Center for Independent Living 
Linking Employment, Abilities & Potential 
1917 N. Ridge Road East, Suite C
Lorain, Ohio 44065
(216) 277-8888
(800) 410-LEAP (5327) 
TDD (216) 277-8800 


Federal Communications Commission 
Office of the Secretary, 
1919 WI Street, NW, Room 222 
Washington, D. C. 20554 

June 22,1998 

Dear Sir or Madam: 

Re: FCC's rules proposing to enforce Section 255 of the Telecommunications Act 

In the Telecommunications Act, Congress gave the Architectural and Transportation Barriers
Compliance Board (Access Board) the primary authority to write accessibility 
guidelines for telecommunications equipment manufacturers. Congress also gave the FCC the
authority to enforce those guidelines, and to enforce the requirements of Section 255 
for telecommunications service providers. The guidelines suggest ways for the manufacturers to
achieve access in the design of their products and require product 
information and instructions to be accessible to people with disabilities. 

It is VERY IMPORTANT that the FCC adopt the complete Access Board Section 255 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. Telecommunications access is important to me because I have many 
friends and consumers of our Center for Independent Living who are Deaf and need these
guidelines to assist in their independence. These FCC decisions will have a tremendous 
impact on the accessibility of telephone equipment and services for many years to come. 

The Americans with Disabilities Act (ADA) requires certain buildings to be accessible if achieving
such access is "readily achievable." The term "readily achievable" has a long 
history to it, and for the most part involves a balancing of the costs of providing access with the
overall financial resources of the company which must provide such 
access. Congress adopted the "readily achievable" concept in Section 255 of the
Telecommunications Act. Specifically, Section 255 requires telecommunications providers 
and manufacturers to provide access where it is readily achievable to do so. 

I oppose allowing companies to consider the extent to which the costs of providing access will be
recovered. Allowing this as a "readily achievable" factor would defeat the 
purposes of Section 255. Allowing a company to consider whether it will recover the costs of
achieving such access has never been permitted under other disability laws. 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. PLEASE follow the definition of  "readily 
achievable" as it had been defined in the ADA.

Congress could not have intended to eliminate "enhanced services" from the scope of Section
255. These services are very important and widely used. Enhanced services 
generally include more advanced telecommunications services, such as voice mail, electronic mail,
interactive voice response systems (which use telephone prompts), and 
audiotext information. The whole purpose of Section 255 was TO EXPAND telecommunications
access. If these services are excluded, then people with a variety of 
disabilities will remain SECOND CLASS CITIZENS with respect to new telecommunications
technological advances. 

Telecommunications have already had a major impact on the ability and opportunity for people
with disabilities to learn, work, and participate in the community. Moreover, just as 
telecommunications is becoming increasingly important in the lives of Americans generally, so
also is its significance in the lives of people with disabilities is destined to grow. If 
these services are not REQUIRED to be accessible, people with disabilities will continue to have
fewer employment opportunities, and will NOT be able to fully participate in today's 
society. PLEASE cover "enhanced services" because coverage of these services is CRITICAL to
full telecommunications access. 

The FCC will enforce Section 255 with a complaint process. I support the following proposals by
the FCC: 

-- There should be no filing fees for informal or formal complaints with the FCC against 
either manufacturers or service providers. Waiving these fees would be in the public interest. 

-- There should not be any time limit for filing complaints, because one never knows when 
he or she will discover that a product or service is inaccessible. 

-- Consumers with disabilities should be able to submit complaints by any accessible 
means available. 

-- Manufacturers and service providers should be required to establish contact points in 
their companies that are accessible to consumers with disabilities. 

Telecommunications access is TREMENDOUSLY important to people with disabilities. PLEASE
make sure that the final rules released by the FCC are strong enough 
TO TRULY MAKE A DIFFERENCE in the way people with disabilities can use
telecommunications. Thank you. 


Sincerely, 
Mary M. Butler, LEAPlClL Advocacy & Outreach Coordinator 

Cc: Congressman Sherrod Brown Senator 
John Glenn 
Senator Michael DeWine 
Ohio Representative John Bender 

The United Way of greater Lorain County
 LEAP is a 501 (c) (3) Tax-Exempt, Non-Profit Corporation


Fax (216) 277-9053
email: leap@ kellnet.com 
http://kellnet.com/leapweb