Advocates for Deaf People Urge Stronger Speech-to-Speech Rules

The FCC should require STS communications assistants to stay on a call at least 20 minutes before transferring the call to another assistant, the National Association of the Deaf and other interest groups said in joint comments. The current minimum is 15 minutes. “For individuals who use STS regularly, the period to adjust to and develop an effective communication with a new CA can very often take over 10 minutes,” the consumer groups said. The 20 minutes should start “when the CA can understand the user sufficiently,” they said.

TRS provider GoAmerica said it “cannot support lengthening the required time … to 20 minutes, nor does it support pegging the time when the CA may switch to when ‘effective communication’ is established.” The FCC should keep the 15-minute minimum, and start it when the assistant enters the call, it said. “Just as STS calls may require extensive concentration on the part of the consumer, they require extensive concentration on the CA’s part,” it said. The commission shouldn’t require assistants “to stay with calls for a very long time, even as long as 40 minutes to an hour,” it said. “That is simply unfair to the CA who may need a break or whose shift has ended.”

Siding with the consumer groups, AT&T supported a 20- minute limit. But it said the clock should start when the person called answers. Sprint Nextel said a minimum isn’t needed, since its assistants “do not watch the clock and will more often than not” stay on calls longer than 15 minutes. But it said the “only objective standard” for starting the clock is “when the call reaches the CA and the caller begins to provide call set-up information.”

The FCC should improve 711 dialing for STS users, the consumer groups said. Commission rules require 711 dialing access for STS, but compliance “is spotty at best,” they said. The groups suggested a requirement that prerecorded 711 greetings provide STS users with an “easy” menu option, allowing them to punch just one more button for access to STS services. “Some STS users have cognitive problems and cannot activate a 10 digit number while others have limited dexterity and difficulty dialing,” the groups said.

GoAmerica and AT&T disagreed. “STS calls represent less than one percent of 711 calls,” so requiring a menu option at the start of every call “would impose an undue burden on the 99 percent of non-STS calls reaching 711,” GoAmerica said. Instead, the FCC should require a single nationwide toll-free number per STS provider, allowing immediate access to an STS communications assistant, it said. The commission shouldn’t require a specific technical solution to the 711 problem, AT&T said. That could “deter innovation,” it said. The FCC should “allow TRS providers to use any type of automation or process … that enables a STS user to reach a [communications assistant] with the least amount of effort.”

Other technical rules urged by consumer groups, on voice muting and confidentiality, prompted less disagreement. The FCC should require STS providers to give users the option of voice muting so the other caller hears only the communications assistant, the groups said. “This practice would encourage many more people with speech disabilities to use STS … as some potential users may be embarrassed by how their speech sounds,” they said. The commission should require STS providers to ask all users whether they have used STS relay and if not explain to them the assistant’s confidentiality requirements, they said. Also, rules should ban assistants from taking notes or otherwise keeping information about a call unless the service user consents, they said.

All commenters agreed with the FCC’s tentative conclusion that Internet-based STS should be declared a telecom relay service eligible for Interstate TRS Fund support. “IP STS is plainly TRS, merely provided … through a different process than the PSTN,” GoAmerica said. Consumer groups said all calls should be compensated from the interstate TRS fund, because it’s “impossible” to tell interstate STS calls from intrastate ones. But TRS providers and consumer groups split on how much money IP STS should receive. Internet calls should get the same funding as existing STS calls, GoAmerica said, agreeing with the FCC’s tentative conclusion. “At this point it appears the cost of IP STS calls will largely track those of STS calls.” But consumer groups said that would work only if “additional and adequate outreach funds are provided.”

More consumer outreach is needed, consumer groups said. STS efforts “have not been adequate to identify and reach potential STS users,” they said. The FCC should require states to promote STS, they said. And the commission should set both intrastate and interstate rates “high enough to provide the necessary funds for STS providers to engage in outreach and education,” they said. To help with consumer training, the FCC “should require that, where needed, home visits be made by qualified language pathologists,” they said.

The FCC has no power to require states to increase rates for intrastate STS calls, Sprint said. “Outreach efforts to promote increased use of intrastate STS services are the responsibility of each state and there is no justification for the Commission to usurp state jurisdiction.” The commission’s power “would appear to be limited to approving or disapproving state TRS programs,” GoAmerica agreed. But the FCC should maintain federal outreach funding for STS and extend it to IP STS, it said.

Debate also stirred on an FCC question on whether it should require a single, nationwide STS provider, because of low usage of STS. GoAmerica opposed the idea. “Competition serves to improve service and innovation to the public,” and having multiple providers improves service availability and reliability, the TRS provider said. IP STS “should be administered nationwide” like other Internet-based telecom relay services, the consumer groups said. The market would determine the number of providers, they said. The American Association of People with Disabilities also supported nationwide STS but said it’s “uncomfortable … with any approach that would take away” from states’ oversight obligations.