified TRS program, the provision
of intrastate TRS in that state falls under the direct supervision of
the Commission. All 50 states, the District of Columbia, and several
U.S. territories have FCC-approved TRS programs. The analog TRS
providers provide the relay services for intrastate, interstate, and
international calls. They seek reimbursement for intrastate analog TRS
calls from the relevant state program and seek reimbursement for
interstate and international calls from the Interstate TRS Fund.
Currently, the Commission recognizes six forms of TRS, three analog
services and three internet-based services. The three analog forms of
TRS are TTY Relay, Speech-to-Speech relay service (STS), and Captioned
Telephone Service (CTS).
3. Section 225 of the Act provides that, generally, costs
attributed to interstate TRS are to be recovered from all subscribers
for every interstate service, while costs for intrastate TRS are
recovered from the intrastate jurisdiction. Each state is responsible
for determining how to fund the provision of intrastate TRS through the
state's TRS program. The interstate costs of analog TRS are recovered
through the FCC-administered TRS Fund, and the Commission is
responsible for determining how providers of interstate TRS shall be
compensated. Since 2007, compensation rates for interstate calls using
analog services have been determined by applying the Multi-State
Average Rate Structure (MARS) methodology, which does not require a
calculation of costs or demand for these specific services.
4. As communications technologies continue to evolve, the TRS
landscape is undergoing significant transformations, necessitating a
re-evaluation of current rules to ensure continued functional
equivalence and efficiency. These developments include a decline in the
use of analog relay services, the emergence of advanced internet-based
solutions, and the integration of accessible communications
functionalities into smart devices.
5. In August 2024, National Association for State Relay
Administration (NASRA) members, Gallaudet University, and TDIforAccess
(TDI) submitted to the Commission a White Paper asserting that the
decline in usage of analog TRS, coupled with the accelerating
transition from traditional analog to IP-based networks, makes it
urgent for federal and state policymakers to proactively adapt TRS
obligations and programs to reflect the evolution to IP-based networks.
TTY Relay
6. Under section 225 of the Act, states are permitted, but not
required, to establish their own TRS programs. The provision of
interstate relay services offered through state TRS programs is
supported by the Interstate TRS Fund. State TRS programs must offer TTY
Relay and STS.
7. TTY is widely acknowledged to be an outdated technology. Over
time, the use of TTY Relay has declined greatly, reflecting a shift
towards internet-based TRS solutions. Annual intrastate usage of TTY
Relay totals less than 2 million minutes with many jurisdictions
reporting less than 1,000 minutes in 2024. As communication networks
modernize and usage declines, state relay programs are seeking guidance
from the Commission regarding the appropriate steps and processes for
phasing out TTY Relay.
8. Given the ongoing technology transition to IP-based networks,
and the obsolescence of TTY Relay, the Commission seek comment on
terminating the mandatory status of TTY Relay for state-based TRS
programs. The Commission believes this would allow states to adapt
their programs to local needs and technological realities, rather than
being burdened by the costs and administrative complexities of
maintaining a service with greatly diminished demand. What are the
administrative and financial implications for state programs if TTY
Relay is no longer mandatory? How would terminating the mandatory
status of TTY Relay impact state programs' ability to continue
supporting other essential relay services?
9. The Commission believes that terminating the mandatory status of
TTY Relay is consistent with the Commission's statutory obligations
under section 225 of the Act. The Commission seeks comment on this
belief. As discussed below, the Commission believes a number of
alternative services will be available to ensure that functionally
equivalent communication is available to the remaining users of TTY
Relay, in those states that choose to terminate the availability of
this service through the state TRS program. For example, IP Relay has
long been available to any user with broadband access. In addition, the
Commission encourages state programs to offer RTT-based relay service
in place of TTY Relay, to the extent that governing state legislation
permits support for such a service through the state TRS program. The
Commission also seeks comment on whether to provide TRS Fund support
for a nationwide RTT-based relay service. Further, as a transitional
step, to ensure that text-based relay service continues to be available
to any user that does not yet have access to an IP-based alternative,
the Commission seeks comment on whether to authorize the temporary
certification of a national provider of TTY Relay, which would be
available in any state where TTY Relay is no longer available through a
state TRS program.
10. The Commission also seeks comment on whether ending the mandate
that state TRS programs support TTY Relay, but temporarily certifying a
national provider, will help the Commission achieve its statutory goals
by ensuring that TRS are available ``in the most efficient manner.''
Does allowing state TRS programs to discontinue TTY relay relieve
analog TRS providers from incurring unnecessary costs? Will it allow
analog TRS providers the ability to reallocate funds and other
resources to more
[[Page 106]]
efficient technology? Will intrastate or interstate TRS Fund
contributors experience any cost savings? What are the costs and
benefits to state TRS programs discontinuing TTY Relay? What would be
the costs and benefits to continue requiring state TRS program to
support TTY Relay? The Commission also seeks comment on whether ending
the mandate to support TTY Relay will further the Act's directive that
TRS regulations encourage the use of existing technology and do not
discourage or impair the development of improved technology. Will these
actions help transition TTY Relay providers and their remaining users
from entirely text-based relay over the public switched telephone
network (PSTN) to multimedia offerings that make full use of the
internet's capabilities to leverage new technologies to meet user
needs? Are there other approaches the Commission should consider to
ensure a smooth transition from TTY Relay to IP-based alternatives?
11. The Commission seeks comment on whether terminating the
mandatory status of TTY Relay is consistent with the obligation of
common carriers under section 225(c) of the Act to provide
telecommunications relay services ``in compliance with the
[Commission's] regulations'' throughout the area in which they offer
service. Under section 225 of the Act, the Commission has the same
oversight and authority with respect to ensuring the availability and
provision of both intrastate and interstate TRS. Pursuant to this
authority, the Commission is directed to set the requirements for
ensuring the provision of TRS and for certifying state programs.
Further, the Commission determined that TRS were not limited to TTY
Relay, and set guidelines for whether a particular type of TRS must be
included within a state TRS program. The Commission believes a common
carrier remains compliant with its obligation to offer TRS so long as
its interstate TRS offerings align both with the Commission's TRS rules
and, where applicable, a state TRS program certified under the
Commission's rules. The Commission believes section 225 of the Act does
not mandate a particular form of TRS be provided and affords the
Commission the ability to re-align its rules around changes in
technology, including the ability to wind down forms of TRS that are
technologically obsolete. The Commission seeks comment on this belief.
12. Although TTY Relay usage is diminishing, some people with
speech or hearing disabilities still rely on TTY devices. Such
individuals should not be left without an effective means of telephone
communication. The Commission seeks comment on how TTY Relay users can
be most effectively and efficiently transitioned to productive
alternatives.
13. To better understand the transitioning landscape, the
Commission seeks comment on the total number of users of TTY Relay,
including users of voice carryover and hearing carryover (in particular
states or in the nation as a whole), as well as any available data on
user location, availability of reliable broadband internet access, and
the extent to which TTY Relay users are utilizing wired or mobile
wireless devices to connect. The Commission also solicits any available
data on TTY Relay user demographic information, such as age and income,
to further the Commission's understanding of the users being impacted
by this transition. The Commission also seeks comment on the extent to
which TTY services are provided without support from state or federal
programs for direct communication with TTY users. Would terminating the
mandatory status of TTY Relay affect the ability to provide the service
on a privately funded basis?
14. The Commission also seeks comment on the prevalence of state
equipment distribution programs (EDPs) or assistive technology (AT)
programs for people with disabilities. How many states currently have
EDPs? AT programs? What equipment is provided under these programs? How
is eligibility for those programs determined? How many programs have
adopted income limits, fiscal caps, or have any other restrictions on
access? To what extent are those programs connected to state TRS
programs? Would changes to the services state TRS programs are required
to provide have an effect on the programs?
15. The Commission seeks comment on the extent to which IP Relay
can serve as a comprehensive alternative for current TTY Relay users
and what, if any, additional steps the Commission should take to
facilitate this transition. Does the requirement for users to have an
IP-enabled device and broadband internet access service present a
barrier to its use by some current TTY Relay users? Are IP Relay
providers ensuring direct communications between IP Relay users? What
types of barriers are TTY Relay users most likely to experience? Are
there steps the Commission could take to mitigate such barriers?
16. RTT communications are able to be converted to be read on TTY
devices and messages sent via TTY devices can be read on devices
supporting RTT. Given the availability of RTT on mobile devices and the
suitability of RTT for transmitting text on IP networks, the Commission
believes that many TTY Relay users are currently using RTT, rather than
a TTY device, to initiate or answer TTY Relay calls. If an individual
initiates such a call using RTT to dial 711, the call may be converted
to the TTY format for communication with a CA. Where an end-to-end RTT
link is possible, a conversion to the TTY format is technically
unnecessary and likely to provide a less reliable text-based
communication channel to the TTY Relay user. The Commission seeks
comment on the extent to which such conversion is occurring, and why.
For example, are there network concerns where the conversion to the
TTY-based format is outside the control of the TTY Relay providers who
would accept RTT communications if the format was retained when the
call reached their call center? Are there economic concerns that hinder
state programs from supporting or TTY Relay providers from installing
the capability to handle RTT calls in TTY Relay call centers? Or are
there legal considerations, e.g., a concern that if the link between
user and CA is IP from end to end, the call might not qualify for
financial support by the state TRS program or the TRS Fund? Are there
other technological or administrative concerns that are inhibiting the
transition to end-to-end RTT?
17. The Commission believes that nothing in the Act restricts state
programs from offering intrastate, RTT-based relay service. Indeed,
section 225 of the Act expressly authorizes states to establish
programs for the provision of intrastate TRS, subject only to
Commission approval. The only conditions required for such approval are
that the program (1) makes intrastate TRS available to eligible
individuals in accordance with the Commission's regulations, and (2)
provides adequate procedures and remedies for enforcing the program's
requirements. In light of this explicit statutory authorization, the
Commission has previously determined that states are not precluded from
funding and administering VRS, IP Relay, or IP CTS, should they choose
to do so. The Commission seeks comment on this belief and analysis.
18. The Commission also seeks comment on whether a RTT-based relay
service would provide a useful alternative to TTY Relay. The Commission
assumes that such a service would operate similarly to TTY Relay, in
that the CA would voice the TRS user's typed text to a hearing party
and type the hearing party's speech back to the TRS user. In addition,
the
[[Page 107]]
Commission assumes that, at least initially, a user would initiate a
RTT-based relay call in the same way as TTY Relay--by dialing 711 to
connect with a CA. The main difference would be that the link between
the texting user and the CA would be carried entirely as an IP format,
using the RTT protocol. Are these assumptions correct or are there more
efficient RTT-based relay service implementations currently operating?
19. Should the Commission amend its rules to expressly authorize
compensation from the TRS Fund for the interstate use of RTT-based
relay service? What are the costs and benefits of making an RTT-based
relay service available as a replacement for TTY Relay? Would the
availability of an RTT-based relay service be more beneficial than IP
Relay for some current TTY Relay users--and if so, in what specific
ways? For example, would it be easier for TTY Relay users to transition
to an RTT-based service than to IP Relay, and if so, in what respects?
How would the two types of services compare in their handling of
emergency 911 calls? Would there be significant cost differences
between IP Relay and RTT-based relay service?
20. The Commission also seeks comment on whether an RTT-based relay
service could be modified to enable callers to initiate a TRS call
without dialing 711, allowing the user to make and receive direct
dialed calls. How could such call initiation methods be implemented,
and how would their introduction affect the cost-benefit comparison
with IP Relay? Further, how does the availability of text-to-speech
software on RTT calls affect the need to connect to a CA and utilize
relay? Is ASR technology similarly available for RTT calls? Where a
consumer can place an end-to-end RTT call does the ability to
communicate via text, voice, text-to-speech software, and ASR alleviate
the need to involve a CA to relay the call?
21. Would all state TRS programs be able and willing to support
RTT-based relay service for intrastate communications? Are there
obstacles that would prevent state programs from supporting RTT-based
relay? If some states are not able to support RTT-based relay, should
the Commission establish a nationwide form of RTT-based relay service
that would be solely supported by the Interstate TRS Fund, and
available in any state that does not maintain a TRS program offering
such a service? Or is the availability of IP Relay--as well as the
availability of text-to-speech software on smartphones or other
devices--sufficient to ensure access to text-to-voice communication, so
that the Commission does not need to establish new forms of text-based
relay service to ensure functionally equivalent access to the voice
communication services?
22. While RTT has largely replaced TTY on wireless networks, its
utility as a direct substitute for TTYs on wireline voice networks is
currently limited as it is not natively available on wireline devices.
The Commission has previously acknowledged the importance of continued
exploration into wireline RTT as an alternative to TTY technology to
achieve a universal, integrated text solution for voice services. The
Commission seeks comment on furthering the availability of RTT across
IP networks, services, and equipment. Should the Commission extend the
TTY support exemption, which allows voice communications services
provided over wireless IP facilities and equipment to support RTT, in
lieu of continuing to provide TTY connectability and TTY signal
compatibility, to include interconnected and non-interconnected VoIP
services provided over wired IP facilities and equipment, if such
services and equipment support RTT? How else should the Commission
encourage wireline providers to support RTT? The Commission also
solicits comments on the necessary technical guidance and cost
expectations for wireline RTT implementation.
23. What would be an appropriate timeline to transition from TTY to
RTT given the current state of RTT deployment? What additional steps,
if any, would assist in replacing TTY with RTT? Are providers
encountering difficulty working with telecommunications carriers to
deploy RTT? Are there additional actions the Commission should take to
encourage the development and deployment of RTT?
24. Direct Video Calling (DVC) is video teleconferencing that
allows conversations to occur between two callers using American Sign
Language (ASL), without the need for translation services. DVC services
are provided to customer call centers as a direct ASL-to-ASL
communication alternative to direct text-based communications such as
TTY-to-TTY calls, and also can be used as an alternative to relay
service. The Commission seeks comment on the extent to which DVC can
serve as a direct communication alternative to TTY-to-TTY
communications when the parties at both ends of the call use ASL--and
what, if any, additional steps the Commission should take to facilitate
this transition. Does the requirement for users to have an IP-enabled
device and broadband internet access service present a barrier to its
use by some current TTY users? What types of barriers are TTY users
most likely to experience? Are there steps the Commission could take to
mitigate such barriers? Is the adoption of DVC widespread among
businesses? Government entities? Should the Commission take additional
actions to encourage the use of DVC?
25. Some state TRS programs or related state agencies have begun
supporting Communication Facilitator services to provide communication
access for individuals who are deafblind. During a video call, a
Communication Facilitator copies sign language from the other video
caller and provides visual information to the individual who is
deafblind through in-person close-vision, tactile sign language,
tracking, or another communication method. The Commission seek comments
on the extent to which Communication Facilitator services can serve as
an alternative to TTY Relay or direct TTY-to-TTY communications for
individuals who are deafblind using braille devices and what, if any,
additional steps the Commission should take to facilitate this
transition. Are Communication Facilitator services only used with video
communications requiring the users to have an IP-enabled device and
broadband internet access service? If so, does this requirement present
a barrier for TTY users who use braille? What types of barriers are TTY
users using braille most likely to experience? Are there steps the
Commission could take to mitigate such barriers? How many states
currently offer Communication Facilitator services? What are the costs
and benefits to offering such services? What steps have states taken to
identify and provide outreach to individuals who are deafblind about
such services? How many hours per day and days per week are these
services available from states that offer them?
26. To ensure that TTY Relay is used appropriately and efficiently,
and to safeguard the TRS Fund from waste, fraud, and abuse, the
Commission seeks comment below on applying user eligibility,
registration, verification, and call detail records requirements to all
forms of TRS--measures that have proven effective in safeguarding other
TRS programs. The Commission seeks comment on the specific processes
for TTY Relay user registration and verification, including the type of
documentation or assessment required to confirm eligibility and how to
balance ease of access for legitimate users with robust protections
against misuse. Are providers able to verify the
[[Page 108]]
identity of TTY Relay users at the beginning of calls? Would user
registration requirements unduly burden state TRS programs in their
support and oversight of intrastate TRS?
Captioned Telephone Service
27. As the telecommunications infrastructure continues its
transition from analog systems to IP-based networks, the usage of
analog CTS has steadily declined. Analog CTS services are administered
at the state level, with states typically contracting with a single
provider. While most state TRS programs support CTS, the Commission
does not mandate support for CTS. In the absence of a mandate, many
states have chosen to wind down and discontinue their analog CTS
services, in response to declining demand. As other state TRS programs
consider whether to continue supporting CTS, the Commission believes it
is beneficial to provide oversight and guidance to ensure users are
able to successfully transition to alternative solutions.
28. One prominent alternative to analog CTS is IP CTS. IP CTS is
administered by the Commission and supports multiple national
providers. Technological advancements have significantly modernized IP
CTS, particularly through the integration of ASR technology. The
viability of IP CTS as a direct alternative to analog CTS has been
demonstrated in practice, underscoring its effectiveness as a modern
solution.
29. As the telecommunications landscape continues to evolve, smart
devices and applications are increasingly incorporating ASR
functionalities. The Commission seeks comment on the extent to which
ASR functionalities on smart devices are comparable in quality and
speed of captions currently offered through Fund-supported IP CTS
providers and whether such services present a viable and efficient
alternative for users transitioning from analog CTS. Does the direct
availability of captions with ASR on smart devices and applications for
use by hearing individuals to communicate using voice communication
services suggest a separate relay service is unnecessary? Are current
users of analog CTS likely to own smart devices? Does every smart
device on the market support this technology? Are older smart devices
used by consumers capable of supporting ASR captioning? Are all smart
devices capable of offering consumers ASR captions on both voice and
video calls? What are the costs for consumers to obtain such equipment?
How difficult or easy is it for end users to use ASR on smart devices?
Are seniors who age into hearing loss likely to be able to use the
smart device with ASR and does that ability change as someone ages into
their 80s and 90s? Do smart device and application providers who offer
ASR captioning permit users to restrict access to the captioning to
protect their privacy? Is customer or technical support available for
users experiencing problems receiving captions? Do smart device and
application providers track the availability and performance of the
captions?
30. Should the Commission take any steps to ensure that such
communications service providers and equipment manufacturers are
providing access to captions under separate statutory authority granted
to the Commission, such as the Commission's authority to ensure
telecommunications services and advanced communications services are
accessible to and usable by individuals with disabilities? Are
obligations or performance objectives for ensuring such ASR captions
are accessible to and usable by people with disabilities necessary? Are
relevant TRS minimum standards (e.g., outage reporting requirements
specific to ASR, redundancy requirements, annual reports attesting to
the current IP CTS minimum standards, annual complaint reports specific
to the captioning solutions being offered on the smart devices, etc.)
reasonable standards to impose for ensuring native captions are
accessible and usable? If such standards are needed, should the
communications service provider or the equipment manufacturer be
subject to the new standards? Does any separate statutory authority
give the Commission jurisdiction to impose on communications service
providers and equipment manufacturers the minimum standards it imposes
on authorized TRS service providers?
31. The transition to IP-based services, including IP CTS and
technologies using ASR, requires internet access and IP-based
specialized equipment which may not be universally available. To help
transition these users the Commission solicits comments on the
feasibility of and burden to state relay programs, telecommunications
carriers, and VoIP providers offering appropriate devices to users who
wish to transition from CTS to an alternate service but may require new
equipment due to network changes or device obsolescence. Are there
lessons state programs that have discontinued analog CTS support have
learned that may be useful to the Commission and users during the
transition to an alternate service?
32. To ensure that CTS is used appropriately and efficiently, and
to safeguard the TRS Fund from waste, fraud, and abuse, the Commission
seeks comment below on applying user eligibility, registration,
verification and call detail records requirements to all forms of TRS.
The Commission seeks comment on the specific processes for CTS user
registration and verification, including the type of documentation or
assessment required to confirm eligibility and how to balance ease of
access for legitimate users with robust protections against misuse.
Speech-to-Speech Relay Service
33. In authorizing the provision of STS in March 2000, the
Commission determined that all certified state TRS programs must offer
STS. STS demand is consistent, with annual usage less than 400,000
minutes. However, unlike TTY Relay and CTS, STS usage has not declined
substantially over time. The emergence of IP-based solutions has
offered new avenues for people with speech disabilities to access
communications services.
34. In 2011, a non-profit organization asked the Commission to open
a proceeding on modernizing STS to incorporate IP video technologies.
With video-assisted STS, the CA would watch the user's face and any
available seen body parts or indicators to add meaning that is
translatable by the CA into clear speech that can be voiced to the
person called. This concept, referred to as video-assisted Speech-to-
Speech (VA-STS), was noted in the Commission's 2013 IP STS Order,
published at 78 FR 49693, August 15, 2013, which recognized that it was
already being offered in several states. The Commission continues to
believe that such an internet-based, video-assisted form of STS holds
significant potential to enhance functional equivalence for individuals
with severe speech disabilities. The Commission seeks comment on this
belief.
35. Recognizing the significant technological advancements since
the 2013 IP STS Order, the Commission proposes to authorize IP STS as a
compensable form of TRS. This proposal includes video-assisted STS as
an integrated or add-on component to IP STS, rather than a standalone
service. The Commission believes the service would likely be app or
web-based to distinguish it from analog STS, which already permits
users to make calls from interconnected VoIP services using internet-
enabled devices. This approach aims to leverage the benefits of IP
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technology, such as enhanced call privacy, improved real-time quality
and efficiency, and greater service reliability, which are increasingly
realized through automation and over-the-top apps. The Commission seeks
comment on this proposal.
36. The Commission also seeks comment on whether authorizing such a
service, with its inherent flexibility and potential for a wider range
of communication modes, will significantly advance the statutory goal
of functional equivalence for individuals with speech disabilities. How
would this structure best integrate with existing TRS frameworks?
Should IP STS providers be directly certified by the Commission and
compensated entirely through the Interstate TRS Fund similar to other
IP-based forms of TRS? Should IP STS calls directly connect to a call
center allowing users to make and receive direct dialed calls? Are
state TRS programs currently supporting and compensating a form of STS
similar to this IP STS proposal? Are they supporting and compensating
video-assisted STS? If so, do STS providers submit compensation claims
for interstate STS minutes for IP STS or video-assisted STS? What are
the specific benefits or challenges of positioning video-assisted STS
as an add-on rather than a separate service or as part of the cost of
providing IP STS? Should IP STS include or support the option for users
to access and use ASR engines for non-standard or atypical speech? Is
such technology already being made available in smart devices and
applications for use within voice communication services, independent
of TRS support?
37. To ensure efficient allocation of resources and effective
program development, the Commission seeks comment on effective
methodologies for assessing the potential demand for new IP STS and
video-assisted STS offerings. How can the Commission best identify and
reach the segments of the community of people with speech disabilities
who would benefit from these services? What data collection mechanisms
or surveys would provide reliable estimates of demand and user
preferences for IP STS and its features? In considering the potential
demand should the Commission distinguish between individuals likely to
use the service and individuals who could use the service but may
prefer to sign or text first?
38. The Commission does not propose to alter the mandatory status
of the analog version of STS at this time. STS remains a mandatory
service that all states with a certified state TRS program must offer.
Currently, STS is provided only through state-certified relay service
programs and has no internet-based, FCC-certified equivalent. This
means that users of STS presently have limited alternatives to
transition to if their state were to terminate the provision of analog
STS. However, the Commission may revisit the mandatory status of analog
STS and its provision at such time as IP STS or other suitable IP-based
solutions are sufficiently developed and widely available, and the
Commission can offer a seamless transition for users from analog STS to
IP-based alternatives. Are state programs able to maintain STS as a
mandatory service if the Commission moves forward with the proposal to
terminate the mandatory status of TTY Relay? Are there challenges
associated with maintaining the mandatory status of STS but not TTY
Relay?
39. To ensure the quality and accountability of IP STS, the
Commission proposes that certification requirements for IP STS
providers should be comparable to those established for other internet-
based TRS services, such as VRS, IP Relay, and IP CTS. Specifically,
applicants would be required to submit detailed plans for service
provision, explanations of how they will comply with all relevant
technical and operational standards, and descriptions of mechanisms for
preventing misuse. The Commission seeks comment on whether additional
certification requirements should be established for IP STS providers.
Should any particular technical capabilities be prerequisites for
certification? Which existing certification requirements, if any,
should not be applicable to IP STS?
40. The introduction of IP STS necessitates a reevaluation and
refinement of existing mandatory minimum standards for STS to ensure
they remain relevant and effective. Current STS rules address aspects
such as CA competency and adherence to confidentiality, but some
provisions, like those relating to only TTY Relay or VRS, would not be
applicable. Should any of the existing mandatory minimum standards not
be applied to the provision of IP STS? The Commission requests that
commenters who identify such rules, explain the incompatibility and
propose changes to the rule to appropriately limit the scope of the
rule. Are there other standards unique to the provision of IP STS that
the Commission should consider adding?
41. STS CAs require specialized training to understand and repeat
the words of individuals with diverse speech patterns. To enhance the
quality and efficiency of STS, providers currently allow STS users to
set up and utilize profiles or preferences to facilitate call
connections. The Commission seeks comment on the feasibility and
benefits of implementing caller profiles for IP STS, including the
types of information that would be necessary for effective routing, and
the safeguards required to protect user privacy and prevent any misuse
of user information. Should users be able to identify preferences
related to the user's unique speech characteristics? Would providing
such preferences enable a user with a particular speech disability to
have their calls routed to CAs or ASR engines specifically trained to
understand that type of speech? The Commission also seeks comment on
how specialized CAs and ASR engine training for IP STS, particularly
for handling atypical speech patterns or utilizing new technologies,
should be defined and supported.
42. The Commission currently requires STS providers to offer the
user the option of having their 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. This feature serves to minimize disruption
to the conversational flow and potentially enhance the privacy and
comfort of the STS user. Should the Commission similarly require IP STS
providers to offer a muting option to users, allowing them to control
whether their own voice is transmitted to the called party? The
Commission seeks comment on providers' experience with the muting
feature in analog STS, as well as any technical issues regarding its
implementation in an IP environment, its impact on call flow and
functional equivalence, and any other benefits or challenges it may
present for IP STS users.
43. To ensure that IP STS are used appropriately and efficiently,
and to safeguard the TRS Fund from waste, fraud, and abuse, the
Commission proposes to apply user eligibility, registration, and
verification requirements similar to those already in place for IP
Relay, VRS, and IP CTS. This would include requiring users to register
with a certified provider and undergo a verification process to confirm
their identify and location, as well as to certify eligibility as
individuals with speech disabilities who require the service for
functionally equivalent communication. The Commission seeks comment on
the specific processes for IP STS user registration and verification,
including the type of documentation or assessment required to confirm
eligibility and how to balance ease of
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access for legitimate users with robust protections against misuse.
44. The Commission believes IP STS providers should be subject to
the same data submission requirements applicable to all TRS providers,
which are designed to ensure effective oversight, fund administration,
and accountability, and to enable the determination of a TRS Fund
budget for each service, as well as the determination of provider
compensation rates. Later in the NPRM, the Commission seeks comment on
whether any modifications to the Commission's call data requirements
are needed to ensure collection of appropriate data for this service
and avoid unnecessary data collection.
45. A perceived challenge for STS has been the low awareness and
resulting flat usage among its potential user base. Due to concerns
that potential STS users were not aware of the service's availability,
the Commission in 2007 added a specific per-minute amount of $1.131 to
the STS compensation rate, specifically for outreach purposes. This
additional funding was intended to promote STS to potential users and
required providers to file annual reports detailing their specific
outreach efforts attributable to this support.
46. Despite the TRS Fund support for outreach by providers, STS
usage remains flat and low in comparison to the number of people with
speech disabilities. The availability of IP STS and the possibility of
nationwide video-assisted STS may present a new opportunity to inform
the public and potential users about the availability of these
services. What steps should the Commission take to ensure effective
outreach concerning IP STS and video-assisted STS? The Commission seeks
comment and data, especially from STS providers and state TRS programs,
on the effectiveness over the last 25 years of outreach to potential
STS users. How many individuals are using STS? What methods have
providers used to market the service or provide outreach to potential
users? Are there places, resources, or communities that are or could be
targeted to reach people with speech disabilities who would benefit
from learning about STS? To what extent have state TRS programs or STS
providers conducted outreach to those places? Have STS providers
developed outreach plans for STS? If not, why not? If so, the
Commission requests information about the details of those plans, and
comments on their strengths and weaknesses. Do providers work with
organizations for people with speech disabilities to conduct outreach?
How broad is the reach of those organizations?
47. If the Commission continues to provide an outreach additive or
other additional outreach support and resources for STS, how should the
Commission measure the effectiveness of such outreach efforts? Should
the Commission consider such an additive for IP STS? Alternatively, is
the low adoption rate for STS services not indicative of a lack or
outreach and awareness, but rather a preference amongst individuals
with speech disabilities for text or sign language communications
through other forms of TRS and advance communication services? Do some
individuals with speech disabilities prefer alternative services such
as online messaging and chat tools or the use of other assistive
technology, such as augmentative and alternative communication (AAC)
devices? Do individuals with speech disabilities who are fluent in sign
language prefer to use VRS or other video-based forms of communication?
If STS usage is a matter of preference rather than outreach should the
Commission discontinue the outreach additive? What are the potential
costs and benefits to discontinuing the additive?
Transitioning Analog Relay Users to Alternatives
48. There may be some analog TRS users who, for various reasons,
cannot successfully transition to IP-based telephony solutions without
additional assistance. The Commission seeks comment on the number of
such individuals, the reasons they are unable to transition, and what
means are available to ensure that such individuals remain able to
communicate after the retirement of the copper facilities serving them.
For example, are subsidies available at the state or federal level to
ensure that analog TRS users who cannot otherwise afford to subscribe
to internet access service are able to transition to a VoIP line or
other IP-based communications channel?
49. In a similar vein, the Commission solicit comments on whether
there are specific roles that state relay programs and communication
service providers should fulfill to assist users who wish to transition
to an alternate TRS service (e.g., IP CTS, IP Relay, or RTT-based relay
service) but may require new communication services or equipment due to
network changes or device obsolescence. How can consumers be informed
of prerequisite service or equipment changes and how to obtain them?
What options are available for coordination among interested parties
for ensuring that analog TRS users who need it receive additional
assistance? Are services obtained through universal service programs
and equipment obtained through equipment distribution programs
sufficiently compatible for the equipment to be used with the relevant
services? Can those services and equipment be used with TRS and TRS
equipment?
50. The Commission also seeks comment on the availability and
feasibility of peripheral devices and specialized customer premises
equipment that support captioned phone service or RTT and could be
utilized for calls with VoIP services. Are VoIP services and RTT usable
on the same device (e.g. smartphone, tablet, or laptop) by people with
disabilities? Are there devices that support RTT and are able to
connect to VoIP service devices, particularly VoIP devices without a
screen for viewing text? What are the costs for developing such
equipment? What are the costs to consumers to obtain such equipment?
The Commission also seeks comment on how incurring these transitional
costs would compare to the long-term savings associated with retiring
obsolete hardware and software linked to analog networks, and whether
the cost of these efforts should be compensable from the TRS Fund.
51. Beyond the technological alternatives, the Commission
recognizes the benefit of a structured transition process to ensure
that all individuals with hearing and speech disabilities maintain
access to relay services as analog telecommunications networks
transition to IP-based services. To ensure that no analog relay user is
left without usable TRS during this network evolution, the Commission
seeks comment on developing outreach and transition plans for affected
users in coordination with state TRS relay programs, analog TRS
providers, and communication service providers. Are state TRS programs
able to coordinate with the Commission on such an initiative? Are state
TRS programs better positioned to lead on plan development and
outreach? If so, how should the Commission support such outreach and
plan development? To what extent have state TRS programs and analog
relay service providers begun to establish such plans? What is an
appropriate timeline for the development and implementation of such
plans and outreach? What role can and should communication service
providers, whose users rely on analog TRS, perform in the outreach and
transition process? Are there other state programs, such as
telecommunications equipment
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distribution programs, or state agencies, separate from TRS programs
that the Commission should coordinate with? Should the Commission
coordinate with relevant agencies independently or in connection with
membership associations, such as NASRA and the Telecommunications
Equipment Distribution Program Association (TEDPA)? Should the
Commission coordinate with trade associations whose members include
communication services providers? If a state is considering
discontinuing its state TRS program, what role should the Commission
fulfill in that transition?
52. The Commission also seeks comment on any barriers to
coordination. To what extent are analog TRS providers limited in the
information they are able to share with state TRS programs and the
Commission for conducting outreach, while continuing to protect the
privacy of customer information? What steps can the Commission take to
allow state TRS programs access to more detailed information about
individual analog TRS users? If necessary, how could the Commission
ensure that such consumers are notified about the potential sharing
with and use of personally identifiable information by state TRS
programs? Could analog TRS providers provide this notification? Could
communication service providers provide this notification? If
notification can be provided, should the Commission permit consumers to
opt-out of sharing such information? How should the Commission ensure
such notifications are accessible?
Other Analog Relay Issues
53. Where a form of TRS is not offered in state TRS programs, the
Commission may adopt reasonable measures to ensure equitably
distributed contributions from all interstate and intrastate service
providers subject to the Commission's authority under sections 225 and
715 of the Act. However, states are not precluded from funding and
administering any form of intrastate TRS, including internet-based TRS.
As users of TTY Relay, CTS, and STS transition to internet-based
options, the Commission seeks comment on the extent to which States
plan to continue supporting any forms of TRS, once the telephone
network has fully transitioned from analog to IP technology. For
example, assuming that the Commission affirms the eligibility of RTT-
based relay service and IP STS for TRS Fund compensation, are states
likely to support those forms of TRS? How does the broader ongoing
transition towards an all-IP communication network impact state
decision making? For states that pursue the provision of internet-based
forms of TRS, how should the Commission ensure the appropriate
separation of costs?
54. Some states, leveraging their intrastate TRS funds, have
expanded their offerings beyond analog TRS services to address the
evolving communication needs of their residents. Many states operate
telecommunications equipment programs, often supported by their
intrastate TRS funds. Beyond these, states have pursued other
specialized services and initiatives funded from their intrastate TRS
funds. Missouri, for instance, added Relay Conference Captioning (RCC)
service, a real-time captioning solution designed specifically for
conference calls and group meetings, which it funds from its intrastate
Relay Missouri Fund. Although the Commission does not mandate them, it
has encouraged states to offer non-shared language TRS, noting that
states can permissibly exceed federal mandatory minimum standards to
meet the unique needs of their diverse populations. Two states,
Maryland and Oregon, operate Communication Facilitator (CF) services,
funded from their intrastate Relay Fund, which provide equal access to
telecommunications to residents who are deafblind via in-person skilled
signers so that these people who are deafblind can participate in video
conversations.
55. These additional programs highlight how states utilize their
intrastate TRS funds for equipment distribution programs and
specialized services to address specific community needs. The
Commission seeks comment on whether there are other types of programs
or communication services, beyond those already identified, that states
are considering or funding through their intrastate TRS programs to
support their residents with hearing and speech disabilities. If states
do not end up supporting the internet-based forms of TRS, what is the
optimal role for state relay programs and their intrastate TRS funds?
The Commission also invites comments on how the Commission can support
state-specific initiatives and ensure a cohesive, efficient nationwide
TRS framework as technology and user needs continue to evolve.
56. To ensure the continued availability of TRS to those users who
may still be served by analog telephone facilities, the Commission
seeks comment on whether to establish a temporary national
certification process for providers of TTY Relay and STS. Should a
national certification process for TTY Relay and STS providers mirror
the federal certification framework already in place for internet-based
forms of TRS? The Commission believes such an approach would help
ensure that the diminishing number of users still served by copper
facilities are not left without recourse if the state chooses to
discontinue the provision of TTY Relay or terminates its TRS program
before all users in the state have access to internet-based forms of
TRS. The Commission seeks comment on that belief. Are there other
approaches the Commission should consider to ensure continued access to
TRS services during network transitions? Should the Commission
establish a sunset for the national certification process? What factors
should the Commission consider in establishing a sunset? Should it be
date specific or should the Commission rely on specific events
occurring, such as no TTY Relay use over a one-year period? If the
sunset should be dependent on specific events occurring, what events
should the Commission consider?
57. Under this approach, grant of certification would allow the
certified provider to provide TRS in any state that ends its provision
of TTY Relay or discontinues its TRS program. If more than one
application for certification is received, the Commission seeks comment
on whether the Commission should grant a national certification to a
single applicant or multiple applicants. If the Commission grants a
certification to only one entity, what factors should the Commission
consider in granting that certification? What weight should it assign
the various factors? How should service continuity be ensured in states
where current contracts expire or are terminated, and what coordination
mechanisms would be necessary between state agencies and the national
provider(s)? Alternatively, should the Commission manage the underlying
8XX telephone number associated with 711 in each state? What steps
would the Commission need to take to be able to obtain, hold, and
assign the relevant, underlying 8XX telephone number(s) for TTY Relay
within a state? If the Commission approved multiple national providers,
would the Commission be able to maintain the 711 calling structures?
Could consumers be afforded the opportunity to choose a provider when
dialing 711? What are the costs and benefits of establishing national
certification for TTY Relay? For STS? Would adopting such a national
certification process allow the
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Commission to lift the mandatory status for STS, allowing states to
transition away from analog forms of TRS without surrendering the
certification for their entire TRS program?
58. The Commission also seeks comment on whether to require any
nationally certified analog relay provider(s) to provide CTS in
addition to TTY Relay and STS. Would requiring the provision of all
three forms of analog relay service better ensure that intrastate and
interstate TRS are available nationwide to the extent possible, and in
the most efficient manner?
59. The Commission proposes that the nationally certified relay
provider(s) be compensated from the Interstate TRS Fund, where it is
providing service in a state that has discontinued its TRS program or
does not support the provided forms of TRS. This approach aligns with
the established funding mechanism for IP Relay, VRS, and IP CTS, which
are entirely supported through TRS Fund contributions based on
interstate and intrastate revenue. The Commission seeks comment on this
proposal. The Commission also invites comment on how the jurisdictional
separation of costs between intrastate and interstate funds would work
in practice, where the TRS Fund would reimburse the nationally
certified provider for both its intrastate and interstate minutes of
TRS, and state-contracted providers for only their interstate minutes.
Would such a change unduly burden the calculation of the relevant
contribution factor? The Commission also seeks comment on the potential
costs and benefits of such a funding model on both the TRS Fund and
state-administered funds.
60. While internet-based TRS users are subject to various
registration and verification requirements, analog TRS, such as TTY
Relay, CTS, and STS, currently lack comparable mandated user
registration and centralized verification processes. To further
strengthen the integrity and oversight of the entire TRS program and
build upon the recognized benefits of a user registration database, the
Commission proposes to extend comprehensive user registration and
verification requirements to all forms of TRS, including these analog
services and any future internet-based forms of TRS. This expansion is
crucial to ensuring that all services supported by the TRS Fund operate
with enhanced accountability and to combat waste, fraud, and abuse
program-wide. Such a measure would allow the Commission to gather
complete and accurate data on service demand and utilization across the
entire TRS landscape. The Commission seeks comprehensive comment on the
feasibility, costs, and benefits of extending user registration and
verification requirements to all forms of TRS. Commenters should detail
any unique technical or operational challenges for specific services
(e.g., TTY Relay, STS, CTS, or IP Relay, or proposed IP STS and RTT-
based relay service), and identify the specific types of data that
would be most relevant and least burdensome for the providers to
collect and submit. The Commission also seeks comment on the burdens
this would impose on users of each service and the providers of each
service? Have registration requirements impeded user access or caused
any users not to sign up? What privacy concerns arise with collecting
such data and what methods are available to mitigate such concerns? The
Commission also solicits input on how current user registration data
elements might apply or need modification for these services, and the
timeframe for implementation.
61. In the alternative, the Commission seek comment on codifying
and extending the current IP Relay registration requirements to analog
TRS and the proposed services of IP STS and RTT-based relay service.
Specifically, the Commission seeks comment on codifying a ``reasonable
means of verifying'' and ``consumer education and outreach efforts''
requirements into the Commission's general TRS user registration and
verification rules. This would explicitly require providers to
implement a reasonable and not unduly burdensome means of verifying
user registration and eligibility, alongside consumer education and
outreach efforts on the importance of accurate registration. The
Commission seeks comment on the appropriateness, feasibility, and
potential impact of codifying these specific requirements, including
the costs and benefits of applying them uniformly IP Relay, TTY Relay,
STS, CTS, and the proposed IP STS and RTT-based relay service.
62. The Commission also seeks comment and supporting data on the
various ways individuals currently sign up for service, such as through
an in-person representative, a remote conversation with a CA, or a
purely electronic application with no human interaction. Should the
Commission codify one or more of these proven methods, conducting in-
person or on-camera ID checks, as a safe harbor for identification
verification? The Commission invites commenters to provide specific
data on the efficacy, costs, and benefits associated with different
sign-up and verification methods, including the rate of successful
verification and user experience. The Commission also invites comments
on the safe harbor method for identification verification and whether
another method would be more effective as a safe harbor.
63. TRS providers seeking compensation from the TRS Fund must
submit Call Detail Records (CDRs) to the TRS Fund administrator for
each call for which compensation is sought. The data submission
requirements are designed to ensure effective oversight, fund
administration, and accountability, and to help enable the
determination of a TRS Fund budget for each service, as well as the
determination of provider compensation rates.
64. To further enhance the integrity and ensure consistent
oversight across the entire TRS program, the Commission proposes that
all TRS providers, including those offering traditional analog services
as well as any future forms of TRS, such as IP STS and RTT-based relay
service, submit comprehensive CDRs to the TRS Fund administrator for
intrastate and interstate TRS calls and minutes, whether or not
providers are currently compensated for those minutes from the TRS
Fund. This measure would strengthen the Commission's ability to combat
waste, fraud, and abuse, ensuring that all services supported by the
TRS Fund operate with enhanced accountability. The Commission seeks
comment on the feasibility, costs, and benefits of clarifying that all
TRS providers must meet these CDR requirements, detailing any unique
technical or operational challenges for specific services that receive
compensation from state TRS programs. Commenters should address the
specific types of data that would be most relevant and least burdensome
for analog services to collect and submit, how the current CDR data
elements (e.g., minutes of use, unique identifiers, speed of answer)
might apply or need modification for these services, and the timeframe
for implementation.
65. To help the Commission evaluate the efficacy and
appropriateness of our existing regulatory frameworks, the Commission
also seeks comment on whether any of the current CDR requirements can
be modified or eliminated to reduce administrative burden on providers
and the TRS Fund administrator, without compromising program integrity
or the Commission's oversight capabilities. Commenters should identify
specific CDR elements that they believe are redundant, obsolete, or
impose an unduly burdensome collection effort, and propose alternative
data points or
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methodologies that could achieve the same regulatory objectives more
efficiently. Are some categories of call data inapplicable or
unnecessary for certain types of TRS? Are there additional categories
of call data that should be collected for certain types of TRS? The
Commission also seeks comment on whether the current granularity of
detail required for specific call types, such as integrated VRS in
video conferences, is appropriate, or if a more streamlined approach
could be adopted.
Updating or Deleting Obsolete or Unnecessary Rules
66. As part of the Commission's effort to modernize the TRS
program, the Commission proposes to update the TRS rules by deleting or
modifying regulations that are obsolete or otherwise burdensome and
unnecessary. The Commission seeks comment on these proposals and the
questions, beliefs, and assumptions stated below.
67. Section 64.604(a)(1)(i) of the Commission's rules places a
requirement on TRS providers to ensure ``all CAs be sufficiently
trained to effectively meet the specialized communications needs of
individuals with hearing and speech disabilities.'' To meet this
requirement, many TRS providers maintain their own dedicated CA
training programs. While provider maintained training programs are a
useful and effective mechanism for ensuring CAs are sufficiently
trained, the Commission believes there are other ways TRS providers can
ensure their CAs effectively meet the specialized communications needs
of people with hearing and speech disabilities. For example, providers
may be able to establish that their CAs meet this requirement through
evidence of third-party certifications and degrees, independent
courses, and other life experience that demonstrate a CA has the
required competencies to effectively meet the needs of TRS users.
Accordingly, the Commission proposes to delete the phrase ``be
sufficiently trained to,'' giving providers more flexibility to ensure
CAs effectively meet the specialized communications needs of
individuals with hearing and speech disabilities. The Commission seeks
comment on this proposal and belief.
68. Section 64.604(a)(1)(vi) of the Commission's rules requires TRS
providers to ``make best efforts to accommodate a TRS user's requested
CA gender when a call is initiated and, if a transfer occurs, at the
time the call is transferred to another CA.'' The Commission proposes
to delete this rule. The Commission encourages TRS providers to
accommodate such requests, as fulfilling such requests may provide a
more natural call experience and reduce the number of abandoned TRS
calls. However, ``best efforts'' obligations are inherently difficult
to enforce. Further, the Commission believes TRS providers have a
built-in financial incentive to attempt to fulfill user preferences to
avoid that user changing to another provider or from the user
disconnecting and reconnecting to attempt to find a CA with specific
attributes.
69. Section 64.604(a)(3)(iii) of the Commission's rules allows TRS
providers to decline to complete a call because credit authorization is
denied. The Commission proposes to delete this rule, as the Commission
does not believe credit authorization is currently an issue for TRS
calls. In the last five years, have TRS providers ever declined to
complete a call because credit authorization is denied? If so, what is
the frequency of such occurrences? What is the cost to a provider to
complete a call where credit authorization is denied?
70. Section 64.604(a)(3)(iv) of the Commission's rules requires
analog TRS (TTY Relay, STS, and CTS) to be capable of handling pay-per-
call calls. The Commission proposes to delete this rule. The Commission
believes the use of pay-per-call (900) calls is no longer sufficiently
prevalent in the United States to warrant an explicit rule requiring
TRS providers to support that type of call. The Commission also notes
that, with or without a specific pay-per-call provision, TRS providers
remain subject to the general requirement that they ``be capable of
handling any type of call normally provided by telecommunications
carriers unless the Commission determines that it is not
technologically feasible to do so.'' Is it still technologically
feasible to complete 900 number calls using analog TRS? What are the
costs and benefits of retaining a specific requirement, given that the
general types-of-call provision would still require pay-per-call calls
to be handled if ``normally provided'' and technologically feasible?
71. Section 64.604(a)(3)(v) of the Commission's rules requires TRS
providers to provide specific types of TRS calls, such as text-to-voice
and voice-to-text, one-line voice carry over (VCO), two-line VCO, VCO-
to-TTY, and VCO-to-VCO, one-line hearing carry over (HCO), two-line
HCO, HCO-to-TTY, and HCO-to-HCO. The rule also exempts internet-based
TRS providers from some of these requirements. The Commission seeks
comment on whether updates to this provision are needed. Are there
types of TRS calls or functionality that should be added to or deleted
from the list?
72. Section 64.604(b)(2)(ii)(E) of the Commission's rules requires
a local exchange carrier (LEC), ``upon request,'' to ``provide the call
attempt rates and the rates of calls blocked between the LEC and the
TRS facility to relay administrators and TRS providers.'' The
Commission proposes to delete this requirement. When the Commission
adopted this requirement it also required TRS relay centers to be
designed to a P.01 standard, a network design standard used to ensure
that no more than one percent of calls at the busiest hour of the day
are unable to be delivered to the relay network due to inadequate
facilities. In combination with the speed of answer requirement, the
Commission could ensure that placing a call using TTY Relay was
functionally equivalent to hearing user placing a voice call. The
Commission believes that in meeting these network design standards and
measuring a TRS's providers speed of answer, it is no longer necessary
to maintain an explicit rule for a LEC that serves the TRS center to
provide call attempt rates and the rates of blocked calls between the
LEC and the relay center upon the request of relay administrators and
TRS providers. The Commission seeks comment on this belief.
73. Section 64.604(b)(4)(i) of the Commission's rules incorporates
the statutory requirement that relay services must ``operate every day,
24 hours a day.'' However, the rule exempts relay services (other than
VRS) from this requirement, if they ``are not mandated by this
Commission.'' As a result, TTY Relay and STS, as ``mandatory''
services, are required to operate 24/7, as is VRS, while other ``non-
mandatory'' services--IP Relay, IP CTS, and analog CTS--are exempt from
this requirement. While such differential application of the 24/7
requirement may have been justified on an interim basis, when the
exempt services were still in the experimental stage, the Commission
does not believe that the exemption reflects the current operating
practices of the providers of non-mandated relay service. Further, the
Commission does not believe that the exemption aligns with users'
current expectations regarding these relay services. Therefore, the
Commission proposes to delete this language and require all forms of
TRS to operate every day, 24 hours a day. Adopting this change would
bring this rule into alignment with the statutory requirement that TRS
operate every day for 24 hours per day.
[[Page 114]]
Are there any current forms of TRS, or variants thereof, for which 24/7
operation would be economically burdensome without increased TRS Fund
support? What would be the costs and benefits of continuing to exempt
such services?
74. Section 64.604(b)(5) of the Commission's rules states that
``[n]o regulation set forth in this subpart is intended to discourage
or impair the development of improved technology that fosters the
availability of telecommunications to person with disabilities.'' In
addition, Sec. 64.604(b)(5) of the Commission's rules explicitly
permits TRS facilities to ``use SS7 technology or any other type of
similar technology to enhance the functional equivalency and quality of
TRS'' and provides that facilities that use SS7 technology are subject
to the Calling Party Telephone Number rules. The Commission proposes to
delete this provision in its entirety. The statement that the TRS
regulations ``are not intended to discourage or impair the development
of improved technology'' refers to the statutory directive to the
Commission to ``ensure that regulations prescribed to implement this
section encourage, consistent with section 157(a) of this title, the
use of existing technology and do not discourage or impair the
development of improved technology.'' This statutory directive applies
regardless of any disclaimer in the Commission's rules. Thus, it
appears that the disclaimer in the Commission's rules serves no
purpose. As for the statements regarding SS7 technology, they too
appear to be mere surplusage. Without this language, the Commission
believes such technology would still be permitted for use and that the
Calling Telephone Number rules would continue to apply where SS7 is
used. As such, retention of this provision appears unnecessary.
Closing CG Docket No. 08-15
75. The Commission seeks comment on closing CG Docket No. 08-15,
Speech-to-Speech and internet Protocol (IP) Speech-to-Speech
Telecommunications Relay Services. This docket has been inactive for at
least a decade. Furthermore, the Commission conducted proceedings in
this docket in parallel with CG Docket No. 03-123. In seeking to
develop a fresh record on STS, IP STS, and video-assisted STS, the
Commission does not see a need to maintain a separate duplicative
record, and the Commission believes closing the docket eliminates a
duplicative filing requirement that unnecessarily burden commenters.
The Commission seeks comment on this belief. The only comments that
should be filed in CG Docket No. 08-15 should be those comments raising
concerns with closing CG Docket No. 08-15. Comments on all other
matters in this proceeding should be filed in CG Docket No. 03-123.
Initial Regulatory Flexibility Analysis
76. As required by the Regulatory Flexibility Act of 1980, as
amended (RFA), the Commission has prepared this Initial Regulatory
Flexibility Analysis (IRFA) of the policies and rules proposed in the
NPRM assessing the possible significant economic impact on a
substantial number of small entities. The Commission requests written
public comments on this IRFA. Comments must be identified as responses
to the IRFA and must be filed by the deadlines for comments specified
in the item.
77. Need for, and Objectives of, the Proposed Rules. In the NPRM,
the Commission proposes to phase out mandatory support for TTY Relay,
permit state TRS programs more flexibility to manage their programs,
facilitate the transition from outdated analog forms of TRS to
internet-based forms of TRS and other accessible forms of modern
communications, streamline eligibility, registration, verification, and
data collection requirements, and update or delete obsolete rules. As
communications technologies have evolved, analog TRS have seen
declining or minimal usage. The Commission proposes these changes to
align TRS with modern communications landscape and improve access and
service for users of relay service in order to meet its statutory
obligation to ensure that TRS are available, ``to the extent possible
and in the most efficient manner,'' to individuals with hearing or
speech disabilities in the United States. The Commission also seeks to
ensure that all forms of TRS are used appropriately and efficiently,
and to safeguard the TRS Fund from waste, fraud, and abuse.
78. Legal Basis. The proposed action is authorized pursuant to
sections 1, 2, 4(i), (4)(j), and 225 of the Act.
79. Description and Estimate of the Number of Small Entities
Impacted. The rules proposed in the NPRM will apply to small entities
in the All Other Telecommunications industries. The Commission
estimates that the majority of ``All Other Telecommunications'' firms
can be considered small.
80. Description of Projected Reporting, Recordkeeping, and Other
Compliance Requirements. The changes proposed in the NPRM, if adopted,
could impose new or modified reporting, recordkeeping, or other
compliance obligations on certain small entities that provide TTY
Relay, STS, CTS, or seek to provide IP STS or RTT-based relay service.
The Commission proposes to make clear the applicability of its call
data collection requirements to all forms of TRS to help the TRS Fund
administrator verify the validity of submitted minutes of use and seeks
comments on any modifications to the call data requirements to ensure
collection of appropriate data for each service and avoid unnecessarily
burdening small entities. The Commission also seeks comment on
streamlining and unifying the applicability of user eligibility,
registration, and verification rules to safeguard the TRS program. This
could include the collection and verification of user identity and
location information, as well as, eligibility certifications. The
Commission seeks comment on the specific process that should be
utilized for each form of TRS, including the type of documentation or
assessment required to confirm eligibility, and how to balance ease of
access for legitimate users with robust protections against misuse. The
information the Commission receives in comments will help the
Commission identify and evaluate relevant compliance matters, costs,
and other burdens for small entities that may result from the proposals
and inquiries made in the NPRM.
81. Significant Alternatives Considered That Minimize the
Significant Economic Impact on Small Entities. The proposed changes to
the Commission's TRS rules are designed to align the Commission's TRS
program and state TRS programs with modern communications services and
better serve the needs of relay users. The Commission seeks to
alleviate the burden to state TRS programs and analog TRS providers to
continue to support and maintain outdated forms of TRS that are
becoming more difficult to provide and support over IP-based
communication networks. To facilitate this process, while minimizing
the economic impact to small entities, the Commission inquiries on an
appropriate process for transitioning analog TRS users, plans and
timelines for changes to state TRS program, maintaining support for
analog forms of TRS during the transition period, introducing
comparable, modern forms of TRS, and aligning and right sizing
requirements for registering and verifying TRS users and collecting
call detail records. The item also inquiries about reducing burdens
through updating or deleting obsolete or unnecessarily burdensome
rules.
[[Page 115]]
82. The NPRM, seeks comment from all interested parties,
particularly those of small business entities. Small entities are
encouraged to bring to the Commission's attention any specific concerns
they may have with the proposals outlined in document FCC 25-79 and
outline any suggested alternatives. The Commission expects to consider
the economic impact on small entities, as identified in comments filed
in response to document FCC 25-79, in reaching its final conclusions
and taking action in this proceeding.
83. Federal Rules that May Duplicate, Overlap, or Conflict with the
Proposed Rules. None.
List of Subjects in 47 CFR Part 64
Communications, Communications common carriers, Communications
equipment, Individuals with disabilities, Telecommunications.
Federal Communications Commission.
Marlene Dortch,
Secretary, Office of the Secretary.
Proposed Rules
For the reasons discussed in the preamble, the Federal
Communications Commission proposes to amend 47 CFR part 64 as follows:
PART 64--MISCELLANEOUS RULES RELATING TO COMMON CARRIERS
0
1. The authority for part 64 continues to read as follows:
Authority: 47 U.S.C. 151, 152, 154, 201, 202, 217, 218, 220,
222, 225, 226, 227, 227b, 228, 251(a), 251(e), 254(k), 255, 262,
276, 403(b)(2)(B), (c), 616, 620, 716, 1401-1473, unless otherwise
noted; Pub. L. 115-141, Div. P, sec. 503, 132 Stat. 348, 1091; Pub.
L. 117-338, 136 Stat. 6156.
0
2. Amend Sec. 64.604 by:
0
a. Revising paragraph (a)(1)(i);
0
b. Removing and reserving paragraphs (a)(1)(vi), (a)(3)(iii) and (iv),
and (b)(2)(ii)(E);
0
c. Revising paragraph (b)(4)(i); and
0
d. Removing and reserving paragraph (b)(5).
The revisions read as follows:
Sec. 64.604 Mandatory minimum standards.
* * * * *
(a) * * *
(1) * * *
(i) TRS providers are responsible for requiring that all CAs
effectively meet the specialized communications needs of individuals
with hearing and speech disabilities.
* * * * *
(vi) [Reserved]
* * * * *
(3) * * *
(iii) [Reserved]
(iv) [Reserved]
* * * * *
(b) * * *
(2) * * *
(ii) * * *
(E) [Reserved]
* * * * *
(4) * * *
(i) TRS shall operate every day, 24 hours a day.
* * * * *
(5) [Reserved]
* * * * *
[FR Doc. 2025-24210 Filed 12-31-25; 8:45 am]
BILLING CODE 6712-01-P
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Document
Analog Telecommunications Relay Service Modernization
In this document, the Federal Communications Commission (Commission) proposes to modernize its telecommunications relay services (TRS) rules and seeks comment on phasing out the...
Legal Citation
Federal Register Citation
Use this for formal legal and research references to the published document.
91 FR 104
Web Citation
Suggested Web Citation
Use this when citing the archival web version of the document.
“Analog Telecommunications Relay Service Modernization,” thefederalregister.org (January 2, 2026), https://thefederalregister.org/documents/2025-24210/analog-telecommunications-relay-service-modernization.