CHIEF OPERATING OFFICER
Tel (518) 474-2547
FOX (518) 473-2827
E-mail rcate@mail nysed.gov
July 15, 1998

Office of the Secretary
Federal Communications Commission
Room 222
1919 M Street, NW
Washington, DC 20554

Dear Secretary:

  Thank you for the opportunity to comment on the June 16, 1998
Federal Register proposed rules regarding Telecommunications
Relay Services and Speech-to-Speech Services for Individuals with
Hearing and Speech Disabilities, 47 CFR Part 64, Docket No.
98-67; FCC 98-90.

  The Federal Communications Commission's proposal to expand and
enhance the quality of the Telecommunications Relay Services
(TRS) is a timely one that will benefit all parties in
New York and other states. The Speech-to-Speech Services being
incorporated into the existing TRS within the two-year time frame
is much needed in this State.

  In reviewing the proposal, there are several areas that are
essential to effective TRS service delivery.

The Multilingual Relay Services should be included in the
regulations and used for major languages that are commonly used,
e.g., Spanish.

New York State is working to enhance the 911 telephone system to
include the direct Telecommunications Device for the
Deaf/TeleTypewriter (TDD/TTY) contact. This should be encouraged
and implemented in a consistent manner.

The 85 percent, l0-second rule needs to be looked at closely.
Will people who are deaf, hard of hearing, and speech impaired,
as well as the general public, perceive the delay as
poor quality of service and lack of interest in providing equal
access to all parties involved? Perhaps the rule should be
comparable to that for telephone operators throughout the nation.

o  The concept of not establishing typing speed makes sense;
however, spelling accuracy is critical and the ability to
translate common typing abbreviations and errors is important to
the success of the TRS.

Richard H. Cate

c: Judy Boley, Federal Communications Commission