The Wireless RERC, in collaboration with Georgia Tech’s Center for Advanced Communications Policy (CACP) filed comments before the FCC in response to the Notice of Proposed Rulemaking (NPRM) In the Matter of Access to Telecommunications Equipment and Services by Persons with Disabilities [CG Docket No. 12-32]; Petition for Rulemaking Filed by the Telecommunication Industry Association Regarding Hearing Aid Compatibility Volume Control Requirements [CG Docket No. 13-46]; Amendment of the Commission’s Rules Governing Hearing Aid-Compatible Mobile Handsets [WT Docket No. 07-250]; Comment Sought on 2010 Review of Hearing Aid Compatibility Regulations[WT Docket No. 10-254]. The comments, in large part, were informed by analyses of data collected via the Wireless RERC’s hearing aid compatibility (HAC) survey research. The 2014 HAC survey was designed to gather data from people who use hearing aids and cochlear implants on how well their hearing technology works with their wireless handsets. Answers to the survey questions have provided insight into the effectiveness of hearing aid compatibility requirements in the United States, as well as the need for any amendments to the rules.
The Wireless RERC’s comments supported the incorporation of the proposed 2012 ANSI Wireline Volume Control Standard, and further recommended extending any technology requirements for wireline phones to Voice over Internet Protocol (VoIP) phones, as well. Regarding applying the volume control standard to wireless devices, the comments took a more modified approach. While the Wireless RERC generally agrees with the FCC’s belief “that standards and requirements for manufacturers and service providers are needed for volume control in wireless handsets as well” and respondents to the Wireless RERC’s 2014 HAC Survey indicated that volume control impacted the usability of their wireless handset; ultimately the Wireless RERC supported further investigation of whether it is necessary to incorporate a volume control standard for wireless handsets, recognizing that this might take longer than voluntary compliance via industry driven solutions. Given the complexity of interactions between increasingly sophisticated and powerful wireless handsets, telecom delivery services (i.e. VoIP), hearing aids and the variability of hearing loss amongst the users, the difficulty of crafting regulations that improves access for end-users is not overlooked by the Wireless RERC/CACP. Nevertheless, people with hearing loss deserve and are entitled to parity of access to telecommunications services, wireless, or otherwise.
 1996 HAC R&O, 11 FCC Rcd at 8282 ¶ 78.