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TDI Workshop "Digital Wireless HA and TTY Compatibility"

The compatibility of digital wireless phones with TTYs and hearing aids was an ongoing theme during the entire convention. This workshop featured the following panel members:
- Judy Harkins, PhD, Professor of Communications Studies, Gallaudet University
- Pamela Holmes, Director of Consumer and Regulatory Affairs, Ultratec
- Susan Palmer, Associate Director of Regulatory Affairs, Cingular Wireless
- Karen Peltz-Strauss, Deputy Chief, Consumer Information Bureau, FCC

Judy Harkins introduced the workshop by noting that efforts to achieve hearing aid compatibility started in 1995, and efforts to achieve TTY compatibility began in 1997. The problems are not yet resolved, and digital wireless remains less accessible than analog. Hearing aids may buzz when placed near a digital phone, and TTY text may become garbled. These situations are especially troubling given that analog service is obsolete, and the number of analog providers is decreasing. The FCC is considering allowing service providers to retire analog service; it is more expensive than digital and offers fewer features, but it does offer good coverage.

A consortium of industry, consumer, and government representatives called the TTY Forum has been working the TTY compatibility issue for five years. The original FCC deadline for TTY compatibility was 1997, but industry objections resulted in delays to that date. The current deadline is June 30, 2002, at which time handsets, network, and cables must all support TTY service. Affected companies are filing regular reports, and they expect to make the deadline. However, this doesn't mean that everything is perfect or uniform. Different service providers are offering different services, turbocode won't work with the digital systems, and it's not clear how voice carry over (VCO) will work.

Hearing Aid compatibility is a very different issue. There is currently no deadline, because compatibility between digital wireless phones and hearing aids is not readily achievable. (Section 255 exempts manufacturers and service providers from compatibility that is not readily achievable.)

The problem is that digital wireless transmission often causes hearing aids to buzz. One way to resolve this is to get the phone away from the aid, and some success has been reported for "hands free" accessories that allow the phone to be some distance from a person's head (and therefore, the aid). In addition testing standards are being developed to measure phone emissions and hearing aid susceptibility. These standards won't do anything to improve compatibility, but they should provide a basis for estimating how much interference will exist between a particular phone and a particular hearing aid. Judy mentioned one user who reported that the Samsung 3500 on Sprint PCS seems to work pretty well.

Karen Peltz-Strauss mentioned that one of the motivations for TTY compatibility is the pending E911 requirement, which mandates that wireless phones used for 911 calls must provide the location of the caller. The rule specifies that TTY access is a part of this requirement. Note that this is an absolute requirement, vice the "if readily achievable" exemption of Section 255.

The Hearing Aid Compatibility Act of 1988, which requires wired phones to be hearing aid compatible, exempted mobile phones and private radio. Congress also directed the FCC to periodically review the exemptions of wireless phones. They should review the exemptions every five years, but they haven't yet eliminated the exemption.

In 1995, a wireless coalition asked the FCC to review the exemptions; wireless technology was in its infancy at the time, and the FCC was concerned that requiring hearing aid compatibility would delay development of wireless technology, so the exemptions continued.

Last year, the FCC was asked to eliminate the exemption. The FCC considers four factors in making its decision.
a. Is the revocation in the public interest?
b. Will continuing the exemption have an adverse affect on people with hearing loss?
c. Is it technically feasible?
d. Will eliminating the exemption increase the cost so much that the service will no longer be affordable?

The Hearing Aid Compatibility Act requires that the compatibility mechanism be INTERNAL, and that no extra purchase be required. There hasn't been much progress on hearing aid compatibility for many years, and that has caused a lot of frustration in the hearing loss community. The FCC is currently trying to start a dialog among the wireless industry, hearing aid manufacturers, and consumers to get a solution working. There is no Notice of Proposed Rulemaking yet.

Audience Comment: Phones with flip tops reduce interference substantially, because they move the transmitter away from the hearing aid. It's great that people are working on tests to measure interference, but the FCC really needs to push to reduce the interference, not measure it.

Q: - Does the Hearing Aid Compatibility Act apply to equipment manufacturers or service providers?
A: equipment manufacturers

Comment: Development of the interference test standards is not enough, but it is a good step. Testing drives solutions, because published results will cause competition among the equipment manufacturers.

Susan Palmer noted that achieving TTY compatibility was a long process and that consumers played a vital role. Teamwork on TTY Forum and FCC encouragement were the real motivations for progress. The biggest problem was people's attitudes; once people started working on solutions rather than attitudes, progress happened. It's important to have a list of the things that need to be done. Being required to achieve TTY compatibility was also a big motivating factor.

The solution to the hearing aid compatibility issue will not be as simple as the TTY compatibility issue, partly because hearing aids aren't nearly as uniform as TTYs. But some of the same attitudes and cooperation that helped achieve TTY compatibility need to be applied to hearing aid compatibility.

Pamela Holmes advocated a huge education effort of everyone concerned. She also cautioned that the service providers must be certain that the required equipment is available. Organizations like TDI can play an invaluable role by providing reinforcement on the positive things they see happening. The key to resolving these issues is to ensure that everyone is interacting, and to stay as positive as possible.

Pamela pointed out that the Compact/C and EZcom Pro/C facilitate connection to a wireless phone by providing an audio jack and 2.5 mm connection cable. She also stated that the Ultratec website has a wealth of good technical information, and is a great place to learn about these issues.

Q: Some foreign countries are ahead of us in wireless phones. How are they dealing with these questions?
A: Europe has data services built into cell phones. In some countries, the protocols are the ones that their TTYs use, so the TTYs are already compatible. Otherwise, they don't worry about it. Also IM is very popular there. In hearing aid compatibility, the US is the most proactive. In some countries, the government provides hearing aids, so they are focusing on improving the hearing aids. The best long-term answer is to accommodate TTYs in data services, but for now, we must accommodate them in the voice system.

Q: 6 months ago, Kyocera had plans to make a wireless phone with an integrated TTY. What is the requirement that TTYs be built in?
A. There is no mandate for internal TTY access. Hearing aid compatibility with wired phone doesn't change the phone much, so that compatibility must be internal. However, incorporating a TTY would require the addition of a keyboard, so the TTY does not have to be built in. Also, regarding the Kyocera announcement, it was really an announcement of TTY compatibility in chip, which is very different from an integrated TTY.