MEMORANDUM

TO: Judy Harkins
Gregg Vanderheiden
RERC on Telecommunications Access
Karen Peltz Strauss
KPS Consulting
Re: Summary of new FCC Proceedings

Over the past two weeks, the Federal Communications Commission released two items that may be of interest to you. Public Notices were released for each of these proceedings, though the items themselves are not yet available on line. This memorandum provides a brief summary of these proceedings.

1. TTY Access to Wireless Services

Public Notice Released: August 27, 2002: Wireless Telecommunications Bureau Seeks Comment On Joint Petition For Reconsideration Regarding Digital Wireless Transmission Of 911 Calls Using TTY Devices (Public Notice DA No. 02-2095)

Docket No 94-102

FCC Contact: Andrea Cunningham at (202) 418-1310; TTY (202) 418-1169
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-02-2095A1.doc

Comments Due: September 26, 2002

Reply Comments Due: October 11, 2002

FCC rules required all digital wireless service providers to be capable of transmitting 911 calls made with TTYs as of June 30, 2002. On June 28, 2002, the Commission released an Order responding to several petitions for waiver of this deadline. An earlier RERC-TA memorandum describes the extent to which the Commission granted these various waiver requests.

On July 27, 2002, the Illinois Valley Cellular RSA 2-I Partnership, the Illinois Valley Cellular RSA 2-II Partnership, and Illinois Valley Cellular RSA 2-III, the Missouri RSA No.7 Limited Partnership (known as Mid Missouri Cellular), and Public Service Cellular, Inc. filed a Joint Petition For Reconsideration of the FCC's June 28^th Order. Although the Commission's June Order had granted the waiver requests of these companies, it had also directed them to implement a TDMA solution by December 31, 2003, in the event that they were still operating a TDMA network at that time.

The Petitioners now argue that the requirement to provide TTY-compatible digital services by December 31, 2003 should be sufficient to ensure access to 911 services by people with hearing disabilities who use TTY devices. They say that it is unnecessary to require a TTY solution in TDMA systems that remain operational after that time. They further argue that the availability of TDMA compliant handsets will be uncertain after December 31, 2003, both because of the phase-out of TDMA technology by large carriers and because of the likelihood that TTY users will purchase TTY-compatible phones using technologies that will continue to be supported.

2. NECA Petition on Cost Recovery for Wireless Services

Released: August 30, 2002: National Exchange Carrier Association Petition For Interim Waiver And Rulemaking Regarding The Cost Recovery For Wireless Telecommunications Relay Service Calls (Public Notice DA No.02-2136)

Docket No 98-67

FCC Contact: Andy Firth 202-418-2694

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-02-2136A1.doc

Comments Due: September 30, 2002

Reply Comments Due: October 15, 2002

The National Exchange Carrier Association, Inc. ("NECA" ) is responsible for administering the Interstate Telecommunications Relay Services (TRS) Fund, which provides cost recovery for all interstate telecommunications relay services. An advisory council to NECA, called the Interstate Telecommunications Relay Service Fund Advisory Council, consists of relay providers, carriers, state relay administrators, and consumers, and provides ongoing advice to NECA on matters of TRS interstate reimbursement. FCC rules generally provide that relay costs associated with interstate calls be recovered from the NECA Interstate TRS Fund (i.e., interstate subscribers) and that costs associated with intrastate calls be recovered from intrastate jurisdictions. One exception to this rule are costs associated with video relay service calls, which are reimbursed entirely through the Interstate Fund.

On July 22, 2002, on behalf of its Advisory Council, NECA filed a petition requesting that the Commission waive, on an interim basis, its cost recovery rules on the jurisdictional separation of interstate and intrastate costs, to allow the Interstate TRS Fund to compensate relay service providers for all TRS calls placed from wireless telecommunications devices. The petition also requests the Commission to conduct a rulemaking to decide how relay calls should be reimbursed when the automatic number identification system is unable to determine the jurisdiction of calls.

This summary was prepared as part of the RERC on Telecommunications Access, a joint project of Gallaudet University and the Trace Center, University of Wisconsin-Madison under funding from the National Institute on Disability and Rehabilitation Research (NIDRR) of the US Dept of Education Grant H133E990006. The opinions offered herein are those of the author and do not necessarily represent those of the RERC on Telecommunications Access, the Universities or funding agencies.

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