June 23, 1998

Federal Communications Commission
Office of the Secretary
1919 M Street, NW, Room 222
Washington, D. C. 20554 

Dear Sir:

The NC Assistive Technology Project provides information to people of all
ages and all disabilities about equipment that assists them in becoming more
independent. Access to telecommunications is essential for people with
visual, hearing, and physical disabilities because it enables them to be
interactive, contributing members of society. Systems also must be
accessible to insure the safety of the individual who must communicate in
crisis situations. For these reasons, I am writing to urge adoption of the
Architectural and Transportation Compliance Board (Access Board) Section 255
guidelines for accessibility in telecommunications equipment. These
guidelines issued last year by the Architectural and Transportation
Compliance Board suggest ways for manufacturers to achieve access in product
design. The guidelines also require accessible product information and
instructions for people with disabilities. The accessibility law stated in
Section 255 of the Telecommunications Act was necessary in the first place
because the telecommunications market was not responsive to the needs of
people with disabilities. When considering whether the access is readily
achievable, I urge that the FCC apply the definition of readily achievable
as defined in the Americans with Disabilities Act. 

Enhanced services such as voice mail, electronic mail, interactive voice
response systems using telephone prompts and audiotext information have
become commonplace. Although the FCC’s proposed rules do not cover “enhanced
“ services, they need to be included under Section 255. Excluding these
services from Section 255 will keep people with disabilities, such as those
who are deaf or hard of hearing and those with motor limitations, from
accessing new, widely used technological advances. 

Finally, enforcing section 255 with a complaint process is essential.
Telecommunications companies, both manufacturers and providers, need to have
contacts that are accessible to persons with disabilities. I am in support
of proposals by the FCC that there be no filing fee or time limit for filing
complaints. Submission of complaints needs to be by any accessible means. 

Thank you for the opportunity to provide comments. Sincerely, 

Ricki Cook Project Director