FCC Grants T-Mobile Petition for Clarification on TTY to RTT Transition
Monday, November 06, 2017 | Comments

The FCC granted a petition from T-Mobile USA asking for clarification on the FCC’s report and order that implemented new rules to facilitate the transition from text telephony (TTY) technology to real-time text (RTT).

Specifically, the FCC clarified that when a commercial mobile radio service (CMRS) provider connects to an emergency services IP network (ESInet) to deliver RTT 9-1-1 calls, the CMRS provider does not need to convert RTT to TTY format. Rather, any conversion from RTT to TTY, or other delivery means, is the responsibility of the ESInet provider.

In its petition, T-Mobile asked for clarification, or as an alternative, reconsideration of the report and order. The FCC dismissed the request for reconsideration as moot following the clarification.

In its petition, T-Mobile asserted that a paragraph in the report and order created uncertainty about the obligations of a provider delivering an RTT call to a legacy public-safety answering point (PSAP) served by an ESInet. T-Mobile said that requiring CMRS providers to provide backward compatibility would shift burdens now borne by PSAPs onto wireless carriers by requiring carriers to support transcoding gateways “to ensure that 9-1-1 calls are delivered to PSAPs via the relevant selective router and, at the same time support TTY (Baudot) media, automatic number identification (ANI) and automatic location identification (ALI).”

In the report and order, the FCC said the components referenced by T-Mobile are “all basic 9-1-1 elements that carriers have been required to provide when transmitting calls from TTYs” and said that “we do not believe that requiring the delivery of RTT 9-1-1 calls with these elements would involve any burden shifting.” T-Mobile argued in its petition that the statement conflicted with the architecture of ESInets and would obligate carriers to take on news responsibilities, as well as impose a new burden that would not be technically feasible.

In clarifying the report and order, the FCC said that particular statement was not intended to create an obligation for CMRS providers to convert 9-1-1 RTT calls to TTY before delivery of such calls to an ESInet. The order establishes a general obligation for providers to ensure that RTT is backward compatible with TTY technology so that RTT users can place and receive calls to and from remaining TTY users, including legacy PSAPs, the FCC said. The discussion of backward compatibility only refers to calls delivered to PSAPs via the relevant selective router and did not address the issue raised by T-Mobile, the FCC added. The FCC also agreed with T-Mobile’s argument that such backward compatibility would not be technically feasible. Find the full clarification here.

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