Allow Flexibility in RTT, CTA Tells FCC; NCTA Seeks Wireline Deferral

avoid adopting overbroad regulations that could limit the development of assistive technologies like RTT or inadvertently extend requirements to products that are not intended for voice communications,” CTA said. “The Commission should modify its proposal so that manufacturers have the flexibility to bring the most innovative and effective communications solutions to users who are deaf or have hearing or speech impairments.” NCTA said the FCC should move forward on RTT rules for wireless networks, but defer addressing wireline. “Wireline voice networks and devices have a rapidly declining user base, they generally are not designed to support text-based communications and, except for TTY services, are not used to provide text-based communications,” NCTA said. “Operational challenges of implementing RTT on VoIP systems are potentially significant.” The FCC proposal “poses significant jurisdictional questions” for the California Public Utilities Commission, said CPUC staff in a memo to be considered at the state commission’s Thursday meeting. The staff urged the CPUC to comment on the FCC NPRM. “Because the existing TTY program is analog-based, it falls squarely within the CPUC’s jurisdiction over services that are not IP based or that are purely intrastate,” the CPUC staff said. But the CPUC lacks authority over IP services, except when required or expressly delegated by federal law, it said. “If the FCC determines that RTT is a purely interstate service, the CPUC would be barred from regulating it because the FCC has exclusive jurisdiction over interstate telecommunications services.” If barred from regulating RTT, the CPUC’s Deaf and Disabled Telecommunications Program (DDTP) relay service “likely would have to be terminated at some point in the future,” it said. Also, RTT should be interoperable with analog-based TTY, the CPUC staff said. “Because the DDTP’s relay service is analog-based, and its equipment is imperfectly compatible with IP-based service, existing users of the DDTP’s TTY equipment will be significantly degraded in the event of an abrupt shift to real-time text technology.” The staff objected to a sunset date for TTYs because it said the number of existing TTY customers participating in the DDTP is declining. Instead, the compatibility requirement should remain as long the analog phone system is in place, it said. Comments are due July 11 -- before the CPUC meeting -- but the CPUC can file replies by July 25.