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 PUBLIC  NOTICE  Federal  Communications  Commission  445  12th  St.,  S.  W.  Washington,  D.  C.  20554 
 DA  00-  1811 
 Released:  August  9,  2000 


 TANDY  CORPORATION,  WALKER  EQUIPMENT  AND  AMERIPHONE, 
 INC.  SEEK  WAIVER  OF  HEARING  AID  COMPATIBILITY  VOLUME 
 CONTROL  STANDARDS 
 47  C.  F.  R.  §  68.317(  f) 


 NSD-  L-  00-  17 
 NSD-  L-  00-  22 
 NSD-  L-  00-  63 


 Comment  date:  September  7,  2000 
 Reply  Comment  date:  September  22,  2000 


 On  February  8,  2000,  Tandy  Corporation  filed  a  petition  with  the  Commission  for  waiver  of  68.  317(  f)  of  its  rules,  47  CFR 
 68.  317(  f)  in  order  to  register  under  Part  68  a  cordless  telephone  with  a  feature  that  preserves  a  loud  setting  from  one  use  of 
 the  telephone  to  another.  On  February  23,  2000,  Walker  Equipment,  a  Division  of  Plantronics,  Inc.  filed  a  petition  for 
 waiver  of  the  same  rule  for  various  models  of  corded  and  cordless  telephones  with  a  similar  feature.  On  May  9,  2000 
 Ameriphone,  Inc.  also  petitioned  to  waive  the  rule  for  an  analog  phone  with  this  feature.  We  are  consolidating  these 
 petitions  because  they  raise  the  same  questions  of  policy. 


 All  terminal  equipment  sold  in  the  United  States  and  connected  to  the  public  switched  telephone  network  (PSTN)  must  be 
 registered  under  Part  68  of  the  Commission's  rules,  see  47  C.  F.  R.  §  68.2.  The  Part  68  registration  process  requires  a 
 device  to  conform  to  specifications  designed  to  prevent  harm  to  the  PSTN.  If  an  applicant's  device  meets  Part  68 
 requirements,  the  Commission  issues  a  registration  number  for  it,  thereby  requiring  local  exchange  carriers  to  permit  its 
 connection  to  the  PSTN  in  the  United  States.  A  waiver  of  Section  68.  317(  f)  requested  by  the  above-  mentioned  Petitioners 
 would  allow  them  to  register  their  telephone  despite  the  fact  that  the  telephone  does  not  meet  some  of  the  technical 
 requirements  of  this  section.  A  request  for  waiver  of  one  or  more  requirements  of  Part  68  does  not  excuse  an  applicant 
 from  meeting  the  requirements  for  which  the  applicant  did  not  request  waiver. 


 The  Commission  will  not  waive  any  provision  of  its  rules  unless  good  cause  is  shown,  see  47  C.  F.  R.  §  1.3.  Under  the 
 relevant  case  law,  the  applicant  has  the  burden  of  showing  good  cause  for  a  waiver:  "[  a]  n  applicant  [for  a  waiver]  faces  a 
 high  hurdle  even  at  the  starting  gate."  WAIT  Radio  v.  FCC,  418  F.  2d  1153,  1157  (D.  C.  Cir.  1969).  Nevertheless,  an 
 agency  must  take  a  "hard  look"  at  applications  for  waiver,  id.,  and  must  consider  all  relevant  factors.  See  Citizens  to 
 Preserve  Overton  Park,  Inc.  v.  Volpe,  401  U.  S.  402,  416  (1971).  An  agency  must  adhere  strictly  to  its  rules  unless  a  party 
 can  show  "reasons  why  in  the  public  interest  the  rule  should  be  waived."  FPC  v.  Texaco  Inc.,  377  U.  S.  33,  39  (1964). 
 Finally,  "[  t]  he  agency  must  explain  why  deviation  better  serves  the  public  interest  and  articulate  the  nature  of  the  special 
 circumstances  to  prevent  discriminatory  application  and  to  put  future  parties  on  notice  as  to  its  operation."  Northeast 
 Cellular  Telephone  Company,  L.  P.  v.  FCC,  897  F.  2d  1164,  1166  (D.  C.  Cir.  1990). 


 News  media  information  202  /  418-  0500 
 Fax-  On-  Demand  202  /  418-  2830 
 Internet:  http://  www.  fcc.  gov 
 TTY  202  /  418-  2555 
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 Subparagraph  (f)  of  47  CFR  68.317  requires  that  if  a  telephone  allows  a  gain  in  Receive  Objective  Loudness  Rating 
 (ROLR)  of  more  than  18  dB,  it  must  reset  to  a  nominal  setting  after  being  returned  to  the  on-  hook  state.  The  purpose  of  the 
 requirement  is  to  protect  individuals  without  reduced  hearing,  who  may  use  the  same  telephone,  from  a  sudden  loud  noise 
 that  could  damage  their  ears.  We  note  that  the  volume  control  requirements  are  the  result  of  a  rulemaking  process  that 
 included  a  regulatory  negotiation  committee  of  consumer  and  industry  representatives,  and  that  the  rules  have  just  gone  into 
 effect  this  year. 


 Petitioners  argue  that  their  telephones  would  meet  the  special  needs  of  people  with  hearing  disabilities  by  eliminating  the 
 task  of  having  to  reset  volume  control  each  time  a  telephone  is  taken  off-  hook.  Ameriphone  describes  another  benefit  as 
 eliminating  the  problem  of  missed  dialogue  at  the  beginning  of  a  phone  call  before  the  volume  is  reset.  Petitioners  state  that 
 their  volume  reset  defeat  features  can  be  turned  on  and  off  without  risk  of  accidental  change,  thereby  facilitating  appropriate 
 use  in  either  a  single  user  environment  of  someone  who  needs  amplification  or  a  multi-  user  one  containing  both  persons  with 
 and  without  hearing  disabilities.  Tandy  Corporation  and  Walker  Equipment  claim  that  their  telephones  protect  hearing 
 because  acoustic  pressure  limits  are  still  met.  Ameriphone  contends  that  risk  of  injury  is  minimal  because  of  warnings  on 
 its  telephone,  and  the  sensitivity  of  a  telephone  owner  with  a  hearing  disability  to  protect  the  hearing  of  other  users.  The 
 petition  by  Ameriphone  includes  a  letter  in  support  of  its  telephone  from  a  relevant  consumer  organization,  Self  Help  for 
 Hard  of  Hearing  People,  Inc. 


 We  note  that  a  Petition  for  Partial  Reconsideration,  filed  December  20,  1999  in  WT  Docket  No.  96-  198,  requests  an 
 increase  in  the  minimum  required  adjustable  gain  for  volume  control  on  telephones.  In  that  petition,  the  Council  of 
 Organizational  Representatives  asks  the  Commission  to  reconsider  its  decision  to  require  a  minimum  18  dB  gain,  and 
 instead  adopt  a  20  dB  gain  level  consistent  with  the  Access  Board's  guidelines.  The  Council  notes  that  "[  a]  two  decibel 
 increase  in  a  telephone  headset  volume  is  a  significant  logarithmic  volume  increase  .  .  .  Therefore,  a  small  increase  in 
 decibels  represents  a  great  increase  in  intensity."  In  a  separate  public  notice,  published  in  the  Federal  Register  on  July  7, 
 2000,  the  Commission  set  a  deadline  for  filing  oppositions  and  replies  to  that  petition.  Commenters  to  the  instant  Part  68 
 volume  control  waiver  requests  should  indicate  what  impact  a  20  dB  gain  for  telephone  volume  control  may  have  on  persons 
 without  hearing  disabilities  if  the  Commission  were  to  grant  this  waiver  and  the  Petition  for  Partial  Reconsideration  in  WT 
 Docket  No.  96-  198. 


 Comments  responding  to  this  public  notice  must  be  filed  with  the  Commission  by  September  7,  2000,  and  reply  comments 
 by  September  22,  2000.  Such  comments  should  reference  the  file  numbers  NSD-  L-  00-  17,  NSD-  L-  00-  22  and  NSD-  L-  00- 
 63.  They  should  include  specific  information  about  the  impact  of  this  proposed  waiver. 


 Comments  should  be  sent  to  the  Office  of  the  Secretary,  Federal  Communications  Commission,  445  12th  Street,  SW,  Room 
 TW-  A325,  Washington,  DC  20554.  Two  copies  of  the  comments  should  also  be  sent  to  the  Network  Services  Division, 
 445  12th  Street,  SW,  Room  6-  A207,  Washington,  DC  20554. 


 The  full  text  of  this  document,  the  waiver  petitions,  and  public  comment  will  be  available  for  public  inspection  and  copying 
 during  regular  business  hours  at  the  FCC  Reference  Information  Center,  Portals  II,  445  12th  Street,  SW,  Room  CY-  A257, 
 Washington,  DC  20554.  This  document  may  also  be  purchased  from  the  Commission's  copy  contractor,  International 
 Transcription  Service,  Inc.  (ITS),  1231  20TH  Street,  NW,  Washington,  DC  20036,  telephone  202-  857-  3800,  facsimile 
 202-  857-  3805,  TTY  202-  293-  8810. 


 For  further  information,  contact  Jamal  Mazrui  at  phone  (202)  418-  0069,  email  jmazrui@  fcc.  gov,  or  Susan  Magnotti  at 
 phone  (202)  418-  0871,  email  smagnott@  fcc.  gov  of  the  Network  Services  Division,  Common  Carrier  Bureau.  The  TTY 
 number  is  (202)  418-  0484. 


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