NENA Raises Public Safety Concerns on Real-Time Text Transition
The National Emergency Number Association said the transition from text telephone (TTY) to real-time text (RTT) technology is critical, but the FCC should take into account concerns of 911 call centers. NENA recommended a phased rollout to address public safety concerns. Industry'smajor concern has been that the FCC not micromanage how carriers deploy RTT, but NENA raised another matter (see 1607260020).
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“Because many Public Safety Answering Points (PSAPs) may not be able to accept native RTT in the very short term, TTY-RTT compatibility and inter-carrier RTT interoperability” must be tested before a nationwide rollout can proceed, NENA said in reply comments in docket 16-145. NENA cited "the potential for technical and operational difficulties with such a large rollout,” urging a cautious approach. “Because immediate, error-free adoption of RTT is unlikely, it is vitally important that RTT and TTY interoperate while users and 9-1-1 services switch over to full end-to-end RTT,” NENA said.
NENA also recommended the FCC require all standard wireless handsets be RTT-ready by a date certain. “Thus, NENA agrees with other commenters that handsets need not require both RTT and TTY support within the same device,” the company said.
Groups representing the deaf and hard of hearing took umbrage with Sorenson arguments that providers of video relay services or IP captioned telephone relay services shouldn’t be required to incorporate RTT into their terminal equipment and applications. “While Consumer Groups agree that RTT should not serve as a replacement for TRS [telecommunications relay services], Consumer Groups strongly believe that the effective integration of RTT into TRS is essential to RTT’s widespread accessibility and larger integration into the mainstream telecommunications ecosystem,” they said.
The consumer groups also disputed wireless industry arguments the FCC shouldn’t impose standards. An interoperability standard is key to demonstrate “that RTT is sufficiently ‘reliable and compatible’ so as to qualify as a format that should receive direct access to 911,” the groups said. “If the Commission allows the use of performance standards, as opposed to a baseline interoperability safe harbor standard, this reliability and compatibility will be more difficult to prove, and RTT will run the risk of not receiving direct access to 911.” Telecommunications for the Deaf and Hard of Hearing, the Association of Late-Deafened Adults, Cerebral Palsy and Deaf Organization, Hearing Loss Association of America, Deaf Seniors of America and the National Association of the Deaf signed the filing.
T-Mobile encouraged the FCC to be realistic in its expectations. “Operational RTT is dependent not only upon network readiness, but also on the availability of RTT-capable handsets,” the carrier said. “An obligation to implement prior to the availability of widespread RTT-capable handsets could be viewed as the equivalent of a mandate to deploy via an OTT [over-the-top] solution and would be arbitrary and capricious.”
The FCC should clarify it doesn't intend to extend RTT requirements to all interconnected and non-interconnected VoIP services and applications, Microsoft said in reply comments. “As this proceeding moves forward, we ask that the Commission make clear which services, applications and devices are covered by its rules,” Microsoft said. “Clarity and legal certainty will assist industry in efficiently tailoring its offerings and will provide necessary guidance to consumers about what offerings they can expect to support RTT.”