3049 Noriega Street
San Francisco, CA 94122
                           July 13, 1998              

tvnguyen@fcc.gov

Dear Ms. Nguyen,

I have a colleague whom I really respect. His name is Dr. Bob Segalman
whom I know you have heard from because he has championed
Speech-to-Speech to help an important segment of American citizens
with disabilities. I feel especially close to Dr. Segalman because my
own mother was severely hearing impaired until she was 52 years of age
when a new surgical technique restored much of her hearing loss. I
know how much she would have been in favor of helping people who have
difficulty communicating in speech avail themselves of the new
communications technology to improve their lives. Since January 15,
1998, I have been doing a study of a very debilitating disease.
Through my research, I have met many intelligent, productive citizens
whose quality of life has been improved through the various new
technological devices, one of which is Speech-to-Speech.
Based on these life experiences, I support the Federal Communications
Commission's (FCC) tentative conclusion that STS (Speech-to-Speech) be
required nationally. Its 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 expensive state, all other states
should expect lower cost. Some costs will be much lower. 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. Regardless of the cost, I believe it is an ethical
act to improve the lives of the many people Speech-to-Speech helps.
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 all 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. The FCC could convene such a consumer board to study this
issue.
I am sure that you are familiar with the many other important legal
and technical points surrounding this issue, and I will not repeat
them in my letter. I have chosen those arguments that strike me as
being the most cogent in support of Speech-to-Speech. Nevertheless, I
support the general statement advocated by Dr. Bob Segalman and other
STS advocates.
Cordially yours,
J. Barry Gurdin, Ph.D.
(415)
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