I am making these comments as the executive director of an agency that
provides a wide variety of services to people with developmental disabilities
and a supporter of the Speech-to-Speech (STS) service.

1. Most of the consumers I serve will be unable to respond to this Notice of
Proposed Rulemaking (NPRM) because of the nature of their disabilities. Their
lack of response does not denote a lack of interest.

2. STS should be required nationally even though it does not utilize Text
Telephones (TTYs). I support the California Public Utilities Commission
position that the specific reference to TTYs in the Americans with
Disabilities Act is meant to illustrate the type of technology that might be
used, not preclude the use of other technologies.

3. I support the Federal Communications Commission's (FCC) tentative
conclusion that STS be required nationally.
The reason I support these comments is because the majority of the consumers I
serve are not able to read or write and a large number also have speech
impairments. However, they do have a need to communicate. The use of TTYs is
either very difficult or impossible for them, as is direct voice communication
due to severe speech impairments and learning disabilities. For a more
detailed narrative from someone who is intimately acquainted with STS and its
uses, I would refer you to the comments posted by Bob Segalman. I
wholeheartedly lend my support to his position on this issue and urge your
serious consideration of Speech-to-Speech as a nationwide service.

--part0_900476204_boundary--