Before the 
               Federal Communications Commission
                         Washington, DC


In the Matter of       
Implementation of Section 255 of the     
Telecommunications Act of 1996          

 WT Docket No. 96-198

Access to Telecommunications Services, 
Telecommunications Equipment, and     
Customer Premises Equipment           
By Persons with Disabilities         



     I am an advocate and a deaf person who has been involved with
telecommunication issues for the past 10 years, mostly on the local level.  I am Vice
President of the DC Association of Deaf Citizens(DCADC).  I am also a DCADC
representative to the DC Telecommunication Relay Service Advisory Board and a
member of several national organizations serving the deaf.  After the passage of the
Americans with Disabilities Act (ADA), I was one of the leaders who worked with the DC
Public Commission Service to create the DC Relay Service.

     I urge the FCC to support and adopt the Access Board Guidelines as written.  I
feel the FCC's NPRM isn't clear whether they will fully support the Guidelines.  The
Guidelines are fair and would go a long way towards achieving access to
telecommunication products.  These guidelines (as adopted) are needed to provide
clear guidance on the obligations of companies to make their products and service
accessible.

     I oppose allowing the companies the discretion of determine the extent to which
costs of providing access will be recovered.  The reason for Section 255 is because the
market did not respond to the needs of people with disabilities.  I believe the Access
Guidelines made it clear that it is cheaper to design products and services at the
beginning of the development.  As an example of today's product that incorporate
universal design, you'll find many people carry pagers and they are either set to beep or
vibrate.  However, I'm positive that the majority of the pagers which are set to vibrate is
because it is not to disturb others.  The vibration technology is a great benefit to deaf
people and there was little or no "cost recovery" for the companies concerned.  Another
example is a TV with built in captioning.  It cost the manufacturer very little to add the
decoder chip and they fully recovered the cost when they mass-produce the TVS.

     Modems should include the TTY/ASCII standard known as V.18 which was
developed standard by ITU-T.  The modem manufacturers haven't fully embraced the
V.18 standard because they don't think it will benefit anyone.  That's not true.  Many of
the non-deaf modem users would be able to call their deaf relatives, friends, clients,
etc.  This will not be a burden on the companies because just like the TV with built in
decoder, they can increase the cost by a few dollars and recover the costs of
development in short order.

     I am concerned that the FCC did not consider important and widely used
services such as voice mail and electronic mail in the scope of Section 255 because
they are considered information services.  I disagree.  For example, voice mail may be
considered an "enhanced service" by the local Bell companies, however, they are
regulated by their state's Public Service Commission (PSC).  The PSC sets parameters
and prices for the voice mail and they are widely being used by the public.  As time
goes by, voice mail may become as basic as phone services (or adjunct-to-basic
service).  Let's look at the touch tone phone: In the past, Bell companies (and PSC's)
consider touch tone as an enhanced service and charge extra for it.  However, more
and more Bell companies are now including touch tone as part of their basic services
(or adjunct-to-basic service).  If an enhanced service such as voice mail cost a few
dollars a month for the telephone users, why can't a deaf person pay the same few
dollars a month just to have access to their own TTY mail?  This is asking for like the
same type of services the majority of the public is using.  Don't just deny us and leave
us out of these services.  One note, the President of DCADC lives with a non-deaf
roommate and they share the same phone number.  She expressed to me one day that
she's looking forward to having a "TTY/Voice Mail" that can benefit the service to each
of them.  The deaf community was lead to believe this would be covered by Section
255.

     I am concerned the that FCC believes the Operator Services for the Deaf (OSD)
seems to meet the need as "adjunct-to-basic services" and assumes that the current
OSD (presently run by AT&T, Sprint and MCI) meet the needs for the TTY users.  I
disagree.  When using one of the OSD, I have to pay a fee to obtain a phone number. 
Allow me to quote from my Section 255 Reply Comments to the Notice of Inquiry filed
with the FCC on November 27, 1996:
          The common carriers should have TTY lines for the deaf/hard of
          hearing to call in for operator assistance as well as for getting
          phone numbers (through 411).  If the common carriers choose not
          to have TTY Operator or 411 Services, they should contract to a
          vendor to do it.  Currently, as a TTY user, if I call the AT&T
          Operator Service for the Deaf (OSD), I will be charged a fee to get
          a phone number.  I can't even call the 411 from the DC Relay
          Service.  In DC (which I'm quoting from the Bell Atlantic (BA)
          Phone Directory), "Residence customers have a monthly allowance
          of five Directory Assistance calls per line.  Calls over that allowance
          cost 36 cent each." 
               I support the FCC's proposal regarding the complaint process.  I believe it is fair
and reasonable.     

     Let's not allow just the plain, old, simple and very basic products and services to
be accessible -- let's allow other products and services to be covered because millions
of Americans are using them and taking advantage of them.  The deaf community feels
as though the rest of us take such things for granted while we do not.  Let's stop this
and mandate that companies serve us and they will realize that the services will benefit
other Americans too.

     Thank you for the opportunity to comment on this important matter.


                                        Respectfully submitted,



                                        David J. Nelson



June 30, 1998