PROGRESS CENTER for Independent Living
June 26,1998 
Federal Communication Commission
Secretary Magalie Salas 
1919 M Street, NW, Room 222 
Washington, D. C. 20554 

Dear Secretary Salas: 
I am writing in response to the Federal Communication's rules proposing to
enforce section 225 of the Telecomunications Act. Implementing these rules
would only weaken the intended purpose of this act -that all telecommunications
manufacturers and service providers make their products and services accessible
to people with disabilities.

That is why I am urging the FCC to adopt the Access Board Section 225
guidelines for both manufacturers and service providers. These guidelines are
needed to provide clear guidance on the obligation of companies to make their
products and services accessible to ALL people with disabilities. I have a speech
disability. I often use the Relay System which expedites my communication
process. This service provides independence for me, both in my professional and
personal life. Without the Relay System, I would have to struggle making phone
calls. 

I am very concerned that under the FCC's proposed rules companies would be
allowed to consider what is 'keadily achievable" in providing services, 
allowing these companies to consider the extent to which the costs of providing
access will be recovered. This would only defeat the spirit of Section 225. After
all, Section 225 of the Telecommunication Act is in existence because the market
failed to respond to the needs of people with disabilities. 

The FCC's proposed rules do not cover "enhanced services" under Section 225,
being deemed information rather than telecommunications services. I can tell you
that if you include these services under Section 225 it would make life fairer for
the disabled community. For instance, I have difficulty accessing my voice mail
at work because I cannot physically respond quickly enough to the commands on
my voice mail message before it defaults, making it frustrating for me to use this
service. 

I strongly reccommend that the FCC adopt the Access Board guidlines instead of
its proposed rules to enforce Section 225. This effort will enable people with
disabilities to have complete access to telecommunications services. I thank you
for your time regarding this matter. 

Sincerely,

Larry Biondi
Advocacy Specialist 

LB8177A 


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