PENNSYLVANIA PUBLIC UTILITY COMMISSION
Implementation of 711 Access for the Telecommunications Relay Service; Doc. No. M-00900239
[29 Pa.B. 5479]
Public Meeting held
September 15, 1999
Commissioners Present: John M. Quain, Chairperson; Robert K. Bloom, Vice Chairperson; David W. Rolka; Nora Mead Brownell; Aaron Wilson, Jr.
By the Commission:
By this Tentative Order, the Commission presents a proposed implementation plan for 711 abbreviated dialing access to the Telecommunications Relay Service (TRS) in Pennsylvania. We will establish a 30-day comment period on this proposed 711 implementation plan. In addition, we will designate a 711 Implementation Committee.
On February 19, 1997, the Federal Communications Commission (FCC) issued its First Report and Order and Further Notice of Proposed Rulemaking In the Matter of the Use of N11 Codes and Other Abbreviated Dialing Arrangements. The First Report and Order, inter alia, ordered Bell Communications Research (Bellcore), as the National Numbering Plan (NANP) Administrator, to assign 711 as a National code for TRS use.
The use of 711 abbreviated dialing provides easier access to the TRS system. Ease of access to the TRS system furthers the goals of the Americans with Disabilities Act of 1990 (ADA) which requires functionally equivalent access to the telephone network for persons with speech or hearing disabilities. Simplicity of TRS access encourages and supports use by hearing persons as well as hearing and speech impaired persons. Using 711 Nationwide would facilitate consistency from state to state. Currently there are many TRS numbers assigned among and within states, often making access to the relay service confusing and difficult.
In May of 1992, the FCC released a Notice of Proposed Rulemaking proposing that Incumbent Local Exchange Carriers (ILECs) be required to provide abbreviated dialing arrangements utilizing ''N11 codes,'' or three digit telephone numbers, for a variety of applications. On February 19, 1997, the FCC issued its First Report and Order and Further Notice of Proposed Rulemaking (Docket No. 92-105) that, among other things, directed Bellcore to assign 711 on a Nationwide basis for access to the states' TRS Relay Centers. In that Order, the FCC tentatively concluded that Nationwide implementation of 711 for TRS access should occur within 3 years.
Bell Atlantic-Pennsylvania, Inc. (Bell) initiated a dialogue with Commission Staff in the Fall of 1998 for implementing 711 access in Pennsylvania. Bell's intent is to implement 711 access throughout its operating territory. On February 8, 1999, the state of Maryland, with Bell's assistance, officially launched 711 access to the state's TRS system, and became the first state in the continental United States to do so. Successful implementation of 711 access in Maryland should facilitate implementation in Pennsylvania, since our proposed implementation plan is based on the Maryland plan.
Since the initial dialogue with Bell, Commission Staff has met and discussed implementation issues with Bell and AT&T Communications of Pennsylvania, Inc. (the TRS provider in Pennsylvania), the Pennsylvania Telephone Association (PTA), representatives of the CLEC community, and representatives of the hearing and speech impaired community. On November 4, 1998, Commission Staff held discussions with Bell, AT&T, and the PTA to get an update on the progress being made with implementation, and to address issues and concerns still needing to be resolved. Issues discussed included: should 711 be used for both text and voice users; the need to coordinate implementation with all LECs operating in the state; the impact of an FCC final rulemaking; the need for coordinating 711 access with pay telephone providers1 (including LECs and COCOTS); and the importance of public awareness on the availability of 711. Bell and AT&T each discussed their approaches for implementing 711. Both companies were requested to make a presentation at the next meeting of the TRS Advisory Board.
On December 3, 1998, Bell and AT&T made informational presentations on their respective alternatives at the TRS Board Meeting. The Advisory Board members were given an opportunity to hear the alternatives presented, and provide feedback on their concerns. At the March 28, 19992 meeting of the TRS Advisory Board, both alternatives were presented to the Board for their feedback. The members expressed no preference for either option; however, the consensus from the Advisory Board was that the Commission should implement 711 access as soon as possible. The members felt that abbreviated dialing for TRS access was of considerable benefit to the hearing and speech impaired community, and did not have a preference regarding the technical aspects of implementation.
On February 2, 1999, Staff met with AT&T and Bell to discuss reconciling the differing approaches. Subsequently, Bell and AT&T reached a consensus on the implementation of 711. It was agreed that 711 would handle both voice and text calls, and that 711 calls would be routed by the LEC to the appropriate Relay Center 800 number.
A meeting was held on May 4, 1999 with Bell, AT&T, the PTA, and several of the large facilities-based CLECs to discuss the proposal and hear the concerns of the broader ILEC and CLEC community. The proposed implementation plan was described and discussed. All companies present indicated that it would not be a problem to reprogram their switches to accommodate 711 call routing (one company reported that it could be done with less than 2 months notice). In addition, the companies present indicated that the cost would be nominal and that they would not seek cost reimbursement. Subsequent to that meeting, Bell made a presentation at the PTA's Small Company Committee meeting, on May 11, 1999, for their input on any problems or concerns. The PTA received no negative feedback.
On June 8, 1999, the Federal Communications Commission (FCC) issued a Public Notice on convening a public forum on 711 access to the telecommunications relay service. The FCC invited individuals with hearing or speech disabilities, state administrators, members of the telecommunications industry and others to a forum on September 8, 1999, to discuss implementing 711 access to the TRS system Nationwide. The stated goal of the forum is to identify the steps that must be taken to implement 711 access to TRS, any obstacles to implementation, and how those obstacles can be resolved. The FCC also indicated that a Final Rulemaking will follow the Public Forum. We submitted comments to the FCC on July 30, 1999, describing our intent to implement 711 in Pennsylvania and describing our proposed plan.
III. Proposed Implementation Plan
Implementing 711 service in Pennsylvania will enable customers to dial only three digits to send text or voice messages using the Telecommunications Relay Service (TRS). The TRS provider in Pennsylvania is AT&T Communications of Pennsylvania, Inc.
The proposed plan for implementing 711 access in Pennsylvania involves using 711 for both voice and text telephone (TTY) calls. Both voice and TTY users will dial 711 to access the TRS Relay Center. ILECs and facilities-based CLECs will translate the 711 call to the current TRS 800 number that is used for voice calls, (800) 654-5988. The translation normally occurs within 1 second. The current voice number and the current TTY number will still be available for calls for those TRS users not using the abbreviated 711 dialing.
When the call reaches the TRS Relay Center, the Pennsylvania customer will enter an Enhanced Voice Upfront Automation (EVUFA) Call Flow where voice customers will be greeted with an initial ''Pennsylvania Relay'' prompt. The system will immediately be listening for touch-tone prompts to expedite the call setup.
The first step will be to determine the correct call-type option for the customer. The system will begin with a voice prompt. The customer will be prompted to press ''1'' if a voice call, ''2'' if ASCII or ''3'' if Baudot. If the user presses ''1'' for voice, they will go to another menu and be asked to press ''0'' for a Communications Assistant, ''1'' to enter the number being called, or ''2'' for an explanation of how the TRS Service works. This initial voice prompt menu takes about 5-7 seconds.
Although unable to hear the prompt, the voice message provides the necessary pause for TTY users to enter their call-type option selection, either preprogrammed or manually. ASCII and Baudot customers will be encouraged to program their computer or TTY to automatically dial 711, followed by a pause, and then a ''2'' or ''3'' depending on their specific needs. If the text customer (ASCII or Baudot) programs their computer or TTY, or manually enters their selection, then the call is immediately routed to the correct modem (ASCII or Baudot).
The voice message gives the requisite information to Hearing Carry-Over3 (HCO) callers to properly choose their correct call-type option. Voice Carry-Over4 (VCO) calls are typically processed as TTY calls (Baudot). Most VCO callers use a regular TTY machine and can easily choose their correct call-type option (#3). For VCO callers using the newer non-TTY VCO-telephones, the Relay system would time-out and transfer the caller to a Communications Assistant for handling either after choosing an option (''3'') or by timing-out due to the caller taking no action at all.
If the user does not press any number on this initial menu a 5-second time-out occurs, after which the caller's ANI (Auto-Number Identification) is checked for an entry in the Relay Choice Profile Database. The Relay Choice Profile Database will check the customer's telephone number to determine if there is a prearranged option in the database on the choice of call type--voice, ASCII or Baudot. For the customer who takes no action, checking the Relay Choice Profile Database would take about 1-2 seconds.
If the customer has a Relay Choice Profile, the call will be sent to the appropriate option, either ASCII or Baudot. If the user does not have a Relay Choice Profile established, the call goes to the ASCII seek tone. If the user does not respond to ASCII (in about 5-7 seconds), the call goes to the Baudot seek tone. If the user does not respond to Baudot (again in about 5-7 seconds), the call is sent to a Communications Assistant for help.
At worst, a TRS call using 711 would take no more than 28 seconds to be processed. This worst case scenario assumes that the call is using the Baudot text format, the customer has no Relay Choice Profile set up, and/or does not choose an option at the initial prompt, necessitating going through all of the steps. At best, ASCII and Baudot customers could get to the correct modem in 3 seconds, which is faster than currently.
Both ILECs and facilities-based CLECs will need to implement 711 access, in order for there to be complete Statewide coverage. There will be press releases detailing the implementation of 711 in the State; a bill insert will be developed to be included in all customers' bills; and the Customer Guide pages of the telephone books will be updated to include the use of 711. Pay telephone providers (LECs and COCOTS) will be notified of 711 so that their ''smartphones'' can be programmed to translate the 711 call directly from the pay telephone itself.
We find that the 711 abbreviated dialing will facilitate the hearing and speech impaired community's access to the TRS system. It is also our belief that the hearing public would be more inclined to call TRS users (those that are speech or hearing impaired) if dialing was simplified.
To assist us with 711 implementation, we will direct that a 711 Implementation Committee be established to develop guidelines for implementation in Pennsylvania. The 711 Implementation Committee will be charged with developing industry guidelines on the following: guidelines of processes required for implementation of the 711 plan; identify critical success factors such as determining switch conversion timeframes and the relay provider conversion timeframe; suggest a feasible cutover date; identify parties to be involved and notified of the 711 implementation plan (ILECs, CLECs, IXCs, wireless carriers, pay telephone providers, and TRS user groups); identify the best method of industry notification (for example, industry publications); develop a customer notification program (press releases, directory changes, bill inserts, and the like) including template text; input to the Local Exchange Routing Guide (LERG); determine the need for system testing and/or a trial period; evaluate the need for special trouble shooting reporting procedures; and evaluate other areas the Committee deems relevant and appropriate. The 711 Implementation Committee will consist of representatives of AT&T, Bell, the PTA, facilities-based CLECs, the hearing and speech impaired community, and Commission Staff. The 711 Implementation Committee's findings will be used in our Final Order on 711 Implementation.
We seek comment on our proposed implementation plan for 711 access. The proposed plan as outlined above, was developed from negotiations over the past year. However, we recognize that there may be other comments and suggestions from the affected industry groups, the general public or advocacy groups. We designate a 30-day comment period to provide the opportunity for comments on the proposed 711 implementation plan to be submitted for consideration.
We direct that this Tentative Order be published in the Pennsylvania Bulletin, that a 30-day comment period be established, and that a 711 Implementation Committee be instituted. The Final Order on 711 implementation will take into consideration the comments that we receive, the findings of the 711 Implementation Committee and information from the FCC's Public Forum held on September 8, 1999;
It Is Ordered That:
1. Within 20 days after the date of entry of this Tentative Order, AT&T shall meet with our Bureau of Fixed Utility Services regarding the establishment of the 711 Implementation Committee.
2. This Tentative order be published in the Pennsylvania Bulletin as soon as practicable.
3. A 30-day comment period be established from the date of publication in the Pennsylvania Bulletin. Comments should be addressed to: Secretary James J. McNulty, PA Public Utility Commission, P. O. Box 3265, Harrisburg, PA 17105-3265. Comments must include the following on the first page: Comments on the Implementation of 711 Access for the Telecommunications Relay Service; Tentative Order at Docket No. M-00900239.
4. A copy of this Tentative Order be served on all Incumbent Local Exchange Companies (ILECs) and Competitive Local Exchange Companies (CLECs) operating in the Commonwealth, the Pennsylvania Telephone Association, members of the TRS Advisory Board, the Central Atlantic Payphone Association, Association for Local Telecommunications Services; Cellular Telecommunications Industry Association, the Office of Consumer Advocate, and the Office of Small Business Advocate.
5. Questions concerning this Tentative Order should be addressed to Anthony J. Rametta, Bureau of Fixed Utility Services, (717) 787-2359, e-mail address--rametta@ puc.state.pa.us.
JAMES J. MCNULTY,
[Pa.B. Doc. No. 99-1782. Filed for public inspection October 15, 1999, 9:00 a.m.]
1 Some pay telephones are ''smartphones'' that can be programmed to directly route the 711 call to the appropriate TRS Relay Center number. Pay telephone providers will need to program their smartphones to route the 711 call.
2 A new 2 year term for Relay Advisory Board members began in January 1999.
3 Hearing Carryover callers are those callers that are speech impaired, but can hear the message from the non-TTY user.
4 Voice Carryover callers are those callers that are hearing impaired, but can speak to voice their message directly to the non-TTY user.
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