36 CFR Part 1193 Telecommunications Act (Section 255) Accessibility Guidelines - Preamble

Paragraph (c) Access to moving text (Section-by-Section Analysis)

Comment. The NPRM provision exempted TTYs from this provision because it assumed a person who needed static text could ask the TTY sender to pause or type slowly. The Trace Center pointed out that there are many automatic TTY messages for which this option is not possible. Also, the message recipient could not communicate the request to the sender until the sender had completed typing and transmitted "GA." Trace further noted that many TTYs have a means to save text or are equipped with a printer.

Response. The Board agrees that automatic messages could be a problem and that one may not be able to communicate with the sender until the message has gone by. In addition, this provision applies to telecommunications equipment and customer premises equipment, not peripheral devices. Since the majority of TTYs to which this provision would apply would usually have a printer or a feature to save the message to memory for playback line by line, the Board has removed the exception.