FCC Mandates TTY Compatibility for Cell Phones

We have long been reporting our concerns that people who use hearing aids, CIs, ALDs, and TTYs are being excluded from digital cellular networks, and that the emerging dominance of digital service over analog will preclude people with hearing loss from mobile access. However, a recent FCC Report and Order sets deadlines for digital cellular networks to provide TTY compatibility. I don't know if the required technical modifications will provide compatibility with other hearing loss devices, but at least we know that TTYs will work over digital networks.

By the way, some of our readers may have played a part in promoting this order. A few weeks ago we published some of your stories describing the problems you have had with this technology. A reader forwarded these to Pam Holmes, who forwarded them on to the FCC committee. In her email informing me of this order Pam said, "I believe the communications I forwarded from your readers was instrumental in pushing for the final vote on these rules." So congratulations to those of you who spoke up. I'm sure you had no idea as you were writing your stories that they would have such an impact. It renews my faith that an individual can make a difference if she perseveres.

Pam provided the following summary of the contents of the order: "Cellular manufacturers need to have their digital TTY solution completed by December, 2001 and the cellular service providers must have the solution in place with telephone handsets available no later than June 2002. I believe we will see some available before that time."

Those who want to read the entire order will find it on the Disabilities Rights Office's web site at www.fcc.gov/cib/dro/.

And those who prefer a middle ground, please keep reading. I've summarized what I think are the most important or interesting points in the remainder of this article.

The FCC initially required TTY compatibility starting October 1, 1997. Technical difficulties transmitting the TTY's Baudot audio tones caused the FCC to postpone the initial date to December 31, 1998. The FCC has since granted over 100 waivers to this requirement, which is why we have no TTY compatibility to date.

An organization called the Wireless TTY Forum, which represents a broad spectrum of interested parties, has been searching for a solution. In 1999, the TTY Forum recommended a solution proposed by Lucent Technology, and the subcommittees representing two of the digital transmission technologies (CDMA and TDMA) approved that solution. A solution for the GSM protocol has been proposed, and one for the iDEN protocol is in the works.

In light of this progress, the Wireless Telecommunications Bureau released a Public Notice on May 17, 2000, seeking comment on a proposed deadline of December 31, 2001. SBC, Ericsson, and Motorola agree with the proposed deadline, as long as the affected carriers are permitted an additional six months (until June 30, 2002) to deploy and test the solution in their systems. Other carriers argue that the deadline proposed in the Public Notice is infeasible for a variety of reasons.

The current FCC ruling mandates these dates and encourages earlier implementation, if possible. It also dismisses the 104 previously granted waivers on the grounds that they are rendered moot by the technological advances that have occurred in the last few years.

The FCC also expressed its desire to provide a method of monitoring progress. While their stated preference is for direct quarterly progress reports from the carriers and manufacturers, they are allowing reporting through the TTY Forum.

One potential issue with wireless compatibility involves the use of proprietary enhanced communications protocols. You're probably currently using these protocols without knowing it. They provide improved service over analog channels, but may cause problems when employed over digital channels. The FCC is taking no action on this issue in the current ruling, but is directing the industry to investigate and work towards necessary solutions. The FCC may take future action on this issue, if required to implement a solution.

Another issue with some current wireless equipment is its incompatibility with VCO calls. The problem is that plugging the TTY into the audio jack disables the microphone, so that the VCO user's spoken words are not transmitted. This can currently be overcome by unplugging the TTY before speaking and plugging it back in when finished speaking. A "push to talk" button that enables the microphone is one possible solution. The FCC expects manufacturers to resolve this issue.

A third issue with some phones is the inability to simultaneously use the audio jack (to connect a TTY) and the power jack (to plug the phone into the wall for power). The problem is caused by the close proximity of the two jacks, which prevents simultaneous connections. The FCC expects manufacturers to resolve this issue.

The FCC also expressed concern that TTY users may be forced to use more expensive analog service in order to have wireless access, and that they may lose their analog service altogether, as it is phased out in favor of the digital solution. They encouraged carriers who provide both analog and digital service in an area to offer TTY users analog pricing on a par with their local digital pricing, at least until they achieve digital TTY compatibility. They also encouraged carriers who currently provide analog service to continue to make it available to TTY users until a digital replacement is available.