Before the 
               Federal Communications Commission
                     Washington, D.C. 20554
                                
                                
                                
In the Matter of 

Implementation of Section 255 of
Telecommunications Act of 1996 
WT Docket No. 96-198
Access to Telecommunications Services,
Telecommunications Equipment, and
Customer Premises Equipment
By Persons with Disabilities



           REPLY COMMENTS BY LUCENT TECHNOLOGIES INC.
                                
                                
                                
                                                   Diane M. Law
                                              Corporate Counsel
                                             Regulatory Affairs
Law Division
                                       Lucent Technologies Inc.
                                                               
                                                               
Introduction
Pursuant to Section 1.415 of the Federal Communications Commission's Rules, Lucent
Technologies Inc. ("Lucent") respectfully submits the following Reply Comments in
response to the Notice of Proposed Rulemaking, FCC 98-55, released April 20, 1998
("Notice"). The Notice sought comment on issues related to Section 255 of the
Communications Act regarding the accessibility of telecommunications services and
customer premises equipment (CPE) to persons with disabilities.(1) Section 255
requires manufacturers of telecommunications equipment and CPE to "ensure that the
equipment is designed, developed, and fabricated to be accessible to and usable by
individuals with disabilities, if readily achievable."

 In our comments, Lucent voiced full support for the goals of Section 255 and urged
the Commission to implement Section 255 in arealistic manner. Lucent reiterates the
request that the Commission impose standing requirements for complainants that take
into account the special situation of business equipment customers and
manufacturers.(2) Lucent agrees with the Multimedia Telecommunications
Association (MMTA) that employers, not manufacturers, should be the first contact
for employee-based accessibility problems.(3)

 Lucent also supports the Telecommunications Industry Association's (TIA) definitions
of "accessibility," "disability," and "readily achievable" and its dispute resolution
process.(4) Lucent supports TIA's proposals because we believe they will lead to real
increases in the accessibility of telecommunications equipment and CPE without
imposing undue regulatory burdens on manufacturers. 

Finally, Lucent would like to respond to some commenters who have argued that
manufacturers should be solely responsible for Section 255 compliance when
accessibility issues can be resolved only through changes to equipment in carriers'
networks.(5) Lucent agrees with PCIA that the carrier-manufacturer relationship
should be characterized as a partnership designed to ensure that both parties comply
with Section 255 requirements.(6) Telecommunications carriers configure their
networks to their own specifications(7) and make their own purchasing decisions.
Manufacturers work closely with telecommunications carriers to develop equipment to
carriers' specifications. Of course, manufacturers must design and manufacture
"accessible" telecommunications equipment, if readily achievable. Assuming a
manufacturer has complied with this requirement, it should not be held responsible for
accessibility problems that result from a particular carrier's use of equipment or
network configuration. Thus, manufacturers cannot and should not be solely
responsible for carriers' compliance with Section 255.

Conclusion
Lucent fully supports the goals of Section 255 and will strive to make its products
more accessible, to the extent readily achievable. Lucent urges the Commission,
however, to implement Section 255 in a manner that does not impose unnecessary
regulatory burdens or alter manufacturers' incentives to invest in the development of
new accessible technologies. Lucent firmly believes that such a realistic
approach to Section 255 is workable and can yield substantial benefits for consumers
with disabilities.

Respectfully submitted,
Lucent Technologies Inc.

By
Diane M. Law
 Corporate Counsel
Lucent Technologies Inc.
1825 Eye St. NW, 10th Floor
Washington, DC 20006
(202) 756-7092

1.  1 47 U.S.C.  255.
2. See Lucent comments at 11-12.
3. MMTA comments at 22-23.
4. See TIA comments generally.
5. See USTA comments at 4.
6. PCIA comments at 8.
7. Telecommunications carriers, however, may not install network features, functions,
or capabilities that do not comply with the guidelines and standards established
pursuant to section 255 or 256. 47 U.S.C.  251(a)(2).