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EAAC MCLS Report

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Released: March 11, 2013












Emergency Access Advisory Committee (EAAC)
Working Group 3 Recommendations on Current 9-1-1
and Next Generation 9-1-1: Media Communication
Line Services Used to Ensure Effective
Communication with Callers with Disabilities

March 1, 2013











Table of Contents

I. SUMMARY ........................................................................................................................ 4
II. RECOMMENDATIONS .................................................................................................... 5
III. BACKGROUND ................................................................................................................. 5
A.
Technical Standards ........................................................................................................ 7
1.
3GPP work on Modality Requirements and Preferences ............................................. 7
2.
ETSI work on Total Conversation Access to Emergency Services ............................. 7
3.
SIPForum Video Relay Service Working Group ......................................................... 7
B.
Video Technologies ........................................................................................................ 7
C.
The PSAP Response ........................................................................................................ 8
D.
Well-Being of SLIs and CAs .......................................................................................... 9
IV. SUMMARY OF ISSUES .................................................................................................... 9
V. FUNCTIONAL REQUIREMENTS FOR CALLERS ...................................................... 10
VI. FUNCTIONAL REQUIREMENTS FOR TELECOMMUNICATORS .......................... 10
VII.
DIFFERENCE BETWEEN MEDIA COMMUNICATION LINES SERVICES
AND TELCOMMUNICATIONS RELAY SERVICES ................................................... 11
VIII. MCLS ESTABLISHMENT .............................................................................................. 12
IX. GENERAL REQUIREMENTS FOR BOTH MCLS AND PSAPs .................................. 12
X. MCLS OPERATIONS IN PRE-NG9-1-1 ENVIRONMENT ........................................... 13
XI. MCLS STANDARDS ....................................................................................................... 14
XII.
SIGN LANGUAGE INTERPRETERS AND COMMUNICATION ASSISTANTS ...... 15
A.
Minimum Skills ............................................................................................................. 15
B.
Certification .................................................................................................................. 16
C.
Minimum Qualification (error rate of text, rate of delay) ............................................. 16
D.
Communication Capability Requirement ...................................................................... 17
E.
Skills Evaluation (voice, sign, type) ............................................................................. 17
XIII. TRAINING ........................................................................................................................ 18
A.
Sign Language Interpreters (SLIs) ................................................................................ 18
B.
Communication Assistant (CA) .................................................................................... 19
C.
PSAP Telecommunicators ............................................................................................ 20
D.
Learning Methodologies and Resources ....................................................................... 21
1.
Simulations ................................................................................................................. 21
2.
MCLS ......................................................................................................................... 21
3.
Resources ................................................................................................................... 21
XIV. CRITICAL INCIDENT STRESS MANAGEMENT (CISM) .......................................... 22



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XV. MONITORING AND EVALUATION ............................................................................. 23
A.
Quality Assurance ......................................................................................................... 23
B.
Evaluation of Recording for Legal purpose .................................................................. 23
XVI. CALLER PROFILES ........................................................................................................ 23
A)
Emergency Profile or Registry Recommendations ....................................................... 24
XVII. CONSUMER EDUCATION............................................................................................. 25
XVIII. CONCLUSION ................................................................................................................. 27
APPENDIX A: NG9-1-1 PC33 Use Case 3: ASL Caller Requiring Video Remote Interpreter .. 28
APPENDIX B: Legacy 9-1-1 - Hearing person who speaks foreign language other than English
calls 9-1-1 ...................................................................................................................................... 29
APPENDIX C: Legacy 9-1-1: Video Relay Service (VRS) – Calling 9-1-1 ............................... 30
APPENDIX D: NG9-1-1: A person calls 9-1-1 using multimedia (caller profile) ..................... 31
APPENDIX E: NG9-1-1: A person calls 9-1-1 using multimedia ............................................... 32






























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1.

SUMMARY


Communication technologies are rapidly changing and expanding. Individuals with disabilities
are taking advantage of these trends to meet their communication needs. It is critical that
individuals with disabilities are able to call 9-1-1 directly, using new and advanced
communication devices.

Direct access to 9-1-1 may include various combinations of technology, such as video, text,
voice and data. Individuals with disabilities should have the opportunity to determine which
communication method would best help them communicate effectively. For example,
videophones are preferred communication mode for individuals who are deaf, deaf-blind and
hard of hearing. Video technologies such as Visually Assisted Speech-to-Speech (VA STS) are
becoming a preferred communication mode for people with speech disabilities. They feel secure
in using this technology to call 9-1-1 and expect telecommunicators to provide effective services
for all 9-1-1 calls.

Next Generation 9-1-1 (NG9-1-1) provides the ability to directly connect to 9-1-1 using various
devices, which include video, real-time text, voice1, and data. Direct access to NG9-1-1 will also
enable multi-party video conferencing. This will give telecommunicators the opportunity to
visually assess the caller and surroundings in order to dispatch appropriate assistance, and record
multi-party video conferencing in addition to voice and text communications.

The Emergency Access Advisory Committee (EAAC) recommends that the Federal
Communications Commission (FCC), U.S. Department of Transportation (DOT) and U.S.
Department of Justice (DOJ) take appropriate steps, wherever necessary, to ensure that Public
Safety Answering Points (PSAPs) utilize trained and qualified sign language interpreters (SLIs)
and Communication Assistants (CAs) with emergency expertise via Media Communication Line
Services (MCLS) during Next Generation 9-1-1 (NG9-1-1) emergency calls.

MCLS is defined as a translation service for people with disabilities and telecommunicators
using video, voice, text, and data during NG9-1-1 calls. It is an extension of the language
assistance line concept used in legacy 9-1-1 and E9-1-1 Public Safety Answering Points
(PSAPs). People with disabilities face various barriers in communicating with NG9-1-1 PSAPs.
By utilizing video, voice, text, and MCLS, PSAPs will bridge these barriers by providing the
appropriate communication assistance via multi-party calls.

Providing effective communication within the NG9-1-1 environment requires PSAP personnel to
be trained and qualified to support MCLS services. SLIs and CAs must be able to handle NG9-
1-1 calls and to interpret or assist parties effectively, accurately and impartially in emergency
situations as well as use a combination of communication modes accessible to individuals with
disabilities. The requirements for MCLS include development of certification standards for
qualified personnel, performance standards; and standard operating procedures that require direct
access to 9-1-1 for callers with disabilities, as opposed indirect access (e.g. relayed calls).

1 See also EAAC recommendation P2.2, EAAC Report and Recommendations. Released on
1/26/2012.

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EAAC recommends that MCLS become a nationally recognized certified standard service for
NG9-1-1.

This paper describes procedures, protocols, and guidelines for setting up MCLS in order to meet
the EAAC recommendations.


II.

RECOMMENDATIONS


To ensure effective communication to individuals with disabilities in NG9-1-1 environments,
EAAC recommends that the following be established:

1) Independent MCLS centers, to be nationally recognized and certified
2) National standard operational protocol (SOP) for MCLS
3) Standard qualifications for Sign Language Interpreters (SLIs) and other types of
Communication Assistants (CAs) in handling 9-1-1 calls
4) Standard training for SLIs, and CAs
5) Standard employee assistance program for SLI and CAs
6) Standard quality assurance (MCLS, SLIs, CAs)
7) Consumer Outreach and Education Program
8) General interoperability requirements and technical standards for MCLS and PSAPs
9) Standard policy and operational protocol for contingency plans for MCLS


III.

BACKGROUND


The U.S. population currently includes more than 54 million people with disabilities, including
people who are deaf, deaf-blind, late deafened, hard of hearing, or who have speech disabilities.
For these people, calling for emergency assistance via NG9-1-1 may require use of specific
communication modalities that differ from those used by the general population.

The original 9-1-1 system, introduced in 1968, was based on wired telephones connected by
copper landlines. Since then, the system has been updated to include features such as automatic
number and location identification and enhanced call routing to the most appropriate PSAP.
Consumer communication electronics development, however, has outpaced the advancements to
the legacy 9-1-1 system. More recent communication technologies are allowing citizens to make
not only voice calls, but also to transmit text messages, real-time text, pictures, video, and data.

Today, there are consensus among EAAC and 9-1-1 stakeholders that it is time to update the 9-1-
1 infrastructure to enable the transmission of this type of digital information from callers to the
9-1-1 center, and on to the emergency responder community. NG9-1-1 is a system of 9-1-1
services and databases that run on an Internet Protocol (IP) based network, which allows
automatic and advanced sharing of digital data among all public safety responders, public safety
answering points (PSAPs), emergency management, traffic operations, and other entities.
Telecommunicators will be able to process all types of calls, including non-voice (multimedia)
calls and messages, and utilize several media simultaneously on the same call.

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As per EAAC recommendation T3.4, NG9-1-1 must include the capability to recognize the type
of call and language, as well as media preferences, before the call is routed to the most
appropriate PSAP, as this saves valuable time in setting up accessible communications.2 The
“most appropriate PSAP” may be one designated to receive MCLS-enhanced 9-1-1 calls – for a
number of PSAPs; allowing telecommunicator skills to be consistently used and enhanced; and
the cost to be shared among PSAPs.
According to EAAC Report on Emergency Calling for Persons with Disabilities Survey Review
and Analysis 2011, two critical issues were emphasized:
a) 83% of respondents indicated that it was very important that they are able to call 9-1-1
using the same device (using text, video, voice, and/or captioned telephone) that they use
to typically communicate every day3 and
b) 77% of respondents emphasized that it was very important to call 9-1-1 directly rather
than via relay service.4

Information required to signal the call type, language and media preferences for callers with
disabilities could be provisioned from different sources. One of the features in NG9-1-1 will
include access to a wide range of supportive databases to be used for call processing. One
example of such a database would be from subscribers/users account information obtained from
application forms filled out by individuals for services and products. It is recommended that two
fields be added to the application asking users to indicate their language and communication
preferences when they make a 9-1-1 call. However, it is not required for those questions to be
answered.

Once information on location, call type, language and media preferences are available, when
establishing an emergency call, NG9-1-1 policy routing database entries can be used to route the
call to the appropriate PSAP and automatically determine the appropriate interpretive services to
be added to the multi-party conference. This will save time in determining how to communicate
with the caller through video, voice, real-time text and other considerations needed for the
user. Examples of databases from which information can be obtained are subscriber/user
account information, relay service providers, communication devices, medical equipment
information, alarm system, profiles stored in the emergency service system and other information
pertaining to callers.
Appendix A describes this schema for sign language communications via video. Note: other
types of interpretive services via other media should be arranged in similar ways.


2 EAAC Report and Recommendation, http://www.fcc.gov/document/eaac-report-and-
recommendations, page 33
3 EAAC Report on Emergency Calling for Persons with Disabilities Survey Review and Analysis
2011, question # 23 on page 30
4 EAAC Report on Emergency Calling for Persons with Disabilities Survey Review and Analysis
2011, question #22 on page 29

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A.

Technical Standards


EAAC has become aware of ongoing activities in standards development organizations and
industry forums related to use of caller profiles and accessible communication for deciding on
invocation of assisting services in calls. EAAC recommends that the FCC and DOJ check the
status of these actions and use as much of them as feasible when MCLS services are
implemented. People with disabilities expect to use the same device they use in everyday
communication, for direct calls to 9-1-1. It is crucial that equipment and services support the
NG9-1-1 standards and MCLS services.

1) 3GPP work on Modality Requirements and Preferences
3GPP standardizing wireless communication has, during 2012, initiated work on defining
user profiles for indicating and negotiation of language and modality requirements and
preferences. This will enable NG9-1-1 to detect need for invocation of MCLS.
The service specification 3GPPTS 22.101 has been modified with the approach to make
emergency service user profiles, but was changed to be of general value.
2) ETSI work on Total Conversation Access to Emergency Services
The standardization body European Telecommunications Standards Institute (ETSI) has just
completed work and published a technical report on the topic of Total Conversation Access
to Emergency Services. The document describes many aspects of emergency calls with
video, audio and real-time text. Profile usage for invocation of services is included. The
report is numbered ETSI TR 104 170. It describes the needs and recommended functions in
general terms, as well as specifically for the native Session Initiation Protocol (SIP) and the
Internet Protocol Multimedia Subsystem (IMS) multimedia telephony technologies.

As of December 2012, the work continues with a technical specification on the same topic
called ETSI TS 101 470 Total Conversation Access to Emergency Services; with similar
topics but more strict implementable style.

3) SIPForum Video Relay Service Working Group
SIPForum (December 2012) started work on creating a specification for relay services with
the purpose to harmonize relay services and enable interoperability between users of relay
services. The focus is on video relay services, but other services will also be mentioned.
Profile usage and emergency calling are both within scope for this work, which is planned to
be ready during 2013.

B.

Video Technologies


Video technologies are increasingly becoming popular and it is expected that they will become a
common mode of communication for everyone. As a result, it is also likely that individuals will
expect to call 9-1-1 directly using video technologies. Some of those callers could be people with
disabilities.


7


Additionally, non-English speaking people have been calling 9-1-1 directly for many years and
PSAP telecommunicators have been connecting these calls with language services in order to
effectively communicate. This becomes in essence a conference call (see Appendix B). These
non-English speaking callers are not required to pre-register. Telecommunicators simply assess
what language is necessary. If the Telecommunicator is not able to determine the language, s/he
transfers the call to contracted language services for assistance. Language services have
someone who does assessments before transferring the caller to an interpreter speaking a similar
dialect.

A similar service and process should be available to people with disabilities that use varying
modalities for communication such as, but not limited to, telephone captioning or video
telephones for American Sign Language (ASL). This process serves as a fallback for situations
where the caller’s preferences cannot be recognized automatically (via preregistration) before
connecting to the PSAP, as described above. One such example would be the situation where the
person with disabilities borrows someone else’s phone to call 9-1-1.

According to Registry of Interpreters for Deaf (RID), there were approximately 4,000 video sign
language interpreters (VIs) working for video relay service providers in 2007.5 However the
usage of video technologies in several devices such as computers, smart phones and tablets has
expanded since the publication of the RID’s Video Relay Service Interpreting: Standard Practice
paper. Usage of video relay services has increased. It is assumed there are approximately 5,000
VIs for 125 video relay call centers nationwide6. They process approximately 8.9 million
minutes of typical relay telephone calls between sign language and voice each month7. There is
currently no data indicating the number of minutes or calls to 9-1-1 .

Working conditions vary from provider to provider. VIs are trained to be transparent, non-
participatory, and confidential. They are screened for employment based on their ability to
receive and express sign language.

C.

The PSAP Response


The average speed with which 9-1-1 calls are processed by PSAPs varies among Internet Based
Telecommunications Relay Services (iTRSs) such as Video Relay Service (VRS), Internet
Protocol (IP) Relay Service, and IP Captioned Telephone Service (IP CTS). The NENA
standard requires that 90% of all 9-1-1 calls to be answered within 10 seconds.8 The FCC
regulations require iTRS providers to respond to 80% of all calls (not specifically emergency
calls) in 120 seconds (VRS) or 10 seconds (IP Relay and IP CTS) and 9-1-1 relayed calls are to

5 http://www.rid.org/UserFiles/File/pdfs/Standard_Practice_Papers/Drafts
_June_2006/VRS_SPP.pdf
6 Since the exact data is confidential and proprietary, the posted figures are reasonably estimated.
7 The website Rolka Loube Saltzer Associates (RSLA, the FCC TRS administrator includes the
Performance Status report dated July 2011 to June 2012 - see http://www.r-l-s-
a.com/TRS/reports/2012-06TRSStatus.pdf
8 NENA 56-005, Section 3.1, Standard for Answering 9-1-1 Calls

8


receive priority. However, there is no FCC standard regulation for 9-1-1 relayed calls to be
connected to the appropriate PSAPs within reasonable time, which is inconsistent and unsafe.

The public believes calling 9-1-1 will result in immediate help. Those who are deaf, deaf-blind,
hard-of-hearing or have speech disabilities trust that their 9-1-1 call responses will be immediate
and functionally equivalent.

D.

Well-Being of SLIs and CAs


Another area of concern is the well-being of SLIs and CAs. Research studies on occupational
hazards indicate that VRS is the most stressful and depressing setting for the interpreters9, mostly
due to unexpected calls and demands posed by emergency calls.

There is currently no national and uniform standard for relay service providers in processing 9-1-
1 calls, or training protocols for SLIs and CAs. Protocols, policies and procedures for training
staff vary for each relay service provider and/or call center. The provision of specialized training
to approximately 5,000 non-emergency VRS interpreters, to handle emergency-related calls, is
considered costly and challenging. But standard, specialized training is exactly what is needed in
order to for effective communications to occur between the caller and 9-1-1.


IV.

SUMMARY OF ISSUES


Due to rapid changing communication technologies, Media Communication Line Services
(MLCS) must be established to facilitate 9-1-1 calls in the NG9-1-1 environment in order to
allow individuals with disabilities to make direct 9-1-1 video calls using different
communication modalities. Both MCLS call centers and PSAPs need to adhere to pertinent
standards for NG9-1-1 to be fully interoperable.

Standard personnel qualifications (operational training, Sign Language Interpreters’ &
Communication Assistants’ skills qualification, etc.) should be developed for handling NG9-1-1
calls.

There is a need to establish standard operating procedures for PSAPs to handle calls from
individuals with disabilities who have voluntarily identified their communication preferences and
modes.




9 R. Dean (2010). Occupational Health Risks in Different Interpreting Work Settings. University
of Rochester. Online: http://www.imiaweb.org/uploads/pages/564_2.pdf (last accessed:
12/21/2012) and Dean, R. K. & Pollard, R. Q (2001). The application of demand-control theory
to sign language interpreting: Implications for stress and interpreter training. Journal of Deaf
Studies and Deaf Education 6
(1), 1-14


9


V.

FUNCTIONAL REQUIREMENTS FOR CALLERS


The following requirements are associated with the caller’s ability to effectively communicate
with PSAPs. Callers must be able to:
a) Call 9-1-1 directly using any device and/or apps via video, text, voice, and data anytime
using 3-digit numbers (9-1-1);
b) Express their communication preferences and receive appropriate MCLS whenever
necessary to communicate with 9-1-1 telecommunicators, independent of caller data or
profile (e.g., subscriber/user account information);
c) Identify communication preferences within the information provided during call
establishment so that MCLS can be automatically invoked at a PSAP;
d) Request a change in MCLS or an additional MCLS when necessary (e.g,. by switching
the mode of communication during a call from text to sign language) without having to
disconnect the call; and
e) Use their preferred terminal for 9-1-1 calls, and have their terminal support multipoint
video conference calls with PSAPs and MCLS.


VI.

FUNCTIONAL REQUIREMENTS FOR TELECOMMUNICATORS


A Telecommunicator must have ability to:
a) Provide and maintain quality MCLS service to callers with disabilities;
b) Provide appropriate auxiliary services based on callers’ communication needs,
preferences and expectations;
c) Determine and clarify caller preferences, needs and expectations;
d) Augment caller data (subscriber/user account information) with information about
communication needs and preferences allowing the telecommunicator to better target and
assess communication preferences;
e) Anticipate caller preferences, needs, and expectations during the call and provide MCLS
in a timely manner, appropriate to caller needs and preferences;
f) Offer possible extras and add-ons appropriately and provide additional MCLS services
where appropriate;
g) Identify problems in services and take action immediately to address them;
h) Modify MCLS (e.g., mode of communication, media types) whenever necessary;
i) Initiate or terminate a MCLS service without having to disconnect the call;
j) Replace SLIs/CAs as needed;
k) Provide a MCLS service to a caller, independent of relay services;
l) Communicate with the caller and SLIs/CAs in a multipoint video conference call; and
m) Access a multipoint control unit (for media) and focus (for signaling) in all conference
calls so that it is possible to connect multiple video and audio end points to conferences
simultaneously.





10


VII. DIFFERENCE BETWEEN MEDIA COMMUNICATION LINES SERVICES AND
TELCOMMUNICATIONS RELAY SERVICES


Today, an individual who uses VRS dials 9-1-1 on their device and is first connected to a video
interpreter (VI), then the VI connects to the PSAP (sometimes there is another connection to a
third party in-between the VI and the PSAP for call routing purposes) (See diagram in Appendix
C). The FCC requires that individuals who may call 9-1-1 are to be given a10-digit number
including area code for the PSAP after registering with their preferred relay service(s).
Registration includes the caller’s name, physical address and 10-digit number. When the
individual calls 9-1-1 via VRS today, the caller information should be electronically transmitted
to the PSAP’s with the automatic number identification/automatic location identification
(ANI/ALI) screen. However, sometimes the caller information does not appear on the ANI/ALI
screen because the call goes through an administrative line other than the 9-1-1 trunk line.


Each relay service provider is required to train their sign language interpreters on proper
handling of 9-1-1 calls; however, the content, depth and length of training varies from one
provider to another. There are currently no training standards. Each VRS provider develops
their own protocols for how the calls are to be handled. There is no national standard for relay
service providers’ processing of 9-1-1 calls. Also, there are no minimum requirements or
standards to determine whether video interpreters are qualified to interpret 9-1-1 calls.

Therefore, in order to address this aforementioned issue, Media Communication Line Services
(MCLS) must be implemented and functioned like any language services with which PSAPs
have contracts. When a video call is connected to 9-1-1 directly, the telecommunicator connects
the caller with the MCLS call center (or the connection is established automatically based on the
caller’s profile) – the same concept as when the telecommunicator connects to language services
whenever a foreign language speaker calls 9-1-1 (see diagram in Appendix D). Like other PSAP
telecommunicators, the SLIs and CAs will be required to go through physical and psychological
evaluations to determine their capability to perform their job in a stressful environment. SLIs and
CAs will be specifically trained to handle 9-1-1 calls using varying communication modalities to
accommodate the needs of individuals with disabilities. Also, PSAP telecommunicators should
be trained to handle video calls as well as auditory communication modes.

Multi-party video conferencing will allow telecommunicators the opportunity to visually assess
the caller and/or surroundings in order to provide appropriate assistance. NG9-1-1 will record all
media types present in video conferencing calls.

Additionally, many consumers who are deaf or hard of hearing who use ASL as a secondary
language (oral or late-deafened) may benefit from using both video for ASL and speech reading
and captions. MCLS should have the ability for the telecommunicators to connect in multiple
ways, including audio, video (see the interpreter and the telecommunicator synchronously) and
/or captions via real-time text.

Furthermore, the VRS providers have obligation to accommodate their services to comply with
the FCC regulations where revisions and compensations may be made only after time-consuming
public rulemaking processes. The MCLS call centers will need to update their services and

11


technology, from time to time as needed, independently of VRS policies as required by FCC.
The EAAC recommends that the certification requirements for the MCLS call centers to be
developed by the FCC, DOJ, DOT, and other federal agencies.


VIII. MCLS ESTABLISHMENT


PSAPs that receive calls from callers using varying communication modalities (video phones,
captioned phones) will have seamless multi-conference connection abilities to any of the nation’s
MCLS call centers.

In order to effectively provide direct connect 9-1-1 services to all people using various
communication modalities, the EAAC recommends that the FCC should require the
establishment of multiple MCLS call centers, for redundancy and in order to ensure that any
PSAP can connect conference services in a single call. Criteria for technical requirements,
operational requirements, training requirements, and sustained funding must be considered prior
to establishment.

Established MCLS call centers should be able to provide video and text language services for
people with disabilities who use varying methods of communication, including but not limited to
American Sign Language and captioning. MCLS call centers must have established training
credentials and certifications for ALL qualified SLIs and CAs to adequately meet the needs of
emergency callers using varying communication methods.

Accreditation of MCLS call centers include setup requirements and training credentials for
meeting the needs of emergency callers using varying communication methods as described in
following pages.


IX.

GENERAL REQUIREMENTS FOR BOTH MCLS AND PSAPs


PSAPs should have the ability to instantly connect to the MCLS call centers, established
throughout the United States. MCLS call centers should be strategically located throughout the
country, so as to achieve redundancy in the face of disasters that affect the ability of any one
center to maintain operations. Direct connection to these call centers should be available for all
PSAPs. PSAP telecommunicators should have the technological ability to connect to MCLS in a
timely manner.

In order to have multi-video conferencing with text and voice, both PSAPs and MCLS agencies
should include the following list of requirements in their system for smooth call processing:
a) Network connectivity to different network systems at same time
b) Location determination for mobile devices (GPS), and ability to obtain location
within mobile applications
c) Ability to convey location, call type and language preferences within signaling
d) Redundancy
e) Overflow routing and connection abilities to multiple MCLS call centers

12


f) Ability to connect to different devices and services
g) Timeline for implementation including how each PSAP will transition from using
VRS or TRS to direct connect to MCLS call centers for direct 9-1-1 service for
people with disabilities.
h) Quick and seamless connection from PSAP to MCLS Call Center
i) Protocols and codecs for audio, real-time text, video and text messages (as per the
NENA i3 standards, and EAAC recommendation T2.1)10
j) Multi-video conferencing, including voice and text for all parties
k) Media quality standard for video, audio and text. (need to set up minimum
requirements on high quality media for both download and upload, sufficient to meet
all callers’ communication preferences)
l) Technical factors adaptive to user's connection capacity (especially video bandwidth
adaptation)
m) Ability to handle addition of users to conferences via dial-in and dial-out, as well as
other call operations
n) Security and privacy during the transmission of all communication channels and
media
o) Queue information in video and text
p) Include different communication modalities (text, video, voice, data)
1) Types of communication preferences
a) American Sign Language (ASL)
b) Other sign language systems (i.e., Signed Exact English (SEE), Conceptually
Accurate Signed English (CASE), Pidgin Sign English (PSE), Cued Speech)
c) Sign language and text (real-time text or messaging)
d) Voice and sign language with captions
e) Voice (with or without speechreading via video) and captions
f) Sign language one way, 9-1-1 text or voice back (i.e., Deafblind)
g) Speech-to-Speech support11
h) Language, memory and cognitive support
i) Augmentative Alternative Communication (AAC) devices12
j) Any combination of text, voice and sign language


X. MCLS OPERATIONS IN PRE-NG9-1-1 ENVIRONMENT


The EAAC believes that achieving equal access to 9-1-1 emergency services by individuals with
disabilities is part of the migration to the national Internet protocol-enabled emergency network
(NG9-1-1) and is a matter of long-term national policy. However, there are steps that need to be
considered for preparing MCLS call centers for transition to NG9-1-1 environment.


10 EAAC Report and Recommendation, http://www.fcc.gov/document/eaac-report-and-
recommendations, page 30
11 http://www.fcc.gov/guides/speech-speech-relay-service
12 AAC assists an individual with speech disability to communicate via electronic or non-
electronic devices. http://www.ussaac.org/aboutaac.htm

13


EAAC has found that current video and IP relay service providers have frequently improperly
delivered or handled emergency calls to Public Safety Answering Points via the existing 9-1-1
networks, as required by FCC regulations. EAAC recommends the implementation of a national
Media Communication Line Services (MCLS) through either a national entity or through
regional entities. Therefore, criteria for technical requirements, operational requirements,
training requirements, and funding continuity must be considered prior to establishment of
MCLS. Specifically, EAAC recommends that the Commission:

1.
Work with US DOJ, DOT and appropriate federal agencies to take the appropriate
steps to expedite any regulatory changes needed to adopt the recommended solution.
Among regulatory changes include:
a)
Policies, procedures and practices relating to ASA between callers and
PSAPs
b)
System redundancy
c)
Contingency and back-up plan
d)
Call-back procedures
e)
Qualification of SLIs and CAs for handling emergency calls via relay
services
f)
Training requirements for SLIs and CAs including varying communication
methods to accommodate needs of callers
g)
Certification for MCLS call centers
2.
Collaborate with relay service providers and MCLS centers to develop interim
recording and retaining relayed calls in accordance with State and local PSAPs’ policies
and procedures;
3.
Require VRS/IP Providers to make their service compatible with recommended
guidelines as set forth in National Emergency Number Association (NENA) Specification
for i3 Solution in order to forward all 9-1-1 calls to a MCLS center.13


XI.

MCLS STANDARDS


MCLS shall maintain highly skilled SLIs and CAs to provide effective communication services
between callers and Telecommunicators during crisis calls. The MCLS should include the
following:
a) Line Services
b) Privacy and security in studio arrangement
c) Availability of interpreters, CAs, and services 24/7/365
d) Certified Deaf interpreters (CDI) who are native or near native in ASL, to provide
assistance to interpreters as back-up whenever the interpreters are not able to
understand sign language users
e) Length of response time from SLI or CA
f) Teaming-up of multiple interpreters and/or CAs for maximum efficiency and speed of
communication

13 http://c.ymcdn.com/sites/www.nena.org/resource/collection/2851C951-69FF-40F0-A6B8-
36A714CB085D/NENA_08-751-v1_i3_Requirements_LTD.pdf

14


g) Time to respond after an incoming request for services (mean value and max for 97%
of the calls)
h) Contingency Plan, to include ability to transfer the service to another call center.
i) Redundancy for catastrophic situations. Service centers in different locations.
Redundant communication routes.
j) Liability
k) Consistent and uniform policies regarding various communication situations
l) Unique operator identification in a way that protects their privacy (such as ID
number), so that they can be identified for reporting or quality assurance purposes, or
asked for during resumption of a disconnected call.
m) Call case logging
n) Compensation for services rendered to include
1) Stand-by
2) Minutes for calls


XII. SIGN LANGUAGE INTERPRETERS AND COMMUNICATION ASSISTANTS


The role of Sign Language Interpreters (SLIs) and Communication Assistants (CAs) is to
translate, transliterates or interpret conversation between one or more end users.

A.

Minimum Skills


The MCLS agency is responsible for hiring qualified and skilled VIs and CAs to handle relayed
9-1-1 calls between callers using different modalities and 9-1-1 Telecommunicators. Intensive
training for handling emergencies is required.

Both SLIs and CAs must demonstrate competency in:
• Typing (60 wpm)
• Spelling (how many errors acceptable?)
• Interpretation of sign language in various modes and styles
• Interpretation of written communication of people with disabilities
• Knowledge of hearing and speech disability cultures
• Etiquette
It is critical that both SLIs and CAs should possess the following specified skills for providing
effective communication performance during emergencies, similar to PSAP Telecommunicators.
The SLIs and CAs will be required to go through physical and psychological evaluations to
determine their capability to perform the essential functions of the job in a stressful environment.
SLIs and CAs may also be required to go through drug screening, criminal history check,
polygraph exam, and/or computerized voice stress analysis. SLIs and CAs will be intensively
trained to handle video 9-1-1 calls using different communication modalities to accommodate the
needs of individuals with disabilities.



15


B.

Certification


The requirement that qualifies sign language interpreters or CAs to work in a MCLS agency is to
have skill sets to handle 9-1-1 calls.

Sign Language Interpreter (SLI): According to the ADA, a “qualified” Interpreter is able to
interpret effectively, accurately and impartially both receptively and expressively, using any
necessary specialized vocabulary. The interpreter must possess National Interpreter Certification
(Master, Advanced), Certificate of Interpretation (CI) and/or Certified Deaf Interpreter (CDI)
from Registry of Interpreters for the Deaf (RID) or certification from state agencies.

Communication Assistant (CA): There currently is no available certification specific to CAs.
However, we recommend that as part of the MCLS procedures and policies, appropriate
certifications are developed for CAs handling 9-1-1 calls.

SLIs and CAs must have completed the training, specifically designed for handling 9-1-1 calls
from people who are disabled, as described in the next few pages. Additional certification and
training criteria should be established for MCLS call centers.

A team of qualified individuals, expert in sign language and communication assistance, should
be established to evaluate SLIs and CAs for skills and qualifications. Recommendations of
evaluators selected for the team shall be freelance interpreters, staff from sign language
interpreter agencies, teachers of ASL, teachers/board members of state deaf schools, teacher
working with individuals with speech disabilities & disabilities, members of American Sign
Language Teachers Association chapters (ASLTA), officers of Deaf organizations/clubs,
National Association for Hearing and Speech Action (NAHSA), United Cerebral Palsy
Foundation, or national organizations or associations servicing persons with disabilities and
individuals with speech disabilities and/or disabilities. This group shall be diverse, neutral, and
professional in order to evaluate appropriately and to determine the results without any possible
conflict of interest.

C.

Minimum Qualification (error rate of text, rate of delay)


Handling 9-1-1 calls can be highly stressful and require SLIs and CAs to be able to relay
messages both receptive and expressive effectively between both parties.

Desirable Minimum Experience:

Sign Language Interpreters
• 5 years or more community interpreting experience (consisting of at least 2 years of law
enforcement and/or medical emergency interpreting services)
• At least 1,000 hours of in VRS experience
• Speak word by word or translate to English while reading text messages from the caller
• Have taken Deaf studies or knowledge of Deaf culture from the early 1900’s to current
year.
• Vast knowledge of classifiers including facial expressions, body language, etc.

16



Communication Assistants
• 5 years or more as speech therapist, speech language pathologist or have worked with
people with speech disabilities
• At least 1 year experience in Speech-to-Speech (traditional/video) with more than 1000
hours
• At least 1 year experience in text relay with more than 1000 hours
• Knowledgeable of speech patterns (neurological and language)
• Speak word by word or translate to English while reading text messages from the caller

D.

Communication Capability Requirement


The SLIs and CAs must possess the following skills to be qualified as employees with the MCLS
agency.

Sign Language Interpreter:
• Must be able to handle callers with various communication modalities (sign, voice, text)
• Must be able to use receptive and expressive skills with regional signs, signs for names &
locations
• Must be able to speak word by word or translate to English while reading text messages
from the caller
• Must be able to work with callers who have other disabilities in addition to those with
hearing loss, vision loss, mental health, limited language skills, etc.

Communication Assistant:
• Must have an understanding of various types of speech disabilities (neurological and
language)
• Must also possess clear and articulate voice communications
• Must be patient
- some callers may have long pauses
- some callers may not be clear so therefore they would be asked to repeat or to clarify
- some non-disabled people may become frustrated
• Must have strong listening skills
- some callers may have garbled speech

E.

Skills Evaluation (voice, sign, type)


It is recommended that SLIs and CAs be evaluated by a neutral group of subject matters experts
(SMEs) to ensure the SLI and CA are qualified in handling 9-1-1 calls. See Section XI B for
recommendations on criteria of evaluators.

Also it is recommended that SLIs and CAs have their performance review at least every 6
months.




17


Sign Language Interpreter:
• Voice translation
• ASL translation in various communication style

Communication Assistant:
• Revoicing
a) People with varying speech disabilities
b) People who are deaf, deaf-blind or hard of hearing

CAs should be evaluated for their re-voicing for people with various degrees of speech
intelligibility at least every 6 months.


XIII. TRAINING


Effective communication is required when a caller who is deaf, deaf-blind, hard of hearing, who
has a speech disability or who has another disability, calls a PSAP. Training is required for all
parties involved. PSAP Telecommunicators should be properly trained on methodologies for
connecting to the MCLS call center. If a caller is seen as well as heard by the Telecommunicator
or if text communication is received, the PSAP Telecommunicator should be aware of how to
effectively connect to MCLS call center for multi-party conferencing and to provide service in
the most expedient and seamless way possible.

A.

Sign Language Interpreters (SLIs)


SLIs should be qualified to provide functional equivalency for communication through, but not
limited to, oral interpreting, written captions, or any combination. This will help expedite
effective communication and response for services during 9-1-1 calls. Training for SLIs shall
include, but are not limited to:

1.
Procedures for connecting and multi-conferencing with SLI or CA to a caller and a
PSAP Telecommunicator.
2.
Emergency communications training, for interaction between callers,
Telecommunicators, and emergency responder personnel.
3.
9-1-1 protocol training for emergency response, similar to training provided to
Telecommunicators. SLIs will receive training on procedural matters and incident
command for emergency responders. This will help SLIs understand the needs of
responders on the scene and what will be communicated to the caller and how to
interpret it properly
4.
9-1-1 and emergency responder awareness (e.g., fire, law enforcement, emergency
medical services [EMS]), and 9-1-1 call handling methodologies. This training will
include medical terminology (and appropriate signs), legal terms, procedures, and
local agency names. Additionally, incidents that are likely to result in high volume
calls (e.g., automobile accident on a crowded roadway, missing persons, etc.) should
be described and discussions should occur on how these call types affect these
processes. These scenarios will provide SLIs with an overview of actions and

18


decisions being made by the PSAP Telecommunicators and allow for SLIs to provide
better transparency to both the caller and the Telecommunicator.
5.
Basic first aid and cardiopulmonary resuscitation (CPR) training. The training would
help SLIs to understand techniques and procedures described by a Telecommunicator
during a relevant emergency call (e.g., choking, checking a pulse, etc.) and also to
provide appropriate signs to callers.
6.
Critical incident care. Critical incident care refers to assisting callers with critical
incident call handling (appropriate tone and statements to a survivor of an incident or
someone who is assisting a survivor. Critical incident care also refers to self-care for
the SLI or CA and stress management in dealing with vicarious trauma (See Section
XIII – Critical Incident Stress).
7.
Regionally appropriate signs, name signs, and signs for specific locations and people.
8.
Deaf culture from the early 1900’s to current year.

B.

Communication Assistant (CA)


A Communication Assistant (CA) should be available for people with hearing loss and limited/
no proficiency in American Sign Language (ASL) when contacting 9-1-1. CAs should be
qualified in the same areas as a SLI to provide functional equivalency for communication
through, but not limited to, oral interpreting, written captions, or any combination.

While there is not a required length of training for CAs in their current roles, the FCC requires
that all CAs be sufficiently trained to effectively meet the specialized communications needs of
individuals with hearing and speech difficulties. CAs are required to possess competent skills in
typing (minimum of 60 words per minute), grammar, spelling, interpretation of typewritten ASL,
and familiarity with hearing and speech disability cultures, languages and etiquette. CAs must
also possess clear and articulate voice communications.

CAs should receive more extensive training for handling 9-1-1 or emergency calls through a
MCLS call center. CAs should receive training and evaluation in the following areas:

1.
Procedures for connecting and multi-conferencing with SLI or CA to a caller and a
PSAP Telecommunicator.
2.
Emergency communications training, for interaction between callers,
Telecommunicators, and emergency responder personnel.
3.
9-1-1 protocol training for emergency response, similar to training provided to
Telecommunicators. SLIs will receive training on procedural matters and incident
command for emergency responders. This will help SLIs understand the needs of
responders on the scene and what needs to be communicated to the caller and how to
interpret it properly.
4.
9-1-1 and emergency responder awareness (e.g., fire, law enforcement, emergency
medical services [EMS]), and 9-1-1 call handling methodologies. This training will
include medical terminology (and appropriate signs), legal terms, procedures, and
local agency names. Additionally, incidents that are likely to result in high volume
calls (e.g., automobile accident on a crowded roadway, missing persons, etc.) should
be described and discussions should occur on how these call types affect these

19


processes should occur. These scenarios will provide CAs with an overview of
actions and decisions being made by the PSAP Telecommunicators and allow for
SLIs to provide better transparency to both the caller and the Telecommunicator.
5.
Basic first aid and cardiopulmonary resuscitation (CPR) training. The training would
help SLIs to understand techniques and procedures described by a Telecommunicator
during a relevant emergency call (e.g., choking, checking a pulse, etc.) and also to
provide appropriate signs to callers.
6.
Critical incident care. Critical incident care refers to assisting callers with critical
incident stress as required (appropriate tone and statements to a survivor of an
incident or someone who is assisting a survivor. Critical incident stress also refers to
self-care for the CA and stress management in dealing with vicarious trauma (See
Section VII – Critical Incident Stress).
7.
Regionally appropriate names and specific locations or terms.
8.
Deaf/Hard of Hearing culture from the early 1900’s to current year.

C.

PSAP Telecommunicators

PSAP Telecommunicators should be trained to handle video calls as well as auditory
communication modes used by people with speech disabilities. Multi-video conferencing will be
included in NG9-1-1. This will give Telecommunicators the opportunity to assess the caller and
surroundings in order to send appropriate assistance. NG9-1-1 will record the video of multi-
video conferencing.
PSAP Telecommunicators should receive specialized training in order to provide effective
communication for consumers using alternative communication methods. Training must include,
but is not limited to:

1.
Procedures for connecting and multi-conferencing with a caller and SLI or CA.
2.
Information on the roles/responsibilities of SLIs and CAs during a call.
Telecommunicators should speak directly to the caller and assist in seamless
communication whereas SLI or communications assistant remain as transparent as
possible. In other words, Telecommunicator should not speak to SLI and say “tell
him/her this or that.” Questions or comments should be made as if no SLI were
present.
3.
Policies and procedures for connecting to an SLI or CA as needed.
Telecommunicators should be trained on identifying callers who may have the need
for SLI or communications assistant.
4.
Protocols for handling the lag time while finding the language, ASL, or
communications assistant and connecting to SLI or CA (and acceptable rate of delay).
5.
Procedures and scenarios for the possible lag time between SLI or communications
assistant and the caller before information can be conveyed.
6.
Use of short sentences and simple vocabulary and short phrases to convey questions
and instructions. For example, during an emergency medical dispatching (EMD)
scenario, if there is no understanding, the Telecommunicator may be allowed to
rephrase. Simpler words, such as “awake” instead of “conscious”, should be used.

20


7.
Basic overview of the language differences between spoken language and ASL, such
as the importance of facial expressions, classifiers, and the different syntax of ASL.
8.
Differences with the varying modalities of communications and the people who use
them. All people who use communication assistance do not have equivalent
knowledge and proficiency with varying modalities of communications. For example,
false statements: “all people who are deaf or hard of hearing read lips”, or “all people
who are deaf or hard of hearing know sign language” or “all people who are deaf or
hard of hearing have an equal understanding of written English and can read captions,
etc.”

D.

Learning Methodologies and Resources


Some education or training may be both efficient and cost-effective if done through online
training methods. However, collaboration with other members of the PSAP community makes
some face-to-face training scenarios the optimal method. A blended learning path for all
individuals is recommended.

1. Simulations

PSAP Telecommunicators, SLIs and CAs will participate in training drills, table top
exercises, and simulations to prepare them for assisting people who are deaf, deaf-blind,
hard of hearing or speech impaired.

2. MCLS

The use of MCLS call centers and PSAPs, from the beginning of the call, saves valuable
time in an emergency. MCLS will be effective for calls that can be automatically
connected as well as non-automatic connection. Proper training in uniform procedures,
especially hand-on activities, provides for effective handling. Training prerequisites need
to be established.

3. Resources

Multiple resources are available for MCLS to engage in these types of training efforts.
MCLS should work with local PSAPs to coordinate training efforts or to look for
recommendations for outside training courses. With the transition to NG9-1-1, training
courses and resources for video emergency calls should become more widespread and
uniform. State and local chapters of the National Emergency Number Association
(NENA) and the Association of Public Safety Communications Officials (APCO), as well
as the National Academies for Emergency Dispatch (NAED) provide additional
information on training courses, training standards, and additional detail on any of the
described topics.





21


XIV. CRITICAL INCIDENT STRESS MANAGEMENT (CISM)


The EAAC recommends that qualifying MCLS agencies are required to provide critical incident
stress management services to their employees. Proper stress management methods and training
for SLIs and CAs is essential to protect the health and well-being of employees. By handling a
video emergency call, SLIs and CAs are potentially exposed to traumatizing events. Current
research is beginning to show a correlation between emergency call handling and symptoms of
post-traumatic stress disorder (PTSD), and researchers believe that the addition of video to a call
will only compound these effects. It is important that SLIs and CAs are provided proper stress
management training and proper outlets to help cope with stressful situations.

A March 2012 report discusses findings that suggest physical exposure to an incident may not be
necessary to cause symptoms of PTSD in Telecommunicators.14 With the advent of NG9-1-1,
researchers and the 9-1-1 stakeholder community, including the FCC’s Communications
Security, Reliability and Interoperability Council (CSRIC), are concerned that the addition of
video to emergency calls could have a negative impact on Telecommunicator emotional
wellbeing.15 These are concerns that currently face SLIs and CAs today.

According to the REACH112 project in Europe, the reports indicate that PSAP
Telecommunicators, after working with video in emergency calls, are in general very positive to
the medium, and the concerns they had before beginning to work with video in 112 calls were
reduced. Having video available to convey the impression of professional handling, and to
perceive more information by viewing directly rather than interpreting answers, can be very
satisfying and reduce stress appearing otherwise by being distanced from the emergency scene
and the frustration of not getting sufficient information through questions and answers.

Ongoing stress management training is essential for SLIs and CAs to be able to perform their job
at the high degree of efficiency necessary to provide the service required during an emergency
call. This type of training provides SLIs and CAs with scenarios that can cause stress, how to
perform during these situations, and how to cope with the situation in the hours, days, and weeks
following the event. Trainees are also provided with resources (e.g., hotlines, reading materials,
councilor information, etc.) to obtain assistance following a traumatic incident.

In addition to ongoing stress management training, there are multiple tools that SLIs and CAs
can leverage to aid in coping with stressful incidents. Comprehensive CISM programs can be
implemented that focus on peer driven support immediately following an incident with periodic
follow-ups to ensure personnel are handling stress in a healthy manner. Peer support and an
open dialogue about the different ways to deal with stress in the work place can greatly improve
effectiveness of stress management programs. Additionally, mentoring programs provide
guidance to new staff and allow for seasoned staff to provide support from an experienced

14 Pierce, H. & Lilly, M. (2012) Duty-related trauma exposure in 9-1-1 telecommunicators:
Considering the risk for posttraumatic stress. Journal of Traumatic Stress 25(2), pp. 211-215,
April 2012. DOI: 10.1002/jts.21687
15 CSRIC II WG4B Final Report, p. 33: http://transition.fcc.gov/pshs/docs/csric/CSRIC-WG4B-
Final-Report.pdf

22


source. Group or individual counseling sessions allow for discussions to occur in a safe place
with a professional who is trained in helping communications professionals dealing with
extremely stressful and emotional working environments.


XV. MONITORING AND EVALUATION


A.

Quality Assurance

In order for MCLS call centers to provide effective services, it is critical that the centers
are to modify on a timely manner based on:
a) Feedback method on the services rendered.
b) Statement in the contract that gives right to not use a specific SLI.
c) Electronic method to report issues quickly during or after a call.

B.

Evaluation of Recording for Legal purpose
1. PSAPs record and store video conversation for a specific period of time, according to
state or local law. These recording may be evaluated if:
a) Internal to the PSAP - it is recommended that the recording be evaluated by a
neutral group of SMEs as defined in Section XI B.
b) Court – A recording may be requested or be subpoenaed for legal purposes.
Recording may be evaluated by request.

2. MCLS call centers may review caller conversations for quality assurance and training
purposes in the same manner as any PSAPs.


XVI. CALLER PROFILES


As indicated in the background section, there are discussions in various groups about the benefit
of user profiles for rapid guidance during 9-1-1 call establishment in order to achieve suitable
service in the call. Storage of such profiles can be arranged for use in the NG9-1-1 environment.

The discussion in this chapter covers profiles stored in the NG9-1-1 system, while some
conclusions may be valid also for profiles stored in other parts of the communication systems.

The profiles to be stored in the NG9-1-1 system could cover factors of interest in emergency
situations. Generally, it is not necessary for anyone including individuals with disabilities to
store such information with 9-1-1. The main goal of NG9-1-1 is to process all types of
emergency calls including non-voice (multi-media) calls and messages. Individuals with
disabilities, like any non-disabled individuals, can choose to store profiles or not. It is essential
that everyone should be informed on the advantages and disadvantages of registering profiles
with 9-1-1. Caller profile registration must be voluntary and may provide valuable information
regarding medical conditions, type of disability, language, and/or communication modes as well
as other critical data for first responders in the most seamless method possible in time of
emergency.


23


The privacy and confidentiality of persons with disabilities must be protected. There are many
issues around this type of data due to HIPPA laws and, whenever it becomes available, the caller
will have to indicate in their information data that it is permitted to release to authorized
personnel. There are current discussions on who is “authorized” and whether this is only for
EMT or licensed medical person or if this should include 9-1-1 Telecommunicators or
dispatchers.

While information included in signaling may help eliminate some educated guess work by the
Telecommunicators as to what communications assistance is required (ASL, captions, oral
interpreter, Spanish or other languages), additional data or the caller profile may provide PSAPs
additional information such as medical condition, type of disability or other critical information
that callers wish for first responders to be aware. PSAPs are encouraged to explore and
collaborate with local communities on the best practices for creating and maintaining caller
profile registrations. PSAPs are also encouraged to work with individual companies and
consumers to acquire access, where possible, of caller profiles to eliminate redundancy. The
maintenance of the profile should be the responsibility of the individual consumer, renewed a
minimum of six months.

Callers who may have data information stored for retrieval during the emergency call may make
a quick and synchronous connection to appropriate PSAP & MCLS. In a same manner as
ANI/ALI, the communication preference, language preference, medical information, and
frequent physical addresses will appear on Telecommunicator screen. Also Telecommunicators
will be able to see the caller profile and to provide appropriate services to callers who may not be
able to communicate their needs. (See diagram in Appendix D) The challenges for individuals
who do not have stored data information include time delays in finding out communication
preference, getting MCLS on the line, and limited access to callers’ information that may be
pertinent to the emergency, such as information about medical conditions or type of disability.
(See diagram in Appendix E)

A.

Emergency Profile or Registry Recommendations


The concept of NG9-1-1 is to have access to a wide variety of databases for routing or call
processing. Examples of databases are subscriber/user account information with services and/or
products, relay service providers, communication devices, medical equipment information, alarm
system, vehicle telemetry, and other data information.

1) Profile information that Telecommunicators obtain data from could be:
a) form filled out by the caller, family member, social worker, and/or others
b) vCard or medical records forwarded by the caller
c) link to other databases such as medical records, vehicle, sensors, or other data
information
d) Emergency service organization
e) Communication service providers

2) Primary specific information on caller to be included in database could be:

a) Language

24


b) Communication Modes – for example, can’t hear but can speak
c) Preferred media types (video, text, audio, voice, AAC, etc.)
d) Disability
e) Frequent address(es)
f) Medical Alert – medications – known allergies
g) Special exit and route procedures
h) Link to other databases
i) Others

It is recommended that the following references are considered and possibly extended when
establishing the system for storing, managing, signaling and using caller data information for
accessible NG9-1-1:

• Internet Engineering Task Force (IETF) RFC 3840 and IETF RFC 3841, caller
preferences and caller capabilities16
• NENA 71-001 NG9-1-1 Additional Data17
• ETSI ES 202 746 User Profile Preferences and Information18
• IETF on additional data in emergency calls: draft-ietf-ecrit-additional-data19
• Global Public Inclusive Infrastructure (GPII)20


XVII. CONSUMER EDUCATION


The evolution to NG9-1-1 is likely to take some time, and will produce a changing patchwork of
available technologies as local and state migration is completed nationwide. As transition
occurs, it is important to educate the public on new forms of available communication access to
9-1-1 and where the communication access is available for use.

Even today, consumers are not aware of options being offered to reach 9-1-1, such as alternative
communication modes and relay services. To the extent possible, consumers should be made
aware of the best way to help themselves in an emergency, optimal modalities to meet their
individual communication preferences, and the best questions to ask PSAPs to make sure the
appropriate communication modes are available when and where they are needed.


16 http://www.ietf.org/rfc/rfc3841.txt
17 http://www.nena.org/general/custom.asp?page=NG911_AdditionalData
18http://www.etsi.org/deliver/etsi_es/202700_202799/202746/01.01.01_60/es_202746v010101p.
pdf
19 http://tools.ietf.org/html/draft-ietf-ecrit-additional-data
20 http://gpii.net


25


The need for public education has been stated by previous FCC advisory groups, including the
Communications Security, Reliability and Interoperability Council (CSRIC), Working Group
4B:
“Effective public education and awareness programs about NG9-1-1 and the appropriate
use of NG9-1-1 must be developed. Educating the public about NG9-1-1 should be done
in two phases, with two distinct results in mind. First, the public should be educated
about the benefits of NG9-1-1 to create a groundswell of support for its implementation.
An informed and engaged public will act as an extremely powerful and influential
lobbying group with decision makers who may be under-informed about the creation of
NG9-1-1. Later, when transition is nearing completion, the public must also be educated
about NG9-1-1’s expanded capabilities for receiving information and about how they can
best use these new options for contacting emergency services, as well as the limitations of
the new system.”


It is essential that NG9-1-1 public education include specific components to address the needs of
people with disabilities. Every community will tailor its consumer education to meet its
particular needs, but there are a number of topics that should be considered, such as:


Subscriber/user account information

Caller profile registration

How the 9-1-1 call is processed when registered or not registered

Choosing relay services or PSAP who will connect callers with SLI or CA

Pros and cons of relay services and MCLS

Options for communication access while calling 9-1-1

Criminal charges for improper use or abuse of 9-1-1 calls

It will be a challenge, but necessary, to devise a plan that includes information on HOW to reach
9-1-1 as well as WHERE specific communication modalities are available to individual PSAPs.
It will also be a challenge to update this information as the migration to NG9-1-1 continues.
State and local 9-1-1 authorities are strongly encouraged to work with individuals, advocates and
organizations familiar with the emergency communication preferences of people with disabilities
to identify their needs – from their perspective. Melding these needs with the particular needs of
PSAP Telecommunicators will provide the framework for a public education program that
enables PSAP Telecommunicators the ability to help callers in truly effective ways.

There may be a variety of options for how and where NG9-1-1 consumer education could be
conducted. While in-person or video education may be preferable, other methods may be useful,
such as webcast demonstrations (i.e., YouTube, etc.), public service announcements with open
captions, and SLI and descriptive video services. Public education could be conducted in a
number of venues, including Deaf and Hard of Hearing Commission meetings, Deaf/hard of
hearing/deaf-blind/late deafened clubs/organizations as well as organizations or associations
servicing persons with disabilities meetings, booths at events, and informational presentations.

The timing of efforts should not only consider conducting consumer education before a new
emergency communication option is available, but ongoing education after implementation of
new technologies – perhaps on an annual basis. The credibility of the information is crucial, so

26


presenters should be selected carefully, and it is recommended that the message be delivered by
both PSAPs and community leaders; making sure that all appropriate accommodations are
available (SLIs, caption, etc.). A collaborative approach will not only ensure appropriate
expertise, but may also leverage resources and facilitate the process of reaching the greatest
number of people who need the information.

The options for public education contained in this document are not meant to be an exhaustive or
detailed list, but are intended to raise general issues for providing information about the NG9-1-1
system to the public that is truly useful for both consumers and PSAP Telecommunicators, and
effective in making both callers and PSAP Telecommunicators ready for communicating in an
emergency.


XVIII. CONCLUSION


Live video and text communication is becoming popular for communication worldwide and will
be commonly used among all people.

Video technologies (stand alone, built-in webcam via computer, tablets & smart phones) are
expanding, as well as applications which individual use for video communication. Products and
applications from video relay service will not be the only method for calling 9-1-1. Video
conferencing is also expanding. It is essential that individuals have direct access to 9-1-1 via
video (as well as audio, real-time text, text messaging, and data) using any application and
device.

Text communication via IP and various methodologies for cellular phones and land line
communications are being used more and more every day. TTYs continue to be a viable method
of communication for people with various disabilities. It is also essential that individuals have
direct access to 9-1-1 via text methods using any application and device.

An additional benefit of having direct video call to 9-1-1 is Telecommunicators will be able to
provide visual information on callers and their surroundings to first responders. This will help to
minimize frustration and problems for both callers and first responders, as well.

Like hearing callers, people with disabilities will be able to call 9-1-1 directly and have
Telecommunicators to connect the caller with a SLI or CA. Clear communication during times
of emergency is critical. However, many individuals may not be able to communicate
effectively due to their disabilities, injury or shock. Therefore, it is recommended that Media
Communication Line Services (MCLS) be established to facilitate effective communication for
people who need to contact NG9-1-1 in an emergency.


27


APPENDIX A: NG9-1-1 PC33 Use Case 3: ASL Caller Requiring Video Remote
Interpreter (VRI)


NG9-1-1 PC3 Use Case 3:
ASL Cal er requiring VRI
5
1

NG9-1-1

3

Provider


2
4
1.  ASL Video Emergency Call
2.  NG9-1-1 with video
3.  PSAP establishes PC3 with caller
4.  VRI is added to conference
5.  Centralized recording captures media from all endpoints



© 2011 Avaya Inc. All rights reserved.
8















28



APPENDIX B: Legacy 9-1-1 - Hearing person who speaks foreign language other than
English calls 9-1-1


When a hearing person calls, the Telecommunicator recognizes that s/he speaks another
language. The Telecommunicator will connect to a language services agency to provide
translation services, turning the call into a three-way conference call. The PSAP has a contract
with the language services agency.




Caller


PSAP










Lan


guage

Services


























29


APPENDIX C: Legacy 9-1-1: Video Relay Service (VRS) – Calling 9-1-1


• A person calls VRS first and then interpreter call 9-1-1.
• VRS providers have contracts with vendors that provide routing services to appropriate
PSAPs.
• Video Interpreters call the routing service vendor first and give address to a live person
prior to connecting to PSAPs.
• Calls can go through non-emergency, emergency or administrative lines rather than via
the 9-1-1 line. Telecommunicators have priority to respond to calls coming through
9-1-1 line, so non-9-1-1 line calls can result in delayed responses.
• The video interpreter relays communication between Telecommunicator and caller.




Routing


Services






PSAP






Video

Caller


Interpreter





















30


APPENDIX D: NG9-1-1: A person calls 9-1-1 using multimedia (caller profile)


When a person calls NG9-1-1, the signaling will reflect the desired communication mode,
language preference and a specific combination of media types, and then will connect to the
PSAP, engaging the Media Communication Line Service simultaneously. During the call set-up,
MCLS will be invoked automatically as necessary, and the Telecommunicator will receive the
caller profile at her/his station stating the type of communication mode the caller prefers prior to
answering the call. All three parties involved in the call will have video conferencing. There
will be different types of communication modalities involved depending on the need of the
callers. Examples are shown in Diagram E.

PSAP will record all media types involved in the conversations.





PSAP






9-1-1

Caller


Caller

Profile


Database






Media Communication Line


Service





















31


APPENDIX E: NG9-1-1: A person calls 9-1-1 using multimedia


When a person calls 9-1-1 via video or other types of media, the Telecommunicator recognizes
that the caller needs SLI or another type of assistance such as revoicers, and then connects to
MCLS (same concept as language services). The caller’s terminal will engage in a call, such as
video conferencing. There will be different types of communication modalities involved
depending on the needs of the callers. Examples are:
• Deaf-Blind (DB) – interpreter will voice what DB signs and then Telecommunicator
responds by typing to DB who will read Large Print or Braille
• Speech Disabled (SD) – interpreter will revoice what the SD says and then
Telecommunicator will talk directly to SD
• Late Deafened (LD) or others who are learning ASL – LD will voice to
Telecommunicator and have interpreter to sign along with captions, or speechread the
interpreter

PSAP will record all media types involved in the conversations.






Caller

PSAP








Media


Communication


Line Service





32

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