Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
In the Matter of )
) WT Docket No. 07-250
Amendment of the Commission’s Rules )
Governing Hearing Aid-Compatible Mobile ) DA 11-1707
Handsets )
COMMENTS OF
SAMSUNG TELECOMMUNICATIONS AMERICA, LLC
I. INTRODUCTION
Samsung Telecommunications America, LLC (“Samsung”) hereby submits these
comments in support of the Second Further Notice of Proposed Rulemaking (“Notice”) released
in the above-captioned proceeding.
1
In the Notice, the Wireless Telecommunications Bureau
(“WTB”) and Office of Engineering and Technology (“OET”) (collectively the “Bureaus”)
propose to incorporate the most current hearing aid compatibility (“HAC”) technical standard
(the “2011 Standard”) into the Commission’s rules (the “HAC rules”).
2
Samsung supports the Notice’s proposal to incorporate the 2011 Standard into the HAC
rules to replace the earlier, 2007 version of the standard (“2007 Standard”)
3
currently
1
Amendment of the Commission’s Rules Governing Hearing Aid-Compatible Mobile Handsets,
WT Docket No. 07-250, Second Further Notice of Proposed Rulemaking, 26 FCC Rcd 14991
(WTB/OET 2011) (“Notice”). The Wireless Telecommunications Bureau and the Office of
Engineering and Technology are acting pursuant to delegated authority.
2
Accredited Standards Committee C63® – Electromagnetic Compatibility, American National
Standard Methods of Measurement of Compatibility between Wireless Communications Devices
and Hearing Aids, ANSI C63.19-2011 (May 27, 2011) (“2011 Standard”).
3
Accredited Standards Committee C63® – Electromagnetic Compatibility, American National
Standard Methods of Measurement of Compatibility between Wireless Communications Devices
and Hearing Aids, ANSI C63.19-2007 (Jun. 8, 2007) (“2007 Standard”).
2incorporated in the rules, and urges the Commission to do so expeditiously. Samsung has a
longstanding commitment to the goals of the Commission’s HAC rules as applied to mobile
devices. Samsung’s track record of complying with the HAC rules across a wide product line of
mobile devices demonstrates this commitment. In fact, Samsung successfully has achieved HAC
compliance even in devices for which HAC implementation is most challenging: GSM smart
phones with thin form factors such as the Galaxy S II.
Samsung also urges the Commission to grant the pending joint Petition for Partial
Reconsideration (“Petition”) of the 2010 Second Report and Order in this docket,
4
filed by LG,
Motorola, Nokia, Research In Motion, Samsung and Sony Ericsson.
5
In addition, Samsung
encourages the Commission to take expedited action on the issues regarding HAC that remain
open from the related 2010 Further Notice
6
and the 2010 Review PN.
7
II. THE COMMISSION PROMPTLY SHOULD ADOPT THE 2011 STANDARD AS
PROPOSED
Samsung supports the Notice’s proposal to adopt the 2011 Standard into the HAC rules.
Samsung agrees with the tentative conclusion in the Notice that “doing so would serve the public
4
See Amendment of the Commission’s Rules Governing Hearing Aid-Compatible Mobile
Handsets, WT Docket No. 07-250, Policy Statement and Second Report and Order and Further
Notice of Proposed Rulemaking, 25 FCC Rcd 11167 (2010) (“2010 Second Report and Order”
and “2010 Further Notice”).
5
See Petition for Partial Reconsideration of LG, Motorola, Nokia, Research In Motion,
Samsung, and Sony Ericsson, WT Docket No. 07-250 (filed Oct. 8, 2010) (“Petition”). The
Petition demonstrates that the Commission should apply equally to all handset manufacturers the
“power down” rule that allows a manufacturer to enable user-controlled transmit power
reductions of up to 2.5 decibels to demonstrate compliance with the HAC rules for digital mobile
handsets operating on the GSM air interface in the 1900 MHz band. The Petition has not been
addressed, or even placed on public notice, since it was filed over fifteen months ago.
6
See 2010 Further Notice, 25 FCC Rcd 11167 (2010).
7
See Comment Sought on 2010 Review of Hearing Aid Compatibility Regulations, WT Docket
No. 10-254, Public Notice, 25 FCC Rcd 17566 (WTB 2010) (“2010 Review PN”).
3interest by aligning the Commission’s rules with advances in technology and by bringing
additional frequency bands and air interfaces under the [HAC] regime.”
8
The 2011 Standard makes multiple changes to the 2007 Standard that promote the public
interest. These changes benefit consumers by permitting manufacturers to implement HAC
solutions in their mobile handsets more readily. For example:
The 2011 Standard applies broadly to new air interfaces and protocols.
9
Such
broad applicability is increasingly important as new technologies develop because
it provides the means of determining HAC compliance for new technologies.
10
The 2011 Standard uses the Modulation Interference Factor (“MIF”).
11
MIF
directly characterizes the risk of interference between mobile handsets and
hearing aids, and therefore is preferable to the prior approach of applying the
estimated Articulation Weighting Factor (“AWF”) and Probe Modulation Factor
(“PMF”). MIF techniques are technology-agnostic and are more accurate than
AWF/PMF techniques in supporting the evaluation of the risk of interference.
The 2011 Standard applies to a wider range of frequencies (i.e., 698 MHz - 6
GHz) than the 2007 Standard.
12
This wider range of coverage is important to
8
See Notice at 14994 ¶6.
9
See id. at 14992 ¶3.
10
As explained in Section III of these Comments, however, the introduction of new air interfaces
will require the Commission, through OET’s Laboratory Division, to issue guidelines to
Telecommunications Certification Bodies (“TCBs”) for their use when determining HAC ratings
of devices. Because such TCB guidelines are a gating factor for deployment of HAC-compliant
handsets using new air interfaces, the Commission promptly should develop and issue such
guidelines.
11
See id. at 14992–93 ¶ 3; see also 2011 Standard at 12, 13, 14-15, 77-78.
12
See Notice at 14992 ¶ 3; see also 2011 Standard at 13.
4both consumers and manufacturers. The certainty provided by the 2011 Standard
will allow Samsung to provide HAC in 2.5 GHz phones and future phones using
other frequencies.
The 2011 Standard exempts certain low power transmitters from testing. Low
power transmitters pose no significant interference risk. These transmitters are
deemed to have an M4 rating under the 2011 Standard, which is acceptable under
the HAC rules.
13
This exemption, which applies, for example, to Wi-Fi, also
simplifies HAC compliance.
III. SAMSUNG SUPPORTS A ONE-YEAR TRANSITION PERIOD, BUT THE
COMMISSION SHOULD DEVELOP TESTING GUIDELINES PROMPTLY TO
PERMIT NEAR-TERM USE OF THE 2011 STANDARD
Samsung supports the Commission’s proposal to allow a one-year transition period
during which manufacturers can choose either the 2007 Standard or 2011 Standard for HAC
testing of a particular handset.
14
This transition period provides a reasonable period of time for
manufacturers that are not yet ready to move to the new standard to prepare. Because of the
evolutionary, though still significant, differences between the 2011 Standard and the 2007
Standard, a one-year phase-out of testing pursuant to the 2007 Standard is more than adequate.
More importantly, however, the Commission should allow manufacturers that are ready
to move to the new standard to do so without delay. To facilitate the ability of such
manufacturers to commence use of the 2011 Standard prior to the expiration of the transition
period, Samsung urges the Commission promptly to issue guidelines to be used by
Telecommunications Certification Bodies (“TCBs”) to determine HAC ratings of devices under
13
See Notice at 14992–93 ¶3.
14
See id. at 14994–50 ¶7.
5the 2011 Standard. Use of MIF rather than AWF/PMF techniques will require the Commission
to issue guidelines to TCBs for their use. As a result, the availability of TCB guidelines will be a
gating factor with respect to the use of the 2011 Standard by manufacturers.
In addition, during development of the 2011 Standard, incomplete provision was made
for T-rating testing for Voice over Internet Protocol (“VoIP”) carried over new technologies such
as Long Term Evolution (“LTE”) (e.g., Voice over LTE or “VoLTE”), because the technology
was so new. As a result, no test equipment yet supports the T-rating test with respect to VoLTE.
Therefore, the Commission should focus on preparing a guideline for such a T-rating test to
enable the development of appropriate test equipment.
Further, the Commission should allow the use of the 2011 Standard for HAC ratings of
devices that contain new technologies, such as VoLTE and WiMAX, even prior to the
development of T-rating guidelines and test equipment for VoIP carried over these new
technologies. This will prevent the current lack of T-rating testing protocols for these new
technologies from delaying the adoption of HAC compliance under the 2011 Standard by
manufacturers producing devices that use these new technologies. To prevent this from causing
consumer confusion, the Commission should require manufacturers to provide appropriate
disclosures to consumers (similar to the text given by the Commission’s current rules at Section
20.19(f)(2)
15
) regarding the lack of T-rating testing of the new technologies used by these
devices, until such time as T-rating testing for these new technologies becomes feasible.
IV. CONCLUSION
For the reasons set forth above, Samsung supports the Bureaus’ proposal to incorporate
the 2011 Standard into its HAC rules and urges the Commission promptly to establish the TCB
15
See 47 C.F.R. § 20.19(f)(2).
6testing guidelines that will be required to fully implement this proposed revision to the HAC
rules.
Respectfully submitted,
SAMSUNG TELECOMMUNICATIONS AMERICA, LLC
By: /s/ Cindi Moreland
Cindi Moreland
Vice President and General Counsel
1301 E. Lookout Dr.
Richardson, TX 75082
(972) 761-7000
John Godfrey
Vice President,
Government & Public Affairs
Samsung Information Systems America, Inc.
1200 New Hampshire Avenue, N.W.
Washington, DC 20036
(202) 887-5667
January 13, 2012