From:      Al Sonnenstrahl <sonny@clark.nets
To:        A16.A16(RDANCEY),A4.A4(MCONTEE,JBOLEY),FCC~IL.SMT...
Date:      7/18/9&l 6:18pm
Subject:   TRS NPRM CC Docket No.98-67 Comments

Since I am on the road, I trust that you will accept the
attached as my formal comments to the TRS NPRM which was released
on May 20, 1998 and file it accordingly.

For your convenience, the first attachment is in Microsoft Word
97 and the second one is in text format.  If problems, please let
me know.

Thanks a million!

Al Sonnenstrahl

cc:B7.B7(PGREGORY),J7.J7(KMONTEIT)



       Before the
Federal Communications Commission  
   Washington, DC 20554         

In the Matter of

Telecommunications Relay Services    
and Speech-to-Speech Services for     
Individuals with Hearing and       
Speech Disabilities              

CC Docket No. 98-67

Comments

Submitted by

     Alfred Sonnenstrahl
   Sonny Access Consulting
   10910 Brewer House Road
North Bethesda, Maryland  20852-3463
       800-735-2258 TRS
     301-770-7555 TTY/Fax
      sonny@clark.net

July 20, 1998

Background:

1.  My name is Alfred Sonnenstrahl.  I was the executive director
of a national consumer oriented telecommunications organization
for people with hearing disabilities, Telecommunications for the
Deaf, Incorporated (TDI) from 1987 to 1996.  TDI assisted in
writing telecommunications related languages in Titles II and IV
of the Americans with Disabilities Act (ADA). Also, as a
result of TDI's assistance in orienting the Federal
Communications Commission (FCC) to the text telephone (TTY)
network in the early 1990's, the FCC issued a Telecommunications
Relay Services (TRS) Order on July 26, 1991 and created a
Disability Issues Task Force (DITF).  The TRS Order implemented
TRS in each state.  DITF developed internal orientation to
disability issues for FCC personnel in order to issue realistic
regulations that were workable for Americans with or without
disabilities.  In addition,  TDI initiated training programs for
all TRS providers before they established internal training
programs from 1990 to 1995.  I also served as the vice chair of
the Interstate TRS Advisory Board, which was administered by the
National Exchange Carriers Association (NECA).

2.  I want to take this opportunity to applaud the FCC for
revisiting the TRS Order.  Since 1991, issues have emerged that
need to be updated, redefined, reemphasized,  and clarified.  The
following are my comments to the Notice of Proposed Rulemaking,
CC Docket No.  98-67, which was released on May 20, 1998.

3.  Please note that numbers in parentheses after subheadings
refer to the paragraph numbers within the TRS NPRM CC Docket No. 
98-67, adopted on May 14, 1998, and released on May 20, 1998.

Who are the  "Common Carriers"? (14)

4.  "Wire or radio communication service" needs to be emphasized.
Currently many common carriers, including wired and wireless
telecommunications companies, do not realize that they have the
ultimate responsibility to provide TRS.  About 80% of the states
are under the impression that they, not the common carriers, have
the ultimate responsibility of recovering costs and administering
intrastate TRS.  Also, in some states, the wireless industry
remains inaccessible to TRS.

5.  The definition of "Common Carriers" needs to be revisited and
reemphasized.  When the ADA was passed eight years ago, "common
carriers" covered the wired telephone industry.  Because of the
development of new technology, quite a few industries, including
cellular telephones and personal communications, have been
entering the picture.

"Improved" Relay Services: (15, 19-39)

6.  "Improved relay services should be reviewed carefully.  The
main intention of Title IV of the ADA in 1990 was to ensure that
all electronic utility systems, voice telephone and text
telephone systems were accessible to each other.  In other words,

the intention was to be as consistent as all other electronic
systems.  TRS involve human personnel who serve as Communications
Assistants (CA) to bridge the gap between voice language and
text language systems only because the voice recognition system
has not reached an acceptable effective level yet.

7.  Are Speech to Speech (STS), Video Relay Interpreting VRI),
and Multi-Lingual services (MLS) considered as utility or human
services?  STS, VRI, and MLS, by all means,  are valid services
and should be considered.  STS, as I understand, is when a
specialist/voice interpreter who could understand sufficiently
intelligible speech being spoken by a caller with speech
disabilities at one end of the phone repeats what is said legibly
to a voice user on the other end of the phone.  VRI, as I
understand, is when a specialist/sign language interpreter who
interprets sign language being signed by a caller with minimal
ability to type English and speaks legibly to a voice user on the
other end of the phone.  MLS, as I understand, is when a
specialist/translator who could understand one language being
either typed or spoken by a caller at one end of the phone
translates this to a different language to either a voice or TTY
user on the other end of the phone.

8.  Should the FCC declare that these services are utility
services, these services should be incorporated as part of TRS
and their related costs should be recovered by all end users.  If
they are considered as human services, they should be referred to
other agencies, such as the Department of Health and Human
Services, to establish and maintain procedures and cost recovery
mechanisms.

Functionally Equivalency:

9.  Functional equivalency" needs to be re-emphasized.  Under
current conditions, TRS providers do not have the incentives to
provide current technology which could enhance functional
equivalency due to their contractual obligations which tend to
last between three and five years. Common carriers,at this point,
do not seem to realize their legal obligations while state
administrators tend to concentrate on obsolete contractual
commitments and keeping taxes instead of tariffs as low as
possible.

10.  Since it appears that there is no time frame for the common
carriers to achieve higher readily achievable functional
equivalent TRS,it is recommended that the FCC issue a time table
to achieve goals. Under current conditions, TRS providers tend to
delay as long as the length of current state contracts before
inserting new features.  I propose that a grace period of 12
months be given to each TRS provider to include any readily
achievable functionally equivalent features.

Emergency Services: (40-41)

11.  Ultimately, 911 should handle all TTY calls.  TRS should
not be involved in handling emergency calls because of various
reasons. The caller's 911 jurisdiction tends not to be within the
TRS center's 911 jurisdiction, thus causing time delays for the
CA to trace a lo-digit number to reach the caller's 911 center
which could have drastic consequences.  Also, it would be
difficult for CAs to shift from neutral stances while handling
regular TRS calls to personal involvement while handling
emergency related calls. Furthermore, CAs tend not to be trained
to handle emergency situations. However, due to time sensitivity,
TRS must not refuse any emergency related calls.

12.  All issues related to emergency TRS calls should be
considered non-proprietary.  Such issues which include procedural
standards, record keeping, etc., like all 911 calls, should be
shared with the public and reported to the Dept of Justice which
is currently making efforts to assist all emergency points
accessible to all TTY calls.

Enhanced services: (42-46)

13.  Had the common carriers been observing their legal
obligations as defined by the 1991 FCC TRS Order, the functional
equivalency of new features such as voice menu driven systems
would not be a problem today.  In reality, the voice menus are a
problem because CAs are unable to maintain the speed of
transmission and the TTY users are unable to interrupt CAs.  Had
TRS been using, for example, Turbocode, the above-mentioned
problems would have been minimized.

Speed-of-Answer Requirements: (47-53)

14.  The 85%-10 second rule should be maintained only with live
CAs. Automated answering systems should be within the rule, not
beyond the rule.

Abandoned Calls: (53)

15.  Abandoned calls should include attempted calls before they
are answered. Current abandoned calls data are limited to those
which were disconnected only after they were answered by TRS.

Typing Speed: (54-60)

16.  It is imperative that the FCC establish minimum typing speed
standards. Under current conditions, NECA reimburses "certified"
TRS centers for interstate calls without minimum typing speed
standards.  It would appear discriminatory should NECA and TRS
consumers pay for longer calls because of CAs' minimal and
variable typing speeds and the absence of higher technology
such as Turbocode.

In-Call Replacement of CAs: (61-62)

17.  The FCC is to be commended for proposing a minimum l0-minute
stay on each TRS call.  However, we need to add that should the
calls be about to end such as when one party was saying "Good
bye" or signing off, CAs should remain on line until such calls
are completed.

Competition Issues: (63-68)

18.  Since the Telecommunications Act of 1996 encourages
competition in telecommunications markets, TRS single vendoring
is discriminatory.

19.  To create and maintain an intrastate multivendor
environment, each state should create a state TRS commission
(STRSC) using a structure similar to respective state insurance
commissions.  Each STRSC could establish its own TRS criteria and
certify any provider meeting such criteria before calls from that
state are initiated. As for the rates,  STRSC could function as
respective state regulatory commissions by assessing and
approving the rates and then paying state certified providers for
services rendered in respective states.

Treatment of TRS Customer Information: (69-72)

19.  The disclosure of "customer network information" should
remain proprietary only in multi vendor settings.  In other
words, should the FCC encourage the continuance single vendoring,
customer network information should be considered the property of
respective state TRS administrators.

Other Issues: (77-80)

20.  With multi vendoring, each provider will have the incentives
to comply with functional equivalency by adding various TRS
features such as call release, caller ID recognition, 2-line VCO,
etc.; that is, if the FCC decide not to regulate such features.

National TRS Advisory Committee: (73-76, 78)

21.  Should single vendoring remain in effect, it is strongly
recommended that a National TRS Advisory Board be created and
maintained to monitor effectiveness and functional equivalency of
TRS issues.  The Board is to report the findings to the FCC for
certification, re-certification, and enforcement.

Respectfully submitted by

Alfred Sonnenstrahl
Sonny Access Consulting
10910 Brewer House Road
North Bethesda, MD   20852-3463
800-735-2258 TRS
301-770-7555 TTY/Fax
sonny@clark.net