1708 Linden Street South Jacksonville, Illinois 62650-3210 June 25, 1998 Office of the Secretary Federal Communications Commission Washington, D. C. 20554 Re: FCC Proceeding 96-198: Section 255 of the 1996 Telecommunications Act ACCESS to Telecommunications Services, Equipment, & Customer Premise Equipment Dear Mr. Secretary: I am hard of hearing and full telecommunication service continues to be inaccessible. I have covered several points that concern me about the document as proposed by FCC. 1) Please urge your FCC staff to adopt the Access Board guidelines for BOTH manufacturers and service providers. Precise wording must be written so industry will understand their ACCESS responsibilities and obligations in their design of new telecommunication equipment. I can't use my cellular phone with my telephone switch in my hearing aid. The sales people don't understand and the industry's responsibilities and obligations seem to be missing. The cellular phone is INACCESSIBLE. 2) When Congress wrote the Telecommunications Act, it adopted the term "readily achievable" from the Americans with Disabilities Act. FCC wants to use "cost recovery". The cost recovery concept will UNDERMINE the concept of accessibility in our society. Again, telecoils were not mandated for cellular telephones and they don't work with telecoils for hearing aid users like me. 3) There is an uncomfortable feeling about the "complaint process". I do support the proposal not to require filing fees directed at manufacturers or service providers. Please support the waiving of such fees for formal complaints against common carriers. Also it seems that FCC could automatically deny my day in court. I support the right of an individual to file complaints. 4) The proposed rules omit "enhanced services" from coverage under Section 255. These services are INACCESSIBLE to me, ie. automated voice response systems and voice mail. I find it difficult to complete critical calls that are part of these services. Please address this as a critical access issue under Section 255 and if you leave this out, such services severely limits my educational and employment opportunities and would interfere with my full participation in today's society. Please make everything accessible for the hard of hearing. Thank you. Sincerely, Theodore G. Huber, Consumer who is hard of hearing