Below are selected industry comments on FCC's proposed Sec. 255 rules.
Congress intended these rules to make possible greater accessibility of
telecommunications equipment and services for people with disabilities.
The reality may not turn out as intended if industry has its way. The
backlash against independence and full participation has already begun.
It is not too late to stop these critters. Reply comments from the
positions below are still being accepted by the FCC. You can even e-mail
them in. Go to http://www.fcc.gov and go to the disability issues task
force home page there to find the details. The full text of all of the
comments summarized below are available and completely accessible to
all. Let's not end up as roadkill on the information super highway.
kelly
MOTOROLA (annual sales $28 Billion)
--They have suggested to the FCC to fine people with disabilities and
forbid them from filing complaints in the future if during the
complaint process confidential information is disclosed.
MULTIMEDIA TELECOMMUNICATIONS ASSOCIATION (MMTA)
They assert that the FCC should rely on market mechanisms as primary
enforcer of Sec 255. MMTA also said the FCC should require people with
disabilities to complain to employer first if the equipment is not
accessible in the workplace.
BELL SOUTH (telco with net income about $500 million a quarter):
--Says they are not responsible for lack of disability access if they
didn't assemble the product, even if their name is on the product.
--They only want complaints to be made to them by disabled customers,
no one else and must be made within two years (presumably of product
release).
INFORMATION TECHNOLOGY INDUSTRY COUNCIL
( representing more than forty company members in addition to trade
associations) --Says that manufacturers do not have control over
software features and functions in their equipment so they should not
be responsible for accessibility defects.
--They also state that if another company makes 'accessible
equivalent products' then a company has met its obligations.
BRIGHTPOINT (net income first quarter 98 $8.8 million)
--Says they don't think they should be responsible for accessibility
even though they do light assembly, programming and labeling of
products.
BUSINESS SOFTWARE ALLIANCE (BSA)
Includes IBM, Microsoft, Compaq and DEC, and Intuit, Intel, Adobe,
Symantic. --They say "it's wholly impracticable and contrary to the
public interest" to include voice mail, email, etc. under Sec. 255.
CONSUMER ELECTRONICS MANUFACTURERS ASSOCIATION (CEMA)
--They state FCC doesn't have statutory authority to promulgate
mandatory rules for 255. --They also stated that the financial
resources of the parent company shouldn't be considered to make things
accessible if readily achievable. --They also want the FCC to require
complainants with disabilities to contact manufacturer first.
CELLULAR TELECOMMUNICATIONS INDUSTRY ASSOCIATION (CTIA)
--They want the costs associated with complying with any FCC's
regulations for 255 as part of the determination of a readily
achievable product. --They also wants Congress to allocate money to
them to make the network accessible for disability!
NEXTEL Communications Company (98 first quarter revenues of $327
million) --They want regulations that make them "free from frivolous
and harassing complaints".
PERSONAL COMMUNICATIONS INDUSTRY ASSOCIATION (PCIA)
--They want readily achievable to include an `intricate set of
factors' that go beyond current ADA definition.
LUCENT TECHNOLOGIES (annual sales exceed $26 Billion)
-- They say definition of disability should be only people who
experience, as a result of physical or mental impairments, difficulty
accessing telecommunications equipment and CPE and not use the ADA
definition.
SBC (NET income $912 million first quarter of 98)
--They see no difference between "accessible to" and "usable by"
(i.e., as long as the product is accessible, there is no need to have
supported documentation or technical support that addresses needs of
people with disabilities).
TELECOMMUNICATIONS INDUSTRY ASSOCIATION (TIA)
(representing over 900 large and small companies)
--They said the FCC should require people with disabilities who are
directly aggrieved by a perceived lack of accessibility to go to
manufacturer first, not the FCC; --They add that FCC should require
people with disabilities with complaints to provide detailed
information about his or her disability; --Also that the FCC should
require people with disabilities with complaints to report what steps
they have taken to obtain an accessible product before filing a
complaint with the FCC; --TIA predicts dire consequences if they are
forced to make things accessible for people with disabilities under
current FCC proposed rules: - "[Sec. 255 compliance will] damage the
innovation process", and "distort industry towards inefficient small
firms", and "encourage the export of design and manufacturing
employment to overseas". --They say Sec. 255 is "`excessive
regulation" which will have a "`devastating impact on manufacturers".
UNIDEN (with annual sales of $87 Billion)
--says that telecom manufacturers should not have to use the Access
Board's guidelines because they "do not offer the level of specificity
nor the level of detail required by the manufacturers". Note: Uniden
was not at the table during the TAAC process.
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