OnStar petitioned the FCC for reconsideration of rule changes tha...

call center-based telematics services, it offers Personal Calling, a prepaid interconnected service that lets users make and receive hands-free mobile calls on the public switched telephone network. OnStar told the FCC that Personal Calling uses the same embedded telematics unit as is used to deliver its core telematics services. Personal Calling allows hands-free dialing through voice recognition software and doesn’t include a keypad for manual dialing. OnStar said it meets the definition of a reseller because it buys wholesale airtime capacity from wireless carriers and makes it available to end users at retail rates. As a wireless reseller, OnStar said it would be required to make its Personal Calling service accessible to TTY users to dial 911. OnStar said the rule changes were “procedurally flawed because the adopting order did not provide any rationale for applying the TTY requirement to resellers, and does not reflect sound public policy as it relates to providers of vehicle-based calling services.” OnStar said it raises driver distraction issues to require the conversion of a hands-free service for in-vehicle calling into a hands-on one using TTY technology. “Given the complexity of the safety and technical feasibility issues involved, the Commission should exempt CMRS resellers of vehicle-based calling services from the TTY compatibility obligation, or at a minimum, provide for a reasonable transition period before compliance is required,” OnStar said. If the FCC were to conclude a vehicle-based TTY compatibility requirement is needed, OnStar said it should focus on careful implementation. It said the requirement “should be designed in a way that minimizes, to the greatest extent possible, the likelihood that the driver will use the device while the vehicle is in motion.” OnStar stressed such a requirement should be examined in light of state laws that attempt to curb distracted driving, including those regulating the use of screen-based devices in cars. “At the federal level, the National Highway Transportation Safety Administration may have an interest in the issue, given that agency’s emphasis on reducing driver distractions,” OnStar said. In part, the company also argued its system facilitates calls by hard of hearing users.