XLV.During the course of this proceeding, various commenters raised suggestions for improving STS that went beyond the scope of the 2008 STS NPRM. For example, AAPD recommended that STS user profiles be immediately available to an STS CA each time an STS user places a call, to allow the provider to provide a better and more “consistent STS relay experience” for users.46In addition, AAPD and the TDI Coalition recommended that when an STS user is silent and does not say “good-bye,” the CA should not terminate the call until at least 60 seconds has passed; in this way, the call would not be disconnected prematurely.47 Another recommendation, made by several commenters, was for the FCC to establish an STS Advisory Council for the purpose of formulating an STS outreach plan. We seek comment on these recommendations, and any other matters that the Commission should address to achieve the full utilization of STS. For example, should we establish a mandatory minimum standard for training of CAs who handle STS calls or any other mandatory minimum standards that are specific to STS?48 Finally, we seek information about any technological advances in end user equipment since the submissions of the petitions in this proceeding that may bear on the provision of this service.
XLVI.To what extent should providers be required to allow STS users to create caller profiles? Such profiles generally allow users to pre-submit their preferences for call handling, including their contact information (for emergencies), language preferences, and speed dial numbers,49 which may speed up the time needed for STS call set-up. If providers should be required to offer caller profiles, what should users be allowed to include in these profiles? What are the costs and benefits of mandating the availability of profiles?
XLVII.Finally, are there other enhancements to STS that the Commission should know about? For example, one provider recently implemented a national wireless short code to make it easier to place or receive STS calls.50 We seek comment on the benefits of using such a code nationwide. We generally invite comment on other improvements that can be made to STS consistent with the functional equivalency mandate and section 225 more generally.
A.Comment Filing Procedures
XLIX.Pursuant to sections 1.415 and 1.419 of the Commission’s rules,1 interested parties may file comments and reply comments regarding the Notice on or before the dates indicated on the first page of this document. Comments may be filed using the Commission’s Electronic Comment Filing System (ECFS).2
Electronic Filers: Comments may be filed electronically using the Internet by accessing the Commission’s Electronic Comment Filing System (ECFS): http://fjallfoss.fcc.gov/ecfs2/.
Paper Filers: Parties who choose to file by paper must file an original and one copy of each filing. If more than one docket or rulemaking number appears in the caption of this proceeding, filers must submit two additional copies for each additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission’s Secretary, Office of the Secretary, Federal Communications Commission.
All hand-delivered or messenger-delivered paper filings for the Commission’s Secretary must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325, Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries must be held together with rubber bands or fasteners. Any envelopes must be disposed of before entering the building.
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th Street, SW, Washington DC 20554.
L.Documents in CG Docket Nos. 08-15 and 03-123 will be available for public inspection and copying during business hours at the FCC Reference Information Center, Portals II, 445 12th Street SW, Room CY-A257, Washington, D.C. 20554. The documents may also be purchased from BCPI, telephone (202) 488-5300, facsimile (202) 488-5563, TTY (202) 488-5562, e-mail firstname.lastname@example.org.
A.Ex Parte Presentations
LI.This proceeding shall be treated as a “permit-but-disclose” proceeding in accordance with the Commission's ex parte rules.3Persons making ex parte presentations must file a copy of any written presentation or a memorandum summarizing any oral presentation within two business days after the presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral ex parte presentations are reminded that memoranda summarizing the presentations must (1) list all persons attending or otherwise participating in the meeting at which the ex parte presentation was made, and (2) summarize all data presented and arguments made during the presentation. If the presentation consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s written comments, memoranda or other filings in the proceeding, the presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them in the memorandum. Documents shown or given to Commission staff during ex parte meetings are deemed to be written ex parte presentations and must be filed consistent with rule 1.1206(b).4 In proceedings governed by rule 1.49(f)5 or for which the Commission has made available a method of electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations, and all attachments thereto, must be filed through the electronic comment filing system available for that proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in this proceeding should familiarize themselves with the Commission’s ex parte rules.