On May 23, the Ad Hoc Coalition of International Telecommunications Companies (“Coalition”)(www.TelecomCoalition.com) filed with the Federal Communications Commission (“Commission”) an Opposition to the proposed continued imposition of the Telecommunications Relay Service (“TRS”) Fund Contribution Factor on International Telecommunications Services (“Opposition”). In its Opposition, the Coalition asks the FCC to suspend all further imposition of the proposed TRS Fund fee factor on international telecommunications revenues pending equitable reform of the TRS contribution regime, which disproportionately and unlawfully burdens international service providers.
The Coalition argues that the assumptions upon which international TRS contributions were based no longer hold factually true. While the Commission based its initial TRS Fund contribution decision on the idea that both interstate and international services would be funded, available, and widely used by the deaf and hard of hearing communities, new information proves that international TRS is, at best, lightly used. Further, that international telecommunications revenue is disproportionately “taxed” to support the fund (potentially by as much as a factor of 10 to 1). Therefore, the Opposition argues the Commission must account for this pertinent new evidence and reformulate its contribution calculation to ensure that providers of interstate and international telecommunications each contribute equitably.
The Opposition also proposes a new method of calculating TRS Fund contributions. It proposes that the TRS administrator would:
- Calculate the total Fund requirements;
- Separately identify the total number of compensable minutes of interstate and international TRS/VRS calling;
- Determine the percentage of total compensable minutes for both interstate and international minutes, respectively; and
- Apply a separate contribution factor to interstate and international telecommunications services revenues based on the calculation.
For international telecommunications services revenues, the Opposition proposes to apply a fee factor proportionate to the percentage of compensable international TRS/VRS minutes. Likewise, the Opposition proposes to apply a fee factor proportionate to the percentage of compensable interstate TRS/VRS minutes for interstate telecommunications services revenues.
If you have any questions about the Ad Hoc Coalition or would like to support its Opposition by filing Reply Comments in Docket 03-123 or funding further advocacy (including Appellate Court review, if necessary), please contact Jonathan S. Marashlian at 703-714-1313 or by email: jsm@commlawgroup.com.
