Learning Disabilities Association of America 
Pittsburg, PA 15234-1349
412/341-1515
FAX 412/344-0224

In the Matter of Implementation of Section 255 of the 
Tecommunication Act of 1998 
WT Dkt 98198 

June 25, 1998


COMMENTS OF LDA, The Learning Disabilities Association of America 

LDA, The Learning Disabilities Association of America submits these comments to
the Federal Communications Commission (FCC) on its proposed Section 255 rules.
LDA is a national , non profit, volunteer organization including individuals with
learning disabilities, their families, and professionals. LDA is dedicated to enhancing
the quality of life for all individuals with learning disabilities and their families, to
alleviating the restricting effects of learning disabilities, and to supporting endeavors
to determine the causes of learning disabilities. LDA seeks to accomplish this
through advocacy, education, research and service and through collaborative efforts.
 
LDA applauds the FCC for issuing proposed rules to supplement Section 255 of the
Telecommunications Act of 1998. Increased access to telecommunications
equipment is critical to expanding employment, educational, and recreational
opportunities for individuals whose learning disabilities make it difficult, if not
impossible to respond readily to a series of spoken instructions. LDA urges the FCC
to adopt the following recommendations so that the needs of individuals with
learning disabilities are fully considered in the design, development, and manufacture
of telecommunications products and services. 

LDA urges the FCC to adopt the Section 255 guidelines issued by the Architectural
and Transportation Barriers Compliance Board (Access Board) on February 3, 1998.
In addition to the guidelines on achieving accessibility, LDA urges the FCC to adopt
and enforce the following guidelines for both service providers and equipment
manufacturers. 

* Individuals with disabilities should be included in market research on products or
services. 

* Individuals with disabilities should be included in design trials and product
demonstrations. 

* Reasonable efforts should be made to validate access solutions through testing
with individuals with disabilities. 

* Manufacturers and service providers should be required to provide access to
product and service information, including their accessibility features. To the extent
that such information is made available to the general public, it should be made
available in accessible formats or modes, upon request, at no extra charge. 


* Substantial changes or upgrades to existing products should be made accessible to
individuals with disabilities. 

* Software, hardware, or firmware that are integral to telecommunications shouid be
covered by the Section 255 rules. 

LDA supports the FCC decision to require an assessment of accessibility and
compatibility for each product. 

LDA urges the FCC to include in its rules accessibility of advanced
telecommunications technologies, such as voice mail, electronic mail, interactive 
telephone prompt systems, and interment telephony as well basic telephone services.
 
LDA recognizes the need to balance the costs of including an access feature in the
overall financial resources of the covered entity. LDA opposes allowing 
consideration of the extent to which an accessible product can be marketed and the
extent to which costs can be recovered . The only reason an accessibility law such as 
Section 255 was needed is because the market did not respond to the needs of
people with disabilities 

LDA supports many of the FCC proposals concerning consumer complains, but 

* asks for clarification of the means available to seek redress under Section 255, and
 
* opposes the rule that would require consumers to first receive approval from the
FCC before being permitted to bring a formal FCC complaint. 


LDA thanks the FCC for the opportunity to submit these comments and urges the
FCC to act promptly in issuing rules that will fully ensure telecommunications access
by individuals with learning disabilities. 

Respectfully submitted

Harrison Sylvester, President, 
LDA, Learning Disabilities Association of America 



Web site: http://www.ldanatl.org 
e-mail: ldanat@usaorg.net
A National Non-Profit Organization