Comments of the Northern Virginia Resource Center for Deaf and Hard of Hearing Persons Notice of Proposed Rulemaking on Telecommunications Relay Services CC Docket 98-67 The Northern Virginia Resource Center for Deaf and Hard of Hearing Persons serves the counties of Arlington, Fairfax, Fauquier, Loudoun, and Prince William as well as the cities of Alexandria, Fairfax, Manassas and Manassas Park. Its mission is to serve as a catalyst in the empowerment of people who are deaf and hard of hearing. We are pleased to see attention being given to needs for improvement in the regulations for telecommunications relay services (TRS). However, we are disappointed to see few real improvements are being proposed. Consumers residing in our service area have expressed continuing dissatisfaction with TRS services, and few of their concerns have been addressed by this NPRM. TRS are, in many ways, falling further behind as technology advances, instead of approaching the "functional equivalence" they were created to provide. A. Improved TRS 1. We strongly support applicability to any wire and radio communication services. 2. We strongly support the recovery of costs for improvements and the development of guidelines by NECA. However, it is not clear who will decided what "improved" services can be funded, by what criteria they will be judged, and how funding would be made available. We would like to see a great deal of funding made available to give incentive for TRS to become much more functionally equivalent. 3. We strongly support the amended new definition for Communications Assistant. B. Speech-to-Speech We support the FCC's proposal to make this new relay service mandatory. C. Video Relay Interpreting We support the proposed guidelines A through C. However, we are very disappointed that the FCC did not propose to mandate this service as it has speech-to-speech. Within our service area, there are 170,000 deaf and hard of hearing people. We estimate that 5, or approximately 8,500 of them, could benefit from video relay interpreting (VRI). We believe this is far more than can benefit from speech-to-speech services. Texas has already taken the step of making videophone equipment available through its state equipment distribution program. If such equipment is made readily available and affordable, with smooth transmission, ease of use, and professional interpreters, it would make VRI a very viable option. VRI, especially that with higher transmission speeds and the most recent technology, would be useful to diverse groups, including senior tit-izens who are not comfortable with TTYs, those with disabilities that iimic their ability to type, those with American Sign Language as a native language, those who rely on speech reading skills, or recently or temporarily deafened persons. At our Center, we regularly see people who are uncomfortable or unable to make TTY-to-voice relay calls. Some are senior citizens who never used a telephone while growing up and are not comfortable using today's high tech TTYs. There are many others for whom we have had to intercede on during the past few years when their relay calls were not understood be(.ause their English skills were insufficient. These people were confident in their sign language skills but not in their reading and typing skills. TRS as it exists now is not Serving them well. VRI should be phased in immediately and be supported by TRS 24 hours per day for home use, not just at regional centers. Further, we would like to have the FCC revisit VRI within 18 months as technology for POTS and internet technology improves and becomes widespread. We do not believe that there is a shortage of qualified interpreters for this service, since it can be located where many qualified interpreters are widely available. North Carolina's VRI uses interpreters in Arizona. We also believe that the cost of this service will decline as technology develops and people become more efficient at using VRI. For American Sign Language users, VR1 offers "real time" transmission and reception of conversations, which should cut the amount of time needed per call drastically. D. Multilingual Relay Services We support same language to same language relay services as a recoverable expense, with the states given flexibility to decide when to provide it for languages other than English. We also support American Sign Language to English relay services as recoverable if states choose to provide it. States should also be given the option of providing foreign translation services as a recoverable expense. We support continuing the policy that TRS be verbatim unless the consumer requests translation. E. Access to Emergency Services TRS should be mandated to support 911 calls as a backup and have the capability to provide ANI to 911 centers. The FCC should use the same definition of "emergency" as that used in voice telephone situations. We believe this capacity is necessary. Although our local 911 center is among the exemplary ones, it is not infallible. Two years ago, an employee and a volunteer of our Center, on separate phone lines, failed repeatedly to reach the 911 center by TTY when trying to report a suicide attempt. While the volunteer remained on the TTY line hoping for an answer, the employee was able to reach the 911 center by voice through the relay service. This experience taught us the importance of having such a backup. F. Access to Enhanced Services We strongly disagree with the statement that Congress did not give sufficient jurisdiction under Title IV to mandate TRS access to these services. The Congressional Record of May 17, 1990 (#2434-:400) reports an exchange which clearly shows Congressional intent. Two states, New York and Wisconsin, require the capture of audiotext information. We support this as a standard for TRS. G. Mandatory Minimum Standards We support the uniform measurement of speed-of-answer but strongly disagree with a standard of 852437010f calls answered in 10 seconds or less. Such a lengthy delay is a far cry from "functional equivalence". Experience with TRS also shows that when call setup is not paid for by states, there is no incentive for delays and calls are connected much faster. We support the phase in of a standard that would reduce speed-of-answer time to three seconds or less. We continue to support the phase-in of realtime transmission, where CA typing speeds must continue to rise to the rate of speech. At a minimum, the entry level standard for CAs should be 65 words per minute. Some states are already mandating higher typing speeds, and technology such as Turbo Code can support the higher transmission rates for text. We support a rule to require CAs to stay on a TRS call, and we strongly prefer that the requirement be fifteen minutes. While most calls are less than ten minutes, when a longer call is made, we find it is even more difficult for a new CA to easily enter a conversation without all the background information. The requirement that CAs stay with a call is an important one for consumers. One of our employees has memorized the steps for a voice messaging system that she calls frequently for business reasons. To make the call quickly and effectively, she gives instructions at the beginning for the CA, listing the sequence of numbers to push, etc.. On numerous occasions, after she has typed all this information, a new CA will relieve the one to whom she has been typing. Often the information she has just provided does not transfer to the screen of the new CA in its entirety and she must repeat the instructions all over again. This is very frustrating. We oppose the proposed rule that TRS users not be allowed to request a specific gender during a CA transfer. The same gender should be kept during any transfer unless it is impossible to do so. We are very disappointed that other recent improvements are not addressed for minimum standards. Technology such as two-line VCO, the ability to interrupt, and other features are now becoming commonplace on TTYs. TRS should be able to support these features as they help us approach true "functional equivalence." We strongly support a requirement that there be no "trainee CA" permitted to provide true relay services. No CA should be answering calls who has not been fully trained to meet the minimum standards. H. Competition Issues We strongly support the encouragement of multi--vendoring. The FCC should support consumer choice of TRS provider just & it does local competition through the Telecommunications Act of 1996. We also strongly support consumer involvement in the selection of the relay provider. The FCC has asked whether single providers are linked with poor TRS quality. Since virtually all states up to this point have had single TRS providers and poor quality is quite uniform, it seems clear the two are linked. Further, some vendors are not interested in states with smaller call volume under the current system, and this is not likely to change unless they look at the national consumer market as a whole. We also believe that the FCC should rule strongly against states which require TRS to be provided from a specific in-state L-cation if it will serve as a deterrent to competition. I. TRS Consumer Information We believe the transfer of relay provider information should be seamless, and consumers should not have to set up relay profiles again with a new provider. We agree that the information of relay consumer preferences is proprietary, but believe that it should be viewed as proprietary to the consumer, not the TRS provider. J. Enforcement and Certification We believe the recertification process for TRS should require that each state consult actively with consumer organizations. States should be required to have information on file at all times at the FCC and posted on the FCC website showing the location and address where consumers can file complaints. K. Other Issues Among the issues not addressed are: The need for more outreach on TRS to the general public The need for consumer involvement in certification and monitoring of TRS Services provided to the general public that are not always available to TRS users -- Caller ID, Call conferencing, etc. Thank you for this opportunity to provide comments. We wish the FCC much success in improving the regulations for TRS. Cheryl Heppner, Executive Director Northern Virginia Resource Center for Deaf and Hard of Hearing Persons 10363 Democracy Lane Fairfax, VA 22030 703-352-9057 TTY NVRCheryl@aol.com