DJ 192-180-04237
                                                APR 14 1992

The Honorable Strom Thurmond
United States Senate
217 Russell Senate Office Building
Washington, D.C. 20510-0010

        Re: #2064210032

Dear Senator Thurmond:

        I am writing in response to your recent inquiry on behalf of
your constituents.

        We are aware of the concern expressed by your constituents
and the National Emergency Number Association about the provision
in our regulation implementing title II of the Americans with
Disabilities Act that states "telephone emergency services,
including 911 services, shall provide direct access to
individuals who use TDD's and computer modems."

        The apparent concern is that by mandating access to persons
using computer modems, the regulation may require that there be
access by every format that could be used by a modem, including
those that are not compatible with equipment presently used by
emergency service systems. That is not the case. The regulation
does not require telephone emergency systems to do anything that
is technologically infeasible; accordingly, we are interpreting
the requirement for access by computer modems to mean only when
the modem is using the Baudot format. Until it can be
technically proven that communications in another format can
operate in a reliable and compatible manner in a given telephone
emergency, the public service answering point is not required to
provide direct access to computer modems using other formats.

cc: Records; CRS Files; Oneglia; Wodatch; McDowney.
    :udd:jonessandra:911.thurmond.constituents

01-00589





        Simply put, if a hearing impaired person places an emergency call using 
the ASCII mode, chances are virtually certain that the call will not be handled
properly. It could disconnect, receive garbled data or make no connection
at all. The result could be a possible loss of life or property. Emergency
centers will be held liable for conditions over which they have no control.
The hearing and speech impaired will not be served with the same quality
assurance that others have come to expect of their emergency centers and the
advent of the 9-1-1 systems.

We need your help to keep this from happening. We feel that the reference
to "computer modem" should be removed from the implementation rules until
technology can assure that every T.D.D. call will be answered with the same
quality as a voice placed call.

Please contact the Department of Justice and urge this change be made. Our
contact is:

                        Mr. Robert Mather, Attorney
                        U. S. Department of Justice
                        Civil Rights Division
                        Coordination and Review Section
                        P. O. Box 66118
                        Washington, D. C. 20035-6118

                        Telephone: (202) 307-2236

Very truly yours,

LANCASTER POLICE DEPARTMENT

W. B. Sumner
Chief of Police/Fire Department Administrator

WBS/css










01-00591 

January 7, 1992

The Honorable Strom Thurmond
SR-128 Russell Senate Office Bldg.
Washington, DC 20510
Honorable Thurmond:

        I am a member of the National Emergency Number Association (NENA).
I am writing to you to alert you to a flaw in the implementation rules
for Title II Section 35 of the A.D.A Law. (Hearing and Speech
Impaired). Our organization supports the A.D.A. Law 100%. However,
The Dept. of Justice, who provided these rules, have set in motion a

situation that could be fatal to a hearing and speech impaired person.
        The hearing and speech impaired community must communicate by
using a device similar to a typewriter (called a T.D.D.). They also
communicate using a personal computer (PC). The Justice Dept.
specifies that all emergency services shall provide direct access to
individuals who use T.D.D.s and computer modems.

        In the past, they have communicated using a baudot modem. It
still serves virtually all of the hearing and speech impaired today.
It is compatible with our emergency centers. But with the advent of
the personal computer, a new modem with a language called ASCII
(American Standard Code for Information Interchange) appeared. Its
original design was for a business machine to communicate with another
business machine, without human involvement.

        However, since it is being placed into T.D.D.s, and is the norm
for P.C.s, it presents a problem. It is not compatible with emergency
centers equipment. Also, there is at this time, no technology that
exists that will connect an incoming ASCII call to an ASCII modem in
the emergency centers and quarantee connection.

        Simply put, if a hearing impaired person places an emergency call
using ASCII mode, chances are virtually certain that the call will not
be handled properly. It could disconnect, receive garbled data or make
no connection at all. The result could be a possible loss of life or
property. Emergency centers will be held liable for conditions over
which they have no control. The hearing and speech impaired will not
be served with the same quality assurance that others have come to
expect of their emergency centers and the advent of 9-1-1 systems.


01-00590

                                -2-

We need your help to keep this from happening. We feel that the
reference to "computer modem" should be removed from the implementation
rules until technology can assure that every T.D.D. call will be
answered with the same quality as a voice placed call.

        Please contact the Dept. of Justice and urge this change be made.
Our contact is:

                Mr. Robert Mather, Attorney
                U. S. Department of Justice
                    Civil Rights Division
                Coordination and Review Section
                        P.O. Box 6118
                Washington, DC 20035-6118

                Telephone: (202) 307-2236

Sincerely,

Ralph E. Inman
President

REI/kb

01-00592