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If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Before the Federal Communications Commission Washington, D.C. 20554 ) In the Matter of ) ) Telecommunications Relay Services, ) CC Docket No. 90-571 the Americans with Disabilities Act of 1990,) and the Telecommunications Act of 1996) ) NOTICE OF INQUIRY Adopted: January 9, 1997 Released: January 14, 1997 Comment Date: March 17, 1997 Reply Comment Date: April 21, 1997 I. INTRODUCTION 1. Title IV of the Americans with Disabilities Act of 1990 (ADA) requires the Commission to ensure that Telecommunications Relay Services (TRS) are available, to the extent possible and in the most efficient manner, to persons with hearing or speech disabilities in the United States. TRS is a telephone transmission service designed to give persons with hearing or speech disabilities "functionally equivalent" access to the telephone network. TRS has been available on a uniform, nationwide basis since July 26, 1993. In this Notice of Inquiry (NOI), we seek comment on the effectiveness of the current TRS program. We also seek comment on new technologies and possible rule changes that could improve TRS. 2. The Telecommunications Act of 1996 (1996 Act) also includes several provisions designed to improve access to telecommunications by persons with disabilities. In particular, Section 255 of the Communications Act of 1934, as amended (the Act), states that telecommunications equipment manufacturers and service providers must make their equipment and services accessible to persons with disabilities, if "readily achievable." TRS provides access to the voice telephone network for over 30 million Americans with hearing and speech disabilities, and to millions of voice telephone users who use TRS to call friends, family members, and associates who have hearing or speech disabilities. In this NOI, therefore, we seek to identify to what extent existing TRS, and any improvements to TRS, may also help to make providing access to certain telecommunications services "readily achievable." 3. The likelihood of achieving the goals of both Title IV of the ADA and Section 255 of the Act can also be maximized if TRS serves the largest possible population of people with hearing and speech disabilities. We desire, therefore, to explore how TRS can be improved to bring more individuals with hearing and speech disabilities within its service capabilities, including people with severe speech disabilities, people who cannot effectively use text telephones (TTYs), and people who do not use English as their primary language. The purpose of this NOI is to ensure that Title IV of the ADA and the 1996 Act are fused into an effective statutory scheme that provides the greatest degree of access to telecommunications services by individuals with hearing and speech disabilities. II. BACKGROUND 4. The Commission sets minimum operational, functional and technical standards for TRS, certifies state TRS programs, and oversees the administration of the interstate TRS cost- recovery fund. Since Commission requirements for TRS took effect on July 26, 1993, use of TRS has grown rapidly. Interstate TRS use grew at an average rate of 1.5 percent per month during the first two years of TRS, i.e., July 1993 through July 1995. For the 1997 calendar year, the TRS Fund administrator has projected approximately 193 million minutes of TRS use, including 166 million minutes of intrastate use and 27 million minutes of interstate use. TRS is offered 7 days a week, 24 hours a day in all 50 states, the District of Columbia, Puerto Rico, and the U.S. Virgin Islands. 5. The Commission's rules preserve flexibility in the provision of TRS, allowing carriers to provide TRS throughout their service areas "individually, through designees, through a competitively selected vendor, or in concert with other carriers." Interstate TRS is currently provided by 12 primary providers, among which are major interexchange carriers, local exchange carriers, state entities, and non-profit organizations. 6. Currently, TRS uses dedicated equipment and staff (Communications Assistants or CAs) that relay conversations between persons using text telephones (TTYs) and persons who use conventional telephones. To access TRS, a TTY user dials the telephone number of the local TRS center. For a TRS user, this first step - the inbound call to the TRS center - is functionally equivalent to receiving a "dial tone." The caller then gives the number of the party he or she desires to call to theCA. The CA in turn places an outbound voice call to the called party. The CA serves as the "link" in the conversation, converting all TTY messages from the caller into voice messages, and all voice messages from the called party into typed messages for the TTY user. The process is performed in reverse when a voice telephone user initiates the call. 7. TRS providers are also required to provide reduced forms of TRS known as "voice carry over" (VCO) and "hearing carry over" (HCO). With VCO a person with a hearing disability speaks directly to the other end user, and the CA types back the response. With HCO, a person with a speech disability listens directly to the other end user, but responds by typing on a TTY and relies on the CA to speak the text as typed. 8. Congress has directed the Commission to ensure that persons with hearing and speech disabilities benefit from technological advances. Title IV of the ADA states that "the Commission shall ensure that regulations prescribed to implement this section encourage . . . the use of existing technology and do not discourage or impair the development of improved technology." Similarly, the House Report on the ADA states that "this legislation is not intended to discourage innovation regarding telecommunications services to individuals with hearing and speech impairments. The hearing and speech-impaired communities should be allowed to benefit from advancing technology. As such, the provisions of the Section do not seek to entrench current technology, but rather to allow for new, more efficient and more advanced technology." 9. In our first Report and Order on TRS, we stated that "we intend to monitor closely, through the complaint process and otherwise, the actual quality of relay services. If experience shows that imposition of additional minimum standards is required, we will not hesitate to prescribe such standards." Through this NOI, we seek to assess the quality of existing TRS and the costs and benefits of imposing additional minimum TRS standards. We note that current Commission certifications of state TRS programs expire on July 26, 1998, and this NOI will give us an opportunity to evaluate the effectiveness of our TRS standards prior to the next certification cycle. III. DISCUSSION A. IMPROVED TRS - COVERAGE UNDER TITLE IV OF THE ADA 10. As a preliminary matter, we seek comment on whether the requirements of Title IV of the ADA also apply to any improved TRS services. We use the term "improved TRS" to describe any form of TRS that goes beyond the current TTY-to-speech and speech- to-TTY paradigm. For example, video relay interpreting (VRI) is a form of telecommunications relay service in which the traditional text-to-speech CA using a TTY is replaced by a CA with sign language skills, and the call is relayed through video telephony. Title IV of the ADA defines "telecommunications relay services" as "telephone transmission services that provide the ability for an individual who has a hearing impairment or speech impairment to engage in communication by wire or radio in a manner that is functionally equivalent to the ability of an individual who does not have a[n] . . . impairment to communicate using voice communication services by wire or radio." TRS includes services that enable communication between TTY users and voice telephone users, but is not limited to such services. 11. Accordingly, we seek comment on whether improved TRS services are "telecommunications relay services" within the meaning of Title IV and our TRS rules. If improved interstate or intrastate TRS services are "relay services" within the meaning of the statutory language, must these services comply with all standards for TRS under Title IV and our rules? For example, must these improved services comply with our call confidentiality, speed of answer, and anti-blockage requirements? Furthermore, we seek comment on whether such improved relay services must meet our minimum standards regardless of whether they are offered voluntarily or pursuant to State or Federal requirements. 12. Our current definition of "Communications Assistant" defines a CA as "a person who transliterates conversation from text to voice and from voice to text between two end users of TRS." We seek comment on whether, in order to bring improved TRS services within the scope of our regulations, we would also need to modify the definition of "Communications Assistant" to encompass the transliteration of telephone conversations in formats other than text-to-speech and speech-to-text. B. VIDEO RELAY INTERPRETING (VRI) 1. Background 13. Since the implementation of TRS in July 1993, many TRS providers have, on their own initiative, sought to develop innovative forms of TRS by offering services and features not required under the Commission's current rules. The development of Video Relay Interpreting (VRI) is an example of this innovation in the TRS industry. VRI takes advantage of advances in computer technology and the increasing deployment of the Integrated Services Digital Network (ISDN). VRI involves the addition of personal computer (PC) video equipment and sign language interpreting services to the existing TRS network. VRI allows persons with hearing or speech disabilities to communicate with a CA through visual modes of communication, such as American Sign Language (ASL), Signed English, or lip-reading, rather than by typing on a TTY. Because communication through a TTY is much slower than ordinary speech or ASL, VRI would allow for a much faster and more natural conversation than is possible with basic TRS. 14. The Texas Public Utility Commission, Sprint, Southwestern Bell, and associations representing people with hearing and speech disabilities worked together on a month-long Video Relay Trial in Austin, Texas, in January 1995 (Texas Trial). Video conferencing equipment was installed at a school for the deaf and two community centers in Austin, and Southwestern Bell installed ISDN lines from these locations to the Texas TRS center. The three Texas Trial centers were open for the use of VRI from 3:00 to 7:00 PM Mondays through Fridays. A total of 231 calls were relayed during this Trial, and the average call length was three minutes. The Trial Report indicates that there was an "overwhelmingly favorable" response to the VRI concept from Trial participants. A second VRI trial in Texas began in September 1996. 2. Comment Requested a. Technical Feasibility 15. We seek comment on the technical feasibility of offering VRI services. Commenters should supply the Commission with data from any prior or ongoing VRI offerings, including the Texas Trial. We are interested in learning the extent to which VRI services could feasibly be offered by TRS providers given the current state of network and PC technologies. Are any TRS providers currently offering, or planning to offer, around- the-clock VRI service? Could VRI services be gradually phased in over a period of time? Commenters should also address the costs of providing VRI. Assuming that VRI uses ISDN technology as the primary link between VRI users and the TRS center, we seek comment on when ISDN deployment will be sufficiently ubiquitous for VRI to become a standard TRS offering. 16. We recognize that ISDN is perhaps the most widely available platform for the delivery of video telephony to residential end users at this time. Are video telephony platforms, other than ISDN, being considered or studied for VRI services? Does the industry anticipate that video telephony will be delivered through other means in the near future (e.g., two-way coaxial cable, direct satellite, or terrestrial wireless services such as local multipoint distribution systems (LMDS)), on a sufficiently broad level to support national VRI services? Furthermore, to what extent can VRI implementation be integrated into the development of national networks for other video applications, such as telemedicine? 17. We are also interested in learning whether current personal computer video products (especially in conjunction with ISDN) provide the degree of video quality needed for communication through American Sign Language, Signed English, fingerspelling, cued speech, lip-reading, oral interpreting, or any other forms of visual communication commonly used by persons with hearing and speech disabilities. Can data compression and personal computer video capabilities be improved independent of the transmission method, thus improving video quality without requiring more bandwidth or transmission capacity? What are the current costs of personal computer video products needed to provide effective VRI services? b. Benefits of VRI 18. We seek comment on the potential of VRI to improve the functional equivalency of TRS, i.e., by increasing the speed and fluidity of conversations. We request data on the average speed at which various forms of communication occur, such as voice, TTY, American Sign Language and Signed English. We also desire to assess the potential market for national VRI services. Commenters, especially TRS providers, should address whether they believe the implementation of VRI services will increase the overall use of TRS services, i.e., by providing an alternative for persons who are dissatisfied with TTY-based TRS, or are not comfortable using TTYs. We also ask commenters to discuss whether the implementation of VRI could spur the development of other services benefiting persons with disabilities, or enhance the accessibility of other telecommunications services, in light of Section 255 of the Act. Commenters should also discuss whether the widespread use of VRI may encourage the development of telecommunications services that could benefit all Americans, not just those with hearing and speech disabilities. c. Availability of Interpreters 19. Much more than standard TRS, VRI is a unique combination of technology and human resources. The provision of VRI will necessarily involve the use of qualified sign language interpreters. We seek comment on whether there are now enough qualified sign language interpreters for TRS providers to offer VRI on a statewide, or nationwide scale. We are also interested in learning of any strategies that TRS providers would adopt to ensure an adequate supply of interpreters, if they choose to offer VRI services, or were required to do so under a state contract. 20. Since TRS I, we have been acutely aware that TRS is "labor-intensive," and that "accurate and meaningful [CA] standards. . .translate into cost savings." We therefore seek comment on whether the Commission should adopt standards to ensure that TRS centers have qualified interpreters, if VRI becomes a standard TRS feature. If so, what should these standards be? Should the Commission, for example, adopt minimum quality standards for interpreting services delivered over the public telephone network, similar to our current quality standards for CAs? Alternatively, should the Commission rely on the market to ensure quality? d. Privacy and Confidentiality 21. We note that Title IV of the ADA required the Commission to enact regulations that "prohibit relay operators from disclosing the content of any relayed conversation and from keeping records of the content of any such conversation beyond the duration of the call." In TRS I, we codified these statutory requirements in our rules, recognizing that "the ADA prohibition of disclosure furthers the statutory purpose that TRS be functionally equivalent to regular telephone service. We believe that confidentiality is essential to the service, and that users of TRS have confidence in the basic privacy of their conversations." Furthermore, we stated that relay operators and TRS providers would be subject to the same liability and service obligations as common carriers generally. 22. We seek comment on the privacy and confidentiality issues posed by the use of VRI. In particular, we ask whether the technology of VRI raises privacy or confidentiality concerns that are different from those present in traditional TRS. For example, we note that because a VRI user and an interpreter will be in visual contact, the "anonymity" of a traditional TRS conversation will disappear. The probability that the interpreter will be able to identify or recognize the caller is therefore much greater than in current TRS. We ask commenters to discuss how the Commission and TRS providers can ensure that confidentiality is preserved in VRI, and to address issues of potential liability of video relay interpreters. Finally, we request comment on what, if any, additional rules the Commission should adopt to address the privacy concerns raised by VRI. e. Costs of VRI 23. Our oversight of the TRS program is guided by two broad principles: Title IV requires TRS services to be provided (1) to "the extent possible" and (2) in the "most efficient manner." Therefore, in our TRS program, we seek both to provide the greatest degree of functionally equivalent access, and to ensure that our requirements neither unduly raise the costs of providing TRS, nor displace market forces that could improve TRS services. We seek detailed information on the costs of providing VRI services. Commenters should specify whether their cost data are historical (i.e., from states that have experimented with or launched VRI), or projected. Commenters should also indicate which costs are fixed and which are variable, and also which costs are one-time capital costs and which are continuing costs. Costs should, to the extent possible, be expressed as per-minute and per- month averages, and separated into interstate and intrastate costs. 24. What facilities, equipment and personnel costs must be incurred in order to launch a statewide VRI program, operating 24 hours a day, 7 days a week in a state with significant TRS calling volumes? What costs would be involved in offering VRI on a more limited basis? We also request comment on whether the costs of providing VRI are likely to decline in the near future (i.e., will the rates for ISDN service, or the price of personal computer equipment and video software be reduced?). To what extent can infrastructure costs be minimized through the use of existing facilities, networks and interpreting resources? How would the personnel and human resources costs compare to current TRS human resources costs? We also ask commenters to address whether the centralization of telecommunications relay services into regional centers capable of handling traffic for several states will make it more cost-effective to provide interstate and intrastate VRI services. 25. We note that Commission rules require that "TRS users shall pay rates no greater than the rates paid for functionally equivalent voice communication services with respect to such factors as the duration of the call, the time of day, and the distance from the point of origin to the point of termination." Commenters should therefore address the cost issue from the perspective of the TRS end user. Specifically, we request comment on whether carriers, in order to ensure that TRS users pay rates no greater than voice users for "functionally equivalent" services, could feasibly offer residential ISDN service to qualifying VRI users at discounted rates. If so, how could carriers recover the cost of providing such discounted rates? Or, if VRI users must pay the full cost for ISDN, would TRS providers still be in compliance with our regulations, because the VRI users are "similarly-situated" to all other ISDN users, and pay rates no greater than any other ISDN user? 26. Customer premises equipment costs may also pose significant barriers to the widespread deployment of VRI. To access this service, TRS users would probably need either to (1) travel to a community VRI center, or (2) purchase expensive computer equipment and have an ISDN line installed in their residences. The "community center" concept could offer significant access to VRI, especially if such centers are strategically located near areas with a substantial number of persons with hearing and speech disabilities (i.e., at residential schools for children who are deaf). We seek comment on what other strategies states and TRS providers could implement to lower consumer costs, and thus facilitate universal access to VRI. For example, should personal computer video conferencing equipment be included within existing equipment distribution programs? If so, what are the costs of providing such equipment, and who would incur the costs of distributing this equipment? C. SPEECH-TO-SPEECH RELAY SERVICES 1. Background 27. Speech-to-speech relay services, also known as "voice-access relay services," expand the services that TRS currently provides to people with speech disabilities. Speech- to-speech services involve the use of specially trained CAs as relay "voices" for persons with speech disabilities, including people who use voice synthesizers. Specially trained CAs understand the speech of persons who communicate with impaired speech or with the use of voice synthesizers, and can repeat the words spoken to ensure that the callers are understood. This may allow for a faster and more natural conversation than is possible when communicating through a TTY. Speech-to-speech services can also benefit persons who have both speech disabilities and limited hand use (e.g., persons with cerebral palsy), for whom using a TTY is difficult. 2. Comment Requested 28. We seek comment on our statutory authority to require speech-to-speech services. We also request comment on the feasibility of requiring speech-to-speech relay services within our mandatory minimum TRS standards. In this regard, we request information on any speech-to-speech trials that have been conducted. To what extent have TRS providers nationwide been offering speech-to-speech services on a voluntary basis? Do TRS providers or state relay administrators currently have plans to include speech-to-speech services as one of their core services in the future? 29. Our preliminary review of speech-to-speech service indicates that these services do not require additional equipment or network upgrades, but do require personnel with special skills. We request detailed comment on: (1) the number of potential users of speech-to-speech services; (2) whether there already are enough trained personnel capable of providing speech-to-speech services; and (3) the potential costs of providing speech-to-speech services. D. MULTILINGUAL RELAY SERVICES 1. Background 30. The Commission's TRS rules generally require TRS to be capable of handling any type of call "normally provided by common carriers," and the burden of proving the infeasibility of handling any type of call is placed upon the carrier. The essence of common carriage is the transmission of public communication without regard to the content of such communication. Because transmission is transparent, the public telephone network does not distinguish among the languages used by those engaged in voice-to-voice telephone conversations. 31. Individuals with hearing and speech disabilities who use written or spoken languages other than English, may not be able to communicate with a voice caller through the relay service when both end users share a foreign language. This is so because the critical "link" in the relay process - the CA - may not be fluent in the desired language. Therefore, the CA cannot pronounce the typed language on the TTY, nor transliterate the spoken language into typed words. 32. The legislative history of the ADA states that carriers are "encouraged to accommodate individuals who speak a language other than English. This is particularly important in areas in which there is a substantial population of individuals for whom English is not the primary language. However, carriers are not required to provide relay services in languages other than those which predominate among large sections of the population." In TRS I, the Commission stated that: "we realize that specialized needs (e.g., foreign language needs) may change over time or with new technological advances. Rather than articulate a low threshold of expectations, a safe harbor, we instead expect that TRS providers will deliver the excellent level of service all telephone consumers demand." We seek, in this NOI, to revisit the issue of multilingual TRS, and assess to what degree this service is now available, or is still needed. 2. Comment Requested 33. We request comment on whether Title IV encompasses TRS services which involve the direct "relaying" of conversations in a language other than English (e.g., a TRS call between a TTY user and voice user who both use Spanish). As noted above, we currently have no rules requiring multilingual TRS. We seek to learn what multilingual services are now offered by TRS providers and whether there is a need for additional multilingual TRS services. Are multilingual services currently offered in all areas of the country where there are a large number of users for whom English is a second language or not used at all? If there is a need for additional multilingual TRS services, we seek comment on whether we should adopt rules requiring the provision of such services. If we were to adopt rules, what criteria should be developed by the Commission for determining when a carrier must provide multilingual TRS? What benchmarks could the Commission use for determining whether a language "predominates" among a large segment of the population? Commenters should also discuss the feasibility and costs of providing multilingual TRS services in areas which would meet the "predominance" criteria. In particular, we request comment on the availability of multilingual CAs, and whether the centralization of TRS into multi-state centers will make it easier for TRS providers to offer this service. E. IMPROVED TRS - INTERSTATE COST RECOVERY ISSUES 34. The Commission's rules provide for an interstate cost recovery mechanism (TRS Fund). Every carrier providing telecommunications services contributes to the TRS fund on the basis of its relative share of gross interstate revenues. Contributions are made by all common carriers for every interstate service, and contributions are based on a "contribution factor" determined annually by the Commission. Eligible TRS providers are entitled to compensation for the reasonable costs of providing interstate TRS, based upon total monthly interstate minutes of use and a "payment rate" established annually by the Commission. The TRS Fund is currently administered by the National Exchange Carrier Association (NECA). Pursuant to the jurisdictional cost separation mandates of the ADA, intrastate TRS costs are recovered by the States pursuant to a variety of mechanisms, including base-rate payments, subscriber line surcharges and legislative appropriations. 35. We note that the ADA, which states that "costs caused by interstate telecommunications relay services shall be recovered from all subscribers for every interstate service," does not explicitly limit interstate costs eligible for recovery from the TRS Fund to TTY-to-voice or voice-to-TTY relay services. We seek comment, therefore, on whether allowing TRS providers to recover the costs of providing improved interstate TRS services from the TRS Fund, including costs caused by interstate video relay, speech-to-speech and multilingual TRS, is consistent with the Congressional intent underlying the ADA. Commenters should also address whether current TRS Fund rules allow for the recovery of costs for voluntarily-provided services (i.e., services that are not required under our minimum standards). 36. Under the Commission's rules, TRS providers are reimbursed for interstate TRS costs on a "conversation minutes" basis - i.e., beginning after call set-up and concluding after the last message call unit. Commenters, therefore, should address whether improved TRS services, such as video relay, would require lengthy call set-up procedures that would not be recoverable under current TRS Fund rules. F. SCOPE OF ACCESS PROVIDED 1. Background 37. Our rules require TRS to be "capable of handling any type of call normally provided by common carriers." In enacting the ADA, however, Congress specifically indicated that "there are some services, such as audiotext services, that connect callers to recorded information services. It is not the function of this legislation to facilitate access to these kind of services." Accordingly, when adopting our TRS rules, we held that TRS providers were not required to offer access to enhanced services, but we encouraged the provision of access to such services where technically feasible. We believe that some TRS providers may be offering, or planning to offer, some degree of access to enhanced services on a voluntary basis. 2. Comment Requested 38. We seek to develop a record on the scope of access currently being offered by TRS providers. Specifically, we request comment on whether there are any services covered by Title IV that are not currently accessible through TRS. If so, we request comment on the types of services involved, the reasons for the lack of access, and how such access might be provided. We also request comment on whether any TRS providers are currently offering, or planning to offer, access to any enhanced services on a voluntary basis. If so, we request comment on the types of services provided, why the TRS provider decided to offer such access, the demand for such access, and the cost and technical issues involved in such offerings. 39. We also seek comment on the interaction between Title IV and Section 255. We note that Section 255 requires telecommunications service providers and equipment manufacturers to ensure that their services and equipment are accessible to and usable by individuals with disabilities, if readily achievable. We seek comment on how these provisions may work together to result in improved access for TRS users. G. OTHER WAYS TO IMPROVE TRS 1. Call Interruptions or Suspensions 40. In order to preserve the functional equivalency of TRS, it is important that TRS users be able to begin and end a TRS call without arbitrary suspensions or unnecessary interruptions from the CA. Commission regulations generally prohibit CAs from "intentionally altering a relayed conversation" and from "limiting" the length of calls. As a matter of practice, we apply the terms "intentional alteration" and "limiting" calls broadly, and discourage any interruptions or interjections on the part of the CA that disrupt the continuity of a TRS call, except where necessary for facilitation of the call (i.e., to ask for clarification of unintelligible messages). 41. We seek comment on the effectiveness of our rules in this area. We request comment on: (1) the average length of TRS calls; (2) the extent to which any CA-initiated call suspensions may be occurring, i.e., for purposes of changing CAs at the end of the current CA's working shift; (3) if there are any suspensions or interruptions, why they are occurring; (4) whether these suspensions cause a problem for TRS users; and (5) the current policies of TRS providers on call completion. 2. TTY/Telebraille Equipment Distribution 42. We recognize that, as long as individuals with hearing and speech disabilities are required to purchase specialized customer premises equipment (CPE), including TTYs, such individuals may not enjoy the same access to the telephone network as voice telephone users. This is because such specialized equipment can be much more expensive than a regular telephone. In recognition of this, our rules currently permit common carriers to provide, under tariff, customer premises equipment needed by persons with hearing, speech, vision or mobility impairments to such persons or to associations or institutions that regularly require the equipment to communicate with such persons. Common carriers, therefore, may offer such CPE as a tariffed service; some state legislatures have also passed legislation enacting such equipment distribution programs. 43. We seek comment on how effective our rules have been in encouraging carriers to distribute TTY, Telebraille and other specialized customer premises equipment voluntarily at discounted rates, or free of charge. We also seek comment on the extent to which carriers or state legislatures have introduced or enacted equipment distribution programs. Are maintenance services and high-quality equipment provided? What are the average prices for CPE used to access TRS, including TTYs and Telebraille equipment? Do any studies show how many potential TRS users fail to use the service because they cannot afford the necessary equipment? Could the equipment necessary for VRI use also be included in such programs? We also seek general comment on what specific steps, if any, the Commission can take within its statutory authority to further promote equipment distribution programs. 3. CA Training and Quality Standards 44. Our operational standards require TRS providers to ensure that CAs are trained to meet the specialized communication needs of individuals with hearing and speech disabilities, and possess both competent skills in typing, grammar, spelling, interpretation of typewritten ASL, and familiarity with hearing and speech disability cultures, languages and etiquette. We seek general comment on the effectiveness of this rule over the past three years. Based on the experiences of TRS users and providers, are there noticeable gaps in CA quality and training standards that we should address? If so, commenters should also discuss whether we can most effectively guarantee a minimum level of CA quality through regulations (i.e., by modifying our minimum standards), or through enforcement actions taken in response to complaints. Commenters should provide specific examples of ways to improve CA quality and training. 4. Information and Outreach 45. As with any telecommunications service, consumer education, training and outreach are essential to the success of TRS. Our rules require carriers to "assure that callers in their service areas are aware of the availability and use of TRS" through publication in carrier directories, periodic billing inserts, placement of TRS instructions in telephone directories, directory assistance services, and incorporation of TTY numbers in their telephone directories. We seek comment on how effective carrier efforts to ensure that callers are aware of TRS have been to date, and whether our current rules cause carriers to conduct effective educational programs. We are especially interested in whether carriers have been presenting information about TRS to the general telephone user population, as well as to individuals with hearing and speech disabilities. 46. Businesses and other voice telephone users sometimes refuse to accept TRS calls, or hang up on TRS users, in the mistaken belief that TRS calls are sales calls or "third-party" calls, or would involve a breach of customer confidentiality. We believe that such problems can, to some extent, be remedied through outreach and training to business and commercial institutions, in particular financial institutions that transmit confidential information over the telephone. Education on the TRS program and the confidentiality of TRS calls would lessen the number of refused TRS calls. We seek comment, therefore, on how carriers can better inform business and commercial customers about the availability and use of TRS. 5. TTY Listings 47. Our rules list "incorporation of TT[Y] numbers in telephone directories" as one mechanism through which carriers can promote awareness of TRS. While we recognize that TTY listings are often made available through independently-published directories, we also believe that "mainstream" TTY listings would reduce the frustration experienced by voice callers searching for TTY listings, or the frustration experienced by voice callers who are unfamiliar with the tones of a TTY and cannot recognize a dialed number as a TTY number (i.e., a TTY listing would provide "advance notice" that a specific number may be answered by a TTY user). We seek general comment on the extent to which carriers are currently offering TTY users the option of having their number designated as a TTY number, either in published directories or through Directory Assistance (DA) services. 6. Other Areas of Improvement 48. We request comment on the overall effectiveness of the TRS program. What other changes can be made to ensure that functionally equivalent access "to the extent possible and in the most efficient manner" is provided? We seek comment on whether our operational, technical and functional standards, in particular our standards regarding call blockage and speed of answer, need to be revised or updated to reflect the experience and growth of the TRS industry. We are interested in learning of other new technologies that we have not addressed in this NOI, especially technologies that are likely to become available within the next ten to fifteen years. For example, are voice recognition and other speech-to- text or text-to-speech systems being developed that could eventually replace human CAs? Finally, we invite general comment on other ways in which the Commission's mandatory minimum standards should be revised or improved to reflect the growth and experience of the TRS industry. IV. CONCLUSION 49. This NOI reflects our belief that TRS is a fast-evolving segment of the telecommunications industry, and that new technologies should be used as they become available, to ensure that TRS provides the greatest degree of functional equivalence for the 30 million Americans with hearing and speech disabilities. TRS should accommodate, to the extent possible, the wide diversity of persons with hearing and speech disabilities, who have varying degrees of hearing and/or speech loss and use different modes of communication. We encourage interested persons to comment on the issues raised in this NOI and to make any other recommendations related to the improvement of TRS. V. PROCEDURAL MATTERS 50. Authority. We issue this NOI pursuant to authority contained in Sections 4(i), 4(j), 225, 255 and 710(g) of the Communications Act of 1934, as amended by the Telecommunications Act of 1996, 47 U.S.C.  154(i), 154(j), 225, 255, and 610(g). 51. Comment Information. Pursuant to applicable procedures set forth in Sections 1.415 and 1.419 of our rules, 47 C.F.R.  1.415, 1.419, interested parties may file comments on or before March 17, 1997, and reply comments on or before April 21, 1997. To file formally in this proceeding, parties must file an original and six copies of all comments and reply comments with the reference number "CC Docket 90-571" on each copy. If parties want each Commissioner to receive a personal copy of their comments, they must file an original plus eleven copies. Comments and reply comments should be sent to the Office of the Secretary, Federal Communications Commission, 1919 M Street, N.W., Washington, D.C. 20554. Interested parties should also send two copies of their comments and reply comments to Andy Firth, Federal Communications Commission, 2000 M Street, NW, Room 210, Washington, DC 20554, and one copy of each to the International Transcription Service, Inc. ("ITS"), 2100 M Street, NW, Suite 140, Washington, DC, 20037. Comments and reply comments will be available for public inspection during regular business hours in the FCC Reference Center (Room 239) of the Federal Communications Commission, 1919 M Street, N.W., Washington, D.C. 20554. Interested persons may also obtain copies from ITS. 52. Ex Parte Rules. Section 1.1204(a)(4) of our rules, 47 C.F.R.  1.1204(a)(4), exempts this proceeding from ex parte requirements. 53. Additional Information. For additional information on this proceeding, contact Andy Firth, (202) 418-2224 (tty), (202) 418-1898 (voice). E-mail: afirth@fcc.gov. FCC Internet Home Page: http://www.fcc.gov. FCC Disabilities Issues Page: http://www.fcc.gov/dtf/dtfhome.html. 54. Accessible Formats. For information on obtaining this document in accessible formats, contact Sheila Ray at the International Transcription Service at (202) 857-3800, (202) 293-8810 (tty). . FEDERAL COMMUNICATIONS COMMISSION William F. Caton Acting Secretary