Federal Communications Commission DA 17-86
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Telecommunications Relay Services and Speech-
to-Speech Services for Individuals with Hearing 
and Speech Disabilities
Structure and Practices of the Video Relay Service 
Program
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CG Docket No. 03-123
CG Docket No. 10-51
ORDER AND DECLARATORY RULING
Adopted:  January 18, 2017 Released:  January 18, 2017
By the Acting Chief, Wireline Competition Bureau and Chief, Consumer and Governmental Affairs 
Bureau:
I. INTRODUCTION
1. In this Order, the Wireline Competition Bureau and Consumer and Governmental Affairs 
Bureau (Bureaus) of the Federal Communications Commission (Commission) grant a petition filed by 
VTCSecure, LLC (VTCSecure or Petitioner) on July 6, 2016, seeking waiver of Sections 64.613(a)(1), 
(a)(2), (a)(4), and (b)(2) and 64.623(c) of the Commission’s rules to allow VTCSecure, a provider of 
direct video calling (DVC) customer support services,
1
to access the telecommunications relay service 
(TRS) Numbering Directory.
2
The Bureaus further grant the Petitioner’s request for a declaratory ruling 
that video relay service (VRS) providers must route and connect all direct voice, video and text calls 
                                                     
1
Although the Petitioner refers to “direct sign language (SL)” customer support services, herein we use the term 
“direct video calling (DVC)” customer support services to comport with other Commission references to these 
services.  A direct video calling (DVC) customer support service, for the purpose of this waiver, is a telephonic 
customer assistance service provided by an organization that permits individuals who are deaf, hard of hearing, deaf-
blind, or have a speech disability, using telephone numbers that are registered in the TRS numbering directory, to 
engage in real-time video communication in sign language without a customer assistance agent.  The purpose of 
DVC is to provide direct telephone service to such individuals that is functionally equivalent to voice 
communications service provided to hearing individuals who do not have speech disabilities.
2
See 47 CFR §§ 64.613(a)(1), (2), (4), 64.613(b)(2), and 64.623(c); Petition of VTCSecure, LLC for Waiver of 
Sections 64.613(a)(1), 64.613(a)(2), 64.613(a)(4), 64.613(b)(2), and 64.623(c) of the Commission’s Regulations and 
Request for Declaratory Ruling to Permit Providers of Direct Sign Language Customer Support Service to Access 
the TRS Numbering Directory, CG Docket Nos. 10-51 and 03-123 (filed July 6, 2016) (Petition).  The Bureaus 
released a public notice on July 18, 2016, seeking comment on the petition.  Wireline Competition Bureau and 
Consumer & Governmental Affairs Bureau Seek Comment on VTCSecure Petition for Waiver of Sections 
64.613(a)(1)-(2), (4), 64.613(b)(2), and 64.623(c) of the Commission’s Rules and Request for Declaratory Ruling to 
Permit Providers of Direct Sign Language Customer Support Service to Access the Telecommunications Relay 
Services Numbering Directory, Public Notice, 31 FCC Rcd 7688 (2016).  The following parties filed comments or 
replies, or both:  Charles Bullock; Communications Service for the Deaf, Inc. (CSD); Gallaudet University; 
Telecommunications for the Deaf and Hard of Hearing, Inc., et al. (Consumer Groups); Judith A. Jonas; ASL 
Services Holdings, LLC d/b/a GlobalVRS, et al. (VRS Providers); and VTCSecure, LLC (VTCSecure).  
Federal Communications Commission DA 17-86
2
between telephone numbers listed in the TRS Numbering Directory.  We find that the Petitioner has 
demonstrated good cause for waiver and that the requested declaratory ruling is warranted under the 
Commission’s TRS rules and decisions.  We also conclude that the waiver and declaratory ruling will 
promote cooperation and interoperability between VRS providers and VTCSecure.   
II. BACKGROUND
2. Under Title IV of the Americans with Disabilities Act (ADA), the Commission must 
ensure that individuals with hearing and speech disabilities in the United States have access to TRS, 
which can facilitate use of the telephone system between these persons and other individuals.
3
  Title IV 
requires the Commission to ensure that the access provided by such relay services is “functionally 
equivalent”
4
to voice telephone services “to the extent possible and in the most efficient manner.”
5
  
Additionally, the Commission’s regulations must encourage the use of existing technology and must not 
“discourage or impair the development of improved technology.”
6
3. When Congress enacted Title IV, codified in the Communications Act at Section 225, relay 
calls were placed by individuals, who were deaf, hard of hearing, deaf-blind, or have a speech disability 
using a text telephone device (TTY) connected to the public switched telephone network (PSTN).
7
  As 
new technology developed, the Commission recognized new forms of TRS, including Internet-based 
forms of TRS, namely VRS, Internet Protocol (IP) Relay, and IP captioned telephone service.
8
  The 
Commission has defined relay services, including Internet-based TRS (iTRS), as a means of 
communication that uses communications assistants (CAs) to facilitate telephone conversations between 
two or more end users of TRS.
9
  
4. In 2008, the Commission adopted rules establishing a TRS Numbering Directory, 
administered by a neutral TRS Numbering Administrator, to map each registered iTRS user’s North 
American Numbering Plan (NANP) telephone number to his or her end device.
10
  Under those rules, VRS 
                                                     
3
Pub. L. No. 101-336, § 401 (1990); 47 U.S.C. § 225 (as amended by the Twenty-First Century Communications 
and Video Accessibility Act of 2010 (CVAA), Pub. L. No. 111-260, § 103(b), 124 Stat. 2751, 2755 (2010); Pub. L. 
No. 111-265 (technical amendments to CVAA)). See also Structure and Practices of the Video Relay Service 
Program, Report and Order and Further Notice of Proposed Rulemaking, 28 FCC Rcd 8618, 8620, para. 2 (2013) 
(VRS Reform Order).
4
47 U.S.C. § 225(a)(3); VRS Reform Order, 28 FCC Rcd at 8620.
5
47 U.S.C. § 225(b)(1); VRS Reform Order, 28 FCC Rcd at 8620.
6
47 U.S.C. § 225(a)(2); see also VRS Reform Order, 28 FCC Rcd at 8621, para. 2. 
7
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities; E911 Requirements for IP-Enabled Service Providers, Report and Order and Further Notice of 
Proposed Rulemaking, 23 FCC Rcd 11591, 11593, para. 4 (2008) (iTRS Order).
8
Id.  See also Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities, Report and Order, 15 FCC Rcd 5141, 5152-54, paras. 21-27 (2000); In the Matter of Provision 
of Improved Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities, Declaratory Ruling and Second Further Notice of Proposed Rulemaking, 17 FCC Rcd 7779, 
7783-84, paras. 10-14; iTRS Order, 23 FCC Rcd at 11592-93, para. 1. 
9
See, e.g., 47 CFR § 64.601(a)(15) (defining iTRS as “[a] telecommunications relay service (TRS) in which an 
individual with a hearing or a speech disability connects to a TRS communications assistant using an Internet 
Protocol-enabled device via the Internet, rather than the public switched telephone network. iTRS does not include 
the use of a text telephone (TTY) over an interconnected voice over Internet Protocol service”); 47 CFR § 
64.601(a)(40) (defining VRS as “[a] telecommunications relay service that allows people with hearing or speech 
disabilities who use sign language to communicate with voice telephone users through video equipment. The video 
link allows the CA to view and interpret the party’s signed conversation and relay the conversation back and forth 
with a voice caller.”).
10
See iTRS Order, 23 FCC Rcd 11591 (2008); see also 47 CFR §§ 64.601(a)(36), 64.613(a).
Federal Communications Commission DA 17-86
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providers must now obtain current routing information, including IP addresses or domain names and user 
names, from their registered iTRS users, and include that information in the TRS Numbering Directory, 
so that calls to and from those TRS users may be properly routed.
11
    
5. In 2013, the Commission “amended its rules to improve the structure, efficiency, and 
quality of the VRS program”
12
while reaffirming that “the Commission’s regulations must encourage the 
use of existing technology and must not discourage the development of new technology.”
13
  In this order, 
the Commission explained that traditionally, VRS communications have “require[d] the interaction of 
three separate yet interlinked components: (1) VRS access technologies (e.g., a videophone… [or 
software application]), (2) video communication service (the ‘platform’ that providers use to route calls to 
and from their users), and (3) relay service provided by ASL [American Sign Language]-fluent CAs.”
14
  
VRS providers are compensated by the Interstate TRS Fund (TRS Fund or the Fund)
15
for the reasonable 
costs of providing interstate VRS services based on formulas submitted by the administrator of the TRS 
Fund and approved or modified by the Commission.
16
  
6. According to VTCSecure’s petition, VTCSecure provides a sign language DVC customer 
support service to businesses and government agencies that permits consumers to use a NANP telephone 
number “to engage in real time video communications, including audio, to share information of the user’s 
choosing, and provides the ability for any person, including a deaf, hard of hearing, deaf-blind or speech 
impaired individual, to engage in communications that are functionally equivalent to voice 
communications by hearing individuals.”
17
  The Petitioner explains that Section 64.613(a) of the 
Commission’s rules bars DVC customer service providers from accessing the TRS Numbering Directory 
because such providers’ “services do not meet the iTRS, VRS, or point-to-point service definitions,” 
which “require the participation of a communications assistant or VRS providers.”
18
  Further, the 
Petitioner states that DVC customer support service numbers may or may not be an “individual” as used 
in the definition of “Registered Internet-based TRS user” set forth in section 64.601(a)(27)], and that 
DVC customer support service representatives may or may not be “registered with” a VRS provider as is 
                                                     
11
See iTRS Order, 23 FCC Rcd 11591.
12
VRS Reform Order, 28 FCC Rcd at 8777, para. 1. 
13
VRS Reform Order, 28 FCC Rcd at 8621, para. 2; see also 47 U.S.C. § 225(d)(2).
14
VRS Reform Order, 28 FCC Rcd at 8621, para. 4; see also Structure and Practices of the Video Relay Service 
Program, Notice of Inquiry, 25 FCC Rcd 8597, 8608, para. 32 (2010) (“To initiate a VRS call, a consumer uses a 
VRS access technology to connect to an ASL-fluent CA over the Internet via a broadband video communication 
service. The CA, in turn, places an outbound telephone call to the called party. During the call, the CA relays the 
communications between the two parties, signing what the hearing person says to the ASL user and conveying the 
ASL user’s responses in voice to the hearing person.”).
15
The TRS Fund was established by the Commission to compensate TRS providers for the reasonable costs of 
providing interstate TRS.  See 47 CFR § 64.604(c)(5)(iii)(E)(1).  Every carrier providing interstate 
telecommunications services (including interconnected VoIP service providers and non-interconnected VoIP service 
providers) must contribute to the TRS Fund on the basis of interstate end-user revenues as set forth in the 
Commission’s rules.  47 CFR § 64.604(c)(5)(iii)(A).  The Fund is administered by an entity selected by the 
Commission, currently Rolka Loube Associates, which sets provider compensation rates, funding requirements, and 
the carrier contribution factor on an annual basis, subject to the Commission’s approval.  See 47 CFR § 
64.604(c)(5)(iii)(H).
16
47 CFR § 64.604(c)(5)(iii)(E).
17
Petition at 5.
18
Id.; see also 47 CFR § 64.601(a)(15) (“connects to a TRS communications assistant using an Internet Protocol-
enabled device”), 47 CFR § 64.601(a)(40) (“The video link allows the CA to view and interpret the party’s signed 
conversation…”), 47 CFR § 64.5103(m) (“over VRS provider facilities” and “assigned to customers by VRS 
providers”).
Federal Communications Commission DA 17-86
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necessary to fit within the registration requirements of Section 64.611 of the rules.
19
  Similarly, Section 
64.613(a)(2), which specifies the format of records in the TRS Numbering Directory, limits the Uniform 
Resource Identifier instructions to only geographically appropriate NANP telephone numbers for VRS 
users and IP Relay users, therein leaving “open the possibility for disputes among VRS and direct SL
customer support service providers over how to properly route communications between a VRS user 
device and a direct SL customer support service user device.”
20
  Finally, the Petitioner notes that Section 
64.613(a)(4) permits access to the TRS Numbering Directory only by the TRS Numbering Administrator 
and iTRS providers; DVC customer support services are thus prohibited from accessing the directory 
because they do not meet the definition of “Internet-based TRS providers” that provide TRS to services 
“in which an individual with a hearing or speech disability connects to a TRS communications 
assistant….”
21
  
7. VTCSecure requests waiver of these provisions to allow DVC customer support services 
providers to have access to the TRS Numbering Directory so that they can add their DVC customer 
service numbers to the directory, VRS providers can properly route such numbers, and DVC customer 
support service providers can make outbound calls to deaf customers.
22
  Furthermore, because Sections 
64.613(b)(2) and 64.623(c)
23
of the rules may prevent the TRS Numbering Administrator from allowing 
anyone other than a VRS provider to access the TRS Numbering Directory, VTCSecure requests waiver 
of these provisions as well.
24
  VTCSecure also requests a declaratory ruling to clarify that “VRS providers 
are obligated to support the ability of VRS users” to make and receive direct video, voice and text calls to 
and from “any NANP telephone number listed in the TRS Numbering Directory, including direct [A]SL 
customer support service NANP telephone numbers, using the routing information for each such number 
contained in the TRS Numbering Directory.”
25
III. DISCUSSION
A. Waiver to Allow Providers of DVC Customer Support Services to Access the TRS
Numbering Directory
1. Good Cause
8. Generally, the Commission’s rules may be waived for good cause shown.
26
  The 
Commission may exercise its discretion to waive a rule where the particular facts make strict compliance 
inconsistent with the public interest.
27
  In addition, the Commission may take into account considerations 
of hardship, equity, or more effective implementation of overall policy on an individual basis.
28
  Waiver 
                                                     
19
Petition at 8; see also 47 CFR § 64.611 (requiring, among other things, that a user attest to having a hearing or 
speech disability and provide the user’s full name, address, date of birth, and last four digits of his or her social 
security number). 
20
Petition at 9.
21
Id. at 10; see also 47 CFR § 64.601(a)(15).
22
Petition at 1. 
23
Sections 64.613(b)(2) and 64.623(c) of the Commission’s rules require the TRS Numbering Administrator to 
administer the TRS Numbering Directory according to the terms of its contract.
24
Petition at 11-12.  See also Telecommunications Relay Services and Speech-to-Speech Services for Individuals 
with Hearing and Speech Disabilities, Order, 30 FCC Rcd 13452, 13454, para. 6 (2015) (“We also waive sections 
64.613(b)(2) and 64.623(c) as to the TRS Numbering Administrator, Neustar, to the extent either of these provisions 
separately prohibits Neustar from granting VTCSecure or MITRE access to the directory.”).
25
Petition at 18-19.
26
47 CFR § 1.3.
27
Northeast Cellular Telephone Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990) (Northeast Cellular).
Federal Communications Commission DA 17-86
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of the Commission’s rules is therefore appropriate only if special circumstances warrant a deviation from 
the general rule, and such deviation will serve the public interest.
29
9. Based on the record before us, we find that VTCSecure has demonstrated good cause for 
waiver of sections 64.613(a)(1), (2), (4), 64.613(b)(2), and 64.623(c) of the rules establishing that only the 
NANP telephone number of each “registered Internet based TRS User” may be included in the TRS 
Numbering Directory.
30
Allowing VTCSecure access to the TRS Numbering Directory will enable 
individuals who are deaf, hard of hearing, deaf-blind or have a speech disability to move closer to 
obtaining the functional equivalency Congress envisioned in enacting Title IV of the ADA.  As the 
Commission has repeatedly recognized, compared to traditional TRS, “point-to-point services even more 
directly support the [purposes of section 225]” because they “increase the utility of the Nation’s telephone 
system” for persons with hearing and speech disabilities by “provid[ing] direct communication –
including all visual cues that are so important to persons with hearing and speech disabilities.”
31
  Because 
the consumer interacting with DVC customer support services is utilizing VRS provider facilities and 
VRS access technology at the consumer’s end of the call, we consider DVC customer support services to 
be a subset of point-to-point service.
32
  We agree with Gallaudet University that, “[w]ith direct video 
communications, especially if the call takers are members of the deaf community themselves, the risk for 
mistranslations between ASL and English is eliminated, and thus the risk for costly and frustrating 
misunderstandings is also greatly reduced, if not eliminated.”
33
  Moreover, as Consumer Groups argue, 
granting DVC customer support services access to the TRS Numbering Directory will enhance the 
functional equivalence of the TRS program by granting VRS users more direct, visual, reciprocal 
communication.
34
10. We also find that granting VTCSecure access to the TRS Numbering Directory will 
likely reduce the TRS costs that would otherwise be borne by the TRS Fund by enabling customer 
support services to be used in lieu of VRS.
35
  As the Commission has recognized, direct video 
communication for consumers using DVC is more efficient than traditional TRS because it is “more rapid
in that [it] involve[s] direct, rather than interpreted, communication” and “does not trigger the costs 
involved with interpretation or unnecessary routing….”
36
  In addition to increasing functional equivalency 
and reducing costs of the TRS program, we also agree with VTCSecure that granting this petition will 
(Continued from previous page)                                                            
28
WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969) (WAIT Radio); Northeast Cellular, 897 F.2d at 1166.
29
Northeast Cellular, 897 F.2d at 1166.
30
47 CFR §§ 64.613(a)(1), (2), (4), 64.613(b)(2), and 64.623(c).
31
Telecommunications Relay Services and Speech-to-Speech Service for Individuals with Hearing and Speech 
Disabilities; E911 Requirements for IP-Enabled Service Providers, Second Report and Order and Order on 
Reconsideration, 24 FCC Rcd 791, 821, para. 67 (2008) (Second TRS Numbering Order); see also Structure and 
Practices of the Video Relay Service; Telecommunications Relay Services and Speech-to-Speech Services for 
Individuals with Hearing and Speech Disabilities, Further Notice of Proposed Rulemaking, 30 FCC Rcd 12973, 
12995-6, para. 61 (2015) (VRS 2015 FNPRM).
32
See 47 CFR § 64.5103(m) (defining “point-to-point service” as “a service that enables a VRS customer to place 
and receive non-relay calls without the assistance of a CA over the VRS provider facilities using VRS access 
technology. Such calls are made by means of ten-digit NANP numbers assigned to customers by VRS providers.”).
33
Gallaudet University Comments at 2. 
34
See Consumer Groups Comments at 4.
35
Id. at 4 (“[e]nabling VRS users to communicate directly with hearing individuals who can sign will not only 
conserve the resources of the TRS Fund, as people will elect to use a video phone instead of VRS minutes, but will 
also allow more natural, efficient and effective communications between the parties.”).
36
Second TRS Numbering Order, 24 FCC Rcd at 821, para. 67; see also Petition at 16. 
Federal Communications Commission DA 17-86
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increase employment opportunities for deaf persons at businesses and agencies that use DVC customer 
support.
37
11. Further, as explained below, we do not find meritorious the various specific concerns 
raised by the VRS Providers in opposition to VTCSecure’s petition.  Therefore, we find good cause for a 
waiver in light of the particular facts, the public interest, and considerations of hardship, equity, and more 
effective implementation of overall policy.
38
  Because we find good cause to grant the requested waiver, 
we reject the VRS Providers’ argument that the Commission must conduct a notice-and-comment 
rulemaking before granting DVC customer support service providers’ access to the TRS Numbering 
Directory.
39
2. Specific Concerns Raised by Commenters
12. Mandatory Use of DVC.  VRS providers ask us to “ensure that any use of direct sign-
language customer-support service is optional, not mandatory, and that users are still able to place a VRS 
call to every company’s standard customer-support numbers.”
40
  Because Petitioner’s proposal does not 
contemplate being a mandatory service and TRS customers will continue to have access to all VRS 
provider services,
41
we find any further clarification unnecessary.
13. VRS Provider Costs.  VRS providers additionally ask that the Commission clarify “that 
any modifications to the rules do not impose obligations on VRS providers or otherwise tax the TRS 
Fund.”
42
  They express concern that “[a]ssumption of an additional obligation to implement 
interoperability with direct sign-language support services would only exacerbate [their] financial 
condition.”
43
  They ask the Commission to clarify that “the cost of complying with these obligations can 
be recovered through an exogenous-cost adjustment consistent with the adjustments authorized when the 
Numbering Directory was first implemented.”
44
  Because the burden will be on VTCSecure to comply 
with the same interoperability requirements
45
and the same privacy standards imposed on VRS providers 
by Section 64 of the Commission’s rules,
46
we do not believe that additional burdens will be imposed on 
VRS providers beyond the providers’ already existing interoperability requirements.  
14. Security, Reliability, and Privacy.  VRS providers express concern that expanding access 
to the TRS Numbering Directory to non-VRS providers would create significant security and reliability
challenges.
47
  They assert that, to protect the security of the database, the Commission must, at a 
minimum, ensure that only entities with a legitimate need can access the database.
48
  Consumer Groups 
similarly request that the Commission “require providers of direct SL customer support service to comply 
                                                     
37
See Petition at 1.
38
WAIT Radio, 418 F.2d at 1159; Northeast Cellular, 897 F.2d at 1166.
39
See VRS Providers Comments at 1, 3-4.
40
VRS Providers Comments at 2.
41
VTCSecure Reply at 15 (“VTCSecure agrees one hundred percent that functional equivalence requires that deaf 
and hard of hearing consumers must be able to choose for themselves whether to call a customer support service line 
directly or using a VRS interpreter.”).
42
VRS Providers Comments at 11. 
43
VRS Providers Comments at 11-12.
44
VRS Providers Comments at 12.
45
See 47 CFR §§ 64.619, 64.621, 64.617.
46
See, e.g., 47 CFR §§ 64.611(a)(4), 64.2001-64.2011. 
47
VRS Providers Comments at 1. 
48
Id. at 4.
Federal Communications Commission DA 17-86
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with all privacy and related consumer protection requirements applicable to VRS providers with access to 
the TRS Numbering Directory, including Customer Proprietary Network Information (CPNI) 
requirements.”
49
  
15. In response, VTCSecure maintains that it does not have any access to VRS CPNI or other 
personal information that VRS users provide to their default provider or any other VRS provider.
50
  
Regarding its ability to identify the VRS providers serving particular telephone numbers, VTCSecure
responds that because it serves only businesses, agencies, and organizations, not VRS users, and is not 
compensated through the TRS Fund, it lacks any incentive to attempt “to lure away a VRS provider’s 
customers.”
51
  Furthermore, VTCSecure states that because it will be registered with the Commission 
through its Form 499 filing and will be working with the TRS Numbering Administrator to access the 
directory, there will be no difficulty in addressing any concerns about its compliance with the 
Commission’s requirements.
52
  
16. The Bureaus recognize that the security, reliability, and the privacy of VRS users are 
critical to the success of the TRS program.  The comments, however, do not provide any concrete 
evidence of a security or reliability risk.
53
  In addition, as VTCSecure explains, it would not have access 
to VRS users’ CPNI, and in any case will be subject to enforcement action for violation of applicable 
privacy and security rules.  Indeed, as the Petitioner and some commenters suggest, granting this waiver 
may benefit the privacy and security interests of those TRS users who might prefer to conduct 
confidential communications on sensitive matters without the involvement of a CA.
54
  We concur with 
CSD that “any regulation intended to perpetuate limited access to the TRS Directory under the guises of 
security and reliability … does not serve the public interest.”
55
  By granting this request for waiver, we 
will maintain the level of protection TRS users expect while allowing for improved privacy options 
through direct video communication.
17. Ten-digit Numbers for Hearing Individuals.  Some commenters suggest that the 
Commission should expand the TRS Numbering Directory to include the ten-digit numbers of hearing 
individuals so that they may also “place and receive direct (point-to-point) video calls to and from other 
VRS users.”
56
  These commenters argue that individuals, “who are [A]SL competent, and have business 
and personal relationships with deaf individuals, need access to the [TRS Numbering Directory] for the 
same reasons” as the Petitioner.
57
  While such a decision may promote the functional equivalency of the 
VRS program, it is beyond the scope of this petition and we therefore decline to address it at this time.
B. Declaratory Ruling on Routing of DVC Calls by VRS Providers  
18. VTCSecure additionally requests a declaratory ruling that refusal by VRS providers to 
“recognize and properly route video calls originating from or directed to the domain and IP address of an 
NANP telephone number included in the TRS Numbering Directory is a violation of the Commission’s 
                                                     
49
Consumer Groups Comments at 7-8; see also 47 CFR §§ 64.5101-64.5111.
50
VTC Secure Reply at 7. VTCSecure states that the only CPNI that a DVC service provider has access to is that of 
the business, agency, or organization to which it provides service, and that CPNI is already protected under the 
Commission’s existing CPNI rules. Id. at 7-8.
51
Id. at 9.
52
Id. at 10-11.
53
See VTCSecure Reply at 10.
54
See id. at 5; Consumer Groups Comments at 5.
55
CSD Comments at 3.
56
Consumer Groups Comments at 4; see also CSD Comments at 2-7; Charles Bullock Comments at 1-3.
57
Judith A. Jonas Comments at 1. 
Federal Communications Commission DA 17-86
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regulations.”
58
  The Petitioner points out that the US VRS Provider Interoperability Profile, as adopted by 
the Session Initiation Protocol (SIP) Forum Video Relay Service Task Group, instructs VRS providers to 
complete only those calls with source IP addresses on a list of known peer providers.
59
  If “the source IP 
address of the [A]SL customer service number is not associated with one of the ‘peer providers’ – i.e., 
another VRS Provider – then the VRS provider is directed not to complete the call to its VRS end user.”
60
  
In addition, because “the provision of direct SL customer support service reduces the number of 
compensable VRS minutes for which a VRS provider is paid by the TRS Fund,” the Petitioner argues that 
VRS providers have a disincentive “to facilitate direct SL customer support service.”
61
  No commenters 
directly addressed VTCSecure’s request for a declaratory ruling. 
19. We find merit to VTCSecure’s request for a declaratory ruling and therefore clarify that 
VRS providers may not refuse to recognize and route direct voice, video, or text calls originating from or 
directed to the domain and IP address of an NANP telephone number included in the TRS Numbering 
Directory.  We agree that without this requirement, VRS users may be unable to reach DVC customer 
support service numbers, and vice versa, due to the risk that calls “to a domain name not on the VRS 
providers’ white list” may not be completed.
62
  The Commission has a longstanding policy regarding 
interoperability and has previously stated that “all default providers must support the ability of VRS users 
to make point-to-point calls without the intervention of an interpreter.”
63
  This requirement applies with 
respect to DVC customer service calls, which as noted above, are a subset of point-to-point calls.
64
20. We agree with Gallaudet University that while “cooperation by the VRS providers with 
respect to call routing for calls originating from direct sign language call centers” is “essential,” ensuring 
“that the videophones and VRS provider networks are fully interoperable with the systems deployed by 
the call centers” is equally important.
65
  Therefore, just as the VRS providers are required to route DVC 
customer service calls, we waive these rules on the condition that VTCSecure ensures the interoperability 
of its system with the VRS provider network.
IV. ORDERING CLAUSES
21. Accordingly, IT IS ORDERED, pursuant to sections 1, 4(i), 5(c), 225, and 251 of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 151, 154(i), 155(c), 225, and 251, and to the 
authority delegated in sections 0.91, 0.141, 0.291, 0.361, and 1.3 of the Commission’s rules, 47 CFR §§ 
0.91, 0.141, 0.291, 0.361 and 1.3, that the petition for waiver of sections 64.613(a)(1), 64.613(a)(2), 
64.613(a)(4), 64.613(b)(2), and 64.623(c) of the Commission’s rules IS GRANTED, as described herein.
                                                     
58
Petition at 3. 
59
See SIP Forum, VRS US Providers Profile TWG-6-1.0 at 15-16 (2015), 
http://www.sipforum.org/component/option,com_docman/task,cat_view/gid,134/Itemid,261/. (Section 9.2.2.1 states 
that “[a]uthentication of the peer provider is achieved by checking the source IP address of SIP signaling traffic 
received on R1 to ensure that the sender's address is one of the known peering addresses for the peer provider.” 
Section 9.2.3 then states that “[i]f the source IP address of the request is not in the list of peers then the request must 
not be processed.”).  See also Petition at 10-11.
60
Petition at 11.
61
Id. at 8; see also CSD Comments at 4 (“Because any Direct ASL Services operation may siphon away 
compensable minutes from VRS providers, such an arrangement presents a conflict; VRS providers should not be 
expected to indefinitely support entities providing Direct Video ASL Services operations gratis when such 
operations risk eroding their revenue.”). 
62
Petition at 3.
63
Second TRS Numbering Order at para. 65; see also Petition at 18. 
64
See supra para. 9.
65
Gallaudet University Comments at 3.
Federal Communications Commission DA 17-86
9
22. IT IS FURTHER ORDERED, pursuant to section 1.102(b)(1) of the Commission’s rules, 
47 CFR § 1.102(b)(1), that this order SHALL BE EFFECTIVE upon release. 
FEDERAL COMMUNICATIONS COMMISSION
Kris Monteith 
Acting Chief, Wireline Competition Bureau
Alison Kutler
Chief, Consumer and Governmental Affairs Bureau