Hamilton Relay Asks FCC to Weigh All IP CTS Issues in FNPRM; CaptionCall Opposes Tier Plan

to employ the Multistate Average Rate Structure (MARS) for calculating IP CTS rates, because MARS is the only market-based [telecom relay service] rate mechanism ...[and] has proven to produce predictable rates that reasonably compensate IP CTS providers" for costs, said a Hamilton filing posted Wednesday in docket 13-24 on conversations with aides to Chairman Ajit Pai and Commissioner Brendan Carr. It asked the FCC, as it did on video relay service rates, to release for comment any IP CTS draft order before a vote. CaptionCall and parent Sorenson Communications opposed a ClearCaptions proposal for a four-tier rate structure, and they urged the FCC not to propose any rate tiers in an FNPRM. Although the FCC has adopted VRS rate tiers, "the IP CTS market is fundamentally different" and such an approach could be disruptive, they said Tuesday. CaptionCall said Sept. 7 it believed all the rate issues should be considered in an FNPRM, but it understood the FCC was considering setting a transitional rate; if the commission does so, the company urged regulators not to prejudge issues. CaptionCall agreed with Sprint that "service quality standards" must be considered with long-term rates. "We also agree with Sprint and Hamilton that the MARS methodology has avoided dramatic swings in the IP CTS rate, allowing providers to invest in their services with reasonable certainty that they will recover their investments," said a filing it and Sorenson made on a meeting with a Pai aide.