COMMENTS ON THE STS NOTICE OF PROPOSED RULE XAKING -  Revised
7/5/98

(PLEASE ACCEPT THE FOLLOWING LATE COMMENTS. WHEN THEY WERE
SUBMITTED PREVIOUSLY--AND ON TIME--THE SYSTEM REJECTED THEM AND
RETURNED THEM TO ME WHILE I WAS ON VACATION.   THANK YOU.  
7/25/98

I am making these comments as an occasional user of
Speech-to-Speech (STS)  I have used it to communicate with a
speech disabled friend, as well as with my own mother when I was
myself temporarily speech disabled.   The service is invaluable.

REGULATORY ISSUES - GENERAL

1. Many consumers and potential consumers will be unable to
respond to this Notice of Proposed Rulemaking  INPRM) because of
the nature of their multiple disabilities.   Please do not take
the lack of response as a lack of interest.

2. Text Telephones (TTYs) have been the standard technology for
improving communication for the deaf,  formerly the only
community recognized as needing assistance in telephone
communication.  It is important to recognize that there are other
speech disabled people for whom TTY service is not applicable.  
For these people, STS is (or could become) an essential
technology. STS should be required nationally even though it does
not util:ze the standard technology, TTYs. I support the
California Public Utilities Commission (CPUC) position that the
specific reference to TTYs in the Americans with Disabilities Act
(ADA) ) "...is meant to illustrate the type of technology that
might be used, not to preclude the use of other technologies."

  Title IV of the ADA is applicable to any wire or radio
communication service that enables persons with hearing or
speech disabilities to engage in communication with persons
without such disabilities and is not limited to services using
TTYs.

3.  Regarding the specifics of how STS should most effectively be
implemented I refer you to the communication you have received
from Bob Segalman in this regard.   I hope you will study it with
care and come to the same conclusion that I have: that STS should 
be implemented nationwide so that the speech disabled of this
country can live their lives with greater ease and hope to
conduct their lives and business with the same advantages that
enjoyed by those who are not speech disabled.  That is,  after
all, the intent of the ADA.

Sincerely,
Augusta Goldstein

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