Name
Company
Address
State & Zip

Dear:

In the E911 First Report and Order, the Commission adopted rules requiring wireless carriers to ensure that TTY users can access E911 services over wireless telecommunications systems.⁽¹⁾ I am writing to urge you to devote the resources necessary to bring your company into compliance with these rules.

The Commission recognized potential technical challenges associated with supporting TTY signaling over wireless systems in the E911 First Report and Order, and therefore delayed the implementation date of the TTY/E911 compatibility requirements from October 1, 1996, to October 1, 1997. In petitions for reconsideration of the E911 First Report and Order, carriers requested additional time to meet the TTY requirements using digital systems. In the E911 Reconsideration Order, the Commission suspended enforcement of the TTY/E911 compatibility rules for digital wireless systems until October 1, 1998.⁽²⁾ More recently, the Wireless Telecommunications Bureau, on September 30, 1998, provided another extension of the deadline for compliance with TTY/E911 compatibility requirements -- this time, to November 15, 1998.⁽³⁾

It is my understanding that, since September 1997, the Wireless TTY Forum -- a committee consisting of wireless carriers and equipment manufacturers, manufacturers of TTY equipment, emergency and relay service providers, and consumer organizations representing individuals who are deaf or hard-of hearing -- has met on eight occasions in an effort to develop solutions that will enable TTY users to make 911 calls on digital networks. Although members of the Wireless TTY Forum have assured me that the Forum has made some progress toward achieving this goal, the Forum has been unable to adopt any solutions that will allow TTY users to call 911 using digital wireless systems.

I recognize that there may be technical hurdles to overcome in achieving TTY compatibility with digital wireless phones. I firmly believe, however, that this is a critical undertaking, because no segment of our community should be disadvantaged or left behind when it comes to telecommunications and emergency services. Individuals who are deaf or hard-of-hearing or who have speech disabilities must be provided with the same wireless technologies available to other Americans so that they may share in the benefits of these technologies and live safer, healthier lives.

Commission staff have met with representatives from the wireless industry to stress the importance of this matter. I am writing to reinforce that message and to personally request that you take whatever actions are necessary to ensure compliance with the Commission's TTY/E911 rules. I would also like to emphasize that, in my opinion, any future suspension of the enforcement of our TTY rules will likely depend on carriers providing evidence and assurance that a TTY/E911 compatibility solution that meets the needs of consumers can and will be implemented within the shortest feasible time.

Sincerely,

William E. Kennard
Chairman

1. Section 20.18(c) of the Commission's Rules, 47 C.F.R. § 20.18(c), adopted in Revision of the Commission's Rules To Ensure Compatibility with Enhanced 911 Emergency Calling Systems, Report and Order and Further Notice of Proposed Rulemaking, 11 FCC Rcd 18676 (1996) (E911 First Report and Order).

2. Revision of the Commission's Rules To Ensure Compatibility with Enhanced 911 Emergency Calling Systems, Memorandum Opinion and Order, 12 FCC Rcd 22665 (1997) (E911 Reconsideration Order). In the E911 Reconsideration Order, the Commission also delegated to the Wireless Telecommunications Bureau the authority to grant up to a three-month extension of the October 1, 1998, deadline.

3. Revision of the Commission's Rules To Ensure Compatibility with Enhanced 911 Emergency Calling Systems, Order, DA 98-1982, released Sept. 30, 1998 (Extension Order).