Reply Comments about Speech-to-Speech from :
Bob Segalman, Ph. D.
Founder of Speech-to-Speech

About 80% of comments to the FCC on Speech-to-Speech (STS) were
positive. Most commenters favored all carriers providing service
within two years.

I will respond to the negative comments that were filed about STS
in response to the NPRM Proceeding 98-67. To the best of my
knowledge, I speak for the majority of consumers. A great
proportion of consumers will be unable to file reply comments
because of the severity of their disability. Like many consumers,
I have profound cerebral palsy.

1. Comments to the FCC from several vendors outside the speech
disabled community reveal that they have not been informed of the
necessity of providing adequate STS outreach. For STS to be a
viable service, vendors or state contract administrators in each
state must insure that there is sufficient outreach to develop an
adequate user base.

Currently, several states provide STS without sufficient
outreach, and the call volume is extremely low in those states.
This speech disabled community is unable to use STS without
extensive outreach. The very successful California outreach plan
is in the public domain. Write to me at bob. segalman@ worldnet.
att. net if you want a copy.

Unlike the deaf community (that had TTYs long before they
had relay), people with speech disabilities did not used the
telephone prior to the availability of STS; thus, they don't have
an inherent grasp of how useful the telephone and STS can be to
them. Outreach staff must teach consumers to use STS one by one.
Staff must also teach consumers to overcome the practical,
social, and psychological barriers to using it. California did
this successfully as demonstrated by its outbound call volume of
4,000 calls a month.

Examples of States with inadequate outreach:
Bell Atlantic questions if Speech-to-Speech should be a
mandatory service because of the low STS call volume in Maryland.
One primary reason for the low call volume in Maryland (compared
with the high call volume in California) is the lack of an
extensive Speech-to-Speech outreach program in Maryland.
On the contrary, the Maryland Department of Budget and
Management which monitors Speech-to-Speech in Maryland favors
providing Speech-to-Speech throughout the US, despite the low
call volumes in Maryland. Clearly Maryland's call volume problem
can be solved with a $100k annual investment in outreach
activity.

AT& T had concerns about making STS mandatory because of
the low call volume of its Speech-to-Speech program in Georgia.
Again, Georgia lacks an outreach program specific to the STS
community. If such an outreach is established, call volumes
could greatly increase. California has an extensive
Speech-to-Speech Outreach program and consumers make about 4,000
outbound Speech-to-Speech calls a month. California's outreach
program for the first year cost only $160,000 and was well worth
the money.

2. "Confidentiality" must be defined differently for STS than for
TTY relay. MCI's request that confidentiality should be defined
for STS as it is for TTY relay is inappropriate given the nature
of the speech disabled population. For STS to work effectively,
the following (A through E below) differences from TTY relay's
definition of confidentiality must be employed. This list of five
differences come from the California Relay Service contract
section on STS:

I suggest that Section 64.604 is further revised to read as
follows:

"° 64.604. Mandatory minimum standards.
(a) Operational standards -
(1) * * *
(2) Confidentiality and conversation content. Except as
authorized by section 705 of the Communications Act, 47 U. S. C.
605, CAs are prohibited from disclosing the content of any
relayed conversation regardless of content and from keeping
records of the content of any conversation beyond the duration of
a call, even if to do so would be inconsistent with state or
local law. FOR STS THE WORD "CALL" APPLIES TO AN INCOMING CALL.
CAs are prohibited from intentionally altering a relayed
conversation and, to the extent that it is not inconsistent with
federal, state, or local law regarding use of telephone company
facilities for illegal purposes, must relay all conversation
verbatim unless the user specifically requests summarization. In
the event a CA encounters a automated voice-menu or audiotext
system during a relay call, and the CA cannot relay the call and
interact with the automated system simultaneously in a
functionally equivalent manner, the CA is allowed to alert the
TRS user that an automated system is present and inquire whether
the user wants the CA to summarize the message or listen for a
specific message.

"To be more specific:
A. While CAs may not counsel, advise, or interject personal
opinions into a conversation, they may ask questions to
clarify what was said particularly if the meaning or context is
unclear. (" Apple" differs from "ample", "articulate" differs
from "article", "interest" differs from "inter-test", "pants"
differs from "Lance".) Never guess what somebody says!

B. CAs may interact with users having a problem using
the service and to reassure new users. CAs may reassure users
that the user was understood.

C. CAs also may interact with users to help the user use
the service more effectively. This is particularly necessary in
helping developmentally delayed users with short-term memory 
loss. For example, they may correct a telephone number that the
user receives from one caller and then repeats in error to the
agent in requesting another call. CAs must never attempt to
assist users in ways that could interfere with the user's
independence. The above directions may appear self-contradictory
but are not in light of the wide variance in intellectual
capacity within this user group. An opportunity for a CA to
facilitate communication takes priority over transparency.
However, the agent must not facilitate if there is a great risk
of diminishing communication.

D. Given the limited telephone experience and delayed
social development of some users, CAs will prompt users leaving
messages on answering machines who forget to leave their name
and/ or telephone number.

E. CAs will avoid informality interpretable by users as
patronizing. Adult users must always be treated as mature adults
regardless of their behavior."*

*Paragraph A through E come from the California Relay
Service contract between the California Public Utilities
Commission and MCI.

3. The United Cerebral Palsy Association submitted one comment as
a national organization rather than asking local units and
consumers to reply. Please understand that that one comment
represents the support of Speech-to-Speech by thousands of
consumers, many of whom have disabilities which make them unable
to prepare their own comments.

4. Emergency services for people with moderate speech
disabilities need to be provided through Speech-to-Speech. People
with speech disabilities cannot be understood by regular 911
operators and it is not cost effective to train all 911 operators
on how to answer calls from people with speech disabilities given
the small number of 911 calls to be made by people with speech
disabilities.

5. STS can be offered cost effectively even in very small states
in a way that would eliminate the Idaho PUC's fiscal concern
about low call volume.  I agree that Idaho should subcontract
with an STS provider in a larger state to provide Idaho with
Speech-to-Speech in a cost effective manner. This would eliminate
concerns abou CA wages and efficiency. For this reason, I agree
with Bell Atlantic that regional STS centers would make STS more
effective.

6. SHHH is correct that Speech-to-Speech may be very useful to
some people with hearing loss.

7. STS needs to have the same answer time requirements as other
relay services. In California, full-time STS service began with
no penalty for the vendor not providing prompt answer time.
During those periods when the answer was slow (up to 10 minutes),
consumers sometimes refused to use STS. 

This slow answer time occurred during a trial service
when no answer time requirements were in effect for the provider.
Now that the California provider is required to meet the same
answer time and blockage rate requirements as for regular CRS,
those requirements are being met. It is therefore, possible for
a provider to meet such requirements for STS.

Thus, United Cerebral Palsy is correct when they say:
"We believe there is no reason to relax the speed of answer
time."

While MCI has bottom line concerns for not wanting
mandated answer time requirements, STS cannot survive without
answer time requirements that are the same as the TTY relay.

8. I oppose Ameritech's request that:
"..., the Commission should not adopt its rule requiring
communications assistants not to take on new TRS calls
within their last ten minutes before leaving work, which
would hamper the scheduling process at TRS centers. At
the very least, the Commission should cut the ten-minute
period to five minutes."

Ameritech needs to build the scheduling cost into their
bid. Ameritch could bid differently for TTY relay and
Speech-to-Speech. My reasoning is that because the psychological
effect of changing CAs during a call is often disruptive to
people with speech disabilities, minimum time-on-call shall be
established to which CAs shall be required to conform. In the
initial stages of a call, there is a settling-in time whereby the
caller and the CA get accustomed to each other. During this time
the caller with the speech disability develops the assurance that
the CA will understand him/ her. Rotation of a CA during a call
disrupts this assurance and the speech disabled consumer's
confidence, and may actually cause the user to speak less
clearly.

9. Relaxing the 30 second answer time requirement makes sense.
United Cerebral Palsy is correct that:

"While the length of time that elapses from the time the
communications assistant (CA) answers the inbound call
and when the outbound call begins may be prolonged
because of speaking time, I recommend that quality
control standards, such as speed in answering calls
should be the same as for TTY relay."

10. Southwestern Bell and the Kansas Relay Service both expect
difficulty serving people with very severe speech disabilities.
Yet serving such people is not an issue as STS is not designed
to serve people with very severe speech disabilities.

STS is designed only for use by people with speech
understandable to a patient person with excellent hearing. In 
California, that now includes a user base of estimated at about
150 people. Users determine themselves, by experience, whether
they talk well enough to use STS. If they can make themselves
understand to the CA's, then they use STS; if they can not make
themselves understood, then they stop using STS after a few
calls, as the process becomes too frustrating.

Southwestern Bell does not want STS to be mandatory because it
thinks that CA's might be difficult to find and train.  SBC has
never identified or trained potential CAs, I have! I had no
difficulty finding and training CAs. I guided both Sprint
and MCI in identifying potential STS CAs from among the TTY CA's
in their employ at the time. We simply picked the most patient
CAs with the best hearing and gave them each 1-2 days training.
The majority of them do a fine job.

SBC notes the difficulty in finding instructors for STS
CAs. Yet the detailed curriculum that I used to train many
current CAs is in the public domain. MCI and Sprint probably
still use it. Any trainer of TTY relay CA's should be able to
train STS CAs after reading my curriculum.

SBC expects difficulty in finding STS instructors for
every relay center. Yet STS will probably be offered from only 3
or 4 centers nationally -so one or two instructors could serve
the whole country. Thus, difficulty finding and training CAs is
not a reason to avoid making STS mandatory in two years.

11. The cost of STS is reasonable. Sprint is, in fact,
providing it in Maryland at the same per minute cost as regular
relay.

GTE also discusses cost: "GTE is concerned, however, that,
in Hawaii, it will be required to implement an STS capability
before adequate funding is available. For this reason, GTE asks
the Commission to rule either (1) that states may set the
implementation schedule for STS based on their ability to provide
funding; or (2) that TRS providers in a state need not provide
STS until adequate funding is available from the state."

In evaluating GTE's funding funding (see above), the FCC
should note that people with speech disabilities do not have the
political power to assure quick and adequate funding. So if the
FCC allows vendors to wait for state funding, then STS may never
become a reality in many states.

Yet cost should not be an issue as the cost of STS is
very low. In California, STS costs about $0.6m a year, compared
with TTY relay which costs about $20m a year. With that low
cost, it does not appear ethical to make users wait more than two
years for service.

12. The comments of the Kansas Relay Service, Inc. state that
they have no experience handling STS calls. This explains why
KRSI does not understand that STS is designed only for use by
people with speech understandable to a patient person with
excellent hearing. Because of that misunderstanding, 
inappropriately discusses providing STS to people with very
severe speech disabilities. KRSI questions the FCC's
recommendations for STS based on their misunderstanding of the
function of STS.

Also because of that misunderstanding, KRSI recommends extensive
"individual service" not now being offered by any STS vendor.
Such service would be impractical and very expensive to provide.

KRSI asks that the FCC not require STS to be offered only on a
regional or national basis. Yet, it would not appear cost
effective for a single state to offer Speech-to-Speech.
California probably will always have the largest user base.
Currently, California has an estimated 150 users. For such a
small user base, regional and national providers appear more
practical.

-Bob Segalman, PhD
Founder of Speech-to-Speech 6