Here is a comment that our national group of disability organizations filed on the FCC website on this issue. It would be extremely helpful if Mr. Obama filed a short ex parte comment in Proceedings 08-15 and 03-123 supporting the telephone assistance program for people with speech disabilities.
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities
Speech-to-Speech and Internet Protocol (IP) Speech-to-Speech Telecommunications Relay Services
)
CG Docket No. 03-123
CG Docket No. 08-15
COMMENTS OF
TELECOMMUNICATIONS FOR THE DEAF AND HARD OF HEARING, INC.;
SPEECH COMMUNICATIONS ASSISTANCE BY TELEPHONE, INC.;
ASSOCIATION OF LATE-DEAFENED ADULTS, INC.;
NATIONAL ASSOCIATION OF THE DEAF;
DEAF AND HARD OF HEARING CONSUMER ADVOCACY NETWORK;
CALIFORNIA COALITION OF AGENCIES SERVING
THE DEAF AND HARD OF HEARING; AND
HEARING LOSS ASSOCIATION OF AMERICA
Telecommunications for the Deaf and Hard of Hearing, Inc. (“TDI”), Speech Communications Assistance by Telephone, Inc. (“SCT”), Association of Late-Deafened Adults, Inc. (“ALDA”), National Association of the Deaf (“NAD”), Deaf and Hard of Hearing Consumer Advocacy Network (“DHHCAN”), California Coalition of Agencies Serving the Deaf and Hard of Hearing (“CCASDHH”) and Hearing Loss Association of America (“HLAA”) (collectively, the “Consumer Groups”),hereby submits their comments in response to the Commission’s Notice of Proposed Rulemaking in the above-captioned proceeding.[1]
With the NPRM, the Commission has taken an important next step towards assuring that those individuals with disabilities affecting their speech can access the telephone system. As the Commission is well aware, speech-to-speech relay (“STS”) allows a person who has difficulty speaking or being understood on the telephone to communicate using his or her own voice or voice synthesizer. An STS communication assistant (“CA”) re-voices the words of the person with a speech disability so the person on the other end of the phone call can understand them. Since many deaf or partially-deaf individuals communicate verbally, STS provides a vital communications service for these individuals as well. The Consumer Groups therefore commend the Commission for initiating this proceeding and look forward to working with the Commission staff to address any concerns that may be raised in response to the NPRM.
I. sts issues
A. Miscellaneous Issues
Time of the Call. The Consumer Groups agree with the Commission’s tentative conclusion to require an STS CA to remain on a call for a minimum of 20 minutes, rather than the present minimum of 15 minutes.[2] 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. This is particularly true when users alternate between voice and a talking PC in determining which medium is more effective. Requiring an STS CA to remain on the call for at least 20 minutes will serve to provide more efficient and effective communications. As to when the 20 minute “clock” should begin, the Consumer Groups submit that effective communication begins when the CA can understand the user sufficiently so that the user can complete the call to satisfactorily.
Muting of the Voice. STS providers should also be required to offer the STS user the option of having her or his voice muted so that the other party to the call hears only the STS CA re-voicing the call, and not the voice of the STS user as well.[3] This practice would encourage many more people with speech disabilities to use STS who are not already doing so, as some potential users may be embarrassed by how their speech sounds. As the Commission noted in the NPRM, many STS providers are already offering this option, and that many STS users prefer that their voice not be passed through to the other party to the call because it can be distracting and make the call flow less smoothly.[4] Requiring that a user be given the option of voice muting would increase the number of STS users.
Confidentiality. STS operators should be required to inform users on every call that the information relayed on the call is confidential. Once a user has been informed one time, if the user does not wish to be informed on subsequent STS call, the user’s preference can be noted in his or her profile.[5]
Retention of Information. STS callers should have the option to put in their profile that they do not want information retained between consecutive outbound calls and they do not want CAs to make any written notes. This option will allow STS users maximum privacy if they want it, while continuing to enable other users to store difficult to pronounce information.
Silence on the Line. The Commission should also require that when an STS caller is silent but does not say “good-bye,” the CA cannot disconnect from either party until at least 60 seconds has passed. This will ensure that calls will not be prematurely disconnected for those individuals with cognitive and dexterity disabilities problems whose conversations include prolonged instances of silence.
B. STS 711 Issues
STS users should have easy access to STS through 711. As the Commission set forth in its Second Improved TRS Order, “we require that all TRS providers successfully implement 711 dialing access for STS users.”[6] The Consumer Groups submit that the method chosen by STS providers to comply with the Second Improved TRS Order is less of significance, then the need to comply. In fact, in the Consumer Group’s experience, compliance with the Second Improved TRS Order is spotty at best. To increase compliance, the Commission could simply require that a menu be added to the 711 greeting providing the STS user the option, for example, to “press 1 for Speech-to-Speech.” Since some STS users have cognitive problems and cannot activate a 10 digit number, while others have limited dexterity and difficulty dialing, simply pressing one button will ensure that STS will be used by more people who need the service.
With the proper outreach procedures, there could eventually be 500,000 STS users in the United States, all of whom deserve easy access to STS. Requiring only STS users to specifically request STS detracts from the functional equivalency of STS as compared with TTY relay, also offered through 711.
STS providers must ensure that all STS users fully understand that they have the opportunity to have their telephone numbers configured for STS and to complete an STS profile, that would include the default provider selected by each user. Using a profile will greatly increase ease of access to STS and ensure appropriate call handling. Each provider must also customize the Caller Profile form for STS users by including all relevant information the STS user believes will be helpful to the CA and beneficial to the STS user or the party being called. STS providers could have the option to limit this profile to 100 words or less. Thus, when a user with a profile and configured STS number makes or receives an STS call, all relevant information will appear on the CA’s screen. The form should be simple to fill out, and it should be possible to send it in a variety of ways (either through the CA or email, fax, directly online, U.S Postal Service, etc.)
II. IP STS Issues
Form of TRS. The Consumer Groups agree with the majority of the conclusions set forth in the NPRM regarding IP STS. In particular, the Consumer Groups agree that IP STS is a form of TRS compensable from the Interstate TRS Fund because it is an extension of STS that gives persons with speech disabilities an alternative way to initiate an STS call and reach a CA.[7] Because IP STS allows persons with disabilities to use a computer, or other electronic device connected to the Internet, to initiate a call and speak with the CA, IP STS utilizes features from both the STS and IP Relay services that the Commission has already deemed as forms of TRS. Thus, the Consumer Groups agree with the Commission’s conclusion that a service should be considered IP STS so long as it allows the STS user to connect to the CA via a computer or similar device and the Internet, rather than by making a traditional telephone call.[8]
Interstate TRS Fund. Consistent with the present treatment of the other Internet-based forms of TRS (e.g., VRS, IP Relay, and IP CTS), and since one link of the call is made via the Internet, it is generally not possible to determine whether a particular call is interstate or intrastate. The Consumer Groups therefore agree that all IP STS calls should be compensated from the Fund if provided in compliance with the Commission’s rules.[9]
Compensation Rate. The Consumer Groups disagree however, with the Commission’s tentative conclusion that IP STS should be compensated at the same per-minute rate as STS,,[10] unless additional and adequate outreach funds are provided. The reimbursement rate for IP STS, if recognized as a service eligible for compensation from the Interstate TRS Fund, should be determined by what efforts the providers must make to ensure that the service is useful to consumers and that a significant proportion of prospective users have an opportunity to learn to use the service. As discussed below, for IP STS to be effective, the reimbursement rate must be high enough to give providers the incentive to identify and reach users from a small population.
III. Other STS and IP STS Issues
A. Outreach and Compensation
The Consumer Groups are concerned that outreach efforts with respect to STS have not been adequate to identify and reach potential STS users. The Consumer Groups therefore suggest that states be required to provide STS users adequate information regarding the availability of STS. Since STS was established in an effort to provide effective telecommunications services to Americans with speech disabilities, these important services cannot be effective if consumers do not know that they exist.
The Consumer Groups are pleased that the FCC is continuing to provide for STS outreach by establishing a $2.7248 per minute rate for interstate STS. From the perspective of interstate calls, the providers are now receiving adequate financial incentive to identify and train many potential STS users who do not know that STS exists. The Consumer Groups urge that the Commission continue with that high rate for interstate STS an ongoing basis.
However, the MARS rate is not adequate to generate the necessary STS outreach because the providers would have no funds and hence no financial incentive to perform STS outreach. In other words, the MARS rate is insufficient to fund both STS and the marketing necessary for widespread outreach. The Consumer Groups therefore recommend that both intrastate and interstate rates to be set high enough to provide the necessary funds for STS providers to engage in outreach and education. Such higher rates are also important since, as discussed below; intensive consumer training will also be needed.
As far as the Consumer Groups are aware, there is no known successful STS outreach method to reach consumers in large numbers. The Consumer Groups therefore suggest that the Commission establish an STS Advisory Council and work to ensure that each potential user of STS nationwide will be identified and trained. The STS Advisory Council can, among other things, develop national short and long range plans that will increase consumer awareness and education.
B. Consumer Training
Unlike the adoption of VRS by the disability community where deaf consumers transferred telephone skills (both social skills and technical skills) from previous relay experience, many new IP STS users will not have used the telephone. The ability to learn to use IP STS will therefore require a significant lifestyle change. The Commission should require that, where needed, home visits be made by qualified speech language pathologists (“SLPs”) to enable new IP STS users to internalize the social and psychological lifestyle changes that are necessary to use IP STS. As individuals with speech disabilities often have social and psychological barriers to telecommunications, it is unlikely that individuals with speech disabilities will use STS without the home visits by SLPs to overcome these social and psychological barriers. In the Consumer Groups’ experience, there has generally been a lack of long-term use resulting from brief customer introductions to STS as compared with greater success from multiple home visits by an SLP. For this reason, the Consumer Groups strongly recommend that STS outreach be funded to allow 3-10 home visits. Building such a cost into the STS reimbursement rate would not cause it to exceed the current VRS reimbursement rate. VRS users need such expenses for interpreter services, and STS users need the expense for training. Consumer training not only benefits STS users, but it benefits the general public by making it possible to interact over the telephone in a meaningful way with people who have speech disabilities. Moreover, even with the proposed 3-10 home visits, new STS users’ exposure time to STS would still be less than the average citizen’s lifetime exposure time to general telephone advertising.
As part and parcel with adequate outreach and STS user training, STS and IP STS compensation rates should be sufficient so that CAs can be paid adequately enough to establish a career path for the CA - just as video relay interpreters are compensated. Since video relay users have the ability to receive service from interpreters who have the motivation to provide good service (because of adequate compensation and a career path), so too should STS users have that same ability. STS and IP STS compensation rates should also be sufficient so that Supervisors and CAs can receive regular training from qualified SLPs in order that they have a thorough understanding of the physiology of STS users. This would result in a much higher quality of STS service than currently exists and would help curtail users from abandoning STS due to what they perceive to be sub par CAs.
C. Nationwide Provision of STS
The Consumer Groups submit that IP STS should be administered nationwide in a manner similar to VRS with the marketplace determining the number of providers. A nationwide IP STS service is reasonable given the small number of potential users. Indeed, when the number of potential users (approximately 500,000 to 1,000,000 for STS and IP STS combined) is divided among the states, some states would have fewer than 500 potential users.
Because IP STS calls cannot be jurisdictionalized between interstate and intrastate, the Commission has ample authority to mandate a nationwide approach and encourage competitive providers. Moreover, to the extent there are states that do not have the resources or otherwise do not wish to administer state STS programs due to there being only a limited number of potential STS users, the Commission has the authority under Section 225 of the Act to administer STS programs within those states.
The Consumer Groups submit that the Commission’s rules ought to encourage competitive STS and IP STS providers. Competition encourages innovation and will result in a greater variety of services and better quality service. We have already seen the benefits of competition in the case of VRS, and the Consumer Groups encourage competitive STS and IP STS providers.
IV. Conclusion
The Consumer Groups estimate that only approximately one-third of those with a speech disorder - or nearly 1 million Americans - have the requisite hearing, cognitive, and social skills to use STS. The number of people who can benefit from STS and IP STS is far greater when other populations are considered, such as people who are hard of hearing or deaf whose speech is not readily understood. There is also a “rolling population” of people recovering from stroke and brain injury who may need to use STS or IP STS for a few months until their speech is improved. Traditional outreach methods may not work because potential users do not know each other and are not available in groups, thereby making the spreading information through word-of-mouth or group training ineffective. Many potential STS and IP STS users have never used the telephone and may have a reluctance to try, out of a fear of failure and the experience of rejection. Given all of this, the Commission must take the lead to ensure that STS and IP STS and their providers are fully funded and made accessible to those individuals who need it.
Respectfully submitted,
_______________________
Bob Segalman, Ph.D., Sc.D. (Hon.),
President, Speech Communications Assistance by Telephone, Inc.
515 P Street, #403
Sacramento, CA 95814
Paul Gagnier
Eliot Greenwald
Nguyen Vu
Bingham McCutchen LLP
2020 K Street, NW
Washington, DC 20006
Counsel to Telecommunications for the Deaf and Hard of Hearing, Inc.
Nancy J. Bloch
Chief Executive Officer
National Association of the Deaf
8630 Fenton Street, Suite 820
Silver Spring, MD 20910
Claude L. Stout
Executive Director
Telecommunications for the Deaf and Hard of Hearing, Inc.
8630 Fenton Street, Suite 604
(301) 589-3786
Edward Kelly
Chair
California Coalition of Agencies Serving the Deaf and Hard of Hearing, Inc.
6022 Cerritos Avenue
Cypress, CA 90630
Christine Seymour
President
Association of Late-Deafened Adults, Inc.
8038 MacIntosh Lane
Rockford, IL 61107
Cheryl Heppner
Vice Chair
Deaf and Hard of Hearing Consumer Advocacy Network
3951 Pender Drive, Suite 130
Fairfax, VA 22030
Brenda Battat
Hearing Loss Association of America
7910 Woodmont Ave., Suite 1200
Bethesda, MD 20814
[1] See Telecommunications Relay Services And Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123 et al., Notice of Proposed Rulemaking, FCC 08-149 (rel. June 24, 2008) (“NPRM”).
[2] Id. at ¶ 14.
[3] Id. at ¶ 16
[4] Id. at ¶ 16.
[5] This requirement should apply to users with or without speech disabilities.
[6] Telecommunication Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, Second Report and Order, 18 FCC Rcd 12379 (June 17, 2003) (“Second Improved TRS Order”).
[7] NPRM at ¶ 18.
[8] Id.
[9] Id. at ¶ 19.
[10] Id. at ¶ 20.
Herding Turtles: Obama, Cerebral Palsy and Telephone Access for People with Speech Disability
Barak Obama has mastered an art that I have spent much of my life trying to master. This art is commonly known as community organizing, but I’ve always thought it was more akin to “herding turtles”. Wikipedia defines community organizing as “civil society non-profits that operate within a…community”. These organizations are filled with many diverse people with their own well intentioned agendas. Sometimes, getting these folks to move in one unified direction is as easy as getting fifty turtles to cross a street.
Obama and I have had very different experiences in our journey through our communities. I am not running for president, which as far as I can imagine must feel like the Large Hadron Collider of community organizing. However, I am operating with cerebral palsy and a severe speech disability. Obama and I each have our own turtles, but without fail we keep trying to get them to the other side of that street.
Unlike Obama, I had an advantage in my early life. Obama’s journey of leadership began at a much later age than mine did. My father was the leader of several Jewish communities in the United States. Watching Dad’s trials and errors gave me a head start. His job included raising and distributing funds and organizing recreational and educational programs. This proved very stressful at times, because of the myriad agendas of the volunteers he was working with. It was by watching him that I came to understand his position in the community as a turtle shepherd.
Many people with whom Dad worked were donors who felt that their large donations gave them the right to dictate agency goals. Dad laughingly recalled a budget meeting at which the biggest donor went on a tirade because of an expense for wooden pliers. He spent fifteen minutes criticizing Dad for allowing the janitor to spend money on wooden pliers when metal ones were stronger and cheaper. This rich, autocratic donor was a bit sheepish when Dad explained that the wooden pliers were for the janitor’s safety when doing electrical work. Dad also joked that much of his time was spent preventing several of the local Rabbis from killing each other (or the janitor).
Later in life Dad became a social work and sociology professor at the University of Texas at Austin. In 1969, at the height of the Vietnam War, he utilized the same mediation skills he had developed earlier when the Students for a Democratic Society (SDS) brought their national convention to the campus. The Texas state politicians were also there herding turtles at the capital. The police and politicians were determined to have a confrontation with SDS-a veritable showdown at the OK Corral. Dad organized the campus clergy to take roles in calming down these opposing factions. When the University denied SDS the privilege of meeting on campus, the religious centers organized to provide space for each of the SDS events. The clergy chaperoned the events and intervened any time an SDS member proposed illegal action. Dad also convinced the Austin police to stay off of the campus unless they were called. He neutralized the right-wing extremists and kept the confrontation at bay-a confrontation that would have erupted in violence. The closest they came to an incident was when some of the more radical SDS members skinny dipped in the campus pond. The attending clergymen convinced the radicals to put their clothes back on before any police could be called.
As an adult, I took over the family business and have been herding my own turtles for the last twenty years. I took the tools my father gave me and got off to a running start. Having a speech disability made me the perfect candidate for a committee assignment dealing with speech disabilities for the California Public Utilities Commission. This position allowed me to work towards developing a telephone assistance service for Californians with speech disabilities.
I wanted to enable People with Speech Disabilities (PSDs) in all states and in several other countries to have an accessible telephone service. In 1990, out of my own frustration over not being understood over the phone, I started Speech to Speech (STS), a service where trained professionals to revoice for me. STS works much like TTY relay for the deaf community. I successfully lobbied the California Public Utilities Commission (PUC) and the FCC to require that STS be added as a service of the TTY relay. Additionally, I was privileged to help write the FCC regulations for STS. I also visited every member of the California Legislature asking for their signatures on letters to the California PUC in support of STS. Most of them agreed to do so, probably because in addition to its lack of controversy, they most likely wanted to get me and my huge power wheelchair out of their small offices to make room for better financed lobbyists!
Daily independence is often taken for granted. To make a phone call and be understood by the person on the other end is a golden opportunity for someone with speech disabilities. Imagine all of the phone calls you have made in the last week. Now imagine that instead of just being able to plug in your blue tooth and go, you had to ask a friend to help you make every call. We all deserve a high quality of life even those of us with disabilities.
The continued success of STS depends upon a delicate balance between consumer needs, state and federal regulations, and the ability of the contracting telephone companies to make a profit. There are many problems facing STS and if these problems were addressed, the FCC and the contracting telephone companies could work together to make this program effective for everyone involved.
These problems include:
1.)Outreach. Many people with speech disabilities are not aware that this program exists, nor do they have training to use it currently.
2.)Communications Assistants (CAs)-human revoicers-need better training in order to adequately meet the needs of STS users.
3.)If the system were run nationally, rather than as a state to state program, the training, outreach and monitoring of STS would be much more cohesive and effective.
4.)The FCC is about to approve an internet based STS program. However, because of the poverty level of most people with speech disabilities, their access to PC’s and other hardware necessary to use this system is limited at best.
5.)Confidentiality needs to be assured for the consumers of STS. Otherwise potential users will abstain from taking advantage of a service provided for them.
6.)We must stop the abuse of the system by people who don’t have speech abilities (such as people in penal institutions using it because it is a toll free number).
7.)People with speech disabilities need to unite as a political force to protect STS. You can easily help with this process.
This is not a comprehensive list of the systemic problems with STS. I am not accusing any provider of wrong doing, nor am I apologizing for the inability of those of us who designed STS to predict the difficulties that would evolve over time. STS needs to be as easily accessible as TTY. Providers need to see profit incentive from this service, and consumers need to have the best possible access to their independence.
Here’s where you come in. The FCC wants to hear from people who support STS consumers (as they rarely do). In order to improve STS (and address some of the issues pointed out above) the FCC issued a Notice of Proposed Rule Making in Proceeding 08-15 and 03-123. The FCC needs to hear that this issue is close to many people’s hearts. Through at least October, the FCC will accept “Ex Parte” input from the public about STS and internet STS issues at http://www.fcc.gov. If you would like help filing, or have any questions please feel free to contact me at drsts@comcast.net and I will be glad to file for you, or answer you concerns.
This subpopulation cannot speak for itself and needs your voice. The best thing you can do to help people with speech disabilities is to file comments with the FCC. Meanwhile, like Obama, I’ll keep herding turtles, and trying to improve the quality of life for my community.
Bob
Bob Segalman, Ph.D., Sc.D. (Hon.), Founder of Speech-to-Speech
515 P Street, #403; Sacramento, CA 95814
Call 1-888-877-5302 and then ask for me at 916-448-5517
E-mail: drsts@comcast.net
Website: http://www.speechtospeech.org
IM: Mensaman1 (in Yahoo) -- the fastest way to reach me.
