DISABILITY RIGHTS EDUCATION AND DEFENSE FUND
2212 - 6th Street
Berkeley, CA 94710
(510) 644-2555

June 22, 1998

Federal Communications Commission
Office of the Secretary,
1919 M Street, NW, Room 222
Washington, D.C.  20554
REGARDING WT Docket No. 96-198, IMPLEMENENTING Section 255 of the
Telecommunications Act of 1996
Dear Sir/Madam:
     The Disability Rights Education and Defense Fund strongly urges the
FCC to take the following positions in this regulation:
1.   The FCC should fully adopt  the Access Board Guidelines, for both
manufacturers and service providers!  These guidelines are needed to
provide clear guidance on the obligations of companies to make their
products and services accessible.
2. We strongly oppose the "cost recovery" concept.  The FCC proposes to
allow companies to be able to consider whether they will be able to recover
the costs of providing access, and the extent to which they will be able to
market an accessible product.  These factors may allow a company to get out
of its access obligations merely because the market for certain accessible
products may be smaller.  This goes against the whole purpose of Section
255.  Section 255 was intended to require access to people with
disabilities because market forces alone were not enough to ensure that
access.  Allowing a company to consider whether it will recoverthe costs of
achieving such access has never been permitted under other disability laws.
     Allowing this as a "readily achievable" factor would defeat the
purposes of Section 255.  The only reason we needed an accessibility law
such as Section 255 is because the market did not  respond to the needs of
people with disabilities.
3. We support Enhanced Services.

4. We strongly support a complaint process with no filing fees and no time
limits.  Companies must allow complaints in alternative format; and require
accessible company contact points (such as via TTY).
Yours truly,


Marilyn Golden
Policy Analyst



___________________________

Marilyn Golden
mgolden@wli.net
Disability Rights Education and Defense Fund

Please note!  New e-mail address above.