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The need for TDD/telephone relay service has been proven in eight states ocross ine country. Now hundroos of thousondo or dolls oro modo ooon doy by door, hooring impaired and speach Impaired people who provlously nod to wall and depend on a neor ing friend or relative (or sometimes a stranger ) to make their business and personal phone calls for them. This Includes numerous people who were denied jobs on the 80s-old pretext that "you might have to make a phone call in the course of your job so a deol person could not handle this position." Millions of people have been danied the right to live their own lives independently because major telephone corporations have not taken the extra steps to provide simple phone service to thot segment of the population until reloy legislation is passed in their stote. The technology necessary to provide relay service hos existed for at least a decade.

A TOD/telephono roloy service provides a vital link between people, hearing and cool, who could not otherwise communicate over the telephone. A doof, hearing impaired or speech impaired coller who uses a TDD ( Telecommunication Device for the Deal) calls into the service and types to & Relay Operator over the operator's computer terminal. (in Minnesota, an IBM PS2 Model 50-7 Is used with an Ultratech Intalemodem as a lorge screen TDD and for Intrastale long distance Information. No record of a coller's conversation is kept on paper or disk 10 Insure confidentiality.) The operator calls the voice user on a separate phone line. When both Dorlies are on line, the operator roads the door caller's words aloud to the hearing person and types tho hoor ing coller's words to the door person. The Relor Operator is only responsible to Dests the conversation from one person to the other and acts as a "human telephone wire“. Likoa telephone they do not consor.edll. correct. protect, dovisa.counsel or otherwise interfere with the business of the call. All calls and information oro kopt completely confidential. Orton tho operator needs to 'ranslate the grommor of American Sign Language to spoken English and Dock spain. This requires a knowledge not only of ASL grammar but also of the culture of Dear people and the Door Community.

These servicos are more than just telephones and computer terminals. A relay service Is comprised of both lolecommuncations equipment and human beings. Notcher functions without the other. Certainly it is important io nove the best up to date equipment, but that's not enough. It's not only phono lines and liber optics, It's about ethics, responsibility and cultural understanding. Just passing words is not sufficient. A Relay Operator must focililoto communication. That is a lask which requires human Intervention. Some Door collers type standard English, somo type ASL grammar. Some collers feel they should try to uso English, ovan 11 their English skills are not strong. Occasionally a coller nos nod no formal training in ASL or English and invents their own grammatical structure. Here are some examples of roloy conversations:

"Avold of me to pick on you for smoking?" (Hove you been avoiding me because I picked on you for smoking?)

"Touch finish Now York you ?" (Hove you returned from visiting Now York?)

"I ask you question must my something moon prove or not novo only Interviow?" (DO 1 need written proor.resumo, references, or just an interview ?)

"Thots well I very nopo wait for opon job that you will be much hard work doing that well I am good record that show it that loo patience." (I hope you novo a job opening. I will wall for 11. I work hard and have a good record and I have patience.)


"Time yestercoy I called you but was not thero i message someone but I wolled for no answer on the phone but now I just calling you that is why." (I called yostordoy but you were not in so I left a message with someone. Nobody returned my coll so I'm calling now.)

A Deal Coller wonts to phone the outo body shop where his cor is being painted. The manager sovs to the cool coller (through the Relor Operator) "Wo oro bening schedule so your cor isn't resoy. Things novo beon noctic here." Then the monoper usos a common English idiom near Ing people use all the timo. "We'll have all the pieces together by Friosy." The Door caller. typing In ASL grammar , is unlomillor with this common spoken English expression. He explodos, typing fur lously on his TDD "Why pieces? Why you tako oport my car? You must point It onlyi“ The Operator needs to translate the idlom and type in "Friday all finish ready".

A Deor caller gives the operator a number to dial to call a friend. The Roloy Operator dials and pots a phone company recording saying that number is temporarily disconnected Whon informed that the number is disconnected, the Dear caller types "Check the other phone in the living room. Maybe that's still plupoed in." Hearing people are familiar with these recordings. We have heard them all our lives. A Door caller will not be that familiar with the Ins and outs of the phone system.

After five o'clock a Deor coller wonts to phone their doctor. The office is closed and the answering service answers, soying "Dr. Smith's offico". The Deaf caller is not familiar with answering services ond begins to ask medical questions, assuming the live person at the doctor's office must be a doctor or nurse.

Those are typical examples of relay conversations. The callers are not using bed English. They are not ignorant people. Thoy oro using their own language, ASL, and encountering aspects of tolephone use with which they are unfamiller, aspects and events wo lake for granted at the Minnesota Rolay Servico, operators are trained by a number of door consumers and interpreting experts in Deol Culture, Language and ethics.

The "common carriers" and Intorstole phone companies mentioned in the bill are phone companies which nove the lechnological capabilities but may not hove the humanistic capabilities and cross-cultural understanding necessary to provide quality relay service. It is a natural assumption to see "TDD/Telephone Rolay Service" and think that a telephone company is the right choice. But the telephone/telecommunications aspect comprises per hops 30% of the components of a roloy service. It is for faster and more cost offective to put the 30% telecommunications espect where the 70% Door Culture and Language expertise already reside.

Al AT&I's California Rolay Service (CRS), already operating for several years, on covisory commiles with a majority of door and noor ing impoired consumers is currently "in the works" to provide the CRS with input ond feedback from the community It serves. In Minnesota. the state Doord which contracts for the Minnesota Rolay Service (MRS) as well as the Board of Directors of D.E.AF. Inc. both nove a majority or Dear and hearing impaired members. The other Services in this country which are run by non-profit opancies oro similarly Door controlled. We do not need to set up a separate committee for roodbeck from the Deer Community because we ach the community. The people who control these services also uso Il every day. To loove the daily decisions and policy implementation of a TDD/tolophono roloy service in the hends of 8 hoor ing-controlled corporation is as obsurd as running the National Organization for Woman with an all-malo board of directors.


Within the first three sentences of il's testimony for this hearing. AT&T demonstrates It's "songitivity" to Door peoplo ond Door oulturo by Invoking tho nomo of Aloxondor Gronom Boll. It is true thol Bell Invented the telephone while trying to design a near Ing omplification device for the Deaf, largely because his wife and mother were door. Bell also considered Door people to be aberrations of nature and felt they looked "freak Ish" If they used sign language. He for Dogs nis wife to sign and supported such educational measures as tying door schoolchildren's hands so they could not use their own language. He attempted to pass legislation which would prohibit two door people from morrying because they might produce doof children. Boll's name is considered o curso word in much of the Deal Community. Do they feel this person is an appropriato representation of their commitment to persons with disabilities?

AT&T's Callfornia Roloy Service claims to process 250.000 calls per month. In an article in the August edition of Silent News, Bill White reports this ligure includes those Incoming calls put on hold that give o recording informing the coller that all operators are busy. plooso walt, olc. These are counted as calls handled even though a percentage of these collers nang up and never reach a Relay Operator. At the same time, because the call has been picked up Dy the phone system, 11 generales cost on the incoming WATS line. The cost of this time on the Incoming WATS lines is paid for by the CRS from the revenues generated by the legislatoo surcharge. The money is paid to the company which provides the WATS lines. AT&T provides ihoso lines. If the service is insufficiently starred or operator speed and quality of service is low, collors must walt bofore they get through to o Roloy Operator. This is the equivalent of you or I picking up our phone receiver and staring at it for lan minutes before we dial the number However, Incomo is generated for the company whenover collers are put on hold for those vory raisons.

Mr. Whilo also reports that many of the California Reloy Service's problems were anticipated by user groups during the planning stopos, but door consumer representatives were shut out of key meetings. CRS is currently doing sued by Ino California Deor community through an organization nomed Greater Los Angeles Dool.

I would like to clearly state that I do not question the motivation, dedication or personal commitment of individuals such as Merril Тutton or any of the AT&T Reloy managers across the country. In our lestimonies we nove agreed on a number of important points. I morely wish to point out thot o largo, hoor ing-controlled to locommunications corporation is not necessarily the best provider of relay service. These services work best when they are created and controlled Dy and constantly accept Input and feedback from the consumers they were designed to serve.

| also wish to express my alarm that the federal communication Commission is using the AT&T California Roloy Service as it's sole model for the dovelopmónt of policies, procedures, guidelines and regulations to cover all relay servicos across the country. The FCC has no Intention. 83 of our lost contact. 10 actively seek Input from door and hoor ing Impaired consumers, Interpreters, linguists or persons with experience in roloying. This 19 somowhot ak in to writing a medical manual on a surgical technique without sook ing the input of qualified medical experts or even on experienced sur son who has actually cut into a patient.

One of the worst problems facing any relay service is the lack of legal or bureaucratic precedent. As roley servicos are so unique and different from anything that has been dono boforo, there are no existing lows, rules, regulations or bur soucratic systems designed to 110 our unusual purpose and policios. Many problems ar 150 as a direct result of people trying to cram tho Roloy Service Into preoxisting categorios that don't apply to us.

We are not an answer ing service, we are not a long distance service and we are not on Information servico. We oro a unique systom comprised of humans and machines designed to rocilllate communication between two people who could not otherwise communicate over standard telephone lines. Our "Invisibility whlle accomplishing this must be acknowledged by those persons in positions or outhority over the services. They need to be made owore thet precedents nove to be set to 11t the Service. Instead of the Services and the community we are here to serve being hindered and frustrated by Inadequate and inappropriate lows and regulations. It is imperative that regulations de established to insure the door and hearing impaired community's neods and rights are respected.

The Dill louches on this briefly by prohibiting Relay Operators from disclosing the content of reloved calls. This is vitally important but the measuro is insufficient. The confidentiality of relayed conversations must be protected as privileged Information, Ine seme as doctor-potient or lowyer-client conversations are protected for any police officer to be able to walk into o relay service and insist on getting information regarding a call is ok in to obtaining evidence througn en Illegal wirelap. (Not to mention that it would rely on the memory of an operator who takes 30 10 40 calls a six-hour shirt and may novo roloyed ine call in question weeks or months beforo.)

Other problems nove stemmed from roloy servicos being treated as long distance carriers or recently (with Bell Allantic) as an information service because of the necessary translation between English and ASL.

Much of the longuage of the ADA dools with setting up seperate intrestalo and Interstate rolov service. Even o single nationwide system has been sugousted. This is unnecessary and potentialy wastoful. Currently all the services run by non-profit openclos oro providing both intra and Interstate service. (Using third-party billing for out-of-stato calls.) Collars in stolos with AT&T services cannot call out of their own state. The technology exists which would allow a coller at point (A) to call through o roloy service al point (B) to the destination at point (C) and only be charged for a direct-diol call from (A) 10 (C).

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We are currently using this system in Minnesota for in-stato toll colls (latcastoto long distanco). If Intorstoto corriors (AT&T. MCI, Sorint, etc.) would implement this system to function whenever tho Raley Operator dialed in a code orter eccessing tho long distance company's lines, this could be done for Interstate calls anywhore in the country, or anywhere in the world. However, no long distance carrier nos bothered to do so as the only people with an application for this function ore people calling through a relay service.

The Amor Icans with Disabilities Act of 1989 must be passed. The millions of door and hearing impotred people in this country have walled long enough for access to the communication equipment that neering people nove enjoyed all their lives.

I strongly Dellove Inot ino concept of consumer empowerment is integral 10 the spirit of the Americans with Disabilities Act. Door Americans and disabled Americans are not asking for "Dor ents" or pity, they are only saying inat everyone deserves an equal chance. Clearly Equal Access 19 every person's civil right, out until consumer controlled TDD/!elepnone reley services are available nationwide, the phrase Equal Access is just empty rhetor 1c.










H.R. 2273 and S. 933



SEPTEMBER 28, 1989

Serial No. 101-95

Printed for the use of the Committee on Energy and Commerce




For sale by the Superintendent of Documenta, Congressional Sales Office

U.S. Government Printing Office, Washington, DC 20402

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