Before the FEDERAL COMMUNICATIONS COMMISSION 
Washington, D. C. 20554

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

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

WT Docket No. 96- 198


COMMENTS OF THE ASSOCIATION OF ACCESS ENGINEERING SPECIALISTS (AAES) 

The Association of Access Engineering Specialists (AAES) is pleased to file
these initial comments in response to the Notice of Proposed Rulemaking, FCC
98-55, issued in the above- captioned docket. We appreciate this opportunity
to provide the FCC (the Commission) with comments on the implementation of
Section 255 of the Communications Act of 1934, as amended (the Act). 

AAES would like to thank the Commission for its recognition and
encouragement of our efforts, stated in paragraph 160 of the NPRM. AAES was,
in fact, founded based on several models which the Commission and the
Architectural and Transportation Barriers Compliance Board (Access Board)
themselves provided for consensual and cooperative development of various
areas of regulatory interest. We note the close and productive working
relationship the Commission has had for many years with various professional
engineering societies, such as the societies of the Institute of Electrical
and Electronic Engineers (IEEE). In the area of voluntary standards
organizations, there is a long history with various American National
Standard Accredited (ANSI) standard- setting bodies such as those in the
IEEE, the Telephone Industry Association (TIA) and others. In addition, the
Commission has made use of outside expertise in responding to questions
related to assessment of compliance, such as the ANSI C63 sub- committee
which provides opinion, when requested, on how testing for compliance with
FCC Part 15 should be conducted. AAES was founded based upon the firm belief
that such cooperative working relationships result in the best and most
refined regulatory implementation. 

We will restrict our comments to those matters where we believe this
association may be most involved. However, a brief history and overview of
AAES may be in order. AAES was founded to assist in the development of the
field of telecommunications access, provide education in access design and
encourage dialogue between all affected parties with the purpose of
constructing consensus solutions to access issues. 

The concept for AAES was developed during the deliberations of the
Telecommunications Access Advisory Committee (TAAC), which was convened by
the Access Board. A number of the participants felt that there was a need to
establish a neutral coordination point, where all affected parties could
meet and develop the field of telecommunications access. From these
discussions two organizations were approached with a request that they
jointly establish such an organization. The National Association of Radio
and Telecommunications Engineers (NARTE) was selected for its long history
with administering certification and credential programs and the technical
expertise of its members in the telecommunications arena. The Rehabilitation
Engineering and Assistive Technology Society of North America (RESNA) was
selected as the primary organization representing professionals in the field
of rehabilitation and assistive technology. Together these two organizations
represent the two areas of technical expertise which are needed in order to
effectively address access questions. AAES was established as a sub- society
of NARTE, with by- laws approved by that board after review by the RESNA
board. A formal Memorandum of Understanding has been executed between RESNA
and NARTE, providing the formal basis for this partnership. However, while
NARTE and RESNA are the founding hosts, AAES, by design, is inclusive. Many
disciplines, interests and viewpoints must be involved if disability access
to telecommunications is to be effectively developed. For this reason AAES
is actively exploring ways in which it can effectively partner with all
involved organizations. However, AAES is not an organization of
organizations but a technical society with individual membership. It is a
place where those working in the many aspects of this field can join
together, dialogue, develop consensus and develop this field. It is
interesting to note that the first member of AAES is a disability advocate.
The second and third were from two of the largest telecommunications
equipment manufacturing companies. Other members quickly joined from the
telecommunications carriers, academia, research centers, fields of adaptive
technology and other areas. It is with great pleasure that we can report
that the goal of inclusive cooperation in this venture is being realized. 

With this background we would comment positively upon the proposal set forth
in paragraph 160- 161 of the NPRM. First, we would comment that before
complaints are considered there is a need to establish common expectations.
Exactly what does readily achievable access look like in 1998 for the
various classes of equipment covered by this action? What techniques and
technologies are available to implement access today? It is because of the 
importance of these and many other related questions that AAES has selected
educational workshops as its first projects. The first of these workshops
was held in August of 1997 and the second will be held on June 29- 30 of
this year. We believe that much work remains to be done in developing a
common understanding of what readily achievable access means, in terms of
specific product realizations. 

Secondly, should the Commission find the involvement of a neutral party in
an alternative dispute resolution process useful, AAES is willing to serve
such a function. We believe, at this time, our membership is uniquely
constituted to serve such a purpose. 

Third, we note that it may be most effective to refer some questions for
consideration in advance of any complaints. Certainly a number of important
questions can be recognized now. By developing a body of consensus opinion,
before complaints are filed benefits all parties by providing a more secure
and certain basis upon which to act. Those of our members who helped draft
the section of the TAAC report cited in paragraph 161 state that just such a
concept was contemplated there. It was, and is, believed that consumers and
industry, in cooperation with Commission and Access Board staff, should be
able to put forth inquiries, apart from filing complaints, and receive
informed guidance which represents a balanced viewpoint. By developing
consensus opinions on various questions, all parties are benefited. Industry
will be able to develop its products and services with greater certainty.
Consumers will know with greater specificity what to expect from the
implementation of paragraph 255. 

AAES believes that it is unique in providing an organization in which
telecommunications engineers, consumer representatives, rehabilitation
engineers, designers of assistive technology and regulators come together on
an equal and cooperative basis. We look forward to serving our members and
the Commission in developing consensus opinions and assisting in the
effective and efficient development of telecommunications access. 

AAES thanks the Commission for this opportunity to comment on this most
important matter. We look forward to working with the Commission and its
staff in the successful development of telecommunications access for all of
America's citizens. 

Respectfully submitted, 

THE ASSOCIATION OF ACCESS ENGINEERING ACCESS SPECIALISTS 

John Holmberg
Executive Director
NARTE / AAES
167 Village St.
Medway, Ma. 02053
(508) 533- 8333 

June 30, 1998