TIA Urges FCC to Retain Existing Hearing Aid Compatibility Requirements

February 2011

The Telecommunications Industry Association (TIA) today filed comments with the Federal Communications Commission (FCC) in response to its request for comments on existing hearing aid compatibility (HAC) requirements. TIA urged the Commission to retain existing HAC regulations, which have been enormously successfully in promoting innovation and accessibility in the wireless market place.

HAC regulations require mobile service providers and device manufacturers to offer a certain amount of hearing aid compatible devices to ensure accessibility by consumers with hearing aids. The percentage benchmarks are a result of a consensus plan developed by consumers, industry, and standards organizations in 2008, with an agreement to review in 2010. TIA comments are part of this review.

TIA, which represents companies that manufacture and supply the products and services used in global communications across all technology platforms, urged the FCC to delay revising HAC percentages or revising technical requirements tied to the standard by stating in its filing that: "Issues concerning the ANSI C63.19-2007 standard should be revised after the 2010 standard is adopted and manufacturers have had the opportunity to test and obtain HAC certification."

On behalf of its members TIA submitted the following comments regarding the Wireless Telecommunications Bureau's Public Notice:

>> TIA should retain the existing benchmarks adopted in 2008 and provide time for manufacturers and service providers to test and deploy new models and services under the current standard.

>> Consistent with Section 710 of the Communications Act, FCC concerns related to HAC requirements would be more effectively addressed through the standards development process. TIA recommended that all relevant industry stakeholders should be presented with the opportunity to engage the HAC industry in that process.

>> The FCC should continue to ensure that information collected under the Accessibility Act not impose an undue burden on manufacturers and service providers. The current reporting requirements, which TIA argued could be streamlined, have proven effective in responding to consumer input.

>> The FCC should not dictate technical standards for handset manufacturers. To do so would jeopardize industry innovation in improving such features as volume control, display screens and backlights.

>> TIA urged the FCC to facilitate collaboration among all stakeholders including the Food and Drug Administration (FDA), in order to facilitate a dialogue among hearing aid manufacturers and hearing aid users.

"TIA members have been integral to the successful implementation of the Commission's hearing aid compatibility policies," TIA stated in its filing. "Consistent with its recently-announced Innovation Package of policy recommendations, TIA submits that by encouraging collaboration among stakeholders and the utilization of voluntary consensus-based standards, the Commission can continue to improve accessibility and encourage innovation, thereby meeting its statutory obligations under Section 710 of the Communications Act and maintaining the enormous success of the Commission's HAC regime."

In its filing, TIA also pointed out FCC Chairman Julius Genachowski's "decision to follow the recent Presidential memorandum to Federal agencies targeting burdensome regulations."

"TIA's members - companies in the information and communications technology industry - are among the most innovative in the world," said Vice President for Government Affairs Danielle Coffey. "President Obama recognizes that, while sometimes regulation is necessary, it is imperative that we carefully consider the impact regulations will have on bringing new and improved products and services to the marketplace."

TIA's comments on HAC are available on its FCC filings page at tiaonline.org.

About TIA

The Telecommunications Industry Association (TIA) represents the global information and communications technology (ICT) industry through standards development, advocacy, tradeshows, business opportunities, market intelligence and world-wide environmental regulatory analysis. Since 1924, TIA has been enhancing the business environment for broadband, mobile wireless, information technology, networks, cable, satellite and unified communications. Members' products and services empower communications in every industry and market, including healthcare, education, security, public safety, transportation, government, the military, the environment and entertainment.

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TIA is accredited by the American National Standards Institute (ANSI). Visit tiaonline.org.