Sprint							1850 M Street NW, 11th Floor
    								Washington, DC 20036
    
    July 30, 1999
    
 
    
    Magalie Roman Salas
    Secretary
    Federal Communications Commission
    TW-A325
    445 12th St., SW
    Washington, D.C. 20554
    
                       Re: EX PARTE PRESENTATION
                          CC Docket No. 92-105
    
    Dear Ms. Salas:
     
    Sprint hereby respectfully submits its comments on the implementation of 711 access to
    TRS as requested in the Public Notice released June 16, 1999 (DA 99-1170).
    
    Sprint strongly supports the implementation of 71l access to TRS. The benefits of using
    this abbreviated dialing code are clear: it is easy to remember (as opposed to a toll free
    access number, which varies by TRS center), simple to understand and use, and can be used
    across the country, no matter who the relay provider happens to be in any given state. The
    attractiveness of this abbreviated dialing code to the calling public can be seen in Sprint's
    experience as the TRS provider in Maryland. 711 access was introduced in Maryland in
    February 1999; by June 1999, approximately 44% of total Maryland relay service calls were
    placed by dialing 711. Furthermore, Sprint believes that implementation of 711 access will
    stimulate TRS usage by both hearing and speech impaired customers, and non-impaired
    consumers who wish to communicate with impaired individuals. Again, our experience in
    Maryland suggests that 711 access has contributed to an increase in voice-initiated traffic:
    voice-initiated calls increased 7 percent over a recent 3 month period, significantly higher
    than historical overall TRS growth rates.
    
    Sprint applauds the Commission's decision to allocate the 711 code to TRS access, and
    believes that the Commission should take the lead in establishing broad guidelines to
    govern nationwide implementation of this code, for example, by setting a date by which 711
    access must be implemented. However, the Commission should allow the states to decide
    specific implementation issues relating to 711 roll-out. States need some flexibility to
    accommodate differing circumstances in their region, such as the number of carriers and
    end-user requirements. The differing (but equally valid) approaches in Maryland and New
    York are a case in point.
    
   

    
    Ms. Salas
    Page 2
    
    Maryland was able to implement 711 access to TRS fairly quickly, in part because of the
    relatively small number of local exchange carriers and wireless service providers involved.
    It is the local service provider which translates the 711 code to the relay provider's toll free
    number. Therefore, it was relatively easier to arrange for the deployment of the necessary
    intelligence in each LEC's central office switch, and to coordinate the transfer of calls
    between the LEC and the TRS provider, in Maryland than in New York, which has
    numerous providers of local telephone service.
    
    Maryland and New York have also taken somewhat different approaches to how 711 TRS
    calls are initially answered. Maryland has decided to have 711 relay calls answered by a
    relay operator, keeping the 711 call processing as closely aligned with current relay
    procedures as possible. New York, on the other hand, appears to be leaning towards having
    711 relay calls answered by a voice response unit (VRU), in order to weed out misdialed or
    misrouted calls before the call is handled by a relay operator. By passing only TRS calls to
    the relay operators, speed of answer times are not negatively impacted, and call volumes are
    not artificially inflated, by non-TRS calls. Decisions about the initial answer sequence must
    take into account service level requirements, so that relay providers are not penalized in
    those jurisidictions which elect to route 711 calls to VRUs rather than to a relay operator in
    the first instance.
    
    Sprint looks forward to participating in the Commission's September 8, 1999 forum on 711
    access to TRS. Should you have any questions regarding our comments, please feel free to
    contact me at (202) 828-7444, or Paul Ludwick at (913) 661-8927.
    
    An original and one copy of this letter are being filed.
    
    Sincerely,
    
    Norina Moy
    Director, Federal Regulatory
    Policy and Coordination
    
        cc:    Anna Gomez
        Helene Schrier Nankin
               David Ward