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, 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.  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.  The Commission later
granted over 100 temporary waivers of the rule, which remain pending, while the industry worked
on a solution.

     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.
The 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. 
Currently, Motorola is working on a TTY/digital solution for its proprietary iDEN technology.

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.  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.  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
     
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?  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
           
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.  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 to enforce
compliance with Section 20.18(c).
    
     D.  Consumer Impacts
     
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
     
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.  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
     
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

     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. 




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