The Public Safety and Homeland Security Bureau Clarifies RTT Rules

The Public Safety and Homeland Security Bureau (“Bureau”) released an Order granting T-Mobile’s Petition for Clarification, thereby dismissing its Petition for Reconsideration, of the Commission’s RTT Report and Order implementing new rules to facilitate the transition from text telephony (“TTY”) to real time text (“RTT”). The Bureau clarifies that when a CMRS provider connects to an Emergency Services Internet Protocol Network (“ESInet”) to deliver RTT 911 calls, the CMRS provider does not need to convert RTT to TTY format; any conversion from RTT to TTY is the responsibility of the ESInet provider.

Previously, T-Mobile sought clarification or reconsideration with respect to the scope of the obligation for CMRS providers to deliver 911 RTT calls to Public Safety Answering Points (“PSAPs”), pursuant to the Commission’s RTT Report and Order. T-Mobile asserted that the language of the Report and Order created uncertainty about provider obligations and conflicted with industry practice. The Bureau clarifies in this Order that where a CMRS provider delivers RTT 911 calls to a legacy PSAP by a selective router, the CMRS provider is responsible for performing the necessary conversion from IP to circuit-switched format before it delivers the call to the selective router. For RTT 911 calls to a legacy PSAP served by an ESInet, the conversion to circuit-switched format is the responsibility of the ESInet provider.

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