A text-calling feature has limited value if it works only inside a closed circle. The FCC's January 23, 2017 rule made interoperability part of the minimum functionality for covered real-time-text services and devices. They had to work with other RTT services and devices, and also with TTYs connected to other networks. That is a connectivity condition, not evidence of a more competitive market. [2017-01377][2017-01382]

The route was optional for covered internet-protocol wireless voice providers substituting RTT for TTY support, subject to the applicable accessibility qualifications. RTT sends text as it is created. Required capabilities included calls using the same telephone numbers as voice, simultaneous two-way text and voice on one device, and communication with U.S. 911 answering points. February 22 was the stated effective date. [2017-01377][2017-01382]

The rule did not order recall or retrofit of devices already in service or manufactured before the relevant compliance dates. This matters to the potential value of backward compatibility: the framework did not assume that all existing equipment would be upgraded at once. It also did not establish what a consumer would pay for a new device or service. [2017-01377][2017-01382]

A companion proposal sought comment on a possible 2021 end to RTT-to-TTY compatibility. The FCC called a final sunset premature without further deployment evidence. Both documents come from one proceeding, not independent assessments. They define a transition that could connect newer and older systems, while leaving actual adoption, switching costs and competitive effects to evidence not supplied here. [2017-01377][2017-01382]

Source documents

  1. Transition From TTY to Real-Time Text Technologyhttps://www.govinfo.gov/content/pkg/FR-2017-01-23/html/2017-01377.htm
  2. Transition From TTY to Real-Time Text Technologyhttps://www.govinfo.gov/content/pkg/FR-2017-01-23/html/2017-01382.htm