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EXCERPTS
FROM THE PETITION BEFORE
THE FEDERAL COMMUNICATIONS COMMISSION, CG
DOCKET NO. 03-123
WHAT IS CAPTIONED TELEPHONE SERVICE?
Captioned telephone is similar to captioned television; it
converts spoken words into written text for viewers to
read. The captioned telephone itself looks and works
like any traditional phone, with callers talking and
listening to each other, but with one very significant
difference: real-time captions are displayed on the phone's
built-in screen. The service allows the user to speak
directly to another party with his or her own voice while
its captions allow the user to read the words of the
other party and, if he or she has residual hearing, to
also listen to the voice of the other party. Another
key aspect of captioned telephone is that it maintains
nearly the same level of spontaneity as a typical voice-to-voice
telephone call. The dialogue is closer to synchronous
communication than the asynchronous methods of traditional
relay. In this manner, the captioned telephone user can
speak directly to another party with his or her own voice,
listen to the actual voice and inflections of the other
party, and read the text of the conversation to support
and clarify what is heard and understood.
A one- or two-line captioned telephone user places a call
in the same way that a voice telephone user places a conventional
phone call. As the user dials, the captioned telephone
automatically connects to a captioning service. Call set-up
is entirely invisible to the user; there is no interaction
of any kind between the user and the operator. This improves
upon other types of relay services, because it empowers
the user to make calls directly and to control the content
and flow of the call. For example, if necessary, it is
the captioned telephone user, not the relay operator, who
is the one who asks the speaker to repeat a word or spell
a name.
Captioned telephone calls may also be initiated by non-captioned
telephone users, though the manner of achieving this differs
between the one- and two-line services. Individuals making
incoming calls to a one-line captioned telephone user must
first dial the toll-free captioning service and then enter
the captioned telephone user’s number in order for
the user to receive captions of the conversation. Callers
to a two-line captioned telephone user can simply dial
the telephone number of the captioned telephone user, and
the relay service for the captioned telephone is then connected
automatically through the second telephone line. In either
case, once the call is connected, the captioned telephone
user will be able to hear the calling party and simultaneously
read captions of what the calling party is saying. At present,
captioned telephone service uses voice recognition software
trained to recognize the operator’s voice. The operator
re-voices what is said by the other party and then in near-real-time,
the system converts the speech to text, which is displayed
on the captioned telephone.
WHAT ARE THE BENEFITS OF CAPTIONED TELEPHONE
SERVICE?
The number of Americans who can benefit from a captioned
telephone relay mandate is large and expanding. Currently,
there are approximately 31 million Americans with mild-to-profound
hearing loss, a number that is expected to jump to 40 million
in less than a generation.6 More important than the sheer
number of potential users is the fact that captioned telephone
appeals to a segment of people with hearing loss whose
communication needs are not adequately met by existing
traditional relay services. This underserved population
includes those with hearing loss that prefer to use their
residual hearing, spoken language, and technology such
as hearing aids, cochlear implants and assistive listening
devices, to facilitate communication. The vast majority
of these individuals lost their hearing after the age of
19, and likely grew up using conventional voice telephones.
These individuals may not be comfortable with nor satisfied
with using traditional TRS and may not have sign language
skills to use VRS. Rather, most of these individuals, especially
senior citizens, find it most natural to speak for themselves
on the telephone, listen if they can with amplification,
and read the captioned display for any part of the conversation
they are unable to hear or understand. Others may be late-deafened
and simply prefer to use VCO and receive text in a faster
and more natural manner than using VCO with TTY. The fluidity
of a captioned telephone conversation is what makes it
so attractive.
Captioned telephone relay service has already proven its
ability to provide the target population with the telephone
experience that best approximates that to which they were
accustomed before losing their hearing. The enthusiasm
and intensity with which consumers have fought to obtain – and
sometimes retain – captioned telephone in their home
states is testament to the extraordinary ways in which
these services have improved the lives of people with hearing
loss.7
In addition to facilitating conversation with friends and
family, captioned telephone can provide its users with
greater opportunities to seek employment and carry out
workplace functions. As Americans continue to work beyond
the traditional retirement years, years when a significant
number of individuals will develop hearing loss, the need
for captioned telephone services becomes more critical.
The stress associated with finding a job and retaining
employment begs for a solution such as captioned telephone.
While ordering a pizza or making an appointment is important,
being able to maintain a livelihood to support oneself
is critical. If the goal of the Administration is to increase
jobs for all, then telephone access needs to be functionally
equivalent for all. The petitioners bring to the FCC’s
attention this segment of our population because it is
these individuals whose telephone needs can be brought
up to par through captioned telephone services. The majority
of consumers who currently use captioned telephone relay
services in states where there are trials are adamant that
this service is far more effective for them than traditional
TTY with VCO.
Unfortunately, even 15 years after passage of the Americans
with Disabilities Act (ADA), unemployment among people
with hearing loss remains staggering. According to one
survey conducted in 2004, the number of individuals who
use hearing aids who do not have employment actually increased
by 33% since 2000.8 Research by Gallaudet University similarly
revealed that only 12% of people with hearing loss hold
managerial positions, compared with 29% of the general
population.9 Likewise, 26% of people with hearing loss
hold blue collar jobs, as compared to 12% of the general
population.
Consumers have found that captioned telephone relay service
is more accepted – and more effective – in
employment situations than are other relay services. Because
it is not readily apparent to the called business, government,
or other entity on the receiving end that the caller is
hard of hearing or late-deafened and using an intermediary
for assistance, as it is when other forms of relay are
used, captioned telephone calls are more readily honored.
Once the call is accepted by the recipient, the transparent
nature of the captioned telephone process allows the call
to flow naturally and swiftly for both parties. In fact,
there is such a noticeable difference in the ability to
communicate, that individuals relocating to states where
captioned telephone is not available find themselves desperate
to get the service back because of the benefits it afforded
them when conducting business in their previous state of
residence. 10
Captioned telephone users also report that for the first
time in their lives, they are receiving return calls from
the hearing public on a regular basis. Getting the hearing
public (doctors, dentists, attorneys, teachers, etc.) to
initiate calls using standard forms of TRS has always been
difficult. One individual describes how businesses routinely
used to fail to return his calls when he left a telephone
number for TRS or an IP address for VRS. He explained how
this has changed with his two-line captioned telephone:
My experiences with businesses returning calls via TRS
have been rotten. I’ve yet to receive a successful
contact from a business after leaving instructions on using
TRS. On a recent occasion, however, I called the Brother
Company for tech support to network my new printer and
was asked to leave a number to call, as they were busy.
This time I left my phone number. To my amazement, the
Brother Company called me on my CapTel 1 1/2 hours later
and took about 5 minutes to talk me through getting my
new printer networked with my computer. In addition to
this, most on-line and computerized ordering forms do not
have space for TRS numbers plus the phone number or IP
address. The use of CapTel eliminates this problem because
I can be contacted directly via my regular phone number.
Since the installation of the answering machine to my CapTel,
I’m amazed at how many calls I have received.
In addition to the ever-increasing population of baby
boomers over the age of 65, one in three of whom have some
form of hearing loss, recent statistics reveal 169,000
children under 18 who wear hearing aids, and over one million
children who could benefit from hearing aids but do not
have them.12 As newborn screening and early identification
of hearing loss enable parents to address hearing loss
in babies at younger ages, the use of cochlear implants
in children with hearing loss is also growing, now at an
average rate of 20% each year. Studies have shown that
66% of children with cochlear implants use spoken language
as their primary mode of communicating. As they grow up,
these children, as well as children who wear hearing aids
and other children with residual hearing, will want to
use their residual hearing to maintain their independence
and privacy. Teenagers especially relish the liberty of
talking directly to their friends, hearing their voices,
and speaking for themselves. No teenager wants a parent’s
help to get homework from a friend or even worse, to arrange
a date. In addition, because captioned telephone is transparent,
this service moves the focus of a telephone conversation
away from the child or teenager’s hearing loss, furthering
the young person’s self-esteem and sense of integrity.
Finally, but most importantly, two-line captioned telephone
users are finding that this form of relay offers one of
the most effective methods of communication, and in several
cases, the only form of communication, that they can use
to make emergency 911 calls. Many individuals, especially
those who have lost their hearing later in life, have losses
too severe to use conventional telephones with amplification,
yet these individuals do not type (for TTY access), nor
do they sign (for VRS access). In addition, it is an unfortunate
truth that many 911 call centers, especially in rural and
low populated areas, remain inaccessible to TTY calls,
despite this being a violation of Title II of the ADA.
For all these individuals, two-line captioned telephone
may provide the only viable means of calling emergency
services. Two-line captioned telephone also facilitates
call-backs from 911 PSAPs, because personnel from these
centers are able to call back the user directly, without
first going through a relay intermediary. Ensuring an effective
means of accessing emergency assistance through 911 services
is consistent with longstanding Commission policy, and
points to another reason why a mandate for captioned telephone
is urgently needed.
FUNCTIONAL EQUIVALENCY
Title IV of the ADA requires TRS to be functionally equivalent
to telephone access enjoyed by individuals who are not
hard of hearing, deaf, or speech disabled. 13To achieve
functional equivalency, the segment of people with hearing
loss for whom this petition is brought need to be able
to communicate via the telephone in their preferred mode
of communication – spoken language – in the
manner that they feel is most natural and on a par with
the hearing party at the other end of the call.
(Note: In the excerpts, above, ADA refers to Americans
with Disabilities Act and TRS refers to telephone relay
service.)
To read the petition in its entirety, go to hearingloss.org,
the website for the Hearing Loss Association of America
(formerly SHHH).
Compiled by Pete Fackler, SHHH Rochester Chapter
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