AT&T Services, Inc., on behalf of its subsidiaries (AT&T), has filed a petition for rulemaking requesting that the Federal Communications Commission (FCC) open a docket to explore a change to the FCC’s rules requiring support for text telephone (TTY) technology. AT&T proposes that real-time text (RTT) communications replace TTY as the technology of choice for persons who are deaf, hearing impaired, or speech impaired to access newly deployed voice communications. In its petition, AT&T describes TTY as “an antiquated technology with technical and functional limitations,” and explains that it is “developing and will deploy RTT, which will provide superior functionality to TTY and deliver enhanced, interoperable disability access.” Simultaneously with its petition for rulemaking, AT&T filed a petition for a temporary waiver of Sections 20.18(c) and 64.603 the FCC’s rules which require covered service providers to enable 911 and 711 short code dialing using a TTY device.