Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
_______________________________
)
In the Matter of )
)
Telecommunications Relay Services, ) CC Docket No. 98-67
and Speech-to-Speech Services for )
Individuals with Hearing and Speech )
Disabilities )
_______________________________ )
COMMENTS OF
ULTRATEC, INC.
Pamela Y. Holmes, Director
Consumer & Regulatory Affairs
Ultratec, Inc.
450 Science Drive
Madison, WI 53711
(608) 238-5400 TTY/Voice
Comments: July 20, 1998

I. Introduction/Overview

Ultratec, Inc. hereby submits these comments in response to the Federal
Communication Commission's Notice of Proposed Rulemaking (NPRM) CC
Docket No. 98-67. As a technology provider and a leading manufacturer of text
telephones (TTYs), Ultratec takes great interest in this proceeding since the TRS
network provides a critical communications link for our consumer base as they go
about utilizing the telephone network. Ultratec believes this proceeding will
benefit from our sharing some of the technological solutions we have developed
which could bring the TRS network to a new and higher level of performance.
Ultratec takes special note of the strong expression for functionally
equivalent access by all the major commenters in NOI comments submitted on
March 17, 1997, and April 21, 1997. Ultratec believes the Commission's NPRM
should be expanded to further address the expressed concerns of consumers and
administrators regarding the implementation of technological advancements to
ensure that the telecommunications access afforded to individuals with hearing
loss and speech impairments is 'functionally equivalent' to voice calls.
Ultratec applauds the FCC's issuance of an NPRM with the intent of
providing final rules that include needed changes in order to make certain this
important service is facilitating communications for all those who rely on the TRS
system as envisioned. TRS serves as a vital tool necessary to ensure those who are
deaf, hard of hearing, late-deafened, deaf-blind and speech impaired
telecommunication access for purposes of business, safety, social actions and
optimal employability. In exploring whether the current provisions are sufficient,
one needs to evaluate whether the existing system as currently regulated and
operating serves all the various segments of this population including the hearing,
non-text based users that complete the vital link established in these
communications in a cost effective, functionally equivalent manner.
A. Overview of the NPRM Purpose and TRS Provisions
In the NOI the FCC stated the purpose of this review of the 1991 TRS Order
was, " to ensure...an effective statutory scheme that provides the greatest degree of
access to telecommunications services by individuals with hearing and speech
disabilities." As noted in the FCC NPRM, Congress clearly intended for our TRS
network to keep up with emerging telecommunications provisions to assure
continued access for all segments of the served population. As stated in the House
II Report at 130:
"This legislation is not intended to discourage innovation regarding
telecommunications services to individuals with hearing and speech impairments.

The hearing and speech-impaired communities should be allowed to benefit from
advancing technology. As such, the provisions of the Section do not seek to
entrench current technology, [emphasis added] but rather to allow for new, more
efficient and more advanced technology."
Ultratec fully endorses full implementation of Congress' stated intent and
wishes to see the Commission help bring about the use of innovative new
technologies which will help our nation's TRS network stay in line with current
technological possibilities. In fact, in the Commission's NPRM, VRI and STS are
tentatively proposed as "improved services" that "[go] beyond the current TTY-to-
speech
and speech-to-TTY model," thus extend TRS provisions to those not
already optimally served by the current TRS system. Covering these extensions of
service to ASL users and speech impaired users with reimbursement from the TRS
Fund seems appropriate. We endorse this proposal, and ask that the Commission
entertain expanding this list of "improved" services to include other technologies
that allow TRS to reach under served segments such as for those that are late-
deafened
and those who require real time transmission to compete optimally in the
employment arena. Utilization of voice recognition applications such as Fastran
(Fast Transcription) would be a most appropriate example of a service
enhancement that could reach this untapped pool and would benefit from cost
recovery mechanisms to hasten implementation. Incorporation of voice
recognition technology applications specially designed for relay such as Fastran
will allow TRS to serve a group of individuals currently not sufficiently served by
existing TRS as shown by comments received in the NOI proceeding. As several
commenters asserted, the costs for "improved" TRS should be recoverable from
the TRS fund, regardless of whether such improved services are required or are
provided voluntarily, if they expand the relay to encompass a new segment of the
intended population, yet to be properly served by the current TRS system. We
believe it is appropriate to consider Fastran application for relay as one of the
"improved" services that can qualify for cost recovery, because we believe initial
cost to implement this innovative solution will be a potential obstacle based on the
general practice of 'lowest bid' wins currently in effect across the nation.

B. Cost Recovery for Under Served Segments of the Population
Our nation's relay service opened the doors for 24 hour, 7 days a week
telecommunications access nationwide. We commend those who have
implemented TRS as widely as seen to date, since on occasion legislative
initiatives fall short of proper implementation and enforcement. In fact, the
provision of TRS has probably been one of the most widely implemented
telecommunications-related provisions of this legislative era, aside from
implementation of 911 direct TTY access. However, in this proceeding the
Commission should take care to make certain that the new TRS Order truly
encompasses and serves the entire community of those who are deaf, hard of
hearing, late-deafened, speech impaired. As the FCC has well noted, those who
have speech impairments and those who rely most heavily on ASL represent an
untapped, under served segment of the population TRS is intended to serve. We
believe another untapped, under served segment lies with those that are late-
deafened
as well as deaf, and hard of hearing professionals.
This segment of our population needs, and has requested real-time
transmission to remain competitively employed and interested in making use of
the TRS for all their transactions over the phone. The Association of Late
Deafened Adults stated most emphatically in their NOI comments that, "real-time
transmission is fundamental to 'functional equivalence.' Its absence to date has
generated widespread animosity for today's model of service, and hostility and
impatience on the part of the voice-user towards people who are deaf, hard of
hearing, or speech impaired" (ALDA NOI Comments at 5). Those that grew up
using the phone in the traditional manner often find TRS does not meet their
desired communication level, thus they avoid using the service and sometimes
they avoid using the telephone on their own all together.

C. Title IV Intent to Help Level the Employment Playing Field
If the ADA was intended to 'level the playing field' in the area of
employment, Title IV of the ADA needs to serve as a mechanism to assure real-
time communications to those who need this telecommunication access. If a
prospective employer asks a deaf applicant how they will perform the essential
functions of the job, the deaf candidate is likely to indicate they will rely on relay.
If the prospective employer's experience with relay is not one that they want their
customers and clients to experience this becomes troublesome. In fact, this author
has heard from numerous deaf TRS users stating that their superiors have received
calls from hearing clients and customers asking that the deaf employee not be
allowed to call them through relay as they find it a cumbersome and undesirable
experience. As discriminatory as this may be, this clearly indicates that the current
system is still not optimal or acceptable to some in the employment arena. This
becomes problematic if Title IV is intended to resolve this communication
obstacle for gainful employment.

Also, if one polls text-based, employed professionals as to whether they are
confident and comfortable relying on relay for professional, business calls we
believe you will find many will tell you TRS as currently implemented at limited
text transmission speeds, and often limited typing speeds does not meet their
needs. In fact, many deaf professionals (including some employed by TRS
providers) will tell you they use interpreters to facilitate their calls to control how
they come across over the phone as professionals. For those who do not have the
luxury to compensate in this manner they either take a business risk, ask a co-
worker
to assist them or make the call for them, or scramble to find another avenue
of communicating such as via e-mail or fax. Fortunately these avenues exist,
however, they cannot always replace the back and forth communication that is
available in a live telephone call, and the need for such individuals to be
independent of reliance on others.
If you also poll the hearing non-TTY user regarding their experience of
Relay, although they are grateful for some means of communicating, they too will
tell you it is not the experience they desire or expect given all of the potential
technology that could allow TRS to be a much "improved" service. The National
State Relay Administrators (NASRA) NOI comments state that "technology is
desperately needed to make TRS more 'user friendly' and efficient for voice TRS
callers. The FCC should encourage the industry to develop technology that would
improve the 'flow' of relay calls to be more similar to that of a voice call"
(NASRA NOI comments at 12). Ultratec points out these short comings of our
current TRS system to illustrate the need for technological solutions to address
these weaknesses.
D. Care in Avoiding Anti-Competitive/ Regulatory Practices
Ultratec believes the Commission should not enter into anti-competitive or
harmful regulatory practices that would target specific technologies or technology
developers in ways that would injure their incentive to innovate and supply better,
more cost effective, more time efficient methods of providing TRS services.
Ultratec concurs with Sprint's NOI statement that a technology developer "may be
less eager to develop a new technology if it knows that as soon as it offers the new
technology in the marketplace, the Commission will require ...competitors to also
offer that technology and as a result limit the carrier's ability to reap the full
benefit of its innovation in the marketplace" (Sprint NOI Comments at 4). Ultratec
is not asking the FCC to mandate any specific technologies, however, we are
asking that such technologies provided they have real value to the TRS user, be
recognized as "improved" services that better serve the intended population and
thus are eligible for coverage of TRS Fund cost recovery when implemented.
We wish to note, many of the most important technologies used by TRS
have been developed and patented including the most basic technology of all,
Baudot or "Baudot/Weitbrecht" as it has historically been known. This proprietary
technology, which launched the TTY network in 1963 and upon which the TTY
network is still based, was invented by Robert H. Weitbrecht who patented this
technology and received royalties for the use of it until he died in 1983. VCO and
HCO are also patented inventions which were developed in the mid 1980's and
were first demonstrated by Ultratec at Gallaudet University in 1988. Auto Code
which automatically detects ASCII, Baudot and other codes and automatically
switches the TTY appropriately, Auto I.D. which automatically sends TTY signals
during silent periods so that hearing people will know a TTY is on the line, and
Enhanced TTY Protocol or "Turbo Code" are all patented inventions which have
served to significantly enhance the use and accessibility of the TTY and TRS
network. Many large TRS providers have also been patenting their innovations
and
utilizing their proprietary technologies. Should the Commission impose
regulations which would target such technologies for competition or bring unfair
pressure upon the technology developers, forcing them to give up the rights to
their inventions, there would be little incentive to invest further resources in
improving the network.

II. Need for Technological Advances

A. Industry/Consumer/RBOC/State Administrator Support
Ultratec strongly endorses the NOI comments that support the need for
technological advances and innovativeness. We feel it is very important that
services do not become stagnant and ineffective over time, and that new and
existing technology is implemented. Supporting this view, the FCC has sought to
assure that its administration of the TRS program will not inadvertently deter or
inhibit the deployment of new and advanced technologies that may provide
additional benefits to TRS users (See NOI at 8 -quoting legislative history, and
AT&T at 2-3). In addition, Ameritech, Bell Atlantic, NYNEX, Bell South and
Pacific Telesis generally encourage the deployment and development of improved
forms of TRS where technically and economically feasible and where sufficient
demand exists in the NOI comments. Ultratec supports GTE's NOI statement that
the FCC should not impair the development of technology (GTE NOI comments at
6-7). Ultratec also wishes to endorse Pacific Telesis' NOI comments and the
Commission's goal of ensuring that technological improvements are made
available to persons with disabilities to enable them to fully participate in
telecommunication services (PacTel NOI Comments at 3).

B. Cost Effectiveness/Cost Recovery Mechanisms
Ultratec believes an effective cost recovery mechanism is important.
Without it, contractual agreements often lock themselves into current technologies
for 3 to 5 years. Some states are wisely adding clauses allowing for emerging
technologies that come about during their contract's life span. As important, we
believe that relay services should be operated in a cost effective manner with
quality service which benefits the consumer, the Relay Administration, and the
rate/tax payers who must foot the bill. There presently exist new technologies
which are readily available and can provide tremendous cost benefits, yet are not
being fully utilized nationwide in part due to lack of cost recovery mechanisms.
The Oregon PUC NOI comments suggested rules should be written to
provide incentives to resolve issues such as cost. Ultratec agrees with Oregon and
others and encourages the FCC to carefully consider the option to allow cost
recovery issues when associated with "improved" TRS provisions.
The Commission "agreed with commenters" in paragraph 58 of the
NPRM, "that new technologies, such as enhanced protocols and enhanced
computer software, could greatly increase TRS transmission times and,
consequently, CA typing speeds." (FCC NPRM at paragraph 58). The
Commission seeks comment on the extent to which such technologies have
been adopted by TRS users and TRS providers.
A number of states have implemented use of enhanced protocols since the
NOI comment period. To our knowledge, the states that currently offer an
enhanced protocol are New Jersey, District of Columbia, Maine, Georgia,
Tennessee, California, and Wisconsin. More states are expected to implement use
of an enhanced protocol this year. We hope the states that have implemented this
enhancement or those who intend to implement use of an enhanced protocol will
share this in more detail with you. Several states have contracts expiring in the
next year, thus we anticipate others will consider securing this communication
protocol amongst other new provisions.
At this time, Fastran is very new technology that has yet to be
implemented, but offers tremendous potential for higher transcription speeds
amongst the CA labor pool. With Fastran, a CA simply re-voices the hearing
party's comments, thus the typing speed issue becomes a 'non-issue' as voice
transcription would transmit the spoken text at speeds close to spoken speech.

III. Recognition of Need for Improved and Updated Standards

A. NOI Commenters' Support
Ultratec supports NOI commenters that expressed the need for improved and
updated standards for the purpose of achieving a quality program that brings about
functional equivalence. NASRA acknowledged that current mandatory minimum
quality standards are not strong enough (NASRA NOI comments at 1-2). The
State of Maryland also acknowledged the need to increase minimum standards.
Raising the minimum standards contained in Title IV of the ADA would allow a
greater degree of parity in the ease of access and usage between TRS calls and
standard voice calls (MD NOI comments at 4). All consumers' comments took
strong positions that current standards are inadequate in that they do not reflect
normal, and 'functionally equivalent' telephone conversations between two people
who hear and speak. We believe since functional equivalence was the intent of
Congress, some fine tuning should be done to bring the mandatory minimum
standards up to a more appropriate functional level. However, we feel that care
should be taken to balance regulatory requirements with flexibility for innovation,
thus we concur with Ameritech in their recommendation that the Commission
continue to prescribe minimum quality requirements that are designed to ensure
equivalent and high quality services from the end users' perspective across all
centers (Ameritech at 5-6).

B. FCC 1991 Statement of Intent to Improve Standards as Needed
In the FCC Report and Order released July 26, 1991, the Commission stated,
"we intend to monitor closely, through the complaint process and otherwise, the
actual quality of relay services. If experience shows that imposition of additional
minimum standards is required, we will not hesitate to prescribe such standards."

IV. Functional Equivalence

A. Intent of Congress for Title IV of the ADA
The NAD noted in their initial NOI comments Congress' unequivocal
mandate that regulations implementing Title IV "not discourage or impair
development of improved technology." 47 U.S.C. 225(d)(2). Rather than
"entrench current technology," Title IV was designed "to allow for new, more
efficient and more advanced technology." H.R.Rep. No. 101-485 (II), 101st Cong.,
2d Sess.130 (1990)
Ultratec agrees with numerous NOI comments that acknowledge relay
services "have not kept up with technological advances in the rest of the
telecommunications industry" (NVRC NOI comments at 6). We concur with
SHHH's point stating that, "there needs to be more of a commitment on the part of
relay providers to invest in improvements in technology to bring some
sophistication to the relay" (SHHH NOI comments at 4-6). NVRC wisely points
out that, "current standards do not address the effectiveness and quality of TRS"
which would result in functional equivalency (NVRC NOI comments at 6).
B. Need to Keep Pace with Available Means
Ultratec as well as "NASRA believes that technology is desperately needed
to make TRS more user friendly and efficient for voice TRS callers. The FCC
should encourage the industry to develop technology that would improve the flow
of relay calls to be more similar to that of a voice call" (NASRA NOI comments at
12).
NAD raised the need for "comprehensive monitoring of relay services
nationwide, combined with coordinated efforts by consumers, industry, and
government to ensure those services keep abreast of current technologies...to
ensure a level of relay service that is functionally equivalent to telecommunication
services enjoyed by the general public" (NAD NOI comments at 17-19). Thus, we
are puzzled as to why the Commission largely ignored the expressed concerns of
major commenters for implementation of new technologies that would bring about
functionally equivalent, real-time communications. Functional equivalence needs
to go beyond the 'dial tone' via better answer times, to truly make an impact on
the overall relay experience.
V. Operational, Technical, and Functional Standards
A. Mandatory Minimum Standards
1. CA Competency Skills -Typing Capabilities - Sec. 64.604 (a) (1)
Nearly all of the consumers of relay, as well as the National State Relay
Administrators, commented in their NOI submissions on the need for a mandated
minimum standard for improved Communication Assistant typing capabilities
(NOI Comments of SHHH at 3, AGBell at 3, MATP at 3, CAD at 2, ALDA at 5,
NAD at 6, DC/VA at 3, Nelson at 5, NASRA at 4-5, Coalition at 2). ALDA
pointed out that "minimum standards are painfully inadequate and there is no
incentive for relay providers to exceed them" provided the current structure
lacking consumer-driven competitiveness (ALDA NOI at 4-5). ALDA further
pointed out the current minimal standards do not define and address the
operational, functional and technical standards that are fundamental to a
functionally equivalent service (ALDA NOI at 7). In the 1991 proceeding, the
FCC modified the proposed rules to require TRS providers themselves to be
responsible..." rather than articulate a low threshold of expectations" (FCC Report
and Order, July 26, 1991). As pointed out by the Coalition of Protection and
Advocacy Systems "the CA's typing speed must be increased" (Coalition NOI
Comments at 2).
TRS providers acknowledged it would be difficult to find CA's with this
level of ability in the labor pool. Given the number of commenters (most
importantly the actual users of TRS) that strongly recommended an improvement
in the minimum speed of the overall conversation, it would seem merited that the
FCC consider a bare-bone minimum of no less than 60 words per minute (wpm) to
at least be within the optimal capabilities of the Baudot code at 45.5 baud. Many
commenters suggested typing speeds of 100 wpm. Perhaps the overall concern
can be addressed with voice recognition technologies such as Fastran instead.
Higher transcription speeds are vital to those who wish to take advantage of the
true benefits of enhanced protocols such as Turbo Code or ASCII. Ultratec
encourages the FCC to set minimum requirements for the speed of transcription
(either via CA typing speed or voice recognition use with the CA re-voicing) to
reflect the capabilities of the consumer's current equipment.

VI. New Technologies - Sec. 64.604 (b) (5)
The current regulations state, "No regulation set forth in this subpart is
intended to discourage or impair the development of improved technology that
fosters the availability of telecommunications to persons with disabilities."
Ultratec supports the numerous NOI commenters who expressed the
importance of utilizing new technologies especially new technologies which are
already available. Louisiana Relay Administrative Board encouraged this view
stating, "Technology affords us many opportunities to improve the quality of relay
service. Enhanced protocols such as Turbo Code...enable more efficient use of a
CA's time and a better quality of service to the end user" (LA Relay Adm Bd NOI
comments at 4). Other commenters also noted, "Typing speeds can be enhanced,
especially with the introduction of the new TTY technologies such as Turbo
Code...This would reduce the length of calls, thereby reducing the cost of
services"
(CA PUC NOI comments at 14). NVRC stated, "TRS providers should be
required to regularly upgrade their equipment to keep up with TRS users. This
would include the ability to communicate through Turbo Code..." and keep up
with the pace of technological solutions to unnecessarily slow transmissions, once
they are readily available (NVRC NOI comments at 15).
The remainder of our comments reiterate previously shared information
provided in our reply comments for the Notice of Inquiry. We are entering the
information here so that it is contained within this proceeding as well.
A. Enhanced TTY Protocol (Turbo Code)
Enhanced TTY Protocol, trade named Turbo Code, was invented by
Ultratec specifically to address the telecommunications needs of deaf, hard of
hearing, and speech impaired individuals and to overcome the shortcomings of
traditional Baudot/Weitbrecht and ASCII codes as used in the text telephone
environment. Over the past eight years, Turbo Code has been continuously
improved, modified, and adapted for a variety of applications in text and
combined voice/text communications. Several NOI commenters have made
reference to the speed of Turbo Code and other technical specifications which
Ultratec wishes to clarify for the general benefit of this proceeding.

1. Speed of Turbo Code
The original Turbo Code operated at a maximum speed of approximately
105 words per minute (approximate because of the unique timing of each
character
transmitted, thus different words actually transmit at slightly different speeds).
This is almost twice the speed of Baudot. This speed was chosen because it is
faster than the sustained rate that most people can type (and close to the average
sustained rate that most people talk), yet remains slow enough to be easily
readable
on a traditional 20 character TTY display, even when messages are being sent
from
memory by another TTY or by TRS at maximum speed.
More recent versions of Turbo Code are capable of speeds substantially in
excess of 105 wpm to enable Turbo Code to keep pace with the anticipated speed
of real time relay transcription and to speed up data transfers between the TRS
equipment and the user's TTY when automating calls. Enhanced versions of
Turbo Code also have the capability of slowing down for users whose reading
abilities require slower speeds. The receiving user will be able to control the rate
of transmission from the transmitting party so that reception is at a pace
comfortable to the receiving user.
2. Turbo Code Character Set
Turbo Code is based on a seven bit table which allows for 128 characters.
This compares with only 62 available characters for Baudot and is equivalent to
the character set for ASCII.
3. Compatibility with Baudot and ASCII based TTYs
Turbo Code is completely compatible with older TTYs which do not have
Turbo Code capability. Turbo Code automatically searches to see if the other TTY
is Turbo Code capable by periodically sending a very short burst called a
"synchronization signal". If the other TTY sends back an appropriate signal,
Turbo Code is linked. If not, the Turbo Code unit reverts to Baudot. This
searching is completely transparent to the user and is totally automatic.
In the event that the Turbo Code equipped TTY also has ASCII code, ASCII
is included in the Auto Code search sequence.
B. Advantages of Enhanced TTY Protocol with Interrupt Capabilities
Ultratec agrees with the many NOI commenters who have recognized that
Turbo Code can be of significant value in the relay environment. Consumer's
commented, "Enhanced protocols would be of great value to traditional users of
TRS. ASCII is not always a reliable communication mode. Newer technologies
exist which improves Baudot transmission time yet retains the flexibility of call
transfer, hold, and other functions which can be done via a voice transmission.
Interruption functionality allows for a more natural communication flow. The
FCC should encourage the deployment of this technology" (WI TRS ADV at 4-5).
SHHH supported the deployment of "widespread awareness and availability of
alternative protocols such as the interrupt capabilities which can cut down on the
length of the call by as much as 30%" (SHHH NOI comments at 5). VA/DC
Association of the Deaf, NAD, MATP, and ALDA all commented that newer TTY
protocols, such as Turbo Code, would more closely approximate the speed of
talking, coupled with higher typing speed requirements (NOI comments of
DC/VA
at 3, NAD at 13, MATP at 3, ALDA at 3, WI TRS ADV at 5). However, the
Massachusetts Assistive Technology Partnership noted, "Turbo Code is readily
achievable and available today. It provides faster transmission of the text and does
not have the 60 wpm transmission limit that Baudot has." MATP also noted,
"There is no incentive for relay providers to use Turbo Code, just as there is no
incentive for providers to encourage faster typing speeds by operators because
they
are reimbursed at per-minute rates, and there is no incentive for them to make the
calls any shorter" (MATP NOI comments at 3).
1. Advantages to the Consumer and the Relay Administration
The National Association of State Relay Administrators has acknowledged
the potential cost savings of providing an enhanced protocol in their comments.
"This technology may also reduce the overall minutes of use for relay
services...The speed of transmission should reduce overall minutes of use
including long distance charges to the TTY customer" (NASRA NOI Comments at
10).
Ultratec has conducted extensive testing of Turbo Code as used in relay calls
and has found that the faster transmission speed of Turbo Code alone can save
from 10% to as much as 45% of the time necessary to complete the same relay
call.
At present, the actual average time saved tends to be in the 10% to 20% range, due
primarily to the typing speeds of CAs.
Turbo Code was specifically designed for TTY/TRS use and has several
unique attributes which can further reduce relay call time. As an example, Turbo
Code is automatic. It is not dependent on the TTY user to remember to turn it on.
The opportunity for improved performance is always active. Only a small
percentage of ASCII calls are made to relay, partly because it takes a conscious
effort on the part of the TTY user to make an ASCII call. The user must
specifically know they want to do so and set the proper speed, parity, stop bit, and
duplex settings. With Turbo Code, the technology is engaged whenever available,
thus all Turbo Code equipped users benefit whenever Turbo Code is available.
Another attribute of Turbo Code is interrupt capability which can
significantly reduce the time of a relay call by eliminating unnecessary
conversation. Voice telephone users often interrupt each other during a
conversation, thus speeding the exchange of information. Traditional Baudot does
not allow the CA or the user to interrupt the conversation, thus many
conversations
drag on until the originating party is totally finished. By using interrupt, a user can
ask the originator to move on to another topic, thereby saving whole sections of
conversation similar to the way voice users do.
Another time saving attribute of Turbo Code is direct calling, which allows
the user to dial on their TTY the number of the party they are calling, push one
button on their TTY, and connect to their party through TRS with no interaction
with the CA. This saves virtually all of the "set-up" time for the call. It also
eliminates the inconvenient and unnatural "call within a call" required in
traditional TRS operation. This is a great time saver for both the user and for the
relay and provides a level of service that much more closely approximates that of
the voice telephone network.
Enhanced Turbo Code equipped TTYs are capable of storing user specific
data (the user has total control over this data) which is automatically transmitted to
the relay at the beginning of a call, so that the relay may profile automatically
from
the user's TTY rather than from the user's telephone number. This allows TTY
users to take their profile along as they travel or change the location of their TTY
equipment, thus speeding the set-up with the relay no matter where the user is
calling from. This attribute also allows each user control over her/his profile so
that s/he may change it from time to time, according to individual needs and
preferences.
2. Availability and Cost of Turbo Code
Turbo Code utilizes the same frequencies as traditional Baudot, which were
accurately chosen by Robert Weitbrecht as the best frequencies to send and
receive
low speed data over acoustically coupled telephone lines. These frequencies also
allow Turbo Code to be built into TTYs at little or no additional cost because the
same circuitry may be employed to enable both traditional Baudot/Weitbrecht and
Turbo Code. Turbo Code is supplied free in all new Ultratec TTYs.
Ultratec is also a TRS equipment supplier. Turbo Code capability is
included in Ultratec's InteleRelay equipment as part of the cost of providing the
equipment. There is no additional charge for Turbo Code.
For relays that use non-Ultratec TRS equipment, Turbo Code is available
through a licensing agreement or for a small monthly fixed fee. Due to the reduced
time of a Turbo Code call, the relay administration will actually save many times
this cost, since using Turbo Code can save from 10% to 45% of the time to make a
call. Even the relay users themselves save money out of their own pocket due to
lower charges for shorter long distance calls.
C. High Speed Transcription Technology (Fastran)
In order to achieve real-time relay, there not only needs to be protocols and
user devices that are capable of supporting the faster data transmission rates, but
there also needs to be a method by which spoken information can be transcribed
into text in real-time. Mandating faster typing speeds may be an interim step
towards achieving functional equivalence, but will not be sufficient in achieving
true real-time equivalence.
The world record for typing was set many years ago and was only in the 150
words per minute range. Even this astonishing accomplishment could not be kept
up for very long by the record holder. Only when the transcription rate is able to
keep up with the natural speed of speech will real-time relay become a reality.
Ultratec has experimented with a number of methods of achieving high
speed transcription with promising results. Using a unique method which
combines voice recognition, typing, and several other technologies, Ultratec has
developed transcription systems that will allow a CA with relatively modest
typing
skills to achieve transcription speeds in excess of 100 words per minute with
optimal spelling and word for word accuracy. Ultratec has named this technology
"Fastran", short for Fast Transcription.
As technologies like Fastran become available, true real-time relay becomes
a realizable objective without the need to increase CA typing speed requirements.
Ultratec urges the FCC to encourage the development and use of this new kind of
transcription technology in TRS to help attain true real-time relay service.
D. TTY Protocols, Industry Standards and Compatibility
Currently there are three major protocols used in TTYs in the United States:
Baudot/Weitbrecht, ASCII Bell 103, and Enhanced TTY Protocol (Turbo Code).
Virtually all TTYs in North America have Baudot/Weitbrecht capability. Ultratec
estimates that Turbo Code is the next most widely used enhanced protocol
followed by ASCII.Baudot, being the original protocol of the North American
TTY network, is present in all new Ultratec TTYs being produced.
The population of Turbo Code equipped TTYs is also growing primarily
because Turbo Code costs the consumer nothing to have included in their TTY,
Turbo Code is totally transparent to the user in terms of ease of use, and Turbo
Code is becoming widely accepted due to its enhanced communication capabilities
compared with Baudot and its lack of inherent problems such as disconnects and
set-up complexities and problems which are present with ASCII.
The demand for ASCII equipped TTYs is less than 10% of all TTYs
currently being produced by Ultratec apparently due to their increased cost (retail
is $39 to $79 more per unit), they are considerably more complex to use, and there
is little acceptance or use of ASCII in the TTY network due to disconnects and
set-up problems. Many state programs are now asking for simpler, non-ASCII
equipped TTYs because training users to use ASCII is far more complex and the
actual use of ASCII is very limited.
Ultratec supports the concept of maximum compatibility between all TTYs
and between TTYs and TRS equipment so that all TTY users may take advantage
of the benefits of TRS and of new technologies as they become available. Clear
guidelines for Baudot/Weitbrecht and ASCII Bell 103 protocols have long been
established and are readily available to all providers of TTY equipment and
services. The specifications for Turbo Code and the guidelines regarding its use
are also well defined and available from Ultratec through licensing agreements.
Because all of these protocols are well defined, uniform, and all of the necessary
detailed information on their implementation is available in accordance with
universally accepted business practices, Ultratec believes that TTY protocol
standards are adequately established at this time.
VII. Conclusion
Relay services have made a tremendous impact on people's lives throughout
the country by allowing TTY users to call anyone, whether they have a TTY or
not. Despite the wonderful service it provides, Relay has not yet gained
widespread acceptance due to its limitations. Even simple Relay calls can take far
longer than voice calls. There can be long pauses or delays in conversation with
no way to interrupt people during a call. Many of these frustrations are due to old-
fashion and unnecessarily complex technology, which limits the appeal of Relay
to a wider population. 
Ultratec feels the FCC should encourage the use of new and useful
technologies to ensure the intent of Congress for those who rely on text telephones
and other forms of visual communications, to gain real-time functional
equivalence
within our telephone network. It is imperative that the FCC take a strong stand for
the use of technological solutions and advances as they become available.
However, Ultratec does not encourage the FCC to mandate the use of any specific
technology nor should the FCC limit the technologies that TRS may use to
promote better and more functionally equivalent service. Ultratec encourages the
FCC to consider expanding the cost recovery mechanism provision to incorporate
implementation of voice recognition applications such as Fastran to reach
untapped and under served segments of the intended population.
Ultratec encourages the FCC to explore means of bringing about a truly
consumer-driven competitive TRS environment, and to assure a cost effective,
functionally equivalent service for those who must rely on this avenue of
accessing
our nation's voice-based telecommunications network.

Respectfully submitted,
Pamela Holmes, Director
Consumer & Regulatory Affairs
Ultratec, Inc.
450 Science Drive
Madison, Wisconsin 53711
July 20, 1998