12276 Casero Court 
San Diego, CA 
June 27, 1998 


Office of the Secretary
Federal Communications Commission
Washington, DC 20554 

Re: FCC NPRM, section 255 of the Telecommunications Act of 1996 


Dear Members of the Federal Communications Commission: 

Telecommunications services are vital to all Americans no matter what their
status in life. Those of us with a disability such as hearing loss must rely on
special forms of those services as well as technical accommodations in the
equipment we use to communicate with others on a day-to-day basis. 

I fear the FCC proposal is at variance with Congressional intent of ensuring
telecommunications access filr the disabled population and, ifsome of its
provisions are enforced, will eliminate many of the accommodations we have
come to depend upon. 

1. The Access Board guidelines must be adopted for both manufacturers and
service providers with specific language incorporated so that they will fully
understand their access responsibilities and obligations in their design of new
equipment.

--Time and again I have asked for assistive listening systems in theaters and
public facilities only to be handed a device which cannot be used with my
telecoils and neckloop or my boot cord. Both of these allow me to continue
wearing my hearing aids (which have been specifically designed for my
individual hearing loss) while using an assistive device. Having to rely on the
device provided (an earphone-type), I no longer have the features my own
aids provide for clarity; moreover, the device's across-the-board volume
increase makes some frequencies painfully loud while failing to amplify 
others sufficiently for me to understand the dialogue. Manufacturers and
theater owners must understand that with such an inadequate device they are
not providing access for all people with severe hearing loss or cochlear
implants. 

-- Frequently I encounter telephone booths equipped with fluorescent lighting
which is notorious for creating a loud hum in one's telecoils (needed to hear
over a phone). What possible good can the bright lighting be when any
conversation over the line is overpowered by the noise? 

-- Public phones in busy places such as shopping malls, airports, hotel lobbies,
etc. more often than not do not have any volume enhancement capability, and
many that are so equipped do not boost the volume sufficiently for some of
us. The manufacturers must understand that accessibility is required by law
and enforced by the FCC. 

-- Just yesterday I was considering buying a TV and was chagrined to
discover in one model that the closed captioning was only available when the
TV was in "mute" mode What about the other members of my family who are
not hard of hearing? Or did the manufacturer assume that only a hard of
hearing person would be using the TV? 


2. The term "cost recovery" and its concept is unconscionable. The reason we
now have the ADA and other accessibility laws is because a stimulus had to
be given to bring about accessibility for disabled people. If left to itself, the
business world would not have made the changes necessary, because those
accommodations do cost money, money that often is not completely
recovered. The ultimate benefits, however, far outweigh the initial cost. 

Americans basically believe in looking outfor our fellow man and providing
equal access. 

-- Most hard of hearing people cannot currently use analog cellular phones
because they are not telecoil compatible; that requirement was not written into
law, so manufacturers have not jumped to provide that feature. Yes, its cost
might not be recoverable, but countless hard of hearing people would feel
safer if they had a usable cellular phone in their pocket, purse or car for
emergencies! 

-- What a blessing it is for us to find text message boards in airports and text
boarding information at the gate. Those airlines providing this service have
our gratitude and loyalty; those who do not provide these accommodations
probably have not done so because of the cost feature and because the law
does not insist they comply. 

3. Regarding the complaint process: 

-- Specifying that a consumer's complaint must be resolved within five days
assumes that all complaints are simple ones. Such is not the case, and by
limiting the resolution process to five days no consideration is given to a
company's need to gather information not only on the complaint itself but also
on the possible means available to resolve that complaint. Ten days seems like
a more realistic time frame with the added possiblity of extension to 30 days
for those who indicate a reasonable need. 

-- I heartily approve your proposal to allow an individual to file without fee a
complaint against manufacturers or service. Please include also complaints
against common carriers. The public interest is best served when individuals
can easily lodge complaints. 

-- With the same thought in mind, preventing someone from lodging a
complaint merely because the FCC chooses to do so denies us all the right to
be heard fairly. Please reconsider this particular aspect of your proposal. 



4. "Enhanced services" must be included under Section 255! Voice mail and
automated voice response systems, so common today, are impossible for
many hard of hearing people to understand. Ears affected by hearing loss,
even when properly fitted with hearing aids, cannot process sound as quickly
as normal ears; by the time the first word or two are deciphered, the speaker
is already on to the next sentence. In many cases a hard of hearing person just
plain cannot hear the sound of the instructions over the phone because more 
volume is required. TTY relay services are of no assistance in this situation
due to the lengthy time required for the relay operator to type out the
instructions. 

I do not believe Congress intended for hard of hearing people to be denied
this coverage. WE need access just as much as people with normal hearing!
Too great a part of telecommunications today stems from these enhanced
services whether it be for business calls, medical assistance, employment,
educational purposes or service agencies. 

We need an "automatic out" whereby the caller could be connected to a live
person. 

-- How helpful an automatic out would have been when I was trying to find
out the arrival time of my husband's flight last week. The automated flight
information service was one question after another, one number to push after
another, an impossible series of sounds for my ears to fathom. I finally took
my chances and headed for the airport far too early just in case he should
come in ahead of time. 

-- The same situation arose recently when I tried to find out what time
"Titanic" would be shown with captioning at a theater in Ontario. Advanced
publicity said one performance would be captioned and to call for details. I
called, and what did I get? A recording which was completely unintelligible to
me. Common sense would indicate that someone needing captioning would
not be able to understand a recording! Yet even when I asked my husband to
listen to the recording, no mention was made of a captioned performance. It
took several other calls through Directory Assistance to finally reach a live
person who could provide the needed information. This is not "access" as
intended by Section 255 of the Telecommunications Act! 

Despite the aforementioned difficulties, as a hard of hearing person I do feel
fortunate to be living in these times when I can participate in society and
communicate fairly freely in most situations. For this I credit the ADA and
other accessibility laws enacted by wise, fair and caring legislators. 

Please don't allow accessibility for hard of hearing people to regress to the
heartless conditions and stigma under which my mother and her father
struggled to maintain dignity while advancing years gradually destroyed their
hearing and their ability to communicate. 

Thank you. 
Sincerely, 

Joan P. Ireland