TRS and Speech-to-Speech Report and Order
To: Consumer Contact List
From: Karen Peltz Strauss, RERC-TA
Date: June 23,2003
Re: In the Matter of Telecommunications Relay Service and Speech-to-Speech
Services for Individuals with Hearing and Speech Disabilities, Second
Report and Order, Order on Reconsideration, and Notice of Proposed
Rulemaking, CC Dkt No. 98-67, CG Dkt No. 03-123 (adopted May 15,
2003; released June 17, 2003)
Comments are due 30 days after publication in the Federal Register (FR)
and reply comments are due 45 days after that. The FR publication date is
not yet known.
On June 17, 2003, the Federal Communications Commission (FCC) finalized a new proceeding on telecommunications relay
services (TRS). The document is divided into the following three parts:
1. Second Report and Order addresses matters raised in the FCC's Improved TRS Order and FNPRM released in March of 2000. In
that Order, the Commission added requirements for speech-to-speech and interstate Spanish relay services, defined video relay
services as a covered form of TRS, and proposed coverage of numerous additional types of TRS services and features;
2. Order on Reconsideration addresses various petitions for reconsideration or clarification of the March 2000 Improved
Services Order; and
3. Notice of Proposed Rulemaking (NPRM) contains various proposals for relay services improvement. This is one of what
promises to be an ongoing string of FCC relay proceedings designed to achieve TRS services that are functionally equivalent to
conventional voice telephone services.
A new docket number has now been added to all relay proceedings: CG Dkt No. 03-123. Comments in this proceeding should be
filed under this number, although you may include the other docket number (CC Dkt No. 98-67) on the document as well at least
for the time being. Eventually, 03-123 will likely supercede both 98-67 and 90-571, the original docket number for relay
services.
Note that many abbreviations are used throughout this summary. A brief glossary of these can be found at the end of this
document.
I. Report and Order
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Use of SS7 Technology by TRS Providers The FCC concludes SS7 technology is not restricted to use by common carriers.
Rather, TRS providers are permitted to have access to SS7 technology or similar technologies to facilitate the provision of
relay services. This will enable the following benefits:
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Permit the transmission of information necessary for Caller ID;
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Enable relay calls to be seamlessly transferred to emergency call centers (PSAPs);
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Allow for the transmission of information needed for call blocking;
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May eliminate or reduce the need for TRS providers to manually collect some confidential customer information that is
needed to meet certain TRS minimum standards.
The FCC makes clear that is not requiring SS7, but rather giving relay providers the discretion to use any technology that
enables them to provide the same functionalities. The new Order does, however, require providers to offer certain Caller ID
services where they have available to them the technology needed to transmit calling party identifying information to the
public network. Specifically, such providers are required to pass through EITHER (1) the TRS facility's number, OR (2) a
standard TRS number such as 711, OR (3) the originating caller's number. The Order explains that SS7 and other similar
technologies do not currently have the ability to pass through more than one number at a time. The FCC gives the relay provider
the discretion to choose which of these identifying numbers is passed through to the called party.
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New Types of TRS Calls Within 6 months of the publication of this Order, the following new kinds relay calls are
mandated on an intrastate and interstate basis:
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Two line VCO allows a person with a TTY or VCO screen to talk directly to another party on one line, and read what the
other party says over the second line (typed by the CA). Conversations can flow more smoothly and allow for
interruptions.
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Two line HCO allows a person to use one line for transmitting text to the other party (read by the CA) and the second
line to hear responses.
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HCO to TTY allows calls between an HCO user and a TTY user
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HCO to HCO allows calls between two HCO users
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VCO to TTY allows calls between a VCO user and a TTY user
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VCO to VCO allows calls between two VCO users
The new requirements effectively expand the definition of TRS. Although the ADA defines TRS to include telephone
transmission services that enable an individual with a hearing or speech disability to communicate with hearing individuals,
these new mandates now require the provision of relay services between and among individuals that have disabilities (i.e., no
hearing person to the conversation is required) so long as they use the assistance of a CA. Note, however, that because the FCC
did not seek comment on the provision of HCO to VCO calls, that type of TRS service is not required in this Order.
Waivers: The FCC is waiving the above requirements for IP Relay and VRS providers until January 1, 2008. During this period,
IP Relay and VRS providers must file annual reports with the FCC that detail technological changes, progress made, and the
steps taken to resolve the technological problems that prevent these calls. The first of these reports is due 12 months after
publication of the Order in the FR.
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Emergency Calls In the 2000 Improved Services Order, the FCC concluded in its discussion section that emergency calls
coming into TRS centers should automatically be routed to the most "appropriate" PSAP. However, the actual rule that was
issued specified the routing of such calls to the "nearest" PSAP. In this Order, the FCC clarifies that TRS providers must
automatically and immediately route emergency callers making wireline calls to the "appropriate" PSAP. This is because not
all PSAP service providers use geographic proximity as the only factor that determines where 911 and other emergency calls
should be routed. TRS providers are given 12 months after publication in the FR to comply with this mandate, because the
revised rule may require some system changes. Wireless calls are addressed in the NPRM
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Speech-to-Speech TRS Access Although comments from STS consumers expressed a preference for a dedicated STS-specific
nationwide access dialing number, the FCC rejects that request. The Commission raises concerns that multiple numbers for
different types of TRS services might be confusing, and "contradict the objective of requiring universal, nationwide 711
access to TRS." The FCC also rejects requests for accessing STS through an interactive dialing menu that would create STS
as the first option on the menu. It concludes that 711 access provides an adequate means for customers to reach an STS
CA.
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Long Distance Carrier of Choice - The Order reminds interexchange carriers of their obligation to take whatever steps
are needed to ensure that TRS consumers can make long distance wireline calls through their preferred long distance
carriers.
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New TRS Features and Services Within 6 months of the publication of this Order, the following features and services are
mandated on an intrastate and interstate basis:
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Answering machine message retrieval allows a TTY user to retrieve voice messages left on a voice mailbox or voice
answering machine via TRS.
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Call release allows a CA to set up calls that will ultimate require only TTY to TTY transmissions. For example, this can
occur when a TTY user calls a hospital or hotel switchboard that uses voice, but wants to talk to a person located in a
room with a TTY. Once the switchboard connects the two TTY callers, the CA can drop off from the call, affording privacy to
the callers.
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Speed dialing allows storage of speed dialing codes for specific telephone numbers in a TRS user's consumer profile,
enabling callers to give short hand references for frequently called numbers1.
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Three-way calling allows more than two parties on the same telephone line with the CA. Cost recovery for these calls
will be based on the time that the CA spends facilitating communication, not including call set up time (and not based on
each separate conference leg of the call).
Waivers: The FCC is waiving its mandates for call release, speed dialing and three-way calling for IP Relay and VRS
providers until January 1, 2008. During this period, IP Relay and VRS providers must file annual reports with the FCC that
detail technological changes, progress made, and the steps taken to resolve the technological problems that prevent these
calls. The first of these reports is due 12 months after publication of the Order in the FR. The FCC will not mandate automatic
call forwarding as proposed in its Improved Services Order. This technology allows calls placed by a TRS user to a party to be
automatically forwarded to the other party's (designated) forwarded telephone number. The FCC concludes that this is a feature
that the called party subscribes to through the telephone company. All calls automatically made to the designated number get
forwarded, whether or not they are made through TRS.
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TRS Outreach Although the FCC requested comment on implementing a national outreach campaign in its Improved Services
Order, it now concludes that it does not have a sufficient record to resolve this issue. Additional information is
requested in the NPRM, and will be sought from the Consumer Advisory Committee (CAC).
This section of the FCC's release responds to a number of outstanding requests
for reconsideration and clarification as follows:
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Minimum typing speeds The Commission rejects requests it had received to reduce the minimum typing speed of 60 words per
minute (wpm). The Commission explains that the current minimum is "reasonable and necessary to reduce the length of TRS
calls, and therefore to provide functionally equivalent service. The FCC acknowledges that newly hired CAs may not be
capable of achieving this speed without some training, but insists that CAs test at 60 wpm when they begin handling TRS
calls.
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Hot key for alerting TRS caller to recorded messages The Commission clarifies that "one stroke" technologies other than
a hot key may be used to notify a consumer's TTY that a recording or interactive menu has been reached.
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Remaining with an STS CA for 15 minutes The Commission states that this requirement is a reasonable mandatory minimum
standard and rejects a request to extend its effective date.
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Definition of qualified interpreter The current definition, adopted from the U.S. Department of Justice's ADA
regulations, requires VRS interpreters to "interpret effectively, accurately, and impartially, both receptively and
expressively, using any necessary specialized vocabulary." After this definition was adopted, a TRS provider raised
concerns that this rule would force TRS providers to have VRS interpreters for every specialized professional vocabulary.
In this proceeding, the FCC upholds the original definition, to prevent VRS users from encountering interpreters without
sufficient skills. More specifically, citing a Gallaudet document entitled "Becoming a Sign Language Interpreter," the
Commission explains that interpreters are expected to be able to meet the challenges of varied interpreter situations, and
are, therefore, ़onversant in the vocabularies of various professions and fields."
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Speed of answer In March, 2000, the FCC revised its speed of answer rules to require inclusion of calls that are dropped
and abandoned in calculations of speed of answer time. The FCC now rejects requests for an extension of time for this
mandate. It also rejects a request for waiver of the speed of answer requirement for STS. (Note: A waiver of the speed of
answer mandate is already in effect for VRS until the end of 2003.)
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Reorganization of rules The FCC has moved some of its rules and consolidated others to better present its rules on call
blocking restrictions (the percentage of calls that must be answered within a specified amount of time) and adequate
network capacity.
As part of its ongoing efforts to ensure that TRS meets the functionally equivalent standard, the FCC has issued an NPRM
seeking comment in the following areas:
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National Security/Emergency Preparedness The Commission's Telecommunications Service Priority Program (TSP) contains a
framework for restoring and providing priority telecommunications services to the general public in the event of an
emergency. Services that have priority called "National Security and Emergency Preparedness (NS/EP) recovery priorities are
those needed to respond to local, national or international events that could cause "serious harm to life or property." The
FCC proposes to assign the same NS/EP priority to TRS that is applied to other telecommunications services used for the
public in an emergency. The Commission requests comment on whether its rules should include a mandate to continue TRS
operations in an emergency to the same extent that other local exchange telephone companies are required to continue
operations. This would allow both types of facilities to simultaneously be reinstated when an emergency occurs. The FCC
also seeks comment on whether TRS providers and state programs must provide an operational plan in addition to what is
already required in its rules "to ensure the survivability and continued operations of TRS operations" in an emergency.
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Security of IP Relay Calls Many e-commerce merchants provide message encryption to secure private information
transmitted via the Internet. The FCC seeks comment on whether IP Relay calls should be provided with similar encryption
technology as is used in commercial transactions, or whether alternative security measures can guarantee the security of IP
Relay communications. The FCC also asks whether encryption or other measures will require registration, sign-ins, or
passwords by IP relay users.
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Emergency Calls over Wireless Networks The FCC notes that there are technological challenges in trying to route
emergency TRS calls made over wireless systems to appropriate PSAPs. Specifically, because there is no correlation between
the telephone number and location of a wireless caller, the TRS center's equipment cannot query a database of exchanges to
find the PSAP associated with that caller's number. Thus, TRS providers must have an alternative way to identify the
location of a wireless caller and the designated PSAP. Under the FCC's enhanced 911 (E911) rules, some wireless carriers
may be able to obtain and forward the location information of a TRS call. If a TRS facility receives this information, it
then needs software to access a database that can route the call to the appropriate PSAP. TRS calls routed through wireless
carriers that have not achieved E911 capability would need to be handled differently. In its NPRM, the FCC asks for
information about how TRS facilities currently route emergency wireless calls to appropriate PSAPs, and whether there is
any difference if the relay call is made via 711 or a direct dialing access number. It also seeks comment on whether
wireless carriers should be required to transmit E911 information to TRS centers, and if E911 capability does not exist,
whether the TRS facility should be exempt from having to route wireless emergency calls to the appropriate PSAP. Finally,
it asks whether some other system could be used to provide access to emergency services for wireless calls.
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Non-English Language TRS In prior proceedings, the FCC has deemed TRS calls made between two different languages e.g.,
Spanish and English to be translation services that go beyond the scope of TRS. But in the Improved Services Order of March
2000, the FCC did conclude that translation between American Sign Language and English via TRS was needed to achieve
functional equivalency. After that order was released, the Texas Public Utilities Commission petitioned the Commission to
allow other non-shared language relay services to be reimbursable through the Interstate Relay Fund. Of particular concern
are deaf children who are educated in ASL and English, but who grow up in Spanish speaking families. The FCC acknowledges
that multi-lingual translation TRS services provided to families like these may meet unique TRS user needs. The Commission
now seeks comment on the extent to which such services are needed to achieve functional equivalency, the costs for these
services, what translation services would entail for TRS providers, and whether such services should be reimbursable from
the Interstate Relay Fund. The Commission also asks for a time line for implementation of these services, and how they
would specifically be implemented for VRS, STS and other types of TRS.
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Call Set Up The time needed to set up STS, VRS and other non-traditional TRS calls, such as one and two line VCO and
HCO, varies considerably, and is not currently regulated by the FCC. The Commission seeks comment on how call set up can
best be handled, including information on ways that new technologies can reduce call set up time. The FCC also asks whether
specific call set up times for various forms of TRS should be established and if so, how those should be measured.
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CART Computer access real-time translation (also known as computer-aided real-time transcription or CART) enables a
stenographer to type verbatim speech at rates that far exceed typing. The FCC asks for general information about how CART
can be used by TRS providers, including its technical requirements, training issues, applications, benefits, costs, the
supply of CART providers, and needed TRS waivers. The Commission is interested in knowing whether TRS providers should
offer CART or CART-type services to improve TRS speed.
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Interrupt Functionality Some TRS providers already offer their TRS users the capability of interrupting incoming text
messages, to enable a more natural telephone conversation. The FCC asks for information about how interrupt functionality
is being provided, consumer use of this feature, and whether any non-proprietary TTY protocols can support it.
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LEC Offerings The Commission asks about the application of the following telephone features to TRS. It tentatively
concludes that these should be provided if they are offered by the TRS user's subscribed local carrier and if the TRS
facility can send Caller ID to the local telephone carrier:
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anonymous call rejection automatically rejects calls to the user's number when the calling party has blocked certain
Caller ID information.
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call screening selective call blocking that allows the user to create a list of telephone numbers that the user does not
want to accept
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preferred call-forwarding allows a user to maintain a list of telephone numbers from which calls will be forwarded to
another number
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Talking Return Call (also called automatic call-back) This allows a person to automatically return the last incoming
telephone call whether or not the call was answered. The Commission asks for information on the feasibility of providing
this service and whether it should be mandatory.
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Speech Recognition Technology The FCC asks about the current status of speech recognition technology and the extent to
which TRS providers have already begun using this technology. Parties are asked to address non-proprietary technologies and
whether CA training to use these is necessary.
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Transmission Speed The FCC requests comment on whether it is technologically feasible to improve the transmission speed
for the TTY leg of TRS calls, and how advanced technology to achieve this would be compatible with legacy TTYs.
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TTY Protocols Although, in the FNPRM, the FCC had asked for information on the use of V.18, V.21 and other TTY
protocols, it states that it did not receive enough comment on this issue. The Commission now seeks comment on the extent
to which innovative, non-proprietary TTY protocols are being used, as well as the benefits and disadvantages that each
might have for the provision of TRS.
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Outreach The Commission acknowledges that its current standards already require that carriers take steps to inform the
public about TRS. It then asks a series of questions about making that outreach more effective, including the kinds of
outreach that should be required, the existence of model state programs, the role of federal funding for this purpose, the
best materials to be used to reach target audiences, the current rate of hang-ups on TRS users, the best distribution
methods, and whether additional outreach should be funded by the states for intrastate TRS providers and the TRS Interstate
Fund for interstate providers. Finally, the Commission asks, if it were to require a coordinated outreach campaign, how
that campaign should be funded. For example, it asks whether third parties could be compensated for the costs of such a
program through the TRS Interstate Fund.
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TRS Provider Eligibility to Receive TRS Interstate Fund Payments Currently, there is no method for a TRS provider that
provides only interstate TRS to receive reimbursement for those services if it is not either certified by a state relay
program as an approved intrastate relay provider or is a common carrier. The FCC seeks comment on whether it should
establish a federal certification process to enable such reimbursement to take place. It then proceeds to propose various
conditions for such a certification process: compliance with the FCC's mandatory minimum standards, maintenance of a log of
complaints and their disposition, and submission of a report detailing compliance with the FCC's standards and resolution
of TRS complaints. The Commission also asks whether it should require all interstate TRS providers seeing reimbursement
from the Interstate Relay Fund to apply for federal certification from the Commission regardless of their affiliation with
a state certified program. In addition, the FCC asks whether it should institute a certification process specifically for
IP Relay, VRS, and any other technology that does not easily fit within the traditional intra-interstate jurisdictional
separation of costs. Finally, it asks whether federal certification rules should be different for IP Relay and VRS since
some providers of these services are not common carriers.
CA communications assistant (relay operator)
FCC Federal Communications Commission
FR Federal Register
HCO hearing carry over an individual (often speech disabled) uses the CA to type his or her messages and can hear responses
in return.
PSAP public safety answering point (emergency call center)
STS speech-to-speech relay services
TRS telecommunications relay services
VCO voice carry over an individual (often hard of hearing or late-deafened) can speak for him or herself, and uses the CA to
type back messages in return.
VRS video relay services
This summary was prepared as part of the RERC on Telecommunications Access, a joint project of Gallaudet University and the
Trace Center, University of Wisconsin-Madison under funding from the National Institute on Disability and Rehabilitation
Research (NIDRR) of the US Dept of Education Grant H133E990006. The opinions offered herein are those of the author and do not
necessarily represent those of the RERC on Telecommunications Access, the Universities or funding agencies
This page last updated:August 24, 2003
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