#  DA 00-1091

> Released: May 17, 2000

WIRELESS TELECOMMUNICATIONS BUREAU SEEKS COMMENT

ON NEW IMPLEMENTATION DEADLINE FOR TTY ACCESS

TO DIGITAL WIRELESS SYSTEMS FOR 911 CALLS

#### CC Docket No. 94-102

### 

### COMMENTS DUE: June 19, 2000

**REPLIES DUE: July 19, 2000**

The purpose of this *Public Notice* is to seek comment on a proposed
revised deadline for compliance with the Commission's rule requiring
transmitting of text telephone (TTY) 911 calls on digital wireless
systems, pursuant to 47 C.F.R. § 20.18(c). We also seek information on
other aspects of the various TTY/digital wireless systems compatibility
solutions, including consumer impacts, technical issues, etc. The
temporary waivers of the rule previously granted by the Commission will
remain in place pending the Commission's establishment of an
implementation schedule based on the information received in response to
this Public Notice.

## I. Background and Current Status

In the *E911 First Report and Order*,[^1] the Commission required that,
as of October 1, 1997, all covered wireless carriers must be capable of
transmitting 911 calls from individuals with speech or hearing
disabilities through means other than mobile radio handsets, *e.g.*,
through the use of TTY devices.[^2] To date, carriers operating digital
wireless systems have not been able to comply with this requirement
because digital systems have not been able to accurately pass the
Baudot-encoded audio tones produced by TTY devices. Recognizing the
technical difficulties associated with transmitting TTY calls on digital
wireless systems, the Commission suspended enforcement of the TTY
requirement for digital systems until December 31, 1998.[^3] The
Commission later granted over 100 temporary waivers of the rule, which
remain pending, while the industry worked on a solution.[^4]

Since September 1997, the Wireless TTY Forum (TTY Forum) --- an
organization consisting of wireless carriers, wireless equipment
manufacturers, manufacturers of TTY devices, emergency and relay service
providers, and consumer organizations representing individuals who are
deaf or hard-of-hearing --- has been meeting in an effort to develop
solutions that will enable TTY users to make 911 calls on digital
networks. At the January 26, 1999, meeting of the TTY Forum, Lucent
Technologies (Lucent) presented a potential solution to the TTY/digital
problem.[^5] Number range level0Number range level1Number range
level2Number range level3Number range level4Number range level5Number
range level6Number range level7The Lucent solution has subsequently been
approved by the Telecommunications Industry Association (TIA)
Subcommittees TR45.5 (CDMA) and TR45.3 (TDMA) standards bodies.

Ericsson, Inc. has proposed a potential solution to the TTY/digital
problem for GSM networks. The GSM standards body, Alliance for
Telecommunications Industry Solutions (ATIS) Working Group T1P1.5,
preliminarily adopted Ericsson's proposed solution for industry
balloting. After edits are completed, balloting on this proposed
standard is tentatively scheduled to begin July 28, 2000, and a standard
for GSM networks could be available as early as September 2000.[^6]
Currently, Motorola is working on a TTY/digital solution for its
proprietary iDEN technology.[^7]

## II. Request for Further Comment

##### A. Implementation Deadline

In fulfillment of Section 20.18(c), we expect digital wireless systems
to be widely accessible to TTY devices without imposing additional costs
on consumers who use these devices. In light of the technological
developments related to TTY/digital system compatibility that have
occurred during the past year, we believe it is appropriate to establish
a date certain by which providers of digital wireless services must
begin complying with Section 20.18(c). The approval of the Lucent
solution by two major standards bodies, and the apparent acceptance of
the Ericsson solution by a third standard body, indicates that carriers
providing digital service will be able to enable persons with
disabilities who rely on TTY devices to be able to call 911 in
emergencies using digital wireless phones in the near future.

We note that earlier this year Bell Atlantic Mobile and Lucent issued a
joint press release announcing their intent to collaborate on a new
service that would enable end-users to use their TTY devices in
conjunction with Bell Atlantic's digital cellular system, to be made
available in the second half of 2001.[^8] In light of this statement by
two key industry participants, as well as on the basis of preliminary
discussions Commission staff has held with various Forum participants,
we tentatively view December 31, 2001 as a reasonable deadline for
implementation of a digital wireless TTY solution; and propose that all
wireless carriers begin complying with Section 20.18(c) on or before
this date.

In this *Public Notice*, we seek comment on this proposed deadline,
particularly with respect to whether it would permit equipment
manufacturers and carriers sufficient time to complete the tasks
associated with implementing a system solution of this kind. Given the
adoption or imminent adoption of standards, commenters should be able to
identify the specific tasks they expect to be required to implement a
TTY solution (e.g., development and production of handsets containing
solutions, development and installation of solutions in network
infrastructure, development and production of interface hardware
connecting TTY devices and digital wireless phones, over-the-air testing
of solutions by equipment manufacturers and/or carriers, etc.). In
addition, commenters should provide estimates of how long each task is
expected to take.

We note that, in light of the extended period within which the
Commission has allowed industry groups to work on resolving the TTY
incompatibility problem, the revised deadline the Commission will adopt
will be viewed very seriously. We remind carriers that the Commission
will consider enforcement action, including forfeitures, should this
obligation not be met.[^9] Further suspensions or waivers of the rule
are not contemplated. In the event that a waiver is requested before the
new deadline, the requesting party will need to demonstrate what steps
it has taken to begin implementing a solution, and explain, in detail,
the exceptional circumstances that make it unable to begin complying
within the time specified.

### 

B.  **[Monitoring Progress]{.underline}**

It is imperative that providers of digital wireless service work
diligently to make their systems compatible with TTY devices. We seek
comment on whether the Commission should adopt additional requirements
that would enable it to better monitor carrier progress toward this
goal. For example, should the Commission require digital wireless
service providers to submit an implementation plan for digital TTY
accessibility? In the alternative, should the Commission reinstate the
requirement that industry report to the Commission on a regular
basis?[^10] Periodic reports might include, but not be limited to,
information regarding problems associated with TTY access to digital
wireless systems, the status of proposed technical solutions, and steps
taken to achieve the proposed technical solutions. We also seek comment
about how the Commission may best monitor the progress of technological
developments and the adoption of standards.

C.  **[Enforcement]{.underline}**

Although Section 20.18(c) imposes obligations on carriers, for carriers
to meet these obligations it is critical that handset and network
manufacturers produce equipment capable of facilitating digital TTY
service at the earliest possible date. We expect carriers and
manufacturers to work together to develop and implement solutions in an
expeditious manner. We note that Section 255(b) of the Communications
Act of 1934 requires manufacturers to ensure that equipment is designed,
developed, and fabricated to be accessible to and usable by individuals
with disabilities, if readily achievable. We also note that Section
251(a)(2) of the Act requires that telecommunications carriers not
install network features, functions, or capabilities that do not comply
with the guidelines and standards established pursuant to Section
255.[^11] We seek comment on how these provisions relate to the
implementation of Section 20.18(c). We also seek comment on whether and
how the Commission might use its equipment authorization process[^12] to
enforce compliance with Section 20.18(c).

> **D. [Consumer Impacts]{.underline}**

We expect carriers to make their digital wireless systems compatible
with TTY devices without causing potential adverse impacts to consumers.
Therefore, we seek comment on whether any of the TTY/digital wireless
compatibility solutions could impose additional costs and/or
inconveniences on consumers and if so, the extent and nature of these
costs and/or inconveniences (*e.g.*, excessive battery-drain, possible
loss of existing service features, possible problems associated with the
use of multi-mode phones, possible problems associated with roaming).
Significantly, an impact such as excessive battery-drain is especially
troubling because many consumers have come to rely on wireless phones
for use in emergency situations. To the extent any additional costs or
inconveniences are identified, we also seek comment on steps carriers
can take to eliminate or mitigate such adverse impacts, especially those
that could affect safety of life.

E.  **[Interim Solutions]{.underline}**

Initially, Ericsson's solution for TTY/GSM compatibility will apparently
involve a "smart cable" that itself operates to convert the Baudot tones
to a new signal that is suited for transfer over a digital voice path
without the need for software changes in the handset.[^13] While
Ericsson ultimately intends to integrate the cable's features into the
handset, it has proposed the external cable as an interim solution
because it could be made available before the cable's features are
integrated into the handset. We seek comment on whether Ericsson's
"smart cable" solution for GSM, or any other similar cable, will be
acceptable to TTY users. We also seek comment on whether this type of
solution will impose additional costs and/or inconveniences on consumers
(*e.g.*, additional battery drain to supply power to the cable).

F.  **[International Implications]{.underline}**

We also seek comment on the impact the international use of the GSM air
interface has on development and implementation of a TTY solution.
Specifically, we seek comment on whether the fact that many of the
standards pertaining to GSM technology are adopted in an international
standards-setting process will affect either the speed with which a TTY
solution can be developed and implemented, or the type of solution that
is adopted.

### III. [Procedural Matters]{.underline}

We remind parties that the Commission has granted waivers to carriers
pending a decision on the implementation date. Those waivers remain in
effect.

Pursuant to Section 1.45 of the Commission's Rules, 47 C.F.R. § 1.45,
interested parties may file comments on the proposed implementation
deadline no later than June 19, 2000. Replies shall be filed no later
than July 19, 2000. All comments shall reference the docket number of
this proceeding. Comments may be filed using the Commission's Electronic
Comment Filing System (ECFS) or by filing paper copies. Comments filed
through the ECFS can be sent as an electronic file via the Internet to
http://www.fcc.gov/e-file/ecfs.html. In completing the transmittal
screen, commenters should include their full name, Postal Service
mailing address, and the docket number of this proceeding. Parties
filing electronically should also e-mail a copy of their comments to
pforster@fcc.gov. Parties who choose to file by paper must file an
original and four copies of each filing with the Commission's Secretary
(Magalie Roman Salas, Office of the Secretary, Federal Communications
Commission, 445 12th Street, SW, Washington, D.C. 20554) and a diskette
copy to the Commission's copy contractor (International Transcription
Service, Inc. (ITS), CY-B400, (202) 857-3800).

Pursuant to Section 1.1206 of the Commission's Rules, 47 C.F.R. §
1.1206, this proceeding is a permit-but-disclose proceeding in which *ex
parte* communications are permitted subject to disclosure.

Copies of this *Public Notice* in alternative formats (computer
diskette, large print, audio- cassette, and Braille) are available to
persons with disabilities by contacting Brian Millin at

\(202\) 418-7426 voice, (202) 418-7365 TTY, or at bmillin@fcc.gov. The
*Public Notice* also will be available at: http://www.fcc.gov/cib/dro/.

For further information regarding this *Public Notice*, contact Patrick
Forster, Wireless Telecommunications Bureau, Policy Division, at (202)
418-1310 voice, or (202) 418-7233 TTY.

\- FCC -

[^1]: Revision of the Commission\'s Rules To Ensure Compatibility with
    Enhanced 911 Emergency Calling Systems, *Report and Order and
    Further Notice of Proposed Rulemaking*, 11 FCC Rcd 18676 (1996)
    (*E911 First Report and Order*), *recon*., FCC 97-402, 12 FCC Rcd
    22665 (1997) (*E911 Reconsideration Order*), *further recon.
    pending*.

[^2]: 47 C.F.R. § 20.18(c).

[^3]: *See E911 Reconsideration Order*, 12 FCC Rcd 22695 (para. 59)
    (suspending enforcement of TTY requirement until October 1, 1998*)*;
    Revision of the Commission's Rules to Ensure Compatibility with
    Enhanced 911 Emergency Calling Systems, 13 FCC Rcd 21746 (para. 8)
    (1998) (Wireless Telecommunications Bureau Order extending
    suspension through November 15, 1998); Revision of the Commission's
    Rules to Ensure Compatibility with Enhanced 911 Emergency Calling
    System*s*, 14 FCC Rcd 694 (para. 10) (1998) (Wireless
    Telecommunications Bureau Order extending suspension through
    December 31, 1998) (*November 1998 TTY Order*).

[^4]: Revision of the Commission's Rules To Ensure Compatibility with
    Enhanced 911 Emergency Calling Systems,

    CC Docket No. 94-102, *Order*, 14 FCC Rcd 1700 (1998) (*TTY Waiver
    Order*).

[^5]: The Bureau released a Public Notice on May 13, 1999, announcing
    that, in light of the recent progress made toward addressing the
    TTY/digital compatibility problem, it would delay action on the
    temporary waivers that were granted to car­ri­ers in December 1998,
    pending assessment of the Lucent solution and any other new
    solutions.

[^6]: ^?^ *See* Report of the T1P1.5 TTY ad hoc presented at the April
    5, 2000, Wireless TTY Forum meeting at 8-9.

[^7]: ^?^ *See* TTY Forum Technical Status Report, November 12, 1999, at
    14.

[^8]: *See* "Bell Atlantic Mobile and Lucent Technologies Collaborate on
    First-Ever Digital Cellular Service for Hearing and Speech
    Impaired", Press Release, January 26, 2000. This document is
    available at http://www.bam.com/news2000/01_26_00.htm.

[^9]: *See* 47 U.S.C. § 503(b).

[^10]: *See E911 Reconsideration Order*, 12 FCC Rcd 22695 (para. 63)
    (establishing quarterly reporting requirements that ended September
    30, 1998).

[^11]: *See* 47 U.S.C. § 251(a)(2).

[^12]: *See* 47 C.F.R. § 2.901.

[^13]: ^?^ *See* "Signal Adaptation Module (SAM) for Robust TTY
    Transmission, and Signaling" (Ericsson presentation at the April 5,
    2000, Wireless TTY Forum meeting) at 3-4.