In the Matter of: )

)

PUBLIC FORUM ON 711 ACCESS ) CC Docket No. 92-105

TO TELECOMMUNICATIONS )

RELAY SERVICES )

)

Pages: 1 through 117

Place: Washington, DC

Date: September 8, 1999

THE FEDERAL COMMUNICATIONS COMMISSION

COMMON CARRIER BUREAU

In the Matter of: )

)

PUBLIC FORUM ON 711 ACCESS ) CC Docket No. 92-105

TO TELECOMMUNICATION )

RELAY SERVICES )

)

Wednesday,

September 8, 1999

Federal Communications

Commission

The Portals Building

445 - 12th Street, S.W.

Washington, D.C. 20554

The meeting in the above-entitled matter was

convened, pursuant to Notice, at 1:15 p.m.

BEFORE: HELENE SCHRIER NANKIN

Moderator

APPEARANCES:

**FCC BOARD**

SUSAN NESS, Chair

Commissioner, FCC

**FCC PANELISTS**

YOG VARMA

Deputy Chief, Common Carrier Bureau (CCB)

KURT SCHROEDER

Acting Chief, Network Services Division (NSD), CCB

HELENE SCHRIER NANKIN

Senior Attorney, NSD, CCB

DAVID O. WARD

Senior Legal Advisor, NSD, CCB

APPEARANCES (continued):

**FCC PANELISTS**

JAMAL MAZRUI

Technology Specialist, NSD and Member

Disabilities Issues Task Force (DITF)

PAM GREGORY

Deputy Director, DITF

BRUCE FRANCA

Deputy Chief, Office of Engineering and Technology

MARTY LIEBMAN

Senior Engineer, Wireless Telecommunications

Bureau

**GUEST PANELISTS**

BRENDA BATTAT

Acting Executive Director

Self Help for Hard of Hearing

GIL BECKER

Director, Maryland Relay

BURT J. BOSSI

Product Manager, AT&T

TONI DUNNE

Training and Accessibility Program Manager

Texas 911 Commission

RICHARD ELLIS

Director of Strategic Alliances

Bell Atlantic

PAUL LUDWICK

Product Manager, Sprint Relay

WILLIAM McCLELLAND

Senior Manager, Global Relay

MCI WorldCom

APPEARANCES (continued):

KAREN PELTZ STRAUSS

Legal Counsel

National Association of the Deaf and

Telecommunications Consultant to the

Council of Organizational Representatives

CLAUDE STOUT

Executive Director

Telecommunications for the Deaf, Inc.

[C]{.underline} [O]{.underline} [N]{.underline} [T]{.underline}
[E]{.underline} [N]{.underline} [T]{.underline} [S]{.underline}

[AGENDA ITEM]{.underline} [PAGE]{.underline}

[Introductions]{.underline}

Helene Schrier Nankin, Moderator 6

Kurt Schroeder, Acting Chief, Network Division

[Opening Remarks]{.underline}

Yog Varma, Deputy Chief, Common Carrier Bureau 10

[Session 1: Technical Issues in 711 Access to TRS]{.underline}

Presentations by Guest Speakers:

[The projected costs of implementing an Advanced Intelligent Network
(AIN) based 711 system to]{.underline}

[access TRS and how those costs should be recovered.]{.underline}

Richard Ellis, Director of Strategic Alliances, 15

Bell Atlantic

[Procedures to ensure that TRS centers provide a]{.underline}

[choice of carriers to TRS users that will carry]{.underline}

[their TRS traffic from the TRS center to the]{.underline}

[called party.]{.underline}

Karen Peltz Strauss, Legal Counsel, National 18

Association of the Deaf and Telecommunications

Consultant to the Council of Organizational

Representatives

[AGENDA ITEM]{.underline} [PAGE]{.underline}

William McClelland, Senior Manager, Global Relay, 26

MCI WorldCom

Claude Stout, Executive Director, 79

Telecommunications for the Deaf, Inc.

[Implementation of 711 access to TRS on Commercial]{.underline}

[Mobile Radio Services (CMRS) networks.]{.underline}

Paul Ludwick, Product Manager, Sprint Relay 31

[The format that the Maryland Relay Center, in]{.underline}

[conjunction with Bell Atlantic, has chosen to]{.underline}

[provide 711 access to TRS, and the experience]{.underline}
[of]{.underline}

[other states that are implementing 711 access.]{.underline}

Gil Becker, Director, Maryland Relay 44

Burt J. Bossi, Product Manager, AT&T 40

[Methods to educate and provide technical]{.underline}

[assistance to the public about 711 access]{.underline}

[to TRS, including public service announcements.]{.underline}

Toni Dunne, Training and Accessibility 66

Program Manager, Texas 911 Commission

Brenda Battat, Acting Executive Director, 74

Self Help for Hard of Hearing

[P R O C E E D I N G S]{.underline}

(1:15 p.m.)

MS. NANKIN: My name is Helene Schrier Nankin. I\'m a senior attorney in
the Network Services Division of the FCC\'s Common Carrier Bureau. I
have been working on telecommunications issues for over 10 years. For
three of those years I have been working on telecommunications relay
services issues.

I will be moderating today\'s public forum on 711 access to TRS. I am
very excited about the excellent panel we have gathered here today,
which consists of leaders of the industry, government, and the community
who have dedicated themselves to making telecommunications accessible to
individuals with hearing and speech disabilities.

I will first give a brief background on 711 access to TRS and then
introduce the FCC staff that is seated around the table. There will be
brief introductions and opening remarks, and then I will explain the
format for the rest of the forum.

As I explained later I would like panelists to introduce themselves and
state their affiliations at the start of their presentations. I will
start with a brief background on 711 access to TRS. As many of you know,
in 1997 the FCC reserved 711 for nationwide access to TRS. What this
means is that once 711 is implemented nationwide, relay users will be
able to dial a three‑digit code, 711, to reach a TRS center within a
given state instead of having to dial the 1‑800 or toll‑free access
numbers that they currently dial in each states.

Because users only need to dial and remember a three‑digit code instead
of dialing and remembering separate, toll‑free‑access numbers to TRS
centers in each state, implementation of 711 access to TRS promises to
make TRS more readily accessible nationwide. Not only will having a
nationwide, three‑digit code significantly reduce the number of digits
that must be dialed when placing a relay call \-- it will eliminate the
problem of having to remember the appropriate local relay number when
traveling to different states.

At the same time the FCC set aside 711 access to TRS, the FCC recognized
that there were technical costs and competition issues that needed to be
resolved before states could implement 711 TRS access. So in 1997 the
FCC issued a further notice of approached rulemaking that sought comment
on these issues.

The FCC received several comments and replies in response to the further
notice. Many commenters stated that additional information was needed
before implementation could be published. Since the time the further
notice was issued, Maryland Relay has implemented 711 access to TRS, and
other states are moving toward implementation at varying paces.

We have called this forum of TRS users and user groups, state TRS
administrators, carriers, and FCC staff to gather information on the
remaining technical costs and competition issues that will help states
implement 711 access to TRS.

We would also like to discuss states\' experiences in providing 711
access to relay. We would like to identify the problems with
implementing 711 access to TRS and to encourage information sharing
among the states and carriers on solutions to such problems.

Our overall objective with respect to implementing nationwide 711 access
to TRS is to implement 711 quickly, efficiently, and with minimum cost
to carriers and states. Whatever format for 711 access to TRS is chosen,
it must comply with Section 225 of the Act and the Commission\'s rules,
which require carriers to provide functional equivalent relay service to
that provided to voice users.

I would now like to introduce the FCC staff on the panel to all of you.
To my immediate right is Yog Varma, who is deputy chief of the Common
Carrier Bureau, and to my immediate left is Kurt Schroeder, acting chief
of the Network Services Division. To his left is Jamal Mazrui, who is a
technology specialist in the Network Systems Division, who is also
working with the Disabilities Issues Task Force. To his left is Dave
Ward, senior attorney, who is also an engineer in the Network Systems
Division.

And to my right, to actually Yog\'s right, is Pam Gregory, who is the
deputy director of the of the Disabilities Issues Task Force, and to her
right is Dale Hatfield, who is chief of the Office of Engineering and
Technology. And then to Dale\'s right is Marty Liebman, who is senior
engineer of the Wireless Bureau.

Now, I will turn the forum over to Kurt Schroeder, who as I said, is
acting chief of the Network Systems Division.

MR. SCHROEDER: Thank you very much, Helene. My function right now is
primarily going to be just to introduce Yog Varma, but before I do that,
I would like to thank you all for coming here. It\'s fantastic to see
such a significant turnout for this discussion, and I hope that we will
all learn a great deal about the subjects we will be discussing.

I would also like to thank the many people on our staff who have helped
put this event together. For a three‑hour event like this we have had to
put in a significant amount of time preparing for it, and Deborah
Sabourin, who isn\'t up here with us, Dave Ward, Pat Forster, Marlin
Jones, Allen McLeod, Allen Thomas, and Macell Mora, with the exception
of Dave, none of whom are sitting here with us, have put almost as much
or probably more work into preparing for this than I have certainly, and
I thank them for this work. Jenny Kennedy especially has done a great
deal to help put this together, and I might also like to thank Pam
Gregory, who is over to my right, who has given us invaluable advice
about many of the details of manage this forum.

Now, I would like to introduce Yog Varma. Before joining the FCC a
little over a year ago as deputy chief of the Common Carrier Bureau he
was a senior official for several years, many years, at the New York
Public Utilities Commission, so without any further adieu, I\'ll turn it
over to him.

MR. VARMA: Thanks very much, Kurt. I appreciate it. Good afternoon,
everyone. On behalf of the Commission, first of all, let me welcome you
all to the forum this afternoon. The forum, as you know, is going to
focus on 711 implementation issues. I think the issues that we address
today are very crucial issues that affect the ability of the TRS users
to communicate effectively with everyone else.

Let me take you back, though, for a moment to the Commission\'s 1997
report and order back in February of \'97, about four and a half years
ago. That report and order and the notice of proposed rulemaking had
raised a number of issues. It had raised a number of questions. For
example, even the question of the technical feasibility of 711 had been
raised at that point in time.

It appears to me that in the last three and a half years at least some
of those questions have already been answered. For example, the
technical feasibility of 711 has already been answered, in my view,
because we have 711 deployment in the State of Maryland that was
implemented, I believe, earlier this year. The State of Hawaii also has
been able to deploy 711. In many parts of Canada 711 has similarly been
deployed.

I also gather that the Pennsylvania Commission has been working on a
plan and is inviting public comments on the plan before implementation
of 711 in Pennsylvania. The State of New Jersey is probably not far
behind.

I hope that with the experience in the State of Maryland, Hawaii,
Canada, Pennsylvania, and New Jersey, et cetera, we might be able to
move forward in more widespread deployment and implementation of 711.

711 TRS access is a very important step towards functional equivalency
with voice services. Yes, we have had toll‑free numbers like the 1‑800
types, but none of those numbers offer the convenience a 711 number. I
think it ought to bring TRS users on a par with the users of voice
services and the rest of society. It is important for us to move forward
as quickly as we can on 711.

Yes, there are a number of issues here in the forum today. There are
issues of cost recovery, for example. There are issues concerning
outreach and education. There are issues concerning technical
considerations such as whether we ought to use the Advanced Intelligent
Network or should translations be performed on a
switch‑by‑switch‑by‑switch basis.

There are numerous other issues dealing with implementation and
deployment, but, in my view, there is one issue that rises above all
others. That is the issue of widespread, nationwide deployment of 711 in
as expeditious a manner as possible.

It was two and a half years ago, as I pointed out earlier, that the
Commission reserved 711 for this purpose, yet really looking back, there
are only a handful of states and a small number of companies that have
actually employed 711. Even as the Commission indicated in the February
\'97 report and order, it is hoped that 711 could be deployed on a
large‑scale, widespread, nationwide basis perhaps in three years.

I think we could have done more. I think we should have done more. I
would have to compliment some of the local exchange carriers that have
taken the initiative in moving forward in the deployment of 711. I
really don\'t want to single any carrier.

I think it has been a cooperate effort, but really and truly, I think
Bell Atlantic has taken more of an initiative in moving these issues
forward, in addition the deployment of 711 in Hawaii perhaps under the
auspices of GTE. So I compliment the industry on moving forward, and I
hope that they can do it even more expeditiously down the road.

Once again, I\'m glad that you have joined us, and we look forward to
learning a great deal today from the distinguished panelists who have
taken the time to come and share their thoughts with us. Thanks very
much.

MS. NANKIN: I would like to start by explaining the format for the rest
of the forum. There will be two sessions which will last about an hour
each. We will have a short, 15‑minute break between both sessions.

The first session will concentrate on three topics. The first one is the
projected cost of implementing an Advanced Intelligent Network, or
AIN‑based, 711 system to access TRS and how those costs should be
recovered. The second topic will be the procedures to ensure that TRS
centers provide a choice of carriers to TRS users that will carry the
TRS traffic from the TRS center to the called party. The third issue
will be the implementation of 711 access to TRS on commercial mobile
radio services networks.

For each topic a panelist will make a five‑to‑ten-minute presentation.
After all the panelists have made their presentation in the first
session, other panelists will have an opportunity to add their own
points of view or ask questions. Questions may then be asked by the
Commission staff on the panel and then by members of the public in the
audience. We will address each issue in turn.

Because we have such an interesting topic, we have a lot of ground to
cover. We have to keep panelists to the ten‑minute limit.

In the second session we will follow the same format. We will address
the remaining four topics. First, panelists will make their
five‑to‑ten‑minute presentations, then panelists, followed by Commission
staff and members of the public, may comment and ask questions on each
topic in turn. I will ask each panelist at the start of their
presentation and anyone commenting or asking a question to first
introduce themselves by stating their name, title, and affiliation, and
give a little background on your company or organization. Finally, I
would like to thank all of you for attending the forum and strongly
encourage public participation.

And before we start the forum, Pam would like to say a few words.

MS. GREGORY: Thanks, Helene. In addition to everyone\'s comments, of
course, the DIT director, Meryl Icove, is not here. She is on vacation,
but I know that she passes her thanks and her greetings to everyone
here. And I wanted to recognize a very important group of people who are
not in this room, and maybe people here don\'t know about this, but this
is something that we\'re very, very proud of at the FCC, is that we have
a lot of people with us today via the Internet.

And it\'s very exciting because people can go to our special 711 page,
and they can listen via audio file or real‑time captioning, and we have
a special way that people can send in e‑mails throughout the whole forum
and join us, no matter where they are in the world. So I wanted to
extend a special welcome to anyone who is participating via the
Internet.

MS. NANKIN: Thank you. The first topic will be the cost of providing 711
access to TRS, and Rich Ellis will make that presentation.

MR. ELLIS: My name is Rich Ellis, and I\'m from Bell Atlantic. I\'m the
director of strategic alliances for Bell Atlantic, and in that
capability I\'ve served as a liaison to national disability
organizations and worked with these organizations on many policy issues.

I\'m very pleased to be here. Thank you for inviting us, and I\'m going
to try to set a good example for my counterparts by keeping my remarks
very brief, and I\'ll try to talk very, very slowly for the benefit of
the interpret irs as well, and hopefully we can cover all the ground
today we need to cover.

711 access to relay services first became an issue on our corporate
radar screen in about 1995, when Bell Atlantic of New Jersey received a
request from the State of New Jersey to implement 711. At that time we
reviewed the technological issues involved and determined that using our
Advanced Intelligent Network was the way to go. Now, for those of you
who are not familiar with telephone technology, this is simply an
additional layer of intelligent which rides on top of the network and
allows us to make changes to network services very economically and very
efficiently.

At the time, there were lots of uncertainties related to 711 access. For
example, the number, 711, had not yet been reserved by the FCC. So while
we knew we could physically do a 711 implementation, because of the
uncertainties we decided that it was not an appropriate time to do that.

Two years later, the FCC did reserve 711 as the official numbers for
relay access, and at that time we received requests from the State of
Maryland to implement 711 access to relay centers. So we reassessed the
technological issues involved and decided that it was time to move ahead
on this project.

In terms of costing, we determined the cost to be is where less than
\$100,000 per state. It\'s kind of hard to put an exact number on it
because the platform an already in existence, and it\'s just trying to
figure out what the incremental costs are for 711.

But when we did that we also made the policy decision that Bell Atlantic
would absorb the costs. It would be passed on to the states or to their
relay providers or the relay users. 711 was implemented in Maryland in
February of this year, and Gil will talk later on about the successes
there. I had the pleasure in July of that year to speak at the National
Association of the Deaf Conference and was able to announce that Bell
Atlantic was committing to implement 711 throughout our region, which at
the time extended from Maine to Virginia.

We have continued work on that process. As I mentioned, Maryland is
implemented today. As of today, the southern states of Bell Atlantic,
and someone once said, only in Bell Atlantic could New Jersey be
considered a southern state, but the states from New Jersey down are
pretty much ready to go from our side of the call. We could transfer the
call from the caller to the relay center. But this project requires
cooperation from a number of players, so although we are ready with our
piece, other people are still working on their pieces.

In the north part of the Bell Atlantic region, New York and New England,
we are still doing some final testing on the AIM platform, but we expect
to have that part of our region ready to go with 711 implementation at
the end of the year, early next year. And I think I\'ll just wrap up
right there.

MS. NANKIN: Thank you. The second topic will be procedures for ensuring
that TRS centers provide a choice of carriers to TRS users that will
carry their TRS traffic from the TRS center to the called party. We have
three speakers on this topic \-- Karen Strauss, William McClelland, and
Claude Stout. Karen Strauss will be the first speaker. Karen?

MS. STRAUSS: I\'m here today in two capacities. I\'m representing both
the National Association of the Deaf and the Council of Organizational
Representatives on National Issues Concerning People Who Are Deaf and
Hard of Hearing. The latter uses an acronym, CORE, and it is a coalition
of various deaf and hard‑of‑hearing service organizations and membership
organizations that advocate for the rights and interests of people who
are deaf and hard of hearing.

Carrier of choice has come to have two distinct meanings with respect to
TRS. Initially, this term referred to the right of a rely customer to be
able to choose access to his or her interexchange carrier. The FCC\'s
rules on TRS established this right and state, I quote, that \"TRS users
shall have access to their chosen interchange carrier through the TRS to
the same extent that such access is provided to voice users.\"

While this remains the law of the land, in practice exercising this
right has become a burdensome task. That is because in practice many TRS
users route TRS calls through their own long‑distance services. This is
a problem for two types of consumers.

First, there are many consumers that aren\'t even aware that they must
specify their long‑distance carrier with their relay provider. Although
many of these consumers have already chosen long‑distance carriers with
their local‑service carriers, they may not be getting their carriers of
choice if all of their incoming relay calls in their state are routinely
routed to the interchange company that happens to be the relay provider
for the state.

Second, a number of consumers report that they haven\'t been able to
exercise their right to choose their own long‑distance carrier. One
consumer has reported that he had to go through considerable effort to
change his carrier to one that he had chosen to begin with. Another has
reported that his relay service refused him the right to choose his
individual carrier on an individual‑call basis.

What does this have to do with 711? One of the important things in
implementing 711 is to make sure that when it is implemented that
consumers have the right to choose from their own interchange carriers.
Among other things, this will mean that where a consumer chooses a
carrier the TRS provider must be responsible for including the name of
that carrier in the customer\'s user profile.

When using 711 the customer should be secure in the knowledge that the
communications assistant receiving the call will have ready access to
information about the consumer\'s carrier of choice in the consumer\'s
profile. Similarly, if the consumer wishes to change the carrier on a
call‑by‑call basis, the technology should be in place to allow this
choice to the same extent that voice users have this capability.

There is a second meaning of carrier of choice with respect to relay
services. It also refers to the right to choose a TRS or relay provider
that actually performs the relay of the call. Presently, consumers have
the ability to make such a choice of TRS providers in California and for
intrastate calls, and it\'s only a matter of time before this capability
is spread throughout the entire country.

Both consumers and industry are eager to see increased competition among
relay providers. Increased competition can open the door to new product
and services innovation and improved relay quality. Relay competition,
which is also called \"multivendoring,\" follows the competitive trends
of the Telecommunications Act of 1996.

It promises to offer consumers choice in the relay features that best
suit them. It discourages monopolistic arrangements, and it encourages
telecommunications providers to consistently improve their services.
This will also become increasingly important as the types of relay
services continue to proliferate, including speech‑to‑speech relay
services, video relay services. It\'s only a matter of time before
certain relay providers develop specialties in one or another various,
very distinct relay services.

Implementation of the 7-1-1 code should be completed in a manner that
maintains and fosters relay competition. For example, 711 can be used
much in the same way that callers now use Dial 1 service for their
long‑distance carriers. Application of this type of service would allow
a customer to prescribe to a relay vendor from a home or business, and
hopefully the prescription would not automatically tie an individual to
only one\'s chosen long‑distance carrier.

The customer may prefer the particular features of a long‑distance
carrier to carry the call but a different relay provider to relay the
call. In addition, customers should have the option of dialing a
different number or an additional access code to reach a particular
provider if they are not at home, much in the same way that the public
now has the ability to dial around to one\'s long‑distance carrier of
one\'s choice through a 10‑XXX code or a similar telephone‑access code,
such as a calling card.

Enabling customers to prescribe to their referred relay provider while
enabling these customers to continue accessing a different provider when
away from their preselected phone will achieve a number of objectives.
First, relay providers will be able to compete for individual consumer
subscriptions.

Second, relay providers will continue to compete for state and regional
contracts so that they can serve as a default TRS vendor for those
regions. And then, of course, travelers when traveling would be able to
simply dial 711 and be assured access to TRS anywhere in the U.S.

And finally, relay providers would compete for business from consumers
who are away from that preselected phone, as these customers hopefully
would be able to dial either one of the currently existing national 800
numbers or an alternative relay code to access a particular local
vendor.

Alternatively, 711 could provide a gateway through which customers could
obtain access to multiple relay vendors on a call‑by‑call basis. This
gateway could even be used to access other disability services, such as
TTY operator services and perhaps video‑relay services. A gateway can
also offer one means of allowing a consumer to bypass a preselected
provider for certain calls.

Let me just state, that\'s my presentation on carrier of choice, and I
just also wanted to say, which I should have said at the beginning, I
would like to thank the FCC for holding this forum and greatly
appreciate the FCC\'s interest in seeing 711 expedited as a national
access code throughout the United States. Thank you.

MS. NANKIN: Thank you. Before going on to the next disappear, I would
like to recognize and introduce Tom Power, who is a senior legal adviser
in the Office of the Chairman.

MR. POWER: Thanks. Well, thank you, and the chairman asked me to come
down and say a few words on his behalf. Unfortunately, he couldn\'t make
it today due to some conflicts, but Pam sent him an e‑mail last week
reminding him about this and reminding him of his conflict, we both got
a terse reply, which was brief me on this as soon as possible. So he is
taking in what\'s going on here, and I\'m really glad that we were able
to put this on.

I also want to say a welcome to the folks who are participating via the
Internet and invite them to talk back to us via the e‑mail capability
that I understand they have and let us know anything they\'ve to add
with respect to this proceeding and all our issues regarding
disabilities.

These disabilities issues are really, really important to the chairman.
I can give you any number of examples of how I see that. One is he goes
and speaks to forums like this and conventions, whether regarding
disabilities or other issues, but when he accommodation back after
talking to the disabilities groups and forums I can\'t tell you how
pumped up he is, because it is so easy to see how much progress we can
make in these areas.

We talk a lot about the modern telecommunications networks and services
and everything that\'s available, but it\'s only valuable to the to the
extent that people can use it and only to the extent that everybody can
use it. We have a long history in this country of universal service as a
means of getting services to people in remote areas and in areas where
it costs a lot to serve and to people of low income, but, of course,
that\'s great for those folks, but there are lots of other Americans who
need assistance and service in other ways, and this really is at the
heart of a lot of what the chairman is focused on.

In July we adopted rules pursuant Section 255 of the Act, and I can tell
you that was, I believe, his proudest moment since he has been here. He
is really enthusiastic about these issues, and I know he is really glad
that you all are meeting here today, and thanks to folks like Pam
Gregory from our disabilities task force. I\'m glad to see Jamal here.

We\'ve got a great crew here, and not to pat ourselves on the back too
much, but I do want you to know, and I want them to know how much the
chairman appreciates their help. And particularly on the issue of 711
for TRS services, it just makes as much sense.

Pam was sharing with me some of the numbers from the experience in
Maryland with 711 and how prior to 171 about 75 percent of the TRS calls
were made by people are hearing disabilities. After 711 folks without
the hearing disabilities are making much more of the calls, much more
than they used to make. And, of course, the reason is obvious. If
you\'ve got the disability, and it\'s your only way to make a call,
you\'re going to do it.

For folks who don\'t have disabilities, maybe they don\'t make the call,
but once you use 711 then it makes the call that much easier to make,
you\'re going to see those calls being made, and that, of course, is a
huge improvement.

And I did want to recognize the folks from Maryland at the Office of
Telecommunications Access because I know that they have really been on
the forefront of this and looking into the availability of choice among
long‑distance carriers over TRS, which, of course, is another big issue
that we need to be focusing on, as we just heard.

So I didn\'t want to take up too much time here, but I did want to
express to you the chairman\'s strong commitment to making sure that the
development of new services and new technology and the introduction of
competition, which as the previous disappear was just saying, is at the
heart of what we\'re doing in all the respects, those benefits have to
come to folks with disabilities, too. So thank you for being here, and I
appreciate you taking a little pause here to let me send you the remarks
from the Chairman. Thanks.

MS. NANKIN: Thank you very much, Tom. We will pick up with the second
topic, carrier of choice, and the next disappear will be William
McClelland.

MR. McCLELLAND: Thank you. My name is William McClelland, and I\'m the
senior manager of technical aspects at MCI WorldCom\'s global relay
platform, basically just an engineering kind of guy.

MCI supports 711. We are currently working with Vista IT, Bell Atlantic,
and State of Massachusetts, for implementation in the State of
Massachusetts. It\'s going to reduce confusion in traveling. It\'s going
to facilitate matters for people who didn\'t want to learn the 800
number access. So 711 is supported and looked forward to by MCI. It
provides more functional equivalency for the platform itself.

However, single‑access 711 does present its own set of obstacles. It\'s
going to increase protocol negotiation time and delay call processing in
states that have multiple‑access numbers presently. It\'s going to
increase time to get there.

It\'s going to increase the number of instances where hearing users and
relay operators will be subjected to TTY nasty tones directed into their
ears. So we\'re looking at those aspects. And it doesn\'t address ‑‑
three‑digit 711 does not address a multiple‑vendor environment. It
considers no selection process.

There are voice-automated, as proposed in New York and Pennsylvania,
which has its own aspects and obstacles to overcome. A lot of outreach
and education needs to be done for the users who will have to interact
with a voice‑response unit, and they can\'t hear it in the first place.

So those things have to be taken care of, and scripting would need to be
standardized across the entire platform. And the FCC doesn\'t currently
voice‑intercept, inbound calls, and many state contracts forbid voice
intercept. So a lot of those things have to be looked at.

We\'ve looked at profiling users. We would need to profile everybody
user that\'s on or would use the platform, to provide a faster access.
If you dial 711, you have a profile, we recognize your ante, it would
allow for much faster access and connection times. But it doesn\'t
address things like a multiple‑use household where one user dialing the
711 is deaf, the other user in the household needs voice connection. So
we still have the negotiation time between the two, and you have to look
at it that way. And it doesn\'t address common‑use phones like pay
phones and PBX systems.

Let\'s get on to part two here. If we use 711 in a three‑digit‑dialing
plan, carrier of choice in a multiple‑vendoring environment is going to
very difficult. You\'re going to have to use some sort of testimony so
provide a choice to the subscriber. If it\'s a voice subscriber, you
have many, very fast systems that can do that. A text‑based subscriber
would be slowed down through the system, and again you have outreach and
education.

Carrier of choice on the back end, for people who want to select a
different carrier for interstate or intrastate phone calls is something
that we do across our platform today, and it\'s not viewed as a
difficult situation at all. There are some aspects where we have to go
beyond the normal to get there, where you have a small, long‑distance
provider on the other side of the state, that it\'s common for those
folks to handle, and it may not be convenient for you to do, but we\'ll
provide it.

Other than that, that\'s about it. We\'re ready for 711. We are ready
for Bell Atlantic and in Massachusetts and to provide it in any other
state that\'s ready to do it. Thank you.

MS. NANKIN: Thank you. The next speaker will be Claude Stout, and he
will be the last speaker this on topic.

MR. STOUT (through sign interpreter): Okay. Thank you, Helene. My name
is Claude Stout. I\'m the executive director of Telecommunications for
the Deaf, Inc. On the subject of carrier of choice, Karen really hit a
lot of the points that TTY is pursuing, so there really is no point for
me to repeat those. I would like to add certain points.

Carrier of choice is already complicated by itself, as Karen already
pretty much already explained. Those of us that are deaf or hard of
hearing or lay deafing, deaf‑blind, compared to people without
disabilities, we are entitled to have various access choices as to how
we use carrier of choice. It should be up to us. We don\'t want to be at
the mercy of the system. We want the system to fit our needs, not the
other way around.

It\'s very important that when we want to have carrier of choice that we
have the preference on a presubscribed basis or on a call‑by‑call basis
or whether we use one that we stick with over a certain period of time,
stick with our long‑distance carrier. Those choices should be made by
us, and they should not be limited. They should be more various.

My section and last point that I want to stress is that the complexity
behind the carrier of choice requires intensive outreach, intensive and
pervasive outreach, whether it be activities in programs on what have
each state at their TRS relay administrators and those programs.

Each state has the responsibility to work with the TRS providers to do
good outreach and provide such programs for deaf and hard of hearing,
lay deafing, and deaf‑blind individuals. They all deserve constant
education own how they can use carrier of choice, and that issue still
remains to be a complex issue. They are afraid to use it. They don\'t
know, but if we educate them and explain to them how it works and
broadcast information on televisions and so forth, they will understand
what it means to use carrier of choice. And that\'s basically it for my
comments. Thank you.

MS. NANKIN: Thank you, Claude. We will now go to the third topic, which
will be 711 access to commercial mobile-radio services, and Paul Ludwick
will make this presentation.

MR. LUDWICK: Thank you, Helene. My name is Paul Ludwick. I\'m product
manager for Sprint\'s relay drive. When I came here today, I think I
misunderstood the format a little bit. I thought we were going to get a
chance to speak on all of the topics rather than one selected.

MS. NANKIN: Let me interrupt for one second, if you will.

MR. LUDWICK: Okay.

MS. NANKIN: And the way that you will do that is after we complete this
‑‑ after you make your presentation, we will open it up for comments and
views and questions on each of the topics in turn, so you will.

MR. LUDWICK: This is going to be short, because this is the one topic
that I know the least about. In terms of implementing 711 on a cellular
packet data number, I think the carriers, the CMRS carriers face similar
challenges to those that are faced be the local exchange networks \--
Where to put the functionality, which layer do you put that in? As Rich
stated, you put it up in the higher level, for the intelligent network.
You push it down to the bottom level where the physical switches reside.
I think that\'s a question that needs to be answered there.

I think the CMRS carriers also face some unique challenges, and those
are mainly related to their footprints. Whereas most of the operating
companies have regionalized services, the cellular companies are more
nationwide in nature. What they tend to follow is geographic and
population patterns of the country. So they cover a lot of area, some of
it sparsely, but they cover it. So they have a large area that they need
to modify.

And I think that gives them ‑‑ it could incur a cost‑recovery issue with
them. If we go by Rich\'s number \--I think you mentioned that you
estimated \$100,000 per state \-- I don\'t know if that\'s realistic to
think that that\'s the same cost that would be incurred by a cellular
company, but I think you could probably use it as a rule‑of‑thumb until
you do the proper analysis to determine the exact cost.

So Sprint, for example, has presence with its cellular product in over
20 states. So if we just do the simple math on that, we\'re talking
about a multimillion‑ dollar figure. So I think that they probably need
to have some guidance how they go about recouping their costs for doing
the implementation.

And one other aspect that may or may not be true for an individual
company may be the use of a 7-1-1 code within a handset and within the
switching system. In a lot of cellular systems they were implemented
before 711 was reserved.

So you can use ‑‑ the economy of the airwaves is one of the things that
the cellular companies try to focus on, how do you get the most calls
through the bandwidth that they are allocated? So a lot of them have
gone to abbreviated dialing tones, or some of them have gone to
abbreviated dialing tones, meaning, for example, if you want to reach a
cellular customer care organization, you may do a star‑two on your pad,
but that\'s not what\'s sent to the cellular switch.

In some cases that code could be 711. So, making for abbreviated‑dialing
purposes, they could either send the full 10‑digit number back, or they
couldn\'t use an abbreviated pattern that lets them send less digits and
ultimately use the bandwidth more efficiently.

So I think that\'s two of the major areas that they have as possible
handset modifications and modifications to the switching pattern. And
I\'m sorry, but that\'s the sum total that I have to offer. Thank you.

MS. NANKIN: That\'s good. Thank you. Now, I\'d like to open the first
topic, which is cost of providing 711 access to TRS to the panelists and
see if anyone has any comments, questions, wants to voice their views on
what Rich Ellis had said about the cost of providing 711 access to TRS.

MR. VARMA: My question is for Rich Ellis. My name is Yog Varma. Rich,
you mentioned earlier that voice and data network platform, that it is
undergoing some testing in the Bell Atlantic North or United\'s region.
My question is that my question is that the Advanced Intelligent Network
infrastructure and platform are pretty much the same in both Bell
Atlantic South and in the Bell Atlantic North Region. Why do you
consider it necessary, then, to have to undertake tests in the Bell
Atlantic North Region?

MR. ELLIS: My understanding ‑‑ I\'m going to turn to Trish Smith over my
shoulder, just to confirm this, is that Bell Atlantic South, the old
Bell Atlantic region, was further long in the deployment process of our
burden of AIN, and with the merger there was a need to standardize north
and south, and that process was a now undertaking. It\'s just the
standardization of the platforms between Bell Atlantic\'s region and the
old Bell Atlantic region.

MS. SMITH: We\'ll do our testing on what\'s called next‑generation
platform and AIN, which all of the AIN platform in the North is on
next‑generation platform. We have to be assured that that\'s compliant
and has been tested in lab before we implement 711 in the North.

MR. VARMA: Okay. But I guess my question still is that this underlying
platform comes from the same manufacturers like Lucent, Nortel, et
cetera, with certainly software imposed on them. So I\'m not totally
clear yet on why additional testing is required in the Nynex region. Can
you amplify that, or did I miss your point?

MS. SMITH: Well, you are correct in your perception that we are using
the same switches. There are two platforms out there though, current
generation and next generation platform, and the next‑generation
platform, if I\'m remembering correctly, involves a certain version of
the ISCP. So we have to make sure that everything meshes together and is
working on the next‑generation platform before we turn things up in Bell
Atlantic North. Does that answer your question?

MR. VARMA: I think it does. Let me just follow that up, though. In your
written comments you have indicated that you are ready to move forward
rather quickly in implementing 711 not only in Pennsylvania and New
Jersey, but also in D.C., in Virginia, and West Virginia. You also
mentioned Maine, Vermont, and Rhode Island, which are some of the Bell
Atlantic North states.

You did not mention anything about the States of New York,
Massachusetts, or New Hampshire. And I was wondering if you can amplify
on your written comments and give us some idea as to when you might be
able to move forward on 711 in the States of New York, Massachusetts,
and New Hampshire.

MR. ELLIS: Those states will all be ready to go from our perspective, at
the end of this year, early next year. The other piece of the puzzle,
however, is that the relay center has to be ready on their end.

Maryland was an easy state to implement relatively speaking because,
first of all, there was only one other telecommunications carrier in
Maryland. Maryland already had 10‑digit dialing, which means there will
be fewer misdialed calls with 711, so it\'s just an easier process. And
also they were using the single number for voice and text users already.

The other states in Bell Atlantic use straight numbers for voice and
text, so to put a single‑number solution in that would serve all
customers takes more time on their end, and my understanding is that
there is some ‑‑ just as we faced uncertainty back in 1995, they are
facing uncertainty now in terms of how they implement their solution
given the fact that there\'s no real guidelines from the FCC.

So that\'s the cause of delay. But we are ready to go on our end in the
South now and expect to be ready to go on our end in the North at the
end of this year, early next year. And once the states and the other
carriers are ready to go, we can make the connection.

MR. VARMA: Okay. So, in other words, throughout the Bell Atlantic
region, north and south, it is your assessment that from a technical and
administrative and operational point of view Bell Atlantic will be ready
to deploy 711 throughout the region by the end of this year.

MR. ELLIS: The end of this year, early next year. We can get their calls
from the user to the relay center at that point on.

MR. VARMA: In other words, your end of the work that needs to be done
will have been completed by the end of this year or early next year.

MR. ELLIS: Yes.

MR. VARMA: Of course, I realize that other things have to come into
place as well.

MR. ELLIS: Yes. That\'s correct.

MR. VARMA: Rich, I was wondering if you could also amplify for us,
please, if in these 711 calls, based on the Advanced Intelligent
Network, does the person making the 711 call transmit his or her ANI?

MR. ELLIS: Yes. My understanding is that all of the ANI information
passes the relay center. My understanding was everything we get in a
transitional 800 call would also go through in a 711 call.

MR. VARMA: Okay. So the TRS would receive the ANI of the caller.

MR. ELLIS: Yes.

MR. VARMA: One final question. There are a couple of different types of
technologies or approaches that were, I believe, considered to provide
711, Advanced Intelligent Network being one of them. The other one I
believe I mentioned earlier is translations on a
switch‑by‑switch‑by‑switch basis.

I take it that you examined both of these technical possibilities and
compared their technical and economic capabilities and conversations and
then concluded on that basis that the Advanced Intelligent Network was
the superior of the two.

MR. ELLIS: Yes.

MR. VARMA: Okay. Thanks very much.

MR. WARD: I just want to make a comment. My name is David Ward, and I\'m
with the Federal Communications Commission, Network Systems Division. I
wanted to point out to the state representatives that whether or not the
state selects a particular technology or the state\'s local exchange
carrier selects a particular technology, when the customer dials 711
they will reach a telephone relay service center. The choice of
technology, AIN, may have certain cross‑benefits over a switch‑based
technology, but both of them will do the job.

MR. VARMA: Dave, the switched‑based technology, is the AIN transmitted
to the TRS?

MR. WARD: Yes, sir. The AIN and the switched solution will both
transport in‑band signaling, which ANI will include. Common carrier
signaling out of band is an issue before the Commission one of our
proceedings right now.

MR. VARMA: Thank you.

MS. NANKIN: Kurt, do you have any questions?

MR. SCHROEDER: Yes. For, again, Rich Ellis or anyone else who would like
to jump in, Rich, you mentioned that the cost per state, you estimated,
was about \$100,000, which appeared quite reasonable to me, and I guess
to you, and the company since you\'re going to absorb it.

Now, you said that in states where you\'re ready, are you, Bell
Atlantic, are ready to implement technically that in some cases the
states and or the relay providers need to do more to get ready. What do
you think, if anything, is holding them back from taking those
additional steps that Maryland and Pennsylvania, I guess, we\'re looking
at Massachusetts doing that, too, are starting to take?

MR. ELLIS: I think the question could probably be better answered by the
relay centers and the relay providers. My understanding is that it\'s
just a matter of certainty, of ensuring that if they do some work now,
the rules aren\'t going to change down the road and cause them to undo
things. With the AIN platform we made an investment in implementing 711,
but it was a reasonable investment, and our part of the transition is
fairly straightforward. It gets a little bit more complicated at the
other end of the call, so there is a lot more certainty.

MR. BOSSI: Kurt, that\'s a good question. My name is Burt Bossi. I\'m
product manager for AT&T TRS, and I wrote a few comments down regarding
this issue this issue. For TRS providers the cost of a switch‑based, 711
solution should be eligible, unless the provider differentiates its user
base through multiple toll‑free numbers or the provider makes their
service available on a state‑by‑state basis versus national. That could
also add costs.

If either were the case, the TRS provider would have development costs
associated with the engineering changes, and that\'s necessary to
differentiate their user base with a single toll-free number, or the 711
translation, without disadvantaging the answer time, which Mr.
McClelland mentioned earlier. Some providers have originally decided to
service their user through multiple 800 numbers to get the quickest
connection time, data or voice. We were using the network, the multiple
800 numbers, to differentiate these users. With 711 the onus now becomes
our responsibility to differentiate.

So in summation, if a state currently supports their user base with a
single toll‑free number, the TRS provider is differentiating or
separating with the voice or data user after the call arrives at the TRS
center. If the state currently supports users with multiple toll‑free
numbers, the user is being differentiates within the network based on
the dialed number. This allows the TRS center to answer and service the
user quicker and in the appropriate mode. For TRS as it relates to AT&T
and 711, the cost of these changes currently are managed internally.

So as others mentioned today, there is a number of elements that have to
be changed in the network, in the providers, and in the outreach of the
users, the knowledge base, to make the entire 711 work. When AT&T
finishes its data testing and it rolls its 711‑ready system, it will
roll out nationally, and so all of our states will be ready almost in a
flash cut. We will not be rolling out state-by-state.

MR. VARMA: Burt, the question that I have for you is that some of the
preflight comments that he have received there is some discussion that
we ought to consider the dialing of fourth and fifth digits to further
direct the call in a certain manner. In other words, one could possibly
be two more digits after 711.

My question is that depending on whether a carrier uses the Advanced
Intelligent Network platform or switch‑by‑switch translating, is it
going to be equally difficult for the callers to be able to dial the
fourth or the fifth digit, or is it easier one than the other?

MR. BOSSI: From a provider standpoint if the network folks, the LECs
involved, can do the difference of users for us and deliver the voice
customers to one number and the data customers in another, it becomes
much easier for us. That\'s pretty much the summary.

The fourth and fifth digit, I don\'t think that\'s a concern to the
user, and if we study prior art from the patent office, in 1995 there
were three patents that had originated related with 711 and a full
dialing string of the called party all as one number, where the network
intercepts 711, sends the user to a relay provider, and then the relay
provider already has the 10‑digit number to follow. So there is prior
art related to that from \'96, I believe, \'95 or \'96.

We can do it either way. If the network doesn\'t differentiate, we do.
That\'s the bottom line. What we\'re trying to do is minimize the amount
of seconds it takes for us to differentiate the customers because it
becomes a task. And to our users who are used to being answered quickly
and in the appropriate mode and in the appropriate protocol, it will add
somewhere between five and ten seconds.

MR. VARMA: Okay. Just to sum it up, then, as best as you can assess,
whether a carrier uses the advanced technology network or
switch‑by‑switch translation, it will be possible for the network to
accept the fourth and fifth digit \-- should that be the approach a
state may adopt.

MR. BOSSI: Yes. I would agree.

MR. VARMA: Thank you.

MS. NANKIN: Kurt, do you have any more questions?

MR. SCHROEDER: Yes, I do. It\'s fair to say that ‑‑ well, correct me if
I\'m wrong. I guess it\'s fair to say that cost really isn\'t an
obstacle at this point to implementing 711 in any state? Anyone? Paul?

MR. LUDWICK: The point of view where the recipient, I guess I would say
cost, and the scope of implementing 711, the cost to the relay provider
is really very insignificant compared to the cost of implementing it in
the network. As Burt mentioned, calls to the relay are presented when
the customer dials 711, the local change company or cellular company
retranslates that number to an 800 number.

So for all intents and purposes, for the relay provider it\'s simply
establishes another 800 number or using an existing one, which makes it
simpler but less easy to track, and doing the file maintenance and the
implementation detail that you would typical do at any time when you
implement that type of service \-- testing, followup, verification, that
type of thing. So from the relay‑provider point of view, the cost is
relatively small.

MS. NANKIN: Can I interrupt for one second? Anyone that\'s speaking,
please identify yourself before going on. Just give your name and state
your affiliation.

MR. SCHROEDER: Gil, I think you had a followup.

MR. BECKER: My name is Gil Becker with the Maryland Department of Budget
and Management, responsible for the Maryland Relay. Rich mentioned that
the cost was something under \$100,000 for the implementation, and
getting the technology work is great, but educating the users that there
is availability is important, too. This afternoon I\'ll be giving a
little presentation on some of the outreach efforts we\'ve done,
educating the public, and those costs were close to \$100,000 as well,
to get the word out. So those costs need to be considered.

MR. SCHROEDER: Yeah, I think, Gil, you\'ve anticipated my next question,
which was if implementation costs are not an obstacle, what other costs
are there that might create an issue for states that are still looking
to implement 711? Yes.

MR. McCLELLAND: Bill McClelland, with MCI WorldCom. To answer a couple
of those questions, as far as costs that aren\'t upfront,
get‑the‑system‑ready costs. We\'ve touched on ‑‑ Rich touched on just
briefly and may have missed that, and that\'s a thing that happens in
the system where we inadvertently drop the first digit dialed, and we
end up with a lot of misdialed numbers hitting the platform, or we
increase the amount of time it takes for the setup of the call. Both of
those are incorrect costs to the relay provider, in that it takes us
more human power to facilitate the same amount of relay time in a
situation where we have more misdialed numbers and longer connect times
in that area.

To your previous question about why Bell Atlantic and ‑‑ because I
brought up Massachusetts and that we\'re working on it ‑‑ Bell Atlantic
is not the only LEC provider in the State of Massachusetts. So
coordination for when you take a state to 711 has to be made across
every LEC provider, or you will have people dialing 711 and it\'s not
going anywhere. So there\'s multiple LECs that are involved, and so
there is cost to each one of those LECs to do that work.

MR. SCHROEDER: Are you finding that there is any resistance on the part
of any of the LECs to ‑‑ is varying those costs to make 711 a
possibility?

MR. McCLELLAND: This is Bill McClelland again. We really haven\'t found
any resistance to it, but the coordination effort is yet to be
determined. Who is going to do that? Is it the state\'s responsibility
to coordinator 711? Is it the FCC\'s directive to implement 711?

Is it the relay provider\'s responsibility to coordinator all of the
LECs, because we have to be able to receive whatever they dial us, and
we have to tell them what we want ‑‑ where we want it sent type of
thing? So there is a vast amount of coordination effort when you start
including multiple LEC providers.

MR. WARD: I wanted bring out another point recommended to Yog\'s
question to Burt earlier. I think that the answer given by burt to the
direct question involves other things that are before the Commission
right now, particularly concerning follow‑on digits, abbreviated
dialing, and the ability of using a code, a routing code like 711, to
initiated a second dial tone or a tone that will lift more digits dialed
for additional routing.

I think that theoretically it\'s possible, but implementation on a
universal basis will create considerable cost conversations by all
carriers and switch manufacturers that have not been addressed yet. So I
want everyone here not to leave thinking that this is as clean as it
sounds. It was a direct answer to a direct question. I\'m not disputing
its veracity, but I think there are additional issues that are before
the Commission now that will come out and identify all of the external
issues.

MR. VARMA: I have my own doubts as to how the network would function,
because it is quite possible that after the switch receives the two
digits, 711, that under certain circumstances it may conclude that it
has all of the information that it needs to switch the call. And,
therefore, it is possible that any additional digits that you might dial
after 711 may take you nowhere at all, and those will be superfluous or
digits that the network would not need.

And I would invite anyone in the audience to be able to share with us
any thoughts on this issue of how the network would operate when fourth
and fifth digits are dialed after 711. Would the network accept them and
report that information to use, or would the information be considered
superfluous by the network and would not be of any use at all?

I know, for example, that when people dial 911 the call will go through
right away. The switch doesn\'t wait there, expecting to receive more
digits or something like that. Can anyone comment any further on this
about the use of the fourth or fifth digit after 711?

MS. NANKIN: Rich, do you want to comment?

MR. ELLIS: It\'s Rich Ellis from Bell Atlantic. I want to make a quick
comment on Kurt\'s comment earlier. I want to caution that although the
cost was less than \$100,000 for the AIN platform, I don\'t think you
can extrapolate that to a switch‑based platform, and I\'m not ready to
speak on that, but you might want to double‑check with some of the other
carriers on that.

MR. WARD: Right. I think that\'s true. I think that the fact that Bell
Atlantic had a robust AIN platform to begin with meant that some of the
costs happens adopting 711 to it made it incrementally cheaper than as
if they had to invest in AIN in total before standing up 711. Here
again, if we have a state that has a lessrobust network or has a local
exchange carrier with one, then to go to universal AIN platform in that
state may be cost prohibitive for certain carriers.

MS. SMITH: Three digit versus four‑or five‑digit. With AIN we use
what\'s called an ‑‑

MS. NANKIN: Excuse me for one second. Can you first identify yourself?

MS. SMITH: I\'m sorry. I\'m Trish Smith with Bell Atlantic, and I\'m
addressing the subject of the three‑digit versus four‑or five‑digit
dialing for 711. With AIN we use what\'s called the \"N11 trigger.\"
It\'s the same trigger that\'s used for 911 or 311. So I believe that
that would mean we could only use three digits. And I could certainly
find out more, but I just wanted to caution that I don\'t believe the
AIN platform would support the four or five digits. I\'m not sure.

MR. LUDWICK: Paul Ludwick for Sprint. The reason that the numbering plan
in North America stays away from area codes that are 911, 311, 511 are
so that you don\'t have to make a decision based on time or lack of
digits. You make a decision based on what you receive, the N11, and the
call is placed.

MR. WARD: Yes. It\'s Dave Ward again from the Network Systems Division,
FCC. We went through some of this agony with the conversion from
three‑to four‑digit carrier identification codes, where in theory if the
three‑to‑four‑ digit conversion went too long, we would start having
dialing conflicts. One of the ones we pointed out came from a
manufacturer where people calling Switzerland would wind up getting
Klamath Falls, Oregon. So, I mean, it can get very complicated, and
that\'s why we are in a unique position here to identify all of these
problems so we come out with a common ground that everyone can live
with.

MS. NANKIN: Kurt?

MR. SCHROEDER: One last question. This is our, I think, first question
that we received via the Internet from a Mr. Jim Gorman. I think we\'ve
addressed this at least in part, but I wanted to raise it in case anyone
had anything else to add. The question is, what is required of a TRS
provider to implement 711? And I think he means via AIN in Bell Atlantic
territory. Rich, do you have anything to add?

MR. ELLIS: It\'s more a question for the relay provider. We deliver the
call to the provider, and then they that\'s how they understand it at
their end. So, Burt.

MR. BOSSI: This is Burt Bossi with AT&T, as one of the providers in Bell
Atlantic territory. Currently, we receive our users through multiple
numbers. With 711, we will receive all of the customers through a single
number. That differentiation is the cost for us. Paul can speak to this
for Sprint, but they receive all of their users already with one 800
number, so there is very little for them to do. There\'s more things for
providers that service their customers with multiple 800 numbers.
That\'s pretty much it.

MR. SCHROEDER: Paul or Bill McClelland, do you have anything to add?

MR. McCLELLAND: Bill McClelland with MCI. Basically, Burt said it in a
nutshell. The difference is going to be the impact to the customers, in
effect that they are used to being connected very quickly and the same
way every time by dialing that differentiating access number. As soon as
you compile all of the access numbers into a single access, we increase
the amount of time it takes to go through and get them connected
properly, and you impact the user themselves.

If it\'s a voice user and you answer the call in either ASCII or Baudot,
they may think that they have a fax line or a modem lines just hang up.
If it\'s a TTY user and they are greeted in voice and in ASCII and then
finally in bar doe, you have to go through all of those series, and you
have to ‑‑ until they finally get down and get connected, where if they
were dialing the direct‑access number, they are connected immediately.
So there\'s those items.

MR. SCHROEDER: Paul?

MR. LUDWICK: Paul Ludwick. Could you repeat the question?

MR. SCHROEDER: Yes. It\'s required of a TRS provider to implement 711.
I\'m assuming he means via AIN in Bell Atlantic territory.

MR. LUDWICK: That\'s what I thought. And I guess it really depends on
whether the relay provider uses out‑of‑band signaling, which I typically
equate with AIN functionality. I can tell you that Sprint does not at
this time. We use in‑band signaling, so if that\'s what Jim is referring
to, I would say that would be very difficult for us to do. I don\'t know
about the rest of the folks here, but we rely on our present relay
platform uses in‑band signaling, so that would be the only way that we
could implement it. And, again, we would simply implement it as a
recipient of information.

MS. NANKIN: Thank you. Are there any other comments or views on the
first question related to cost from the audience or the panelists?
Sunny? Please identify yourself first.

SUNNY (through sign interpreter): Yes. My name is Sunny, and I come from
the Consumer Action Network, and I have a question about the pricing.
We\'ve been discussing the cost in a single‑vendor environment. Now,
suppose we are in a multivendor environment. Would the cost be the same
for that?

MS. NANKIN: Would anyone like to take a shot at answering this? Okay.
Paul?

MR. LUDWICK: Paul Ludwick with Sprint. This is based on a high‑level,
limited‑dollar local network. I think the answer is, yes, it makes it
substantially more difficult and expensive to implement because at this
time I\'m unaware of anyone that has any type of screening or call
routing other than point-to-point based on N11 coding. I guess what I\'m
saying is you would have to tie something like a relay carrier
preference to the customer\'s line when 711 is dialed, and I\'m unaware
of anybody that has done or is doing anything in that area.

MR. ELLIS: This is Rich Ellis from Bell Atlantic. Just to agree with
that, it would be incredibly expensive to go back and program each
individual caller preference. It would be a much higher cost than just
borrowing one number for all 711 calls to be directed to.

MS. NANKIN: Burt Bossi?

MR. BOSSI: Burt Bossi, AT&T. I think the analogy is as a user you are
picked to a long‑distance company, and so the local network has a
profile of you. And what we\'re talking about here is a dual pick or a
triple pick to each person\'s name. Huge databases that have to be
administered first created. So, yeah, expensive, very expensive.

MS. NANKIN: Does anyone else from the audience have a question or
comments on this issue?

MR. WARREN: Gary Warren from Hamilton Relay.

SUNNY: I\'m sorry. I just wanted to add, I\'m understanding right now in
California they have a multiple vendor system. Now, will 711 apply to
that state, or how will it apply to that state if they have that type of
system? And will it cost too much?

MS. NANKIN: William, do you want to answer that question?

MR. McCLELLAND: Bill McClelland with MCI World com. Since Paul jumped
the first time, I\'ll take this one. Sprint and MCI right multiple
vendors, with other companies looking to come into California today. 711
is being looked at in California, and one of the initial solutions that
they are looking at is a state gateway, is the easiest way to talk about
it, is a state gateway that would, like one for one provider, two for
the next provider, three for that one, but there is a lot of
coordination effort in that competition is good, but who gets to be
number one, who gets to be number two, who gets to be number three, so
on and so forth down the line there. And all of that has not been worked
out yet.

That would take care of issues like pay phones and common‑use phones
like PBXs and office systems and that type of stuff. Presubscription or
preselection based at LEC is a way to take care of someone at home that
has a fixed ANI, but, again, you\'re talking multiple picks for an
individual number, more databases, more expense in there. It doesn\'t
take care of common use, so you\'re looking at either an upfront gateway
or an extended number of digits.

You were asking about the number of digits, the fourth and fifth digits.
The switches can be programmed to do a lot of different things. If you
went to a fourth and fifth digit, you probably wouldn\'t put that behind
the 711. You would have to put it front of the 711, like 10‑10‑whatever,
only it would be some other type of that type of dialing, so that you
didn\'t get cut off with the 711. But it\'s not something that is in the
system today; it\'s something that would have to be decided upon and
worked upon industrywide and accepted as a standard and then built into
the switches.

So multivendoring in 711 is a very difficult proposition, and it really
has not been touched on hardly at all.

MS. NANKIN: Rich, do you have something to add?

MR. ELLIS: I think that with any innovation of this magnitude we have to
be careful that we don\'t let the perfect be the enemy of the good. One
of the key advantages of 711 is it\'s three digits, easy to remember. If
we start talking about four and five digits, then you add more
complexity in. If we start talking about multivendoring through 711,
right off the bat, again that\'s more complexity. I think we need to
remember that sometimes there is an easy solution in the TTY itself for
speed‑dialing arrangements.

So 711 is just one of the different things we should be considering
here. I just want to be careful that we don\'t get involved in all of
these implementation issues, and we spend as much time trying to find
the perfect solution to every single problem that we end up delaying the
entire implementation process.

MS. NANKIN: There was one more question from the audience on this issue,
and then we are going to take our break.

MR. WARREN: Gary Warren from Hamilton Relay, and maybe half observations
and half questions. I\'m kind of curious what people think. One is, you
look at a state like Iowa or Nebraska or Minnesota, who has numerous ‑‑
Iowa has 100 telephone companies, local exchange companies. And my
question is, do we think that if there was an AIN‑type solution, that
would be at the tandem level, and, therefore, that\'s maybe not as much
an issue, or is it more likely in those states that the switch
translation solution to routing 711 would make it happen faster? I think
the latter is my inclination.

A while back I went back to our own local switch room, as our roots are
a small telephone company, and said, can you do this for me and
translations a day later, yeah, works. But if we ask the same question
many of those companies in terms of an AIN solution, I think it would be
a much longer process and perhaps much more costly, something to think
about.

And the other question I have is the eventual solution of routing 711
either AIN or with the switch translation, does either solution bear on
ultimately the difficulty of passing the caller‑ID‑type class
information, and does that make a difference if we pursue either of
those two solutions, because I sense that the relay community is going
to down the road look for those things, and we need to keep that in mind
as we chart this path.

MS. NANKIN: Does anyone have an answer?

MR. ELLIS: This is Rich again. Everyone is pointing their fingers at me,
so I guess I have all of the answers. My understanding is that the
caller‑ID‑type information gets passed on either platform. The
switch‑by‑switch versus AIN question is something I really can\'t answer
because we are AIN based, but my understanding is it\'s much more
difficult and expensive to do it switch by switch. But if that\'s what
you have, that\'s what you have.

MS. NANKIN: Thank you. Dave, do you want to comment?

MR. WARD: Yes. Dave Ward of the Network Systems Division. I think it\'s
important to understand that there are two elements going on here. The
first one here is internal to the local exchange carrier\'s network, and
then the other one is what information can be passed to expedite the
call handling between the local exchange carrier\'s access tandem and
the TRS center.

One of the issues that we are wrestling with here is the definition of
the common carrier. Is a TRS center a common carrier? Right now, under
our current interpretation, they are not, so the TRS center has to build
the database without having the benefit of Signaling System 7, AIN
platform kinds of information. The database has to be built manually,
and then the ANI trigger from the in‑band signaling will be utilized by
the TRS center for its own locally maintained and built database.

So, in order to take advantage of the full mechanization afforded by
AIN, we have to revisit certain things like definitions of common
carriers and can a local‑exchange carrier transmit Signaling System 7
information so that the information can be transmitted on a more
mechanized level to speed up the time of TRS service.

MS. NANKIN: Okay. In a moment we\'ll take a break, but I just want to
let everyone know that we will pick up where we\'re leaving off right
now. We will start on the questions and comments on the carrier of
choice, and then we will take comments and questions on 711 access to
CMRS. During the break, just for everyone\'s information, restrooms are
located ‑‑ there is a wall right behind this room.

Right behind the wall are the restrooms, but you have to walk around in
order to get to them. And if you would like drinks or coffee or
whatever, Ms. Kennedy, who is standing in the back of the room with her
hand up will be able to lead you there, and we do have wheelchair
accessibility for anyone that needs that. Thank you. We\'ll come back in
15 minutes ‑‑ 10 minute ‑‑ no, 15 minutes.

MS. NANKIN: I would like to welcome you back to the 711 Public Forum,
and we are going to start the second session, but first I would like to
recognize into introduce Commissioner Ness and thank her for coming.

COMMISSIONER NESS: Thank you very much. I just wanted to come down and
underscore my support for your very hard work on implementing 711. I see
711 as an extremely important vehicle for people to communicate around
the country. I am fortunate. I live in Maryland where we now have 711.
So we are seeing the benefits already, and I know this is hard work.

It is detailed, it is complicated, but you are up to the task, and you
will help us to make sure that this service is rolled out as quickly as
possible so that everyone can benefit from this service. So I don\'t
want to keep you any longer from your important work, but I did want you
to know that I care very much about making this happen. Thank you very
much.

MS. NANKIN: Thank you very much for coming and showing your support.

In the second session we will cover the four remaining topics. If you
look at the agenda in your handouts, you can see the four topics. The
first topic will be the Maryland Relay Center\'s choice of format to
provide 711 access to TRS and the experiences of other states that are
implementing 711 access to TRS. We will have two speakers on this topic,
Gil Becker, and then that will be followed by Burt Bossi. Hopefully, he
will rejoin us by the in time to give his presentation. Gil, do you want
to start?

MR. BECKER: Good afternoon. My name is Gil Becker. I\'m with the
Maryland Department of Budget and Management. I\'m responsible for
administration of the Maryland Relay, the fifth busiest
telecommunications relay service in the country. The State of Maryland
implemented the 711 abbreviated dialing access to TRS in February of
1999.

First, I\'d like to say how pleased we are with the success of 711
access to TRS. Customer acceptance has been much greater than expected,
and we couldn\'t be happier. I\'m not saying the is system we have in
place is perfect, because we do still have a few issues to iron out, but
overall 711 addresses several outstanding concerns and it truly brings
relay one step closer to true functional equivalency.

Prior to the implementation of 711 Maryland had one primary number which
handled 99 percent of all calls to the Maryland Relay. This number
served all incoming communication modes, including voice, TTY, VCO, and
ASCII. Two more numbers were established as additional services were at
the to the relay product line for the citizens of Maryland. One number
was added to handle speech‑to‑speech relay and the other to allow relay
users to access 900 pay‑per‑call services and be build directly for
those calls.

Having one primary number to access Maryland Relay had many benefits.
However, there were some drawbacks. The system worked well except for
those calls originating from a PBX. This existing system had what is
known as a \"customer profile,\" also known as \"branding\" or
\"database record\" attached to the ante originating number.

The system remembers the last communication mode used to call into the
relay. Voice callers dialing the relay from a PBX were often frustrated
by having to listen to two series of high‑pitched tones for the TTY or
computer for the last call handled by that PBX trunk.

This was one of the most common complaints received by our office. It
was necessary to explain to the voice caller the PBX issue and ask them
to call the relay again. They were instructed that if they got tones, to
wait for an operator to answer in voice.

A similar situation occurred when accessing relay to households with
persons using multiple user nodes of communication. For example, if a
TTY user in a household was the last person to call the relay, then the
next user in that same household would get TTY tones, whether they were
a voice or a TTY user.

Two common complaints heard among TTY users are failure to get a call
back when they leave a message for someone unfamiliar with relay and
hangups in calling businesses through the relay. Often, new relay users
are intimidated or confused when they receive a message to call their
relay using an 11‑digit number, and then you\'re to give the operator
another 10‑digits number to dial. Others simply hang up when Maryland
Relay calls, thinking it is some sort of telemarketer.

One of the primary goals of our outreach effort was to increase the
public\'s awareness of the availability of relay service. Hopefully, the
increased general awareness would decrease hangups and encourage
callbacks. A three‑digit number not only highlights the importance of
the service, but it makes it easier to remember and more effective as a
marketing tool.

Bell Atlantic can better explain the technical issue of how they set up
abbreviated dialing, but basically when a caller dials 711, that call
affairs at the central office, and it is directed toward an alternative,
toll‑free number, which in turn is sent to the relay.

This conversion translation does seem so add a few seconds to the time
that it takes for a call to arrive at the center. The time that it takes
a live operator to receive a call at their workstation once it arrives
at the relay center is referred to as the \"average speed of answer.\"
These ASA times have remained consistent, at 2.9 to 3.0 seconds since
the implementation of 711.

Calls directed to the 800 number assigned to 711 are handled differently
than other calls coming into relay. These calls are always answered in
the voice mode first, and there is no database lookup. This solves the
problem I referred to earlier associated with PBX systems by ignoring
the last incoming mode of communication to the relay and eliminating
tones to the voice caller.

Unfortunately, setup solved one problem but created another, since the
call is answered in voice first and branding and customer profile is
ignored. TTY, VCO, and ASCII users using 711 must wait longer for the
operator to answer. In addition, VCO users must always identify
themselves since branding is ignored.

To address the issue of longer answer‑to‑tech times for VCO and ASCII,
separate, dedicated, toll‑free numbers for these two access modes will
be implemented during the first quarter of the Year 2000. Until this
alternative is established, we are suggested that callers wishing to use
the branding feature continue to use the original toll‑free number.

Now, the numbers are now in, and the results are remarkable.
Voice‑initiated calls are up an average of 20 percent a month since 711
was implemented seven months ago. These new numbers are in comparison to
the numbers of voice calls initiated during the same month of 1998. Data
as well as customer feedback tell us that voice callers have increased
dramatically. In addition, overall call volume is up 10 percent since
711 began, this compared to several years of only two to three percent
growth.

On average, 44 percent of all callers accessing relay are using 711. In
fact, in July over 47 percent of calls to Maryland Relay were entered
through 711. We expect these numbers to continue to grow.

Another benefit of 711 being answered in voice first is that calls from
the voice callers receiving tones when calling the relay are now almost
nonexistent.

I mentioned that the system isn\'t perfect. We still do have some minor
issues to work out. Because the system always answers in voice first, it
ignores branding. We are encouraging VCO users or callers who wish to
have their calls answered faster in their preferred mode of access to
use the original 800 number. Bell Atlantic has made both their pay
phones and cellular phone service 711-accessible. Bell Atlantic has been
exempary. Unfortunately, not everyone has been as responsive as Bell
Atlantic.

We have contacted both payphone providers and cellular companies,
requesting that they make their systems accessible. However, since it\'s
not yet an FCC requirement, very few have complied. Thank you.

MS. NANKIN: Thank you, Gil. Burt Bossi, would you like to speak on this
topic?

MR. BOSSI: The question, again, was?

MS. NANKIN: Well, it\'s states\' experiences with implementing 711
access to TRS.

MR. BOSSI: The reason that my name was brought up for this topic was
because AT&T TRS, as a provider, is doing things slightly different. I
want the panel and the rest of the folks in the audience to recognize
that as we transition from answering our user base from multiple 800
numbers or multiple-access points to a single, it\'s going to look much
like the model of other providers, where we answer in voice and then in
the data protocols, and then rotate that to voice, instead of separate
voice, ASCII, Baudot per hookup.

So we talked about a slight time delay for the data users because we\'re
answering in voice first. It shouldn\'t be looked at as a negative for
our system, because what it does, it brings us to par with the systems
that are already answering in voice/data modes.

So what we\'re trying to do is create the best application, the best
solution to minimize that delay, and we are using voice‑response units.
We created something called \"upfront automation\" and \"back‑end
automation\" two years ago, and it got wonderful results from the data
customers, where they can center that they are an VCO customer, their
preferences, their call‑forwarding number all before they got to a CA.
The penalty for them was approximately six seconds of time typing in
these numbers. The benefit was they got to their end party, they
connected to their far party 22 seconds quicker. Okay?

So what looked like a penalty on the front end turned out to be a
wonderful time savings on the long side. And at this point I would like
everyone to think about that average‑speed‑of‑answer parameter that we
continue to measure, which is really an old parameter that we should
probably think about changing. TRS providers shouldn\'t be concerned
with how quick they get to a CA. They should be concerned at how quick
they get to their far party, and I think that\'s the real issue. That\'s
a side note. That\'s all my comment.

MS. NANKIN: Thank you very much. The second topic will be the methods to
educate and provide technical assistance to the public about 711 access
to TRS, and because this topic is so important, we actually have five
speakers on this topic: Toni Dunne, Brenda Battat, Claude Stout, Gil
Becker, and Karen Strauss. Tony, would you like to start?

MS. DUNNE: Thank you. Good afternoon, FCC staff, ladies and gentlemen.
My name is Tony Dunne, and I\'m from the Texas Commission on State
Emergency Communications. I also chair the NEMA the National Emergency
Number Association\'s Accessibility Committee, and the Association of
Public Safety Communication Officials\' ADA Committee. These two
professional organizations represent over 6,000 and 12,000 members,
respectively if the field of public‑safety communications. We seek to
advance the speed, accuracy, and reliability of emergency calling
response and are dedicated to the enhancement of public‑safety
communications.

I appreciate the opportunity to speak on the issue of 711 implementation
for TRS, as there are several areas that are of paramount importance to
the public and their safety. So my comments, while I will be addressing
the issue of public education, I also want to address some technical
issues that are very much tied to the aspect of public education.

We have held in 911 that N11 codes should be preserved for services that
are in the public interest and managed by a public service entity. So we
definitely support the implementation of 711 for relay services.

In the field of emergency communications our goal has long been one
nation, one number, and that would be 911 for everyone in terms of
emergencies. However, we recognize the fact that citizens may choose to
use relay service to call when their calls are emergency in nature. Our
primary concern is that in this case that all citizens are ensured an
equitable level of service, no matter which route they take. In an
emergency every second counts. Therefore, how calls are routed and
processed becomes critical to the safety and well‑being of the caller.

Currently, there are a number of ways the various telephone relay
providers handle calls that are emergency in nature. This can range from
requiring the citizen to give a 10‑digit number to the communication
assistant, to the communicates assistant dialing a zero for operator
assistance, or having a directory available for a manual lookup to find
the 10‑digit number for the public safety answering point.

With the implementation of 711 and provider choice, the ability to
connect to the correct response agency becomes even more critical. For
example, if I live in Texas and I choose to use a company based in
another state, how is that company going to process my emergency call
and know who it is that they are supposed to be contacting?

Technology exists to provide methods of routing calls to the appropriate
public‑safety agencies without having to require the citizens to take
extra steps or any additional steps, such as selective routing to
emergency services numbers that are based on the ante that\'s received.
That\'s currently being done in the 911 environment and certainly could
be looked at in the implementation of 711 regarding relay calls.

These are usually handled by databases through network configurations.
In Texas we\'re looking at implementing a stayed wide database, and
through this we are including relay in that whole process so perhaps
that they can interface with the statewide database and get those calls
handled more efficiently. But what that does require us to do is to work
with the companies, the LECs, to resolve interface issues that we face.

So, from the operational aspect, should TRS be allowed to pass the
callers ante or alle information to the emergency service provider, even
where the relay user disconnects before the emergency personnel connect
the, all of these are issues that our citizens out there really don\'t
see, don\'t understand, and we need to educate them with all of these
aspects.

When I bring this up I\'m talking about if someone were to dial a 911
number, and their ante gets to the emergency personnel, and they get
disconnected, say, in a domestic disturbance answer situation, the 911
center has the telephone number on which they can make a call back. When
they go through a relay and that call is handled that way, they
sometimes or often don\'t get that ante passed over to the 911 center so
that they can proceed to handle that call just as if it were made
directly to the 911 center.

Whatever method is invoked for the implementation of 711, if the citizen
calls relay to provide an emergency‑related call, it should be
consistent, transparent, and as effective as possible for those who
would dial 911 direct.

So there is a question about minimum standards here that would be
required, and having said all of this, there may be some people that
feel that we really don\'t have an issue with the public with regards to
the difference between 911 and 711. But I\'d like to share a story with
you.

About a year ago during the opening session of the National Association
of the Deaf\'s Biannual Conference in San Antonio, Texas, Bell Atlantic
did announce their first implementation of 711 in Maryland, and the
announcement was received with great joy. There was lots of jubilance in
the audience. However, at that time I wondered what the impact would be
on 911. And also at that time I cochaired the NAD 911 Committee.

Following the closing of the session the crowds moved towards various
workshops and issues forums, and I had many deaf individuals approach me
to say how excited they were that the deaf would now have their own
emergency telephone number. I continued to get these comments throughout
that week‑long conference. This confirmed my fear that the number, 711,
may be misinterpreted unless there is an educational campaign to clarify
what 711 is for and to reinforce that 911 is still the emergency number.

I shared these concerns with the people in Maryland, and they took this
to heart with their program. But if this is not part of the mandate from
the FCC, will other telephone companies and states voluntarily do the
same, and will they do it as effectively?

So with the implementation of 911, public education becomes more
critical to ensure the public understands the purpose and the use of the
number. 911 has been doing this type of thing for many years. We have
created public service announcements both at local and national levels
with various funding sources.

Television stations air these public service announcements at no cost,
and we include information in bill inserts. We get public figures to
proclaim 911, which, by the way, will be on Friday, September 11, is the
equivalent of our 911 day. And we celebrate the establishments of those
who work in the field of emergency communications.

We outreach to the public by appearing at events and through print
media. And all of this brings an awareness and the key message of what
911 should be used for.

So just as 911 has been doing this, so should the folks involved with
the relay. GTE submitted comments in which they outlined their public
affairs timeline for their implementation strategy. And I strongly
encourage anyone developing such a plan to not only include the public
education aspect for the 711, what it\'s for, but also what it\'s not
for, and that would be to process those emergency calls. They should
still go direct to 911.

And so while this is an example of an approach to a rolling out of
public education it also stopped one month following the implementation
of 711. What we\'ve learned in 911 is that we can\'t just do a public
education campaign sweep and then just drop it. It requires a concerted,
ongoing effort.

Public‑safety professionals are concerned with in the similarity of the
abbreviated dialing pattern that the implementation of an 911 for relay
service will cause an increased use for calls that are emergency in
nature into the 911 center.

So what I would like to say at this point is that please know that I and
the organizations in my agency stand ready to assist in whatever way we
can in the efforts to ensure the public use the appropriate number at
the appropriate time, and I guess that concluded my comments.

I do have a diagram of what 911 Service coverage looks like at this
time, and you can see that not all states have 100 percent 911 service.
And even the areas that do, we continuously have to provide public
education to help the public understand when to use it and when not to
use it, and now that we\'ve got another abbreviated‑dialing number for
the public, we need to make sure that they don\'t get those numbers
confused.

I\'ve also got just a very, very basic, for you guys that are engineers
and technical oriented, this is going to make you laugh inside probably,
but this is a very, very basic diagram of if someone were to call 911
with a basic 911 network. Just simply, they go through a central office,
and it answers at PSAP. This would be an enhanced networks where it\'s
going to go through a tandem. And that\'s where they are going to get
into their database, their ante/alle dip, and it will arrive at the
PSAP, the public safety answering point, at the same time that the call
arrives.

And then this is a more complicated network where we\'ve got wireless
included in that.

And so somewhere within here if capability does exist to interface with
what databases and systems already exist out there to ensure that the
caller, when they are having their call transferred or connected up with
the emergency personnel, will also have the same advantage as if they
were calling that number direct. That concludes my comments.

MS. NANKIN: Thank you. Brenda Battat, would you like to go next?

MS. BATTAT: Good afternoon, everybody. I\'m really pleased to be here.
I\'m Brenda Battat, with Self‑Help for Hard of Hearing People. I
represent a large group of people who are going to be using the relay
primarily as voice carryover use it, and up to now tend to get lost in
the shuffle, as we have in Maryland. I\'ll talk about that later. But
today voice carryover users do not have do not have access to 711 in
Maryland the way that they would like to use it.

In terms of educating the public, I think we can learn a lot, as Toni
says, to use the methods that they have used for 911. It has to be a
very concerted, national type of campaign. But I want to take a little
different tack here for the moment, and 711, I believe, is a very
important step.

HHS supported this in the initial notice of proposed rulemaking, and we
still support it now. But I want to have a word of caution here. 711 is
a front‑end solution to accessing the relay, and I would like to comment
that we need to address the perception of relay, and we need address the
fact that relay is far from efficient from a voice‑carryover perspective
and particularly from a hearing person\'s perspective. And I think this
is going to have an impact.

If we have a massive campaign to get everybody dialing 711 when they get
on there, it\'s an extremely frustrating experience. I think it\'s going
to backfire on us. I think one of the things that I\'m learning now and
I\'m hearing from my members and constituents out there, they are not
getting hung up so much now. They are not hanging up because they don\'t
know what relay is. What\'s happening now is that they are refusing to
take calls because they do know what relay is. And I can give you some
examples. I think we\'ve got to move forward.

Definitely there are still some people there who don\'t know what a
relay call is, but there are more and more people here in public who do
know what relay is, and they just don\'t have time to deal with it.

I can give you some examples. Somebody called Georgetown Hospital to
make an appointment with their doctor in an emergency, and they were
told, I\'m sorry, I\'m on my own. I know what a relay call is. I\'m
manning these desks on my own. I just don\'t have time. I\'ve taken
these relay calls before. They just take too long. Call back on Monday.

Our own receptionist in our office came to me one day, and she says, you
may get a call and a complaint from one of the people who called, and I
said why? She said because there was taking a very long order for
publication, and they couldn\'t fax in the order. I said, would you like
to write in the ordinary, but I had to keep putting them on hold. This
was a relay call. They were putting in a very long order for
publication. She said, I had to put them on hold for at least five times
because I had to take other calls that were coming in, and she said, I
know they were very mad about that, but there was nothing I could do.

I know people have told me that their doctors have actually given them
their e‑mail address because they just don\'t want to have to deal with
the relay because it just takes too long. The doctor is actually giving
out an e‑mail address to a patient. Another doctor is faxing back and
forth rather than use the relay. They\'ve used the relay. They don\'t
like it. They are faxing back and forth.

I had a situation with a colleague of mine, a professional colleague in
a professional organization, that I was making relay calls. I use relays
‑‑ probably 90 percent of my calls are relays, voice carryover, and we
have communicated maybe four or five times through relay.

We were trying to negotiated a collaborative agreement. And she finally
just e‑mailed everyone there and said, I want to come over and meet you.
And she had told me that even though we had been talking on the relay,
she just didn\'t feel that, you know, we were at the point that we
should be, negotiating this whole thing on relay.

So I\'m just giving you some examples here. I do support 711, but I
think parallel with 711 and all of the efforts that everyone is putting
into 711 and accessing relay faster, there has to be an equal access, an
equal emphasis on improving relay and what it can be for hearing, voice
carryover and TTY ASCII users.

It has to be matched with an intensive reach and development effort to
make sure that the relay is truly efficient and that people who can
access by dialing three numbers will want to use it, because right now
I\'m getting a lot of feedback that they do not want to use it, and
it\'s not because they don\'t know \-- it\'s because they do know what
it is.

I think there is an initiative going on right now between an architect
and Sprint, which I\'m participating in, which is development of speech
to text. There are things going on which I think have potential. I think
VCO users is a very largely untapped market. It\'s a very hard market to
reach. I don\'t think we\'ve researched them.

Our consumer groups have not done a good job of reaching them, and
neither have the carriers. But that is the potential market out there. I
would say a very conservative estimate of about five to seven million
users, but there are several hurdles that they have to get through. They
are comparing using ‑‑ with using the voice system because many of them
have used that system.

They are very impatient with it. They have to take some steps before
they use it. They have to purchase equipment that they won\'t have, that
they won\'t typically have a TTY or software TTY or an VCO phone in
their homes. So I just feel like there are a lot of options that would
make it attractive for them to use it, for instance, to be able to make
a switch in the middle of a call and receive a call.

You realize that you are not going to be able to hear this person. You
would like to be able to switch from a voice call to a relay call. That
should be possible. That is going to make it very attractive to these
users. Then it becomes an option, because it\'s not every call that they
can\'t hear. Sometimes I may make a call that I can hear the person,
sometimes I can\'t.

So I just want to emphasize another aspect of this, and don\'t get me
wrong. We support 711, but we have to have something happening that is
going to make this a more efficient system to go along with the 711
access that we\'re proposing.

In terms of just ‑‑ I think a lot of our guest speakers are going to
cover more of the aspect of how to publicize them. I\'m not going to
spend a long time on that, but I agree very much with Toni, in that you
can\'t have one big splash and then drop it. It has to be a very
continued, ongoing effort and a steady effort. I think it has to be on a
national level. I think it\'s something jazzy that maybe a PR company
would pick up pro bono. I think 711 is likely to appeal. We may be able
to get some pro bono assistance on it. The FCC might be able to.

I like very, very much what Sprint has been doing in the State of
Maryland with the initiative, partnering with businesses. I think that
approach is very good because it\'s not on the general public that we
need to convince, but also businesses. That type of program, where
you\'re working ‑‑ I think there needs to be a lot of hands on, a lot of
hands on in, a lot of hands on with companies, really teaching them what
it is. And I think just a written message or a PSA is not enough to get
people to really know how to use it.

So that\'s really what I wanted to cover today. Thank you very much.

MS. NANKIN: The next speaker will be Claude Stout.

MR. STOUT: Hi. My name is Claude Stout, and I\'m the executive director
of the Telecommunications for the Deaf, Inc.

I\'m with Brenda and Toni, with their remarks. Definitely, a public
relations campaign can\'t be a one‑time thing. It can\'t be a one‑shot
deal. It has to be something that\'s ongoing, and it has to be maybe
annual, maybe consistent. The PR campaign has to be something that
can\'t ever be stopped. It will require a lot of funding from
state‑related administrators to bring in the money, but it will be worth
it because as you increase understanding and awareness, you are
increasing educational opportunities, community interactive
opportunities for deaf and hard-of-hearing, lay deaf, and deaf‑blind
consumers.

Toni\'s comments about 911, I think are very valid. You may be
interested in knowing that the statistics have proven that 54 percent of
911 centers all over the U.S. are not ‑‑ 911 is not accessible to deaf
and hard-of-hearing or lay deaf and deaf‑blind individuals ‑‑ 54
percent. And we\'ve already talked and preached and beaten that into
them for 10 to 20 years.

So now here we are with 711, and we have to think this plan out very
carefully. We have to network with the communities and talk with
authorities and professionals in the deafness communities and find out
what makes a public relations campaign work, what makes it stick, what
makes it valid.

Telephone billing sheets to introduce 711 are nice. That would be fine.
Campaigns and advertisements on TV would be fine. Something inserted in
a newspaper or magazine would be nice as well, but don\'t let that be
the only three or four things we do. I suggest that we use word of
mouth. And by that I mean involve the consumers on our advisory boards.

I\'d urge that every state have an advisory board, a TRS advisory board,
to be more specific, or a TRS group within their ‑‑ I know some state
governments have a division of deaf and hard-of-hearing or a commission
on deafness. Let them have a TRS oversight or advisory responsibility,
working with public service commissions.

The FCC asked us in what ways can we educate the public. Well, really,
we\'ve got to educate public service commissions. There are some public
service commissions in the U.S. who are not yet fully knowledgeable or
fully aware about deafness and hard-of-hearing and lay deaf and
deaf‑blind issues and needs regarding telecommunications.

If the FCC decides to rule on this, on the public relations campaign,
make sure that we pass along instructions to the public service
commissions. That way these public service commissions can work more
closely with telephone companies in their areas, because telephone
companies are going to listen to the public service Commissions on what
their examinations are, and they will hear that. The FCC has to pass
that along to the public service commissions and in turn it will be
passed along to the telephone companies.

Now, who is to be involved in each state. We need to make sure that we
establish an advisory counsel, and we let the consumers dictate what
their needs are. We don\'t want to later experience a situation where
authorities in the state government or in the telephone companies are
assuming or making assumptions on the needs of the deaf and the
hard‑of‑hearing community. We have to be careful with how we proceed
with the public relations campaign. That\'s it. Thank you.

MS. NANKIN: Thank you. Gil, Becky, would you like to do safety boards?

MR. BECKER: I have more than a couple of words to say about this topic,
which is very important to us. Methods to educate and provide technical
assistance to the public about 711 access to TRS, including having
public service announcements.

It\'s called many names, including information and referral, outreach,
and also advertsing and public relations. We\'ve always believed that
providing information about TRS to the public is critical to the
continued success. In fact, we are so strongly committed to that idea
that we included a specific dollar amount in our TRS. We knew that we
did not have the in‑house expertise to disseminate the word about TRS in
a cost‑effective manner. For this reason we included this requirement in
our contract.

The, advising, public relations team put in place a comprehensive
program to effectively get the word out about 711. Advertising is part
of the plan that costs you money. Public relations is endorsement by a
third party, such as a newspaper or a TV reporter. Both are important
and work together for an effective campaign.

Our comprehensive outreach program began on February, 1999 with a press
conference that was held in the Maryland Relay Center in Baltimore. This
press conference was held jointly with Bell Atlantic, the State of
Maryland, Sprint, our current TRS provider.

In attendance were members of the Maryland Public Service Commission,
Bell Atlantic, state government, the FCC, our governor\'s advisory board
for telecommunications relay, and members of the general public. Key to
the success of this kick off was attendance by the media. Our public
relations firm was able to entice four television stations, three radio
stations, several newspapers, and the Associated Press to attend. From
this single event we generated a significant amount of coverage, but we
didn\'t stop there.

The same day of the press conference paid television advertising began.
We ran five weeks of advertising in two major television markets in
Baltimore and the Washington metropolitan area. To save money we ran
spots on only one TV station in each market. For those states that have
television markets that border two or more states, I strongly suggest
that you consider joint advertising.

TV advertising is effective, but it\'s also expensive. We opted not to
depend on television advertising bearing free public-service
announcements. We have submitted PSAs to public service stations in the
past, and have minimal air times. Those that were aired were done so at
3 or 4 o\'clock in the morning.

The 30‑second, 711 television spot was actually the second television
spot that we\'ve run within the past year. The first spot was a generic
relay spot. The second spot, which announced 711, was directly linked to
the first ad. At this time, I would like to show you both of the
30‑second TV commercials. If you would look at the screens.

(A videotape was played.)

MR. BECKER: As I said, we ran five weeks of this of this paid
advertising back in February, and we also started another four‑week
campaign just this past week. It just happens to be a coincidence that
it\'s running at the same time as this forum. Several people have come
up to me and said they have seen it already.

During that second week of February \'99 we also began paid present
advising in two major newspaper markets in Maryland. The ad ‑‑ \"It\'s
not the name of a popular convenience store that was convenient,\" ran
in the [Baltimore Sun]{.underline} and the [Washington
Post]{.underline}. In addition, we listened to what Tony had to say, and
we wanted to ensure that TTY users did not did not accuse 711 with 911.
We always encouraged consumers to call 911 in an emergency. We wanted to
make sure there was no confusion.

We ran this TTY‑oriented ad in six deaf publications both locally and
nationally, hoping to get as many relay users as possible, and it ran
four times in each of those publications.

In addition, Bell Atlantic provided a telephone bill insert which was
distributed to almost two and a half million telephone subscribers. The
bill insert reads: \"Did you know Maryland Relay is now even easier to
use?\" on the back of it it says: \"Now to use Maryland Relay from
anywhere inside the state, dial 711.\" And then it goes on to explain
row lay.

Bill inserts are an extremely effective tool to disseminate information.
Since the initial mailing in February we still get calls requesting
information from consumers referring to that bill insert. Bell Atlantic
provided that bill insert at no cost to the state, saving us almost
\$65,000 in printing and postage.

More than a dozen newspaper and magazine articles have been written
about 711, a great deal increasing our exposure to the general
population as well. We also publish a newsletter twice a year which gets
the word out as well. The past two news letters have had articles on
711.

Finally, we provide a toll‑free, customer‑service number which provides
information and technical assistance to individuals requesting
information. On an average month we receive between 500 and 600
inquiries to our customer‑service number. During the month of February
we doubled that number, receiving almost 1,200 calls. In total, we have
spent we have spent almost \$100,000 on 711 outreach. It\'s well worth
it, considering the results have clearly demonstrated the effectiveness
of our campaign.

And we haven\'t stopped with this. As Brenda had said, as Toni had said,
as Claude said, outreach is a continuing effort. It\'s not a one‑time
thing. We\'re always trying to find to find new ways to get the word
out. And, Brenda, we are listening to you. We do know we have issues
with VCO issues. We are looking into that.

Honestly, right now, about three to four percent of our total users are
voice carryover users. But we do know we have a problem, and we are
addressing it. Like I said, we\'re going to have a dedicated toll‑free
number, 800 number. It\'s not going to be as easy as 711, but we will
get much quicker response time, and we are listening. Thank you.

MS. NANKIN: Thank you. Karen Strauss, would you like to talk on this
topic?

MS. STRAUSS: Very, very briefly. In the interest of saving time, I just
wanted to note that I could be speaking out of turn, but I remember that
in a prior FCC proceeding NECA\'s Interstate Advisory Committee
suggested that the entity that can coordinate a national campaign for
advertising relay service.

So I remember that, and I\'m asking the FCC to take that offer
seriously. We have an entity that has actually volunteered to coordinate
a national campaign, and there is very little reason that recovery can
of the costs of engaging in such a campaign cannot be recovered through
the interstate relay fund, just as I would presume many of the costs of
intrastate campaigns are covered through intrastate funds.

Other than that, the only other thing I wanted to mention, now I have
the floor is that I am concerned, because I know we\'re running out of
time, I am concerned about asking TTY callers to go back to using an 800
number for fast access since the original purpose of the petition filed
way back, I believe in 1993, was to expedite access by TTY users through
711.

So that is a grave concern to me. If voice users are going to be
obtaining fast access but TTY users have to go back to using an 800
number to obtain quick access, and I\'m hoping that there is a solution
that can be achieved that fully accomplishes the goal of the original
711 petition for TTY access.

MS. NANKIN: Thank you, Karen. The third topic will be the length of time
in which states can implement switch‑based or AIN 711 system to access
TRS. We will have two speakers on this topic, Toni Dunne and Claude
Stout. Tony, would you like to start?

MS. DUNNE: Here is where I get to say that I misunderstood exactly what
my topic was here, and I am really not the person to talk about
switch‑based implementation timelines. I understood it to be more
implementation of the public‑education aspect of the issues that we were
talking about just previously, so I\'ll defer.

MS. NANKIN: Okay. Claude Stout, would you like to say a few words on
this topic?

MR. STOUT: I\'m not qualified to comment on the technical feasibility of
a nationwide 711, but I think that I need to again spell out the
consumers\' examinations, and those are that please implement 711
nationwide as soon as possible. Don\'t use a lack of technology as an
excuse for not implementing it earlier. Find money or find resources
somehow, and meet our needs as soon as possible. Thank you.

MS. NANKIN: Thank you. Since we haven\'t really addressed this issue,
does anyone have any words say about this issue before moving on to the
fourth topic? Paul?

MR. LUDWICK: This is Paul Ludwick with Sprint. I obviously can\'t speak
for the local exchange companies, but from a relayprovider perspective
711 implementation is not that difficult. So I would expect that a
12‑to‑18‑month time frame for the replay provider is doable. And I guess
I have to qualify that a little bit because it really depends on what
type of involvement the states expect.

From the relayprovider view, we have very little power in implementing
711. We\'re literally mostly along for the ride. As long as the state
government and the state commissions can coordinate local exchange
companies, bring them into agreement, and agree on an implementation
plan, I think all of the relay providers would agree, and I don\'t mean
to speak for them, but I believe that it would not be difficult for us
to support that implementation.

MS. NANKIN: Thank you. Does anyone else wish to speak on this topic?
Sunny, would you like to say a couple of words?

SUNNY: As a former engineer I\'m sure that all of you engineers will
agree to this. Our motto is \"nothing is impossible.\" So I think that
with the FCC\'s mandate, I strongly believe that 711 will be available
to everyone including California within a year or so.

MS. NANKIN: Thank you. Let\'s move on to the fourth topic, which will be
whether to transfer the administration of N11 codes at local level from
the incumbent LECs to the administrator. Rich Ellis will talk on this
topic.

MR. ELLIS: As a local exchange carrier, we\'ve gotten out of the
business of local exchange administration over the past year. We see no
reason to maintain oversight over 11 administration. So we would highly
recommend that it be deeded over to an independent entity. Is that short
and sweet enough for you?

MS. NANKIN: That was perfect. Thank you. Now, as looking at the clock,
it is quarter‑to‑four, I think we are going to be going over a little
bit.

The next section will be questions, and we\'re going to start with
carrier‑of‑choice questions from the first session. So does anyone have
any comments or questions on the carrier‑of‑choice issue? Yog, would you
like to start?

MR. VARMA: I have a question for Mr. McClelland of MCI. You indicated
earlier today that the multivendor environment has not been addressed,
and the carrier‑of‑choice option is a slow option. I was wondering if
you could just amplify on that as to why there are difficulties in
achieving carrier of choice for the TRS users, either under the Advanced
Intelligent Network architecture or the base translation.

MR. McCLELLAND: Bill McClelland with MCI WorldCom. Now, are you talking
about carrier of choice as far as the toll provider or relay provider of
choice?

MR. VARMA: Well, actually both.

MR. McCLELLAND: Okay. I will address both, then. Carrier of choice, as
far as carrying the toll part of the call, be it interstate or
intrastate, any part of the toll call is not something that we don\'t
do. We do that every day. We can do it on a percall basis. We can do it
on a presubscribed basis. And if that carrier is available to you in
that state, we will provide that carrier for you through our relay
system, and that\'s something that we provide today.

MR. VARMA: Do you have that information residing in your database ‑‑

MR. McCLELLAND: Yes, we do.

MR. VARMA: \-- as to who the long‑distance carrier is that the TRS user
as chosen?

MR. McCLELLAND: If they are presubscribed, we have that in a database,
and that is what they are automatically picked to. If they are not
presubscribed and they request a carrier, then we select that carrier
and provide them access through that carrier.

MR. VARMA: Okay. Is it fair for me to say, then, that you have
connectivity from the TRS center to various long‑distance providers in
that area, so that you are able to send the calls through the points of
presence of those interexchange carriers?

MR. McCLELLAND: Yes, sir, we do. Are you ready for the other part now?

MR. VARMA: Yes.

MR. McCLELLAND: Okay. The other part is the more difficult part, in that
711, if we look at the implementation of 711 right now, like in
Maryland, they translate, or they use AIN to point all 711 calls to a
specific designation. All right. To one provider. Okay.

In California you either have to select a provider or you would have to
figure out how to do a percentage of traffic or you would have to put an
upfront mechanism that would allow an individual to select which
provider they want to go to. Because of pay phones and PBXs and that
type of stuff, you would have to upfront that information, which
involves connecting and communicating with what the user want wants to
provide if you\'re doing solely 711. All right?

If you presubscribe everyone in the state, if they dial 711, I want to
use this provider over this provider, you have to multiple pick that AIN
number. Let\'s say that I chose MCI as my relay provider of choice and
some intrastate provider for my in‑state toll calls and a different
provider for my interstate toll calls and even a third provider for
international calls. That multiple pick in there involves more databases
and more development in the local exchange. So there is a huge cost in
that part.

The upfront gateway, which would address PBX systems and common‑use
telephones, puts one more step before you ever get into the relay. You
have to work yourself through another VRU unit before you would ever get
into relay to decide what you want to do from there, so that\'s where
the additional delation would be.

MR. VARMA: Thank you.

MS. NANKIN: Gail, do you have any questions on carrier of choice?
Brenda?

MS. BATTAT: I\'d like to get something clarified, whoever would like to
answer it. You know, there are literally hundreds of long‑distance
providers, and if you contact the TRS in the state and ask them for a
list of long‑distance companies that you can choose from, they will send
you a very small list.

And I have asked why is the list so small, and they say, well, the
long‑distance companies are not registered with us and arranging for
billing arranging with us, and if we don\'t have that billing arranging,
if they don\'t register with us, then we can\'t offer them. And this is
happening. People are wanting to designate a carrier, but they can\'t
because the carrier has not registered.

Is this a fact, and will this still be a fact with 711, because it
definitely is an issue? When we in our office wanted to register with
one of them we couldn\'t. We wanted to select a carrier, and we
couldn\'t because they weren\'t registered with the state relay. And
apparently the state relay have told us that they have written to all of
the carriers and said, you know, register with us, but they don\'t
bother to do it. I don\'t understand what\'s going on. I need to really
understand what\'s happening.

MS. NANKIN: Burt, do you want to answer that question?

MR. BOSSI: This is Burt Bossi with AT&T. I commented on the ex parte
comments regarding this issue, and I\'ll just read them off to you. I
think it answers your question pretty accurately. Let me warn you, it
dives a little bit into the technology involved.

But, first of all, I\'ll say this has little to do with 711. It is more
so just carrier of choice, and there was an FCC meeting regarding this
issue that I know Paul was at and a few others. We talked about this,
and I\'ll just summarize the discussion from that meeting.

The TRS providers are not singularly liable for the availability of
these different carriers. First, the carrier needs to make public that
they are interested in carrying TRS traffic. Then the carrier is invited
to provision a specialized Feature Group B‑type trunk into the same
access tandem that that state\'s relay is providing.

The primary cost to the carrier is this Feature Group B‑type trunk, and
when a business case is prepared weighing the expenses of the special
facilitate with the relatively small amount of traffic, the carriers
usually decline the invitation. This is why only the larger carriers
make themselves available through TRS nationwide.

So, for AT&T\'s sake, if you asked us for the list, it\'s under 10, but
there have been many invitations to join us.

Then we talked about dial‑around carriers, or what we call the 10‑10
companies. They have an even more difficult business case to build
because often these carriers seize regionally specific opportunities and
are only available in high‑profile demographic market areas. This is not
always where the state\'s relay center or network‑access tandem is
located, so, again, the expense is difficult to justify. That\'s the end
of my comments.

MS. NANKIN: Thank you. I think Dave had his hand up first. Dave Ward, do
you want to speak on this issue?

MR. WARD: Yeah. I\'m Dave Ward of the FCC\'s Network Systems Division. I
concur with everything Burt had said. And the Commission we look at the
technical issue that Burt brought up, and we also look at the
enforcement issue. We have regulations on the books now that require
carriers to comply with certain TRS access, and we\'re looking at that
right now.

MS. NANKIN: Karen, did you want to add something?

MS. STRAUSS: I think you may have just answered my question, but now I
understand much better why somebody came into my office last week and
was told that when he tried to us the 10‑10 number he was told by the
relay communications assistant he couldn\'t not. And, in fact, if he
wanted to, they were suggesting that he would be an additional surcharge
would be imposed on him.

That part doesn\'t make a lot of sense to me, but I understand now why
he was rejected, and my question to the FCC was, what are you going to
do about this, because this is inconsistent with what the law is? And
what I think I hear you saying is that your looking into this and will
notify these carriers that they don\'t have the option of rejecting
these relay calms. It\'s completely inconsistent with the ABI.

MR. WARD: That\'s not entirely true, and just let me amplify that. If a
relay customer has access to a certain number of carriers in their local
area, say, for example, AT&T, MCI, and Sprint are offering long‑distance
service to people of a certain town and a relay customer is from that
town, then they, under FCC representations, should have party or access
to the same choice of carriers that they have through their locally
switch that hearing customers have through their locally switch in the
same area.

What we\'re seeing here is the possibility of TRS users accessing the
list of long‑distance carriers that are available at the same access
tandem as the one that serves the local exchange TRS center. So, for
example, the people of Cecil County, Maryland may have one list of
interexchange carriers to pick from, and that doesn\'t matter if they
are TRS users or hearing users, but the people of Baltimore County have
another list.

So through the current access‑tandem arrangements people who call TRS
into Baltimore County get the choice of the Baltimore County residents
and not the Cecil County residents. It is not as clean that we would
like, where it would be universal choice of carriers throughout the
country. In fact, we do allow in a competitive marketplace people to
enter the marketplace and leave the marketplace, depending on where they
consider the profit.

And here we run into the duty required by our TRS regulations and
federal law versus what is a reasonable ingress and egress out of the
competitive marketplace. Suffice it to say, we\'re looking at equalizing
the ability of people who use TRS could you that use the regular public
switched‑telephone network without the assistance of TRS.

MR. VARMA: I know that the chairman of the Commission is very deeply
concerned with this issue. The chairman has expressed to us his concern
of many kinds that TRS users must have the same choices as others do,
and I agree with Dave\'s comments about the rules and the responsibility
that the carriers have. And I hope that we can move forward on this
issue and be able to level the playing field.

But I have a question for you, based on what you indicated earlier, that
while I can understand that there is a business case to be made by a
long‑distance carrier before it would bring in Feature Group B
connectivity to the TRS or a B‑1 or a BS‑3 circuit depending on volumes
and that would there ever be instances where a carrier just does not
have enough volume of business to have direct connectivity to the TRS
center?

But is it not possible for the TRS operator under those circumstances to
be able to send the traffic back to the local exchange carrier\'s access
tandem, and the traffic would be distributed from there to the
long‑distance carrier, as it normally would be for a non‑TRS user?

MR. BOSSI: Burt Bossi, AT&T. Good question. A little bit of confusion
here. We\'re not looking for connectivity from these alternate carriers
into the TRS center. We\'re lodge looking for connectivity, Feature
Group D‑type connectivity to the LEC access tandem, because that\'s how
we handle carrier‑of‑choice calls today.

We simply use MF in‑band signaling to drop all of the information up to
the access tandem, in hopes that that alternative carrier is there
waiting to intercept. In my cases they don\'t want to bring that Feature
Group D‑type trunk into that access tandem. So there is no connectivity
to our center. We handle off the COC traffic just as you illustrated.

MR. VARMA: So you do not transfer calls to a long‑distance carrier\'s
point of preference?

MR. BOSSI: Which is typically the access tandem where we\'re at.

MR. VARMA: Okay.

MR. WARD: Dave Ward of the Network Systems Division. The question should
be directed at a local exchange carrier that is providing the 711
service throughout the state.

The issue would be the design of the network to accommodate what is
known in the long‑distance business as \"back haul,\" where a certain
switch hubbing is preferred so that it\'s cheaper to aggregate and
transport. And in this instance it may not be cheaper, but the same
back‑haul principle would apply, where a path would be created by the
711 local exchange carrier for interconnecting long‑distance carriers
that don\'t have a point of presence in the same access tandem as the
TRS center with the customers that they normally serve in the area where
the call is originated.

MR. VARMA: Okay. Thank you.

MS. NANKIN: Kurt, did you have a question?

MR. SCHROEDER: Yes. Thank you. One thing that we\'ve heard a lot about
is outreach, which I think was one of the first issues that I was
introduced to in the TRS area when I started working on it about a year
ago. And I see it being very important in the carrier‑of‑choice area and
in getting the word out on 711 and so on.

And I gather, we would all be happier, I guess, if more states would
follow the lead of Maryland and actually devote a portion of their
budget for relay to outreach. I guess my question ‑‑ I won\'t direct
this at anyone in particular, but is there a way we can encourage more
states to do that? And then, as, I guess, a supplemental or additional
effort, is there is there a way that we can help coordinate through some
sort of national campaign the states\' efforts so that there will be the
maximum effect from both.

MS. STRAUSS: Let me read to you what the FCC\'s current rule is. As a
lawyer, I like to change rules, but the current order directs carriers
to conduct outreach through the following means \-- publication in the
directories, periodic billing inserts, placement of TRS instructions in
telephone directories, and TTY directories as well, and directory
assistance services.

Now, if you look at those means, you can gather very quickly that that
is not going to research the public. Billing inserts can be effective,
and I\'m glad that they were effective in Maryland. I was one listed. My
name was listed in a billing insert when I served on a consumer panel
for C&P. Not a single person in the entire Maryland, Virginia, and
District area called me to say, hey, I saw your name. I think the vast
majority of the public throws out billing inserts. Anybody that doesn\'t
know about relay services is not going to look in their telephone books
to read about it.

So I guess my answer is that what you have on the books right now is not
I can\'t tell, and one way of changing this is to change the rule and to
indicate in the rule that this is a new requirement, that outreach and
education has to be comprehensive, taking into account the various
recommendations made here and the comments that we will be submitting
subsequent to this proceeding will list several additional ways.

Obviously, Maryland has served as a wonderful example, and there are a
plethora of means that can be instituted on a national basis state by
state, you be it\'s not going to happen, I think, unless it\'s actually
required.

Again, I reiterate, the offer by the NECA representatives who didn\'t
yell at me when I said it, so I\'m going to say it again, that they
obviously made an offer to try to coordinate a national campaign on
relay, so I think that\'s the answer to your question. If that offer
holds, I say go for it.

MR. SCHROEDER: Thank you. Anyone else?

MR. BECKER: Gil Becker.

MR. SCHROEDER: Yes, Gil.

MR. BECKER: I think it\'s all important for the entire package that you
do need to increase the scope of what you are requiring for outreach.
National outreach is very important. I just want to applaud Bell
Atlantic once again because they provide full‑page advertisements in
each of their telephone directories publicizing Maryland Relay and 711
access.

MS. NANKIN: Okay. I think we should move on to the third topic, which is
711 access to commercial mobile radio services. Does anyone have any
questions or comments or views on this topic?

MR. VARMA: I have a question. I think Paul mentioned in the morning
today that the CMRS providers have challenges in implementing 711 which
are similar to those that the wireless carriers face.

I was wondering if there are any CMRS providers currently providing 711
services and what their plans are as being able to provide 711 down the
road as the wireless industry moves forward in that direction. I think
you had attached one of these issues in the morning. If you are able to
answer it, I would appreciate an answer or anyone else from the
audience.

MR. LUDWICK: This is Paul Ludwick with Sprint, and I think I can answer
part, and I\'ll refer the rest of the question. I believe that there are
CMRS carriers operating within the State of Maryland that offer 711, and
I know that Sprint PCCS, our cellular branch, is currently doing an
analysis on cost and every time required for a nationwide 711
implementation. As to the number of CMRS carriers that have offered the
service, I don\'t have a lot of advice I believe the to that. So, Gil,
do you have any information?

MR. BECKER: Unfortunately, I don\'t. We contacted cellular providers and
asked them. We didn\'t do anything formal. We were waiting for a final
ruling from the FCC and didn\'t have any enforcement capability, so it
wasn\'t one of our priorities.

MR. LUDWICK: If I could just add, I think there are a lot of enforcement
implementations in 711. A lot of the companies are trying to stay lean
so that they can maximize shareholder benefit, and until there is some
type of mandate I think you will find major efforts slow.

MR. VARMA: So are you saying that the CMRS providers are of the view
that they are not required to provide 711 at the present time and that
they are waiting for another mandate from the Commission?

MR. LUDWICK: Sir, I think I can say that about all the carriers, not
just CMRS.

MR. VARMA: Okay.

MS. NANKIN: Does anyone else have any questions or comments? Marty
Liebman?

MR. LIEBMAN: Just a followup to Yog\'s question. TRS carriers that are
implementing or contemplating 711, are there any impediments, technical
or otherwise, that you are facing in addition to the ones that Paul
mentioned earlier?

MR. LUDWICK: I\'m only aware of the ones that I mentioned. I\'m sure
there probably are other conversations, but I have not had any in‑depth
discussions could you providers.

MR. LIEBMAN: And is there anything that wireless carriers might want or
need from the Commission in order to assist them in implementing 711?

MR. LUDWICK: This is Paul Ludwick with Sprint, and that\'s kind of a
loaded question, because I think the answer to that is a mandate and
determining how cost recovery is performed.

MS. NANKIN: Okay. Thank you. Anyone else on this issue? We have Pam
Stewart in the back, if you would like to speak.

MS. STEWART: Pam Stewart from Maryland Relay. I just want to confirm
that. I\'ve called a number of the cellular and another that hasn\'t
come up as much are the small payphone companies, and told them that we
have 711 in Maryland, and would you please.

Basically, what they say is not until it\'s required. It is not a
requirement. And some of them have even said, we set things up one way,
and then the FCC changes the rules with the mandate, then we have to
switch what we\'ve done. So a lot of them are not going to do anything
until there is a mandate.

MS. NANKIN: Okay. Thank you. Anyone else? Sunny?

SUNNY: This is Sunny speaking again. I just wanted to make it clear that
we\'re talking about presubscription. We talked about presubscription
for a while, and I wanted you to be aware that there are two
presubscription ‑‑ we talked about single and double.

When Bill talked about presubscription he was talking about the did you
believe presubscription. Do you understand what I\'m talking about here?
Do you understand what I mean? Okay.

As a telephone user, I let my LEC know of my COC. Then when I use the
relay service I will have to tell the relay service provider again what
my COC is. If I don\'t, then they will have their own long‑distance
service invoked. So it has to be done twice. That\'s what\'s happening
today.

MS. NANKIN: Dave?

MR. WARD: Yes. This is Dave Ward again. That\'s correct, and the reason
for that is the signaling information that contains the identity of your
long‑distance carrier of choice that\'s imbedded in the local exchange
carrier\'s record is not transferred automatically to the TRS center.

And the reason for that is the clarification of their FCC rules between
a TRS center, which is more akin to an information service and the
common carrier, which is a common carrier under our regulations. Common
carriers are not permitted to transmit common‑carrier signaling
information to noncommon carriers at this moment. That is one of the
things we\'re revisiting, one of the issues we are revisited in this
next series of TRS proceedings.

MS. NANKIN: Okay. Thank you. We are now going to open up ‑‑ oh, I\'m
sorry. One more question on carrier of choice from Jamal Mazrui.

MR. MAZRUI: This is Jamal Mazrui, Network Systems Division. I wanted to
visit the customer‑branding issue to understand it better. I understand
in Maryland now under 711 that is not being done. Rather, the CA answers
by voice and then determines what mode the user wants for the call.

First, would somebody explain exactly how that process works, when
someone calls? How does that interaction occur, and are there any things
that could be done to make it more efficient, for example, certain
conventions that might be used to quickly indicate what kind of a call?
And then, on the subject of making it more automatic, what can be
technically done? It just seems like we\'re going back a bit to have to
go to the manual approach.

MS. NANKIN: Is there someone that would like to address this issue,
question? Burt?

MR. BOSSI: Burt Bossi, AT&T. I could speak about the automatic approach,
because that\'s the approach that AT&T has been about for many years. We
don\'t believe we\'re taking a step backwards.

The front‑end automation has worked well for our data users. After the
data users were invoked we added it to the voice users, and they very
much appreciated it because it looks, acts, and feels much like any
other menu‑driven system that they have encountered, so it is very easy
for them to take on. There is no outreach necessary for that at all.

But for this new 711, as we collect these customers of all different
types, to answer your question specifically, we will have ‑‑ this is
plan of record ‑‑ this isn\'t what\'s in place yet ‑‑ the plan of record
is we will answer with a relay prompt, very quick, two-second, press 1
for relay, that will differtiate all of the voice customers away from
the data customers. Okay?

If the voice customers press 1, they get subsequent prompts much like
our upfront automation works now, where they could press different
prompts to go directly to a CA, to enter a forward number, to get the
instructions on what is relay because this is if first time they are
returning a call. It saves CA time. It saves cost. Okay?

If they don\'t press a digit, then we simply go and seek for an ASCII
tone, and then we try to synchronize with Baudot and turbo code. And if
all of the those things fail, we end up back at a CA.

MS. NANKIN: Okay. Sure, Paul. Go ahead.

MR. LUDWICK: This is Paul Ludwick with Sprint. And I wanted to follow up
on what Burt said, simply because I haven\'t really had a good
opportunity as yet. But there is pending rulemaking that governs speed
of answer, when and how it\'s measured, and I think that has a big
impact on what Burt is doing, and also what we are currently working
with the State of New York to implement, and that is a VRU front end for
711 calls.

If calls are measured from the point at which they reach the network,
then based on the rules which have previously been made by the
Commission, all of the relay providers will have a very, very difficult
time of making their average speed‑of‑answers requirements, and the
likelihood of going forward with an automated system that front ends
these calls is small, simply because you would not be able to meet your
target after handling 50 percent of your calls which start off with four
seconds for the message and for the call referral.

So I just wanted to bring that to your attention so that we were
combining all these elements that ultimately have an effect on 711.

MS. NANKIN: Thank you. Pam, did you want to say something?

MS. GREGORY: Hi. This is Pam Gregory from the Disabilities Issues Task
Force, and I wanted to bring up an issue that all of us know about but
hasn\'t really been discussed, and that\'s how 711 will affect the
proposed requirement for speech‑to‑speech relay.

I received ‑‑ Helene and I received an e‑mail this morning from the
speech‑to‑speech user community saying, just a reminder to the forum,
don\'t forget about us. We\'re interested in TRS, and we also want to
know, and we want to be part of 711 implementation. So I need to bring
that to the table. Paul, would you like to respond?

MR. LUDWICK: Yes. I\'m sorry to have so much to say, but this is the
part I prepared for. One of the things we want to keep is 711 does not
lend itself very well to differing user groups. We have four to five
different user gropes within TRS, major groups. You\'ve got the
speech‑to‑speech group, TTY users, voice users, and we also have
language users.

I wouldn\'t expect we\'ll go video over 711 just yet. But that being
said, you have no way of distinguishing which of those user groups
you\'re servicing on any given call, and all relay agents do not process
all calls.

Obviously, not all of our relay agents can speak Spanish, so that\'s
handled by a special group of agents in a particular relay center. So I
don\'t know that we\'re providing maximum benefit to the customers who
are the end users of relay by suggesting that 711 is the ultimate access
for relay because for that group it is answered initially by an
English‑speaking agent and then has to be transferred to a
Spanish‑speaking agent, we haven\'t provided them benefit. In fact,
we\'ve done them a disservice on that particular call.

So I think it\'s the same with speech-to-speech. If you answer a call
and an agent is not trained to process those calls, you have a hard time
at first without being disrespectful of getting the information of
getting the information and making the transfer, which ultimately
extends the call. So this is just something to keep in mind.

MS. NANKIN: Brenda?

MS. BATTAT: This directly relates to what happened here in Maryland with
VCO users, and I can tell you we were extremely upset about it because
everybody was very excited that 711 was coming to Maryland. The VCO, we
publicized it, we talked about it to our members, and then we found out
that none of the VCO users could use it.

And I guess one of the things that I have concern about is that the
state can look at the statistics and say, okay, VCO users, 4 percent of
the users, we\'re not going to give them access to 711. I really have a
problem with that. I really have a major problem with that.

And one of the reasons that the percentage is low is because we are not
reaching the people. We are not marketing to them. We don\'t understand
their uses. I just find this extremely disturbing that the decision was
made based on the statistic of 4 percent. Okay. We\'ll just leave them
out this time around. And I called to find out when we would be
included, and I was told we don\'t have any plans to include.

I really want to stress that when people are starting to set up 711 in
their state, that decisions cannot be made like that to leave out what
potentially is, potentially is, if people can eventually get to them,
the biggest user group. I\'m talking probably a conservative estimate of
about seven million people out there who are potential users, VCO users.
We have to reach them. But by not giving them access to 711, I\'m
telling you, is not a way to reach them.

I\'m, you know, very upset about this. I just want to make sure, because
also, when Paul was talking he didn\'t even mention VCO users. They get
left out. And VCO users, when I\'m talking about access to VCO users
I\'m talking about being they want to come in as a voice user. They do
not want to have to type.

Many of them have VCO phones, and to use the VCO phone, you know, to
type in is just a lot more complicated anyway. So when you\'re talking
VCO user, we\'re talking about them accessing at a voice user, but they
want to be able to have text coming back to them.

Please do not forget this group. We are going to be really causing a big
stink if you do.

THE COURT: Pam, would you like to respond?

MS. STEWART: This is Pam Stewart with Maryland Relay. Brenda, I\'m just
trying to figure out what you\'re talking about. You mean that your
branding as a VCO user isn\'t there, not that you can\'t use it, because
all the person has to do is say \"VCO,\" and they will be able to use
VCO on the 711.

MS. BATTAT: No, no. You cannot. As a VCO user I have to type in.

MS. STEWART: No, you don\'t. I\'ve done it. You just say \"VCO,
please,\" and the operator has the key right there. I\'ll come work with
you one day.

MS. BATTAT: Well, I have not reached an operator yet who has been able
to switch me over to VCO. I cannot be branded on 711. I have been told
that many times.

MS. STEWART: You cannot be branded on 711.

MS. BATTAT: Which means that I have to come in on the TTY.

MS. STEWART: No, no, it doesn\'t. I\'d like to come and work with you on
it because I do it myself.

MS. BATTAT: Nobody has been able to switch me as a voice caller. I\'ve
tried it several times. I\'ve tried it almost monthly to see if there\'s
been any change.

MS. STEWART: Okay. I would love to come down and work with you on that
and see, because if that\'s so, then we\'ve got something we have to
work out because you should just be able to say \"VCO, please\" and
switch you. So I would love to come down and work with you.

MS. BATTAT: Right now I haven\'t been able to.

MS. STEWART: Great. Can I come down and work with you, then? Okay.

MS. NANKIN: Thank you. Bill, would you like to say something?

MR. McCLELLAND: Yes. Bill McClelland with MCI WorldCom. To answer
something that Jamal brought up and something that Brenda brought up
about being able to access the system, there is one thing we haven\'t
discussed and that all the relay providers here are dependent upon, and
that\'s customer-furnished equipment.

If there were changes in the technology on the customer-premise side
that would give some type of out-of-band signaling or out-of-voice-range
signaling to the relay provider, we could key on that very easily and go
in that way. That changes the whole aspect. But that\'s CPE equipment
that has to be changed. It\'s a longer term thing, but it\'s a much more
elegant solution.

MS. NANKIN: Thank you. I\'m sorry. I think we\'re going to have to move
on to the next issues, topics, that were discussed in the second
session, and these topics were Maryland experience and other states\'
experience with implementing 711 in their states. Also, education and
technical assistance to the public about 711 access to TRS, the length
of time to implement a 711 system, and whether to transfer the
administration of N11 codes at the local level from the incumbent plat
to NANPA.

Does anyone have any questions or views or comments on any of these four
topics? I\'m going to open it up to everyone.

(No response.)

MS. NANKIN: Dave, do you want to make your comment about the last
question?

MR. WARD: Yeah. It just made me think of something that the gentleman
from MCI said with the in-band or out-of-band within the same call codes
generated by a CPE. That would be the principle used by a cellular
telephone to access 711 or an abbreviated-dialing route, and the
principle would be the same.

The other thing I wanted to mention was something that was brought up
before by Paul Ludwick and Brenda Battat on service quality, and perhaps
the service-quality issue for equalizing what a non-TRS user and a TRS
user gain from the network is not necessarily expressed in terms of the
number of seconds it takes for a CA to answer the line or, for that
matter, for anyone else to answer the line. Maybe the qualitative
equality is something entirely different, and maybe that difference is
in the utility of the network and not necessarily the time it takes for
the network to provide the service.

I\'m just throwing that out. We don\'t have any basis to change the
regulation here and now, but that\'s something that we may consider in
the future, and a robust record on your opinions on measuring TRS
service like we used to measure local-exchange service may not be the
way.

MS. NANKIN: Okay. Well, I would like to thank our panelists for their
excellent presentations and the FCC staff for their insightful questions
and comments and to thank all of you for coming to the forum.

I would also like to let you know that the transcript will be available
on the FCC Web site within 10 working days and also to thank those
people that are watching on the Internet and that have provided us with
questions and their comments, and their questions and comments will be
part of the record.

I would also like to thank Commissioner Ness, Tom Power, and Yog Varma
for their remarks. And just to state a couple of words, I think we\'ve
had a very stimulating and informative discussion.

I would encourage all of you to submit ex partes to the Commission. For
those of you who do not know what these are, they are simply your
comments or views on the issues discussed today at the forum. In order
for them to be ex parte comments and become part of the record, please
label them ex parte comments and place the CC Docket Number 92-105 on
the document.

Please also send them to the secretary\'s office and provide copies to
Kurt Schroeder, myself, and Dave Ward. The full directions for how to
submit ex parte comments are contained in the public notice announcing
the public forum, which is contained in the handouts.

Again, I just want to thank you all for coming, and I thank you.

(Whereupon, at 4:30 p.m., the forum was concluded.)

//

//

//

//

**[REPORTER\'S CERTIFICATE]{.underline}**

**FCC DOCKET NO.**: 92-105

**CASE TITLE**: PUBLIC FORUM ON 711 ACCESS

**HEARING DATE**: September 8, 1999

**LOCATION**: Washington, DC

I hereby certify that the proceedings and evidence are contained fully
and accurately on the tapes and notes reported by me at the hearing in
the above case before the Federal Communications Commission.

Date: \_9-8-99\_\_\_ \_\_Theodore Fambro\_\_\_\_\_\_\_\_\_\_\_\_

Official Reporter

Heritage Reporting Corporation

1220 \"L\" Street, N.W.

Washington, D.C. 20005

**[TRANSCRIBER\'S CERTIFICATE]{.underline}**

I hereby certify that the proceedings and evidence were fully and
accurately transcribed from the tapes and notes provided by the above
named reporter in the above case before the Federal Communications
Commission.

Date: \_9-15-99\_\_ \_\_Theodore Fambro\_\_\_\_\_\_\_\_\_\_\_\_\_

Official Transcriber

Heritage Reporting Corporation

**[PROOFREADER\'S CERTIFICATE]{.underline}**

I hereby certify that the transcript of the proceedings and evidence in
the above referenced case that was held before the Federal
Communications Commission was proofread on the date specified below.

Date: \_9-20-99\_\_ \_\_George McGrath\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Official Proofreader

Heritage Reporting Corporation