Federal Communications Commission 
Before the 
Federal Communications Commission 
Washington, D.C. 
In the Matter of 
Revision of the Commission's Rules 
To Ensure Compatibility with 
Enhanced 911 Emergency 
Calling Systems 
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ORDER 
CC Docket No. 94-102 
RM-8143 
Adopted: November 13, 1998; Released: November 13, 1998 
By the Chief, Wireless Telecommunications Bureau: 
I. INTRODUCTION 
DA 98-2323 
1. The Wireless Telecommunications Bureau (Bureau) is authorized to extend through 
December 31, 1998, the suspension of enforcement of Section 20.18( c) of the Commission's Rules, 1 as 
that section relates to the transmission of 911 calls made from TIY devices using digital wireless 
systems. In an Order released on September 30, 1998, the Bureau extended this suspension through 
November 15, 1998.2 
2. On October 30, 1998, the Cellular Telecommunications Industry Association (CTIA) and 
the Personal Communications Industry Association (PCIA) requested, on behalf of their members, that 
the Bureau continue suspension of enforcement of Section 20.18(c) beyond the scheduled November 
15, 1998, termination date.3 In the October 30 filing, CTIA also submitted the Workplan of the 
Wireless TIY Forum (Forum). The October 30 Workplan identifies possible solutions for TIY access 
over digital wireless systems. 
3. In this Order, we hereby (1) extend the suspension of enforcement of Section 20.18(c) 
through December 31, 1998; (2) encourage and support further efforts of the Forum to work toward 
1 47 C.F.R. § 20.18(c). 
2 Revision of the Commission's Rules To Ensure Compatibility with Enhanced 911 Emergency Calling 
Systems, CC Docket No. 94-102, Order, DA 98-1982 (Wireless Telecom. Bur.), released Sept. 30, 1998 
(September 30 Order). 
3 Joint Comments of the Cellular Telecommunications Industry Association and Personal Communications 
Industry Association at 3. 
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measures to ensure expeditious compliance with the Commission's rules; and (3) establish procedures 
under which wireless carriers subject to the requirements of Section 20.18(c) may petition the 
Commission, not later than December 4, 1998, for waivers of such requirements, which, if granted, 
will take effect on January 1, 1999, after the suspension of enforcement expires. 
4. We are establishing a waiver mechanism that requires carriers to provide specific 
information (including well-documented timetables and milestones) regarding their plans to comply 
with the requirements of Sectfon 20.18(c). We take this action because persons with disabilities who 
rely on TTY devices must be able to use 911 in emergencies, when lives may depend on effective 
communication with public safety personnel. That is why the Americans with Disabilities Act requires 
non-discriminatory access to State and local government services such as 911 for people with speech 
or hearing disabilities. 
II. WIRELESS TTY FORUM ACTIVITIES 
5. Although the October 30 Workplan suggests that carriers operating digital wireless systems 
will not be able to bring themselves into compliance with the requirements of Section 20.18(c) in the 
near future,4 the Bureau is cognizant of the fact that the Forum has striven to develop voice-based and 
data-based solutions to the problems associated with successfully transmitting TTY calls over such 
systems. 
6. The Bureau also believes that the Forum should be encouraged to continue its efforts, since 
it has the opportunity to serve as a vehicle to spur further discussion and analysis of possible solutions. 
For example, we believe that the Forum should continue the task of providing test results and 
demonstrations on several potential methods for dealing with incompatibility between TTY devices 
and the different digital wireless technologies.5 Completion of this testing and the provision of an 
evaluation of the test results by the Forum to the Commission will play a role in the Commission's 
determination of the best means to accomplish compliance with the requirements of Section 20.18( c ). 
ID. PETITIONS FOR WAIVER 
7. As we have noted above, the Bureau is appreciative of the efforts of the Forum in 
examining the technical problems associated with transmitting TTY information over digital wireless 
networks and developing various approaches to solving these problems. We cannot ignore the fact, 
however, that, despite the efforts of the Forum, users of TTY devices will not be able to operate such 
devices in conjunction with digital phones at any time in the near future. 
8. We reach this conclusion based upon our view that the Forum, while it serves as an 
excellent colloquium for individuals representing the wireless industry (carriers and manufacturers), 
4 For example, the Workplan appears to indicate that the estimated time for implementation of a data-based 
solution is between 12 and 18 months. See October 30 Workplan, Appendix C. 
5 See October 30 Workplan at 2. 
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manufacturers of TTY equipment, emergency and relay service providers, and consumer organizations 
that represent individuals who are deaf or hard-of-hearing to meet, exchange ideas, and attempt to 
develop solutions, the Forum is not designed or intended to be an organization that can enforce or 
impose upon carriers any commitment to implement a solution. 
9. As we have described, the Commission has adopted a rule requiring carriers to enable use 
of TTY devices over digital wireless systems, but has suspended enforcement of that rule. Because of 
the significant benefits the requirements established in Section 20.18(c) will provide to individuals who 
are deaf, hard-of-hearing, or who have speech disabilities, we believe that additional action is 
necessary to promote the development of solutions leading to compliance with these requirements. 
10. We conclude, therefore, that a useful step at this juncture, for purposes of continuing the 
process of achieving carrier compliance, is for the Commission to require the carriers to demonstrate 
their commitment to, and plans for, complying with Section 20.18(c). Thus, in addition to extending 
the suspension of enforcement of the rule through December 31, 1998, we are also establishing the 
following procedures and providing the following guidance to carriers who would seek waiver of 
Section 20.18(c) as of January 1, 1999. 
11. Petitions for waiver shall specify with sufficient particularity the following: 
(1) What steps the carrier is taking or intends to take to provide users of TTY devices with the 
capability to operate such devices in conjunction with digital wireless phones. 
(2) When the carrier intends to make this capability available to TTY users. This information 
should include well-documented timetables and milestones from the carrier regarding the 
implementation of this capability. 
(3) What reasonable steps the carrier will take to address the consumer concerns referenced in 
the September 30 Order.6 
To maintain any such waiver, carriers will then be required to file submissions every three months, 
beginning on the date of the waiver grant, indicating progress they are making toward implementation 
of TTY/digital capability. We will evaluate these submissions to determine if the carrier's waiver shall 
remain in effect. 
12. In the case of any carrier seeking a waiver that would become effective on January 1, 
1999, such carrier shall file a petition for waiver with the Commission on or before December 4, 1998. 
6 See September 30 Order at para. 9 & Appendix. 
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