State of New Jersey Department of Labor PO BOX 052 TRENTON NJ 08625-0052 CHRISTINE TODD WHITMAN Governor MEL GELADE Commissioner June 23, 1998 Martha E. Contee, Chief Public Service Division Office of Public Affirs Federal Communications Commission Washington, D. C. 20554 Dear Ms. Contee: Your recent letter to Commissioner Gelade regarding the Federal Communications Commission Notice of Proposed Rulemaking was referred to me for review and response. The Federal Communications Commission Notice of Proposed Rulemaking is a ponderous and technical document. Succinctly put, Section 255 requires manufacturers of telecommunications equipment and service providers to make every effort to assure that these services are accessible to persons with disabilities. It addresses input, control and mechanical functions: -- Operable without vision -- Operable with low vision and limited or no hearing -- Operable without hearing -- Operable with limited manual dexterity -- Operable with limited reach or strength -- Operable without time dependent controls -- Operable without speech -- Operable with limited cognitive shills It also addresses output, display and control functions: -- Availability of visual information -- Availability of visual information for low vision users -- Access to moving test -- Availability of audio information for people who are hard of hearing -- Prevention of visual induced seizures -- Availability of audio cut off -- Non-interference with hearing technology -- Hearing/ aid coupling In addition, it focuses on peripheral devices such as audio amplification, ring signal lights, TTYs, Braille translators, text-to-speech synthesizers and similar devices. The intent of the regulations appear to require manufacturers to consider the access needs of the disabled in the development and production stages of telecommunication devices. The basic premise with this belief is that the costs will be greatly reduced if accessibility is built into the product off the shelf instead of customized at some later date. The indented rules propose a fast track resolution process to complaints concerning accessibility for the disabled. It is hoped that any non-compliance issues formally voiced will subsequently be resolved in days rather then months through this fast track process. The concept of the equality in access and the attempt to resolve accessibility in a rapid simple fashion is both laudable and desirable. If there may be legal or technical issues hidden in the proposed rules of Section 255 which would have impact on the department we are not aware of them From a vocational rehabilitation perspective, I have no negative comments and support the concepts contained in the proposed regulations. I hope this information is helpful. Sincerely, Mark B. boyd, Assistant Commissioner Workforce New Jersey