Office of the Secretary
Federal Communications Commission 
Washington D. C. 20554 


Dear Sir, 

My comments on the NPRM for Section 255 of the Telecommunications Act follow: 

1. It is strongly recommended and urged that the FCC adopt the Access Board
guidelines which is consistent with the Access Board authority given by Congress and
which indicated that the FCC guidelines be consistent with them. 

2. It is firther recommended that the FCC adopt the Access Board guidelines for both 
manufacturers and sevice providers. Clear and consise wording to that effect is needed
to ensure that both manufacturers and service providers understand their access
responsibilites and obligations in their design of new equipment. After considerable
time and a lot of meetings and discussion there seems to be litte progress made in
eliminating the interference to hearing aids suffered when trying to use digital cellular
telephones. I have tried several different manufacturer's phones but all have had the
same problem. With the decline of analog cellular telephones, all of which have
insufficient compatibility with hearing aids, use of Digital Cellular Telephones may
soon be necessary. 

3. The FCC should NOT introduce the concept of "cost recovery" in the definition of
"readily achiviable" but should be consistent with he definition that has traditionally
been used in disability law. Introducing the cost recovery concept here would
undermine the concept of accessibility in our society. Since market forces do not work
it was necessary to have a law such as the ADA to require accessibility. Manufacturers
and service provider already have protection from excessive costs under the present
"readily achievable" standard. I find that in order for me to use any telephone it is
necessary for me to use my "I" coils but lack of the ability to uses this feature in 
cellular telephones has prevented my use of any cellular telephone either analog or
digital! 

4. The NRPM or Section 255 of the Telecommuniations Act provides that the
regulations be enforced via a complaint process which is good for the consumer but
the proposed "fast track" process that would resolve most consumer complaints within
5 days seems too short a time for companis to gather documentation to resolve a
complaint. 10 days would seem to be more reasonable with a possible extension to 30
days if deemed necessary! 

I agree with your proposal that there be no filing fees for complaints directed against 
manufacturers or service providers. 

The proposed Section 255 rules tirther states that it will establish formal legal
pocedures for use only when the complainant requests these procedures and "where
the FCC permits the complainamt to invoke these procedures". I thoroughly disagree
with the statement in quotes as this would take away the right of of individuals to take
a case to court if the FCC chases to oppose such action., I believe conditioning formal
complaints upon FCC approval is unprecendented and unfair that individuals could
automatically be denied taking a case to court because the FCC choose to oppose such
action. 


5. The proposed rules omit "enhanced services" from coverage. The enhance services
include voice mail and automated voice response response system. As a Hard of
Hearing person, I can never understand fast speech and voice response systems are
very frustrating. It is recommended that each such system have a means for the hard of
hearing person to speak to a person and it is urged that such requirement be made part
of the rules. When getting such responses I must rely on a hearing person to make
such calls for me! 


Respectfully submitted, 


George DeVilbiss