KELLOGG, HUBER, HANSEN, TODD & EVANS, P.L. I . MICHAEL K. KELLOGG PETER W. HUBER MARK C. HANSEN K. CHRIS TODD MARK L. EVANS AUSTIN C. SCHLICK STEVEN F. BENZ NEIL M. GORSUCH GEOFFREY M. KLINEBERG 1301 K STREET, N.W. SUITE 1000 WEST WASHINGTON, D.C. 20005-3317 (2021 326-7900 FACSIMILE: 12021 326-7999 August 14, 1998 Magalie R. Salas Office of the Secretary Federal Communications Commission 1919 M Street, N.W. Room 222 Washington, D.C. 20554 I COMMERCE SQUARE 2005 MARKET STREET SUITE 2340 PHILADELPHIA, PA 19103 (215) 864-7270 FACSIMILE: 12151 864-7280 Re: In the Matter of Implementation of Section 255 of the Telecommunications Act of 1996: Access to Telecommunications Services, Telecommunications Equipment, and Customer Premises Equipment by Persons With Disabilities, WT Docket No. 96-198 Dear Ms. Salas: Enclosed for filing are an original and seven copies of SBC Communications Inc. Is Reply Comments in the above-captioned proceeding. Please date-stamp and return the extra copy to the individual delivering this package. Sincerely, Courtney S. Elwood Enclosures In the Matter of BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. Implementation of Section 255 of the ) Telecommunications Act of 1996 ) )WT Docket No. 96-198 Access to Telecommunications Services, ) Telecommunications Equipment, and ) Customer Premises Equipment ) by Persons With Disabilities ) REPLY COMMENTS OF SBC COMMUNICATIONS INC. ROBERT M. LYNCH MICHAEL K. KELLOGG DURWARD D. DUPRE COURTNEY SIMMONS ELWOOD HOPE THURROTT Kellogg, Huber, Hansen, Todd One Bell Plaza & Evans, P.L.L.C. Room 3703 1301 K Street, N.W., Suite 1000 West Dallas, Texas 75202 Washington, D.C. 20005 (214) 464-4244 (202) 326-7900 Counsel for SBC Communications Inc. TABLE OF CONTENTS I. SECTION 255 DOES NOT APPLY TO NON-TELECOM- MUNICATIONS SERVICES SUCH AS INFORMATION SERVICES; HOWEVER, SBC RECOGNIZES THAT CONSUMERS NEED ACCESS TO THESE RESOURCES . . . . , . . . . . . . . . . . . . . . . . 1 II. IF SECTION 255'S REQUIREMENTS ARE APPLIED TO A LINE OF PRODUCTS HAVING COMPARABLE FUNCTIONS, FEATURES, AND PRICE, MANUFACTURERS CAN DESIGN PRODUCTS THAT ARE ACCESSIBLE TO MORE CONSUMERS WITH DISABILITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...4 III. FIVE DAYS TO RESPOND TO A FAST-TRACK COMPLAINT IS NOT REALISTIC . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7 IV. THE FCC SHOULD ENSURE PARITY WITH RESPECTTOAFILINGFEE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..7 BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. In the Matter of ) ) Implementation of Section 255 of the ) Telecommunications Act of 1996 ) )WT Docket No. 96-198 Access to Telecommunications Services, ) Telecommunications Equipment, and ) Customer Premises Equipment ) by Persons With Disabilities ) REPLY COMMENTS OF SBC COMMUNICATIONS INC. SBC Communications Inc. ("SBC") adheres to the positions detailed in its opening comments of June 30, 1998. It has only four specific, but important, points to make in response to comments of other parties to this proceeding. I. SECTION 255 DOES NOT APPLY TO NON-TELECOMMUNICATIONS SERVICES SUCH AS INFORMATION SERVICES; HOWEVER, SBC RECOGNIZES THAT CONSUMERS NEED ACCESS TO THESE RESOURCES Some commenters urge the Commission to disregard the plain language of Section 255 to find that the statute's requirements apply to enhanced or information services. See, e.g., Comments of the National Association of the Deaf at 9-l 7 ("NAD Comments"); Comments of Self Help for Hard of Hearing People, Inc. at 5-7 ("SHHH Comments"); Comments of Universal Service Alliance at 7-8 ("USA Comments").' While SBC understands the concerns voiced by these organizations, it is a bedrock principle of statutory interpretation that where -- as here -- "the statutory language is clear," the "sole function" of a court or agency ""is to enforce it according to its terms.""' Rake v. Wade, 508 U.S. 464,471 (1993) (quoting United States v. Ron Pan Enterprises, Inc., 489 U.S. 235,241 (1989) (quoting minetti v. United States, 242 U.S. 470,485 (1917))). In this case, the language could not */ These commenters advocate reading the term "telecommunications service" "liberally" to include information services in order to accomplish the "overarching intent of Congress . . . to bring Americans with disabilities into the mainstream of the technological age." NAD Comments at 11,9; USA Comments at 7 ("Section 255 . . . should be broadly construed to effectuate its purpose"). be more clear. By its express terms, Section 255 applies only to "telecommunications equipment," "customer premisses equipment" and "telecommunications service," 47 U.S.C. Section 255(b)(c)-- each of which are defined terms under the statute, see 47 U.S.C. Section 153(14),(45),(46). Section 255 does not mention "information service," which by statutory definition expressly excludes "telecommunications service." 47 U.S.C. Section 153(20). Furthermore, the FCC has already twice held that the term "telecommunications services" as used in the Communications Act of 1934, as amended, does not include "information services." Report to Congress, Federal-State Joint Board on Universal Service, CC Dkt. No. 96-45, FCC 98-67,133 (Apr. 10, 1998) ("Commission precedent . . . indicat[es] that telecommunications services and information services are `separate, non-overlapping categories."`); see also Comments of SBC Communications Inc. at 3-4. Therefore, under the "basic canon of statutory construction" "that identical terms within an Act bear the same meaning," Estate of Cowart v. Nicklos Drilling Co., 505 U.S. 469,479 (1992), the Commission must interpret "telecommunications services" when used in Section 255 to exclude information services.2/ The Commission cannot simply brush aside the plain language of the statute and past FCC precedent in an attempt to achieve what some believe to have been Congress's "overarching intent" or "broad objectives." NAD Comments at 9; SHHH Comments at 7; USA Comments at 7. The Supreme Court has expressly criticized that sort of approach to statutory interpretation. In Board of Governors of the Federal Reserve System v. Dimension Financial Corp., 474 U.S. 361 (1986, the Court wrote: Application of "broad purposes" of legislation at the expense of specific provisions ignores the complexity of the problems Congress is called upon to address and the dynamics of legislative action. Congress may be unanimous in its intent to stamp out some vague social or economic evil; however, because its Members may differ sharply on the means for effectuating that intent, the final language of the legislation may reflect hard-fought compromises. Invocation of the "plain purpose" of legislation at the expense of the terms of the statute itself takes no account of the processes of compromise and, in the end, prevents the effectuation of congressional intent. Id at 373-74. Accordingly, the FCC must adhere to the plain statutory language and find that Section 255 does not apply to non-telecommunication services. 2/ The commenters proposing that Section 255 be expanded to cover information services acknowledge that such an interpretation would be a break with the Commission's past and consistent rulings. See NAD Comments at 11-14; USA Comments at 7; SHHH Comments at 6. Moreover, applying Section 255 to only telecommunications services will prevent the FCC from creating an arbitrary disparity between information service providers who happen to also be telecommunications providers, and those information service providers who are not. As GTE explained in its comments: [T]he market for information services is highly competitive. Information services are provided not only by telecommunications service providers, but also by entities that have no capacity to transmit information between points specified by the user of the service. Allowing some providers of information services to do so free of Section 255 accessibility requirements, while requiring other competitors to comply with potentially costly FCC regulation would inhibit the competition that currently exists. Indeed, such regulation would artificially and needlessly discriminate in favor of information services provided by entities not affiliated with a provider of telecommunications services. Comments of GTE at 5. While Section 255 does not apply to non-telecommunications services, that does not mean that SBC will not voluntarily implement accessibility features in its information services. As explained in its opening comments, SBC's Universal Design Policy pledges that each of its subsidiaries will endeavor to create new products and services - including information services - that address the needs of consumers with disabilities. See SBC Comments at 2-3. SBC urges other companies to do the same and commends those that have already voluntarily gone beyond the minimum obligations imposed by the statute. a, a, Comments of Ameritech at 2-5; Comments of Motorola, Inc. at l-5; Comments of Bell Atlantic at l-2; Comments by Lucent Technologies at 3. II. IF SECTION 255'S REQUIREMENTS ARE APPLIED TO A LINE OF PRODUCTS HAVING COMPARABLE FUNCTIONS, FEATURES, AND PRICE, MANUFACTURERS CAN DESIGN PRODUCTS THAT ARE ACCESSIBLE TO MORE CONSUMERS WITH DISABILITIES SBC believes that the best way to ensure that telecommunications products are accessible to individuals with a wide variety of disabilities is for the FCC to apply Section 255's requirements to a line of products with comparable features, functions, and price. SBC, accordingly, supports the Telecommunications Industry Association (,,,A") and others in arguing that the proper inquiry under Section 255 is whether a manufacturer has incorporated all readily achievable accessibility features across a product line, not whether a manufacturer has done so with respect to each individual product. & Comments of the Telecommunications Industry Association at 9-13.3/ The FCC appears to recognize the benefits of a product-line approach in its Notice of Proposed Rulemaking ("NPRM). In paragraph 170, the Commission explained that, in implementing Section 255, "it is reasonable for an informed product-development decision to take into account the accessibility features of other functionally similar products the provider offers, provided it can be demonstrated that such a `product line' analysis increases the overall accessibility of the provider's offerings." NPRM para. 170. A product-line approach is preferable, SBC submits, because it allows a manufacturer to develop products that are accessible to the widest possible audience of consumers. As so many commenters have stated, it is an indisputable fact that "no one product can be accessible to everyone." TIA Comments at 11. Consequently, a product designer will often have to choose between making a product accessible to individuals with one type of disability (for example, fine motor impairment) at the expense of making it accessible to individuals with another disability (gross motor impairment).4/ If Section 255 were applied on a product-by-product basis, the designer will confront this dilemma for each distinct product. The likely outcome would be that same 3/ SBC supports TM's position even though SBC is a service provider, and there are material differences between the regulation of services and products. 4/ The Telecommunications Access Advisory Committee made this precise point in its Final Report, Section 5.2.1, in stating that "because no single interface will accommodate all disabilities, companies must use discretion in choosing among disability features." Other commenters agree. See, e.g., TIA Comments at 27 ("N]o single product can be accessible to everyone because different functional limitations generate conflicting accessibility needs. For example, multiple selectable access features would likely run afoul of the requirement that the product be accessible to persons with cognitive disabilities."); Motorola Comments at l0-11 ("If the FCC were to adopt an approach to Section 255 that required each manufacturer to provide a range of functionally similar, comparably priced products that are accessible, the FCC would create incentives for product differentiation, which is critical to increased accessibility for persons with disabilities. The individual product-by-product paradigm . . . fails to recognize that certain kinds of products and technologies are inherently better-suited to meeting the needs of people with certain fi.mctional limitations than other products and technologies. For this reason, it will often be a waste of resources to require a manufacturer to incorporate features that accommodate different functional limitations into a single product or to document why the manufacturer has determined that it is not 'readily achievable' to do so."); BellSouth Comments at 12 ("Not all products in the marketplace can be equipped with all features. BellSouth thus urges the Commission to conclude that a 'product line' approach in many cases will increase overall accessibility of a company's offerings."). set of disabilities would be repeatedly accommodated, and individuals with other (perhaps less common) disabilities would go without accessibility features at all. If, however, the accessibility requirements were imposed across an entire product line, a company would be allowed to make different products within that line accessible to individuals with different disabilities. SBC recommends, therefore, that the FCC require that the eighteen-point checklist, which was proposed by the Access Board and tentatively adopted by the Commission, be applied only across a product line, and not to each individual product. By "product line," SBC, like TIA, contemplates a group of products "with similar features, functions, and price." TIA Comments at 9. For example, a manufacturer would produce a line of mobile telephones and a line of landline telephones; the product line would not be "telephones" in general. SBC further believes that individuals with disabilities should have some choice among accessible products; therefore, if it is readily achievable, SBC encourages companies to maximize the number of accessibility features that can be accommodated on a single product. Finally, SBC thinks it is in everyone's interest for companies to market their products with accessibility features to the general population. Greater amplification options (which provide improved access for someone who is hard of hearing), for example, may be extremely beneficial for anyone in a noisy environment. Increased access for people with disabilities often benefits people without disabilities. III. FIVE DAYS TO RESPOND TO A FAST-TRACK COMPLAINT IS NOT REALISTIC Among the commenters, there was almost universal agreement aeainst the FCC's proposal to allow a manufacturer or service provider only five business days to respond to a fast-track complaint. a, a, NAD Comments at 35; Comments of the National Council on Disability at 29; TIA Comments at 72-76; Comments of Ameritech at 8-9. As SBC explained in its opening comments (at 17- 1 S), the FCC should allow a manufacturer or provider at least 15, if not 30, days to respond to the complaint with a final action report or with a request for an extension upon a proper showing that "substantial efforts" to resolve the dispute are underway. IV. THE FCC SHOULD ENSURE PARITY WITH RESPECT TO A FILING FEE Some commenters argue that "[t]here should be no filing fees for informal and formal complaints" and the "fees that currently exist for filing [formal] complaints against common carriers should be waived for [formal] complaints brought under Section 255." Comments of the American Council for the Blind 1 15; Comments of Thomas D. Benziger, Access Living of Metropolitan Chicago at 4; Comments of the Long Island Center for Independent Living at 4. The fee for filing a formal complaint against a common carrier is statutorily mandated, See 47 USC Section 158(g), and simply cannot be waived by the FCC on a blanket basis for all Section 255 complaints, see 47 U.S.C. Section 158(d)(2) (allowing waivers in "specific instance[s] for good cause shown"); NPRM, implementation of Section 9 of the Communications Act, 9 FCC Red 6957,6970,124 (1994) (the FCC will grant waivers under Section 158(d)(2) "on a case-by-case basis"). The Commission, accordingly, has no choice but to impose a filing fee -- as a rule that can be waived on a case-by-case basis -- for all Section 255 complaints against common carriers. However, as SBC explained in its opening comments, if the FCC required filing fees for complaints against only common carriers, it would create an arbitrary disparity between common carriers and all others who are subject to Section 255. w SBC Comments at 24. It would also make the formal complaint process susceptible to inappropriate gamesmanship to permit such a disparity. LB, Therefore, SBC recommends that the FCC apply the filing fee for formal Section 255 complaints across the board. At the same time, SBC urges the Commission to use its statutory authority to waive that fee on a case-by-case basis, "where such action would promote the public interest." 47 U.S.C. Section 158(d)(2). In addition, the Commission should work with disability organizations to ensure that information about the waiver process is provided to those who may need it. Finally, and in any event, SBC supports the FCC's decision not to impose filing fees on informal complaints -- a decision that ensures that no individual will be denied the ability to petition the FCC for financial reasons. SBC urges the Commission to adopt the proposals outlined in SBC opening comments and these reply comments in implementing Section 255. By doing so, the FCC will adhere to the letter and spirit of the statute. Respectfully submitted, ROBERT M. LYNCH DURWARD D. DUPRE HOPE THURROTT One Bell Plaza Room 3703 Dallas, Texas 75202 (2 14) 464-4244 MICHAEL K. KELLOGG COURTNEY SIMMONS ELWOOD Kellogg, Huber, Hansen, Todd & Evans, P.L.L.C. 1301 K Street, N.W., Suite 1000 West Washington, D.C. 20005 (202) 326-7900 Counsel for SBC Communications Inc. August 14,1998 SBC Communications Inc.: August 14,1998 CERTIFICATE OF SERVICE I, Holly R. Schroeder, hereby certify that on this 14th day of August, 1998, copies of the Reply Comments of SBC Communications Inc. were served by first-class United States mail, postage prepaid, upon the parties listed on the attached service list. CERTIFICATE OF SERVICE Federal Communications Commission Magalie R. Salas Office of the Secretary Federal Communications Commission 1919 M Street, N.W. Room 222 Washington, D.C. 20554 Judy Boley Federal Communications Commission 1919 M Street, N.W. Room 234 Washington, D.C. 20554 Timothy Fain OMB Desk Officer 10236 NEOB 725 17th Street, N.W. Washington, D.C. 20503 Access Living Access to Independence and Mobility AccommoDAtor The Advocacy Center Thomas D. Benziger Access Living 310 South Peoria, Suite 201 Chicago, IL 60607 Access to Independence and Mobility Two Seventy One East First Street Coming, NY 14830 Malisa W. Janes The AccommoDAtor 2112 West Main Houston, TX 77098-33 17 Ann Maclaine Lois V. Simpson The Advocacy Center 225 Baronne Street, Suite 2112 New Orleans, LA 70 112 Advocacy Awareness Access AirTouch Communications, Inc. American Council of the Blind American Foundation for the Blind Donald E. Maroney Advocacy Awareness Access 640 East Eisenhower Loveland, CO 80537-3954 Pamela J. Riley David A. Cross AirTouch Communications, Inc. 1818 N Street, N.W., Suite 800 Washington, D.C. 20036 Charles D. Cosson AirTouch Communications, Inc. One California Street, 29th Floor San Francisco, CA 94111 D. Alfred Ducharme American Council of the Blind 1155 15th Street, N.W., Suite 720 Washington, D.C. 20005 Joseph Van Eaton Miller & Van Eaton, PLLC 1155 Connecticut Avenue, N.W. Suite 1000 Washington, D.C. 20036 American Public Communications Council Albert H. Kramer Robert F. Aldrich Valerie M. Furman Dickstein Shapiro Morin & Oshinsky 2101 L Street, N.W. Washington, D.C. 20037 Ameritech Ameritech New Media Alan N. Baker Ameritech 2000 West Ameritech Center Drive Hoffman Estates, IL 60196 Christopher M. Heimann Ameritech 1401 H Street, N.W., Suite 1020 Washington, D.C. 20005 2 Architectural and Transportation Barriers Compliance Board Lawrence W. Roffee Architectural and Transportation Barriers Compliance Board 133 1 F Street, N. W., Suite 1000 Washington, D.C. 20004-l 111 Association of Access Engineering Specialists John Holmberg NARTE/AAES 167 Village Street Medway, MA 02053 AT&T Corp. Gene A. Bechtel Bell Atlantic Telephone Companies BellSouth Corporation Kim Blackseth Mark C. Rosenblum Peter H. Jacoby AT&T Corp. 295 North Maple Avenue Room 325051 Basking Ridge, NJ 07920 Gene A. Bechtel Bechtel & Cole Chartered 1901 L Street, N.W., Suite 250 Washington, D.C. 20036 Lawrence W. Katz Bell Atlantic Telephone Companies 1320 N. Court House Road 8th Floor Arlington, VA 22201 M. Robert Sutherland A. Kirven Gilbert III BellSouth Corporation Suite 1700 1155 Peachtree Street, N.E. Atlanta, GA 30309-3610 Kim Blackseth 565 Bellevue Avenue Apt. No. 1902 Oakland, CA 94610 3 Brightpoint, Inc. Business Software Alliance California Foundation for Independent California Foundation for Independent Living Center Living Center California Public Utilities Commission Steven E. Five1 Brightpoint, Inc. 6402 Corporate Drive Indianapolis, IN 46278 Andrew 2. So&nick Baker & Daniels 300 North Meridian Street Suite 2700 Indianapolis, IN 46204-l 782 Gerard J. Waldron Laurel E. Miller Covington & Burling 1201 Pennsylvania Avenue, N.W. Washington, D.C. 20044 Becca Gould Business Software Alliance 1150 8th Street, N.W., Suite 700 Washington, D.C. 20036 910 K Street, Suite 350 Sacramento, CA 95814-3577 Helen M. Mickiewicz California Public Utilities Commission 605 Van Ness Avenue San Francisco, CA 94102 Campaign for Telecommunications Access David J. Newburger Newburger & Vossmeyer One Metropolitan Square Suite 2400 St. Louis, MO 63 102 Cape Organization for Rights of the Disabled Cathy Taylor Cape Organization for Rights of the Disabled 114 Enterprise Road Hyannis, MA 02601 4 Cellular Phone Taskforce Arthur Firstenberg Cellular Phone Taskforce Post Office Box 100404 Brooklyn, NY 11210 Cellular Telecommunications Industry Assoc. Michael F. Altschul Randall S. Coleman Andrea D. Williams Cellular Telecommunications Industry Association 1250 Connecticut Avenue, N.W. Suite 200 Washington, D.C. 20036 Center for Disability Rights Bruce E. Darling Center for Disability Rights 584 Lake Avenue Rochester, NY 146 13 Computer and Communications Industry Assoc. Richard D. Marks Megan H. Troy Vinson & Elkins, L.L.P. The Willard Office Building 145 5 Pennsylvania Avenue, N. W. Washington, D.C. 20004-1008 State of Connecticut State of Connecticut Office of Protection and Advocacy for Persons with Disabilities 60B Weston Street Hartford, CT 06120-1551 Consumer Electronics Manufacturers Association George A. Hanover Gary Klein Consumer Electronics Manufacturers Assoc. 2500 Wilson Boulevard Arlington, VA 22201 Conxus Communications CPB/WGBH National Center David A. Nall Benign0 E. Bartolome, Jr. Kimberly S. Reindl Squire, Sanders & Dempsey, LLP 1201 Pennsylvania Avenue, N. W. P. 0. Box 407 Washington, D.C. 20044 Michael D. Layman Conxus Communications 12 North Main Street Greenville, SC 29601 Larry Goldberg Media Access 125 Western Avenue Boston, MA 02134 Nancy A. Dietrich Nancy A. Dietrich 2621 Brookfield Court Columbia, IL 62236-2620 Disability Rights Education and Defense Fund Disability Rights Education and Defense Fund 1633 Q Street, N.W., Suite 220 Washington, D .C . 20009 Ericsson Inc. Mervin D. Garretson David Geeslin David C. Jatlow Young 8z Jatlow 2300 N Street, N.W., Suite 600 Washington, D.C. 20037 Mervin D. Garretson 2 1 Cotton Patch Hills P. 0. Box 398 Bethany Beach, DE 19930-0398 David Geeslin 7555 North Gale Street Indianapolis, IN 46240-3637 Governor's Council on Disability Joanne Groshardt GTE Service Corporation William D. Goren Governor's Council on Disability 33 15 West Truman Boulevard Suite 132 P. 0. Box 1668 Jefferson City, MO 65 102-l 668 Joanne Groshardt 302 Traihidge Drive Richardson, TX 75081 John F. Raposa GTE Service Corporation 600 Hidden Ridge HQE03 J27 P. 0. Box 152092 Irving, TX 75015-2092 Andre J. Lachance GTE Service Corporation 1850 M Street, NW., Suite 1200 Washington, D.C. 20036 Theodore G. Huber Theodore G. Huber 1708 Linden Street South Jacksonville, IL 62650-3210 Illinois Deaf and Hard of Hearing Commission Thomas D. Benziger Illinois Deaf and Hard of Hearing Commission 1925 Hawthorne Avenue Westchester, IL 60 154 Illinois/Iowa Center For Independent Living Liz Sherwin Illinois/Iowa Center For Independent Living P. 0. Box 6156 Rock Island, IL 61204-6156 Information Technology Industry Council Colleen Boothby Janine Goodman Levine, Blaszak, Block & Boothby, LLP 2001 L Street, N.W., Suite 900 Washington, D.C. 20036 7 Joan P. Ireland Justice-For-All June Isaacson Kailes Leo A. LaPointe Learning Disabilities Association of America Lighthouse Inc. Linking Employment, Abilities & Potential (LEAP) Long Island Center for Independent Living, Inc. Fiona J. Branton Information Technology Industry Council 1250 I Street, N.W., Suite 200 Washington, D.C. 20005 Joan P. Ireland 12276 Casero Court San Diego, CA 92128-2723 Fred Fay Justice-For-All 2054 Main Street Concord, MA 0 1742 June Isaacson Kailes 6201 Ocean Front Walk, Suite 2 Playa Del Rey, CA 90293 Leo A. LaPointe 49 Highland Terrace Worthington, OH 43085 Harrison Sylvester Learning Disabilities Association of America 4156 Library Road Pittsburgh, PA 15234-1349 Barbara Silverstone Lighthouse Inc. 111 East 59th Street New York, NY 10022-1202 Linking Employment, Abilities & Potential 19 17 N. Ridge Road East, Suite C Lorain, OH 44055 Patricia Moore Long Island Center for Independent Living 3601 Hempstead Turnpike, Suite 208 Levittown, NY 11756 8 Lucent Technologies Diane M. Law Lucent Technologies 1825 I Street, N.W., Tenth Floor Washington, D.C. 20006 Michigan Protection & Advocacy Service Laura Remson Mitchell Elizabeth W. Bauer Michigan Protection & Advocacy Service 106 W. Allegan, Suite 300 Lansing, MI 48933- 1706 Laura Remson Mitchell 19955 Blythe Street Winnetka, CA 91306 Motorola, Inc. Thomas C. Collier, Jr. Steven K. Davidson Jennifer M. Quinn Karen E. Lloyd Steptoe & Joshson, LLP 1330 Connecticut Avenue, N.W. Washington, D.C. 20036 Mary E. Brooner Office of Government Relations Motorola, Inc. 1350 I Street, N.W., Suite 400 Washington, D.C. 20005 Alfred R. Lucas Motorola, Inc. 3301 Quantum Boulevard Boynton Beach, FL 33426 Multimedia Telecommunications Association Albert H. Kramer Robert F. Aldrich Valerie M. Furman Dickstein Shapiro Morin & Oshinsky 2101 L Street, N.W. Washington, D.C. 20037 Dana Mulvany Dana Mulvany 350 Budd Avenue Apt. No. Al Campbell, CA 95008 9 NC Assistive Technology Project National Association for the Deaf Ricki Cook NC Assistive Technology Project 110 Navaho Drive, Suite 10 1 Raleigh, NC 27609 Karen Peltz Strauss National Association for the Deaf 8 14 Thayer Avenue Silver Spring, MD 20910-4500 Lori Dolqueist Institute for Public Representation Georgetown University Law Center 600 New Jersey Avenue Washington, D.C. 20001-2022 National Cable Television Association Daniel L. Brenner David L. Nicoll National Cable Television Association 1724 Massachusetts Avenue, N. W. Washington, D.C. 20036 National Catholic Office for the Deaf National Catholic Office for the Deaf 7202 Buchanan Street Landover Hills, MD 20784-2236 David J. Nelson Nextel Communications, Inc. Northern Telecom Inc. David J. Nelson 909 F Street, N.E. Washington, D.C. 20002 Robert S. Foosaner Lawrence R. Krevor Laura L. Holloway Nextel Communications, Inc. 1450 G Street, N.W., Suite 425 Washington, D.C. 20005 Stephen L . Goodman Halprin, Temple, Goodman & Sugrue 1100 New York Avenue, N.W. Suite 650 East Washington, D.C. 20005 10 Oklahoma Department of Rehabilitation Services Oklahoma Assistive Technology Project Personal Communications Industry Association Philips Consumer Communications LP President's Committee on Employment of People With Disabilities Richard Radtke John G. Lamb, Jr. Northern Telecom Inc. 2100 Lakeside Boulevard Richardson, TX 7508 l-l 599 Linda Parker Oklahoma Department of Rehabilitation Services 3535 NW 58th Street, Suite 500 Oklahoma City, OK 73 112-48 15 Linda Jaco Oklahoma Assistive Technology Project OSU Wellness Center 1514 West Hall of Fame Stillwater, OK 74078-2026 Mark J. Golden Robert L. Hoggarth Todd B. Lantor Personal Communications Industry Association 500 Montgomery Street, Suite 700 Alexandria, VA 22314-1561 Gerard G. Nelson Philips Consumer Communications LP 535 Mountain Avenue Murray Hill, NJ 07974 Tony Coelho Chairman President's Committee on Employment of People With Disabilities 1331 F Street, N.W. Washington, D.C. 20004-l 107 Richard Radtke 45-Pookela Place Kaneohe, HI 96744 11 -- Self-Help for Hard of Hearing People, Inc. Randy Sergeant Siemens Business Communication Systems, Inc. Telecommunications for the Deaf, Inc. Telecommunications Industry Association Uniden America Corporation Donna L. Sorkin Self-Help for Hard of Hearing People, Inc. 7910 Woodmont Avenue, Suite 1200 Bethesda, MD 208 14 Gene A. Bechtel Bechtel & Cole Chartered 1901 L Street, N.W., Suite 250 Washington, D.C. 20036 Randy Sergeant 75 14 E. Taylor Scottsdale, AZ 85257 Randolph J. May Timothy J. Cooney Sutherland, Asbill & Brennan, LLP 1275 Pennsylvania Avenue, N.W. Washington, D.C. 20004-2404 Scott E. Wollaston Siemens Business Communication Systems 4900 Old Ironside Drive P. 0. Box 58075 M/S 103 Santa Clara, CA 95052-8075 Claude L. Stout Telecommunications for the Deaf, Inc. 8630 Fenton Street, Suite 604 Silver Spring, MD 20910 Grant Seiffert Telecommunications Industry Association 1300 Pennsylvania Avenue, N.W. Suite 350 Washington, D.C. 20004 Gregg P. Skall Howard J. Barr Michael J. Lehmkuhl Pepper & Corazzini, L.L.P. 1776 K Street, N.W., Suite 200 Washington, D.C. 20006 12 United Cerebral Palsy Associations United States Telephone Association Universal Service Alliance Gregg C. Vanderheiden Ronald H. Vickery Wisconsin Association of the Deaf World Institute of Disability Nancy Flinn United Cerebral Palsy Associations 1660 L Street, N.W., Suite 700 Washington, D.C. 20036 Lawrence E. Sarjeant Linda Kent Keith Townsend United States Telephone Association 1401 H Street, N.W., Suite 600 Washington, D.C. 20005 William F. Maher, Jr. Halprin, Temple, Goodman 8z Sugrue 1100 New York Avenue, N. W. Suite 650 East Washington, D.C. 20005 Carl K. Oshiro Universal Service Alliance 100 First Street, Suite 2540 San Francisco, CA 94105 Gregg C. Vanderheiden Trace R & D Center 5901 Research Park Boulevard Madison, WI 53719 Ronald H. Vickery 404 Benton Drive Rome, GA 30165 Stephanie Buell John R. Hathway Pam Holmes Wisconsin Association of the Deaf 6701 Seybold Road, Suite 114 Madison, WI 53719 Betsy Bayha World Institute of Disability 5 10 Sixteenth Street, Suite 100 Oakland, CA 946 12