Federal Communications Commission Washington, D.C. 20554 September 26, 2017 1 DA 17-885 Small Entity Compliance Guide Structure and Practices of the Video Relay Service Program Report and Order and Further Notice of Proposed Rulemaking DA 17-76 CG Docket No. 10-51 CG Docket No. 03-123 Released: January 17, 2017 This Guide is prepared in accordance with the requirements of Section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996. It is intended to help small entities—small businesses, small organizations (non-profits), and small governmental jurisdictions—comply with the revised rules adopted in the above-referenced Federal Communications Commission (FCC or Commission) rulemaking dockets. This Guide is not intended to replace or supersede these rules, but to facilitate compliance with the rules. Although we have attempted to cover all parts of the rules that might be especially important to small entities, the coverage may not be exhaustive. This Guide cannot anticipate all situations in which the rules apply. Furthermore, the Commission retains the discretion to adopt case-by-case approaches, where appropriate, that may differ from this Guide. Any decision regarding a particular small entity will be based on the statute and relevant rules. In any civil or administrative action against a small entity for a violation of rules, the content of a Small Entity Compliance Guide may be considered as evidence of the reasonableness or appropriateness of proposed fines, penalties, or damages. Interested parties are free to file comments regarding this Guide and the appropriateness of its application to a particular situation. The FCC will then consider whether the recommendations or interpretations in the Guide are appropriate in that situation. The FCC may decide to revise this Guide without public notice to reflect changes in the FCC’s approach to implementing a rule, or it may clarify or update the text of the Guide. Direct your comments and recommendations, or calls for further assistance, to the FCC’s Consumer Center: 1-888-CALL-FCC (1-888-225-5322) TTY: 1-888-TELL-FCC (1-888-835-5322) Videophone: 1-844-4-FCC-ASL (1-844-432-2275) Fax: 1-866-418-0232 2I. OBJECTIVE OF THE PROCEEDING On January 17, 2017, the Consumer and Governmental Affairs Bureau, pursuant to delegated authority, released the 2017 VRS Interoperability Order amending the telecommunication relay service (TRS) rules to incorporate by reference certain technical standards for the interoperability and portability of services, equipment, and software used for video relay service (VRS). 1 This service allows persons with hearing or speech disabilities to use American Sign Language to communicate in near real time through a communications assistant, via video over a broadband Internet connection. 2 The VRS interoperability and portability requirements are intended to (1) allow VRS users to make and receive calls through any VRS provider, and to choose a different default provider, without changing the access technology used to place calls, and (2) ensure that VRS users can make point-to-point calls to all other VRS users, irrespective of the default provider of the calling and called party. The 2017 VRS Interoperability Order, specifically incorporates: (1) The US Video Relay Service (VRS) Provider Interoperability Profile, Version 15, SIP Forum Document Number: VRS US Providers Profile TWG-6-1 (Oct. 14, 2015) (VRS Provider Interoperability Profile); (2) the Interoperability Profile for Relay User Equipment, draft-vrs-rue-dispatch-00 (July 20, 2016) (RUE Profile); and (3) Internet Engineering Task Force (IETF) Request for Comments (RFC) 6351, xCard: vCard XML Representation (August 2011) (xCard XML Format). II. COMPLIANCE REQUIREMENTS VRS Provider Interoperability Profile. All VRS providers must ensure that their provision of VRS and video communications, including their access technology, meets the requirements of the VRS Provider Interoperability Profile. The Provider Interoperability Profile provides technical specifications for the interface between two VRS providers, as well as the interface between a VRS provider and the TRS Numbering Directory. The VRS Provider Interoperability Profile is available from the Federal Communications Commission, 445 12th Street, SW, Washington, DC 20554, at https://www.fcc.gov/files/sip-forum-vrs-us-providers-profile-twg-6-1. RUE Profile. All VRS providers must ensure that their VRS access technologies and their video communication service platforms are interoperable with the VRS Access Technology Reference Platform (ACE App), including for point-to-point calls, in accordance with the Interoperability Profile for Relay User Equipment (RUE Profile). The RUE Profile provides technical specifications that define a standard interface between a VRS user’s equipment and the services offered by VRS providers. The RUE Profile specifies a basic interface that is usable with any provider, so that a user can freely access any provider and switch to a different default provider, without the need to change equipment or software and without experiencing any inconvenience or disruption of communications functions. VRS providers will not be compensated for minutes of use involving their VRS access technologies or video communication service platforms that are not interoperable with the VRS Access Technology Reference Platform. 3 However, the 2017 VRS Interoperability Order does not make the RUE Profile applicable to user equipment and software supplied by VRS providers at this time. 4 The RUE Profile is available from IETF Secretariat, 5177 Brandin Court, Fremont, CA 94538, 510-492-4080, at https://datatracker.ietf.org/doc/draft-vrs-rue- dispatch/. 1 Structure and Practices of the Video Relay Service Program; Telecommunications Relay Services and Speech-to- Speech Services for Individuals with Hearing and Speech Disabilities, Report and Order and Further Notice of Proposed Rulemaking, 32 FCC Rcd 687 (2017) (2017 VRS Interoperability Order). 2 Structure and Practices of the VRS Program et al., Report and Order and Further Notice of Proposed Rulemaking, 28 FCC Rcd 8618, 8621, para. 3 (2013). 3 47 CFR § 64.621(a)(3). 4 2017 VRS Interoperability Order, 32 FCC Rcd at 692, para. 13. 3xCard XML Format. All VRS providers must provide a standard xCard export interface to enable users to import their lists of contacts in xCard XML format, in accordance with the xCard XML format standard for exporting and importing user personal contact lists and user speed dial lists, RFC 6351, as specified in the RUE Profile. The xCard XML format is available from IETF Secretariat, 5177 Brandin Court, Fremont, CA 94538, 510-492-4080, at https://tools.ietf.org/html/rfc6351. III. RECORDKEEPING The 2017 VRS Interoperability Order does not impose any new recordkeeping requirements. IV. IMPACT ON SMALL BUSINESS The 2017 VRS Interoperability Order adopts rule changes governing compliance obligations and requires VRS providers to modify their networks, e.g., their protocols for routing calls to other providers and for enabling users to import contact lists, as necessary to conform to the technical standards incorporated into the existing TRS interoperability rules. The 2017 VRS Interoperability Order will, however, generally benefit small entities. Technical standards for interoperability benefit the smaller VRS providers because consumers find the services of smaller providers to be more attractive when these services are interoperable than when they are not interoperable. In addition, all of the VRS providers participated in the discussions associated with the development of the standards. Further, to minimize any adverse impact on VRS providers, the 2017 VRS Interoperability Order includes an alternative that narrows the scope of application of the technical standard for the interface between provider networks and user equipment and software, so that it governs only the interface between a provider’s network and user equipment that employs designated open-source user software, rather than all user equipment and software. Finally, the 2017 VRS Interoperability Order includes extended implementation periods to ensure that providers have sufficient time to implement the standards. V. DATES The 2017 VRS Interoperability Order became effective May 30, 2017. VRS Provider Interoperability Profile. The compliance date for meeting the standards of the VRS Provider Interoperability Profile is December 20, 2017. Rue Profile. The compliance date for meeting the standards of the RUE Profile is April 27, 2018. The Commission expects the ACE App will be released in the near future and therefore found it reasonable to allow one year from Federal Register publication of the 2017 VRS Interoperability Order for VRS providers to complete software development, testing and deployment to ensure that their networks are interoperable with the ACE App. 5 xCard XML format. The compliance date for meeting the standards of the xCard XML format is October 24, 2017. VI. INTERNET LINKS Report and Order and Further Notice of Proposed Rulemaking, DA 17-76 ? https://apps.fcc.gov/edocs_public/attachmatch/DA-17-76A1_Rcd.pdf VRS Interconnection Rules ? Electronic Code of Federal Regulations: http://www.ecfr.gov/ (Search for 47 CFR § 64.621) 5 2017 VRS Interoperability Order, 32 FCC Rcd at 692, para. 14.