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 STATEMENT  OF  COMMISSIONER  MICHAEL  J.  COPPS 
 Re:  Telecommunications  Relay  and  Speech-  to-  Speech  Services  for  Individuals  with  Hearing  and  Speech  Disabilities,  Order  (CC  Docket  No.  98-  67,  CG  Docket 
 No.  03-  123) 
 The  concept  of  “functional  equivalency”  is  at  the  heart  of  the  Americans  with  Disabilities  Act.  “Functional  equivalency”  means  that  54  million  Americans  have  a  right  to  equal  access  to 
 communications  technologies  and  an  equal  opportunity  to  succeed. 
 Today’s  decision  delves  deep  into  the  mechanics  of  “functional  equivalency”  by  determining  appropriate  compensation  rates.  To  this  end,  our  Order  separately  accounts  for  IP 
 Relay  and  traditional  TRS.  This  approach  allows  service  provider  compensation  to  more  accurately  reflect  cost. 


 This  Order  also  adopts  a  compensation  rate  for  VRS  based  on  a  median  of  the  individual  rates  of  providers  submitting  cost  and  demand  data.  I  support  this  outcome,  but  remain 
 concerned  that  our  calculation  of  VRS  rates  has  an  ad  hoc  and  last  minute  quality.  This  is  not  fair  to  VRS  consumers  or  providers.  We  need  to  work  harder  to  bring  consistency  and  transparency 
 to  the  calculation  process.  We  also  must  provide  an  expeditious  and  thoughtful  response  to  speed  of  answer  and  interoperability  concerns  raised  by  the  deaf  and  hard-  of-  hearing  community.  With 
 the  “functional  equivalency”  standard  as  our  guide,  I  look  forward  to  working  with  my  colleagues  to  do  so. 
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