EX PARTE OR LATE cII... ED
HOFSTRA, H"
t" N I VE R S "1\
., I
RECEIVED
The Hon. Reed Hundt
Chairman
Federal Communications Commiss on
1919 H street NW
Washington, DC 20SS4
Dear Chairman Hundt"
:JAN 12 1995
November 29, 1994
I have just become aware of the Federal Communications Commission
proceeding to expand proposed rules for location and monitoring
services (LMS). I am writing to make sure that the FCC is aware
of the potential negative effects that these rules may have on
consumers with disabilities. LMS services would have a higher
priority in the 902-928 Mhz spectrum range than Part 15
unlicensed devices, and would potentially interfere with new
technology that would benefit people with disabilities.
A simple example is the cordless telephone which is a convenience
for people who are~able-bodied".For many people with mobility
limitations, they have become a necessity -- because they cannot
quickly run to a ringing telephone. Some friends of mine keep a
cordless phone on their Wheelchairs, making it both convenient
and easy to answer a ringing phone. The next generation of these
cordless telephones that are digital will most probably operate
in the 902-928 Mhz spectrum. Hence my concern over interference
from LMS with future technoloqies of vital importance to
Americans wit.h d. sat)] Ii i ties.
Digital cordless telephones and other new digitized devices will
take on increasing importance for Americans with disabilities in
the years to come Cordless telephones of the future may have
two-way interactive video screens so that a deaf person could use
sign language to communicate over the phone, or the phone may
have a text print-out. For people with speech limitations,
digitized phones may offer synthesized speech, giving them a
clearly understandable "voice". To the extent that the new
location and monitorIng services are allowed to operate in this
spectrum and create Interference w th these Part 15 devices,
much-needed ass i st i ve techno1oCfv rn'oc.Iucts may be rendered
inoperable or even useless.
Were the Commission to decide to expand the use of this spectrum
by LMS, it would discourage development of newer such devices and
services, further harming Americans with disabilities. I believe
this to be a key-onsideration~nFCC decision according
No. ot Copies rec'd.. -1IQ.
List A8CDE- U---
The Hon. Reed Hundt, 11/29/94, P. 2
automatic vehicle monitoring (AVM) and/or LMS services greater
use of the 902-928 Mhz spectrum would signal to the market that
new digitized products and services would become increasingly
unreliable, due to growing interference. Such a decision by the
FCC would dampen investment in new and innovative wireless
technologies.
My long-standing involvement in pUblic policy issues connected
with disability and technology makes me sensitive to these
issues. Since 1976, I have worked closely with the US Congress
Office of Technology Assessment, the US House of Representatives
Committee on Science and Technology, and other legislative
bodies, as well as the executive branch (National Institutes of
Health, National Science Foundation, National Institute on
Disability and Rehabilitation Research, and Architectural and
Transportation Barriers Compliance Board, for which I was
director of research 1984-1987). I am author of Personal
Computers and Special Needs (Sybex Computer Books, 1984) and
numerous other books and articles on technology as it affects
people with disabilities and senior citizens.
This work makes me acutely aware of the potentially far-reaching
effects of the decisions the FCC soon will make on Part 15. It
also sensitizes me to the necessity for intelligent compromise.
I would hope that the FCC would balance the need to maintain the
integrity of unlicensed spectrum -- so that current products will
work without interference and so that industry will continue to
research future devices -- while at the same time supporting AVM
and LMS services. One such compromise might be encourage
developing AVM and LMS services to find creative ways to avoid
interference with unlicensed wireless devices.
I would ask that the FCC, in its
and any other consumer concerns.