From: "Fernando H. F. Botelho" To: A4. A4( JBOLEY), FCCMAIL. SMTPNLM(" fain_ t@ al. eop. gov") Date: 5/2/98 10: 35pm Subject: comments on Section 255 To whom it may concern, let me start by thanking you for seeking feedback from the general public as well as allowing the delivery of this feedback via email. I would like to strongly agree with the recommendation that equipment manufacturers make information such as manuals readily accessible to the disabled by providing text or ASCII versions of the same to interested parties. These must be up to date and as complete as versions in print and other media provided to the general public. Voice output should also be part of all equipment where this is technically possible, and in the few cases where it is not, industry must adopt an infra-red bidirectional port standard which the disabled will then be able to use to access as well as input information. such ports are extremely inexpensive to produce, so much so, that they should be made a requirement in wide varieties of equipment especially if no other alternative means of input and output is provided. Such a port would allow blind or death individuals to bring their own adaptive input/ output device to interface with a wide variety of equipment in the telecommunications industry as well as banking (ATMs) and other sectors of the digital equipment world. A communication protocol must be standardized and nonproprietary in order for such a requirement to have any positive impact. Development of this standard must be done in consultation with consumer groups, adaptive equipment producers, and telecommunication equipment manufacturers. This obviously, should be made in coordination with groups from every one of these realms internationally in order to make a dramatic difference in the quality of life of the disabled and ensure its long-term acceptance and further justify investments in R& D. Regarding whether services such as voice mail should or should not be considered telecommunication services to be included under section 255; I suggest the common sense test. Voice mail as well as e-mail have become an integral part of telecommunications in the 1990s and the trend is only toward a greater reliance on such means of communication. The implications of this fact as they pertain to Section 255 is that items such as email software, browsing software, and other essential parts of the equipment and software combinations required to make use of email, Internet telephony, W-based email, and voice mail must if section 255 is to be taken seriously, fall under the jurisdiction of the same. Another important, crucial, consideration is that all telecommunications equipment should fall under the requirements set forth under Section 255. By this I mean that not only end user equipment such as telephones but also other equipment utilized throughout the telecommunications network. The disabled are not only users of technology, but are developers, workers, maintenance personnel, scientists, and so forth. It should not be assumed that equipment other than that used by the consumers is not included or otherwise many possibilities of employment, technological development, and innovation are closed to a large segment of society. it would be a disservice to the United States of America as well as other countries following and emulating the innovations brought about here. One comment on factors such as the height in which a public phone may be installed.... Just like the manufacturer specifies the temperature ranges, electrical voltage, and other technical specifications under which the equipment is designed to operate effectively, it also must describe to the otherwise uninformed customer that height of installation is a crucial part for the effective operation of the device. Failure to comply with such a specification would then become a liability of the authority responsible for the installation and maintenance of the equipment. Accessibility is a shared responsibility and ignorance cannot be allowed to become an excuse. Just like producers of aerosol products have no control over whether or not their products will be used over a burning candle but still provide warning regarding flammability, so too should telecommunications equipment producers regarding mis-installation of their products such as the installation of a public phone at a certain height. With regard to cost accounting issues,... it can safely be assumed that if a corporation or industry group argues that accessibility costs cannot be accounted or estimated, that these costs are probably minimal relative to the overall development effort and therefore, in the absence of reliable data cost cannot be allowed to be used as an excuse to avoid compliance with Section 255 requirements. it is once again a matter of common sense and wise business practices that costs of any significance to the bottom line are carefully kept track of.... Microsoft or any other company trying to use bad accounting or what would be called in other circumstances "selective amnesia" or "selective accounting", must not be allowed to avoid compliance with Section 255. Thank you for your consideration, Fernando Botelho