Please review the following and send any comments to:
Toni Dunne
[email protected] or [email protected]

Before the

Federal Communications Commission

Washington, D.C. 20554 )

In the Matter of ))

Telecommunications Relay Services ) CC Docket No. 98-67

and Speech-to-Speech Services for )

Individuals with Hearing and Speech )

Disabilities )



Adopted: May 14, 1998 Released: May 20, 1998

Comment Date: July 20, 1998

Reply Comment Date: September 14, 1998

By the Commission:

Table of Contents

Paragraph No.




A. Coverage of Improved TRS Under Title IV of the ADA 9

1. Scope of TRS Generally 9

2. Speech-to-Speech (STS) Relay Service 19

3. Video Relay Interpreting (VRI) Services 27

4. Multilingual Relay Services (MRS) and Translation Services 35

5. Access to Emergency Services 40

6. Access to Enhanced Services 42

B. Mandatory Minimum Standards 47

1. Speed of Answer Requirements 47

2. CA Quality and Training 54

3. In-Call Replacement of CAs 61

C. Competition Issues 63

1. Multivendoring 63

2. Treatment of TRS Customer Information 69

D. Enforcement and Certification Issues 73

E. Other Issues 77

40. Background and Comments. The Commission?s current TRS regulations require that “CAs shall handle emergency calls in the same manner as they handle any other TRS calls.” Although this issue was not raised in the NOI, several emergency number and public safety associations filed reply comments asserting that further Commission guidance and minimum standards may be necessary in this area. Commenters suggest that there is inconsistency and confusion among the states and TRS providers as to how such calls should be handled. APSCO and NENA assert that, due to the “critical nature” of emergency calls, CA processing of those calls is of utmost importance, but the procedures for handling the calls vary from state-to-state. APSCO and NENA ask that the Commission establish minimum standards for call handling in this area, and suggest that consideration be given to: (1) using databases to match the TRS caller?s automatic number information (ANI) with the appropriate emergency service number in his or her area; (2) allowing the TRS center to pass the caller?s ANI information to the emergency service provider, even where the TRS user disconnects before emergency personnel are connected (i.e., the functional equivalent of 911 “call-back”); and (3) defining what constitutes an “emergency” call. TX-ACSEC also supported the need for minimum standards in this area.

41. Discussion. We recognize that, despite Department of Justice regulations under Title II of the ADA that require state and local government entities to make emergency services directly accessible to TTY users, many individuals with hearing and speech disabilities may choose to contact emergency services via a TRS center. While CAs should handle these types of calls in the same manner as they handle any other TRS call, we are concerned that the lack of consistency among TRS providers regarding the handling of emergency calls may jeopardize public safety. Moreover, we believe that TRS users should be informed as to how emergency calls will be handled by any TRS center. Accordingly, we seek further comment on this issue. Commenters should address, among other things: (1) whether TRS centers should be required under the Commission?s rules to pass a caller?s ANI to an emergency services operator; and (2) how “emergency calls” should be defined. We also ask TRS providers to describe their current operating procedures for incoming emergency calls. Commenters who propose that the Commission adopt minimum standards in this area should propose specific rule language to implement their proposals.