Without such a framework, I am concerned that we risk providing the telecommunications industry with a vague and cumbersome mandate that will result in costly and complex complaint proceedings rather than cooperative and innovative solutions. I do not believe Congress intended such a result. While TIA's member companies not only make the kinds of equipment but also provide the sorts of telecommunications services covered by Section 255, the following perspectives are chiefly those of equipment manufacturers and suppliers to the telecommunications industry. As means of oversight, policy statements and guidelines are to be preferred to rules, so long as they provide clear criteria for resolution of disputes. TIA recommends, at least initially, that enunciation of policy through statements or guidelines be the preferred approach.
Rules are relatively inflexible and difficult to amend or delete when changes are needed.
Moreover, the results from the Access Board will be in the form of accessibility guidelines for equipment. In its singular responsibility for resolving complaints, the FCC needs to satisfy itself that the Access Board's guidelines are workable, equitable and clear. Definitions must be consistent with the use of terms in TA 96 as a whole, and with the ADA where referenced. In Section III, the NOI asks for comment on several definitions. The definitions are discussed at NOI 9-10.