EX PARTE LATE Comment of the American Association Of People With Disabilities The American Association of People with Disabilities (AAPD)1 is pleased to offer some brief comments in support of Speech-to-Speech (STS) relay service used by persons with speech disabilities and by their family members, friends and colleagues who make phone calls to persons with speech disabilities. In particular, we focus on the need for the STS reimbursement rate to incorporate sufficient reimbursement for providers to conduct appropriate outreach to the community so that persons with speech disabilities can use this form of relay service. We also state here that we support the comments of the group, Speech Communication Assistance By Telephone, Inc., a non-profit group that advocates on behalf of persons with speech disabilities, many of whom are users of STS. We ask the Commission to review carefully this group’s comments about the MARS plan and the impact of reimbursement rates on STS. Functional Equivalency is Essential for Persons with Speech Disabilities AAPD asserts that Section 225 of the Telecommunications Act is instrumental in ensuring persons with hearing disabilities and persons with speech disabilities have access to our nation’s telephone systems. We recognize that the need to achieve functional equivalency is particularly urgent for people with severe speech disabilities who may encounter significant barriers when making voice telephone calls. They are likely to experience hang-ups and disconnects and may never even attempt to make a phone call at all. We believe that there may be numerous persons with speech disabilities who may still be unaware of this form of relay service, or have become speech disabled since its inception, or who could avail themselves of this form of relay service now or in the future, such as children with speech disabilities entering the education system and who will need accessibility of telephony in their futures. STS provides a significant means of accessibility of voice telephony and is one way that the Americans with Disabilities Act ensures a measure of non-discrimination for our nation’s citizens with speech disabilities. Significant Numbers of Adults and Children with Speech Disabilities AAPD notes that the U.S. Census Bureau reports that there are 2.6 million persons who are age 15 and older who have some difficulty having their speech understood by others and of this number, 610,000 were unable to have their speech understood at all.2 These are significant numbers of working age persons who would be unable to use voice telephone service. The difficulties in securing and maintaining employment are enormous for persons with speech disabilities, who may be ignored, disregarded and otherwise rejected due to prejudices against persons with speech disabilities or prejudices against concomitant physical or other disabilities. Furthermore, we point to the number of children with speech disabilities reported in a recent U.S. Department of Education report. The report surveyed 2,906 pre-school children with disabilities in the nation’s special education programs and asserts that “Nearly half (46%) of preschoolers with disabilities were identified as having a speech or language impairment as their primary disability…..”3 The same research reports that “The vast majority of children with disabilities age 3-5 who received special education services received speech or language therapy (93%).”4 We believe there is a significant amount of speech disability among the nation’s special education population and that this is not going to change. These children with speech disabilities will become the adults of tomorrow and will need access to telephony like everyone else. We believe the need remains strong to ensure Speech-to-Speech relay – and outreach to the public about this form of relay -- so that as this group of children ages and enters the workforce and enters mainstream social activities, they will have functional equivalence in telephony in order to lead lives of independence and not become relegated to lives of dependence based on their speech disability. Importance of Reaching 911 Services through STS Relay We note that when making 911 or emergency phone calls, persons with speech disabilities of any age may not be understood by 411 services and 911 Public Safety Answering Point operators. STS may be the only means of telephony for hundreds of thousands of children and adults with speech disabilities attempting to reach 911 services centers or other emergency services since they may encounter severe barriers to being heard and understood when dialing 911 directly or dialing directly to a hospital or other first responder. STS provides an opportunity for persons with speech disability to reach a specially trained Communications Assistant to relay the conversation back and forth between the person with the speech disability and the other party to the call, such as an operator at a 911 services center or other emergency service. Absent knowledge of STS these persons with speech disabilities may be left abandoned and alone in emergency settings, unaware that they could call relay service and use STS to meet their emergency situation needs. We therefore strongly urge the Commission to assess the reimbursement rate for STS in light of this aspect of need so as to make sure there is greater awareness of STS. We encourage the Commission to work with TRS providers to develop an outreach program for STS that specifically focuses on the ability to reach 911 and related emergency centers or first responders. Summary We assert that there needs to be substantively more public outreach so that persons with speech disabilities, and their family members and representatives, know of the relay service and how to make an STS relay call. We believe a reimbursement rate that addresses outreach to the community of persons with speech disabilities would help STS users greatly. We believe that the Commission should acknowledge more deeply the difficulties in using telephony for persons with speech disability, and target the STS form of relay service with a reimbursement rate to providers that incorporates the continuing need for outreach about STS to ensure that the functional equivalence mandate of TRS is better actualized for persons with speech disabilities. Respectfully submitted, 1 AAPD is the largest national nonprofit cross-disability member organization in the United States, dedicated to ensuring economic self-sufficiency and political empowerment for the more than 50 million Americans with disabilities. AAPD works in coalition with other disability organizations for the full implementation and enforcement of disability nondiscrimination laws, particularly the Americans with Disabilities Act (ADA) of 1990 and the Rehabilitation Act of 1973, and other statutes. 2 In “Facts for Features: Americans with Disabilities Act: July 26, 2007,” United States Census Bureau, May 29, 2007, at http://www.census.gov/Press-Release/www/releases/archives/facts_for_features_special_editions/010102.html, last accessed October 9, 2007. 3 “Preschoolers with Disabilities: Characteristics, Services, and Results. Wave 1 Overview Report from the Pre-Elementary Education Longitudinal Study (PEELS),” Institute of Education Sciences, National Center for Special Education Research, U.S. Department of Labor, NCSER 2006-3003, August 2006, page xxiii, Executive Summary. At http://ies.ed.gov/ncser/pdf/20063003.pdf, last accessed October 9, 2007. 4 Ibid.
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