FCC Grants AT&T Waiver of TTY Rules in IP Environment

The Commission released an Order granting AT&T a temporary, limited waiver of the Commission’s requirements to support text telephony (TTY) technology on wireless networks to the extent that they use Internet Protocol (IP) technologies.  This waiver expires December 31, 2017, or upon the effective date of rules providing for alternative IP-based wireless accessibility solutions, whichever is earlier.

On June 12, 2015, simultaneous with its waiver petition, AT&T filed a petition requesting that the Commission initiate a rulemaking proceeding to authorize the substitution of a newer form of text communication, real-time text (RTT), as an alternative accessibility solution to TTY technology for use in the IP-based environment.  AT&T stated that the grant of its requested waiver would further the TTY-to-RTT transition by enabling it to focused on deploying IP-based solutions that will hasten the development of RTT.  The Commission found that AT&T demonstrated “good cause” for a waiver, and specifically took the following factors into account:

  • Major technical barriers exist to reliably supporting TTY transmissions over IP networks;
  • General agreement that overall use of TTYs has declined greatly, and that TTYs are seldom used on wireless networks;
  • Granting the waiver would be in keeping with the statutory goal of replacing legacy TTY technology with more effective means of accessing 911;
  • Short-term waiver does not appear likely to impact current TTY capabilities on legacy wireless and wireline networks;
  • Granting the waiver appears likely to create significant long-term benefits for consumers generally because it has the potential to encourage the development and wider deployment of VoIP services.

Conditions:  Because consumers who currently rely on TTY will lose their ability to access next-generation wireless networks via TTY during the waiver, the Commission imposed certain conditions on the grant of the waiver.  First, AT&T is required to apprise its customers within 30 days of the effective date of the Order that (1) TTY technology will not be supported for calls to 911 services over IP-based wireless services; and (2) there are alternative PSTN-based and IP-based accessibility solutions for people with communication disabilities for such calls.  Second, AT&T is required to file a report with the Commission once every six months regarding its progress toward and the status of the availability of new IP-based accessibility solutions, such as RTT.

Scope:  This waiver applies to AT&T, with respect to its IP-based wireless services.  This waiver does not impact or cover requirements for the support of TTY technology for any wireline services or wireless services not offered on an IP network.  While several commenters urged the Commission to apply the waiver to all entities covered under the rules, the Commission will instead consider requests for waivers from “similarly situated providers seeking a similar waiver of the TTY requirements” that include the necessary criteria for waiver relief and commit to complying with the conditions stated in the Order (discussed below).

Waiver Requests:  Any carrier or service provider seeking a waiver should file a request describing the wireless services it provides, explaining the difficulties it has encountered or expects to encounter in providing connectivity to TTY devices over wireless IP networks, stating the extent to which it expects that it will be able to deploy accessible text alternatives to TTY technology by December 31, 2017, and committing to compliance with the reporting requirements and other conditions stated herein.  The Commission expects “to look most favorably upon petitions for waiver that also specify with sufficient particularity the following: (1) What steps the carrier is taking or intends to take to ensure that the accessibility text alternatives that it intends to deploy will be accessible to people with communication disabilities, interoperable with other IP-based wireless text services, and backward compatible with TTYs; and (2) well-documented timetables and milestones regarding the implementation of these capabilities.”  The Commission anticipates that all conditions imposed by this Order with respect to AT&T will also apply to waivers granted to other parties.

Feel free to contact us with any questions.

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