DA 02-2095

August 27, 2002

**WIRELESS TELECOMMUNICATIONS BUREAU**

**SEEKS COMMENT ON JOINT PETITION FOR RECONSIDERATION**

**REGARDING DIGITAL WIRELESS TRANSMISSION OF 911 CALLS USING TTY
DEVICES**

(CC Docket No. 94-102)

**Comments/Oppositions Date: September 26, 2002**

**Reply Comments Date: October 11, 2002**

The Commission's rules require that, by June 30, 2002, all digital
wireless service providers were to be capable of transmitting 911 calls
made using text telephone (TTY) devices.[^1] On June 28, 2002, the
Wireless Telecommunications Bureau released an Order granting, in whole
or in part, certain petitions for waiver of this deadline.[^2] On July
27, 2002, Illinois Valley Cellular RSA 2-I Partnership, Illinois Valley
Cellular RSA 2-II Partnership, and Illinois Valley Cellular RSA 2-III
(collectively "IVC"), Missouri RSA No.7 Limited Partnership d/b/a/ Mid
Missouri Cellular (MMC), and Public Service Cellular, Inc. (PSC)
(collectively "Petitioners") filed a Joint Petition For Reconsideration
(Petition) seeking limited reconsideration of the Bureau's Order.

The Bureau's Order granted the Petitioners' requests for waiver of the
June 30, 2002, deadline. However, the Petitioners seek reconsideration
of that portion of the Order requiring carriers, by December 31, 2003,
to proceed to implement a TDMA-TTY solution in the event that they still
are operating a TDMA network.[^3] The Petitioners argue that their
provision of new TTY-compatible digital services by December 31, 2003
should be sufficient to ensure that people with hearing disabilities can
obtain access to 911 services using TTY devices and that it is
unnecessary to require them to implement a TTY solution in TDMA systems
that remain operational after that time.[^4] Petitioners further argue
that, because of the phase-out of TDMA technology by large carriers and
the likelihood of long-term TTY users to purchase a TTY-compatible phone
based on technology that will continue to be supported, the availability
of TDMA TTY-compliant handsets is uncertain.[^5]

The Petition is available for public inspection during regular business
hours in the FCC Public Reference Room, Room CY-A257, 445 12^th^ Street,
S.W., Washington, D.C. 20554.

Pursuant to 47 C.F.R. § 1.1200(a), this proceeding is designated as a
"permit but disclose" proceeding and subject to §1.1206 of the
Commission's Rules.[^6] Presentations to or from Commission
decision-making personnel are permissible, provided that *ex parte*
presentations are disclosed pursuant to 47 C.F.R. §1.1206(b).

Interested parties may file comments or oppositions responding to the
Petition on or before September 26, 2002, and reply comments on or
before October 11, 2002. Comments may be filed using the Commission\'s
Electronic Comment Filing System (\"ECFS\") or by filing paper
copies.[^7] Comments filed through the ECFS can be sent via the Internet
to: \<http://www.fcc/e-file/ecfs.html\>. Only one copy of an electronic
submission must be filed. In completing the transmittal screen,
commenters should include their full name, postal service mailing
address, and the applicable docket or rulemaking number.

Parties may also submit an electronic comment by Internet e-mail. To get
filing instructions for e-mail comments, commenters should send an
e-mail to ecfs@fcc.gov, and should include the following words in the
body of the message, \"get form\<your e-mail address\>.\" A sample form
and directions will be sent in reply.

Parties who choose to file by paper must file an original and four
copies of each filing. All filings must be sent to the Commission\'s
Secretary, Marlene Dortch, Office of the Secretary, Federal
Communications Commission, 445 12th Street, S.W., Washington, D.C.
20554. A copy should also be sent to Andra Cunningham, Room 3-B103.

Alternative formats (computer diskette, large print, audio recording and
Braille) are available to persons with disabilities by contacting Brian
Millin, of the Consumer & Governmental Affairs Bureau, at (202)
418-7426, TTY (202) 418-7365, or e-mail at <bmillin@fcc.gov>.  This
*Public Notice* can also be downloaded in Text and ASCII formats at: 
<http://www.fcc.gov/cgb/dro>.

For further information concerning this proceeding, contact Andra
Cunningham, Policy Division, Wireless Telecommunications Bureau at (202)
418-1310, TTY (202) 418-1169.

**- FCC -**

[^1]: *See* Revision of the Commission's Rules to Ensure Compatibility
    with Enhanced 911 Emergency Calling Systems, CC Docket No. 94-102,
    Fourth Report and Order, 15 FCC Rcd 25216, 25218 (2000) (*Fourth
    Report and Order*). *See also* 47 C.F.R. Section 20.18 (c) and
    accompanying note (2001).

[^2]: Revision of the Commission's Rules to Ensure Compatibility with
    Enhanced 911 Emergency Calling Systems, CC Docket No. 94-102 (rel.
    July 28, 2002) (*TTY Waiver Order*).

[^3]: Joint Petition at 2.

[^4]: *Id*. at 2-4.

[^5]: *Id.* at 7-8.

[^6]: 47 C.F.R. §1.1206.

[^7]: *See* *In re* *Electronic Filing of Documents in Rulemaking
    Proceedings*, 13 FCC Rcd. 11322 (1998) (amending Parts 0 and 1 of
    the Commission's rules to allow electronic filing of comments and
    other pleadings).