Ms. Magalie R. Salas
Secretary
Federal Communications Commission
1919 M Street, N.W., Room 222
Washington, D.C. 20554

Re: In the Matter of Telecommunications Relay Services
and Speech-to-Speech for Individuals with Hearing and
Speech Disabilities, CC Dkt. No. 98-67

Dear Ms. Salas:
Enclosed please find one original and six copies of reply comments filed by the
Council of Organizational Representatives on National
Issues Concerning People who are Deaf and Hard of
Hearing.

Sincerely,

Keith Muller
League for the Hard of Hearing
71 W. 23rd Street, 18th Fl.
New York, NY 10010-4162
(212) 741-7650 (V)
(212) 741-1932(TTY)

Evelyn Cherow
American Speech-Language-Hearing Association
10801 Rockville Pike
Rockville, MD 20852
301 897-5700 (V/TTY)
Co-Chairs, COR

Enclosures
cc: Carmell Weathers, Network Services Division (paper and diskette)

KEITH D. MULLER, CO-CHAIR 
LHH
71 WEST 23RD STREET, 18TH FL. 
NEW YORK, NY 10010-4162
(212) 741-3140 (V/TTY)
(212) 255-4413 (FAX)
E-MAIL: KMULLER@LHH.ORG

EVELYN CHEROW, CO-CHAIR
ASHA
10801 ROCKVILLE PIKE
ROCKVILLE, MD 20852
(301) 897-5700 EXT. 135 (V/TTY)
(301) 897-7354 (FAX)
E-MAIL: ECHEROW@ASHA.ORG

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C.

In the Matter of
Telecommunications Relay Services
and Speech-to-Speech Services for
Individuals with Hearing and Speech
Disabilities CC Docket No. 98-67

REPLY COMMENTS OF
THE COUNCIL OF ORGANIZATIONAL REPRESENTATIVES
ON NATIONAL ISSUES CONCERNING
PEOPLE WHO ARE DEAF OR HARD OF HEARING

Keith D. Muller
League for the Hard of Hearing
71 W. 23rd STREET, 18TH FL. 
NEW YORK, NY 10010-4162
(212) 741-7650 (V)
(212) 741-1932 (TTY)

EVELYN CHEROW, CO-CHAIR
American Speech-Language-Hearing Association
10801 ROCKVILLE PIKE
ROCKVILLE, MD 20852
(301) 897-5700 (V/TTY)


Co-Chairs, COR

September 14,1998
SUMMARY
The Council of Organizational Representatives on National Issues Concerning People who are
Deaf or Hard of Hearing (COR) urges the Federal Communications Commission to revise its
rules on telecommunications relay services in a manner that will ensure high quality services
that are functional equivalent to conventional voice services. To this end, we support the
Commission's decision to permit the recovery of costs associated with speech-to-speech relay
services, video relay interpreting, and multilingual relay services. We applaud the Commission's 
decision to provide speech-to-speech relay services within two years, and request that the FCC
issue a further notice of proposed rulemaking on VRI in order to gather additional information
on the feasibility of requiring this as a national relay service. We alsosupport the FCC's
proposals to require the transfer of information about a caller's ANI to a 911 operator, to
improve its speed of answer rules, to improve its enforcement measures, and to limit in-call CA
replacements.

We urge the Commission to create a national advisory committee for the purpose of conducting
a national discussion on new technologies and TTY protocols, TRS outreach measures, and CA
quality standards. We also urge the Commission to adopt existing technical solutions to capture
information provided on voice menu-driven telephone systems, to impose minimum typing
speed and other improved CA standards, and to permit the information in caller profiles to be
passed on to subsequent state relay providers. The measures that we are now proposing will be
necessary for the industry and consumers to keep abreast of new developments in our
nation's telecommunications infrastructure.


TABLE OF CONTENTS
I. Introduction . . . . . . . . . . . . . . . . 1
II. National Advisory Committee . . . . . . . . 3
III. Improved Relay Services . . . . . . . . . . 4
A. Speech-to-Speech Relay Services ............. 6
B. Video Relay Interpreting .................... 7
C. Multilingual Relay Services and Translation 
Services ....................................... 8
IV. Access to Emergency Services.. . . . . . . . 9
V. Voice-Menu Driven Systems and Other Audiotext 
Services . . . . . . . . . . . . . . . . . ..... 10
VI. Mandatory Minimum Standards . . . . . . . . 12
A. Speed of Answer ............................. 12
B. Communications Assistant Quality and 
Training ....................................... 12
VII. Enforcement and Certification Issues ...... 13
VIII. Other Matters . . . . . . . . . . . . . . 14
A. In Call CA Replacement ...................... 14
B. TRS Caller Profiles ......................... 15
IX. Conclusion . . . . . . . . . . . . . . . . . 15 

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C.
In the Matter of Telecommunications Relay Services and Speech-to-Speech Services for
Individuals with Hearing and Speech Disabilities CC Docket No. 98-67

REPLY COMMENTS OF THE COUNCIL OF ORGANIZATIONAL REPRESENTATIVES
ON NATIONAL ISSUES CONCERNING PEOPLE WHO ARE DEAF OR HARD OF
HEARING

I. Introduction
The Council of Organizational Representatives on National Issues Concerning People who are
Deaf or Hard of Hearing (COR) submits these comments in response to the Federal
Communications Commission's (FCC or Commission) Notice of Proposed Rulemaking
(NPRM) to improve our nation's telecommunications relay services (TRS).(1) COR is a
coalition of national organizations that are committed to improving the lives of individuals who
are deaf or hard of hearing. Constituencies of COR organizations provide a variety of services,
including technological and telecommunications services, educational programs, social and
rehabilitation services, support groups and self-help programs, medical, audiological, and
speech-language pathology assessment and rehabilitation services, information on assistive
devices and technology, and general information on other services for deaf and hard of hearing
consumers.

Among other things, COR serves as a bridge among interested organizations, the general
public, and the community of people with disabilities on matters concerning deaf and hard of
hearing individuals.

COR's members have been active participants in the FCC's prior proceedings on TRS, and
joined together to submit comments in the FCC's most recent Notice of Inquiry on this
subject(2). At that time, COR joined the many organizations and consumers who pointed to the
need for bringing relay services closer to the functionally equivalent standard set by Congress in
Title IV of the Americans with Disabilities Act (ADA). The membership of many of COR's
organizations rely on TRS for basic telephone access - for their employment, their recreation,
their medical needs, or their contacts with family, fiends, and colleagues. While implementation
of nationwide relay services over the past five years has significantly increased the independence
of deaf, hard of hearing, and speech disabled persons - individuals who previously were required
to rely on others to make their calls - it is questionable whether the FCC's relay performance
and technical standards have been sufficient to truly provide telephone services which are
functionally equivalent to the services available to the rest of the population.

Slow and inaccurate typing by communications assistants (CAs), long periods of waiting for
TRS while in queue, and the lack of access to voice menu driven telephone systems have been
among the difficulties that have contributed to inferior relay services. Additionally, although
some of the states have engaged in outreach efforts, any poll of the population at large would
quickly reveal that although relay services have been required for five years (and actually
provided by many states long before that(3)), relay services remain largely unknown to the
general population.

We wish to thank the FCC for issuing this NPRM, and believe that many of the Commission's
proposals will in fact bring about substantial improvements in relay services. But we urge the
FCC to go much further by implementing the proposals which we set forth in these comments.
We believe that the measures that we propose will be necessary to keep abreast of new
developments in our nation's ever-changing telecommunications infrastructure.

II. National Advisory Committee
The various comments to the FCC's NPRM reveal with alarming clarity the number of TRS
issues which still need resolution. A national discussion needs to take place concerning the
consideration and implementation of new technologies and TTY protocols, existing and
proposed outreach measures, and minimum standards for CAs.(4) Consumers have consistently
urged the Commission to establish - whether on a temporary or permanent basis - an advisory
committee that could be dedicated to the review and resolution of these pressing issues. COR
joins the many organizations that again urge the FCC to establish an advisory forum for this
purpose. See e.g., National Association of the Deaf/Consumer Action Network (NAD/CAN)
Comments at 27-28; Telecommunications for the Deaf, Inc. (TDI) Comments at 20. Not only
consumers, but the Commission as well will stand to gain so very much if the knowledge and
experiences to the various state relay programs and the consumers served by those programs are
shared in a national forum.

In this regard, we point the Commission to Congressional guidance on this issue:[Given the
unique and specialized needs of the population that will be utilizing telecommunications relay
services, the FCC should pay particular attention to input from representatives of the hearing
and speech impaired community. It is recommended that this input be obtained in a formal
manner such as through an advisory committee that would represent not only
telecommunications relay service consumers but also carriers and other interested parties.(5)

We urge the Commission to address relay issues on a national basis through the creation of an
advisory committee made up of TRS consumers, and representatives from telecommunications
companies, TRA providers, state regulatory bodies, state TRS advisory bodies, and the FCC.

III. Improved Relay Services
We join the many parties to this proceeding that support the FCC's decision to re-define TRS in
a manner that does not limit these services to voice-TTY communications. See e.g., Self Help
for Hard of Hearing Persons, Inc. (SHHH) comments at 2; Spring Comments at 4; TDI
Comments at 4; NAD/CAN Comments at 3; Ultratec Comments at 4. By defining TRS an "any
wire or radio communication service that enables persons with hearing or speech disabilities to
engage in communications with persons without such disabilities..." NPRM 14, the FCC will
ensure that revisions to our nation's TRS will come about as new telecommunications
technologies are developed and deployed.

Accordingly, we strongly endorse the Commission's proposal to allow the recovery of the costs
associated with providing "improved" relay services, such as speech-to-speech, video relay
interpreting, and multilingual interpreting. We do have some concerns, however, as to how
newer relay services and technologies will be able to achieve "improved TRS" status; under the
FCC's current proposals it is this status which will be necessary to obtain recovery for the costs
of providing such advanced offerings. Indeed, we agree with Sprint that the Commission's
regulation of TRS must "be broad enough to encompass the non-TTY-based service currently
being offered in the market as well as services using even newer and more advanced
technologies that may be deployed in the future." Sprint Comments at 4. Toward this end, we
support the suggestion of the Public Utility Commission of Texas (Texas PUC) for a time limit
on FCC determinations as to whether a service is an "improved: TRS service entitled to TRS
reimbursement. Texas PUC Comments at 3; see also TDI Comments at 4. The Texas PUC
expressed concerns about regulatory delays that will hinder the application of rapidly
evolving technologies which are needed to improve TRS. It has proposed that the Commission
issue determinations on requests for "improved TRS" status within approximately three months.
We agree that a reasonable time limit for this purpose is appropriate. In those instances where
the FCC feels that it cannot unilaterally rule on an "improved TRS" request because of its
impact on the community and /or telecommunications providers, we urge the Commission to set
up a mechanism whereby it can initiate an expedited rulemaking proceeding, within three
months of such a request.

A. Speech-to-Speech Relay Services
COR supports the Commission's proposal to require speech-to-speech relay services (STS)
within two years of its final rule in this proceeding. NPRM 23. Indeed, both consumers and
industry alike have joined in applauding this Commission proposal to expand TRS in a manner
that will more effectively reach individuals with speech disabilities. See e.g., Sprint Comments
at 3; American Speech-Language-Hearing Association (ASHA) Comments at 1; President's
Committee on Employment of People with Disabilities (PCEPD) Comments at 6; GTE
Comments at 3; Ameritech Comments at 3; TDI Comments at 6; NAD/CAN Comments at 4.

 Many of those commenting on the Commission's proposal to mandate STS have pointed to the
need to relax or modify certain of the Commission's existing TRS standards for STS. These
groups have noted the differences in STS relay and most notably have raised concerns about
standards affecting the time permitted for the set-up of STS calls, verbatim relaying
requirements, and confidentiality mandates that may not be appropriate for these calls. See e.g.,
ASHA Comments; Massachusetts Assistive Technology Partnership (MATP) Comments at 2;
Bob Segalman Comments. It would appear from these comments that in fact some of the
existing minimum standards employed for TTY-to-voice relay may need to be modified for STS
to be truly effective. We urge the FCC to thoroughly review the proposals put forth by experts in
this area in an effort to promulgate rules that will be responsive to the special needs of STS
users. Additionally, we urge the promulgation of FCC rules that will require significant
outreach efforts to potential users of STS, as well as rules that will allow the recovery of costs
for such outreach efforts. See United Cerebral Palsy Associations Comments at 2; Bob
Segalman Comments; Report of the Deaf and Disabled Telecommunications Program (DDTP),
attached to the California PUC Comments at 4; PCEPD Comments at 7. 

We oppose, however, any permanent relaxing of rules which affect the quality of STS. We agree
with the proposal set forth in the DDTP Report to allow states to have a six month period of
adjustment, during which time they may fully assess cal volumes and traffic patterns; after that
time, these states should be able to provide STS services which meet the FCC's service quality
standards. We point to the experience of the state of California in this regard: California
conducted two trials of STS before the service was offered on a provisional basis, as is now the
status. No ASA or blockage requirements or strict operator training requirements were
mandated during the trial periods while both the DDTP and the provider collected call statistics
and gained experience with the service. Now that the DDTP is purchasing STS, even on a
provisional basis, under the same contract as our conventional TRS service, identical service
quality standards are in place for both services and the provider is able to meet these standards.
DDTP Comments at 3.

B. Video Relay Interpreting
We also support the FCC's tentative proposal to classify VRI as a relay service, and to permit
reimbursement of VRI costs from intrastate and interstate jurisdictions. NPRM 15. Various
parties to this proceeding and the FCC's NOI proceeding have acknowledged the benefits of VRI
for deaf children and adults whose primary language is American Sign Language, VRI can offer
relay services that are truly functionally equivalent to conventional telephone services. The
NAD/CAN has pointed our that "VRI more closely approximates direct telephone conversation,
in that it allows the parties to a call to witness the expression of emotions, enables interruptions,
permits individuals to use their first language (ASL), and facilitates the completion of calls that
use voice driven menu systems." NAD/CAN Comments at 5; see also TDI Comments at 7;
Northern Virginia Resource Center for Deaf and Hard of Hearing Persons (NVRC) Comments
at 1-2.

COR urges the FCC to issue a further notice of proposed rulemaking to gather additional
information on VRI. Commenters to this proceeding raised a number of matters which need to
be answered to successfully phase in VRI, including questions about the appropriate speed of
VRI transmissions, VRI interpreter qualifications and availability, and appropriate VRI
performance standards.

The answers to these and other questions are needed if the FCC is to effectively implement a
mandate for VRI. In the interim, we strongly urge that where VRI is provided, certain standards
be in place conditioning the recovery of costs for these services. Specifically, we support the
Commission's proposals (1) to apply the U.S. Department of Justice definition of "qualified
interpreter" to VRI, and (2) to apply the FCC's existing TRS rules on confidentiality,
conversation content, and type of call to VRI. C.

Multilingual Relay Services and Translation Services We support the FCC's proposal to classify
multilingual relay services (MRS) as an improved relay service, the costs of which will be
recoverable on an intrastate and interstate basis. NPRM 38. We agree with the Texas Public
Utilities Commission (Texas PUC), the DDTP and NAD/CAN that such services should be
more broadly defined, to include not only same-language MRS, but, foreign language
translation that is disability related. See Texas PUC Comments at 9; NAD/CAN Comments at 9.

 DDTP explains that "[d]eaf people born into Spanish-speaking families do not learn written or
spoken Spanish. They learn ASL as their first language (visual) and English later in school as
their second language (written)...The result is the child speaks a different language than the
parents because the child is deaf." DDTP Comments at 6. In these situations, translation
services should be reimbursable because they would be disability related. In the case of both
same-language MRS and translation MRS, however, we agree with others that each state should
decide for itself whether or not to offer these types of relay services. SHHH Comments at 4;
DDTP Comments at 5; TDI Comments at 9.

ASL translation services, which allow CAs to translate ASL-to the extent it can be
typewritten-to English, has already been provided in many parts of the country, and should
continue to be a reimbursable relay expense.(6)

IV. Access to Emergency Services
We strongly support the Commission's proposal to mandate TRS centers to pass a caller's ANI
to a 911 operator, where the relay call is an emergency. We agree with other parties who have
said that a CA should not take it upon his or herself to determine whether an emergency exists,
however. Bell Atlantic Comments at 5; Southwestern Bell Telephone Company, Pacific Bell and
Nevada Bell Comments at 6. As noted by the Kansas Relay Service, Inc. (KRSI), "[a} TRS
center should not be placed in the position of screening or determining the existence or extent of
a claimed emergency." KRSI Comments at 6. Where a caller makes clear that an emergency
exists or specifically requests 911 services, however, CAs should be required to pass on the ANI
to the 911 dispatcher. In a life and death situation, the speed with which this is performed will
be critical. Thus, the manner in which the ANI is ascertained (i.e., via the network or directly
from the caller) and passed on (i.e. through the network or orally from the CA to the 911
operator) will be critical in terms of properly responding to the emergency. Where technically
feasible, network based solutions would appear to be the most efficient means of acquiring and
passing on this type of information.

V. Voice-Menu Driven Systems and Other Audiotext Services
The vast majority of consumers commenting on the FCC's NPRM expressed frustrations with
the failure of TRS to effectively complete voice menu-driven telephone services. See e.g., MATP
Comments at 4; PCEPD Comments at 9; Maryland Department of Budget and Management
(Maryland Dept.) Comments at 7; Association of Tech Act Projects Comments at 3. As noted by
SHHH, not being able to navigate these services, given their proliferation, "creates significant
barriers to telecommunications for people with hearing loss."

SHHH Comments at 5. Access to these telephone services ar needed for equal employment and
educational opportunities, retrieval of information from various recreation and transportation
facilities, and access to a multitude of governmental services. Thus, SHHH and others are
correct in concluding that access to these interactive services is essential to achieving functional
equivalence.

Several parties to this proceeding have proposed an interim solution which would permit the
recording of messages from voice-menu driven systems. This method, apparently already
employed in some states, uses a digital recording which captures the entire audiotext
message on tape. With the recording, the CA is able to control the speed at which the message is
relayed to the TRS consumer, and can then obtain the prompts needed to call back the audiotext
number. See Texas PUC Comments at 11; DDTP Comments at 8; MATP Comments at 4; Steve
Gregory Comments at 11-12.

Although not fully equivalent to voice access, the above solution of electronically recording
messages contained on menu-driven systems offers an improvement to the virtual lack of access
that now exists with respect to these systems. Because this is technically feasible, and requires
only the minimal expense of purchasing recording equipment, we urge the FCC to issue a rule
requiring thecapturing of audiotext messages in this manner.

The FCC states that it is not authorized to require access to audiotext services. NPRM 45.
However, various commenters to this proceeding have quoted a passage from the legislative
history of the ADA which provides the Commission with the jurisdiction needed to mandate
these services where technologically possible. See e.g., NAD/CAN Comments at 12; TDI
Comments at 11, quoting a colloquy between Congressmen Hoyer and Congressman Luken on
this issue.(7)

Sprint reports that it already provides access to 900 calls at nine of its relay centers, and notes
that the use of these services is growing dramatically. Sprint Comments at 5-6. The fact that the
technology already exists to provide these services provides the Commission with the authority
it needs to mandate the provision of TRS access to 900 telephone services. The absence of such
a mandate comes into conflict with Title IV's directive prohibiting relay providers from "failing
to fulfill the obligations of common carriers by refusing calls"(8) as well as the Commission's
own requirement that TRS be "capable of handling any type of call normally provided by
common carriers."(9) As noted by the NAD and CAN, "the Commission has always required
that carriers bear the burden of proving the infeasibility of handling any type of call. Insofar as
at least some carriers are providing access to pay-per-call services, those that are failing to do so
have an obligation under the Commission's own rules to explain why they are unable to
complete these calls."

NAAD/CAN Comments at 12-13. (emphasis in original).

VI. Mandatory Minimum Standards
A. Speed of Answer
Cor supports the FCC's proposal (1) to require TRS providers to answer 85% of all relay calls
within "10 seconds by a CA prepared to place the TRS call at that time," NPRM 50 (emphasis
in original), and (2) to require that this calculation be performed on a daily basis.

ID. This rule will reduce distortion of the actual TRS blockage rates, and eliminate waiting in
queue for long periods of time. We agree with others, however, that the FCC should continue to
monitor the blockage rates of TRS calls, to determine whether the new calculations are effective
in reducing these rates. See e.g., NAD/CAN Comments ar 15. Many parties to this proceeding
have recommended even shorter speeds of answer. Should the new requirements be insufficient,
we urge the FCC to re-open this issue and reduce even further the permitted speed of answer.
B. Communications Assistant Quality and Training Despite the fact that consumers have
vociferously complained about the quality of TRS and the competency of CAs, the FCC has
decided not to propose a minimum typing speed or any other improved CA standards. Nor does
the Commission propose the adoption of, or cost recovery for, any new TRS technologies, such
as enhanced TTY protocols, new computer software, such as auto-correct, two line VCO,
caller-ID recognition, or the call-release feature. These and other new advancements could
improve considerably thetransmission speed of relay calls, bring these calls closer to the
standard of functional equivalency. As noted by others, TRS is not a new service; the
experiences of over a decade of these services emphatically call out for improved relay
standards.

When the Commission issued its First Report and Order on TRS in 1991, it explained its
reluctance to mandate a minimum typing speed: "[r}ather than articulate a low threshold of
expectations, a safe harbor, we instead expect that TRS providers will deliver the excellent level
of service all telephone consumers demand."(10) It is time now to fulfill that goal. At a
minimum, the Commission should require, on a national level, the highest typing speed
required by any state, and should review that standard on a biennial basis. In addition, we agree
with others that typing qualifications of CAs should be assessed through oral typing tests, rather
than text-to-type, in order to more accurately test relay performance and spelling skills. The
speed at which CAs are able to accurately and effectively type is presently linked to the extent to
which a relay provider can offer functionally equivalent relay services. We are hopeful that new
technologies will do even a better job of achieving real time TRS transmissions in the future.
We urge the Commission not to ignore the existence of these new technologies and to mandate,
or at least permit cost recovery for, the provision of these technologies where they will improve
relay service quality and more closely approximate the functional equivalent standard.

VII. Enforcement and Certification Issues
We support the Commission's decision to require states to notify the Commission about
substantive changes in their TRS programs within sixty days of making those changes. NPRM
75. We strongly support the FCC's proposal to require TRS programs to make available to TRS
users "informational materials on state and Commission complaint procedures sufficient for
users to know the proper procedures for filing complaints." Id. In addition to these measures, we
support the following measures, put forth by the NAD, CAN, and SHHH, to ensure the prompt
and effective enforcement of the FCC's mandates: (1) The FCC should require providers to file
information on their complaint procedures with the FCC; the FCC should then post such
information on its Disabilities Issues Task Force's web site; (2) TRS providers and state
commissions should be required to keep logs of consumer complaints, and should be
required to provide these logs to the Commission upon the Commission's request and at the time
that it seeks recertification; (3) The FCC should adopt specific guidelines for the handling of
relay complaints within the states. Such guidelines should require (1) that a consumer must
receive an acknowledgment that his or her complaint has been received within 15 days after it
has been filed, and (2) that a complaint which remains unresolved after a period of 30 days
(after being filed with the relay provider) must be referred to the appropriate state forum
assigned the responsibility for resolving TRS complaints. SHHH Comments at 11; NAD/CAN
Comments at 23-24.

VII. Other Matters
A. In Call CA Replacement-COR supports the Commission's proposal that CAs stay on a call
for at least ten minutes before an in-call CA transfer may occur. NPRM 62. As noted by the
NAD and CAN, "this rule will eliminate much of the disruption that currently takes place when
CAs change mid-call." Comments of the NAD/CAN at 19. We further urge that if a call is about
to end, CAs should not be permitted to leave a call, even if the ten minute mark has been
exceeded. See e.g., SHHH Comments at 10.

B. TRS Caller Profiles-Consumers unanimously wish to have the information in their caller
profiles passed on to new state relay providers. NVRC Comments at 3; Maryland Dept.
Comments at 10; Texas PUC Comments at 16; USA DeafSports Federation Comments at 5;
NAD/CAN Comments at 21-23. These profiles contain valuable information, including the
caller's carrier of choice, preferred type of call (VCO/HCO), CA gender preference, mode of
introduction, language type (English, ASL, or foreign language), and other relay features. We
urge the Commission to allow states to provide a seamless continuation of TRS when the state
changes relay providers by permitting the transfer of these caller profiles.

IX. Conclusion
COR wishes to thank the Commission for the opportunity to submit these comments. COR urges
the Commission to adopt the suggestions set forth in these comments so that our nation's relay
services can truly be functionally equivalent to voice telephone services.

Respectfully submitted,

Keith Muller
League for the Hard of Hearing
71 W. 23rd Street, 18th Fl.
New York, NY 10010-4162
(212) 741-7650 (V)
(212) 741-1932(TTY)

Evelyn Cherow
American Speech-Language-Hearing Association
10801 Rockville Pike
Rockville, MD 20852
301 897-5700 (V/TTY)

Co-Chairs, COR 

September 14, 1998
1.  The following members of COR support these comment: American Academy of Audiology,
American Academy of Otolaryngology-Head and Neck Surgery, American Society for Deaf
Children, American Speech-Language-Hearing Association, Conference of American
Instructors for the Deaf, League for the Hard of Hearing, National Association of the Deaf,
Registry of Interpreters for the Deaf, Self Help for Hard of Hearing People, Inc., and
Telecommunications for the Deaf, Inc. 

2.  Telecommunications Relay Services, the Americans with Disabilities Act of 1990, and the
Telecommunications Act of 1996, Notice of Inquiry, CC Dkt. No. 90-571, 12 FCC Rcd 1152
(1997).

3.  See National Association of the Deaf and Consumer Action Network Comments at 16, n.22,
citing to the Summary of State Dual Party Relay Services (National Center for Law and
Deafness, July 1989), which noted that the first state relay program began in 1987,
and that sixteen additional states had state relay programs before the introduction of the ADA.

4.  The FCC has tentatively declined to propose a minimum typing speed for CAs. It is nor
clear, however, whether, before taking this action, the FCC took into consideration the varying
typing speeds required across the United States. Complete information on this matter is needed
to make a sound judgment about the need for a national standard. The same can be said about
the speed of answer requirements, which similarly vary from state to state.

5.  S. Rep. No. 116, 101st Cong., 1st Sess. 79 at 81 (1989).

6.  The NAD and CAN note that the FCC's rules already permit this type of translation service,
and that one relay provider regularly offers this type of service to its customers in their caller
profiles. NAD/CAN Comments at 9-10, citing to MCI Relayer (Summer 1997).

7.  136 Cong. Rec. H2434 (May 19, 1990).

8.  47 U.S.C.  225(d)(1)(E).

9.  47 C.F.R. 64.604(a)(3).

10.  In the Matter of Telecommunications Services for Individuals with Hearing and Speech
Disabilities and the Americans with Disabilities Act of 1990, Report and Order and Request for
Comments, CC Dkt. No. 90-571, FCC 90-376 (July 26, 1991) 9.