Consumer Groups Embrace RTT Rules; Industry Urges Flexibility
Groups representing the deaf and hard of hearing urged the FCC to approve proposed rules forcing a transition from the text telephone (TTY) to real-time text (RTT) technology. Carriers have led the move to RTT, though industry commenters are asking the FCC to provide flexibility in the final rules. An April rulemaking notice sought comment in docket 16-145 (see 1604280055). In earlier comments, groups like CTA sought flexibility in the RTT transition.
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For many years, TTY technology “was the sole means for persons who are deaf, hard of hearing, deaf-blind, and speech disabled and those with additional disabilities to send and receive ‘person-to-person text communications in real-time,’” the consumer groups said. “However, TTY technology experiences reliability and transmission problems on modern, IP-based networks. RTT, a native IP accessibility solution, has emerged as an effective alternative to TTY because it maintains the core function of TTY while also offering advantages in terms of availability, reliability, and improved or additional functionalities.”
The consumer groups urged the FCC to require carriers to implement RTT by Dec. 31, 2017, and proposed a deadline for non-Tier I providers of June 30, 2018. The FCC also should require that handsets and other text-capable end user devices sold after Dec. 31, 2017, have RTT capability and should approve its proposals on interoperability and backward-compatibility. Telecommunications for the Deaf and Hard of Hearing, the Association of Late-Deafened Adults, Cerebral Palsy and Deaf Organization, Hearing Loss Association of America and National Association of the Deaf signed the filing.
CTIA said the commission should adopt “flexible, technology-neutral rules with a phased-in framework of RTT features and capabilities.” The agency should “learn from the wireless TTY experience and avoid adopting rules based on a snapshot of technology that will invariably lead to an outdated mandate,” the group said. CTIA sought some changes to the FCC proposal. The group said it would be an “unnecessary burden” to require providers and manufacturers to support both TTY and RTT capabilities in new wireless equipment. The agency shouldn't declare that a single RTT implementation or standard satisfies its rules, CTIA said. The commission “should not micromanage specific RTT features and functionalities,” the filing said. “These should develop over time, in response to consumer demand.”
The Competitive Carriers Association said non-nationwide providers will need more time than was proposed by the FCC to deploy RTT. “Because of their size and dominance of the technical ecosystem, development of a fully interoperable and backwards-compatible solution will necessarily be driven by the two largest wireless providers who have been driving the equipment ecosystem for RTT functionality,” CCA said. “Tier II and Tier III carriers have less ability to influence the technical ecosystem in which RTT will operate.”
Verizon also said the transition will be difficult. The FCC should “recognize the significant device and network changes necessary and provide flexibility and an appropriate timeline for providers to migrate to any new RTT requirements,” the carrier said. “Rather than create detailed mandates for RTT in its early stages of deployment, the Commission should continue to allow flexibility to substitute RTT for TTY technology.”
“TTY is half-duplex, is inefficient, has a limited character set, and requires a separate assistive device -- all of which are antithetical to cutting-edge wireless technologies,” AT&T said. “TTY is less reliable when used with IP-based wireless networks.” AT&T agreed with the FCC that RTT should be backward compatible with TTY and said larger carriers should be able to meet proposed deadlines. But it also urged flexibility in the rules. “While AT&T supports minimum functionality requirements to ensure that RTT replaces the functions of and allows for an orderly transition from TTY … other features of RTT should be consumer driven,” the carrier said. Any requirement carriers add video to an RTT call session is “especially problematic because it would require development of new user interfaces, triggers significant concerns about capacity in a service provider’s managed networks, and is more likely to increase error rates for RTT transmissions over Wi-Fi or other unmanaged networks,” the company said.
Any requirements on RTT should be “grounded in what is feasible,” T-Mobile said. Rules also should “allow carriers the flexibility to implement and deploy RTT (and any other accessibility solution) in the way that makes the most sense for each carrier, given unique network architectures and relationships with handset manufacturers,” the carrier said.