COMMENTS ON THE STS NOTICE OF PROPOSED RULE MAKING - Revised 7/5/98

I am making these comments as an advocate of people who are severely speech
impaired and have benefitted from technology to communicate.

REGULATORY ISSUES - GENERAL

1. Many consumers and potential consumers will be unable to
respond to this Notice of Proposed Rulemaking (NPRM) because of
the nature of their multiple disabilities. Please do not take
the lack of response as a lack of interest.

2. Speech-to-Speech should be required nationally even though it
does not utilize Text Telephones (TTYs). I support the California
Public Utilities Commission (CPUC) position that the
specific reference to TTYs in the Americans with Disabilities Act
(ADA) "... is meant to illustrate the type of technology that
might be used, not to preclude the use of other technologies."
Title IV of the ADA is applicable to any wire or radio
communication service that enables persons with hearing or speech
disabilities to engage in communication with persons without such
disabilities and is not limited to services using TTYs.
STS services fall within the scope of the ADA's
definition of "telecommunications relay services" as a telephone
transmission service that enables an individual who has a speech
disability to communicate by wire or radio with a hearing
individual in a manner that is functionally equivalent to the
ability of a person who does not have a speech disability to
communicate using voice communication services by wire or radio.
The NPRM states in paragraph I, 5, that STS comes under
the jurisdiction of the ADA.

3. I support the Federal Communications Commission's (FCC)
tentative conclusion that STS be required nationally; cost should
not prevent establishing a national requirement. STS is an
inexpensive service. The cost of Speech-to-Speech plus outreach
for California for 1997 was less than $1m. As California is the
most populous state, all other states can expect lower costs;
some costs will be much lower. Therefore, this low cost is
another good reason to make STS a national requirement. The
state administrators who questioned making STS a national
requirement because of unknown costs may have not been aware of
the California costs at the time. (See NPRM paragraph 24).


4. I support the FCC's tentative conclusion that the costs of
providing interstate STS should be reimbursed from the interstate
Telecommunications Relay Service (TRS) Fund. This conclusion is
based on, and consistent with, the statutory duty not to
discourage the implementation of improved TRS.

5. While STS may have operational differences that make compliance
with alll current Commission standards for tty relay infeasible,
a panel of consumers and providers should be convened to
determine the appropriateness of compliance with each standard.

6. The STS standards should deviate from those of TRS in the
definition of confidentiality. While general confidentiality is
vital, confidentiality should not be defined as specifically for
STS as for TTY relay. FCC could convene such a consumer board to
study this issue.

Thank you,


Ann Ratcliff Ph.D.