The Rehabilitation Engineering Research Center for Wireless Technologies (Wireless RERC), in collaboration with Georgia Tech’s Center for Advanced Communications Policy (CACP), submitted comments in response to the FCC’s Public Notice, Request for Updated Information And Comment On Wireless Hearing Aid Compatibility (HAC) Regulations [WT Docket Nos. 07-250 and 10-254]. Released on November 21, 2014, the Public Notice sought insight into the current consumer experience, technical or other barriers to the provision of hearing aid compatible mobile phones, and considerations to amend rules for Twenty-First Century Communications and Video Accessibility Act (CVAA) compliance. The Wireless RERC and CACP reaffirmed the belief that the accessibility of information and communications technology (ICT) and services are essential to enhancing inclusion and independence for people with disabilities. Comments were respectfully based on subject matter expertise developed over the past 14 years: findings from consumer surveys and focus groups, policy research, and development efforts. The comments were also largely informed by analyses of data collected via the Wireless RERC’s hearing aid compatibility (HAC) survey research.
The FCC sought to update the record on two principle issues: (1) Whether the FCC should revise the hearing aid compatibility requirement to apply in a technologically neutral manner to all mobile wireless devices; and (2) Whether the FCC should consider moving away from the fractional compliance benchmarks and implement a requirement that all mobile wireless devices must comply with the hearing aid compatibility rules. The Wireless RERC and CACP addressed both issues with the following assertions:
- Ease of finding a compatible phone would be greatly improved if HAC requirements applied to all wireless handsets and would simplify phone selection for people with varying capabilities. For people with hearing loss, when purchasing a handset there are other mainstream and accessibility features to consider in conjunction with HAC compliance. One should not have to sacrifice other phone features to ensure they are purchasing a HAC compliant phone.
- Phones are rapidly changing forms and technologies; the Commission should attempt to create a large tent to encompass as many technologies that might be used in devices with phone features. Most Wi-Fi phones and private internal phone networks interconnect with the public switched telephone network (PSTN) through a gateway so they can be used to make traditional phone calls. …a technologically neutral manner should be adopted.
- Hearing aid users report little improvement in ease of finding a hearing aid compatible wireless handset over the course of implementation of the HAC Act requirements. Substantial proportions of hearing aid users still report their search as being difficult or very difficult. Furthermore, fractional deployment causes problems for consumers in today’s market as more and more consumers are opting to have wireless devices only. These factors indicate it might be time to phase out the fractional deployment rules.
In closing, the comments acknowledged the difficulty of crafting regulations due to the sometimes competing priorities of industry and consumers and the complexity of interaction between increasingly sophisticated and powerful wireless handsets. Nevertheless, they also maintained that people with hearing loss deserve and are entitled to having parity of access to telecommunications services, wireless, or otherwise.
