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Telecommunications Relay Services (TRS) allow individuals with hearing and/or speech disabilities to place and receive calls over the Public Switch Telephone Network (PSTN). The national TRS infrastructure is mandated by Title IV of the ADA which grants the FCC authority over TRS and directs the Commission to promulgate rules to set forth requirements and enforcement procedures for telephone carriers and TRS providers. The FCC rules are codified in 47 CFR 64.601 through 64.636. TRS is available in all 50 states and all U.S. territories for local and/or long distance calls including Puerto Rico and the District of Columbia.

A caller wishing to use TRS dials 711 to connect to the TRS provider for the caller’s state. The caller is matched with a communications assistant (CA) – a specially-trained operator who facilitates communication between individuals with hearing or speech disabilities and other parties on the call. Several forms of TRS are available as determined by the particular needs of the user and available equipment.

Text-to-voice is the traditional form of TRS and the most commonly encountered by those who have been party to a relay call. It requires use of a teletype device for the deaf (TTY) to facilitate voice and text communication over the PSTN. The CA transmits verbal communication using TTY, and the TRS caller types responses on the TTY which are spoken by the CA.

Voice Carry Over (VCO) and Hearing Carry Over (HCO) only provide one-way relay, making use of available sensory abilities possessed by the caller. With Voice Carry Over, a person with a hearing disability uses his or her own voice to speak and receives responses from the CA via text. This modality is often used by senior citizens or others who develop hearing loss later in life and are able to speak. Hearing Carry Over allows a caller to use his or her extant hearing on a call to understand speech. The CA only relays responses from the caller transmitted via text which are then spoken by the CA.

Speech-to-speech relay is used by individuals whose speech may be difficult to understand. The caller’s words are relayed by an STS CA, an operator specifically trained to understand a variety of speech disorders. The CA repeats the caller’s words in a manner that makes them clear and understandable to other parties on the call. The person with a speech disability uses his or her own voice or an assistive voice device to communicate with the CA. STS relay is used by individuals with a wide range of speech disabilities including cerebral palsy, muscular dystrophy, Parkinson’s disease, limitations resulting from a stroke or traumatic brain injury, people who stutter and who have had a laryngectomy. Anyone whose speech might be difficult to understand can use speech-to-speech relay.

IP Relay Service

IP Relay Service (IPRS) moves the relay functions off the telephone network and onto the Internet. Rather than using a TTY, the text relay is provided via a web or other Internet-capable interface or device. This eliminates the need to possess TTY equipment and offers the benefits of speed, quality, convenience and competition. The IPRS user must register for a 10-digit phone number in order to place and receive calls. This number is passed to emergency personnel when a call is placed to 911. Telephone carriers are not required by the FCC to provide IP relay services.

A form of IP Relay which is growing in popularity is Video Relay Service (VRS). VRS uses video equipment and a broadband Internet connection to allow the caller and the CA to communicate using sign language. This facilitates greater speed of communication, greater expression through facial expressions and body language, more natural conversation flow including interrupting the other party and allows those for whom ASL is their primary language to use American Sign Language as their communication medium.

Obligations of Telephone Carriers

Every telephone carrier is required to make Telecommunications Relay services available in the coverage area in which it provides voice services. The TRS may be furnished by the carrier, competitively through a vendor or in concert with other carriers. Carriers are also required to provide Interstate Spanish language TRS but are not mandated to provide Spanish TRS within the same state. Carriers must provide both text (TTY) and speech-to-speech relay but are not required to provide IP relay services such as VRS or IP captioned telephone services. Carriers must route all calls placed to 711 to the local TRS as a toll-free call including those placed using VoIP. Interstate carriers – including interconnected and noninterconnected VoIP carriers – are required to contribute to the Telecommunications Relay Service fund, a national fund established by the FCC to fund TRS calls and equipment. TRS calls are free to the caller as TRS providers are paid out of the TRS fund.

Obligations of TRS Providers

The FCC also passed rules that place obligations on TRS providers. These establish minimum standards for operation including qualifications for CAs, procedures for handling calls and types of relay services that must be provided. The FCC also established technical standards for calls including speed of answer requirements, equal access to interexchange carriers and operation standards including 24-hour daily operation. Requirements for registration and certification of TRS providers including IPRS and VRS were also established. The FCC also established procedures for the handling of emergency calls by TRS providers. Finally, as directed by the CVAA, the FCC established the National Deaf-Blind Equipment Distribution Program (NDBEDP) to provide telecommunications access, Internet access and advanced communications equipment to low-income individuals who are deaf-blind. Such equipment is funded using the TRS fund. This was established as a two-year pilot by the FCC and recently extended for an additional year. The FCC also issued an NPRM seeking comment on the feasibility of making the NDBEDP permanent.

Coming Up

In final post in this series, I will explore the requirements for next-generation 911 services.