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Separate Statement of Commissioner Gloria Tristani

Revision of the FCC's Rules to Ensure Compatibility with Enhanced 911
Emergency Calling Systems, CC Docket 94-102, Memorandum Opinion and Order
December 1, 1997



One of the Commission's mandates under the Communications Act is "promoting the safety of life and property through the use of wire and radio communication." Today, we act on that mandate by assuring that all wireless phone users will have access to 911 emergency services without cumbersome code identification or subscriber validation procedures. In doing so, we recognize that ensuring direct access to 911 services is a public good benefitting all Americans, not simply those placing the call. I note that many wireless carriers have acted in the public interest and already implemented the practice of passing all wireless 911 calls.

At the same time we broaden access to 911, it concerns me that we must delay implementation, for digital systems, of our previously adopted requirement that carriers provide 911 access to customers using TTY or text telephone devices. Wireless telephones have become part of our nation's culture precisely because they are about access -- with mobility, they afford constant communication. This key characteristic also makes the wireless phone uniquely useful as a safety device. Indeed, many wireless subscribers cite safety as the main reason for purchasing a mobile telephone, and public safety organizations have observed that a large and ever-increasing number of 911 calls originate from a wireless telephone. I am concerned that by delaying the requirement of TTY compatibility for digital systems, we effectively deny access to those Americans who are deaf, hard-of-hearing, or who have speech disabilities.

In agreeing to a 12-month delay in these requirements, I am mindful that representatives of consumer groups and the deaf and hard-of-hearing community have joined with industry representatives to request additional time for implementation of the TTY requirement. The technical hindrances to TTY compatibility must be resolved through the cooperative efforts of carriers, consumer groups, TTY users, public safety agencies and equipment manufacturers. While I am pleased that this effort has begun, in the coming months I will be particularly attentive to its progress. I expect these groups will exert their best efforts in assuring that all Americans, equally, have access to the combined benefits of wireless telephony and public safety services.