In Comments filed January 2016 in response to the Federal Communications Commission (FCC) Notice of Proposed Rulemaking (NPRM) regarding Hearing Aid Compatible (HAC) wireless phones, Hearing Loss Association of America (HLAA), TDI, National Association of the Deaf (NAD), and the Deaf/Hard of Hearing Technology Rehabilitation Engineering Research Center (DHH Tech RERC) urged the FCC to adopt the consensus agreement drafted by Consumer Groups and the wireless industry. Adopting that agreement would mean the FCC would set new benchmarks that would result in 66 percent of all wireless phones becoming HAC in two years, 85 percent in five years and that the Commission will consider 100 percent HAC achievability in eight years. Adopting the Proposal will increase the number and percentage of HAC phones available to people with hearing loss, and may ensure that all devices are HAC in the future. Such a result is clearly in the public interest.
In their Comments in the same NPRM, Apple, Inc. requested that the FCC rule that its proprietary technology is an acceptable alternative to the FCC’s existing HAC requirements.
In our Reply Comments filed February 12, 2016, in response to Apple’s Comments, HLAA, Consumer Groups and the DHH Tech RERC said:
From a consumer perspective, the issue of proprietary solutions poses very real and basic accessibility and usability concerns. Proprietary solutions are typically encumbered by patents, subject to vendor lock-in and prevent interoperability between software and hardware from different vendors. Acoustic coupling and inductive coupling via telecoils between wireless devices and hearing devices provide universal access and interoperability. Telecoils have become a boon to consumers precisely because they are an open solution for connecting to any phone while at the same time providing vastly more functionality to hearing aids by also connecting to wide area listening systems. A proprietary system that excludes telecoils is accessible and usable only if the consumer uses that one brand of phone that they are locked into. Consumers are literally left out of the loop if they wish to change to a different phone or hearing aid or if the proprietary phone/hearing aid system is broken, lost, or unavailable and they must resort to connecting via someone else’s phone