On December 18, 2015, the FCC published a notice soliciting Comments and Reply Comments on a Petition for Rulemaking filed by IDT Telecom, wherein IDT requests a rulemaking to to review and revise its rules and policies on the contribution methodology for the Interstate Telecommunications Relay Service (TRS) Fund. Specifically, IDT requests that the Commission implement a contribution methodology that includes intrastate revenue within the TRS Fund contribution base.  In addition, IDT requests that the Commission remove the rule provision requiring that video relay service costs shall be recovered from only interstate and international revenue. 

IDT asserts that expanding the TRS Fund contribution base to include intrastate revenue would greatly increase and strengthen the base of the TRS Fund.  Under the existing TRS funding mechanism, TRS is funded through carrier contributions calculated at 1.635% (adjusted annually) of a carrier’s combined interstate and international revenue, with intrastate revenue excluded.  If the FCC grants IDT’s requested rule changes, TRS costs for service providers with higher interstate and international revenue would significantly decrease.  On the other hand, TRS costs for provides whose revenue is more heavily weighted towards intrastate would experience an increase.

Comments and Reply Comments are due 15 days and 25 days, respectively, following publication of the Petition for Rulemaking in the Federal Register.  As of the date of this Advisory, the Petition has not yet been published in the Federal Register.

If you are interested in filing comments or replies, please contact the attorney assigned to your account or, in the alternative, Jonathan Marashlian at jsm@commlawgroup.com.