FCC Allows IP Networks to Sub RTT for TTY Capability

December 16, 2016–The FCC today unanimously voted to amend its rules to allow IP (Internet protocol)-based networks to fulfill accessibility requirements by deploying RTT (real-time text) technology in lieu of supporting legacy TTY (text telephone) devices, resolving apparent disputes over whether to mandate various functionalities and attributes of RTT offerings.

The order adopted today in CG docket 16-145 and GN docket 15-178 sets a transition period for RTT implementation beginning Dec. 21, 2017, and ending in June 2021, Michael Scott, attorney-adviser in the FCC’s Disability Rights Office, said in presenting the item at today’s meeting.

The order requires RTT deployments to be backwards-compatible with TTY services and interoperable with RTT offerings on other networks.  It establishes adherence to the RFC 4013 standard as a safe harbor, Mr. Scott said.  He also said that it requires that RTT offerings have the ability to initiate and receive communications using the same 10-digit numbers used for voice and text communications. An accompanying further notice of proposed rulemaking asks about the appropriate timeline for ending the TTY backwards-compatibility requirement, Mr. Scott said.  It also asks about the need for RTT features to enable use of the technology by persons with cognitive disabilities and by deaf-blind individuals.

The text of the item was not available at TRDaily’s news deadline. The agency’s action stems from a petition for rulemaking filed by AT&T, Inc., last year (TRDaily, June 12), in which the company said that the rule change would allow network operators and device manufacturers to trade “an antiquated technology with technical and functional limitations” for a technology that enables “fully accessible IP-based services that seamlessly integrate voice and text, obviating the need for external assistive devices and potentially reducing reliance on relay services.”

Since AT&T’s request, the FCC has granted requests by AT&T, Verizon Communications, Inc., Cellular South, Inc., and the Competitive Carriers Association on behalf of its members for waivers of the agency’s requirement to support TTY use to the extent that carriers use IP technologies, conditioned on commitments to develop RTT services on their wireless IP networks.

Because RTT technology delivers characters as they are typed, rather than writing for the user to hit “send,” public safety answering points will receive incomplete RTT  messages sent to 911 by people who are unable to complete their message, the FCC said in a press release.  It also highlighted the ability to use RTT for direct, real-time communications between people with disabilities and those without.  RTT technology can be used in “off-the-shelf devices like common smartphones,” it added.

Gallaudet University President Roberta Cordano addressed the Commissioners during the meeting, praising their action and saying that RTT technology “creates wonderful possibilities, allowing communication to take place anytime, anywhere.”  She added that it means users don’t have to wait for the other person to finish typing, unlike the frustration of being unable to interrupt when using TTY technology.

The order does not mandate RTT deployment but instead lays out a path for those providers that choose to offer it.

In her statement, Commissioner Mignon L. Clyburn expressed regret that the order did not do all that she hoped it would, saying that it “represents just the first of many steps we must take, and now, if you will forgive me for continuing with the sports analogies, we will pass the baton to the wireless service providers and manufacturers, to get us all to the finish line. I know you are committed to making Real Time Text work, and I thank you for that. But I am also looking to you, relying on you, urging you, to provide the necessary support for Real Time Text, in order for it to fulfill its promise. Continue to work with consumer groups to ensure that the needs of the communities they represent are met by implementing features and capabilities that support successful deployment and broad adoption of Real Time Text. This is your chance to show us that you, that the market, can successfully address these issues without a mandate from us to do so.”

Commissioner Jessica Rosenworcel said, “For those who choose to move forward, we require Real-Time Text to be interoperable across networks and devices as well as backward-compatible with TTY systems. Real-Time Text will also need to support 911 communications and simultaneous voice and text features. I hope in time Real-Time Text is universally available as a native function. But for now, transition to this technology will transition our accessibility policies to the future. And that’s something we should all support.”

Commissioner Ajit Pai praised the benefits of RTT, including the speed, efficiency, and conversational-style of communications that don’t require a “send” button or a relay service intermediary.  The only problem with RTT, he added, has been that the FCC’s rules have not kept up, requiring carriers instead to support legacy TTY use. “Thankfully, this changes today. Our Order gives carriers the flexibility to invest in and deploy RTT instead of TTY. This, in turn, will enable consumers—particularly those with hearing and speech disabilities—to take advantage of the benefits of advanced IP technologies,” Commissioner Pai said. “I want to thank my colleagues for working in good faith to find common ground on this item, and I want to express my gratitude to the advocates in the hearing and speech disability community for the work you have done to advance this cause,” he added.

Commissioner Mike O’Rielly said, “Whether [RTT] will ultimately be successful will be up to consumers, but, going forward, wireless providers and manufacturers can choose — but are not required — to implement RTT. If these entities decide to offer RTT, then they no longer need to support outdated and rarely used TTY technology on their respective wireless networks.”

He added, “While it is about time that the Commission’s antiquated rules are modified and updated, I am pleased that the move to alternative technologies is being done here without imposing further technology mandates. Although it appears that the wireless industry is united and committed to moving forward with RTT, the Commission should not be in the business of dictating technology choices and picking winners and losers. Instead, such decisions should be driven by the free market and industry innovation. To argue that disability needs cannot be addressed without mandates and force ignores the modern reality of technology advancement and the interest of many in serving a desirable group of consumers.”

Commissioner O’Rielly also said that the Commission “should not mandate the design of service offerings” in regard to issues such as “whether RTT should be offered natively or as an application, latency and error rates, and character and text capabilities. These improvements from what was in the notice allow me to support this item. But there are still some things I am not enamored with. For instance, I would have preferred that manufacturers have no requirements in this area. Wireless providers should be able to work with manufacturers to obtain the necessary handsets without Commission involvement. In this case, however, manufacturers already fall under the accessibility and TTY requirements, so it makes some sense to include the changes contained within,” he said.

“Additionally, some wireless providers have expressed concern about the use of RTT on nonservice initialized (NSI) devices, which this item punts to the NSI 911 proceeding. As I have stated before, it is time for the Commission to resolve the NSI 911 issue once and for all. The Commission also needs to consider how RTT affects our text-to-911 requirement. Not surprisingly, there has been a lack of adoption by localities and PSAPs in which only one out of every five counties have operational text-to- 911.  Specifically, we should examine whether our text-to-911 mandate should be pursued or altered given that Commission finding here that RTT communications to 911 are superior to SMS,” Commissioner O’Rielly added.

Chairman Tom Wheeler signed a portion of his statement that he read at the meeting. In his written statement, he said, “In some places, this item sets out basic requirements for how to do this. In others, it offers strong guidance on how to achieve this in a way that will ensure that people with disabilities have the same access as voice telephone users. It is now up to industry to get this right. It will be critical to work with consumers on this — to confer with people with disabilities about their needs, and the features that are essential to making real-time text a successful alternative to TTYs and voice services. We understand that a lot of industry-consumer collaboration has already occurred on bringing us to this point. Let’s make it to the finish line,” the Chairman added.

In a joint statement, Telecommunications for the Deaf and Gallaudet University said, “We are pleased that the consensus-building between consumers, academics, carriers, and the FCC has culminated in an unanimous 5-0 vote on the RTT item. This underlines the importance of RTT to all stakeholders. We look forward to continuing to work with industry and the Commission during the TTY-to-RTT transition, by helping implement the requirements in the order, and assisting in making the recommendations a reality. We stand ready to assist with a smooth rollout that will result in a much improved wireless telecommunication experience for all Americans.” – Lynn Stanton, lynn.stanton@wolterskluwer.com

Courtesy TRDaily