TD believes the importance of timely public awareness of the implementation of 711 service outweighs any cost savings related to the retroactive acceptance of previously mailed information related to 711.
Recommendation
TD recommends no changes to the proposal for bill inserts.
Comments
DDTP comments that the bill insert should include all of the phone numbers for current CRS providers, direct numbers for Voice Carry Over (VCO), Spanish, and Speech to Speech (STS) to ensure quicker connections to those services. DDTP that local providers should develop a targeted direct mail piece to Private Branch Exchange (PBX) owners informing them of the need for reprogramming their equipment for access to 711 and that the mailer include a customer service number for the local provider.
Verizon comments that it opposes the requirement for bill inserts to disclose the existence of alternative relay providers. Verizon comments that the statement that existing 800 numbers will remain in effect is sufficient to convey information about 711 service and that any additional information will dilute the intended message.
Pacific comments that bill inserts should not be required. Pacific comments that including information about 711 at the end of a bill is more cost effective and less confusing than alternative forms of consumer education.
Roseville comments that clarification of the contents of the bill inserts is necessary.
AT&T comments that bill inserts are not preferable and that the inclusion of information about alternative relay providers will require AT&T to develop a different information plan for the state of California. AT&T comments that period billing statements and information provided to new customers is more effective than one time bill inserts.
FCC 00-257 permits carriers to determine the method by which the connection to the relay service through the use of abbreviated dialing is executed as long as minimum service quality standards and implementation dates are met. Consistent with that report and order, TD proposed carriers implement 711 service using either Advanced Intelligent Network (AIN) technology or switch-based technology as they see fit. Minimum service quality standards as detailed in 47 CFR 64.604 must be met or exceeded.
Workshop responses
DDTP requested clarification of presubscription requirements and options. DDTP expressed some concern about the inability to select the relay service provider associated with TD's proposal for all 711 calls to be handled by the primary relay service provider.
The Translation Number has been identified as 866.212.8408 by MCI/WorldCom's (WorldCom) relay service. This number is owned by DDTP.
Bill McClelland was identified as the technician in charge of MCI's relay service. Certain technical questions could be directed to him at bill.mcclelland@wcom.com.
Bill Stobbe (representing DDTP) indicated that the translation number would still be in effect if the CRS provider changes.
Discussion
Presubscription is not a service offered for the 711 abbreviated dialing code. The existence of alternative relay numbers that do not use abbreviated dialing is functionally equivalent to presubscription.
Recommendation
TD recommends no changes to TD guidelines for technical specifications. Additionally TD does not recommend changes to the design of 711 to incorporate presubscription options using an abbreviated dialing code. TD recommends the adoption of the FCC's minimum service quality requirements as detailed in 47 CFR 64.604 where they are in excess of the minimum service quality standards mandated by CRS.
Comments
DDTP comments that problems associated with misdials were not addressed in the workshop. DDTP would like providers to indicate the rate of misdial rates for 71X prefixes and area codes.
Roseville comments that CRS minimum quality standards should only apply to a relay service provider or should be in accordance only with the FCC's standards.
The nature of service provision by CRS via 711 prolongs the length of calls due to call type identification and translation/voicing. In the presence of time-based rates for carrier services this increase in call duration potentially creates inequitable charges for functionally equivalent communication services for persons with hearing or speech disabilities. TD proposed all calls to CRS via 711 be exempted from charges consistent with 47 USCS 225 (d).
TD believes this rate structure applies to all carriers and would like to emphasize that Carriers of Last Resort (CoLR), payphones, and wireless providers, as well as operators of commercial PBX systems are not exempted. With regard to payphone operators, calls to a telecommunication relay service are exempted from charges by payphone service providers under 47 CFR 64.13000(b). TD proposed that all LECs and CLCs that provide dial tone to payphone owners amend their tariffs to include free calls to CRS via 711.
TD proposed that wireless providers not charge for access to 711 including airtime for CRS services because wireless providers are not exempted from 47 USCS 225 (d).
Additionally TD proposed that hotels, hospitals, and other commercial operators of PBX systems be required to provide access to 711.
Workshop Responses
ATTW declined to discuss its intended rates for 711 in the presence of competitors citing a potential violation of SEC rules related to price fixing. ATTW maintained this viewpoint despite being informed that this was a public workshop, that specific prices would not be discussed and that the rate structure portion of the workshop was trying to determine if a non-zero fee would be associated with 711 service. WorldCom also neglected to indicate a price. Cingular indicated they intended to charge for airtime for 711 calls, but not toll.
Discussion
The authority of state regulatory agencies over wireless providers is limited at best. ATT's and MCI's minimal contribution provides little clarification of their position regarding rate structures for 711 service. No information was provided with regard to discriminatory rate practices related to 47 USCS 225 (d).
Recommendation
