FCC Consumer Advisory Committee
Recommendation: Support of Petition for Rulemaking Filed by Rebecca Ladew, 
June 26, 2006
In the Matter of
Telecommunications Relay Services And Speech- To- Speech Services ) 
For Individuals With Hearing And Speech Disabilities 
CG Docket No. 03- 123 
The Consumer Advisory Committee (CAC) offers these comments in support of a 
Petition for Rulemaking filed by Rebecca Ladew in docket No. CG 03-123 on 
June 26, 2006. 
On March 6, 2000 the FCC released a report and order stating that a Speech to 
Speech communications assistant (CA)  must remain on a call for a minimum of 
15 minutes.2 At that time, the FCC explained that the requirement, “reduces 
potential disruption and will make the call more functionally equivalent to voice 
telephone calls.” 
The Consumer Advisory committee (CAC) respectfully requests that the FCC 
extend the minimum time on a Speech-to-Speech call to twenty (20) minutes for 
the following reasons:
1. It takes enormous concentration for many persons with 
speech disabilities (PSDs), in contrast to people without a 
speech disability, to perform the following tasks, all at the 
same time: 
a. Begin speaking,
b. Think and form their response, and
c. Listen with intent to their caller.
2. The interruption caused by the change of agents disrupts the 
PSD’s concentration on each of these activities. Example 
from STS user, “Sometimes I am so flustered by that 
interruption that I forget what I am going to say. Other STS 
users have reported the same concern.”
  
2 Telecommunications Relay Services and Speech-to-Speech Services for Individuals with 
Hearing and Speech Disabilities, Report and Order and Further Notice of Proposed Rulemaking, 
CC Dkt. 98-67, FCC 00-56, 15 FCC Rcd 5140 (March 6, 2000), ¶68.
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3. It generally takes a few minutes for a CA to begin to maximize 
his or her understanding of the speech patterns of a particular 
PSD. Once this understanding of the PSD is maximized, the 
speed of the conversation can increase. Unfortunately, when 
agents change, this process of maximizing conversation pace 
must begin again. 
4. CAs often have trouble understanding people’s names and 
unusual technical words spoken by the PSD.  This results in 
the PSDs being required to spell out these words. After a 
change of CAs, the PSD must repeat this entire process 
again. This results in slowing down the conversation 
considerably.
5. Reducing the frequency of CA change increases the fluidity of 
the call.  The result is a call that is more functionally 
equivalent to a call between two non-speech disabled callers.
6. Reducing the frequency of CA change will also save relay 
costs because calls will be processed more efficiently, without 
the need to ask the PSDs to unnecessarily repeat words and 
phrases.
At the time that the FCC adopted this rule, it explained that this amount of 
time made sense in part because most traditional TRS calls lasted for less 
than ten minutes.3 Given their nature, however, STS calls often last longer 
than text-to-voice calls; changing CAs on these calls prior to 20 minutes 
can seriously disrupt their flow and impair functionally equivalent 
telephone service.  Accordingly, the CAC requests that the FCC extend 
the time a CA remains on a call to 20 minutes. 
We further request that the FCC specify that the 20 minutes on a call  
requested above begins when effective communication begins.  Effective 
communication is achieved when the CA is able to relay the 
communications between the parties accurately and impartially, and 
interpret for the PSD both receptively and expressively, using any 
necessary specialized vocabulary.  Whether or not effective 
communication has been achieved should be determined on a case by 
case basis. What this means is that although the CA may generally be 
qualified to handle STS calls in most situations, he/she may come upon a 
call that requires specific skills that he/she does not have; in this case, 
he/she will not be qualified to provide effective communication and an 
alternate CA must be obtained.  The period of time allowed before a call 
can be transferred to another CA should begin only after the new CA is 
secured, and the caller is able to achieve effective communication.
  
3 Id. at ¶69.
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Adopted: April 7, 2006