Telecommunications Recommendations

Telecommunications(1), (2)

Like other aspects of electronic information technology (EIT), telecommunications poses specific accessibility issues for almost every community of persons with disabilities. Some of today's barriers have easy technological solutions, while others do not. Among the people who are most affected by telecommunications accessibility are those who are deaf or hard of hearing and those with disabilities affecting speech. TTY's (text telephones, often called TDD's -- "telecommunication devices for deaf persons") can be used by these people to communicate with others who also use TTY's, or -- through the Telephone Relay Service (TRS) that was established by title IV of the Americans with Disabilities Act (ADA) -- with others who use traditional voice telephones. Other individuals who are affected by telecommunications accessibility include those who have difficulty pressing touch-tone buttons, persons who are blind or who have low vision who cannot see visually displayed information such as message waiting or caller ID indicators, and persons with cognitive impairments or learning disabilities who have difficulty understanding or remembering serial connection choices (press 1 for ___; press 2 for ___; etc.).

Innovation in accessible telecommunications has dramatically increased in recent years, due in large part to the enactment of section 255 of the Telecommunications Act of 1996 (the Act). Unlike section 508 of the Rehabilitation Act, which only applies to federal agencies and departments, section 255 applies directly to those with the most control over the technology: the designers and manufacturers of telecommunications systems and equipment. Section 255 requires manufacturers of telecommunications systems and equipment and customer premises equipment to ensure that their products are designed, developed, and fabricated to be accessible to and usable by individuals with disabilities, if doing so is readily achievable. When it is not readily achievable to make the products accessible, the Act requires manufacturers to ensure that the equipment is compatible with existing peripheral devices or specialized customer premises equipment commonly used by persons with disabilities to achieve access, if doing so is readily achievable.

Innovation in the telecommunications industry will likely continue to provide federal agencies with an ever-increasing range of accessible products and services from which to choose.

Telecommunications Findings

To determine the current level of accessibility of agencies' telecommunications products and services, the Component Questionnaire asked specific questions in each of the following categories:(3)

  • providing direct access for TTY callers,
  • making full use of the Telephone Relay Service,
  • providing accessible pagers and paging systems,
  • making all telecommunications services accessible to all persons, and
  • evaluating overall telecommunications services for accessibility

Agencies were also asked to summarize their telecommunications findings and recommendations in an overall, subjective agency report.

A. Providing direct access for TTY callers (Questions 1, 2, 3, 5, 6, 10e).

A TTY is a device that is used in conjunction with a telephone to communicate with persons who are deaf, who are hard of hearing, or who have disabilities affecting speech. To communicate by TTY, a person types his or her conversation, which is read on a lighted display screen and/or paper printout feature of the TTY by the person who receives the call. Both parties must have TTY's to communicate. When typing on a TTY, each letter is transmitted by an electronic code called Baudot, which is sent from the TTY on the sending end of the call through the telephone line in the form of tones to the TTY on the receiving end of the call, the same way voiced communications occur between two parties. The receiving TTY transforms the tones back to letters on a small display screen and/or on a paper printout.

Communication between two persons using older models of TTY's can only occur in one direction at a time; both persons who are conversing cannot type to each other at the same time but must take turns sending and receiving. A person sending a communication by TTY indicates that he or she has finished transmitting by typing the command, "GA," which stands for "go ahead."

A person can also use a computer with a TTY modem and related software to communicate with someone who has a TTY or who has a computer with TTY software and a modem. Computers generally operate in American Standard Code for Information Exchange (ASCII), an electronic "language." A person who uses ASCII must use an ASCII/Baudot modem and related software to convert the ASCII code into Baudot code to communicate with another person who is using a Baudot-based system. Similarly, a person who is using a Baudot-based TTY must utilize conversion software to communicate with a person using an ASCII-based computer. Some TTY's can function in both Baudot and ASCII.

The Component Questionnaire asked several different questions to determine the extent to which TTY users (federal employees and members of the public) are able to communicate with federal agencies. Question 1 measured the extent to which TTY users are able to communicate directly with federal employees, that is, whether federal employees can receive TTY calls without relying on an outside relay service or third-party services. Direct access can be achieved by providing and advertising a dedicated TTY line or by maintaining standard telephone lines that are staffed by persons with both voice and TTY capabilities. The results of the survey were somewhat surprising: mid-sized agencies were significantly more likely to provide direct access to incoming TTY callers than larger or smaller agencies. This statistic may reflect a greater degree of centralized call centers among mid-sized agencies than others.

Question 2 asked whether agencies that used incoming call sequencing systems ensured that those systems were able to acknowledge a TTY call, send a "wait" message to the caller, and accept the call in sequence. Very few agencies offer this capability, even though many agencies -- especially those in large and mid-sized categories -- use incoming call sequencing systems. Interestingly, very small agencies do a much better job than others of ensuring that their incoming call sequencing systems are accessible to TTY users in this respect.

Question 3 focused more specifically on whether employee workstations -- as opposed to incoming call centers -- were equipped with TTY's or equivalent technology so that federal employees could accept direct TTY calls. Again, overall, mid-sized and very small agencies fared much better in this regard than did the large and small agencies.

The next direct-access TTY question, Question 5, asked whether any automated information services with prerecorded voice messages were also available in a text messaging mode that could be used by TTY callers. Very few agencies provide text message equivalents for automated information services, despite the fact that a large majority of components in all agency size categories provide automated information services for voice callers. Mid-sized agencies again fared the best in this regard.

More people who traditionally used TTY's are switching to other types of equivalent technology that often uses ASCII signals rather than Baudot tones. Question 6 of the Component Questionnaire was designed to determine whether agencies were equipped to handle incoming ASCII signal calls. Few agencies in any category size are equipped to handle ASCII calls unless the user converts the ASCII tones to Baudot tones by using special software.

To handle a large volume of calls more efficiently, a large majority of agencies in all size categories operate telephone services that require callers to select from an interactive menu of choices for proper connection (e.g., "press 1 for ____, press 2 for ____, etc.") or have sophisticated connection systems that allow callers to connect with a specific person by spelling the desired person's last name with the telephone keypads for connection purposes.

Question 10(e) was designed to determine whether these connection systems are accessible to TTY users. While few components of cabinet level and large agencies make such systems accessible to TTY users, a moderate number of components in all other agency size categories do so.

Promising Practice Social Security AdminD

B. Making full use of Telephone Relay Services (Question 4).

Prior to the late 1980's, people who were deaf or hard of hearing, as well as those who have disabilities affecting speech, were generally only able to call other people who had TTY's. Title IV of the Americans with Disabilities Act (ADA), which amended section 255 of the Telecommunications Act, 47 U.S.C. § 255, established the Telephone Relay Services (TRS) nationwide.(4) TRS enables telephone conversations between people who use TTY's and those who do not. Specifically, a TTY user may telephone a voice user by calling a TRS provider, where an operator will place the call to the voice user and relay the conversation by transcribing spoken content for the TTY user and reading text aloud for the voice user. Likewise, voice users may place calls to TTY users through the TRS.

Frustrations often experienced by TTY usersD

Some people who are deaf or hard of hearing have understandable speech. Many such persons prefer to speak for themselves on the telephone, rather than have TRS operators voice their typewritten communication. This method of using TTY's is referred to as "voice carry over" (VCO). The VCO user will place a call through the TRS, will speak over the telephone to a nondisabled person, and the TRS operator will type the nondisabled person's communication for the VCO user to read on his or her TTY. The TRS operator usually does not interfere with the VCO user's spoken communication. "Hearing carry over" is the corresponding service that is available for people who can hear but who have disabilities affecting speech.

There are other types of relay services that do not require the use of a TTY, such as video relay interpreting(5) and speech-to-speech relay.(6) While some state TRS services and some private businesses offer these services, the Federal Information Relay Service (FIRS) does not.

While use of the TRS has a greater impact on an agency's ability to meet its general non-discrimination and reasonable accommodation obligations under sections 501 and 504 of the Rehabilitation Act, there are also implications for section 508: to the extent that an agency finds that it is an undue burden to develop, procure, maintain, or use telecommunications systems ­ including services, software, and equipment ­ that are accessible to persons who use TTY's, it must provide an accessible alternative way for TTY users to obtain the information that would have been obtained over a system that was directly usable by them, pursuant to section 508(a)(1)(B). The TRS can provide a cost-effective means for agencies to meet this obligation.

In many circumstances, federal agencies may provide a reasonable degree of communications access between employees who use TTY's and employees who use standard telephones, as well as between members of the public who use TTY's and employees who use standard telephones, by taking full advantage of the toll-free TRS.(7) Unfortunately, the self-evaluation revealed that the majority of agencies do not provide adequate training to their employees regarding the availability and use of the TRS.(8)

This lack of training likely results in a significant underutilization of the TRS and in the provision of lesser government services to persons who are deaf or hard of hearing or who have disabilities affecting speech. Unlike some other aspects of telecommunications accessibility, improving the extent to which the federal government makes use of the TRS is relatively cost-free.

When agencies do not adequately train employees regarding how to use the TRS, members of the public, job applicants, and federal employees with disabilities are affected. Many federal employees are instructed not to accept collect calls on behalf of their agencies. Some may mistake TRS operators for collect call operators and refuse to accept calls placed by TTY users through the TRS.

How to use the Federal Relay ServiceD
Lack of training on TTYsD

B. Providing accessible pagers and paging systems (Questions 7 and 8).

Only a decade ago, it would have been difficult, if not impossible, for federal agencies to provide paging services and equipment that provided users with options. Today, pagers and paging services allow for users to select notification via vibration, audio output, and/or visual display. Messages can be sent via direct TTY, TTY-to-voice translation, alphanumeric, e-mail, and digitized voice. Messages can be delivered via digital recordings, alphanumeric output, and even the font and size of visual messages can be set to user preferences. Many of these features, such as visual display screens, were developed and marketed for business men and women to enable them to be notified of incoming pages when use of audible tones would disrupt meetings. This technology can also provide federal employees who are deaf or hard of hearing with the same ability to receive pages as their peers.

Larger agencies are far more likely than smaller agencies to provide some employees with pagers. Almost all agencies that provide pagers use systems that allow the user to choose between audible or alternate (usually a vibration) notification for incoming pages. Slightly fewer use paging systems that provide users with a choice of audible or visual display pagers.

C. Making telephone services available to all persons (Questions 9, 10a-d).

Federal agencies are using many more information telecommunications services than ever before. Caller ID, which informs the call recipient of a caller's identity before picking up the phone, allows the recipient to screen calls in a way that was only achievable before with the assistance of a highly effective secretary. Voice mail, now widely used, ensures that messages are not written down inaccurately or lost. Message waiting notification informs users when they have messages waiting in the voice mail system. Telephones equipped with the ability to display these and other types of visual information or status cues are becoming more common in the federal workplace. While many of these newer telephone services allow nondisabled federal employees to work more efficiently and effectively, a great many agencies are not ensuring that these services are accessible to persons who are blind or who have low vision, despite the availability of accessible alternatives.(9)

On the whole, larger agencies are more likely than smaller agencies to use these improved telephone services. Fewer than half of the agencies which provide caller ID services make them accessible for users who are blind or who have low vision. Roughly just over half of the agencies that provide message waiting notification services make those services accessible to people who are blind or who have low vision. The self-evaluation revealed no clear patterns regarding whether agencies made other types of visual information or status cues accessible to blind people or those who have low vision.

There is another type of telecommunications service that is not dependent on the user's desk-top equipment. More agencies, to increase efficiency and reduce personnel-related expenses, are requiring callers to navigate their telephone interactive menu systems or prerecorded messages through touch-tone menu selection rather than a human operator. Some of these systems require serial choices for proper connection, (e.g., "press 1 for ___, press 2 for ___, . . . "). Others require callers to spell a persons's last name with the telephone keypads, (e.g., to reach John Doe, the caller would press 3 - 6 - 3 as the numbers on the telephone keypad corresponding to D-O-E). Another variation on this theme is to provide a variety of prerecorded messages, often containing commonly requested information, that can be selected by choosing the appropriate touch-tone number corresponding to a menu option.

While these features can enhance an agency's operations, they can also present barriers for some people with disabilities. Persons with disabilities affecting manual dexterity may find it impossible or at least very difficult to press touch-tone buttons. Some persons with cognitive impairments or learning disabilities may have difficulty understanding or remembering the options presented to them. TTY users who call through the TRS generally have to call repeatedly to give the TRS operator an opportunity to accurately convey the full menu, have the caller communicate his or her choice, and ultimately choose the correct touch-tone to activate the system. Another real, though less obvious, problem is that most interactive menu connection systems have timed defaults which require callers to proceed at an average rate of speed or the call is terminated. Someone with significant cerebral palsy who pushes touch tone buttons with a pointing device held in her mouth may find that she cannot negotiate the system quickly enough.(10)

Most of these difficulties can be ameliorated if callers were provided the option to speak directly with a live operator for assistance. The self-evaluation revealed that a clear majority of agencies provide some operator assistance for their automated incoming call connection systems. A significant portion of these, however, do not provide operator assistance during all times that the lines are in use.

In spite of agency downsizing, agencies should be encouraged to retain live operators instead of going to fully automated systems.

Another way to increase the accessibility of automated call connection systems is to allow callers to modify the default time within which they are required to respond with their choices, or simply to maintain systems which do not have a timed response default setting at all. The self-evaluation revealed that very few agencies maintain systems that allowed users to modify default time settings; none of these are in the mid-sized, small, or very small agency size categories. Of the remaining components that maintain automated call connection systems, the percentages of agencies' systems that do not have default time settings at all (increasing these systems' accessibility) are inversely proportionate to the size of the agency. In other words, smaller agencies -- which are likely to have a smaller volume of incoming calls -- are less likely to require callers to make quick selections from interactive menu systems.

Lastly, for some people with disabilities, serial connection systems become accessible when the caller is given an option to activate the system through voice commands rather than touch-tone selections. Voice recognition technology has quickly become more accurate, widely available, and much less expensive than ever before. While few agencies in any size category currently provide a voice-response option, it is likely that more agencies will incorporate such options into their automated call connection systems in the near future as prices continue to drop and availability becomes more wide-spread.

Evaluating overall telecommunications services (Question 11).

After answering the specific questions regarding telecommunications accessibility, agency components were asked to describe the degree to which their telecommunications systems, overall, were accessible to users with disabilities (Question 11). Relatively few agencies concluded without reservation that their major telecommunications systems are generally accessible. Just less than half of agencies described their telecommunications applications as generally accessible, while recognizing problems in some fringe areas. Fewer mid-sized agencies than the larger or smaller agencies determined that some of their telecommunications applications excluded one or more communities of persons with disabilities, while roughly 20 percent of all agencies determined that their major telecommunications applications as generally inaccessible to one or more communities of persons with disabilities.

Most components noted that they had few problems making their pagers and paging systems accessible to persons with disabilities.

Many components noted that as a result of their self-evaluation, they already have placed TTY's in areas with frequent public contact, or are planning on doing so in the near future. In one instance, the Social Security Administration (SSA) provides stand-alone TTY's in the lobby areas, health centers and union offices at SSA Headquarter buildings, and ensures that pay phone TTY's are available for personal phone calls by employees and members of the public. Another instance, the Department of Labor intends to "establish a Department requirement to provide a TTY phone in all . . . human resource and finance offices," as well as security guard desks and stations. (Dept. of Labor, Overall Agency Evaluation, p. 7; [noted as pending within DOL]). The Department of Labor also intends to broadly distribute a list of locations of TTY's and the contact number for the Federal Information Relay Service. Id.

Many agencies, such as the National Archives and Records Administration (NARA), indicated in their overall agency evaluations that as they upgrade their telephone systems, they will consider accessibility as one of the primary issues. As NARA replaces its telephone system in 2001:

. . .  one of the primary functional requirements will be accessibility by TTY/TDD systems to provide access to recorded information and to serial choices that provide line connections. NARA will improve training and availability of operators who can assist TTY/TDD calls.

NARA's Overall Agency Evaluation at 4.

Other agencies are exploring options to correct some of the barriers identified during the self-evaluation process. For instance, the Merit Systems Protection Board is considering adding an attendant to its 800 information line and adding equivalent service for TTY users who cannot currently use the agency's toll-free information line. Merit Systems Protection Board's Overall Agency Report at 3. Similarly, the Civil Rights Commission is considering adding a text messaging mode to its automated information services which currently operate only with prerecorded voice messages. Civil Rights Commission's Overall Agency Report at 2. Still other agencies plan to make more modest changes, such as incorporating instructions regarding how to use the TRS into the next edition of the agency's telephone directory. Federal Maritime Commission's Overall Agency Report at 1.

Sometimes, it appears that the interdisciplinary nature of telecommunications accessibility solutions may stifle their acceptance. For instance, some of the common intra-agency budgeting, procurement, and personnel divisions between traditional "Information Technology" staff and telecommunications staff can stifle innovative, cost-effective approaches to solving some of the barriers identified in this Report. Therefore, agencies can provide direct access for TTY callers by purchasing software that, in essence, enables every desktop computer to function like a TTY. Computer-based TTY technology can be more cost-effective than outfitting federal workstations with stand-alone TTYs. In at least one cabinet-level agency, resistance has come from the telecommunications staff, who do not want to purchase software that would run on a secure network, as well as from the Information Technology staff, who do not see as their mission making the agency's telecommunications services more accessible to persons with disabilities. High-level leadership may be required to address some of these interdisciplinary issues.

On the other hand, some agencies have looked past the traditional divide between telecommunications and information technology, using telecommunications as a means to ensure that information otherwise provided via computers is available to everyone.

As in other areas, those agencies with more centralized administrative structures generally tended to be those who were best able to implement telecommunications accessibility solutions and who had the fewest telecommunications barriers. As telecommunications technology continues to advance, it will be important that all agencies ­ regardless of administrative structure ­ are able to timely and efficiently find and implement solutions to telecommunications barriers as they arise.

Promising Practice: Job LineD

In light of these findings, the Department recommends the following:

Training. Each agency should train all federal employees who communicate by telephone with the public or with other employees on how to use TTY's, the Telephone Relay Service (TRS), and the Federal Information Relay Service (FIRS). GSA and the Access Board, in consultation with the FCC, should develop a short, electronic training module that can be made available through agency intranet sites at minimal expense.

TTY's in Public Areas. Each agency should provide TTY's, outlets, and shelves wherever the agency provides telephones for members of the public.

TTY's in Call Centers. Each agency should install TTY lines wherever it receives a large volume of incoming calls.

FIRS. GSA, in consultation with the FCC and other key agencies and inter-agency groups, should explore upgrading the Federal Information Relay Service (FIRS) to include video relay interpreting and speech-to-speech relay services.

Operators. Each cabinet level, large, and mid-sized agency should make operators available on its interactive automated telephone services and should allow callers to connect with operators by pressing "0" or by staying on the line. See General Appendix A (Categories of Agencies). Small and very small agencies should explore cost-sharing measures to provide operators for their interactive telephone services.

Equivalent Interactive TTY Telephone Services. Each agency should configure its interactive telephone systems to be compatible with TTY's ­ or should provide equivalent TTY interactive systems containing the same functions and information (and updated as often). This goal can be easily accomplished by adding a second telephone line with a TTY message and TTY compatible features that are equivalent to those provided on the interactive voice systems.

Equivalent TTY Toll-Free Information Services. Each agency that provides toll-free information lines should ensure that those lines support TTY use or the agency should maintain equivalent separate toll-free TTY information systems that are staffed to be as responsive as the standard toll-free information lines.

Computer-Based TTY Equivalency Systems. GSA and the Access Board, in consultation with the FCC and other key agencies and inter-agency groups, should explore purchasing a government-wide license (or multiple licenses to offer to agencies) of ASCII/computer-based TTY systems to ensure that all agencies' employees with networked computers have TTY equivalency on their network with minimal per-employee costs. Appropriate attention should be paid to factors such as computer network security.

Voice Recognition Technology. GSA and the Access Board, in consultation with the FCC and other key agencies and inter-agency groups, should explore buying multiple licenses for voice recognition technology to install on all agencies' interactive telephone systems.

'Telecommunications Technology Assistance Center'. The FCC, in consultation with GSA, the Access Board, and other key agencies and inter-agency groups, should establish a telecommunications technical assistance center. This Technical Assistance Center should assist agencies in working with manufacturers ­ for example, to reconfigure telephone systems to send a "wait" signal to TTY users ­ and to take full advantage of advances in technology that are coming from section 255 of the Telecom Act and section 508 of the Rehabilitation Act.

1. This document is available on the Department of Justice's section 508 Web site ( People with disabilities may request copies in Braille, large print, or on computer disk by calling 1-800-514-0301 (voice) or 1-800-514-0383 (TTY).

2. The data underlying the analysis given below appears at Telecommunications Appendix A (Question-by-Question Results from the Component Questionnaire). Workforce statistics for weighing the telecommunications data are set forth in Telecommunications Appendix B.

3. Because of these categories, some survey questions are discussed out of order in this Report.

4. The provision of Telephone Relay Services required by title IV of the ADA is enforced by the Federal Communications Commission (FCC). See, "Frequently Asked Questions on Telecommunications Relay Service (TRS)," which is available on the FCC Web site ( A directory of TRS providers is also available on FCC's Internet site (

5. Video relay interpreting (VRI) allows a nondisabled person to speak over a telephone to a sign language interpreter in a remote location. A real-time video stream of the sign language interpreter "signing" the nondisabled person's words is fed through a computer to a deaf or hard of hearing person who then reads the interpreter's sign language and responds using sign language. A real-time video stream of the person who is deaf or hard of hearing is fed to the sign language interpreter, who then voices the signed communication to the nondisabled person over the telephone. Except for the use of technology, the process greatly resembles typical person-to-person communication via a sign language interpreter. On February 17, the FCC adopted new rules that make it easier for TRS providers to fund VRI services. FCC Docket CC 98-67.

6. Speech-to-speech relay services are used by those whose speech is difficult for others to understand, such as some people who are profoundly hard of hearing or deaf and those who have disabilities affecting speech (i.e., cerebral palsy). Specially trained relay operators recite the words of the caller (or recipient) with a disability, allowing the person to communicate with others. On February 17, 2000, the FCC amended its rules to require TRS suppliers to provide speech-to-speech services. FCC Docket CC 98-67.

7. There are some circumstances when it is inappropriate to rely on the TRS and when direct TTY service should be provided, such as for emergency call centers (i.e., 9-1-1 centers). Calls placed through the TRS take quite a bit longer than direct TTY connections and, because the relay operator may not be familiar with technical terms, can be less accurate.

8. All Telephone Relay Service (TRS) providers, including the Federal Information Relay Service (FIRS), will provide employee training available upon request. Training generally covers:

  • TTY etiquette, including
    • instructing the voice caller to speak as though he or she was talking directly to the TTY caller, instead of through a third party
    • using the expressions "go ahead" to signal the TTY user that it is his or her turn to communicate; and
  • the confidentiality of all calls placed through the TRS.

9. Some of the disability-friendly products and services that are now offered by mainstream telecommunications companies include:

  • Repeat Dialing -- Redials a busy line when the caller needs to get through; this is especially helpful for persons who have difficulty dialing the phone or remembering telephone numbers;
  • Voice Dialing -- Allows the user to dial handsfree by using voice commands instead of the keypad;
  • Distinctive Ring -- plays different ring patterns for additional telephone numbers; this is especially useful when maintaining separate voice/TTY numbers on same telephone;
  • Talking Caller ID -- Talking Caller ID audibly announces the telephone numbers of callers before the phone is picked up;
  • TTY Caller ID -- TTY Caller ID is a unit that attaches to the user's current phone or TTY that displays the names and numbers of callers before the phone is picked up;
  • Voice mail can be programmed to remind people when to take their medication;
  • Stutter tone: Audibly notifies the user when the receiver is picked up that messages are pending in voice mail by giving a tone that is different from the standard dial tone. This variation in tone is helpful to persons who cannot see visual message indicators; and
  • Nib on the 5 key: Provides tactile location of number placement on keypad. This tactile reference point is especially useful for persons who cannot see the keypad.

10. During the public comment period of the FCC's notice of proposed rulemaking for standards to implement section 255 of the Telecommunications Act, several persons pointed out how these technologies can become barriers to persons with disabilities:

  • "People with disabilities have been terribly affected by such lack of access; many menus offer no option to connect with a human operator and they remain cut off from communication." Dana Mulvaney, commenter, "In re Sections 255 and 251(a)(2) of the Communications Act of 1934, as Amended by the Telecommunications Act of 1996," Federal Communications Commission's Report and Order and Further Notice of Inquiry, FCC 99-181 (adopted July 14, 1999; released Sept. 29, 1999), at 51.
  • "Voice mail and automated voice response systems, so common today, are impossible for many hard of hearing people to understand. Ears affected by hearing loss, even when properly fitted with hearing aids, cannot process sound as quickly as normal ears; by the time the first word or two are deciphered, the speaker is already on to the next sentence." Joan P. Ireland, commenter, Id. at n.237.

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Updated August 6, 2015