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

As a user of Speech-to-Speech (STS) I would like to make the following
comments.

REGULATORY ISSUES - GENERAL

It will be difficult for many consumers and potential consumers to
respond to this Notice of Proposed Rulemaking (NPRM) because of
the nature of their multiple disabilities. Please understand that the
leve of responses you receive may be lower than the actual hlevel of
interest.
I support the Federal Communications Commission's (FCC)
tentative conclusion that STS be required nationally;
cost should not prevent establishment of a national requirement.
STS is a relatively inexpensive service.
(The cost of Speech-to-Speech plus outreach
for California for 1997 was less than $1m.)
The state administrators who questioned making STS a national
requirement because of unknown costs may have not been aware of
the California costs at the time. (See NPRM paragraph 24).
I support the FCC's tentative conclusion that the costs of
providing interstate STS should be reimbursed from the interstate
Telecommunications Relay Service (TRS) Fund. This conclusion is
based on, and consistent with, the statutory duty not to
discourage the implementation of improved TRS.
While STS may have operational differences that make compliance
with certain Commission standards for tty relay infeasible,
I recommend that a panel of consumers and providers be convened to
determine the appropriateness of compliance with each standard.
For instance, the STS standards should deviate from those of TRS in the
definition of confidentiality. While general confidentiality is
vital, confidentiality should not be defined as specifically for
STS as for TTY relay.
REGULATORY ISSUES - QUALITY OF SERVICE
Competition will encourage provision of quality
Speech-to-Speech service. (It is important to keep in mind that this
population is less able to advocate for quality of service as is the deaf
TRS community.)
STS vendor's should be required to provide consistent, reliable,
high-quality
connections, adequate volume, voice transmission, and all other elements
of telephonic telecommunications which able-bodied users enjoy with
standard telephone communication systems.
Users should not have to endure noticeable volume changes during a call,
echoes, unwanted disconnects, problems reaching
800#s, etc. Vendors must provide a consistently high quality of
software, hardware, and other communications devices including
lines, connection between lines, area codes, etc.
Vendors should also provide the state with monthly STS-call volume
data consistent with data collection criteria outlined by FCC.
All services and practices offered TTY relay users and their
callers will be offered Speech-to-Speech users and their callers
in a manner appropriate to their use.
TRS quality control standards, such as speed of answer,
should apply to Speech-to-Speech.
While the delay between when the communications assistant (CA)
answers the inbound call and when the outbound call begins may be
longer because of speaking time, the
required response time for inbound calls should not be relaxed. This
should be made equal to that for TTY relay.
Other examples include:
Speech-to-Speech must be available 24 hours a day, seven days a week, year
round.
Speech-to-Speech must include directory assistance, since 411 operators
often hang up on people with speech disabilities when the person is not
easily understood. In addition, many people with speech mpairmants >
cannot use the 411 services provided for the deaf because they cannot type.
REGULATORY ISSUES: PRACTICES OF COMMUNICATIONS ASSISTANTS
CAs should never revoice what the speech disabled caller says
based on a guesswork, but should request clarification when he/she
is unsure if they have properly comprehended what the consumer has
voiced.
If a line is busy, the CA should immediately repeat aloud the
number dialed to verify that the CA understood the number
correctly.
One available option should be that users themselves may leave answering
machine messages in which
the called party hears the user's voice and the CA re-voicing for
the consumer. Alternatively, the consumer may choose to ask the CA to
voice their message exactly as the consumer dictates the message to the CA,
i.e.: "This is a message for Jim Smith from John Doe. Please
call Mr. Doe after 7 p.m. at 444-5555."
After each call, CAs should offer to make another call for the
consumer.
While CAs should 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.
It should be permissible for CAs to interact with users who may
Experience difficulty using the service to provide reassurance. CAs may
reassure
users that the CA has comprehended the consumer's speech, if necessary.
It will also be important at times for the CAs to interact with consumers
to help the consumer use
the service more effectively. This is particularly necessary
when working with developmentally-delayed users with short-term
memory loss. (For example, a CA may correct a telephone number
that the user received from a caller but repeats in error, upon
their attempt to call the number that they were given in a previous
call.) However, CAs must never attempt to assist users in ways
that could interfere with the user's independence. (This recommendation
may appear self-contradictory, but is not in light of the
wide variance in intellectual capacity within this user group.)
In a word, an opportunity for a CA to facilitate communication should
Take priority over transparency. However, the CA should not facilitate
if there is a great risk of diminishing communication.
Before dialing, the CA should offer to tell the call's recipient who is
calling.
At the start of the call, the CA should announce that he/she
will voice for the speech disabled person throughout the call
unless either party asks, and both parties agree, that CA should
not revoice (except if the caller is profiled for voicing only
when his/her caller doesn't understand.)
Prior to a call, a user should be able to ask the CA to write down
Information that may be given during the ensuing call, for use during
consecutive
calls.
Consumers should be able to ask the CA to assist the consumer to record
An outgoing message (OGM) on consumer's voice mail or answering machine. In
such a case, the consumer will dictate the desired OGM to the CA, and
will give the CA any
directions the CA may need to activate the voice mail or answering
machine OGM recording mechanism.
If the CA must talk to several people at the number called, in order to
reach the desired party, the explanation of Speech-to-Speech need only be
given to the desired party, unless the user specifies otherwise.
REGULATORY ISSUES: SERVICES THAT DIFFER FROM TTY RELAY
Because there are relatively few STS consumers in each jurisdiction,
it would not be efficient for local jurisdictions to train emergency
personnel (such as 911 phone staff) to handle emergency calls for
these consumers with speech disabilities. Such calls should be
made through STS. Under these circumstances, TRS centers should be
required under the Commission's rules to convey a caller's ALI Automatic
number
identification) to emergency services phone personnel. (Current TRS
confidentiality
rules prohibit a CA from revealing a consumer's ALI without the
consumer's prior consent.)
FCC regulations should enable consumers to have STS
retain messages for 24 hours, during which time the consumer may
call back STS and attempt again to reach an answering machine.
Typically, the consumer will inform the CA that he/she wishes to leave a
message on an answering machine and that they prefer to dictate
the message to the CA before the CA dials the number. If the number is
busy, the CAs should offer to retain the message, so that the customer
may call later to leave the message when the answering machine is free.
It may take a long time before the answering machine line
is free. Currently, the only way a consumer can avoid
redictating the message is to stay on the line with the CA and
have her/him keep redialing the number. This policy places an
onerous burden on the consumer with a speech disability for whom
the process of dictating a message may take an extremely long
time. Many consumers do not possess the manual dexterity to
record the message themselves. (Under present rules, the consumer
must call back STS and revoice the message as many times as it
takes until the CA reaches the other number.)
Speech-to-Speech needs to have its own separate 800 number
(separate from the TTY relay number). Only one Speech-to-Speech
number is necessary for each state. Eventually, there should be
one national Speech-to-Speech number.
User assistance (such as STS customer service staff and
complaint resolution personnel) must have the resources necessary
to provide services to Speech-to-Speech users (by voice) of the
same quality available to other users. Customer service staff
should have comprehensive training and knowledge and access to
written policy and procedure manuals employed by STS staff.
Vendors should call each user annually to confirm the accuracy
of the user's profile.
Users should be able to register their home and business telephone
Numbers in their personal Speech-to-Speech profile and indicate what
time and where they can be reached. This will allow speech-able
users to request the speech disabled person by name rather than
by telephone number. This service is provided because many speech
disabled people have trouble saying numbers. Requiring STS consuimers to
give their telephone callers both an 800 number and their own
telephone number would discourage telephone use.
Many people with speech disabilities have memory problems and
many also find it easier to say one number over again than to say
different numbers. Therefore, the 800 number chosen for
Speech-to-Speech should have as many of the same numbers as
possible.
Users should not be required to give the area code for local
calls, since the user's area code will be displayed on the provider
automatic number indication (AMI) equipment. (This will decrease
the speaking requirements for users with speech disabilities.)
CAs must be able to turn up the volume on their console
because some people with speech disabilities either have a
hearing loss. The volume control on the console should be able to
independently increase the volume of the CA and both callers.
If all Speech-to-Speech CAs are engaged in other calls, the
user should hear a recording directing them to wait on the STS
line.
Speech-to-Speech users should be able to make regular relay calls to TTY,
VCO, HCO users through Speech-to-Speech.
Users should be allowed to submit to the STS vendor (by
telephone or other means) lists of names and
telephone numbers of people that they call regularly. Each entry
will be comprised of a name and telephone number which CAs will
employ after accessing the consumer's personal list. In effect,
this list of names and telephone numbers will be a mini-database
unique to each consumer. These lists are necessary because CAs
may have difficulty understanding the name and telephone number
of the person that the speech disabled customer is calling;
(unlike other utterances, this information has no context.)
The vendor should demonstrate adequate knowledge of and
involvement with the speech disabled community to provide a
service which meets the needs of that community. These methods
can include, but are not limited to, employing an STS Program
Manager who has a speech disability; or employing a speech
disabled consultant who spends regularly scheduled time at the relay
assisting the STS program.
An open line with no switching must be provided so that the
CA, the speech disabled caller and the speech-able caller can all
hear each other at all times. The outcome would be similar to
that observed in three way calling.
Speech-to-Speech users should have the option of asking
for people with speech disabilities by name rather than by
telephone number. The consumer must first established his/her
personal profile (ie: database, Hofmann list).
Vendor must provide a database that is adequate to
provide useful consumer profiles.
Consumers should be informed that their call may be monitored.
OTHER ISSUES
COMMUNICATIONS ASSISTANTS: TRAINING, SELECTION, RETENTION, AND WORK
ENVIRONMENT
Vendor should be required to provide monthly or bi-monthly
communication sessions between STS CA staff and management whereby CA
staff may freely make suggestions for improvement of service, policies that
are
more user-friendly, and the like, as well as a
forum for venting frustrations.
These forums will also provide a venue for CAs to share
techniques and methodology that they may have developed to assist
comprehension or other skills required to work with consumers
whose speech or cognitive functions are particularly challenging
to the CA. Consumer's privacy shall be protected at all times,
but identifying information may be shared among CAs, in a private
and confidential area, so that CAs will be able to identify the
consumer for whom the special techniques/method of working with
the consumer has been developed.
All CAs and supervisors who take STS calls should thoroughly
understand and respect the Speech-to-Speech protocols,
requirements, and philosophy.
Counseling personnel, employed by the vendor to assist CAs
with job stress, should learn the values of the Speech-to- Speech
Service before counseling Speech-to-Speech CA staff.
The CAs' work area should be quiet and the partitions between
the CA work stations should be sound proof enough so that CAs can
concentrate intensely on hearing the caller's speech.
(CAs need much more sound proof cubes than used for TTY relay.
Calls may lack confidentiality if it is difficult for a CA to
voice an STS call over ambient noise.)
The vendor should develop a small bank of CAs for the service. This
bank must be large enough to handle the traffic but small enough
so that CAs become accustomed to most of the users' speech
patterns.
Because the psychological effect of changing operators during
a call is often disruptive to people with speech disabilities,
minimum time-on-call shall be established to which CAs should 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.
The CA should only be changed if an outbound call (the
call placed by the CA on behalf of the consumer) lasts more than
five minutes. The CA should then not be changed again unless the
inbound call (a call initiated by the person with a speech
disability to the Speech-to-Speech relay service) lasts more
than 30 minutes.
A change of CA is rarely necessary during Speech-to-Speech
calls as repetitive motion injury is not an issue as it is with
the TTY relay. Performance standards should be created that
allow a CA to take his her scheduled break or other time off the
phone (bathroom, lunch, staff meetings, etc.) without changing
CAs during calls
As part of his/her training, every CA should have a minimum of
8 hours of training by a speech disabilities professional or
consumer expert. STS CA training should include introduction to
various technologies used by consumers to communicate including
voice synthesizers. Training should include introduction to many
speech disabilities. Some training may be provided by video tape.
In order to familiarize STS management with consumers, the STS
vendor's technology, and the developing culture of STS, the
service itself, and provide first hand experience of CA role,
supervisors should be required to perform direct STS live phone
service, in the role of a CA, 4 hours per week. The live phone
work that supervisors perform should be in time segments a minimum
of 30 minutes each in duration.
CAs must be fluent in English, able to speak English without a
distortional accent. CAs should be tested for hearing acuity,
speech comprehension, and English language skills including
vocabulary, grammar, and syntax. This will apply to English and
and all other languages offered to STS users. National standards
must be developed in order to ensure consistent performance and
practice by each vendor and their employees.
It is desirable that CAs have life experience related to people
with speech disability.
All communications assistants should be called operators
because they are a third-party on the line and the term will be
less confusing than communications assistant.
The FCC should establish national standards of hearing acuity
for Communications Assistants (CAs).
STS CAs should have a toll-free number, that is confidential
and safe, where they can call to report perceived abuses of STS
by vendor management.
CAs should be able to give their input to relay advisory committee
without fear of recrimination or job loss. Perhaps the CAs could vote
for a representative who would regularly make presentations to
advisory committee. Presentations could include list of technical
problems, policy problems, and other suggestions for making the
service more consumer-friendly (and better working conditions for
CAs).
Vendors should define acceptable CA hearing acuity and speech
comprehension levels and insure that all CAs meet that criteria.
The STS supervisor will identify CA and remove CAs from
Speech-to-Speech duties if: 1) CAs hearing or concentration has
become impaired because of a cold or other (temporary or
permanent) medical condition. 2) CA is no longer extremely patient
and courteous to customers.
STATE ISSUES
The state relay advisory committee should include a
representative of the Speech Disability Community which
representative should be a Speech-to-Speech user.
Each state should have the option of offering an additional two
hours of training monthly whereby the vendor pays CAs' salaries
for the training and trainers are provided at the state's expense.
Each state should assign at least a one quarter-time person who
is either a knowledgeable consumer or has at least one year of
training in speech disability to monitor STS service quality and
insure that the vendor abides by the contract. This person could
also be employed to perform STS outreach.
OUTREACH ISSUES
Vendors who promote Speech-to-Speech should do so in a manner
appropriate to the target audience.
Each state should assign at least a one three-fourth-time person
who is either a knowledgeable consumer or has at least one year
of training in speech disability to provide outreach. Someone
with an MSW (or equivalent) and with experience working in the
speech disabled community would be best equipped to do the outreach.
Many speech disabled people are very isolated and require extensive
encouragement and counseling before they will be willing to try >
Speech-to-Speech.
Providing inadequate outreach may result in disappointingly low rates of
STS use. The service should not be allowed to fail due to insufficient
outreach efforts.
(California employed two master's level counselors for the
first year and a half of operation in order to recruit and train
150 consumers.)
Because Speech-to-Speech is so new, there is a great
influx of new users. Many new users require one-to-one contact
with trained counselors as an introduction to the service.

That contact is necessary because:

A. Potential users often require individual contact
through the following multiple step process.
First, outreach staff establish contacts with
professionals who interact with people with speech
disabilities. These professionals then refer consumers
to Speech-to-Speech themselves, because such
professionals could not release consumers' names to the
STS Outreach Staff with outd breaking confidentiality.
These professionals include: 1. physicians and
organizations of physicians specializing in neurology,
physical medicine, and ENT., 2. Department of
Rehabilitation Counselors, 3. Staff of Area Boards and
Regional Centers on Developmental Disabilities, 4. Speech
therapists specializing in severe speech disabilities and
their professional organizations, 5. Special Education
teachers, 6. College Centers for People with
Disabilities.
Thus, contact with the non-speech disabled
community is essential in order to reach people with
speech disabilities. At the same time, this contact
encourages non-speech disabled people to call users with
speech disabilities.
Second, staff also identify potential users through
consumer oriented organizations. These organizations can
sometimes provide users' names and telephone numbers with
the user's permission. These organizations include: 1.
Local Assistive Technology Centers, 2. United Cerebral
Palsy Association Centers, 3. Lost Chord Clubs (for
people who have had laryngectomies), 4. Multiple
Sclerosis and Muscular Dystrophy Societies, 5.
Parkinson's and ALS organizations and 6. Independent
Living Centers.
Third, while some users can use Speech-to-Speech with no
further assistance, many users require individual
training by outreach staff. For call volume to be
sufficient, effective outreach must include both easy to
reach and difficult to reach users.

B. Many potential users have never used the telephone
and do not accept the usefulness of the telephone or
Speech-to-Speech. This acceptance often requires intense
one-to-one counseling.

C. Many users have difficulty overcoming "denial" and
other psychological obstacles to the use of Speech-to-
Speech. As the California Public Utilities Commission's
response to the FCC's Notice of Inquiry states, "... the
potential user may still have great reluctance to try,
 for fear of failure and the experience of rejection."

D. Outreach staff must also teach users who lack the
social skills to relate appropriately with agents in
Speech-to-Speech's interactive environment. Speech-to-
Speech agents often must interact extensively with users
having them repeat words or say phrases a different way.
Outreach staff must teach users, many of whom have
limited social skills, to master the Speech-to-Speech
process without becoming overfamiliar with the agents.

E. Family members and caretakers (who often "voice" for
potential Speech-to-Speech users) may resist
Speech-to-Speech use, because they find it threatening.
Speech-to-Speech deprives a family member or caretaker of
the voicing role for a user. This role deprivation can
threaten the co-dependency between user and voicer,
because it limits the voicer's knowledge and control over
the user's telephone calls. Speech-to-Speech outreach
staff provide one-to-one professional counseling to help
potential users, family members and caretakers resolve
these issues.

F. Transportation barriers make it difficult to gather
potential users in one spot for education about
Speech-to-Speech.
Outreach staff often work with them effectively
one-to-one by telephone and in person. Staff often
trains users to facilitate their initial use of
Speech-to-Speech and eliminate barriers to regular
telephone use.

G. Users, families, and caretakers need training and help
resolving practical problems related to telephone
equipment and disability certification. This includes
obtaining and installing body positioning devices,
speakerphones, etc.

H. Users often have cognitive limitations necessitating
one-to-one training. This training must include immediate
feedback in the learning situation.

I. People with speech disabilities have no role models
for telephone use.

Thank you for your consideration of these comments.

LuRetta Fairman
5008 M Street
Sacramento, CA 95819
916-454-5964 home; 916-492-3350 office
E-Mail: lfairman@cris.com