The FCC issued a Public Notice on December 26, 2018 seeking input on a petition from General Motors Holding LLC (“GM”) that requests partial waiver of the interoperability functionalities for accessible real-time text (“RTT”) technology, as defined by the FCC. GM intends to launch an autonomous vehicle (“AV”) ride-hailing service in the near future that will include real time voice communication capability that riders can use to communicate with customer support. GM will also use RTT for such communications and GM seeks to be exempted from certain required RTT interoperability features based on planned limitations of the communications.

Comments on the Public Notice are due by January 25, 2019; and reply comments are due by February 11, 2019.


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01_CFE_12_05_11_NASAThe Federal Communications Commission’s (FCC or the Commission) Notice of Proposed Rulemaking (NPRM) on the transition from text telephone (TTY) to real-time text (RTT) was published in the Federal Register on May 25, 2016, which triggers comment and reply deadlines of July 11 and July 25.  The Commission proposes to amend its rules to replace the obligations of wireless service providers and equipment manufacturers to support TTY technology with obligations that these entities support RTT over IP-based wireless voice services.  The proposal requires RTT to be interoperable across networks and backwards compatible with TTY technology.  The Commission proposes that larger Tier I wireless providers must implement RTT by December 31, 2017, and seeks comment on an appropriate timeline for smaller providers (i.e., non-nationwide carriers).  
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On October 6, the FCC issued an Order granting AT&T a temporary limited waiver of the text telephony (TTY) rules “on wireless networks to the extent that they use Internet Protocol (IP) technologies.”  In June 2015, AT&T had filed a Petition for Rulemaking and a separate request for an interim waiver of the Commission’s disabilities access rules to recognize real-time text (RTT) as an acceptable alternative to TTY technology, but the Order does not specifically address AT&T’s request.  The waiver will expire on December 31, 2017 or when the Commission updates its disabilities access rules to “provid[e] for alternative IP-based wireless accessibility solutions, whichever is earlier.”  The Order states that similar waivers may also be granted to other “similarly situated applicants,” provided that they meet the criteria for a waiver and agree to the same conditions. 

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