Federal Communications Commission FCC 13-101   
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of 
Speech-to-Speech and Internet Protocol (IP) 
Speech-to-Speech Telecommunications Relay 
Services
Telecommunications Relay Services
And Speech-to-Speech Services for
Individuals with Hearing and Speech
Disabilities
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CG Docket No. 08-15
CG Docket No. 03-123
REPORT AND ORDER AND 
FURTHER NOTICE OF PROPOSED RULEMAKING
Adopted:  July 19, 2013 Released:  July 19, 2013
Comment Date:  (30 days after date of publication in the Federal Register)
Reply Comment Date:  (45 days after date of publication in the Federal Register)
By the Commission: Acting Chairwoman Clyburn and Commissioners Rosenworcel and Pai issuing 
separate statements.
I. INTRODUCTION
1. In this Report and Order (Order), we amend certain telecommunications relay services
(TRS) mandatory minimum standards applicable to Speech-to-Speech (STS) relay service.
1
These 
amendments will ensure that persons with speech disabilities have access to relay services that address 
their unique needs, in furtherance of the objectives of section 225 of the Communications Act of 1934, as 
amended (“Act”),
2
to provide relay services in a manner that is functionally equivalent to conventional 
telephone voice services. In the Further Notice of Proposed Rulemaking (Notice) we seek comment on 
other ways to improve the efficiency and effectiveness of the STS program, for example by creating a 
nationwide STS outreach program.  The actions taken in this proceeding and proposed in the Notice
                                                          
1
This Report and Order follows a Notice of Proposed Rulemaking seeking comment on various issues concerning 
STS.  See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities; Speech-to-Speech and Internet Protocol (IP) Speech-to-Speech Telecommunications Relay 
Service, CG Docket Nos. 03-123 and 08-15, Notice of Proposed Rulemaking, 23 FCC Rcd 10663 (2008) (2008 STS 
NPRM).  TRS, required by Title IV of the Americans with Disabilities Act of 1990 (ADA), enables a person with a 
hearing or speech disability to access the nation’s telephone system to communicate with another person through a 
relay provider and a communications assistant (CA).  See generally 47 U.S.C. § 225; 47 C.F.R. § 64.601 et seq. (the 
TRS regulations).  See also Telecommunications Relay Services and Speech-to-Speech Services for Individuals with 
Hearing and Speech Disabilities, CC Docket Nos. 90-571 and 98-67 and CG Docket No. 03-123, Report and Order, 
Order on Reconsideration, and Further Notice of Proposed Rulemaking, 19 FCC Rcd 12475, 12479-80, ¶ 3 n.18 
(2004) (2004 TRS Report and Order) (discussing how TRS works).  Unless otherwise indicated, references in this 
item to “STS” refer to PSTN- or interconnected VoIP-based STS.
2
47 C.F.R. § 225.
Federal Communications Commission FCC 13-101   
2
demonstrate the Commission’s longstanding commitment to ensuring that TRS is available to enable 
Americans with hearing and speech disabilities to communicate in a manner that is functionally 
equivalent to communications using voice telephone service.
II. BACKGROUND
A. TRS and STS
2. Title IV of the ADA requires the Commission to ensure that TRS is available to all 
individuals with hearing and speech disabilities in the United States and to increase the utility of the 
telephone system by enabling these persons to access the telephone system to make calls to, and receive 
calls from, other individuals.
3
  Under Title IV, the Commission must ensure that, “to the extent possible 
and in the most efficient manner,”
4
relay services are made available that provide access to the telephone 
system that is “functionally equivalent” to voice telephone services.
5
The functional equivalency standard
serves as a benchmark for determining which services and features TRS providers must offer to 
consumers, and is reflected throughout Title IV of the ADA and the Commission’s TRS mandatory 
minimum standards.
6
    
3. When Congress first enacted section 225 of the Communications Act, relay calls were 
placed using a text telephone device (TTY) connected to the PSTN.  Since then, the Commission has
determined that several new forms of relay fall within the definition of TRS and decided to include 
PSTN-based STS,
7
captioned telephone service (CTS),
8
video relay service (VRS),
9
Internet Protocol 
Relay (IP Relay),
10
and IP captioned telephone service (IP CTS)
11
as compensable forms of TRS.
                                                          
3
Pub. L. No. 101-336, § 401 (1990); 47 U.S.C. § 225.  When originally drafted, Title IV of the ADA limited relay 
communications to calls between individuals who had a hearing or speech disability and hearing persons.  However, 
the Twenty-First Century Communications and Video Accessibility Act (CVAA) amended the definition of TRS to 
enable people with hearing or speech disabilities to use TRS to communicate with any other individual, whether or 
not they have a disability.  Specifically, the new definition defines TRS as “telephone transmission services that 
provide the ability for an individual who is deaf, hard of hearing, deaf-blind, or who has a speech disability to 
engage in communication by wire or radio with one or more individuals, in a manner that is functionally equivalent 
to the ability of a hearing individual who does not have a speech disability to communicate using voice 
communication services by wire or radio.”  Pub. L. No. 111-260 § 103(a), codified at 47 U.S.C. § 225(a)(3). See
also S. Rep. No. 336, 111
th
Cong. 2d. Sess. (2010) at 2-3.   
4
47 U.S.C. § 225(b)(1).
5
47 U.S.C. § 225(a)(3).
6
47 U.S.C. § 225(a)(3). See also 47 C.F.R. § 64.604 (TRS mandatory minimum standards).
7
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, CC Docket No. 98-67, Report and Order and Further Notice of Proposed Rulemaking, 15 FCC Rcd 
5140, 5149, ¶ 15 (2000) (2000 TRS Report and Order). 
8
CTS is a form of TRS that allows the user to both listen to what is said over the telephone and simultaneously read 
captions of what the other person is saying on a telephone that has a text display.  See Telecommunications Relay 
Services, and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CC Docket No. 98-
67, Declaratory Ruling, 18 FCC Rcd 16121 (2003) (CTS Declaratory Ruling).
9
VRS is a form of TRS that enables the VRS user and another person to communicate through a CA in sign 
language via a video link over broadband services.  See 2000 TRS Report and Order, 15 FCC Rcd at 5152–54, ¶¶ 
21–27.
10
IP Relay is a text-based form of TRS that uses the Internet for the link of the call between the relay user and the 
CA.  See Provision of Improved Telecommunications Relay Services and Speech-to-Speech Services for Individuals 
with Hearing and Speech Disabilities, CC Docket No. 98-67, Declaratory Ruling and Second Further Notice of 
Proposed Rulemaking, 17 FCC Rcd 7779 (2002) (IP Relay Declaratory Ruling). 
Federal Communications Commission FCC 13-101   
3
4. In March 2000, the Commission mandated that carriers obligated to provide TRS also 
provide STS so that persons with speech disabilities can access the telephone system.
12
  STS utilizes 
specially trained CAs who understand the speech patterns of persons with speech disabilities and can 
repeat the words spoken by such individuals to the other parties to a relayed call.
13
  A person with a 
speech disability can initiate an STS call by dialing 711 (the nationwide access code for state relay 
providers) and giving the CA the number of the person he or she wishes to call.  The CA then makes the 
outbound call, and re-voices what the STS user says to the called party.  Persons desiring to call a person 
with a speech disability via STS can also dial 711 to reach a CA who can handle the call.  At present, 
states are responsible for compensating providers for the costs of providing intrastate STS, while the
Interstate Telecommunications Relay Services Fund (Fund) compensates providers for the costs of 
providing interstate STS.
14
B. 2006 Petition for Rulemaking to Modify STS Rules
5. On June 26, 2006, Bob Segalman and Rebecca Ladew (Petitioners) filed a petition 
requesting that the Commission amend its rules to require an STS CA to stay with the call for a minimum 
of 20 minutes, rather than 15 minutes, to the extent the call lasts 20 minutes or longer.
15
Generally, the 
TRS rules require CAs to stay with a call for at least 10 minutes prior to transferring the call to another 
CA.
16
  However, when the Commission first approved STS as a form of TRS eligible for compensation 
from the TRS Fund in 2000, it required STS CAs to stay with a call for at least 15 minutes before being 
permitted to transfer the call to another CA.
17
  The Commission explained that the longer minimum for 
STS calls was appropriate because “changing CAs can be particularly disruptive to users with speech 
disabilities.”
18
  The Commission also noted that “during the initial stages of a relay call there is a
“settling-in” period.  During this time, “callers with speech disabilities develop greater assurance that the 
CA will understand them,” and “[r]otation of a CA during an STS call disrupts this assurance, and may 
even cause the user to speak less clearly.”
19
  
6. Petitioners assert that because “STS calls often last much longer than text-to-voice 
calls[,] changing CAs on these calls prior to 20 minutes can seriously disrupt their flow and impair 
(Continued from previous page)                                                           
11
IP CTS is a form of captioned telephone relay service that uses an Internet connection to carry the captions 
between the relay provider and the user.  See Telecommunications Relay Services and Speech-to-Speech Services for 
Individuals with Hearing and Speech Disabilities; Internet-based Captioned Telephone Service, CG Docket No. 03-
123, Declaratory Ruling, 22 FCC Rcd 379, 388, ¶ 22 (2007) (IP CTS Declaratory Ruling).
12
See 2000 TRS Report and Order, 15 FCC Rcd at 5148-51, ¶¶ 14-20.
13
Id. at 5148, ¶ 14; 47 C.F.R. § 64.601(a)(30).
14
See 2004 TRS Report and Order, 19 FCC Rcd at 12482-83, ¶¶ 7-8; 47 C.F.R. § 64.604(c)(5). See also 47 U.S.C. 
§ 225(d)(3).  The Act does not prescribe a specific funding method for state programs to compensate their intrastate 
TRS providers, but states generally recover the costs of intrastate TRS either through rate adjustments or surcharges 
assessed on all intrastate end users, and reimburse TRS providers directly for their intrastate TRS costs.  
15
Bob Segalman and Rebecca Ladew, Petition for Amendment to TRS Rule on Speech-to-Speech Relay Service, CG 
Docket No. 03-123, at 1(filed June 26, 2006) (2006 STS Petition). 
16
47 C.F.R. §64.605(a)(1)(v).  A CA might transfer a call, for example, if he or she is getting ready to end a work 
shift.
17
2000 TRS Report and Order, 15 FCC Rcd at 5169-70, ¶¶ 68-70; 47 C.F.R. § 64.604(a)(1)(v).  
18
2000 TRS Report and Order, 15 FCC Rcd at 5170, ¶ 70.
19
Id.
Federal Communications Commission FCC 13-101   
4
functionally equivalent telephone service.”
20
  They explain that it generally takes a few minutes for a CA 
to begin to maximize his or her understanding of the speech patterns of a particular person with a speech 
disability, especially when people’s names and unusual technical words are used during a conversation.
21
  
Petitioners assert that reducing the frequency of CA changes will result in calls being processed more 
efficiently, and that if the Commission makes the proposed rule change the cost of STS will be reduced.
22
7. Petitioners also request that the Commission specify that the 20 minute period begins
when “effective” communication begins between the STS user and the CA.
23
Specifically, petitioners 
request that the Commission mandate that a call may not be transferred to a new CA until at least 20 
minutes have passed after the caller establishes effective communication with the CA.  Petitioners define 
effective communication to be “when the CA is able to relay the communications between the parties 
accurately and impartially, and interpret for the [person with a speech disability] both receptively and 
expressively, using any necessary specialized vocabulary.”
24
C. 2007 Request for Clarification that IP STS is a Form of TRS Eligible for 
Compensation from the Interstate TRS Fund
8. On December 21, 2007, Hawk Relay filed a Request for Clarification that IP STS is a 
form of TRS eligible for compensation from the Fund.
25
  The IP STS Request describes IP STS as a type 
of STS that uses the Internet to connect the consumer to the relay provider.
26
  Instead of using a standard 
telephone to make the relay call, an IP STS user can use a computer or mobile device
27
and, with the 
installation of softphone application software, make a voice call via the Internet to the relay provider.
28
  
According to the IP STS Request, an IP STS call is initiated by the relay user clicking an icon on his or 
her computer or device.  The user is connected to a CA over the Internet and tells the CA the number to 
be dialed; the CA then connects the IP STS user with the called party and relays the call between the two 
parties.
29
  The IP STS Request asserts that IP STS offers several benefits over PSTN-based (or 
                                                          
20
2006 STS Petition at 3.
21
Id. at 2.
22
Id. at 3.
23
Id.  The current rule simply states that the CA “answering and placing an STS call must stay with the call for a 
minimum of fifteen minutes” without specifying when this period should begin.  47 C.F.R. § 64.604(a)(1)(v).     
24
2006 STS Petition at 3.
25
Hawk Relay, Request for Expedited Clarification for the Provision and Cost Recovery of Internet Protocol 
Speech-to-Speech Relay Service, CG Docket No. 08-15 (filed Dec. 21, 2007) (IP STS Request).  The IP STS Request
was moved from CG Docket No. 03-123 to a newly created docket for IP STS related issues, CG Docket No. 08-15.  
Hawk Relay no longer holds eligibility certification for the provision of relay services as its 5-year certification 
period expired on September 21, 2012.  See Notice of Certification of Hawk Relay, LLC as a Provider of Internet 
Protocol Relay (IP Relay) and Video Relay Service (VRS) Eligible for Compensation from the Interstate 
Telecommunications Relay Service (TRS) Fund, CG Docket No. 03-123, Public Notice, 22 FCC Rcd 17020 (2007)
(granting a 5-year certification period).  However, various other parties, including the Interstate TRS Council and 
various consumer groups have expressed their strong support for an IP version of STS. 
26
Id. at 3 (IP STS is “no different than traditional STS except … that the user connects to a relay provider through 
the Internet”).
27
The IP STS Request indicated that individuals could use personal digital assistants, or PDAs, to make STS calls.  
Id. at 2-3.  We refer more broadly to mobile devices in this Order. 
28
Id. at 2-3.  
29
Id. at 3.
Federal Communications Commission FCC 13-101   
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“traditional”) STS, including portability (the user’s electronic device is not tied to a specific location) and
ease of use, particularly for persons with limited dexterity (the user does not have to dial a number, but 
can just click on one icon, to initiate a call).
30
  
9. The IP STS Request further asserts that, as “an extension of traditional STS,” IP STS falls 
within the scope of TRS under Title IV of the ADA because it allows persons with speech disabilities to 
access the telephone system to communicate by wire or radio.
31
  The IP STS Request also notes that 
Congress requested the Commission to adopt TRS regulations that do “not discourage or impair the 
development of improved technology.”
32
  Consistent with this mandate, the IP STS Request explains, the 
Commission has previously recognized new forms of TRS, including other Internet-based forms of TRS 
(VRS, IP Relay and IP CTS), and so IP STS calls should also be eligible for compensation from the 
Fund.
33
  Finally, the IP STS Request asks that certain TRS mandatory minimum standards be waived for 
IP STS either because they have been waived for STS or are not applicable to an Internet-based service.
34
    
D. 2008 STS NPRM
10. On June 24, 2008, the Commission released the 2008 STS NPRM in response to the 2006 
STS Petition and the IP STS Request.
35
  The Commission sought comment on whether to amend the TRS 
rules to require STS CAs to stay with a call for a minimum of 20 minutes (rather than 15 minutes), and 
whether the Commission should more specifically define the point at which the minimum period of time 
begins to run.
36
  The Commission also sought comment on two other STS issues related to service quality.  
First, the Commission sought comment on whether to amend the TRS rules to require that STS providers 
offer the STS user the option of having his or her voice muted so that the other party to the call will hear 
only the STS CA re-voicing the call, and not the voice of the STS user as well.
37
  Second, the 
Commission sought comment on whether there are ways to ensure that STS users calling 711, the 
nationwide dialing access code for TRS, will promptly reach an STS CA to handle their calls.
38
  The 
latter inquiry followed a prior Commission inquiry, initiated in 2003, into whether access to STS could be 
improved by using a dialing menu, e.g., an interactive voice response (IVR) system that would allow STS 
                                                          
30
Id. at 3-5.
31
Id. at 5, citing 47 U.S.C. § 225(a)(3).
32
Id. at 5, citing 47 U.S.C. § 225(d)(2).
33
Id. at 5.  The IP STS Request did not, however, address whether all IP STS calls should be compensated from the 
Fund (i.e., both interstate and intrastate), and did not suggest what the appropriate IP STS compensation rate should 
be, or whether it should be different than the interstate STS rate.
34
Id. at 6-7. See generally 47 C.F.R. § 64.604.  On February 4, 2008, the Consumer and Governmental Affairs 
Bureau sought comment on the IP STS Request in a Public Notice.  Consumer & Governmental Affairs Bureau 
Seeks Comment on Request for Clarification that Internet Protocol Speech to Speech Service is a Form of 
Telecommunications Relay Service Compensable from the Interstate TRS Fund, CG Docket No. 08-15, Public 
Notice, 23 FCC Rcd 1649 (2008).  See Appendix B for list of commenters to this Notice.    
35
See 2008 STS NPRM.
36
Id. at 10668, ¶¶ 14-15.
37
Id. at 10668-69, ¶ 16.
38
Id. at 10669, ¶ 17.  In 2000, the Commission adopted nationwide 711 dialing access to allow both persons with 
hearing and speech disabilities and persons without such disabilities to initiate a TRS call from any telephone, 
anywhere in the United States, and be connected to the TRS facility serving that calling area.  Use of N11 Codes and 
Other Abbreviated Dialing Arrangements, CC Docket No. 92-105, Report and Order, 15 FCC Rcd 15188 (2000) 
(711 TRS Dialing Order).  711 dialing access for TRS became effective on October 1, 2001.  Id. at 15204, ¶ 32.
Federal Communications Commission FCC 13-101   
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users to choose STS as the first option in a voice dialing menu.
39
  Although the Commission declined to 
adopt such a requirement at that time, the Commission stated that it would continue to monitor the 
implementation of 711 dialing access for TRS calls (including STS calls) and encouraged TRS providers 
to be innovative in finding ways to facilitate access to their services.
40
11. With respect to IP STS, the 2008 STS NPRM sought comment on its tentative conclusions 
that IP STS is a form of TRS compensable from the Fund, that it should be compensated at the same rate 
as STS, and that an entity desiring to offer IP STS could become eligible to do so by being accepted into a 
certified state TRS program, subcontracting with an entity that is part of a certified state program, or by 
seeking Commission certification.
41
  The Commission also tentatively concluded that “present eligibility 
to receive compensation from the Fund for the provision of other forms of TRS (including STS) would 
not confer eligibility with regard to the provision of IP STS.”
42
  Further, the Commission sought comment 
on the extent to which certain TRS mandatory minimum standards should be temporarily waived or 
permanently made not applicable to IP STS.
43
  In addition, the Commission sought comment on whether 
the requirements for emergency call handling and ten-digit numbering in the 2008 Interim Emergency 
Call Handling Order
44
and the 2008 TRS Numbering Order
45
should apply to IP STS.
46
12. In the 2008 STS NPRM, the Commission also sought comment on specific outreach 
efforts that could extend the reach of STS (and possibly IP STS) to new users, and asked whether the 
                                                          
39
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, CC Docket No. 98-67, CG Docket No. 03-123, Second Report and Order, Order on Reconsideration, 
and Notice of Proposed Rulemaking, 18 FCC Rcd 12379, 12410-11, ¶¶ 50-52 (2003) (2003 TRS Order).
40
Id. at 12411-12, ¶ 53. In the 2003 TRS Order, the Commission also declined to adopt a separate three digit access 
number specifically for STS, concluding that the ability to use the general 711 TRS dialing code provided an 
adequate means for STS consumers to reach an STS CA.  See also 2000 TRS Report and Order, 15 FCC Rcd at 
5192, ¶ 126 (seeking comment on a separate nationwide access number for STS relay).  The Commission explained 
that in any 711 call, the CA has to route and set up the call according to the type of TRS call (e.g., STS) requested.  
To the extent STS calls are not reaching STS CAs in an appropriate fashion, the Commission added, the TRS 
provider may need to provide additional CA training, deploy advanced technologies, or offer multiple dialing 
options. 2003 TRS Order, 18 FCC Rcd at 12410-11, ¶ 51.
41
2008 STS NPRM, 23 FCC Rcd at 10669-71, ¶¶ 18-23.
42
Id. at 10671, ¶ 23. The Commission first established federal certification procedures for common carriers desiring 
to offer VRS and IP Relay service in 2005.  Telecommunications Relay Telecommunications Relay Services and 
Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123, Report 
and Order and Order on Reconsideration, 20 FCC Rcd 20577 (2005) (Provider Certification Order).  More recently, 
the Commission adopted new rules amending its processes for certifying all Internet-based TRS providers seeking 
eligibility for payment from the Fund.  See Structure and Practices of the Video Relay Service Program, CG Docket 
No. 10-51, Second Report and Order, 26 FCC Rcd 10898 (2011) (iTRS Certification Order).
43
2008 STS NPRM, 23 FCC Rcd at 10671-72, ¶ 24.
44
  Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities; E911 Requirements for IP-Enabled Service Providers, CG Docket No. 03-123, WC Docket No. 05-
196, Report and Order, 23 FCC Rcd 5255 (2008) (2008 Interim Emergency Call Handling Order).  Specifically, the 
Commission required Internet-based TRS providers to, in part:  (1) accept emergency calls and deliver them to an 
appropriate public safety answering point that corresponds to the caller’s location; (2) request, at the beginning of an 
emergency call, the caller’s location; and (3) implement a system so that incoming emergency calls are given 
priority handling if there is a queue. Id. at 5265, ¶ 16.
45
See 2008 TRS Numbering Order. 
46
2008 STS NPRM, 23 FCC Rcd at 10672, ¶ 25.    
Federal Communications Commission FCC 13-101   
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Commission should mandate such efforts for both intrastate and interstate providers.
47
  In addition, the 
Commission requested public feedback on whether it has the authority to require individual states to 
increase the compensation rates paid for intrastate STS, and ways to ensure that compensation for 
providers is adequate for the level of outreach necessary to reach potential STS users.
48
  Finally, the 
Commission sought comment on a suggestion to have a single, nationwide provider offer both interstate 
and intrastate STS and IP STS.
49
      
E. 2010 Interstate TRS Advisory Council Proposal/2010 STS Petition 
13. On October 20, 2010, the Interstate TRS Advisory Council
50
voted, at its semi-annual 
meeting, to propose that the Commission: (1) establish one nationwide outreach program for STS rather 
than having each state TRS program conduct individual outreach efforts; (2) initiate a rulemaking 
proceeding on the feasibility of establishing one nationwide STS provider; and (3) approve IP STS as a 
compensable form of TRS.
51
  On November 12, 2010, Petitioners submitted a second petition 
recommending adoption of the first two of the Advisory Council’s proposals, and proposing other matters
for the Commission’s consideration.
52
  Specifically, the petition requested first that the Commission 
utilize a single entity to deliver an effective, nationwide outreach program.
53
  In this regard, the petition 
alleged that although six different STS providers had received more than $394,000 in outreach funding 
from March 2008 through July 2010, during that same period, STS call volumes had decreased.  Next, 
Petitioners requested that the Commission initiate a proceeding to administer STS through a single 
provider, both because of the small volume associated with this service, and “to avoid the many problems 
that have resulted from VRS being administered by a large number of [providers].”
54
      
                                                          
47
Id. at 10672-73, ¶¶ 26-27.
48
Id. at 10673, ¶ 27.
49
Id. at 10673, ¶ 28, citing SCT Comments at 6.  In response to the 2008 STS NPRM, the Commission received ten 
comments and five reply comments.  See Appendix B for list of commenters to this and related notices in this 
proceeding.
50
The Interstate TRS Advisory Council monitors matters concerning TRS cost recovery for the Commission.  
Pursuant to 47 C.F.R. § 64.604(c)(5)(iii)(H), the TRS Fund Administrator established the council as “a non-paid 
voluntary advisory committee of persons from the hearing and speech disability community, TRS users (voice and 
text telephone), interstate service providers, state representatives, and TRS providers, which [meets] at reasonable 
intervals (at least semi-annually) in order to monitor TRS cost recovery matters.” See also Telecommunications 
Relay Services and the Americans with Disabilities Act of 1990, CC Docket No. 90-571, Third Report and Order, 8 
FCC Rcd 5300 (1993) (discussing the need for and creation of this council).
51
See National Exchange Carrier Association, Telecommunications Relay Services and Speech-to-Speech Services 
for Individuals with Hearing and Speech Disabilities, CG Docket Nos. 03-123 and 10-51, Interstate 
Telecommunications Relay Services Fund Payment Formula and Fund Size Estimate, Exhibit F (Apr. 29, 2011) 
(2011 Annual TRS Rate Filing) (filed with the accompanying TRS Advisory Council Meeting Minutes of October 
20, 2011).
52
Bob Segalman and Rebecca Ladew, Petition for Rulemaking, CG Docket No. 03-123 (filed Nov. 12, 2010) (2010 
STS Petition). Bob Segalman has served on the Interstate TRS Advisory Council.
53
2010 STS Petition at 2.
54
Id. at 2-3.   The petition also requested approval of “remote interpreting” to allow speech and language 
pathologists to work from home as STS CAs, to the extent such remote interpreting is approved for VRS.  Id. at 3-4.  
Insofar as the practice of handling VRS from home is currently prohibited, we reject this request at this time.  See 47 
C.F.R. § 64.604(b)(4)(iii); Structure and Practices of the Video Relay Service Program, CG Docket No. 10-51, 
Report and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 5545, 5556-5558, ¶¶ 16-20 (2011) (VRS 
Structure and Practices Order).  To the extent that we revise this VRS rule, we will consider re-visiting this matter 
as well for STS CAs. 
Federal Communications Commission FCC 13-101   
8
F. 2011 Petition for Rulemaking for Video Assisted STS 
14. On October 20, 2011, SCT, together with eight other national disability organizations,
filed a petition requesting the Commission to open a proceeding on modernizing STS to allow people 
with speech disabilities to benefit from modern IP technologies through the use of video-assisted STS, or
VA-STS (2011VA-STS Petition).
55
  VA-STS connects the caller and the CA via a broadband video link, 
which allows the CA to see STS users as they are speaking.  Petitioners claim that giving the CA the 
ability to see the STS caller’s mouth movements, facial expressions, and gestures, and possibly even cue 
cards, can enable the CA to better understand and re-voice for the caller.
56
  In this manner, Petitioners 
assert, VA-STS provides functional equivalence to many individuals with speech disabilities who are not 
able to utilize traditional STS successfully.
57
  Petitioners point to the fact that there are many face and 
body indicators, including the “location, orientation and movement of body, body parts and head, facial 
expression and other non-manual indicators” that can add meaning to the speech of a speech impaired 
individual, and without which cues the individual may not be understood.
58
  
III. REPORT AND ORDER
A. Amendments to STS Mandatory Minimum Standards 
15. We amend our rules to require for each STS call lasting for 20 minutes or longer, that an
STS CA stay with the call for a minimum of 20 minutes before transferring the call to another CA.
59
  We 
also specifically define the point at which this time period starts.  We further require STS providers to 
provide consumers the option to have their voice muted, and to provide a means by which STS users 
dialing 711 may promptly reach an STS CA.
60
  We decline to require state TRS programs to increase their 
outreach funding for intrastate STS calls,
61
but in the accompanying Notice, consider a proposal for STS 
to be offered through a single nationwide provider, as well as the merits of coordinating a national 
                                                          
55
Speech Communications Assistance by Telephone (SCT), Petition for Rulemaking for Video Assisted STS (VID-
STS) to Facilitate Phone Communication for People with Severe Speech Disabilities, CG Docket No. 03-123 (filed 
Oct. 20, 2011) (2011 VA-STS Petition).  SCT was joined in this petition by the American Association of People with 
Disabilities, Telecommunication for the Deaf and Hard of Hearing, Inc. (TDI), the Disability Rights and Education 
Defense Fund, the National Association of the Deaf, the Washington State Communications Access Project, the SSB 
BART Group, TecAccess, and the Autistic Self-Advocacy Network. Also attached to the Petitioners’ submission is 
a consumer petition signed by over 80 individuals and organizations in support of VA-STS.  The 2011 VA-STS 
Petition refers to video-assisted STS as VID-STS.  However, since some states now providing this service refer to it 
as VA-STS, for the purposes of this proceeding, the Commission has adopted the VA-STS acronym.  See e.g., 
California (VA-STS) http://ddtp.cpuc.ca.gov/default1.aspx?id=2974.
56
2011 VA-STS Petition at 2.
57
Id. (positing that one reason that the current form of STS may be underutilized is that many people with speech 
disabilities can only be understood if they can be seen by the person with whom they are communicating when 
making phone calls and that, without these additional cues, the CA has insufficient information to facilitate a 
conversation).
58
Id. Petitioners also argue that the addition of VA-STS as a form of STS that can be made available to users would 
enhance the employability of individuals with speech disabilities, and improve their access to emergency services. 
Id. at 3. They further claim that such a regulatory change would comport with the intent of the CVAA, because this 
law “recognizes how new technologies are converging and can be used to support the phone conversations of people 
with hearing and speech disabilities.”  Id. at 4.
59
For calls of less than 20 minutes, the same CA must remain on the call for the duration of the call.  We thus grant 
in part the relief sought in the 2006 STS Petition.
60
These issues were raised in the 2008 STS NPRM, 23 FCC Rcd at 10668-69, ¶¶ 16-17.
61
See 2008 STS NPRM, 23 FCC Rcd at 10672-73, ¶ 26.
Federal Communications Commission FCC 13-101   
9
outreach program for STS through a single entity.
62
  In addition, in the Notice, we seek input on whether 
to adopt other measures that may have the potential to improve the STS program.   
16. Minimum Time Period a CA Must Stay with a Call.  As we have recognized in the past,
given the nature of the interaction between an STS user and an STS CA, requiring a longer minimum 
period of time that an STS CA must stay with a call than is required for other forms of TRS furthers 
section 225’s functional equivalency objective.  Based upon the record concerning past experience with 
the preexisting 15 minute period of time that an STS CA must stay with a call, we now conclude than an 
incremental increase to 20 minutes would better ensure functional equivalency, and we amend our rule 
accordingly.
63
  In particular, although the Commission’s rules currently require STS CAs to stay with a 
call for 15 minutes, Petitioners claim that allowing for the currently required extra 5 minutes beyond the 
10 minute stay time required for traditional TRS is still not sufficient for STS users.  Specifically, as 
noted above, Petitioners assert that “changing CAs on . . . calls prior to 20 minutes can seriously disrupt 
their flow and impair functionally equivalent telephone service.”
64
  Although some providers contend that 
a 20 minute stay time is too burdensome,
65
other commenters to this proceeding agree on the importance 
of extending the CA stay time to at least 20 minutes – and potentially even longer – noting that it 
generally takes a substantial period of time (up to ten minutes or more) for an STS CA to adjust to, and 
develop effective communication with, an STS user, given STS users’ unique speech patterns.
66
  The 
record also confirms that transferring an ongoing call to a new CA is often disruptive because the new 
STS CA must adjust to the speech patterns of the STS user.
67
  Further, as the 2006 STS Petition notes, 
persons with speech disabilities often require a greater amount of time and concentration to perform the 
tasks of listening to the other party, thinking, forming a response, and then speaking.
68
  STS users also 
require greater time to spell out more unusual names and words that the CA may have difficulty 
understanding.
69
  Moreover, we believe that an incremental increase of 5 minutes in the minimum stay 
time for STS CAs strikes the appropriate balance between concerns regarding the burdens on CAs and the 
record evidence regarding the needs of STS users.
70
  For these various reasons, we revise our rules to 
                                                          
62
See 2010 STS Petition at 2-3.
63
See Appendix A (amending 47 C.F.R. § 64.604(a)(1)(v)).
64
2006 STS Petition at 3.
65
GoAmerica (predecessor to Purple Communications) does not support extending the minimum time to 20 
minutes.  It asserts that in many cases, given the long call set up time, the CA could be required to stay on a call for 
a long period of time without a break.  GoAmerica Comments at 7.  Sprint, although not specifically objecting to 
extending the minimum time to 20 minutes, suggests that no minimum time should be mandated and that providers 
should simply be required to offer and ensure quality service throughout a call.  Sprint Comments at 2.
66
See AAPD Comments at 4 (filed June 12, 2008); AT&T Comments at 2 (filed Sept. 12, 2008); TDI Coalition 
Comments at 2 (filed Sept. 12, 2008); Ching Comments at 1-2 (filed July 28, 2008); Cohen Reply Comments at 1 
(filed Sept. 29, 2008); Gaston Reply at 1 (filed Sept. 15, 2008); Letter from Claude L. Stout, TDI, et al., to Hon. 
Julius Genachowski, Chairman, FCC, et al., CG Docket Nos. 03-123, 08-15, at 2 (filed June 19, 2012) (TDI et al.
June 19, 2012 Ex Parte Letter); Letter from Tricia K. Buckles Shepherd, President, California Speech-Language-
Hearing Association, to Hon. Julius Genachowski, Chairman, FCC, et al., CG Docket Nos. 03-123 and 08-15, at 1 
(filed Sept. 25, 2012) (CSHA Sept. 25, 2012 Ex Parte Letter). 
67
2006 STS Petition at 2; AAPD Comments at 4; TDI Coalition Comments at 2-3.
68
2006 STS Petition at 2.
69
Id. 
70
As discussed above, some commenters argued that a minimum stay time of even longer than 20 minutes might be 
needed, while some providers express concern about the burden a 20 minute stay time could pose for CAs.  With 
respect to the latter issue, we note that AT&T stated that “The Commission [initially] limited the ‘stay’ period for 
STS CAs to 15 minutes due to concerns about fatigue of the CAs. . . .  AT&T’s experience has been that most CAs 
(continued....)
Federal Communications Commission FCC 13-101   
10
require that STS CAs stay on a call for a minimum of 20 minutes to ensure that such calls are not unduly 
disrupted and that STS users have meaningful access to the telephone system, consistent with section 
225’s goal of functional equivalency.
71
17. Commenters are divided on when this 20 minute period should begin to run.  A few 
commenters suggest that the 20 minute period should begin when the CA can adequately understand the 
speech of the STS user, so that the CA can effectively voice what the STS user says to the other party to 
the call.
72
  Some of these parties further suggest that the STS user be the one who determines when such 
“effective communication” has been established.
73
  However, other commenters, such as AT&T, advocate
for use of a more objective standard to signal the start of this 20 minute period, such as when the CA 
reaches the called party.
74
18. We conclude that the 20 minute time period should begin when the CA reaches the called 
party, and amend our rules accordingly.
75
  Although we recognize the importance of ensuring that the 
STS user and the CA are able to understand one another, so that the CA accurately conveys the utterances 
of the person with a speech disability, we are concerned that Petitioners’ request to base this starting time 
on what they define as “effective communication” – i.e., “when a CA is able to relay the communication 
between the parties accurately and impartially, and interpret for the [person with a speech disability] both 
receptively and expressively, using any necessary specialized vocabulary”
76
– is too subjective to allow 
for any meaningful enforcement of the 20 minute rule. Therefore, we adopt an objective standard to 
define when the 20 minute period begins to run:  when the CA reaches the called party and begins 
relaying the call.  However, we emphasize that, for calls initiated by persons with speech disabilities, the 
CA should initiate an outbound call to the voice telephone user only when he or she is effectively
communicating with the STS user.  Moreover, especially for STS calls initiated by persons without a 
speech disability, we conclude that if, once the called party has been reached, the STS user and the CA 
are at any point unable to communicate effectively, the STS provider may switch the call to a different 
CA before the 20 minute period has expired without violating the 20 minute in-call replacement rule.  
Such result is consistent with our ruling in the VRS context, that “if the party using sign language or the 
VRS CA find that they are not communicating effectively given the nature of the call, the VRS provider 
may have another CA handle the call without violating the 10-minute in-call replacement rule.”
77
  The 
(Continued from previous page)                                                           
stay on a STS call for much longer than 15 minutes and that adding five more minutes to the mandatory stay period
will have minimal impact on the CAs’ fatigue level.”  AT&T Comments at 3, n.3.
71
The 15 minute CA stay time was adopted in the 2000 TRS Report and Order when the Commission concluded 
that STS falls within the scope of the TRS definition and requires that common carriers offer STS by March 2001.  
See 2000 TRS Report and Order, 15 FCC Rcd at 5171, ¶ 70.  The Petitioners now reasonably request a longer stay 
time based on a number of years of experience with the 15 minute stay rule.
72
See e.g., AAPD Comments at 3-4; TDI Coalition Comments at 2-3; Ching Reply Comments at 2; Cohen Reply 
Comments at 2; TDI Coalition Reply Comments at 4-5.
73
See e.g., Ching Reply Comments at 2.  
74
See AT&T Comments at 3. 
75
See Appendix A (amending 47 C.F.R. § 64.604(a)(1)(v)).  We note that this is the same starting point for 
measuring billable conversation minutes.
76
See 2006 STS Petition at 3.
77
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, CG Docket No. 03-123, Order, 21 FCC Rcd 6733, 6736, ¶ 9 (2006) (VRS In-Call Replacement Order) 
As we stated in the context of VRS, the exception to the STS 20 minute in-call replacement rule does not permit 
STS providers or CAs to switch CAs for other reasons unrelated to the ability to effectively communicate.  Id. at 
6736, ¶ 9 n.30.
Federal Communications Commission FCC 13-101   
11
Commission adopted this exception because the in-call replacement rule “is principally intended for the 
benefit of the TRS user,” and when the user and the CA are not effectively communicating, the in-call 
replacement rule should not act as a barrier to ensuring that the relay provider can appropriately handle 
the call.
78
  We believe the same exception should apply to STS, for the same reasons.   
19. Option for STS User to Have Voice Muted.  We conclude that STS providers must offer 
STS users the option to have their voices muted so that the other party to the call will hear only the CA, 
not the user’s voice, and we amend our rules accordingly.
79
  Commenters supported this requirement,
80
and the record reflects that some TRS providers already offer this option.
81
  We agree with commenters 
that this option will likely give more persons with speech disabilities the confidence to use STS because 
many such individuals are hesitant to allow the called party to hear their speech.
82
  For STS users who
want this option, we believe it will help to minimize disruption to the conversational flow of a call, 
thereby increasing the STS user’s ability to carry on a phone conversation that is functionally equivalent 
to a voice-to-voice call. Accordingly, we amend our rules to require that all STS providers offer each STS 
user the option to have his or her voice muted so that the other party to the call will only hear the CA, not 
the user’s voice. 
20. STS Calls Initiated by Dialing 711.  In 2000, the Commission adopted nationwide 711 
dialing access to allow both persons with disabilities and voice telephone users to initiate a TRS call from 
any telephone, anywhere in the United States, and be connected to the TRS facility serving that calling 
area.
83
  The Commission found that by eliminating the difficulties that individuals had with finding or 
remembering various relay numbers as they traveled from state to state, and by reducing the number of 
digits needed for accessing relay services, nationwide implementation of 711 access to TRS made relay 
access convenient, fast, and uncomplicated, resulting in greater functional equivalence for TRS use.
84
21. As noted above, in 2008, we sought comment on a number of 711 issues specific to STS 
users.
85
  We noted that the Commission was in receipt of complaints from STS users who reported being 
disconnected upon dialing 711 during the transfer to an STS CA, indicating perhaps a lack of proper 
training on the part of some CAs, or the lack of proper equipment to receive and transfer STS calls to an 
STS CA.
86
  We asked whether there are means by which we could ensure that STS users can reach an 
STS CA promptly and without disconnection after dialing 711, for example through the use of a prompt 
or menu.
87
  In response, several commenters propose that when an STS user dials 711, the call should 
automatically reach an interactive voice response (IVR) system menu with STS as an option at the first 
                                                          
78
Id.
79
See Appendix A (adding 47 C.F.R. § 64.604(a)(1)(viii)).
80
See e.g., AAPD Comments at 4; AT&T Comments at 3; TDI Coalition Comments at 3; Hamilton Comments at 2; 
Cohen Reply Comments at 2; TDI et al. June 19, 2012 Ex Parte Letter at 2; CSHA Sept. 25, 2012 Ex Parte Letter at 
1.
81
See, e.g., GoAmerica Comments at 7; Hamilton Relay Comments at 2.
82
See, e.g., AAPD Comments at 4; TDI Coalition Comments at 3.
83
711 TRS Dialing Order.  711 dialing access for TRS became effective on October 1, 2001.  Id. at 15204, ¶ 32.
84
711 TRS Dialing Order, 15 FCC Rcd at 15196-97, ¶ 14.
85
2008 STS NPRM, 23 FCC Rcd at 10669, ¶ 17. 
86
2008 STS NPRM, 23 FCC Rcd at 10666, ¶ 9. 
87
Id. at 10669, ¶ 17. The Commission had declined to adopt this type of dialing menu requirement for 711 in its 
2003 TRS Order, but stated therein that it would monitor the implementation of 711 dialing access, as 711 dialing 
access was relatively new at that time.  2003 TRS Order, 18 FCC Rcd at 12411-12, ¶¶ 52-53.
Federal Communications Commission FCC 13-101   
12
level of menu prompts, such as “Press 1 for Speech-to-Speech service.”
88
  Sprint offers such functionality 
in Texas and New York.
89
22. Rather than mandating any particular technical solution,
90
we conclude that STS 
providers must, at a minimum, employ the same means of enabling their STS users to connect to a CA 
when dialing 711 that they use for all other forms of TRS.  For example, where a provider requires its 
CAs to directly answer incoming 711 calls (i.e., they do not use an IVR menu system for incoming TRS 
calls), it must ensure that its CAs are trained to discern the specific needs of STS users and promptly 
transfer these incoming calls to STS CAs, so that these callers have the same timely access to 
communications that other TRS callers have.
91
Additionally, the provider may not require that the caller 
hang up and dial a different number (e.g., a toll free number) to reach an STS CA because this, too, would 
defeat the purpose of requiring easy dialing access as established in the 711 TRS Dialing Order,
92
and 
impose a particular hardship on STS users, many of whom have limitations in their motor dexterity due to 
stroke, cerebral palsy or other muscular limitations that have caused their speech disabilities.
93
  Moreover, 
ensuring that an STS user does not have to dial twice to reach an STS CA appropriately implements
section 225’s requirement that TRS be provided in a manner that is functionally equivalent to traditional 
telephone service.
94
23. To the extent that a provider uses an IVR menu system that allows a direct connection to 
a CA for TTY-based and other forms of TRS on the first level of menu prompts, it must allow STS users 
to connect directly to an STS CA from that first level of prompts.
95
  Ensuring that STS users are not 
required to navigate through extra dialing menus will enable such users to communicate by telephone in a 
manner that is functionally equivalent to the ability of an individual who does not have a speech 
disability.
96
  In addition, having such direct access should be especially helpful to STS users, who, as 
noted above, may have dexterity limitations.     
24. We note, however, that the mandate for 711 dialing does not preclude STS providers 
from offering a single nationwide toll free number as a supplement to 711 dialing access.  Indeed, the 711 
                                                          
88
See e.g., AAPD Comments at 5; Sprint Comments at 3; TDI Coalition Comments at 5; Cohen Reply at 3; TDI et 
al. June 19, 2012 Ex Parte Letter at 3.
89
See Sprint Comments at 3 (supporting the dialing prompt requirement for STS).
90
See AT&T Comments at 4 (opposes the mandate of any specific technical solution to allow providers to develop 
solutions that enable STS users to reach an STA CA with least amount of effort); GoAmerica Comments at 8 
(asserting that requiring a first level IVR prompt would unduly burden the 99 percent of 711 calls that are not STS 
calls).  Because we do not mandate any specific technical solution at this time, we conclude that our approach does 
not implicate AT&T’s and GoAmerica’s concerns.
91
See Hamilton Comments at 3 (explaining that Hamilton trains its employees to discern the specific needs of STS 
users and does not use an IVR with its 711 system).
92
See AAPD Comments at 4-5 (noting that STS users are sometimes instructed to hang up and dial a toll free STS 
number or that their phone calls are directed to a traditional TRS CA, not one trained in STS); TDI Coalition Reply 
Comments at 6-7.  
93
See e.g., AAPD Comments at 5; TDI Coalition Comments at 5.  See also ¶ 31 infra, describing various medical 
conditions and illnesses that can result in developing a speech disability.
94
See 47 U.S.C. § 225(a)(3). 
95
Specifically, when an STS user dials 711 and connects to an IVR system, if the user receives a list of options, 
such as “Press one for TTY relay, press two for voice carryover relay,” one of these options must allow him or her 
to press a number to reach an STS CA (e.g., “press three for speech-to-speech relay”). 
96
See 47 U.S.C. § 225(a)(3).
Federal Communications Commission FCC 13-101   
13
TRS Dialing Order encouraged the use of alternate, direct access numbers to reach specific relay services 
and made clear that such numbers, as well as caller profiles, which can speed call processing by enabling 
TRS centers to respond to STS callers using their preferred mode of communication, “could provide a 
means of handling relay calls in a manner that is consistent with our mandatory minimum standards.”
97
  
However, contrary to the suggestions of some commenters, a dedicated toll-free number for STS calls 
cannot take the place of 711 STS dialing access, as this would be inconsistent with the intent of the 711 
TRS Dialing Order, which was to ensure that easy dialing access be available to all persons with hearing 
and speech disabilities seeking to use TRS across the country, as well as to voice telephone users seeking 
to call such persons.
98
The same considerations underlying that prior decision continue to persuade us 
that this approach best implements section 225.
B. IP and VA-STS 
25. In the 2008 STS R&O and NPRM, the Commission tentatively concluded that IP STS
meets the definition of TRS under section 225(a)(3) of the Act, and thus may be eligible for compensation
from the Fund.
99
  We explained that IP STS allows persons with speech disabilities to use a computer or 
PDA connected to the Internet, rather than a standard telephone connected to the PSTN, to initiate a call 
and speak to a CA.
100
  In this regard, we noted that IP STS borrows from both the STS and IP Relay 
services that the Commission has previously recognized as forms of TRS.  We also noted that using the 
federal TRS Fund to compensate providers for both interstate and intrastate calls (rather than interstate 
calls only) would be “consistent with the present treatment of the other Internet-based forms of TRS –
VRS, IP Relay, and IP CTS – and the fact that because one link of the call is made via the Internet it is 
generally not possible to determine if a particular call is interstate or intrastate.”
101
  
26. We now conclude, however, that we need additional information in order to determine 
whether an additional form of STS that utilizes Internet-based transmissions is necessary to achieve 
functional equivalence for Americans with speech disabilities, and, if so, to establish the parameters for 
such form of STS .  To begin with, given the growth and development of interconnected VoIP services 
since 2006, it appears that STS users already can obtain the claimed advantages of IP STS, such as the 
ability to make calls on a mobile or Internet-enabled device, by simply using an interconnected VoIP 
service to access a state STS relay center.
102
  Additionally, as noted above, since adopting the 2008 STS 
                                                          
97
711 TRS Dialing Order at 15202, ¶ 28.  
98
Id. at 15196-97, ¶ 14 (noting that “711 access to TRS supports the goals of the Americans with Disabilities Act by 
increasing the integration of people with disabilities into society, and is in the public interest,” citing 42 U.S.C. § 
12101 et seq.).  Contra, GoAmerica Comments at 8 (recommending the adoption of a single nationwide toll-free 
number per STS provider).  The Commission previously rejected adopting a nationwide STS number that was 
different than 711 in 2003 because the 711 TRS Dialing Order already required that carriers implement 711 dialing 
in a way that gives users access to all mandated relay services. See 2003 TRS Order, 18 FCC Rcd at 12379, 12410-
11, ¶¶ 50-51.
99
2008 STS NPRM at 20669-70, ¶¶ 18-19. The Commission also tentatively concluded that entities desiring to 
provide IP STS may seek certification from the Commission under the certification rules that existed at the time.  Id.
at 10671, ¶ 23.
100
Id. at 20669, ¶ 18.  
101
Id. at 20669-70, ¶ 19.
102
Such access is required by our rules and orders.  See IP-Enabled Services; Implementation of Sections 255 and 
251(a)(2) of The Communications Act of 1934, as Enacted by The Telecommunications Act of 1996:  Access to 
Telecommunications Service, Telecommunications Equipment and Customer Premises Equipment by Persons with 
Disabilities; Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities; The Use of N11 Codes and Other Abbreviated Dialing Arrangements, WC Docket No. 04-36, 
(continued....)
Federal Communications Commission FCC 13-101   
14
R&O and NPRM , the Commission received the 2011 VA-STS Petition, requesting the Commission to 
open a proceeding on VA-STS, which employs IP video technologies to enhance relayed communication 
by people with speech disabilities.
103
  Petitioners claim that allowing the CA the ability to see and get 
cues from, “the user’s face and any available seen body parts or indicators,” such as facial expressions 
and the orientation and movement of the body, enables the CA to more effectively re-voice what a person 
with a speech disability says during a call.
104
  
27. We are committed to fulfilling our statutory mandate to encourage the technological 
advancement of TRS services.
105
  We also note that some of the actions taken in the recent VRS Structural 
Reform Order, including the creation of a neutral video communications service platform, user 
registration database and access technology reference platform, could help make VA-STS widely 
available in an efficient manner.
106
  Accordingly, in the coming months, we will open a proceeding to 
seek comment on whether an additional form of STS that utilizes Internet-based transmissions is 
necessary to achieve functional equivalence for Americans with speech disabilities, and, if so, how such 
service should be structured and provided under the Commission’s TRS program.
107
C. Other Matters Pertaining to STS 
28. Some commenters propose other initiatives to further enhance the use and quality of STS.  
For example, the TDI Coalition asserts that STS providers should be required to inform STS users of the 
TRS confidentiality rules so that prospective STS users would be reassured that their privacy is being 
preserved.
108
  While we agree on the need for STS users (who are otherwise not familiar with relay 
services) to understand their right to conversational privacy, we decline to adopt this proposal because we 
(Continued from previous page)                                                           
WT Docket No. 96-198, CG Docket No. 03-123, CC Docket No. 92-105, Report and Order, 22 FCC Rcd 11275, 
11296-97, ¶¶ 42-43 (2007).  
103
See ¶ 14, supra. 
104
2011 VA-STS Petition at 2.
105
See 47 U.S.C. §§ 225(b)(1), (d)(2).  It appears that VA-STS already is being offered in California, Louisiana, and 
Virginia.  Minnesota has also announced its intention to begin providing this service.
106
See Structure and Practices of the Video Relay Service Program; Speech-to-Speech and Internet Protocol (IP) 
Speech-to-Speech Telecommunications Relay Services, CG Docket Nos. 10-51 and 03-123, Report and Order and 
Further Notice of Proposed Rulemaking, 28 FCC Rcd 8618, 8656-60, ¶¶ 87-102 (2013) (VRS Structural Reform 
Order). See also 47 U.S.C. §§ 225(b)(1) (directing the Commission to “ensure that . . . telecommunications relay 
services are available, to the extent possible and in the most efficient manner . . . .”), 225(d)(1) (directing the 
Commission to “prescribe regulations to implement this section”).
107
Some parties propose that STS, as well as Internet-based STS, be provided through a single provider that is 
selected and overseen at the federal level, claiming that the small user base would make provision of this service by 
one provider more efficient, as well as more effective for consumers.  See, e.g., STS Petition at 2-3; AAPD 
Comments at 5; SCT Comments at 6; 2010 STS Petition at 2-3; National Exchange Carrier Association, Interstate 
Telecommunications Relay Services Fund Payment Formula and Fund Size Estimate, CG Docket Nos. 03-123 and 
10-51, Exhibit F (filed Apr. 29, 2011) (TRS Advisory Council urges the Commission to initiate a rulemaking 
proceeding to assess the feasibility of establishing one nationwide provider for all forms of STS).  But see Hamilton 
Comments at 4-5, Sprint Comments at 5, and GoAmerica Comments at 10-11, claiming that the provision of this 
service by one provider would eliminate the competition needed to improve service and foster innovation.   Because 
we believe that the Commission’s decisions regarding the structure of STS should take into consideration all forms 
of this service, including forms of STS that utilize Internet-based transmissions, we will defer consideration of this 
issue until we address the larger structural issues attendant with providing all forms of STS in the next rulemaking 
referenced above.
108
TDI Coalition Comments at 3 (stating that this confidentiality notification is important because of the concerns 
that many prospective STS users have about preserving the privacy and confidentiality of their communications).
Federal Communications Commission FCC 13-101   
15
are concerned that adding this requirement to the start of every STS call may be unduly burdensome for 
both the CA and other users, many of whom may already be familiar with this mandatory minimum 
standard.  Instead, we believe that informing potential users of their right to TRS confidentiality is best 
incorporated into any outreach efforts that are required by our current or future rules.  A second 
recommendation, made by AAPD, is to require STS users’ profiles to be immediately available to the 
STS CA each time an STS user places an STS call so that providers can provide a better and more 
“consistent STS relay experience” for users.
109
We believe that this proposal deserves consideration, but 
defer its resolution until after we seek and obtain further input on its merits in response to the Notice
accompanying this Order.  In addition, AAPD and the TDI Coalition recommend that when an STS user 
is silent and does not say “good-bye,” the CA should not terminate the call until at least 60 seconds has 
passed; in this way, the call would not be disconnected prematurely.
110
The Notice also seeks comment 
on this, as well as the suggestion of several commenters for the FCC to establish an STS Advisory 
Council for the purpose of formulating an STS outreach plan.
111
We therefore will consider these matters 
after receiving public feedback on their merits as well. 
IV. FURTHER NOTICE OF PROPOSED RULEMAKING
A. STS Outreach 
29. Although the Commission approved STS as a compensable relay service in 2000, 
according to the TRS Administrator’s annual rate filings, demand for this service has remained relatively 
modest, and its growth has been slow compared with other forms of TRS.
112
  The 2010 STS Petition
alleges that outreach efforts over the last decade have only resulted in the use of STS by an estimated one 
percent of prospective users.
113
  Several commenters to this proceeding also raise concerns about the 
under-utilization of STS.
114
   
                                                          
109
AAPD Comments at 4.
110
AAPD Comments at 4; TDI Coalition Comments at 4.  
111
See TDI Coalition Comments at 8; AT&T Reply Comments at 7-8; GoAmerica Comments at 9; Hamilton 
Comments at 3. 
112
Rolka Loube Saltzer Associates LLC, Interstate Telecommunications Relay Services Fund Payment Formula and 
Fund Size Estimate, CG Docket Nos. 03-123 and 10-51, at 12 (filed May 1, 2013) (2013 TRS Rate Filing); Rolka 
Loube Saltzer Associates LLC, Interstate Telecommunications Relay Services Fund Payment Formula and Fund 
Size Estimate, CG Docket Nos. 03-123 and 10-51, at 11 (filed Apr. 30, 2012) (2012 TRS Rate Filing); 2011 TRS 
Rate Filing at 11; National Exchange Carrier Association, Interstate Telecommunications Relay Services Fund 
Payment Formula and Fund Size Estimate, CG Docket Nos. 03-123 and 10-51, at 11 (filed Apr. 30, 2010) (2010 
TRS Rate Filing); National Exchange Carrier Association, Interstate Telecommunications Relay Services Fund 
Payment Formula and Fund Size Estimate, CG Docket Nos. 03-123 and 10-51, at 10 (filed May 1, 2009) (2009 TRS 
Rate Filing).
113
2010 STS Petition at 3.  See also ¶ 13, supra, suggesting that despite the distribution of $394,000 in outreach 
funding to six different STS providers from 2008-2010, STS call volume during that period decreased. 
114
See, e.g., SCT Reply Comments in response to the 2011 TRS Rate Filing (filed May 23, 2011) (stating that 
despite additional funding for outreach, the efforts have been ineffective and proposing a nationwide outreach 
program to be conducted by a third party entity).  Previously, in response to the 2008 Rate Order, 
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, CG Docket No. 03-123, Order, 23 FCC Rcd 9976 (2008) (2008 Rate Order), several parties expressed 
the need to improve STS outreach.  See Hamilton Comments at 2-3; TDI Coalition Comments at 8; GoAmerica 
Comments at 10 (suggesting additional outreach funds for IP STS if approved as a new form of compensable TRS).
Federal Communications Commission FCC 13-101   
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30. According to the National Institute on Deafness and Other Communication Disorders 
(NIDCD), there is a sizeable population of people in the United States who have speech disabilities.
115
  
This population includes individuals who have spasmodic dysphonia,
116
cleft palates,
117
cerebral palsy,
118
Parkinson’s disease,
119
Amyotrophic Lateral Sclerosis (ALS or Lou Gehrig’s),
120
aphasia,
121
Huntington’s 
disease,
122
and speech disabilities such as stuttering or stammering.
123
  As our nation continues to age, the 
incidence of older Americans likely to acquire conditions that cause speech disabilities is likely to rise.
124
  
Moreover, traumatic brain injury (TBI) is recognized as the signature wound of the wars in Iraq and 
                                                          
115
National Institutes on Health, “Statistics on Voice, Speech, and Language.” NIH National Institute on Deafness 
and Other Communication Disorders, June 7, 2010, https://www.nidcd.nih.gov/health/statistics/pages/vsl.aspx
(retrieved May 28, 2013).  See also, 2011 VA-STS Petition at 2-3 (providing various statistics on the number of 
people who can benefit from STS). 
116
Spasmodic dysphonia is a voice disorder that is caused by involuntary movements of the muscles of the larynx.  
National Institute on Deafness and Other Communication Disorders, “Statistics on Voice, Speech, and Language” 
(June 7, 2010), https://www.nidcd.nih.gov/health/statistics/pages/vsl.aspx (retrieved May 28, 2013).
117
Id. 
118
See National Institute of Neurological Disorders and Stroke, “Cerebral Palsy: Hope through Research” (Aug. 23,
2012), http://www.ninds.nih.gov/disorders/cerebral_palsy/detail_cerebral_palsy.htm#154443104 (retrieved May 28, 
2013). The United Cerebral Palsy (UCP) Foundation estimates that nearly 800,000 children and adults in the United 
States are living with one or more of the symptoms of cerebral palsy. According to the federal government’s 
Centers for Disease Control and Prevention, each year about 10,000 babies born in the United States will develop 
cerebral palsy. Id.
119
See National Institute of Neurological Disorders and Stroke, “Parkinson Disease Backgrounder” (Oct. 18, 2004),  
http://www.ninds.nih.gov/disorders/parkinsons_disease/parkinsons_disease_backgrounder.htm (retrieved May 28, 
2013). In the United States, at least 500,000 people are believed to have from Parkinson's disease, and about 50,000 
new cases are reported annually.  Id.
120
See ALS Association, “Who Gets ALS?” (Feb. 2011), http://www.alsa.org/about-als/who-gets-als.html (retrieved 
May 28, 2013).  It is estimated that as many as 30,000 Americans have ALS disease at any given time. Id.
121
See National Aphasia Association, “Aphasia Frequently Asked Questions,” 
http://www.aphasia.org/Aphasia%20Facts/aphasia_faq.html (retrieved May 28, 2013).  Aphasia affects about one 
million Americans, or 1 in 250 people, and is more common than Parkinson's disease, cerebral palsy or muscular 
dystrophy. More than 100,000 Americans acquire the disorder each year. Id.
122
See National Institute of Neurological Disorders and Stroke, “Huntington’s Disease: Hope through Research” 
(Apr. 24 2013), http://www.ninds.nih.gov/disorders/huntington/detail_huntington.htm#160493137 (retrieved May 
28, 2013).  More than 15,000 Americans have Huntington’s disease. At least 150,000 others have a 50 percent risk 
of developing the disease and thousands more of their relatives live with the possibility that they, too, might develop 
Huntington’s disease. Id.
123
Gordon, Neil, “Stuttering Incidence and Causes,” Wiley Online Library (Feb. 13, 2007),  
http://onlinelibrary.wiley.com/doi/10.1111/j.1469-8749.2002.tb00806.x/abstract  (retrieved May 28, 2013).   
Although about 80% of an estimated 1% of Americans who stutter will outgrow their disability, there remain 
thousands of Americans who stutter. Id.
124
As people age, their speech is often impacted by changes in language, memory, and swallowing, as well as by 
their increased chances of having a stroke or developing dementia or Parkinson's disease, and thus experiencing the 
concomitant communication disorders related to these diseases. See, e.g., http://www.asha.org/slp/clinical/aging/
(retrieved May 28, 2013).  For example according to the National Institute of Neurological Disorders and Stroke, the 
number of people with Parkinson’s disease is “expected to increase as the average age of the population increases.” 
National Institute of Neurological Disorders and Stroke, “Parkinson Disease Backgrounder” (Oct. 18, 2004),  
http://www.ninds.nih.gov/disorders/parkinsons_disease/parkinsons_disease_backgrounder.htm (retrieved May 28, 
2013).
Federal Communications Commission FCC 13-101   
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Afghanistan, and between 15 percent and 23 percent of the 2 million who have served in wars in Iraq and 
Afghanistan, or 300,000 to 460,000 returning veterans, have experienced a TBI.
125
One of the most 
critical consequences of TBI can be its severe impact upon an individual’s communication and speech
skills.
126
  
31. To ensure that individuals with speech disabilities who need STS become aware of its 
availability and how to access these services, the Commission has been supplementing the STS interstate 
per minute rate to include additional funds for STS outreach activities for the past six years.
127
However, 
this supplemental funding has not increased the number of interstate STS minutes of use by any 
significant amount over the past several years.  Moreover, since 2009, the TRS Fund administrator has 
suggested in each of its annual rate filings that the Commission may wish to revisit this additional funding 
to determine whether there is a more effective way to inform consumers with speech disabilities about the 
availability of this service.
128
32. The Commission would like to learn more about the reasons that STS has not been more 
widely utilized.  For example, are people with speech disabilities not connected to an organized or 
culturally identified disability community that could provide them with information and resources about 
assistive technologies and services that can be of use to them?  Are there other reasons why this service is 
not more widely utilized?  We seek comment on the number of individuals with speech disabilities who 
are potential users of this service and what steps can be taken to ensure that individuals who could benefit 
from STS can use this service.  We specifically ask whether it would be more efficient and effective to 
utilize a single entity to conduct nationwide STS outreach, instead of continuing the current system of 
                                                          
125
See e.g., Congressional Budget Office, “The Veterans Health Administration’s Treatment of PTSD and 
Traumatic Brain Injury Among Recent Combat Veterans” Feb. 2012, 
http://www.cbo.gov/sites/default/files/cbofiles/attachments/02-09-PTSD.pdf (retrieved May 28, 2013); Davis, Marc, 
“Soldiers’ brain trauma cases disputed,” The Atlanta Journal Constitution, Apr. 22, 2012, 
http://www.ajc.com/news/news/local/soldiers-brain-trauma-cases-disputed/nQTD6/ (retrieved May 2, 2013).  
126
See, e.g., Wallace, Gloriajean, “Blast Injury Basics: A Primer for the Medical Speech-Language Pathologist,” 
Brainline.org, http://www.brainline.org/content/2008/08/blast-injury-basics-primer-medical-speech-language-
pathologist_pageall.html (retrieved May 28, 2013); Zoroya, Gregg, “Troops With Traumatic Brain Injury Face Long 
Road to Recovery,” ABC News/USA Today, July 31, 2010), http://abcnews.go.com/Politics/iraq-afghanistan-
troops-traumatic-brain-injury-face-long/story?id=11287674 (retrieved  May 28, 2013).
127
  At present, the STS rate is $2.9921, which includes $1.131 as compensation for outreach activities.  See
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities; Structure and Practices of the Video Relay Service Program, CG Docket Nos. 03-123 and 10-51,
Order, , DA 13-1483 ¶ 7 n.10 (rel. July 1, 2013) (2013 TRS Rate Order); Telecommunications Relay Services and 
Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities; Structure and Practices of the 
Video Relay Service Program, CG Docket Nos. 03-123 and 10-51, Order, 27 FCC Rcd at 7151, ¶ 2  n.6 (2012 TRS 
Rate Order); Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities; Structure and Practices of the Video Relay Service Program, CG Docket Nos. 03-123 and 10-
51, Order, 26 FCC Rcd 9972, 9979, ¶17 (2011) (2011 TRS Rate Order); Telecommunications Relay Services and 
Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123, Order, 25 
FCC Rcd 8689, 8699, ¶¶ 22-23 (2010) (2010 TRS Rate Order); Telecommunications Relay Services and Speech-to-
Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123, Order, 24 FCC Rcd
8628, 8631, 8634, ¶¶ 8, 15 (2009) (2009 TRS Rate Order); Telecommunications Relay Services and Speech-to-
Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123, Order, 23 FCC Rcd
9976, 9978-79, 9981, ¶¶ 6, 13 (2008) (2008 TRS Rate Order); Telecommunications Relay Services and Speech-to-
Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123, Report and Order 
and Declaratory Ruling, 22 FCC Rcd 20140, 20171, ¶ 61 (2007 TRS Cost Recovery Order) (first authorizing this 
supplemental amount).
128
See n.129, supra.
Federal Communications Commission FCC 13-101   
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providing outreach funds to each of the individual interstate STS providers through the STS 
compensation formula.  The 2010 STS Petition recommends contracting with a single entity for the 
delivery of an effective, nationwide STS outreach program in lieu of the current outreach subsidy.
129
   It 
notes that this campaign could educate potential users about the service’s availability because the low 
volume of STS minutes has resulted in “extremely little outreach in most states” and “almost no 
communication between states about effective techniques of providing . . . STS outreach.”
130
  
33. We tentatively agree that centralizing STS outreach efforts supported by the Fund in a 
single, coordinated entity can result in more effectively reaching and educating a greater portion of the 
population of Americans who could benefit from this service, and seek comment on this tentative 
conclusion. The Commission previously has noted the importance of outreach to ensure that the general 
public and people with disabilities acquire sufficient familiarity with TRS to meet Congress’s goal of 
making available, to the extent possible and in the most efficient manner, a nationwide relay service that 
is functionally equivalent to conventional voice telephone services.
131
  Moreover, the Commission 
recently concluded, with respect to VRS and IP Relay, that a national outreach effort that does not rely on 
the efforts of individual providers is necessary and appropriate to achieve these section 225 objectives.
132
  
The Commission explained that outreach conducted by individual VRS and IP Relay providers has not 
been effective in educating the general public about the purpose and functions of these services.  
Additionally, the Commission noted that it has been difficult to determine the extent to which outreach 
expenditures by these TRS providers have overlapped with each other, and therefore the extent to which 
funds devoted to this purpose have been reasonable or excessive.  To remedy this, the Commission set up 
a two-year pilot program, the iTRS National Outreach Program (iTRS-NOP), to provide VRS and IP 
Relay outreach on a national basis through an independent third party outreach coordinator.
133
34. We believe that the section 225 directive for the Commission to prescribe regulations that 
ensure relay services are “available . . . in the most efficient manner”
134
makes it appropriate to take new 
steps to better educate the public about the purpose and functions of STS and provides us with sufficient 
                                                          
129
2010 STS Petition at 2.  
130
Id. at 3.  
131
See, e.g., Telecommunications Services for Individuals with Hearing and Speech Disabilities and the Americans 
with Disabilities Act, CC Docket No. 90-571, Report and Order and Request for Comments, 6 FCC Rcd 4657, 4663, 
¶ 28 (1991) (TRS I) (adopting the outreach requirement); 711 TRS Dialing Order, 15 FCC Rcd at 15189, ¶ 1; VRS 
Structural Reform Order, 28 FCC Rcd at 8632, ¶ 27.
132
See id. at 8634, ¶ 31. This is similar to the Commission’s action to set aside $500,000 for national outreach 
during each TRS Fund year of the National Deaf Blind Equipment Distribution (pilot) Program (NDBEDP) – a 
program established to distribute communications equipment to people who are deaf-blind under the Twenty-First 
Century Communications and Video Accessibility Act . Implementation of the Twenty-First Century 
Communications and Video Accessibility Act of 2010, Section 105, Relay Services for Deaf-Blind Individuals, 26 
FCC Rcd 5640, 5675-76,  ¶ 80 (2011) (NDBEDP Pilot Program Order).  In 2012, the Commission selected a single 
entity to coordinate this outreach effort.  Perkins School for the Blind to Conduct National Outreach for the National 
Deaf-Blind Equipment Distribution Program, CG Docket No. 10-210, Public Notice, 27 FCC Rcd 6143 (2012).
133
VRS Structural Reform Order, 28 FCC Rcd at 8637, ¶ 34.  In that Order, we directed “the Managing Director, in 
consultation with the Chief of CGB, to (i) select one or more iTRS Outreach Coordinators to conduct and coordinate 
IP Relay and VRS outreach nationwide and be compensated through the Fund or (ii) contract with the TRS Fund 
administrator to enter into such arrangements under objectives and factors determined by the Managing Director in 
consultation with the Chief of CGB.”  Id.
134
See 47 U.S.C. §§ 225(b)(1) (directing the Commission to “ensure that . . . telecommunications relay services are 
available, to the extent possible and in the most efficient manner . . . .”), 225(d)(1) (directing the Commission to 
“prescribe regulations to implement this section”).  
Federal Communications Commission FCC 13-101   
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authority to direct that a national STS outreach effort be funded for this purpose from TRS contributions 
as a necessary cost caused by TRS.
135
  We ask commenters whether they agree with this assessment.  We 
further ask commenters whether, given that the Commission has resolved to establish the iTRS-NOP for 
IP Relay and VRS, we should bundle national STS outreach efforts into this national outreach program.  
What are the costs and benefits of combining these efforts?  For example, are there efficiencies to be 
gained in contracting with a single entity or a group of single entities for all types of TRS outreach?  Or 
are there characteristics of STS or the population served by this service that necessitate a separate 
outreach effort?  If the latter, we ask commenters to describe these characteristics, as well as any criteria 
needed for the selection of a national STS outreach coordinator that should be different from the criteria 
used to select a national coordinator of VRS and IP Relay outreach.  Additionally, if the Commission or 
the Interstate TRS Fund administrator contracts with a single entity for the handling of STS calls, and we 
decide on a national outreach effort that is separate from the iTRS-NOP, we seek comment on whether
the entity selected to provide STS also should be eligible to become the national STS outreach 
coordinator, or whether the outreach coordinator should be independent of any provider of STS.  
35. We also seek comment on the criteria that should be used to select a nationwide outreach 
program coordinator, as well as the outreach activities for which such coordinator should be responsible.  
With respect to the latter, we seek feedback on whether the coordinator should be required to engage in 
the following activities, as well as any other activities not identified below:
? Consulting with consumer groups, STS  providers, the TRS Fund administrator, and other STS  
stakeholders;
? Establishing clear and concise messaging about the purposes, functions, and benefits of STS;
? Contacting and providing direct outreach and education to relevant medical, disability and 
senior citizen organizations, associations and medical professionals whose constituencies, members, and 
patients are likely to benefit from STS;
136
? Determining media outlets and other appropriate avenues for providing information about STS to
identified medical, disability and senior citizen organizations, associations, and professionals, the general 
public and potential new-to-category subscribers;
? Preparing for and arranging for publication, press releases, announcements, digital postcards, 
newsletters, and media spots about STS that are directed to identified medical, disability and senior citizen 
organizations, associations, and professionals, as well as retailers and other businesses, including trade 
associations;
? Creating electronic and media tool kits that include samples of the materials listed in the 
previous bullet, and which may also include templates, all of which will be for the purpose of facilitating the 
preparation and distribution of such materials by consumer and industry associations, governmental 
entities, and other STS  stakeholders;
? Providing materials to local, state, and national governmental agencies on the purposes, 
functions, and benefits of STS; and,
? Exploring opportunities to partner and collaborate with other entities to disseminate information 
about STS. 
                                                          
135
2010 STS Petition at 2; VRS Structural Reform Order, 28 FCC Rcd at 8636, ¶ 32, n.93.
136
  Organizations that represent individuals with the types of medical conditions and disabilities listed in paragraph 
31 above may have a particular interest in sharing information about STS with their constituencies and members.  
These would include, for example, organizations that represent or address the interests of individuals with cerebral 
palsy, Parkinson’s disease, strokes, etc. 
Federal Communications Commission FCC 13-101   
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36. We propose that an entity selected by the Commission or the Interstate TRS Fund 
administrator to coordinate such outreach be required to work with and submit periodic reports to the 
Chief of the Consumer and Governmental Affairs Bureau and to the Managing Director, which report 
measure and describe the effectiveness of the entity’s outreach efforts, and seek comment on these 
proposals.  We also seek comment on whether there should be specified levels of outreach activities that 
the STS national outreach coordinator should be required to meet, and how and by whom these levels 
should be set and evaluated.  If a national outreach program is established, we propose that the additional 
amount currently added to the STS per minute rate for outreach be discontinued from future rates, and 
seek comment on this proposal. If we choose not to continue reimbursing the cost of outreach activities 
on a per minute basis to providers, we seek feedback on whether a specified amount should be set aside 
from the Fund on an annual basis for nationwide outreach activities, what this amount should be, and how 
it should be determined. Finally, should the cost of providing STS as well as STS outreach be allocated 
between the Interstate TRS Fund and the state program funds, and, if so, how?
B. Consumer Eligibility, Registration and Verification
37. In recent years, the Commission has undertaken significant efforts to ensure that its 
Internet-based TRS programs are structurally sound and are free from waste, fraud and abuse.
137
  For 
example, the Commission has established registration requirements for IP Relay and VRS users,
138
adopted interim rules requiring that users of IP captioned telephone relay services document their 
eligibility to use that service,
139
and adopted sweeping reforms of the VRS program.
140
  Of particular 
concern to the Commission is making sure that only those individuals who are truly eligible for different 
forms of TRS are allowed to use these services.  Accordingly, we seek comment on how to establish rules 
to clearly define and oversee the eligibility, registration, and verification of STS users.  As an initial 
matter, we note that in the VRS Structural Reform Order, the Commission recently directed the creation 
of a user registration database for VRS users.
141
  Should STS providers be required to use this database to 
register all individuals seeking to use STS, whether STS is provided by a single provider or if it remains 
with the states?  As part of the registration process, should users be permitted to provide self-certification 
that they have a speech disability?  For example, is this readily identifiable to the CA when a call is 
made?  Or should users be required to obtain a signed certification from a qualified independent third 
party that the user has a speech disability that necessitates the use of STS in order to be able to effectively 
communicate when using the telephone?  Should any such user certification be required once, before the 
user begins using the service, or should it have to be renewed at specified intervals, and if the latter, what 
should these intervals be?  Generally, we seek comment on the costs and benefits associated with a 
certification requirement, as well as whether such requirements will effectively fulfill Congress’s 
directive to the Commission, in section 225 of the Communications Act, to ensure that TRS is available, 
“to the extent possible and in the most efficient manner,” to persons with hearing and speech 
disabilities.
142
  Finally, we propose that any certification ultimately required by our rules be made under 
penalty of perjury as an added layer of assurance that the individual’s disability satisfies our eligibility 
                                                          
137
See VRS Structure and Practices Order, 26 FCC Rcd 5545; iTRS Certification Order, 26 FCC Rcd 10898.  
138
See Second TRS Numbering Order, 24 FCC Rcd at 808-811, ¶¶ 36-38.
139
See Misuse of Internet Protocol (IP) Captioned Telephone Service; Telecommunications Relay Services and 
Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket Nos. 13-24 and 03-
123, Order and Notice of Proposed Rulemaking, 28 FCC Rcd 703,716-720, ¶¶ 19-26 (2013).
140
See e.g. VRS Structure and Practices Order; VRS Structural Reform Order.
141
VRS Structural Reform Order, 28 FCC Rcd at 8656, ¶¶ 62-86.
142
47 U.S.C. § 225(b)(1).
Federal Communications Commission FCC 13-101   
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requirements and seek comment on this proposal.
143
  We seek comment on the issue of certification of 
eligibility generally.  Commenters who do not believe these certification proposals are appropriate should 
offer alternative requirements that can be used to ensure that only eligible individuals who are intended to 
benefit from this service (i.e., who need STS to communicate in a manner that is functionally equivalent 
to communication by voice telephone users) are permitted to use it.  We also ask commenters to weigh 
the potential benefits and potential costs of these proposals.
38. We further ask whether we should adopt a centralized process by which the identities of 
STS users are verified, as we have done in the VRS Structural Reform Order.
144
In that Order, we directed 
the Managing Director to ensure that a centralized user registration database has the capability of 
performing an identification verification check when a VRS provider or other party submits a query to the 
database about an existing or potential user.
145
  We further directed that the criteria for identification 
verification (e.g., information to be submitted, acceptable level of risk, etc.) shall be established by the 
Managing Director in consultation with the Commission’s Chief Technology Officer and the Chief of the 
Office of Engineering and Technology. Finally, we required that VRS providers not be permitted to 
register individuals that do not pass the identification verification check conducted through the user 
registration database, and not seek compensation for calls placed by such individuals.  We ask whether 
the same requirements should now apply to STS providers. 
C. Mandatory Minimum Standards for STS
39. In the 2008 STS NPRM, the Commission tentatively concluded that IP STS providers 
would not need to meet the following TRS mandatory minimum standards to be eligible for 
compensation:
146
  (1) CA competency in typing and spelling;
147
(2) ensuring that TTY calls over TRS can 
be transmitted in ASCII and Baudot formats;
148
(3) call release;
149
(4) hearing carry over (HCO) and voice 
carry over (VCO) services;
150
(5) equal access to interexchange carriers;
151
  (6) pay-per-call (900) 
                                                          
143
See, e.g., Lifeline & Link Up Reform and Modernization, WC Docket No. 11-42, Report and Order and Further 
Notice of Proposed Rulemaking, 27 FCC Rcd 6656, 6709-11, ¶¶ 111-14, 6712, ¶ 120 (2012) (amending 47 C.F.R. § 
54.410 to require, among other measures to reduce fraud, abuse, and waste in the Lifeline program, that eligible 
telecommunications carriers obtain initial and annual self-certifications by consumers, under penalty of perjury, 
establishing their eligibility for Lifeline support).  See also 47 C.F.R. § 54.416(a) (requiring eligible 
telecommunications carriers themselves to certify annually, under penalty of perjury, that they have policies and 
procedures in place to ensure that Lifeline subscribers are eligible and that they are in compliance with all federal 
Lifeline certification  procedures).  
144
VRS Structural Reform Order, 28 FCC Rcd at 8656, ¶ 86.
145
Id. (noting that the National Lifeline Accountability Database has the same functionality, and citing Lifeline and 
Link Up Reform and Modernization Order, 27 FCC Rcd at 6743, ¶ 201).
146
2008 STS NPRM, 23 FCC Rcd at 10602, ¶ 24.  
147
This includes the requirement that CAs meet a typing speed of a minimum of 60 words per minute.  47 C.F.R. §
64.604(a)(ii), (iii).
148
Providers of traditional TRS (i.e., text-based TRS calls made using a TTY) must ensure that the TTY can 
communicate in either the ASCII or Baudot formats.  47 C.F.R. §§ 64.601(a)(5), (7), 64.604(b)(1).
149
Call release is a TRS feature that allows the CA to drop from the call after the CA has set up a telephone call 
between two TTY users.  47 C.F.R. § 64.601(a)(8).    
150
HCO permits a person with a speech disability, but who is able to hear, to type text to the other party to the call 
(which is voiced by the CA), and listen in return to what the called party is saying.  47 C.F.R. § 64.601(a)(13).  VCO 
permits a person with a hearing disability, but who is able to speak, to speak directly to the other party to the call 
(instead of typing text), and receive in return the called party’s spoken words as text.  47 C.F.R. § 64.601(a)(42).    
Federal Communications Commission FCC 13-101   
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service;
152
and (7) outbound 711 dialing.
153
  GoAmerica and Hamilton agree with this tentative 
conclusion, and note that certain mandatory minimum standards are either not applicable to IP STS given 
the nature of the service, or should be waived due to present technological infeasibility.
154
      
40. Although we are no longer seeking comment on the provision of IP STS as originally 
conceived in the IP STS Request, we now propose to amend the Commission’s rules to state that the 
following mandatory minimum standards not be applied to any form of STS because they are inapplicable 
to this service, and seek comment on this proposal:  
? CA competency in typing and spelling.  These skills pertain to typing, and a CA is not required to 
type messages during an STS call.
? Ensuring that TTY calls over TRS can be transmitted in ASCII and Baudot formats.  TTYs are 
not used in STS calls.
155
  
? Call release.  This feature is designed to ensure the continuation of a phone call between two 
TTY users, and STS users do not make calls using TTYs.
156
? Voice Carry Over (VCO).  VCO is designed to enable a person with a hearing disability, but who 
is able to speak, to speak directly to the other party to the call, and receive in return the called 
party’s spoken words as text.  An STS user can hear directly the responses of the other party to 
the call.
D. Other Matters
41. During the course of this proceeding, various commenters raised suggestions for 
improving STS that went beyond the scope of the 2008 STS NPRM.  For example, AAPD recommended
that STS user profiles be immediately available to an STS CA each time an STS user places a call, to 
allow the provider to provide a better and more “consistent STS relay experience” for users.
157
  In 
addition, AAPD and the TDI Coalition recommended that when an STS user is silent and does not say 
“good-bye,” the CA should not terminate the call until at least 60 seconds has passed; in this way, the call 
would not be disconnected prematurely.
158
  Another recommendation, made by several commenters, was 
for the FCC to establish an STS Advisory Council for the purpose of formulating an STS outreach plan.  
We seek comment on these recommendations, and any other matters that the Commission should address 
(Continued from previous page)                                                           
151
Equal access to interexchange carriers requires providers to relay long distance calls through the consumer’s 
choice of interexchange carrier.  47 C.F.R. § 64.604(b)(3).  
152
Pay-per-call (900) services are services for calls that include a charge billed to the calling party.  47 C.F.R. § 
64.604(a)(3)(iv).  
153
Outbound 711 dialing permits TRS users to dial 711 to reach a relay provider. 711 Dialing Order, 15 FCC Rcd at 
15190-91, ¶ 3; 47 C.F.R. § 64.603.
154
IP STS Request at 6-7; Hamilton Comments at 4; GoAmerica Comments at 5.
155
Note that although the requirement that “TRS shall transmit conversations between TTY and voice callers in real 
time” is not, by its terms, applicable to STS, STS providers must relay calls between the parties in real time.  See 47 
C.F.R. § 64.604(a)(vii).
156
Call release also is presently waived for IP Relay.  See Telecommunications Relay Services and Speech-to-
Speech Services for Individuals with Hearing and Speech Disabilities; E911 Requirements for IP-Enabled Service 
Providers, CG Docket No. 03-123, WC Docket No. 05-196, Order, 27 FCC Rcd 7113, 7120, ¶¶ 12-13 (2012) (2012
TRS Waiver Order).  
157
AAPD Comments at 4.
158
Id. at 4; TDI Coalition Comments at 4.  
Federal Communications Commission FCC 13-101   
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to achieve the full utilization of STS.  For example, should we establish a mandatory minimum standard 
for training of CAs who handle STS calls or any other mandatory minimum standards that are specific to 
STS?
159
  Finally, we seek information about any technological advances in end user equipment since the 
submissions of the petitions in this proceeding that may bear on the provision of this service. 
42. To what extent should providers be required to allow STS users to create caller profiles?  
Such profiles generally allow users to pre-submit their preferences for call handling, including their 
contact information (for emergencies), language preferences, and speed dial numbers,
160
which may speed 
up the time needed for STS call set-up.  If providers should be required to offer caller profiles, what 
should users be allowed to include in these profiles?  What are the costs and benefits of mandating the 
availability of profiles?
43. Finally, are there other enhancements to STS that the Commission should know about?  
For example, one provider recently implemented a national wireless short code to make it easier to place 
or receive STS calls.
161
  We seek comment on the benefits of using such a code nationwide.  We generally 
invite comment on other improvements that can be made to STS consistent with the functional 
equivalency mandate and section 225 more generally.
V. PROCEDURAL MATTERS
A. Comment Filing Procedures
44. Pursuant to sections 1.415 and 1.419 of the Commission’s rules,
162
interested parties may 
file comments and reply comments regarding the Notice on or before the dates indicated on the first page 
of this document.  Comments may be filed using the Commission’s Electronic Comment Filing System 
(ECFS).
163
   
? Electronic Filers:  Comments may be filed electronically using the Internet by accessing the 
Commission’s Electronic Comment Filing System (ECFS):  http://fjallfoss.fcc.gov/ecfs2/.
? Paper Filers:  Parties who choose to file by paper must file an original and one copy of each 
filing.  If more than one docket or rulemaking number appears in the caption of this 
proceeding, filers must submit two additional copies for each additional docket or rulemaking 
number. 
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail.  All filings must be addressed to the Commission’s 
Secretary, Office of the Secretary, Federal Communications Commission.
? All hand-delivered or messenger-delivered paper filings for the Commission’s Secretary 
must be delivered to FCC Headquarters at 445 12
th
St., SW, Room TW-A325, 
Washington, DC 20554.  The filing hours are 8:00 a.m. to 7:00 p.m.  All hand deliveries 
must be held together with rubber bands or fasteners.  Any envelopes must be disposed of 
before entering the building.  
? Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority 
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD  20743.  
                                                          
159
We note that for all types of TRS, our rules specify certain minimum standards for the CAs who handle these 
calls. See 47 C.F.R. § 64.604(a) (listing operational standards governing CAs in handling relay calls). 
160
See e.g., http://sprintsts.com/myprofile.html
161
See http://www.engadget.com/2012/05/18/sprint-my-wireless-sts-speech-to-speech-service/.
162
47 C.F.R. §§ 1.415 and 1.419.
163
See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998).
Federal Communications Commission FCC 13-101   
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? U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12
th
Street, SW, Washington DC  20554.
45. Documents in CG Docket Nos. 08-15 and 03-123 will be available for public inspection 
and copying during business hours at the FCC Reference Information Center, Portals II, 445 12
th
Street 
SW, Room CY-A257, Washington, D.C. 20554.  The documents may also be purchased from BCPI, 
telephone (202) 488-5300, facsimile (202) 488-5563, TTY (202) 488-5562, e-mail fcc@bcpiweb.com.
B. Ex Parte Presentations  
46. This proceeding shall be treated as a “permit-but-disclose” proceeding in accordance with 
the Commission's ex parte rules.
164
  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 presentations 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 rule 1.1206(b).
165
  In 
proceedings governed by rule 1.49(f)
166
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.
C. Regulatory Flexibility Act 
47. As required by the Regulatory Flexibility Act of 1980, as amended (RFA),
167
the 
Commission has prepared a Final Regulatory Flexibility Certification in which it concludes that, under 
the terms of RFA, there is no significant economic impact on small entities of the policies and rules 
addressed in this document.  The Certification is set forth in Appendix C.  
48. As required by the RFA, the Commission has prepared an Initial Regulatory Flexibility 
Analysis (IRFA) of the possible significant economic impact on small entities of the policies and rules 
addressed in this item.  The IRFA is set forth in Appendix. D.  Written public comments are requested on 
this IRFA.  Comments must be identified as responses to the IRFA and must be filed by the deadlines for 
comments on the Notice provided on or before the dates indicated on the first page of this Order and 
Notice.  The Commission will send a copy of the Notice, including this IRFA, to the Chief Counsel for 
                                                          
164
47 C.F.R. §§ 1.1200–1.1216.
165
Id. § 1.1206(b).
166
Id. § 1.49(f).
167
5 U.S.C. §§ 601 et. seq.  The RFA has been amended by the Contract With America Advancement Act of 1996. 
Pub. L. No. 104-121, 110 Stat. 847 (1996) (CWAAA).  Title II of the CWAAA is the Small Business Regulatory 
Enforcement Fairness Act of 1996 (SBREFA).
Federal Communications Commission FCC 13-101   
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Advocacy of the Small Business Administration.
168
  In addition, the Order and Notice and IRFA (or 
summaries thereof) will be published in the Federal Register.
169
D. Paperwork Reduction Act Analysis
49. Paperwork Reduction Act of 1995 Analysis.  The Order does not contain any new or 
modified information collection requirements subject to the Paperwork Reduction Act of 1995 (PRA).
170
  
In addition, therefore, it does not contain any new or modified information collection burden for small 
business concerns with fewer than 25 employees, pursuant to the Small Business Paperwork Relief Act of 
2002.
171
50. The Notice seeks comment on proposed new information collection requirements.  If the 
Commission adopts any new information collection requirement, the Commission will publish another 
notice in the Federal Register inviting the public to comment on the requirements, as required by the 
PRA.
172
In addition, pursuant to the Small Business Paperwork Relief Act of 2002,
173
the Commission 
will seek specific comment on how it might further reduce the information collection burden for small 
business concerns with fewer than 25 employees.
E. Congressional Review Act
51. The Commission will send a copy of this Order in a report to be sent to Congress and the 
Government Accountability Office pursuant to the Congressional Review Act.
174
F. Materials in Accessible Formats
52. To request materials in accessible formats (such as Braille, large print, electronic files, or 
audio format), send an e-mail to fcc504@fcc.gov or call the Consumer and Governmental Affairs Bureau 
at (202) 418-0530 (voice) or (202) 418-0432 (TTY).  This Report and Order and Further Notice of 
Proposed Rulemaking can also be downloaded in Word and Portable Document Formats (PDF) at 
http://www.fcc.gov/cgb/dro/trs.html.
VI. ORDERING CLAUSES
53. Accordingly, IT IS ORDERED that, pursuant to sections 1, 4(i), (j), and (o), 225, and 403 
of the Communications Act of 1934, as amended, 47 U.S.C. §§ 151, 154(i), (j), and (o), 225, and 403, this 
Report and Order and Further Notice of Proposed Rulemaking IS HEREBY ADOPTED.
54. IT IS FURTHER ORDERED that the 2006 STS Petition IS GRANTED to the extent 
indicated herein.
55. IT IS FURTHER ORDERED that section 64.604 of the Commission’s Rules, 47 C.F.R. § 
64.604, IS AMENDED as specified in Appendix A, effective 60 days after publication of the Report and 
Order in the Federal Register.
56. IT IS FURTHER ORDERED that the Commission’s Consumer and Governmental 
Affairs Bureau, Reference Information Center, SHALL SEND a copy of this Report and Order and 
                                                          
168
See id. § 603(a).
169
Id.
170
Public Law 104-13.
171
Public Law 107-198.  See 44 U.S.C. § 3506(c)(4).
172
Public Law 104-13.  See 44 U.S.C. §§ 3501-3520.
173
Public Law 107-198.  See 44 U.S.C. § 3506(c)(4).
174
5 U.S.C. § 801(a)(1)(A).
Federal Communications Commission FCC 13-101   
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Further Notice of Proposed Rulemaking, including the Final Regulatory Flexibility Certification and 
Initial Regulatory Flexibility Analysis, to the Chief Counsel for Advocacy of the Small Business 
Administration.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch                                                                                                                              
Secretary
Federal Communications Commission FCC 13-101   
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APPENDIX A
Final Rule Changes
The Commission amends 47 C.F.R. Part 64 as follows:
PART 64 – MISCELLANEOUS RULES RELATING TO COMMON CARRIERS
1.  The authority citation for part 64 continues to read as follows:
Authority:  47 U.S.C. 154, 254(k); 403 (b)(2)(B), (c), Public Law 104-104, 110 Stat. 56.  Interpret or 
apply 47 U.S.C. 201, 218, 222, 225, 226, 228, 254(k), 616, 620, and the Middle Class Tax Relief and Job 
Creation Act of 2012, Pub. L. 112-96, unless otherwise noted.
2.  Amend section 64.604 by revising paragraph (a)(1)(v) and by adding paragraphs (a)(1)(viii) and (b)(7) 
to read as follows:
§ 64.604 Mandatory minimum standards. 
(a)  Operational standards
(1) * * *
* * * * *
(v)  CAs answering and placing a TTY-based TRS or VRS call shall stay with the call for a minimum of 
ten minutes.  CAs answering and placing an STS call shall stay with the call for a minimum of twenty 
minutes.  The minimum time period shall begin to run when the CA reaches the called party.  The 
obligation of the CA to stay with the call shall terminate upon the earlier of (1) the termination of the call 
by one of the parties to the call or (2) the completion of the minimum time period.
* * * * *
(viii)  STS providers shall offer STS users the option to have their voices muted so that the other party to 
the call will hear only the CA and will not hear the STS user’s voice.
* * * * *
(b) * * *
(7)  STS 711 Calls.  An STS provider shall, at a minimum, employ the same means of enabling an STS 
user to connect to a CA when dialing 711 that the provider uses for all other forms of TRS.  When a CA 
directly answers an incoming 711 call, the CA shall transfer the STS user to an STS CA without requiring 
the STS user to take any additional steps.  When an interactive voice response (IVR) system answers an 
incoming 711 call, the IVR system shall allow for an STS user to connect directly to an STS CA using the 
same level of prompts as the IVR system uses for all other forms of TRS.
* * * * *
Federal Communications Commission FCC 13-101   
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APPENDIX B
List of Commenters
COMMENTERS COMMENT DATE
PN on Hawk IP STS Request
American Network, Inc. May 22, 2008
Speech Communications Assistance by 
Telephone, Inc. (SCT)
May 8, 2008
2008 STS Petition
American Association of People with 
Disabilities (AAPD)
September 12, 2008
Hamilton Relay, Inc. September 12, 2008
GoAmerica, Inc. September 12, 2008
Hawk Relay, LLC September 12, 2008
Indianapolis Resource Center for Independent 
Living (IRCIL)
September 12, 2008
Services for Independent Living (SILC) September 12, 2008
Sprint Nextel Corporation September 12, 2008
Walton Options for Independent Living 
(WOIL)
September 12, 2008
TDI Coalition consisting of:
Telecommunications for the Deaf and Hard of 
Hearing, Inc.
September 12, 2008
Speech Communications Assistance by 
Telephone, Inc.
September 12, 2008
Association of Late-Deafened Adults, Inc. September 12, 2008
National Association of the Deaf September 12, 2008
Deaf and Hard of Hearing Consumer Advocacy 
Network
September 12, 2008
California Coalition of Agencies Serving the 
Deaf and Hard of Hearing
September 12, 2008
Hearing Loss Association of America September 12, 2008
Center for People with Disabilities (CPWD) September 11, 2008
Winston Ching July 28, 2008
REPLY COMMENTS REPLY COMMENT DATE
AT&T
Hawk Relay
September 29, 2008
September 29, 2008
Law Offices of Jane Cohen, LLC September 29, 2008
TDI Coalition September 29, 2008
Winston Ching September 29, 2008
Federal Communications Commission FCC 13-101   
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APPENDIX C
Final Regulatory Flexibility Certification
1. The Regulatory Flexibility Act of 1980, as amended (RFA)
1
requires that a regulatory 
flexibility analysis be prepared for rulemaking proceedings, unless the agency certifies that “the rule will 
not have a significant economic impact on a substantial number of small entities.”
2
  The RFA generally 
defines “small entity” as having the same meaning as the terms “small business,” “small organization,” 
and “small governmental jurisdiction.”
3
  In addition, the term “small business” has the same meaning as 
the term “small business concern” under the Small Business Act.
4
A small business concern is one 
which:  (1) is independently owned and operated; (2) is not dominant in its field of operation; and (3) 
satisfies any additional criteria established by the Small Business Administration (SBA).
5
2. Speech-to-speech (STS) relay service is a form of telecommunications relay service 
(TRS) that utilizes specially trained communications assistants (CAs) who understand the speech patterns 
of persons with speech disabilities and can repeat the words spoken by such individuals to the other 
parties to a relayed call.
6
  In the Report and Order, the Commission concludes that requiring an STS CA 
to stay with the call for a minimum of 20 minutes is best served to ensure the effective and efficient 
relaying of STS calls.  The Commission also finds that requiring that STS providers offer the STS user 
the option of having her or his voice muted so that the other party to the call would hear only the STS CA 
re-voicing the call, and not the voice of the STS user as well, will give potential STS users the confidence 
necessary to use STS.  In this Report and Order, the Commission further requires that STS providers 
must, at a minimum, employ the same means of enabling their STS users to connect to a CA when dialing 
711 that they use for all other forms of TRS.  For example, when a CA directly answers an incoming 711 
call, the CA must transfer the STS user to an STS CA without requiring the STS user to take any 
additional steps.  When an interactive voice response (IVR) system answers an incoming 711 call, the 
IVR system must allow for an STS user to connect directly to an STS CA using the same level of prompts 
as the IVR system uses for all other forms of PSTN-based TRS. 
3. The Commission concludes that these new requirements are necessary to improve the
effectiveness and quality of STS so that individuals with speech disabilities may receive functionally 
equivalent telephone service, as mandated by Title IV of the Americans with Disabilities Act.  We believe 
that none of these requirements would impose a significant burden on providers, including small 
                                                          
1
5 U.S.C. §§ 601 et. seq. The RFA has been amended by the Contract With America Advancement Act of 1996, 
Pub. L. No. 104-121, 110 Stat. 847 (1996) (CWAAA).  Title II of the CWAAA is the Small Business Regulatory 
Enforcement Fairness Act of 1996 (SBREFA).
2
5 U.S.C. § 605(b).
3
5 U.S.C. § 601(6).
4
5 U.S.C. § 601(3) (incorporating by reference the definition of “small business concern” in Small Business Act, 
15 U.S.C. § 632).  Pursuant to 5 U.S.C. § 601(3), the statutory definition of a small business applies “unless an 
agency, after consultation with the Office of Advocacy of the Small Business Administration and after opportunity 
for public comment, establishes one or more definitions of such term which are appropriate to the activities of the 
agency and publishes such definition(s) in the Federal Register.”
5
Small Business Act, § 15 U.S.C. § 632. 
6
47 C.F.R. § 64.601(a)(30); Telecommunications Relay Services and Speech-to-Speech Services for Individuals with 
Hearing and Speech Disabilities, CC Docket No. 98-67, Report and Order and Further Notice of Proposed 
Rulemaking, 15 FCC Rcd 5140, 5148, ¶ 14 (2000) (“2000 TRS Report and Order”).
Federal Communications Commission FCC 13-101   
30
businesses.  Specifically, each of the three new requirements entail only minor operational changes that 
can be accomplished at minimal cost to each provider of STS, including small businesses.  
4. In analyzing whether a substantial number of small entities will be affected by the 
requirements adopted in the Report and Order, the Commission notes that the SBA has developed a small 
business size standard for Wired Telecommunications Carriers, which consists of all such firms having 
1,500 or fewer employees.
7
  Five providers currently receive compensation from the Interstate TRS Fund 
for providing STS:  AT&T Corporation; Hamilton Relay, Inc.; Kansas Relay Service, Inc.; Purple 
Communications, Inc. and Sprint Nextel Corporation.  The Commission notes that only one of these five 
providers is a small entity under the SBA’s small business size standard.  Because each of the three new 
requirements adopted in the Report and Order entail only minor operational changes that can be 
accomplished at de minimis cost to each provider of STS, the Commission concludes that there will be no 
significant economic impact on the small entities affected by the changes adopted in this Report and 
Order.  
5. Therefore, for all of the reasons stated above, we certify that the requirements of this 
Report and Order will not have a significant economic impact on a substantial number of small entities.  
6. The Commission will send a copy of the Report and Order, including a copy of this Final 
Regulatory Flexibility Certification, to the Chief Counsel for Advocacy of the SBA.
8
  This final 
certification will also be published in the Federal Register.
9
                                                          
7
13 C.F.R. § 121.201, NAICS code 517110.  According to Census Bureau data for 2007, there were 31,996 firms in 
the Wired Telecommunications Carrier category which operated for the entire year.  U.S. Census Bureau, 2007 
Economic Census, Sector 51: EC0751SSSZ2: Information: Subject Series - Estab & Firm Size: Employment Size of 
Establishments for the United States: 2007 (Release Date: 11/19/2010).  
http://factfinder.census.gov/servlet/IBQTable?_bm=y&-geo_id=&-fds_name=EC0700A1&-_skip=700&-
ds_name=EC0751SSSZ2&-_lang=en.  Of this total, 30,178 firms had employment of 99 or fewer employees, and an 
additional 1,818 firms had employment of 100 employees or more.  Thus, under this size standard, the vast majority 
of firms can be considered small.  (The census data do not provide a more precise estimate of the number of firms 
that have employment of 1,500 or fewer employees; the largest category provided is “Firms with 100 employees or 
more”).  Id.
8
See 5 U.S.C. § 605(b).
9
See id.
Federal Communications Commission FCC 13-101   
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APPENDIX D
Initial Regulatory Flexibility Analysis
1. As required by the Regulatory Flexibility Act (RFA),
1
the Commission has prepared this 
Initial Regulatory Flexibility Analysis (IRFA) of the possible significant economic impact on small 
entities by the policies and rules proposed in this Further Notice of Proposed Rulemaking.  Written public 
comments are requested on this IRFA.  Comments must be identified as responses to the IRFA and must 
be filed by the deadlines for comments in the Further Notice.  The Commission will send a copy of this 
Further Notice, including this IRFA, to the Chief Counsel for Advocacy of the Small Business 
Administration (SBA).
2
  In addition, the Further Notice and IRFA (or summaries thereof) will be 
published in the Federal Register.
3
A. Need for, and Objectives of, the Proposed Rules
2. Speech-to-speech (STS) relay service is a form of telecommunications relay service 
(TRS) that utilizes specially trained communications assistants (CAs) who understand the speech patterns 
of persons with speech disabilities and can repeat the words spoken by such individuals to the other 
parties to a relayed call.
4
In the Further Notice of Proposed Rulemaking (Notice), the Commission seeks
comment on four main issues.  First, the Commission seeks comment on ways to improve outreach to 
increase awareness and utilization for STS, and whether the Commission should contract with a single 
entity to educate potential users about the service’s availability.  Second, to ensure the integrity and long 
term sustainability of the service and prevent waste, fraud, and abuse, the Commission seeks comment on 
whether it should adopt consumer eligibility, registration and verification requirements to ensure that only 
individuals with speech disabilities who need the service can use it.  Third, the Commission seeks 
comment on whether certain mandatory minimum standards, are inapplicable to STS, including CA 
competency in typing and spelling, transmission format of TTY calls, call release of a CA from a call 
with only two TTY users, and voice carry over (VCO), where a person with a hearing disability speaks to 
the other party to the call, but receives the other party’s spoken words as text from the CA.  Fourth, the 
Commission seeks comment on whether to adopt requirements for STS providers to facilitate the ability 
of STS users to create caller profiles.  The Commission tentatively concludes that these proposed rule 
changes may be necessary to improve the efficiency of the STS program and to ensure effective, quality 
STS services so that users with speech disabilities may receive functionally equivalent telephone service, 
as mandated by Title IV of the Americans with Disabilities Act.
B. Legal Basis
3. The legal basis for any action that may be taken pursuant to the Notice is contained in 
sections 1, 2, 4(i), 4(j), and 225 of the Communications Act of 1934, as amended.
5
C. Description and Estimate of the Number of Small Entities to Which the Proposed 
                                                          
1
5 U.S.C. § 601 et seq.  The RFA has been amended by the Small Business Regulatory Enforcement Fairness Act of 
1996 (SBREFA). Pub. L. No. 104-121, Title II, 110 Stat. 857 (1996).  Title II of the CWAAA is the Small Business 
Regulatory Enforcement Fairness Act of 1996 (SBREFA).
2
See 5 U.S.C. § 603(a).
3
See 5 U.S.C. § 603(a).
4
47 C.F.R. § 64.601(a)(30); Telecommunications Relay Services and Speech-to-Speech Services for Individuals with 
Hearing and Speech Disabilities, CC Docket No. 98-67, Report and Order and Further Notice of Proposed 
Rulemaking, 15 FCC Rcd 5140, 5148, ¶ 14 (2000) (“2000 TRS Report and Order”).
5
47 U.S.C. §§ 151, 152, 154(i), 154(j), and 225.
Federal Communications Commission FCC 13-101   
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Rules May Apply
4. The RFA directs agencies to provide a description of, and where feasible, an estimate of 
the number of small entities that may be affected by the rules.
6
The RFA generally defines the term 
“small entity” as having the same meaning as the terms “small business,” “small organization,” and 
“small governmental jurisdiction.”
7
In addition, the term “small business” has the same meaning as the 
term “small business concern” under the Small Business Act.
8
  A small business concern is one which:  
(1) is independently owned and operated; (2) is not dominant in its field of operation; and (3) satisfies any 
additional criteria established by the SBA.
9
5. We believe that the entities that may be affected by the proposed rules are STS providers.  
Neither the Commission nor the SBA has developed a definition of “small entity” specifically directed 
toward STS providers.  The closest applicable size standard under the SBA rules is for Wired 
Telecommunications Carriers, which consists of all such firms having 1,500 or fewer employees.
10
  Five 
providers currently receive compensation from the Interstate TRS Fund for providing STS:  AT&T 
Corporation; Hamilton Relay, Inc.; Kansas Relay Service, Inc.; Purple Communications, Inc.; and Sprint 
Nextel Corporation.  Therefore, we conclude that one of the five STS providers that would be affected by 
the proposed rules is deemed to be a small entity under the SBA’s small business size standard. 
D. Description of Projected Reporting, Recordkeeping, and Other Compliance 
Requirements
6. Certain rule changes, if adopted by the Commission, would modify rules or add 
requirements governing reporting, recordkeeping and other compliance obligations. 
7. If the Commission were to contract with a single outreach coordinator to educate 
potential users about the availability of STS, STS providers, including small entities, would be relieved of 
the obligation to conduct outreach, but would still be permitted to engage in their own marketing 
activities.  There would be no reporting or recordkeeping obligations associated with the proposed rule 
change.
8. If the Commission were to adopt consumer eligibility, registration and verification 
requirements to ensure that only individuals with speech disabilities who need the service can use it, STS 
providers, including small entities, would be required to collect, verify, and maintain certain information 
                                                          
6
5 U.S.C. § 604(a)(3).
7
5 U.S.C. § 601(6). 
8
5 U.S.C. § 601(3) (incorporating by reference the definition of “small business concern” in the Small Business Act, 
15 U.S.C. § 632). Pursuant to 5 U.S.C. § 601(3), the statutory definition of a small business applies “unless an 
agency, after consultation with the Office of Advocacy of the Small Business Administration and after opportunity
for public comment, establishes one or more definitions of such term which are appropriate to the activities of the 
agency and publishes such definition(s) in the Federal Register.”
9
15 U.S.C. § 632.  
10
13 C.F.R. § 121.201, NAICS code 517110.  According to Census Bureau data for 2007, there were 31,996 firms 
in the Wired Telecommunications Carrier category which operated for the entire year.  U.S. Census Bureau, 2007 
Economic Census, Sector 51: EC0751SSSZ2: Information: Subject Series - Estab & Firm Size: Employment Size of 
Establishments for the United States: 2007 (Release Date: 11/19/2010).  
http://factfinder.census.gov/servlet/IBQTable?_bm=y&-geo_id=&-fds_name=EC0700A1&-_skip=700&-
ds_name=EC0751SSSZ2&-_lang=en.  Of this total, 30,178 firms had employment of 99 or fewer employees, and an 
additional 1,818 firms had employment of 100 employees or more.  Thus, under this size standard, the vast majority 
of firms can be considered small.  (The census data do not provide a more precise estimate of the number of firms 
that have employment of 1,500 or fewer employees; the largest category provided is “Firms with 100 employees or 
more”).  Id. 
Federal Communications Commission FCC 13-101   
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from consumers and to maintain such information.  The Commission believes that such costs would be 
reasonable for STS providers, because it is the consumers who would be required to supply the 
information to the providers.  In other words, the obligation of the providers, including small entities,
would be to receive the information from the consumers, and to verify and maintain the information.  The 
Commission believes that the recordkeeping cost to providers would be de minimis for receiving and 
maintaining the information, and that the cost of verifying the information would be reasonable, because 
the task of verification would likely be contracted out to a company that can do such verification at a 
reasonable price, as is typically done in the banking industry and other industries that require verification 
of consumer-supplied information.  If the Commission assigns the task of verification to the manager of a 
common database, then the STS providers would transfer the information to the central database manager, 
and the TRS Fund would compensate the database manager.  Under the latter scenario, TRS providers, 
including small entities, would not be responsible for the cost of verification.  
9. If the Commission were to find certain mandatory minimum TRS standards to be 
inapplicable to STS, all STS providers, including small entities, would benefit because they would not 
need to comply with those mandatory minimum standards and would be relieved of recordkeeping and 
reporting obligations associated with such mandatory minimum standards. 
10. If the Commission were to adopt requirements for STS providers to permit STS users to 
create caller profiles, STS providers, including small entities, would need to obtain and maintain 
information supplied by the users.  However, the cost of creating and maintaining user profiles would be 
outweighed by the cost savings associated with reduced call set-up time, which is not compensable 
because providers may bill the Fund for conversation minutes only.  
E. Steps Taken to Minimize Significant Economic Impact on Small Entities and 
Significant Alternatives Considered
11. The RFA requires an agency to describe any significant alternatives, specific to small 
entities, that it has considered in developing its approach, which may include the following four 
alternatives (among others): “(1) the establishment of differing compliance or reporting requirements or 
timetables that take into account the resources available to small entities; (2) the clarification, 
consolidation, or simplification of compliance and reporting requirements under the rule for such small 
entities; (3) the use of performance rather than design standards; and (4) an exemption from coverage of 
the rule, or any part thereof, for such small entities.”
11
12. In general, alternatives to proposed rules are discussed only when those rules pose a 
significant adverse economic impact on small entities.  In this context, however, two of the proposed rules 
would confer benefits as explained below. 
13. If the Commission were to contract with a single outreach coordinator to educate 
potential users about the availability of STS, STS providers, including small entities, would benefit, 
because they would be relieved of the obligation to conduct outreach.  STS providers would still be 
permitted to engage in their own marketing activities. 
14. If the Commission were to adopt consumer eligibility, registration and verification 
requirements to ensure that only individuals with speech disabilities who need the service can use it, STS 
providers, including small entities, would be required to collect, verify, and maintain certain information 
from consumers.  The Commission believes that such costs would be reasonable for STS providers, 
because it is the consumers who would be required to supply the information to the providers.  In other 
words, the obligation of the providers, including small entities, would be to receive the information from 
the consumers, and to verify and maintain the information.  The Commission believes that the 
recordkeeping cost to providers would be de minimis for receiving and maintaining the information, and 
                                                          
11
5 U.S.C. § 603(c)(1)-(c)(4).
Federal Communications Commission FCC 13-101   
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that the cost of verifying the information would be reasonable, because the task of verification would 
likely be contracted out to a company that can do such verification at a reasonable price, as is typically 
done in the banking industry and other industries that require verification of consumer-supplied 
information.  One alternative to relieve STS providers, including small entities of the verification 
obligations would be to assign the task of verification to the manager of a common database.  If this were 
done, STS providers would transfer the information to the central database manager, and the TRS Fund 
would compensate the database manager.  Under the latter scenario, TRS providers, including small 
entities, would not be responsible for the cost of verification.  The Commission is not proposing other
alternatives for small entities because these requirements may be needed to limit waste, fraud and abuse, 
and an ineligible user can potentially defraud the TRS Fund by obtaining service from large and small 
entities alike.  Therefore, if the Commission were to adopt registration, certification and verification 
procedures, the same requirements would need to apply to users of small entities as well as large entities.
15. If the Commission were to find certain mandatory minimum TRS standards to be 
inapplicable to STS, all STS providers, including small entities, would benefit because they would not 
need to comply with those mandatory minimum standards and would be relieved of  recordkeeping and 
reporting obligations associated with such mandatory minimum standards.
16. If the Commission were to adopt requirements for STS providers to permit STS users to 
create caller profiles, STS providers, including small entities, would need to obtain and maintain 
information supplied by the users.  However, STS providers, including small entities, would benefit from 
establishing user profiles because the cost of creating and maintaining user profiles would be outweighed 
by the cost savings associated with reduced call set-up time.  Call set-up time is not compensable because 
providers may bill the Fund for conversation minutes only.
F. Federal Rules that May Duplicate, Overlap, or Conflict with Proposed Rules
17. None. 
Federal Communications Commission FCC 13-101   
35
STATEMENT OF
ACTING CHAIRWOMAN MIGNON CLYBURN
Re: Speech-to-Speech (STS) and Internet Protocol (IP) Speech-to-Speech Telecommunications Relay 
Services; Telecommunications Relay Services and Speech-to-Speech Services for Individuals with 
Hearing and Speech Disabilities, CG Docket Nos. 08-15 and 03-123
Today we mark the eve of the anniversary of the Americans with Disabilities Act in three distinct 
ways.  First, as you have just heard, we are improving the service that allows people with speech 
disabilities to communicate through telephone networks.  This is another step toward fulfilling the 
promise of Title IV of the ADA, which requires access by people with hearing or speech disabilities to 
our telephone system through telecommunications relay services.  Second, our Consumer Bureau will 
release a Public Notice seeking comment on a request to update our hearing aid compatibility standards, 
which will allow people with hearing loss to have better volume control on wireline phones.  Finally, later 
this morning, we will hear from our staff about the Commission’s implementation of another landmark 
law, the Twenty-First Century Communications and Video Accessibility Act.  The CVAA is already 
ensuring that all Americans with disabilities are able to use a host of the latest communications and video 
programming technologies currently available to the general public. 
The Speech-to-Speech, or “STS” item before us highlights a unique service that allows those with 
speech disabilities to connect to others using the phone network and specially trained communications
assistants.  The Commission first mandated STS in 2000 as a means of fulfilling our charge under the 
ADA, to ensure that the nation’s relay services make use of modern technologies.
In the years that followed, the Commission has received requests and proposals for improving 
this critical service, and today, we answer these requests by improving service standards for those using 
phone services.  
By requiring communication assistants to stay with each STS call for a minimum of 20 minutes, 
we lessen the disruption that sometimes results when assistants are timed out from a call before it is 
concluded.  It generally takes a few minutes for a communications assistant to gain a full understanding of 
the speech patterns of a person with a speech disability, especially if names and technical terms are used 
during a conversation.  Reducing the number of times that these assistants must change during a call will 
result in greater functional equivalency for the user and will allow these calls to be processed more 
efficiently.  Similarly, our requirement for STS providers to offer users the option of having their voices 
muted during a call will minimize disruption to the conversational flow of the call.  Finally, by ensuring 
that consumers who access STS by dialing 711 are able to promptly reach a communication assistant, we 
will make it easier for them to use these services.
We also seek comment on other ways we can improve STS.  We particularly remain concerned 
that despite considerable outreach funding that has been provided over the past several years, there are 
many potential STS users who could benefit from, but remain unaware of, this service.   The proposal to 
centralize STS outreach efforts through a single, national outreach coordinator is another step in 
improving the Commission’s stewardship of the TRS Fund. Our goal is to efficiently reach and educate a 
greater portion of the population of Americans who could benefit from this service. We also ask how best 
to register, certify and verify STS users, which builds on our recent actions on video relay services to curb 
waste, fraud, and abuse.  There should be no doubt about our unwavering commitment to a sustainable 
Fund supporting these services.
Federal Communications Commission FCC 13-101   
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Finally, we are aware that a new form of STS, which uses video technology over broadband to 
allow the communication assistant to see the STS user as he or she is speaking, is now being provided by 
certain state TRS programs.  We understand from some of the petitioners in this proceeding, that having 
the ability to see the STS caller’s facial expressions, gestures, and lip movements – as well as cue cards 
that the caller could hold up to show names and other difficult-to-pronounce words – can help the 
communications assistant to better understand, and re-voice, for the STS user.  We will be opening a 
second STS proceeding in the coming months, to seek comment on this new form of STS, as well as other 
ways that Internet-based technologies can help improve this service.
I am so pleased to announce these new rules, which bring us closer to functional equivalence for 
Americans with speech disabilities.  STS relay provides an invaluable service to these often overlooked 
members of our community, and enables them to participate more fully in American life.   I wish to
acknowledge the extraordinary work of Dr. Bob Segalman, founder of STS, whose ingenuity has enabled 
people with speech disabilities across the country to enjoy independence and privacy when using the 
telephone.  Unfortunately, Bob could not be here with us today as he is based in California, but we hope 
that he is watching our live web feed.  We know that he is with us in spirit.  Additionally, I want to 
express appreciation to Rebecca Ladew, a local Speech-to-Speech advocate, who has served on some of 
our advisory committees.  Bob and Rebecca, your commitment to these issues is unparalleled, and we 
thank you for the work that you have done to make it possible for people with speech disabilities to have 
seamless communication. 
Of course, today and next week’s ADA celebration are milestones, but by no means the end of 
the road.  So much more remains to be done to ensure that people with disabilities are full participants in 
this communications revolution.  I thank my fellow Commissioners for joining me as we move further 
toward this most important goal.
I want to thank the Consumer and Governmental Affairs Bureau for its outstanding work to 
ensure that individuals with speech disabilities have full access to our communications system, and for all 
your efforts to fulfill our obligations under the Americans with Disabilities Act.
Federal Communications Commission FCC 13-101   
37
STATEMENT OF
COMMISSIONER JESSICA ROSENWORCEL
Re: Speech-to-Speech and Internet Protocol (IP) Speech-to-Speech Telecommunications Relay 
Services, Telecommunications Relay Services and Speech-to-Speech Services for Individuals with 
Hearing and Speech Disabilities, CG Docket Nos. 08-15, 03-123
Under the Americans with Disabilities Act, functional equivalency has been the foundation of our 
telecommunications relay service policies.  Functional equivalency may sound like the kind of regulatory 
lingo that only a lawyer could love.  But for millions of Americans with hearing and speech impairments, 
it means that they have the right and ability to pick up the phone, reach out and connect, and participate 
more fully in the world.
Today, more than one million Americans, including an increasing number of veterans suffering 
from brain injuries, live with speech disabilities.  These disabilities can make it difficult to communicate 
and hard to make even a simple phone call.  But the Commission’s speech-to-speech telecommunications 
relay service is designed to help.  Our rules permit people with speech disabilities to speak with a trained 
communications assistant who then relays the words of the speech-to-speech user to the called party.  It 
means that people with speech disabilities can do the things so many of us take for granted—pick up the 
phone and seek emergency help; secure a job; make a doctor’s appointment; follow up with a child’s 
teacher; and connect with family and friends.
But as good as this program is, there is room for improvement.  So today we take steps to 
improve speech-to-speech services.  Specifically, to limit disruption for users, we require communications 
assistants to stay on the line for at least 20 minutes before switching the caller to a new assistant.  At the 
same time, we permit a speech-to-speech communications assistant to transfer a call to another assistant if 
he or she is unable to understand the speech-to-speech user.  Speech-to-speech users also may now mute 
their voices on a call to reduce listener confusion.  In addition, we seek comment on ways to increase 
awareness of the speech-to-speech program so it can help more people with speech disabilities 
communicate effectively.  The net result should be more dignity for users, more clarity for 
communications assistants, and more effective calls.  
Thank you to the Consumer and Governmental Affairs Bureau for your work today and for your 
continued commitment to functional equivalency.  
Federal Communications Commission FCC 13-101   
38
STATEMENT OF
COMMISSIONER AJIT PAI
Re: Speech-to-Speech and Internet Protocol (IP) Speech-to-Speech Telecommunications Relay 
Services, CG Docket No. 08-15; Telecommunications Relay Services for Speech-to-Speech 
Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123.
Seventy-nine years ago, Congress created the Commission “to make available, so far as possible, 
to all the people of the United States, without discrimination . . . a rapid, efficient, Nation-wide, and 
world-wide wire and radio communication service.”
1
  And Congress reiterated that message 23 years ago 
with the passage of the Americans with Disabilities Act.  Today we reaffirm our commitment to this vital 
mission by strengthening the Telecommunications Relay Service (TRS) program used by so many 
Americans with disabilities.
The reforms we make to the Speech-to-Speech component of TRS may appear incremental for 
some, but they can be monumental for those in need.  The muting requirement, for example, is a simple 
fix to ensure that the message of those with a speaking disability comes through clearly.  Extending the 
minimum stay-time should allow fuller, longer discussions for users.  And making Speech-to-Speech 
service easier to access is just as important; there’s no reason why 711 can’t offer the full range of TRS 
programs, including Speech-to-Speech service, from the same straightforward, interactive menu.
None of the reforms adopted today would be possible without the hard work of the Commission’s 
Disability Rights Office—Gregory Hlibok, Marilyn Abraham, Helen Chang, Rosaline Crawford, Jackie 
Ellington, Elaine Gardner, Eliot Greenwald, Solita Griffis, Christina Hebert, John Herzog, Roger 
Holberg, Sherita Kennedy, Cheryl King, Diane Mason, Judy Miller, Traci Randolph, ShaVonne Morris, 
Suzy Rosen Singleton, and Dana Wilson—along with their front-office support: Kris Monteith, Karen 
Peltz Strauss, and Robert Aldrich.  Thank you for everything you’ve done not only with respect to today’s 
item but in your ongoing work to support Americans with disabilities.
                                                          
1
47 U.S.C. § 151.