[1] CAN's regular members are: American Association of the Deaf-Blind, American Athletic Association of the Deaf, American Society for Deaf Children, Association of Late Deafened Adults, Deaf Women United, Inc., Gallaudet University Alumni Association, National Association of the Deaf, National Black Deaf Advocates, National Congress of Jewish Deaf, National Fraternal Society of the Deaf, National Hispanic Council of Deaf and Hard of Hearing People, and Telecommunications for the Deaf, Inc. CAN's affiliate members are: Association of College Educators: Deaf and Hard of Hearing, American Deafness and Rehabilitation Association, Convention of American Instructors of the Deaf, The Caption Center, Conference of Educational Administrators Serving the Deaf, Inc., National Captioning Institute, and Registry of Interpreters for the Deaf, Inc.

    [2] 1996 Act [[section]]254(b).

    [3] AFB Comments at 2. AFB demonstrates this point by noting that accessible communications networks now enable people who are blind to read newspapers.

    [4] Indeed, the fact that individuals with disabilities are covered by other sections of the Telecommunications Act as well does not in any way lesson the responsibility to include these individuals within our nation's universal service policies. As shown below, a failure to include such individuals would run counter to virtually every Congressional action taken on the matter of telecommunications access for these individuals.

    [5] 47 U.S.C. 151.

    [6]Pub. L. No. 97-410, codified as amended at 47 U.S.C. [[section]]610 (1988).

    [7]Second Computer Inquiry ("Computer II"), 77 F.C.C. 2d 384, 446-47 1980), recon. 84 F.C.C. 2d 50 (1981), further recon. 88 FCC 2d 512 (1981), aff'd sub nom. Computer & Communications Indus. Assoc. v. FCC, 693 F. 2d 198 (D.C. Cir. 1982).

    [8] Such equipment includes, for example, text telephones (TTYs), artificial larynxes, telebraille machines, and breath-activated telephones.

    [9] 47 U.S.C. [[section]]610(g).

    [10] H.R. Rep. No. 888, 97th Cong., 2d Sess. 4 (1982) (emphasis added).

    [11] 47 U.S.C [[section]]610(b).

    [12] Pub. L. No. 100-394, codified at 47 U.S.C. [[section]]610 (1988).

    [13] H.R. Rep No. 674, 100th Cong., 2d Sess. 7 (1988). Noting that the telephone is a "major and indispensable part in the business and social lives of all Americans," the House Committee on Energy and Commerce concluded that, without telephone access, individuals with hearing disabilities "are put at a significant disadvantage, id. at 3, [and that] . . .[t]he inability to use all the telephones imposes social and economic costs on not only the hearing impaired, but the whole nation." Id. at 7.

    [14] Pub. L. No. 101-336, codified at 47 U.S.C. [[section]]225. Prior to the 1990 legislation, Congress had also enacted the Telecommunications Accessibility Enhancement Act of 1988 which established a federal relay system for calls to, from, and within the federal government. Pub. L. No. 100-542, codified at 40 U.S.C. [[section]]762 (1988).

    [15] Title IV provides: "In order to carry out the purposes established under section 1, to make available to all individuals in the United States a rapid, efficient nationwide communications service, and to increase the utility of the telephone system of the Nation, the Commission shall ensure that interstate and intrastate telecommunications relay services are available to the extent possible and in the most efficient manner, to hearing impaired and speech impaired individuals in the United States". 47 U.S.C. 225(b) (emphasis added).

    [16] S. Rep No. 116, 101st Cong., 1st Sess. 77-78 (1989); see also 136 Cong. Rec. H2432 (daily ed. May 17, 1990) (statement of Rep. Dingell).

    [17] The following limitations of relay services, upon which text telephone (TTY) users depend for most of their telephone communications, demonstrate this point: (1) Relay services are ineffective in completing audiotext calls that utilize interactive prompts, 900 calls requiring fees, and many pre-recorded messages; (2) Because most relay services utilize the Baudot format, conversations can take place in only one direction at a time (using the half-duplex mode) (3) Relay calls transmit conversations at a rate far slower than the speed of voice-to-voice communications, adding to the long distance costs of relay users; and (4) relay services cannot complete long distance coin-sent-paid calls from public telephones (technological difficulties prevent the exchange of coin deposits and signalling information). In addition, to date, many hearing individuals remain unfamiliar, and consequently, reluctant to use relay services. Often these individuals simply hang up on a relay caller, assuming such call to be a solicitation.

    [18] Notice at [[paragraph]]16.

    [19] Id.

    [20] Notice at [[paragraph]]50.

    [21] The proliferation of these programs was in part a response to the deregulation of specialized customer premises equipment in the early to mid 1980's. However, the growth of such programs has slowed considerably in more recent years.

    [22] For example, Colorado's program has permitted the distribution of special equipment to state, city and municipal offices. In addition, Nevada's Rehabilitation Division has placed TTYs in various social service agencies, including hospitals and libraries, and Illinois' program has provided for the distribution of TTYs to organizations representing disabled individuals.

    [23] Notice at [[paragraph]]19.

    [24] Notice at [[paragraph]]19.

    [25] Notice at [[paragraph]]21, citing 1996 Act [[section]](c)(1)(A).

    [26] Notice at [[paragraph]]2.

    [27] As noted above, this already applies to touch tone service. If the FCC chooses to include such service within its universal service list, requirements should also be in place to ensure that the services accessed through automated systems via touch tone phones are accessible to TTY users.

    [28] 1996 Act [[section]]254(h).

    [29] Notice at [[paragraph]]72.

    [30] 47 U.S.C. [[section]]225(d)(1(D).

    [31] Notice of Proposed Rulemaking, FCC 90-376, CC Docket No. 90-571 at p.9 n.19 (released Nov. 16, 1990).

    [32] Notice at [[paragraph]]56.

    [33] Indeed, the Commission seeks comment on specific changes that can be made to the Lifeline and Link Up programs to ensure the provision of quality services at just, reasonable, and affordable rates. Notice at [[paragraph]]65. A uniform TTY discount could easily be incorporated into these discount programs.

    [34] Notice at [[paragraph]]43, citing Section 214(e)(1).

    [35] USCC Comments at 22.