The Wireless RERC submitted reply comments in response to the FCC’s Further Notice of Proposed Rulemaking In the Matter of the Transition from TTY to Real-Time Text Technology [CG Docket No. 16-145]; Petition for Rulemaking to Update Commission’s Rules for Access to Support the transition from TTY to Real-Time Text Technology, and Petition for Waiver of Rules Requiring Support of TTY Technology [GN Docket No. 15-178]. While the reply comments supported transitioning from Teletypewriter (TTY) to Real-Time Text (RTT) technology, we concurred with other stakeholder recommendations that the manner and speed in which it is done take into account those most at risk of losing all text communications access if TTY becomes unavailable. While most people with hearing and speech disabilities have a preference for text or video-based communications, there are still some that rely on TTY to place both emergency and non-emergency calls. For no one to be left behind, it is imperative that the transition process includes collecting data on network support, RTT-capable devices on the market, their accessibility levels, and end-user ownership rates. These data would shed light on both industry deployment rates and user adoption rates, users being both consumers and 911 call centers.
