USTelecom Concerned About Growth in TRS Fund, Telco Contributions

USTelecom voiced concerns about proposed increases in the Telecom Relay Service fund and industry contribution factor, in reply comments posted Friday in docket 10-51, after initial comments were submitted the week before (see 1506090027). The proposals of TRS administrator Rolka Loube Saltzer Associates "would undo much of the good work the Commission has undertaken in recent years to effectively manage the TRS program, promote efficiency, and control costs," USTelecom said. Rolka Loube proposed an "alarming increase of nearly 40% in the TRS contribution factor" for telecom carriers paying into the fund, USTelecom said, saying proposed funding was projected to rise from $793 million to $1.05 billion, a 32 percent increase. "The Commission must be cognizant of the fact that adopting the proposed projection will impose significant and potentially unnecessary costs on consumers," the group said. USTelecom agreed with Comptel's initial comments that the timing of the proposed contribution factor raised problems because both the FCC order announcing the rate increases and its effective date would likely occur on or around July 1, when the new TRS funding year starts. "In addition to providing limited time for a complete assessment and analysis of the significant increase in the contribution factor, carriers will essentially be forced to either substantially increase their customers’ fees, or 'eat the cost of the increase where their contracts or other billing arrangements preclude raising interstate service rates,'" USTelecom said, citing Comptel. USTelecom urged the FCC to move up the adoption of the TRS contribution factor "well in advance" of annual access tariff filings due in mid-June. Ultratec filed replies that supported keeping the multistate average rate structure methodology for IP captioned telephone service. Neither USTelecom nor Ultratec filed initial comments, while other parties that did, such as video relay service providers seeking to head off further rate cuts in their compensation, submitted replies that were consistent with their initial comments, with some elaborating on their arguments.