Federal Communications Commission FCC 07-110 
STATEMENT OF 
COMMISSIONER JONATHAN S. ADELSTEIN
Re:  IP-Enabled Services; Implementation of Sections 255 and 251(a)(2) of the Communications Act of 
1934, as Enacted by the Telecommunications Act of 1996: Access to Telecommunications Service, 
Telecommunications Equipment and Customer Premises Equipment by Persons with Disabilities; The 
Use of N11 Codes and Other Abbreviated Dialing Arrangements, WC Docket No. 04-36, WT Docket No. 
96-198, CG Docket No. 03-123, CC Docket No. 92-105.
In this Order, we take important steps to implement Congress’ vision that the promise of new 
communications technology should benefit all Americans, including those with disabilities. We advance 
that vision by extending the disability access requirements of the Act to providers of interconnected VoIP 
services and equipment, and by ensuring that interconnected VoIP providers contribute to the interstate 
TRS Fund.  
Through sections 225 and 255 of the Act, Congress codified important principles that have 
ensured access to functionally-equivalent services for persons with disabilities.  I strongly believe that we 
must extend the ADA’s important protections beyond the world of narrowband telephone service, so I am 
pleased to support this item.  
With consumers and businesses increasingly migrating to interconnected VoIP, we must ensure 
that providers of those services and manufacturers of equipment or CPE that is specially designed to 
provide them comply with the requirements of section 255.  Particularly as many consumers forego the
use of their traditional phone service and as VoIP is embraced in the workplace, these new services must 
provide for “reasonably achievable” accessibility.  Millions of Americans with disabilities should not 
have to worry if their phone service will work in the manner in which they have come to expect, such as 
supporting the use of TTYs and shortened dialing codes like 711.  This accessibility is critical in order to 
promote the independence of persons with disabilities, participation in our society, and critical access in 
emergency situations.  
Indeed, Americans with disabilities can benefit from widely-available and accessible 
interconnected VoIP services.  More broadly, IP protocols are increasingly allowing services to combine 
voice, video, and text in ways that will allow persons with disabilities to communicate far more 
effectively.  Applying section 255 to interconnected VoIP services and equipment will help ensure that 
accessibility issues are considered early in the development process, which should lessen the need to 
retrofit regulatory and technical protections after the-fact.  At the same time, there is much work to be 
done to develop specific standards, so I encourage all parties to continue to work toward the common 
goals of accessibility, functional equivalence, and innovation. 
This Order also correctly concludes that providers of interconnected VoIP services should 
contribute to the TRS Fund.  If an interconnected VoIP service provider shares in the benefits of having 
the ability to access and use TRS or Video Relay Service (VRS), which draws more customers to their 
service, they should also share in the burdens by contributing to the fund.  This action provides a broader 
and more sustainable base of contributors to the TRS Fund, but it is worth noting that we have more work 
to do.   Particularly as we come to the close of the current funding year, it is important that we move 
forward with our review of the rate-setting mechanisms and that we work to inject more transparency and 
predictability in that process.  
I want to thank the Chairman and the Bureau for their hard work on this item, and I look forward 
to working with them, my colleagues, and the disability community as we turn to the challenges ahead.