Inequity In An Emergency

Audrey Fraizer

Audrey Fraizer


Audrey Fraizer

Calling 911 and speaking to an emergency dispatcher is something most take for granted. The emergency dispatcher asks questions, gathers information, and notifies response. The caller follows over-the-phone Pre-Arrival Instructions, when necessary, and the emergency dispatcher optimally stays on the line until fire, police, or medical responders arrive on scene.

Although a simplified description, the process is repeated thousands upon thousands of times each day around the country. It’s also a process that people who are Deaf and hard of hearing cannot take for granted. Despite laws and regulations to make things equal and accessible, emergency communication, in most cases, is not functionally equivalent to those who can hear.

Within the Deaf Community, access to 911 is sorely lacking and generally assumed to be inadequate in light of insufficient funding to update to modern technologies, said Zainab Alkebsi, Policy Counsel, Law and Advocacy Center, National Association of the Deaf (NAD).

“Most 911 call centers have not updated to text-to-911 because local administrative agencies in question have failed to take proper steps to set aside appropriate funds necessary to upgrade the call centers' equipment to handle such technology,” Alkebsi said. “Without these appropriations, Deaf or hard of hearing people lack appropriate access to 911 in many areas. They are unable to communicate in the way of the 21st century.”

The NAD is a national civil rights organization of, by, and for Deaf or hard of hearing individuals that advocates for improving lives through early intervention, education, employment, health care, technology, telecommunications, emergency communications, and youth leadership.

Some headway


In December 2012, the FCC released a proposal requiring all wireless carriers and providers of “interconnected” text messaging applications to support the ability of consumers to send text messages to 911 where PSAPs are also prepared to receive the texts. The proposal included a carrier provision to send automated “bounce back” error messages when a text is sent to a 911 center where the service is not available. In 2014, this proposal was codified into a rule mandating this access.

The numbers of PSAPs ready to receive text-to-911 have grown significantly since 2012, according to the FCC Master PSAP Registry. As of Nov. 15, 2019, there were 2,113 PSAPs listed, up from 189 PSAPs appearing when the FCC started the registry in September 2015.1 In 2015, less than 3% of the nation’s 6,000 public safety answering points had implemented text-to-911; since then, the number of PSAPs using the platform has increased to 30%.2 Six states have 100% population served by NG911 capable services, although at different stages of services offered to the public.3

The lack of text-to-911 is a disservice to the majority of Deaf or hard of hearing people who no longer have TTYs.

“The DOJ is not doing anything to mandate these centers to deploy text-to-911,” Alkebsi said. “Imagine being faced with an emergency and being unable to contact 911. Deaf or hard of hearing people are faced with a stressful, scary event and on top of that, are unable to easily obtain help when needed simply because the authorities have not prioritized accessibility within 911 services.”

Text-to-911 advantages

Indiana is in the unique position of having 100% of its counties using text-to-911.

Primary PSAPS in all 92 Indiana counties have had the ability to receive and send text messages since 2016 and, though not every PSAP jumped immediately on board, the state now tops the nation with the number of text sessions processed by telecommunicators. Thirty secondary PSAPs can send outbound messages after being transferred text sessions from a primary center. In the last 12 months (through November 2019), they exceeded even their expectations with 273,080 text sessions for inbound and outbound text messages combined. PSAPs received 11,181 text sessions in the centers, while telecommunicators initiated 261,599 outbound text sessions because of 911 disconnects.

Text-to-911 was introduced in 2014 to the Indiana Statewide 911 Board, said Ed Reuter, Executive Director. The Statewide 911 Board Office implemented a plan by approaching six counties initially known for their progressive direction in providing emergency communications services.

At first, PSAPs were concerned the text-to-911 system would create extra work and require additional personnel to work within the centers, causing an increase in local budgets. However, as a result of success stories from the inaugural group, agencies from across the state wanted to be a part of this program. Text-to-911 is also second nature to the new generation of telecommunicators who have grown up using cellphones and texting. They’re versed in digital technology.

As Reuter explained, text-to-911 was expanding beyond the board’s original intention to improve services for the deaf and hard of hearing, which it does, but also broadened its appeal to offer vital assistance when voice communication endangered the caller.

The Indiana Statewide 911 Board still recommends “Voice is Best,” with a caller texting when unable to speak or in a position when they cannot talk that could jeopardize their safety. Texting might be the only or last option for a person in danger. Reuter has a catalog of examples of how text-to-911 has provided the best defense for a range of crises: hiding from a kidnapper, hiding from burglars in your home, needing access to a legally protected parking space when someone has illegally parked there, and witnessing a drug deal.

Indiana Statewide 911 Office Deputy Director Laurel Simmermeyer was with the Decatur County (Indiana, USA) Sheriff’s Department for nearly 20 years. As a telecommunicator, she attended her department's annual TTY training, but never did she receive a call requiring a TTY device for a person who was Deaf or hard of hearing.

That did not diminish TTY’s importance, Simmermeyer said. “It was there if we needed it.”

Indiana’s 2,200 dispatchers answer approximately 3.6 million 911 calls per year. They also answer about 12 million additional administrative calls by people who don’t call the emergency 911 line. The Statewide 911 Board provides approximately 40% of the funding for local PSAPs’ operational expenses. User surcharges provide 911 funding from monthly end-user surcharges—$1 for landline, wireless, and other types of phones—which are collected by phone service providers. Indiana continues to explore how to improve the text-to-911 services through real-time text.

At Charleston County Consolidated 911, text-to-911 was introduced in 2015 and while it isn’t used as commonly as voice calls, it is an important tool for 911, said Brittany Gooding, an emergency dispatcher who because of her hearing loss can educate the Deaf Community on what information an emergency dispatcher is looking for in a text message.

“I’m looking for the ‘W’s’: Where the incident is, who is involved, what happened, when it happened, and are there any weapons involved,” Gooding said. “I need to gather these details from a caller to give my responders.”

(See Gooding’s column that complements this story.)


In 2012, ProQA Paramount introduced a feature in which the user can right-click on any question or instruction and an option will appear to “Send SMS” that is passed to the Command and Control system or existing messaging infrastructure. If technology allows it, the caller’s response can be passed to ProQA and appears in a response window. There is also an option to “Send clarifier,” which allows for freeform text exchange to confirm the appropriate response to the answer or next action for the instruction. The Salt Lake City 911 Bureau software incorporates the scripted medical, fire, and police protocol for use in every call and text.

Federal requirements

The 1990 Americans with Disabilities Act (ADA), enacted July 26, 1990, requires public entities to provide an equitable level of service to persons with disabilities, to the same level provided to all other citizens. The Department of Justice (DOJ) has historically interpreted direct and equal access to 911 for individuals with disabilities who use TTY/TDD. Direct access means that PSAPs MUST be able to directly receive TTY calls without relying on outside relay services or third-party services (TPS).

TTY (invented in 1960 and mandated in PSAPs since 1991/1992) pairs an electromechanical typewriter with a communication channel that allows people to communicate through typed messages. Early models were cumbersome and as electronic technology advanced, so did TTY. Digital technology enables computers to talk directly to TTYs through either a landline or cellphone. TTY (TeleTYpe) and TDD (Telecommunications Device for the Deaf) acronyms are used interchangeably to refer to any type of text-based telecommunications equipment used by a person who does not have enough functional hearing to understand speech, even with amplification.

“Back in the day, a handset was plugged into the TTY machine,” said Lisa Burnette, Director, Salt Lake City (Utah, USA) 911 Bureau. “Now it’s all in the phone system. When a person using TTY dials 911, the phone system recognizes the beeps as incoming beeps from a TTY.” The call drops to the general console and goes to the first available line according to the automatic call distribution system.

The Salt Lake City 911 Bureau activated text-to-911 in February 2015, soon after the installation of new software and phone system. The center received 30 texts the first year, a number that increased tenfold by 2018. Text-to-911 revolutionized emergency communications, Burnette said, but even before text-to-911, the bureau’s TTY system was seldom used.

“We trained every month to stay current, but a lot of times when we picked up, it was a fax coming over the same phone line,” said Burnette, who has answered “maybe one” call requiring TTY during her 27 years and nine months at the bureau.

The Salt Lake City 911 Bureau isn’t alone. As technology develops, TTY is losing its relevance. “Typically, PSAPs receive few if any TTY calls because TTY usage has declined so precipitously, but they still must maintain it,” said David Furth, Deputy Bureau Chief, Public Safety & Homeland Security Bureau at the Federal Communications Commission (FCC), during an FCC-sponsored PSAP Education Day: Real-Time Text.4

The FCC regulates telecommunications and advanced communications service providers and manufacturers—not PSAPs. The DOJ, which is responsible for enforcing laws, has not changed its requirement for TTY since the ADA was enacted and mandated. All PSAPs must have TTYs, although the department did issue a letter—not a rule—in 2013 stating that PSAPs can allow alternatives as long as they maintain TTY capability.

These alternatives go beyond legacy-based devices into NG911 capabilities that include digital and IP-based devices. Among these devices are wired and mobile videophones, SMS, and text messaging over wireless devices including smartphones, as well as electronic faxing over a computer with internet access, are replacing TTY, along with use of a webcam and voice over internet (VOIP) technology..5

TPS uses a relay operator called a communication assistant (CA) who relays the call between the caller using text or video and the PSAP. In most IP-based video or text-relay services, the CA receives the call from the person originating the call, places the call to the PSAP, and then relays the conversation between the caller and the PSAP.

Real-time text

Real-time text (RTT) is the up-and-coming technology for the Deaf, hard of hearing, DeafBlind, and speech impaired. It allows text to be sent immediately as it is created through wireless handsets that use IP-based technology on networks that support RTT.6 With RTT, characters are transmitted immediately once typed and displayed immediately to the receiving party. The immediacy offers the same conversational directions and interactivity as voice.

The FCC adopted rules to facilitate a transition from TTY technology to RTT “as a reliable and interoperable universal text solution over wireless Internet Protocol (IP)-enabled networks for people who are Deaf, hard of hearing, DeafBlind, or have a speech disability.”7 The rule went into effect Feb. 22, 2017.

RTT can be used as a stand-alone feature or it can be used in conjunction with other real-time features such as TTY and video conferencing. RTT and TTY are to be treated as a voice call; RTT must also be compatible with TTY to support PSAPs that are not capable of RTT to RTT communications and continue to rely on TTY.

“PSAPs need to be prepared for that,” Furth said. “It should also make them think about technology upgrades and moving to NG911 because everyone recognizes the choices it offers to consumers. TTYs are rather dormant.”8

NG911 allows direct access to 911 emergency services using various communication modalities. On Feb. 23, 2016, the National Emergency Number Association (NENA) announced its support to accelerate the deployment of NG911 services using voice, video, text, and data across the United States by the end of 2020.9

Companies that choose to provide RTT services instead of supporting TTYs over their wireless IP networks must follow the following timelines10:

Wireless providers

  • Dec. 31, 2017: Companies that provide wireless services nationwide—AT&T, Verizon, T-Mobile and Sprint—must either make a downloadable RTT application or plug-in available or implement changes to their networks to support RTT and offer at least one RTT-capable handset.
  • Dec. 31, 2019: Nationwide carriers must support RTT on all of their new wireless devices.
  • June 30, 2020: Companies that provide wireless services locally or regionally, but not nationwide, must either make a downloadable RTT application or plug-in available, or implement changes to their networks to support RTT and offer at least one RTT-capable handset.
  • June 30, 2021: Local and regional providers (including resellers) must support RTT on all their new wireless devices.

Wireless equipment manufacturers

  • Dec. 31, 2018: Manufacturers of handsets for use with wireless IP-based voice services must implement RTT in all handsets manufactured after Dec. 31, 2018.

Can’t go away

A TTY still has its place, despite up and coming technology, according to the NAD.

“While the NAD advocates for implementation of modern text-to-911 technologies, we also believe the needs of these populations should not be left behind,” Alkebsi said. “There are certain populations within the deaf community that still rely on TTYs, such as those who are DeafBlind, senior citizens, or who live in rural areas without internet.”

When there is a power outage and the internet is down, for example, having a TTY with battery backup power and a landline may be the only way to connect to emergency services.

Prior to working at the center, Gooding was aware of relay services. She has video relay on her cellphone but is hesitant to use in an emergency because, as a relative newcomer to ASL, her signing is slow although she understands it well. She did not know of anyone who had used TTY.

“Then I learned about text-to-911,” she said. “Not only do Deaf or hard of hearing callers find texting information easier, but callers who are in a dangerous situation where speaking freely is not an option can use text-to-911.”

While TTY is not commonly used, Gooding supports the continued presence of TTY in the communication center.

“You never know if someone has TTY,” she said. “If we didn’t have it, the call would be lost, and we never want that to happen.”


1“Text to 911 Master PSAP Registry.” 2019; Nov. 15. Federal Communications Commission. https://www.fcc.gov/files/text-911-master-psap-registryxlsx (accessed Nov. 18, 2019).

2 “TechFest aims to improve text-to-911 services.” GCN. 2019; July 10. https://gcn.com/articles/2019/07/10/techfest-text-to-911.aspx (accessed Dec. 9, 2019).

3 “2017 National 911 Progress Report.” National 911 Program. 2017; November. https://www.911.gov/pdf/National-911-Program-Profile-Database-Progress-Report-2017.pdf (accessed Nov. 18, 2019).

4 “Real-Time Text: Improving Accessible Telecommunications.” Federal Communications Commission. 2017; Dec. 19. https://www.fcc.gov/consumers/guides/real-time-text-improving-accessible-telecommunications (accessed Nov. 18, 2019).

5 Cromartie J, Gaffey B, Seaboldt M. “Evaluating Communication Technologies for the Deaf and Hard of Hearing.” Worcester Polytechnic Institute. 2012; March 2. https://web.wpi.edu/Pubs/E-project/Available/E-project-022812-225227/unrestricted/Evaluating_Communication_Technologies_for_the_Deaf_and_Hard_of_Hearing.pdf (accessed Nov. 18, 2019).

6 “Transition From TTY to Real-Time Text Technology.” Federal Communications Commission. 2017; Jan. 23. https://www.federalregister.gov/documents/2017/01/23/2017-01377/transition-from-tty-to-real-time-text-technology (accessed Nov. 18, 2019).

7 “Real-Time Text: Improving Accessibility.” Federal Communications Commission. 2017; Dec. 19. https://www.fcc.gov/sites/default/files/real-time-text.pdf (accessed Nov. 18, 2019).

8 See note 2.

9 “NENA Standard Managers Guide to Americans with Disabilities (ADA) Title II: Direct Access.” NENA. 2018; Nov. 11. https://cdn.ymaws.com/www.nena.org/resource/resmgr/standards/nena-sta-035.2-201x__52-002_.pdf (accessed Nov. 18, 2019).

10 See note 7.

Quick Statistics About Hearing

  • Nearly 50 million Americans have hearing loss.
  • Approximately 16% of American adults (37.5 million) aged 18 and over report some trouble hearing.
  • The estimated number of adults 20–69 years old with hearing loss declined from an estimate of 28.0 million in 1999–2004 to 27.7 million in 2011–2012.
  • About 18% of adults aged 20–69 have speech-frequency hearing loss in both ears from among those who report 5 or more years of exposure to very loud noise at work, as compared to 5.5% of adults with speech-frequency hearing loss in both ears who report no occupational noise exposure.
  • One in eight people in the United States (13%, or 30 million) aged 12 years or older has hearing loss in both ears, based on standard hearing examinations.
  • About 2% of adults aged 45 to 54 have disabling hearing loss. The rate increases to 8.5% for adults aged 55 to 64. Nearly 25% of those aged 65 to 74 and 50% of those who are 75 and older have disabling hearing loss.
  • Occupational hearing loss is the most recorded occupational illness in manufacturing (17,700 cases out of 59,100 cases), accounting for 1 in 9 recordable illnesses.
  • The number of people with hearing loss is more than those living with Parkinson’s, epilepsy, Alzheimer’s, and diabetes combined.


“Quick Statistics About Hearing.” National Institute on Deafness and Other Communication Disorders. 2016; Dec. 15. https://www.nidcd.nih.gov/health/statistics/quick-statistics-hearing (accessed Nov. 13, 2019).

TTY Etiquette

TTY involves training and the use of proper TTY etiquette, as outlined in the NENA document:1

  • It is extremely important to type the term GA when you are through with your statement and want a response from the person on the other end of the line. The term GA means “go ahead, it’s your turn to talk.”
  • Tone of voice is not transmitted on a TTY/TDD, so it is necessary to type the letter Q (or QQ) when asking a question (plus GA to request a response).
  • When getting ready to end the conversation, a caller may type GASK, which means “I am through, do you have anything else to say?”
  • SKSK means “Bye, I am hanging up now.” Telecommunicators shall stay on the line with the TTY/TDD caller as long as it is safe for the caller to do so. If it becomes unsafe for the caller to stay on the line, ask them to lay the receiver down and exit the area/building.


"TTY/TDD Communications Standard Operating Procedure Model Recommendation.” NENA PSAP Operations Group. NENA-STA-037.2-201X (originally 56-004). 2005; June 25. https://cdn.ymaws.com/www.nena.org/resource/resmgr/standards/nena-sta-037.2-2018__orig_56.pdf (accessed Nov. 13, 2019).