Before the FEDERAL COMMUNICATIONS COMMISSION
Washington, D. C. 20554

In the Matter of Implementation of Section 255 of the Telecommunications Act
of 1966
Access to Telecommunications Services, Telecommunications Equipment, and
Customer Premises Equipment By Person with Disabilities
WT Docket No. 96-198

Comments of Ericsson Inc.

Ericsson Inc. (“ Ericsson”), by its attorney, hereby submits its comments in
the above captioned proceeding.[1] In support of its comments Ericsson states
as follows:

Ericsson is a manufacturer of telecommunications systems and equipment for
wireless and wireline networks. Ericsson has developed telecommunications
equipment which can be used by persons with disabilities It has also been
actively involved in organizations which have continuing dialogue with
members of the disability community and whose goal is to make
telecommunications products accessible to individuals with disabilities. For
example, it is an active member of the TTY Forum which is addressing

The Wireless E-9 11 TTY compatibility requirement Ericsson is also involved
in the University of Oklahoma EMC Center program for the investigation of
the interaction between hearing aids and wireless phones. Ericsson was
selected to be a full member of the Telecommunications Access Advisory
Committee (“ TAAC”) which was established by the Architectural and
Transportation Barriers Compliance Board (“ Access Board’) to assist in
developing accessibility guidelines for telecommunications equipment and CPE
required by Section 255 of the Telecommunications Act of 1996.[2] It has
submitted comments in the Access Board’s Section 255 Yotice of Proposed Rule
Making as well as in the Commission’s Section 255 Notice of Inquiry As a
result of the foregoing, Ericsson is fully qualified to submit comments with
regard to the instant NPRM.

Ericsson is familiar with the Comments being submitted in the NPRM by the
Telecommunications Industry Association (TIA). Ericsson fully supports
the Comments tiled by TIA in all respects since it believes the framework
proposed by TIA will serve to enhance accessibility on the one hand without
undue regulatory burdens being imposed on manufacturers on the other hand.

Among other things, Ericsson supports the ability of a manufacturer to
exercise discretion in incorporating accessibility features within a product
line rather than requiring manufacturers to evaluate the Access Board’s 18
point checklist with regard to every product.

Ericsson also supports the TIA definitions of “accessibility”, “disability”
and “readily achievable.“ With regard to the definition of the term
“disability”, Ericsson agrees with TIA that the term should include only
existing disabilities which prevent or hinder a person from using
telecommunications equipment or CPE as a result of the disability in
question. In this regard, Ericsson notes that the Commission proposes to use
the Access Board’s list of categories of common disabilities that should be
considered in analyzing equipment and service offerings under Section 255
and that the Commission does not view the list as either exhaustive or
final. [3] Though Ericsson understands that there may be legitimate reasons
for not wanting to limit the list of affected disabilities, it asserts that
an open- ended list makes it virtually impossible for a manufacturer to meet
its obligations under Section 255. If a manufacturer does not know that a
given disability or condition is a “disability” within the context of
Section 255. it is impossible for the manufacturer to take steps to
determine if it is readily achievable to incorporate accessibility features
into a product for the disability or condition involved.

Ericsson also supports the substitution of TIA’s “dispute resolution
process” for the Commission’s fast track complaint process In addition to
the time frame for responses to fast track complaints being unreasonably
short, the fast track process will not result in the elimination or
reduction of perceived Section 255 complaints. In fact, the opposite is
likely to occur. TIA’s dispute resolution process on the other hand, will
reduce the number of complaints that have to be adjudicated by the FCC and
will also serve to reduce the resource commitment the FCC has to make to the
Section 255 implementation process. Adoption of the TIA dispute resolution
process will also reduce the resources manufacturers have to commit to
administrative litigation and thereby increase the resources that
manufacturers can devote to try and incorporate more accessibility features
into their products.

Ericsson will continue to strive to make its products more accessible, to
the extent readily achievable. However, it believes the overall level of
accessibility will be increased if the Commission adopts the proposals set
forth in the Comments filed by TIA.

Respectmlly submitted, Ericsson Inc

David C. Jatlow, Ebq Its Attorney

Young & Jatlow 2300 N Street, N. W Suite 600 Washington, D. C. 20037 (202)
663 -9080

June 30, 1998

ENDNOTES
[1] In the Matter of Implementation of Section 255 of the Telecommunication. v
Act of1996 Access to Telecommunication Services, Telecommunications
Equipment, and Custorer Premises Equipment by Persons with Disabilities.
Notice of Proposed Rule Making. WT Docket No. 96-198 FCC Rcd  (released
April 2, 1998) (hereinafter NPRM).

[2] Telecommunications Act of 1996, pub. l. 104-104, 110 Stat.56 (1996).

[3] NPRM, p. 70.