FEDERAL COMMUNICATIONS COMMISSION
August 19,2011
JULIUS GENACHQWSKI
CHAIRMAN
The Honorable Jo Bonner
U.S. House of Representatives
2236 Rayburn House Office Building
Washington, D.C. 20515
Dear Congressman Bonner:
Thank you for your letter supporting the application for certification filed by Convo
Communications. J appreciate your support for the video relay service (VRS), which has become a
critical communications tool for many Americans who are deaf or hard of hearing.
The Commission has been reviewing the VRS program to ensure that the provision of VRS
is fair, efficient, and sustainable, and to consider mechanisms for combating waste, fraud, and
abuse. This review included an examination ofthe Commission's certification program for VRS
and other Internet-based telecommunications relay service (iTRS) providers. On July 28, 2011, the
Commission released an Order adopting a revised certification process for these providers. The
Order establishes clear criteria for granting certification to qualifying entities, and adopts measures
that will enable the Commission to exercise the oversight needed to ensure full compliance with the
TRS rules. One new provision requires all iTRS providers to obtain certification from the
Commission in order to be eligible to receive compensation from the TRS Fund.
Convo currently is providing service under a revenue sharing arrangement with a certified
provider. Under that arrangement, Convo provides VRS and then receives compensation for those
services from the certified entity, which in turn gets paid for VRS from the Fund. The Commission
has directed such arrangements to cease by October I, 20 I 1, because some ofthese types of
arrangements have been associated with fraud and abuse of the VRS program. However, Convo
may be able to continue providing VRS ifit files an amended certification application as soon as
possible after the rules adopted in the new certification Order become effective. In a May 18,2011
filing, Convo indicated its intention to submit such an amendment to its certification application.
Once submitted, the Commission's staff will review Convo's anlended application as expeditiously
as possible
The Commission is dedicated to fulfilling the vision ofCongress for a nationwide TRS that
is available to all Americans in the most efficient manner. I appreciate your interest in this very
important matter. Please let me know if I can be ofany further assistance.
Si y,
Julius Genachowski
445 12TH STREET S.W. WASHINGTON, D.C. 20554 • 202·418-1000
FEDERAL COMMUNICATIONS COMMISSION
August 19,20II
JULIUS GENACHOWSKI
CHAIRMAN
The Honorable Jim Langevin
U.S. House of Representatives
109 Cannon House Office Building
Washington, D.C. 20515
Dear Congressman Langevin:
Thank you for your letter supporting the application lor certification filed by Convo
Communications. I appreciate your support for the video relay service (VRS), which has become a
critical communications tool for many Americans who are deaf or hard of hearing.
The Commission has been reviewing the VRS program to ensure that the provision ofVRS
is fair, efficient, and sustainable, and to consider mechanisms for combating waste, fraud, and
abuse. This review included an exanlination ofthe Commission's certification program for VRS
and other Internet-based telecommunications relay service (iTRS) providers. On July 28, 2011, the
Commission released an Order adopting a revised certification process for these providers. The
Order establishes clear criteria for granting certification to qualifying entities, and adopts measures
that will enable the Commission to exercise the oversight needed to ensure full compliance with the
TRS rules. One new provision requires all iTRS providers to obtain certi fication from the
Commission in order to be eligible to receive compensation from the TRS Fund.
Convo currently is providing service under a revenue sharing arrangement with a certified
provider. Under that arrangement, Convo provides VRS and then receives compensation for those
services from the certified entity, which in turn gets paid for VRS from the Fund. The Commission
has directed such arrangements to cease by October I, 2011, because some ofthese types of
arrangements have been associated with fraud and abuse of the VRS program. However, Convo
may be able to continue providing VRS ifit files an amended certification application as soon as
possible after the rules adopted in the new certification Order become effective. In a May 18,20 I I
filing, Convo indicated its intention to submit such an amendment to its certification application.
Once submitted, the Commission's staff will review Convo's amended application as expeditiously
as possible
The Commission is dedicated to fulfilling the vision ofCongress for a nationwide TRS that
is available to all Americans in the most efficient manner. I appreciate your interest in this very
important matter. Please let me know if I can be ofany further assistance.
Sincerely,
Julius Genachowski
445 12TH STREET S.W. WASHINGTON, D.C. 20554 • 202-418-1000
FEDERAL COMMUNICATIONS COMMISSION
August 19,2011
JULIUS GENACHOWSKI
CHAIRMAN
Thc Honorable Tom McClintock
U.S. House of Representatives
428 Cannon House Office Building
Washington, D.C. 20515
Dear Congressman McClintock:
Thank you for your letter supporting the application for certification filcd by Convo
Communications. I appreciate your support for the video relay service (VRS), which has become a
critical communications tool for many Americans who are deaf or hard of hearing.
The Commission has been reviewing thc VRS program to ensure that the provision of VRS
is fair, eflicient, and sustainable, and to consider mechanisms for combating waste, fraud, and
abuse. This review included an examination ofthe Commission's certification program for VRS
and other Internet-based telecommunications relay service (iTRS) providers. On July 28, 2011, the
Commission released an Order adopting a revised certification process for thcse providers. The
Order establishes clear criteria for granting certification to qualifying entities, and adopts measures
that will enable the Commission to excrcise the ovcrsight needed to ensure full compliancc with the
TRS rules. One new provision requires all iTRS providers to obtain certification from the
Commission in order to be eligible to receive compensation from the TRS Fund.
Convo currently is providing service under a revenue sharing arrangcment with a certified
provider. Under that arrangement, Convo provides VRS and then receives compensation for those
services from the certified entity, which in turn gcts paid for VRS from the Fund. The Commission
has directed such arrangements to cease by October I, 20 II, because some of these types of
arrangements have been associated with fraud and abuse ofthe VRS program. However, Convo
may be able to continue providing VRS ifit files an amended certification application as soon as
possible after the rules adopted in the new ccrtification Order become effective. In a May 18,2011
filing, Convo indicated its intention to submit such an amendment 10 its certification application.
Once submitted, the Commission's staff will review Convo's amended application as expeditiously
as possible
The Commission is dedicated to fulfilling the vision ofCongress for a nationwide TRS that
is available to all Americans in thc most cfficicnt manner. I appreciate your interest in this very
important matter. Please let me know if I can be ofany further assistance.
Sincerely,
Julius Genachowski
445 I2THSTREETS,W.WASHINGTON, D.C. 20554 • 202-418-1000
FEDERAL COMMUNICATIONS COMMISSION
August 19,2011
JULIUS GENACHOWSKI
CHAIRMAN
The Honorable Jim McDermott
U.S. House of Representatives
1035 Longwo11h (-louse Office Building
Washington, D.C. 20515
Dear Congressman McDermott:
Thank you for your leiter supporting the application for certification filed by Convo
Communications. I appreciate your support for the video relay service (VRS), which has become a
critical communications tool for many Americans who are deaf or hard of hearing.
The Commission has been reviewing the VRS program to ensure that the provision of VRS
is fair, efficient, and sustainable. and to consider mechanisms for combating waste, fraud, and
abuse. This review included an examination of the Commission's certification program for VRS
and other Internet-based telecommunications relay service (iTRS) providers. On July 28, 20II, the
Commission released an Order adopting a revised certification process for these providers. The
Order establishes clear criteria for granting certification to qualifying entities, and adopts measures
that will enable the Commission to exercise the oversight needed to ensure full compliance with the
TRS rules. One new provision requires all iTRS providers to obtain certification from the
Commission in order to be eligible to receive compensation from the TRS Fund.
Convo currently is providing service under a revenue sharing arrangement with a certified
provider. Under that arrangement, Convo provides VRS and then receives compensation for those
services from the certified entity, which in turn gets paid for VRS from the Fund. The Commission
has directed such arrangements to cease by October 1,2011, because some of these types of
arrangements have been associated with fraud and abuse of the VRS program. However, Convo
may be able to continue providing VRS if it files an amended certification application as soon as
possible after the rules adopted in the new certification Order become effective. In a May 18, 20 I 1
filing, Convo indicated its intention to submit such an amendment to its certification application.
Once submitted, the Commission's staff will review Convo's amended application as expeditiously
as possible
The Commission is dedicated to fulfilling the vision of Congress for a nationwide TRS that
is available to all Americans in the most efficient manner. I appreciate your interest in this very
important matter. Please let me know if 1can be ofany further assistance.
Sincerely,
Julius Genachowski
445 12TH STREET S.W WASHINGTON, D.C. 20554 • 202-4 I 8-1 000
FEDERAL COMMUNICATIONS COMMISSION
August 19,2011
JULIUS GENACHQWSKt
CHAIRMAN
The Honorable Gerald "Jerry" M. McNerney
U.S. House of Representatives
1210 Longworth House Office Building
Washington, D.C. 20515
Dear Congressman McNerney:
Thank you for your letter supporting the application for certification filed by Convo
Communications. I appreciate your support for the video relay service (V RS), which has become a
critical communications tool for many Americans who are deaf or hard ofhearing.
The Commission has been reviewing the VRS program to ensure that the provision of VRS
is fair, efficient, and sustainable, and to consider mechanisms for combating waste, fraud, and
abuse. This review included an examination ofthe Commission's certification program for VRS
and other Internet-based telecommunications relay service (iTRS) providers. On July 28, 20 II, the
Commission released an Order adopting a revised certification process for these providers. The
Order establishes clear criteria for granting certification to qualifying entities, and adopts measures
that will enable the Commission to exercise the oversight needed to ensure full compliance with the
TRS rules. One new provision requires all iTRS providers to obtain certification from the
Commission in order to be eligible to receive compensation from the TRS Fund.
Convo currently is providing service under a revenue sharing arrangement with a certified
provider. Under that arrangement, Convo provides VRS and then receives compensation for those
services from the certified entity, which in turn gets paid for VRS from the Fund. The Commission
has directed such arrangements to cease by October 1,2011, because some ofthese types of
arrangements have been associated with fraud and abuse ofthe VRS program. However, Convo
may be able to continue providing VRS if it files an amended certification application as soon as
possible after the rules adopted in the new certification Order become effective. In a May 18,2011
filing, Convo indicated its intention to submit such an amendment to its certification application.
Once submitted, the Commission's staff will review Convo's amended application as expeditiously
as possible
The Commission is dedicated to fulfilling the vision of Congress for a nationwide TRS that
is available to all Americans in the most efficient manner. I appreciate your interest in this very
important matter. Please let me know if I can be ofany further assistance.
Sincerely,
JuIius Genachowski
445 12TH STREET S.W. WASHINGTON, D.C. 20554 • 202-418-1000