"Making Full Access A Reality:  
       A Practical Perspective On Translating Vision Into Action"
   Self Help For Hard Of Hearing People, Inc. (SHHH) Annual Convention
                           Kissimmee, Florida
                       (As Prepared For Delivery)
                              June 21, 1996

I.     Introduction

       Thank you. I'm honored to be here today, representing Chairman Reed Hundt and the
Federal Communications Commission.  

       I think it's quite appropriate that SHHH is holding its convention near Disney World. 
One of Disney's legacies is that anything is possible -- and that our only constraint is the limit
of our imaginations.  Likewise, in this new communications era, we can make almost
anything happen -- if we are not hampered by a lack of imagination.  For over a decade,
SHHH has been living this vision, making what was once impossible POSSIBLE for people
who are hard of hearing.  We at the FCC salute your vision and your imagination -- and your
sheer determination.
               
       And let me add that anyone who has followed the Chairman's work at the Commission
knows that he shares your commitment to ensuring full access.  His very real and very
personal dedication to disabilities issues -- and his leadership in this area -- has truly made a
difference at the Commission.  Let me just give you a few examples.

       Last year, the Chairman formed the Disabilities Issues Task Force and appointed
himself Disabilities Commissioner.  The Task Force has played an important role in
monitoring and coordinating all of the Commission's work relating to disabilities issues.  Its
web site, which you can access from the Commission's Home Page, contains information
about ongoing proceedings relating to disabilities, the numerous speeches on the topic, the
Task Force's annual report, Frequently Asked Questions on Disability issues, updates on the
implementation of the Telecommunications Act of 1996, and links to other sites.

       In addition, the Commission is seeking to make all of its processes accessible to those
with disabilities.  Since October, all Commission meetings have been closed captioned.  The
Commission also has received considerable input from all segments of the disability
community, and other Federal agencies, on how it can make its facilities and resources more
available.  In the Wireless Bureau, for example, we have just launched a pilot program to
make our licensing, auctions, and enforcement and outreach processes more accessible.

       The Chairman and all of the Commissioners also have focussed a great deal of time
and energy on substantive issues relating to disabilities.  As I will discuss, implementing the
accessibility and closed captioning provisions in the '96 Act, concluding the Hearing Aid
Compatibility (HAC) wireless process and HAC wireline proceeding, allocating additional
spectrum for assistive learning devices, and improving Telecommunications Relay Services,
are among our highest priorities at the Commission.

II.  The '96 Act:  A Time of Opportunity

       The passage of the '96 Act is a landmark occasion that provides an opportunity for all
of us.  Congress has given us a mandate to foster competition and growth and to ensure
greater consumer choice.  And in no small part because of the tireless work of your
organization and others like it, our Congressional mandate includes ensuring that ALL
Americans share in the benefits of this growth and greater choice.  In short, the promise of
economic growth and greater consumer choice means very little if all Americans don't have
the CHOICE to be consumers.  

       Implementing the provisions in the Act which promote access is one of the
Commission's highest priorities.  The keystone provision of the 1996 Act with regard to
disabilities is Section 255.  This provision requires manufacturers of telecommunications
equipment and CPE and providers of telecommunications services to ensure that their
equipment and services are accessible to persons with disabilities, if readily achievable. 
Section 255 also requires that by August 1997, the U.S. Architectural and Transportation
Barriers Compliance Board -- or Access Board -- develop, in conjunction with the
Commission, initial guidelines for the accessibility of telecommunications equipment and
CPE.  

       The Access Board has convened a Telecommunications Access Advisory Committee,
which has a diverse cross-section of representatives from the disabilities community
(including a representative from SHHH) and the telecommunications industry.  The Advisory
Committee had its first set of meetings last week and will meet several more times before
providing the Access Board its recommendations in January 1997.

       Several staffers from the FCC attended the Advisory Committee's meetings last week. 
In fact, we have been working closely with the Access Board to coordinate our work on
Section 255 since February.  All of us involved in the process know how critical it is that we
all work together, and that we learn from each other, so that we can carry out the provisions
of the law as effectively and efficiently as possible.  To that end, I am proud that the
Wireless Bureau is not only participating in the effort but is coordinating all of the
Commission's work related to Section 255.  In the near future, we hope the Commission will
be releasing a notice on Section 255, which we believe will produce a useful record for the
Advisory Committee as it drafts its equipment recommendations.  And we, in turn, will
benefit greatly from the Advisory Committee's recommendations as we work to implement
this provision.

       The 1996 Act also contains a historic mandate requiring providers of video
programming to ensure that their programming is accessible to people with hearing and vision
disabilities.  Section 713 of the Act requires the Commission to report to Congress by August
of this year on the current availability of closed-captioned video programming, and to develop
regulations promoting closed-captioning within 18 months of enactment of the 1996 Act.  The
Commission is also directed to conduct a study of video description services for people with
visual disabilities.

       In anticipation of the new video programming requirements, the Commission released
a Notice of Inquiry in December 1995, which has now become the basis of the Commission's
implementation of Section 713.  Among the issues that the Commission is considering as it is
drafting its rules is the current availability of closed captioning and video description; the
potential impact of advanced television and digital technologies on the availability of closed
captioning and video description; the cost of closed captioning and video description; and the
market incentives for closed captioning and video devices.  SHHH has provided the
Commission with comments in this rulemaking -- and has given valuable input throughout the
process.  The Commission hopes to issue closed-captioning rules well before their August,
1997 deadline.

III.  HAC-Related Action

A.  Wireline Hearing Aid Compatibility

       Another issue in which I know you've been very involved is the implementation of
The Hearing Aid Compatibility Act of 1988 -- or the HAC Act.  The HAC Act requires the
FCC to take steps to ensure that all essential wireline telephones are compatible with hearing
aids -- and it also requires that all telephones manufactured or imported for use in the U.S.
after August, 1989 be hearing aid compatible.

       The Commission has implemented most of the HAC Act.  In April 1993, in light of
mounting protests from various industry representatives, however, the Commission suspended
regulations that would have applied the HAC Act to all workplace telephones, telephones in
confined settings (such as hospitals and nursing homes), and hotel and motel telephones.

       Last year, the Commission formed a nineteen-member Hearing Aid Compatibility
Negotiated Rulemaking Committee to resolve this controversy.  Members of the Committee
included representatives from the telecommunications industry, other industries affected by
the rules, and consumers with hearing and speech disabilities, including SHHH.  After an
intense negotiating schedule, the Committee reached a full consensus on all work items and
presented its Report to the Commission in August of 1995. The report recommended rules
which would require that, eventually, virtually all wireline phones in workplaces, confined
settings, and hotels and motels to be electro-magnetic coil hearing aid compatible.  The
Committee also recommended that manufacturers be required to provide for volume control of
such phones and to stamp new telephones with the letters "HAC."

       In November 1995, the Commission released a Notice of Proposed Rulemaking
adopting the recommendations of the Committee.  I am happy to report to you that the full
Commission plans to vote on these rules at its open meeting this coming Thursday.
       
B.  Wireless Hearing Aid Compatibility

       We have also been working closely with you on wireless hearing aid compatibility
issues -- and have been happy to see the amount of progress that has occurred since the
January Summit meeting in which the wireless industry, hearing aid manufacturers,
audiologists, and SHHH and other consumer groups participated.  

       As you probably know, about a year ago, SHHH helped to bring wireless HAC issues
to the forefront when, as part of a coalition of hearing disabilities groups called "Hear It
Now," it filed a Petition for Rulemaking with the Commission.  The petition asked the
Commission to address concerns relating to digital PCS devices that create interference and
compatibility problems for hearing aid wearers.  In light of these concerns, industry and
consumers worked together to plan the Summit Meeting in January.  The two-day summit
meeting brought together experts in the field of hearing loss and digital wireless technology to
begin to identify potential accessibility and interference solutions.  

       The meeting was one of the first major events that I attended in my new position as
Chief of the Wireless Bureau.  The two days was very productive for the participants -- they
formed working groups on short-term user and bystander interference issues, long-term user
and bystander interference issues, and hearing aid compatibility -- and agreed to sponsor a
number of tests to understand those issues better. 

       On May 16, the wireless industry, consumer groups, the hearing aid manufacturers,
and the audiologists each issued a separate report to Chairman Hundt.  While the groups were
able to reach consensus on several important issues, they were not able to resolve all of the
issues on the table.  We are confident that this process will continue to move forward -- and
we are happy to assist you in your efforts in any way that we are able.

IV.  Other Items of Interest

A.  Low Power Radio Service Rulemaking

       I thought I would touch on a couple of other items pending at the Commission in
which I know you have an interest.  The low power radio service rulemaking, which
originated in the Wireless Bureau, is moving forward -- I personally read it and signed off on
it a couple of days ago.  

       As some of you may know, low power auditory assistance devices -- or AAD's -- have
been operating on an UNLICENSED basis under Part 15 of our Rules since the 1970's in the
72 MHz band.  These AAD's have experienced increasing levels of interference over the past
several years, as LICENSED users -- such as high power paging systems, public safety users,
industrial users, and land transportation users -- have begun operating in the same band. 
Under our rules, unlicensed users, including users of AAD's, CANNOT cause interference to
licensed users -- and MUST accept any harmful interference caused by licensed users.  

       Four years ago, in a step to provide relief to users of AAD's, the Commission acted to
expand the frequency bands for AAD's to include bands at 74 MHz and 75 MHz.  This action
mitigated the interference problems for users of AADs because the licensed users in these
bands are LOW POWER private land mobile users.  

       The Report and Order that is pending in the Commission would provide further relief
for users of AAD's by permitting the devices to operate on a non-interference basis in the
216-217 MHz band.  AAD's would share the band with law enforcement tracking systems and
point-to-point maritime operations.  This band is preferable to the 72 MHz band, because
there are no licensed users in the band currently, and there will be no HIGH POWERED
licensed users allowed in the band in the future, as long as TV Channel 13 occupies the
adjacent 210-216 MHz band.

       We have worked closely with SHHH on this issue, and we believe that these new
rules will help address many of the problems that users of AAD's are experiencing,
particularly over the medium and long term. We do understand your concerns about how
much you and equipment manufacturers have invested in equipment that operates in the 72
MHz band -- and we pledge to continue to work with you to explore ways to address these
concerns.  In the meantime, let me reiterate that the low power radio service item IS moving
forward, and that I expect the Commission to take action on this in the near future.

B.  Telecommunications Relay Services

       I know that you also have been working with us to improve Telecommunications
Relay Services -- or TRS -- a telephone transmission service designed to give the over 30
million Americans with hearing or speech disabilities "functionally equivalent" access to the
telephone network.  Required under Title IV of the Americans with Disabilities Act (ADA),
TRS has been available on a uniform, nationwide basis since July, 1993.

       In a Notice that the Commission will release in the near future, we will seek comment
on the effectiveness of the current TRS program and on new technologies and possible rule
changes that could improve TRS.  The Notice will also explore how TRS can be improved to
bring more individuals with hearing and speech disabilities within its service capabilities,
including people with severe speech disabilities, people who cannot effectively use text
telephones (TTYs), and people who do not use English as their primary language.  We look
forward to getting your comments on this Notice.

V.  Implementation:  Making The Vision a Reality

       I know that in the months ahead we will continue to work together -- and that your
contributions will be critical to moving these issues forward.  As I said at the outset, we
salute your vision and commitment to achieve what was once considered difficult or
impossible.  You have NOT been limited by your imagination -- or anything else, for that
matter.  And you have a solid record of accomplishments to show for it.

       If I were Chairman Hundt, I probably would spend my closing minutes expanding on
our common vision and setting forth my hopes for the future.  Perhaps what I can add,
though, is a practical perspective on how we translate that vision into action -- and how you
can help us give meaning to our mandates.  

       The first thing I normally tell groups is that it is essential that they participate in our
processes, file comments in our rulemakings, and come meet with us and tell us what's on
their minds.  WELL, .... from what I hear from my colleagues at the Commission, you have
already figured this out and have become effective advocates for your positions.

       I also usually urge groups to build coalitions of support for their implementation plans. 
Building coalitions internally -- or with groups that are your likely allies -- is a necessary but
not sufficient step toward building a more broadly based and diverse coalition.  I suggest you
build broadly based coalitions of support for your ideas for three reasons.

       The first is to foster real understanding.  The issues you  are confronting are
increasingly complex.  So few people understand all the pieces of the puzzle:  the
technological pieces, the regulatory pieces, the disability pieces, the design and marketing
pieces, et cetera.  If we are going to get this right, we have to learn from each other and
understand our different perspectives on implementation.  Your ongoing interference and
compatibility testing with Ericsson and Pacific Bell is a perfect example of the kind of
cooperation and coalition building that I think is essential.

       The second reason you should build broadly-based, diverse coalitions of support will
probably sound tautological:  it makes it more likely that you will achieve your goal -- or
achieve something worthwhile you otherwise would not have.  If you work with potential
adversaries from the outset on implementation strategies, they will feel like they have
"ownership" in the plan and will have a stake in its success.  Reaching a consensus with a
diverse group of stakeholders does not necessarily mean that you have to sacrifice your core
principles.  Your visions and hopes and dreams should be uncompromising and unconstrained,
but your strategy for implementing them should not be. 

       The third reason to build diverse coalitions of support is that it provides you with an
opportunity to work with former or potential adversaries to make some meaningful changes. 
Some companies may initially think that it is in their best interest to be sensitive to disability
issues for public relations purposes.  You have the ability to help them see that being
sensitive to the disability issues -- issues that affect 40 million Americans -- is just good
marketing sense.  

       PacBell's experience, which we learned about at the Access Board Advisory
Committee's meetings last week, is illustrative.  PacBell adopted a universal design policy last
year which has led to innovations that have mass market appeal.  "Talking" Caller ID was
designed to promote access for the blind but is tremendously popular with ALL of its
customers.  And as we learned at last week's meeting, PacBell's experience with universal
design is hardly unique:  such popular innovations as ball mouses on laptops and vibrating
pagers were originally developed as "disability solutions."

       PacBell's experience illustrates a broader point which I would like to leave you with. 
Guaranteeing that all Americans have the opportunity to participate in the telecommunications
revolution is not an AFTERTHOUGHT that is secondary to our aim of fostering competition
and economic growth.  These goals are mutually reinforcing:  ensuring that all Americans
have the choice to be consumers WILL increase the consumer choices of all Americans.  But
we can only continue to discover these mutually beneficial "win-win" solutions if everyone is
at the table and we all work together.  The Chairman makes this point much more eloquently,
so let me conclude with his words:

       "The opportunities of the communications revolution are limitless.  There should be no
limits on who has those opportunities.  Through forging cooperation between public and
private interests we can ensure that all of us have the ability to travel the information
superhighway as it leads us into the new frontier."

       Thank you.