COMMONWEALTH OF PENNSYLVANIA
PENNSYLVANIA PUBLIC UTILITY COMMISSION
P.O. BOX 3265, HARRISBURG, PA 171053265

                      
July 17, 1998           

Maglie R. Salas, Secretary
Office of the Secretary
Federal Communications Commission
1919 M. Street N.W.
Washington, DC 20554

Re:  CC Docket 98-67: Telecommunications Relay Service and
     Speech to Speech Services for Individuals with Hearing
     and Speech Disabilities

Dear Ms. Salas:

  Enclosed for filing are an original and four copies of the
comments on behalf of the Pennsylvania Public Utility Commission
regarding the Notice of Proposed Rulemaking in the
above-referenced matter. I have also enclosed a copy to be time
stamped and returned to me in the stamped self-addressed
envelope.  Thank you for your assistance in this matter.

Sincerely,

Wayne T. Scott
Assistant Counsel
(717) 783-6150


July 17, I998

          BEFORE THE
FEDERAL COMMUNICATIONS COMMISSION
     WASHINGTON, DC 20554

Telecommunications Relay Services      )
and Speech-to-Speech Services for      )    CC Docket No. 98-67
Individuals with Hearing and Speech    )
Disabilities                           )

  COMMENTS OF PENNSYLVANIA PUBLIC UTILITY
COMMISSION ON NOTICE OF PROPOSED RULEMAKING
IN THE MATTER OF TELECOMMUNICATIONS RELAY
  SERVICES AND SPEECH TO SPEECH SERVICES FOR
INDIVIDUALS WITH HEARING AND SPEECH DISABILITIES.

I.    INTRODUCTION

Pursuant to FCC Notice of Proposed Rulemaking released on May 20,
1998, the Pennsylvania Public Utility Commission (Pa. P.U C.)
submits these comments on the proposed rulemaking in the matter
of Telecommunications Relay Services and Speech to Speech Service
for Individuals With Hearing and Speech Disabilities. The Pa.
P.U.C. incorporates the comments of other parties to this
proceeding to the extent that they are consistent with the
comments and positions of the Pa. P.U.C.

               



             II.   THE PENNSYLVANIA POSITION


    1.  The Pa. P.U.C. supports the continued promotion of access
to Telecommunications Relay Services (TRS) for persons with
hearing and speech disabilities who otherwise would have
difficulty in fully participating in our advancing technology in
telecommunications and information systems. The Pa. P.U.C.
believes that it is important to make telephone calls made to TRS
centers more functionally equivalent to the voice
telecommunications network.

    2.  The PA. P.U.C. supports other equally important
provisions of this proposed rulemaking. It is the opinion of the
Pa. PUC that this rulemaking will generally increase the
effectiveness of TRS and aide in attaining the goals anticipated
by the Americans With Disabilities Act of 1990 (ADA).

    3.   The Pa. P.U.C. is submitting this comment in support of
that view.  The Pa. P.U.C. also plans to file reply comments
addressing these comments and the Pa. PUC position, as well as
the position and comments of other commenting parties in
subsequent filings,

Respectfully submitted,

Wayne T. Scott
Assistant Counsel

Frank Wilmarth
Deputy Chief Counsel

Bohdan R. Pankiw
Chief Counsel

Counsel for Pennsylvania Public Utility
Commission

P.O. Box 3265
Harrisburg, PA 17 105-3265
(717)783-6150

Dated: July 17, 1998