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 NO1
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 d 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 NO1 the FCC stated the purpose of this review of the 199
1 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
3assure 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      
4served 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 NO1 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
6over the phone. The Association of Late Deafened Adults stated
most emphatically in their NO1 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 NO1 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
7received 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) NO1 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 NO1 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 NO1 statement that a
9technology developer "may be less eager to develop a new
technology if it knows that as soon s 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 NO1 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 ison the line, and
10 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 NO1 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
11 that may provide additional benefits to TRS users (See NO1 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 NO1 comments. Ultratec
supports GTE's NO1 statement that the FCC should not impair the
development of technology (GTE NO1 comments at6-7). Ultratec also
wishes to endorse Pacific Telesis' NO1 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 NO1
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 
12 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 NO1 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 Cornmission 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 NO1 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
13 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 NO1 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 NO1 comments at l-2). The 
State of Maryland also acknowledged the need to increase minimum
standards. Raising the minimum standards contained in Title IV of
14 the ADA would allow a greater degree of parity in the ease of
access and usage between TRS calls and standard voice calls (MD
NO1 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, 199 1, 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."

1.5

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), 101 st Cong.,

2d Sess. 130 (1990)

  Ultratec agrees with numerous NO1 comments that acknowledge
relay

services "have not kept up with technological advances in the
rest of the

telecommunications industry" (NVRC NO1 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 NO1 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 NO1 comments
at 6).

16

-.-

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
NO1 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 NO1 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.

17

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 NO1 submissions on the need
for a mandated

minimum standard for improved Communication Assistant typing
capabilities

(NO1 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 NO1 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 199 1
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, 199 1). 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 "pm. 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.

19

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 NO1 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 NO1

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 NO1 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 NO1 comments at 15).

20

  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 NO1 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.

21

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.

22

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 NO1 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 (NO1
comments of DC/VA

at 3, NAD at 13, MATP at 3, ALDA at 3, WT 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 ad does

24

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 NO1 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 NO1
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.

2.5

  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 capabll ltv 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.

26

  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.

27

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.

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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. IJsing 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.

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  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

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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

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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

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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

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