DOCKET FILE COPY ORIGINAL ORIGINAL

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

In the Matter of

Implementation of Sections 255 and
25 1 (a)(2) of the Communications Act of
of 1934, as Enacted by the
Telecommunications Act of 1996;

Access to Telecommunications Service,
Telecommunications Equipment and
Customer Premises Equipment by
Persons with Disabilities

WT Docket No. 96-l 98

MOTION FOR EXTENSION OF TIME

   The Voice on the Net Coalition ("VON Coalition"), pursuant to Section 1.46 of the

Commission's rules, hereby requests an extension of the comment and reply comment deadlines

applicable to the Notice of Inquiry ("NOI") released September 29, 1999 in the above-captioned

proceeding.L' This request is supported by the National Association of the Deaf ("NAD"), Self

Help for Hard of Hearing ("SHHH") and the American Foundation for the Blind ("A,,"), each

of which participated in WT Docket No. 96-l 98.

The current comment and reply comment deadlines are November 14, 1999 and

December 14, 1999, respectively. For the reasons explained herein, the VON Coalition requests

The VON Coalition is a trade association whose member companies are involved in the
development of voice services using data networks, including the Internet. Member
companies include service providers such as DeltaThree, IDT, ITXC, and USA Global
Link, and their suppliers, including Cisco, Intel, Microsoft, Netspeak, and Vocaltec.
Additional information regarding the VON Coalition is available on its website,
<<http://www.von.org>>


-2-

an extension of 60 days for each deadline, or until January 13,200O and February 14,2000,

respectively.

  The requested extension will provide the parties with additional time in which to meet

and discuss their concerns. These discussions should more clearly frame the issues and establish

the basis for a continuing dialogue between the VON Coalition and advocates for the disability

community regarding accessibility.

  In addition, the requested extension alleviates potential concerns regarding the sufficiency

of notice. Such concerns are attributable to a delay in Federal Register publication of the NOI.

Though released on September 29, 1999, as of the date of this filing the NO1 had not appeared in

the Federal Register. Extending the comment and reply deadlines ensures that no party is

disadvantaged due to the delay in formal notice.

  While a 30-day extension of each deadline offers the parties the opportunity to meet and

should alleviate concerns regarding notice, for some parties it may result in a shortened period in

which to prepare reply comments, to the detriment of both such parties and the record.

Specifically, a 30-day extension would move the reply deadline to January 14,2000, thereby

requiring that parties prepare their reply comments, in part, during the year-end holidays. Some

of the organizations involved are closed or operate with reduced staff at the end of December. A

60-day extension both avoids this issue and offers the parties greater flexibility in scheduling

calls and meetings.


-3-

For the reasons stated herein, the VON Coalition respectfully requests that the

Commission grant this motion for an extension of time.

Respectfully submitted,

THE VON COALITION

                    I
Bruce D. Jacobs
Susan M. Hafeli
Fisher Wayland Cooper
Leader & Zaragoza LLP
2001 Pennsylvania Ave. N.W.
Suite 400
Washington, D.C. 20006-l 85 1
(202) 659-3494

Date: October 22, 1999