FCC’s Disability Advisory Committee Urges Move Away From TTY

TTY machines are the cumbersome, typewriter-like devices long used by the deaf and hard of hearing to communicate. Last year, groups representing the deaf, hard of hearing and those with speech impediments supported in comments filed at the FCC (see 1508250063) AT&T's calls for the transition from TTY to RTT as part of the IP transition. AT&T, Cellular South and Verizon have all received temporary waivers from the FCC to use RTT as a substitute for TTY (see 1512210045).

“The deficiencies of TTY technologies have been recognized by various committees and the TTY phase out in favor of more effective and efficient technologies is encouraged by the CVAA [Communications and Video Accessibility Act],” said Zainab Alkebsi, policy counsel to the National Association of the Deaf and chair of DAC’s Technology Transition Subcommittee, who presented the report to the full DAC. “Guidance from the FCC, as part of a rulemaking, is necessary to reflect changing consumer behavior and preferences.”

The rulemaking should explore the “practical and legal questions” raised by the transition to TTY and the impact on consumers with disabilities, service providers and manufacturers, Alkebsi said. The subcommittee recommended that the FCC investigate a number of issues, including the appropriate phaseout period.

The TTY-RTT transition is just one part of the much broader IP transition, said Karen Peltz Strauss, deputy chief of the FCC Consumer and Governmental Affairs Bureau. Strauss said she appreciates the DAC's flagging a number of questions for an NPRM and hopes the full FCC will agree that the questions raised should be asked in the proceeding. The report was not controversial and the DAC approved it on a roll call vote.

The ability of those with disabilities to access N11 numbers, such as 211 for community health and disaster information and 311 for municipal government resources, also emerged as an issue at the meeting. The DAC approved a recommendation by its Emergency Communications Subcommittee that the FCC clarify its Telecommunications Relay Service (TRS) rules and remind TRS providers of their responsibility to handle N11 calls.

Strauss said she found it disturbing that the deaf and hard of hearing don’t have access to some N11 services. “Obviously there’s access to 711, since that’s the relay service and there’s access to 911, but there are questions about … whether not having access to certain phone numbers is functionally equivalent,” she said. The issue is important, but Strauss said her bureau already has a full agenda for this year. “I’m concerned that it may not be on the front burner,” she said. “I would like to pose a challenge” to TRS providers “to come up with solutions on your own to make this happen.” Strauss said there are workarounds for 911 and N11 access should not pose an “insurmountable challenge” for industry.

The DAC also approved a report by its Video Programming Subcommittee on the kinds of questions the FCC should raise if it examines whether to increase video description requirements beyond the current 50 hours per calendar quarter of children's or prime-time programs.

Questions the FCC should ask, if it issues a rulemaking, should seek answers on the extent of current consumer use of video-described programming under the existing rules and whether an increase would introduce any technical or operational problems, according to the report. The FCC also should ask about the financial costs of requiring more video-described programming, the report said. “Since the CVAA instructs the FCC to weigh the cost of additional video described programming against the benefits of the need for such programming, how should the FCC measure the benefits and assess the needs,” the report asks.