Telcos Call TRS 711 Emergency Call Rule Too Costly
AT&T and Sprint Nextel urged the FCC to abolish a telecom relay service rule requiring conventional Teletype TRS providers to automatically and immediately call the appropriate public safety answering point when they get a 711 emergency call from an interconnected-VoIP user. In separate comments last week at the FCC, AT&T and Sprint said such users make too few of the calls to justify the costs of building the system needed to comply. But consumer groups said “people with disabilities must have the same access to emergency services as any person without disabilities.”
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The FCC has repeatedly waived the TRS rule, because technology doesn’t allow relay providers to identify the right answering point when they get a 711 call. In April, the Consumer & Governmental Affairs bureau extended the waiver until June 29 and sought comment on “remaining technical, operational, or other issues” preventing conventional TRS providers from correctly routing 711 calls (CD April 3 p13). The bureau also asked how often Teletype is used to make calls though interconnected VoIP, “particularly the incidence of such calls for purposes of obtaining emergency assistance.”
Teletype TRS providers can’t reliably identify the location of VoIP callers because their phone numbers don’t necessarily correspond to their locations, AT&T said. Providing TRS providers access to registered location information could solve the problem, but designing a system to do that would require “more than minimal resources and cooperation from VoIP providers and third parties who administer registered location databases,” it said.
Those costs aren’t justified, AT&T and Sprint said. Most people who are deaf use Internet-based relay services instead of interconnected VoIP, AT&T said. “AT&T VoIP customers completed only 18 [Teletype] calls to 711 in the last year, none of which were emergency calls,” the carrier said. Of the 711 Teletype calls received by AT&T relay centers in the 12 months through March, three in 100,000 were emergency calls, the company said. That’s in part because since 2001 the FCC and relay providers have taught relay customers to dial 911 in emergencies, it said.
Broadband users who can’t hear “are virtually certain to use IP Relay or VRS” rather than Teletype over VoIP, said Sprint, “since they receive such services free of charge whereas they would have to pay for their VoIP service and since the analog-based TTY Baudot tones may be corrupted or suffer degradation when passed through a VoIP provider’s packet-based broadband network.”
The number of TTY users on interconnected VoIP may be small, but it probably will climb as VoIP services become less expensive and more widely available, said the National Association for the Deaf and six other advocacy groups for the hearing impaired. The FCC should make sure that those VoIP users can use TTY in emergencies, they said, saying emergency services “can be reached through TTYs with battery back-ups and interconnected VoIP systems that continue to function for some period of time following a power outage.”
Direct 911 communication may be preferred to 711 emergency dialing because it reduces delays, but there are “undoubtedly” TTY users who will continue to use 711, the consumer groups said. Users may not know direct 911 dialing is possible, or may believe that TTY communication will be understood better by a TRS interpreter than an answering- point operator, they said.
If the commission drops the rule, it should require TRS providers to educate TTY consumers to dial 911 rather than 711 in emergencies, the consumer groups said. The FCC should also start a rulemaking to develop a real-time text standard to replace TTY, they said. “Transmitting TTY tones over the Internet has significant drawbacks, often leaving users with conversations that are garbled or missing information,” it said. An IP-based, real-time system “would allow text communications to be sent directly to PSAPs as part of the next generation 9-1-1 system.”