ADA/TTY Requirements

excerpt from APCO Bulletin article appearing February, 1997 issue, provided by Marj Williams, 206-388-3886

The following is a summary of APCO International ADA Committee Chair Toni Dunne’s TDD/TTY accessibility checklist. See the entire article in the February, 1997 APCO Bulletin.

Self Evaluation Checklist (Title II, Sec. 35.105)

  • Have current services, policies and practices (and their effects), been evaluated to determine if they meet the requirements, and if so, have necessary modifications been made?
  • Have individuals with disabilities or organizations representing them participated in the evaluation process by submitting comments?
  • Has the agency given information to apprise affected individuals of the ADA’s protections against discrimination and applicability to the services of the agency?
  • Does the agency employing 50 or more have a grievance procedure that provides for prompt and equitable resolution of ADA-related complaints?
  • Does the agency provide the same level of service (including ANI/ALI) to all citizens including those using a TDD/TTY?
  • Is there an alternate method of receiving emergency calls from TDD/TTY callers in the event of a failure?
  • Are all workstations that receive emergency calls equipped with TDD/TTY equipment?
  • Is TDD/TTY equipment included in the redundancy plan?
  • Does equipment and methods for transferring emergency calls to other emergency services include TDD/TTY accessible equipment?
  • If an automatic call distribution (ACD) system is used, is there an automatic recording that includes a TDD/TTY recorded message?
  • Does equipment upgrade and expansion plans include TDD/TTY accessibility?
  • Does recording equipment include the point of answer for TDD/TTY equipment?
  • Are TDD/TTYs located where the calltaker can switch from voice mode to TDD/TTY without causing delay in answer time?
  • Can voice carry-over and hearing carry-over calls be handled with the current system?
  • If the TDD/TTY equipment includes preprogrammed messages, have individuals with hearing impairments been consulted regarding the appropriate language?
  • Has the agency explored feasibility of TDD/TTY detection equipment?
  • Does the agency have the capability of providing TDD/TTY users with access to alternative non-emergency numbers?
  • Can the calltaker make a callback using TDD/TTY equipment?
  • Is there a maintenance plan in place for TDD/TTY equipment and procedures? If so, is documentation included?
  • Has the agency developed and implemented standard operating procedures for responding to TDD/TTY calls? If so, has the SOPs been disseminated to calltaking personnel?
  • Do secondary PSAPs have TDD/TTY capability?
  • Is the standard answering time for voice calls comparable to TDD/TTY calls?
  • Do callback procedures include contingencies for reaching TDD/TTY callers?
  • Does the agency keep statistics of TDD/TTY calls?
  • Are there procedures for handling calls from telecommunications relay services (TRS)?
  • If voice calls are transferred to fire or EMS providers, are TDD/TTY calls included?
  • Has the agency developed procedures for handling silent (open line) calls and is TDD/TTY interrogation included?
  • Is a program in place to test the TDD/TTY with the overall system?
  • Does the training program include a comprehensive TDD/TTY training requirement and is training given to all calltakers?
  • Are refresher courses given a minimum of every six months?
  • Is someone assigned to follow technological developments and apply innovations into the training program?
  • Have members of the disability community been consulted in the evaluation process including the creation of SOPs and training?
  • Has a public awareness program been implemented to notify TDD/TTY users of the department’s accessibility and services?
  • Does the telephone directory indicate direct access to telephone emergency services for TDD/TTY users?


Wireless Update

submitted by Jane Bissonnette, 206-674-1030


The annual Telco Vendor conference was held March 2 through March 5 in Orlando, FL. Ursula Davis and I co-chaired the wireless track. Please call me if you’d like the complete track report. Here is a synopsis of the final track report:

The primary goals of the three-day session were:

  • Revisit JEM features for submission to TR45.2
  • Wireless E9-1-1 information model
    • Discussion for contribution to NENA and TR45.2
  • Other issues from the floor

 The first bullet refers to the need to update the feature request list that was developed at a Joint Experts Meeting (JEM) in 1994 and forward the new list to the wireless committee that is developing standards for wireless 9-1-1 (TR45.2). This objective was completed and the new list will be forwarded to that committee in May for them to take under advisement as a guideline in their future work.

 The second bullet was completed. The purpose of this model is to submit a recommendation to the wireless standard committees of functional requirements that will meet the specific technical interface needs of the public safety community in meeting Phase II of the FCC mandate. This report, as a work in progress, is currently being circulated among the National NENA Technical Subcommittee.

 The third bullet refers to the variety of issues that are still outstanding regarding wireless E9-1-1. Some of these issues were referred to other committees within NENA. The specific issues that require further study include:

Forwarded to Other Committees

  • How is (x,y) displayed/data stream for map display – forward to the CPE and Network committees.
  • Wireless Local Loop – This issue addresses wireless competitive dial tone providers. This issue should be sent to the Network committee for review.
  • Wireless PBX – This issue should be sent to the ALEC/PBX Committee for review.
  • Performance Requirements with rules and obligations! Grade of service considerations does NENA want to dictate performance requirements for 9-1-1, carriers, including wireless providers? The committee wil1 bring this issue to NENA and then to CTIA if appropriate.

Work in Progress for Wireless Committee

  • Marriage of wireless call-information to location information when systems are not integrated.
  • What are data elements to share on wireless call (WALI) – The Geo-Reference standard provides location elements, but we need to add subscriber information.
  • Migration paths from today to P. 1 to P.2 with multiple providers.
  • Matrix of methodologies defining different network elements and their compatibility or incompatibility (protocol compatibility chart) Work in progress for Wireless Committee and Protocol Committee
  • Congestion control.
  • Wireless selective Routing within area with multiple Selective Routers.
  • Call associated signaling enhancements – define what minimal set of information to support the basic FCC ruling.
  • Third Party service providers/data to the PSAP.
  • MSC requirements that may differ by PSAP within a single coverage area.
  • Administration of pANI. What will the format for this number be? Who will maintain it?
  • Subscriber (handset, device) originated information.


Number Portability Update

submitted by Doug Gehrke, 206-224-1127

FCC Number Portability Rule

In accordance with the Telecommunications Act of 1996, the FCC ordered all local telephone companies to begin the phased deployment of a number portability method in the largest 100 Metropolitan Statistical Areas (MSAs) by October 1,1997. The Seattle, Tacoma and Portland MSAs are included in this first phase. Other areas would be converted after December 31, 1998 based on a request basis.

The FCC did not mandate a particular technology for number portability. Rather, it established nine performance criteria that a long-term method must meet. The FCC found that only one method, Location Routing Number, appears to meet all the criteria. The method will be tested in the Chicago area during 1997. The FCC also found that regionally deployed databases administered by a neutral third party would be the preferred architecture. The FCC directed the North American Numbering Council (they allocated telephone numbers to telephone companies) to select the regional data administrators.

The FCC also required that until permanent number portability is in place, incumbent carriers must provide services to new entrants that simulate number portability like remote call forwarding (RCF). The FCC has not decided how permanent number portability should be paid for, and has left it to the states to determine the precise form of cost recovery for implementing interim number portability. On November 15, 1996, U S WEST filed suit in federal court claiming the interim number portability rules are an unconstitutional “taking” of property in violation of the Fifth Amendment.

State Number Portability Issues

In October 1995, the WUTC ordered U S WEST and GTE to provide interim number portability using existing services and to review options for permanent number portability. In November 1996, the WUTC accepted an industry report calling for working teams to deal with implementation issues. The WUTC endorsed the report’s recommendation that Washington should join the Western Region Telephone Number Portability database operating under the initiative of the Colorado Public Utility Commission.

9-1-1 Issues

Using Remote Call Forwarding (RCF) as the interim number portability method causes problems for the 9-1-1 operators because the number that ANI displays when 9-1-1 is dialed is not the remote call forwarding number, but rather the number of the line that the RCF number actually “forwards to”. Frequently this is a “secret” number that the caller is unaware of. Confusion is almost always a potential problem in this situation. All problems will not go away with a permanent number portability method. For instance, a prefix could be owned by several companies, so knowing which company to contact for assistance will be a problem. The NENA Database and PSAP equipment subcommittees are developing standards to include fields in the display that will provide the name of the company providing that particular telephone number and perhaps other information.

Number portability, like cellular service before it, provides certain benefits for society that pushes its deployment before all the “bugs” have been worked out. The “bugs” always seem to include how 9-1-1 will interface with the new service. At least with number portability, the 9-1-1 community has had some advance warning and groups like NENA are working to minimize the adverse impact to 9-1-1.