HAC Filing

Summary

On Dec. 16, 2007 the Wireless RERC filed comments to the FCC on Amendment of the Commission’s Rules Governing Hearing Aid Compatible Mobile Handsets, WT Docket No. 07-250. The Wireless RERC noted in response to the FCC’s solicitation that ongoing Wireless RERC research suggests that consumers continue to have problems with the interoperability of cell phones and hear aids. In a recent Wireless RERC Delphi Policy study, an overwhelming majority of respondents, identified "device incompatibility or poor interoperability," as a very important or important issue with cell phones. Further, the Wireless RERC's Survey of User Needs (2002-present) continues to find evidence that consumers with hearing impairments have difficulty finding cell phones in the marketplace that are compatible enough with hearing aids. These findings reveal that cell phone users with hearing impairments are running up against barriers to full usability of their device, which could be addressed through the regulatory process.

RERC Comments

January 29, 2008

Marlene H. Dortch, Secretary

Office of the Secretary

Federal Communications Commission

445 12^th Street, S.W.

TW-A325

Washington, D.C.  20554

             Re:     Amendment of the Commission’s Rules Governing Hearing Aid-Compatible Mobile Handsets

Dear Ms. Dortch:

            Enclosed for filing in the above referenced Notice of Proposed Rulemaking

(NPRM) published at 72 Fed. Reg. 65494, are comments of the Rehabilitation Engineering Research Center for Wireless Technologies (Wireless RERC).

            Should you have any questions concerning this filing, please do not hesitate to contact me via phone (404-385-4618) or e-mail (paul.baker@cacp.gatech.edu).

Respectfully submitted,

Paul M.A. Baker

Project Director, Policy

Rehabilitation Engineering Research Center for Wireless Technologies (Wireless RERC)

Director of Research

Center for Advanced Communications Policy

Georgia Institute of Technology

Enclosure

Before the Federal Communications Commission Washington, D.C. 20554

In the Matter of

Amendment of the Commission’s Rules

Governing Hearing Aid-Compatible Mobile Handsets (WT Docket No. 07-250)

Section 68.4(a) of the Commission’s Rules

Governing Hearing Aid Compatible Telephones

(WT Docket No. 01-309) 

Petition of American National Standards Institute Accredited Standards Committee C63 (EMC)

ANSI ASC C63™

COMMENTS OF THE REHABILITATION ENGINEEERING RESEARCH CENTER FOR WIRELESS TECHNOLOGIES (WIRELESS RERC)[1]

The Rehabilitation Engineering Research Center for Wireless Technologies (Wireless RERC), hereby submits the following comments in response to the Second Report and order and Notice of  Proposed Rulemaking adopted on November 7, 2007, WT Docket Nos. 07-250 and 01-309 on Amendment of the Commission’s Rules Governing Hearing Aid-Compatible Mobile Handsets, Section 68.4(a) of the Commission’s Rules Governing Hearing Aid Compatible Telephones, and Petition of American National Standards Institute Accredited Standards Committee C63 (EMC)

ANSI ASC C63™.

The Wireless RERC commends the FCC for its efforts to ensure that access to mobile telephones is available to all Americans, particularly those with disabilities.  Currently it is estimated that more than 18% of the population has some type of disability[2] including 18.6 million with visual disabilities[3], 31 million with hearing loss[4] and 25 million with physical disabilities that impinge on mobility[5].  Further, approximately 35 million (12.4% of total population) are over the age of 65, a population that frequently is subject to functional limitations that impact their ability to fully access mobile communications devices, a population expected to double by 2030.   People with disabilities are estimated to have over $175 billion in discretionary spending power[6].  Clearly these populations are impacted by technological trends and have an impact on the marketplace.[7]  We also make note that the 31 million Americans who are deaf, or who have a hearing loss, represent a vital and growing market for advanced wireless devices, as evidenced by their use of cell phones[8], and wireless texting devices.[9]

In general, while a wide variety of advanced wireless technologies and services have become available in the U.S., significant issues involving access to, and affordability of, these technologies still exist for people with disabilities.

Specifically we wish to comment on the following paragraph:

Additional deployment milestones (¶49)

            In response to the FCC’s solicitation of comment on additional technological and market constraints that should be considered when evaluating any additional future hearing aid compatibility deployments, ongoing Wireless RERC research suggests that consumers continue to have problems with the interoperability of cell phones and hear aids. In a recent Delphi Policy[10] study, an overwhelming majority of respondents, 92 percent, identified “device incompatibility or poor interoperability” specifically, hearing aid compatibility, as a very important or important issue with cell phones. Further, the Wireless RERC's Survey of User Needs (2002-present) continues to find evidence that consumers with hearing impairments have difficulty finding cell phones in the marketplace that are compatible enough with hearing aids.[11]

Preliminary findings reveal that of 1208 respondents to the RERC's Survey of User Needs, more than 20% (N=247) use hearing aids with their wireless devices. Of these hearing aid users, 19.3% indicated that the mobile wireless device they use is either "hard to use", or they "can't use it without help."  When asked to rank the most important features of mobile wireless devices, 65% of these people ranked "compatibility with hearing aids" as their primary concern.

The Wireless RERC also conducted a separate survey in 2007 of cell phone users with hearing aids or cochlear implants. Of 102 respondents, 64 (62.7%) said that it was "difficult" or "very difficult" to find a phone that works with the hearing technology they use.

These findings reveal that cell phone users with hearing impairments are running up against barriers to full usability of their device which could be addressed through the regulatory process.  The Wireless RERC believes that the FCC needs to expand the rules on hearing aid compatible phones to increase the number of models available with M4/T4 compatibility.

Existing advanced telecommunication services allow people with disabilities to more fully participate in community life, and these services have enriched the lives of countless Americans with disabilities. Increased deployment of new services, and access to cost-effective advanced telecommunications services will only further the goals of accessibility set forth by Congress, the Commission, the Americans with Disabilities Act, and President George W. Bush’s New Freedom Initiative.

Respectfully submitted,

Paul M.A. Baker, Director of Research

In consultation with

Ed Price, Project Director

Ben Lippincott, Director, Industry Relations

Jim Mueller, Director, User Centered Research

Lynne Broderick, Manager, Consumer Outreach

Helena Mitchell, Executive Director

Center for Advanced Communications Policy

            and the

Rehabilitation Engineering Research Center for Wireless Technologies

500 10^th Street, 3^rd Fl. NW

Atlanta, GA 30332-0620

Phone: (404) 385-4618

Dated this 20^th day of December  2007