National Catholic Office for the Deaf
7202 Buchanan Street
Landover Hills, MD 20784-2236
301-577-1684 V/TTY
301-577-4184 TTY
301-577-1690 FAX

July 20, 1998                   

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

Dear Commission Members:

Re: WT Docket No 98-87, Notice of Proposed Rule Making on
     Telecommunications Relay Services

I am writing in regard to the proposed rule making on
Telecommunications Relay Services. I am a Deaf consumer of
services and the Executive Director of the National Catholic
Office for the Deaf (NCOD). Equitable access is very important
to my ability to perform the duties of my position effectively
and efficiently.  In addition to me, one staff member is Deaf and
one is Hard of Hearing. We are pleased to see proposals which
clearly benefit hearing and speech-disabled Americans' access to
advanced telecommunications services such as:

--To allow the costs of providing interstate "improved" relay
services to be reimbursed from the interstate Telecommunications
Relay System (TRS) Fund.

--To require common carriers providing voice transmission
services to provide Speech to Speech (STS) services to users with
speech disabilities throughout their service areas within 2 years
after formal adoption of the rule.

--To strengthen speed-of-answer requirements for TRS providers so
85% of all calls are answered within 10 seconds by a
Communication Assistant prepared to place the TRS call at that
time.

However, I believe it is in the best interest of Deaf and Hard of
Hearing citizens, as well as hearing citizens whom we communicate
with, to also provide TRS access to audiotext and pay-per-call
services.  These services are increasingly used by businesses in
the United States, presenting substantial barriers to TRS
users such as my staff and myself.

Thank you very much for considering my concerns listed above and
hopefully incorporating them to strengthen the rules. This would
truly make a difference in the way Deaf, Hard of Hearing and
hearing citizens use TRS.

Sincerely,

FkOfficio Member

Arvilla Rank
Executive Director

Enclosure (5 copies)

CC Karen Strauss

A Pastoral Service with Persons who are Deaf or Hard of Hearing