NAD and Consumer Groups File Comments on VoIP Contributions to the TRS Fund

On May 4, 2011, the National Association of the Deaf took the lead, and was joined by other consumer groups, in submitting comments in response to a Notice of Proposed Rulemaking issued by the Federal Communications Commission (FCC) asking for comments about VoIP contributions to the Telecommunications Relay Services (TRS) Fund. The Twenty-First Century Communications and Video Accessibility Act of 2010 (Accessibility Act), signed by President Obama last fall, requires that each interconnected VoIP service provider and each provider of non-interconnected VoIP service shall participate in and contribute to the TRS Fund.

We support the FCC proposal to require that all interconnected and non-interconnected VoIP service shall contribute to the TRS Fund. Interconnected VoIP service allows people to make and receive calls to and from traditional phone numbers using an Internet connection (i.e. Vonage.). Non-Interconnected VoIP service allows people to only make or receive calls from or to the public switched telephone network (i.e. making a call to somebody’s cell phone through Skype.) The TRS Fund has traditionally been funded by wire and radio telephone services, however, as technology changes, more and more calls are being made over VoIP. In order for the TRS Fund to remain solvent in the future, it is critical for new kinds of telephone services to contribute to the TRS Fund.

The TRS Fund is not only for individuals who are deaf or hard of hearing, it serves everyone who interacts by telephone with an individual who is deaf or hard of hearing, including but not limited to employers, co-workers, employees, doctors, lawyers, business people, bankers, colleagues, and family and friends.